Progress and Problems in Programs for Managing High-Level Radioactive Wastes

Published by the Government Accountability Office on 1971-01-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)



         Progress And Problems
         In Programs For Managing’”
         High-Level Radioactive Wastes”l-164052
         Atomic Energy CornmissIon “,&


                                 COMf=TROLLE*R     GEZNbRAL   OF     THE      UNITED   STATES
                                                 WASHINGTON     DC         20548


                  Dear    Mr   Chairman*

                           This IS our report       on progress        and problems   m pro-
                  grams     for managmg      high-level      radloactlve      wastes by the
                  Atomic     Energy   Commlsslon.         The reylew        was made   In ac-
                  cordance     with requests      made on October          24 and Decem-
                  ber 15, 1969

                         Copies  of this report  are bemg    sent today to the
                  Vice Chalrman      of your Commlttee    and to the Atomic
                  Energy   Commlsslon.

                         We believe    that      the contents          of this report           would
                  be of interest   to other        committees           and members             of Con-

         DIGEST                                                                                           1
           1       INTRODUCTION                                                                           6

           2      INTERIM AND LONG-TERM
                                            OF AEC'S HIGH-
                  LEVEL RADIOACTIVEWASTES                                                                 15
APPENDIX                                                      Page

 III       Prlnclpal  management offxrals     of the Atomic
              Energy Commlsslon responsible    for admlnls-
              tratlon of actlvltxes  dlscussed In this
              report                                          105


AEC        Atomic    Energy Commlsslon

GAO        General   Accounting   Office
                        TO                              PROGRESSAND PROBLEMSIN
                 ONATOMICENERGY                         PROGRAMSFOR MANAGING  HIGH-
       OF THEUNITEDSTATES                               LEVEL RADIOACTIVE WASTES
                                                        Atomic Energy Commission


      The General Accounting Office (GAO) reviewed the po11c1es and procedures
      of the Atomic Energy Commission (AEC) for the management of radloactlve
      wastes, to determine the actions taken on the matters discussed In GAO's
      previous report dated May 29, 1968, on this subJect.

      This review, like Its predecessor, was made at the request of the Joint
      Committee on Atomic Energy, Congress of the United States.

      A subJect of widespread concern and Interest,  AEC's radioactive waste
      management programs are designed to protect the public, private and pub-
      11c  property, and the general environment from the hazards of excessive
      radiation   from radioactive wastes

      ~ropess made
      AEC has made progress In carrying out Its programs for the effective
      management of radioactive   waste materials which must be contained ana
      Isolated from that    art of the earth and Its atmosphere where life ex-
      ists ('the biosphere P

      Since the issuance of GAO's prior       report,   AEC has

           --Taken further steps to Improve policies   and practices   at its opera-
              tional sites for the safe storage of high-level   radloactlve   wastes.
              (See p 15 )
           --Made progress toward developing and Implementing long-term-storage
             methods for radioactive    wastes being retained on an interim basis
              In tank storage as llqulds   and as wet solids   (See p. 33 >

           --Initiated   an evaluation of the adequacy of the policies and prac-
             tices followed at operatlonal   sites in the ground burial of radlo-
             active solid wastes.     (See p 48 )

           --Taken steps to develop and Implement plans for long-term      storage
              of plutonium-contaminated wastes   (See p 49 )

  --EstablIshed    (May 1970) a Dlvlslon of Waste and Scrap Management
     which will (1) review and approve or disapprove AEC Installation
     waste management plans, (2) coordinate management of storage and
     ground burial of contaminated sol id wastes, and (3) manage opera-
     tions of Federal reposltorles     for disposal of solldifled and solid
     wastes     (See P 9 )
  --Announced (June 1970) the selectlon of a site and plans for the
     development of an ln7tlal   Federal repository  for the demonstration
     of long-term storage In salt mines of high-level     radloactlve  solidi-
     fled wastes and plutonium-contaminated    solId wastes.    (See p, 61 )

  --Published     (November 1970) an amendment to its     llcenslng   regulations
     to establish    criteria on siting of commercial    fuel-reprocessing
     plants, interim storage of radloactlve    wastes     generated at such
     plants, and long-term storage of such wastes       in Federal reposlto-
     ries.    (See p. 64 )

AEC 1s faced w7th complex technical       problems associated with the man-
agement of large quantities     of high-level    radioactIve wastes generated
at its various installations       The bulk of such wastes was generated at
the chemical-reprocessing    plants prior to the development of the tech-
nology now available    for handling these wastes

Although considerable progress has been made by AEC, as stated above,
problems remain to be resolved and delays are being experienced in
Implement7ng certain policies  and practices.

GAO has noted that,

  --Implementation   of some programs to provide for lnterlm or long-term
     storage of radloactlve  solidlfled wastes held in underground tanks
     has been delayed because of operational   and technical dlfflcultles.
     (See p 15 )

  --As the waste storage tanks and engIneered systems Increase in age
     and are utlllzed  more because of the accumulation of new wastes,
     there 1s an increased possl6lllty  of tank incidents occurring until
     all liquids are removed from the older tanks      (See p. 33 )

  --The proposal for long-term storage in bedrock caverns of wastes
     which are now retained in underground tanks at the Savannah River
     Plant requires further evaluation by underground exploration before
     it can be approved    (See p 33 1 4\

  --Considerably   more time 1s believed necessary before a determlnatlon
     can be made as to whether the interim-storage   method being employed
     at Rlchland for certain wastes (solids in exlstlng   tanks) will be
     acceptable for long-term storage     (See p 33 )SJC
  --AEC's goal for long-term storage of plutontum-contaminated          solld
    wastes ~111 be more difficult      to achjeve If it becomes necessary
     to retrieve  and transfer slgnlflcant     quantltles   of waste burled
     prior to April 30, 1970, since provision for retrieval         was not a
     primary consideration    at the time of burial       (See p. 47 )

ComnerczaZZy generated wastes

In addition to managing its own waste, AEC IS responsTble for regulating
practices of commercial firms and for ensuring safe, long-term storage
of the large volumes of radioactlve     wastes that have been and will be
generated by licensed fuel-reprocessing      plants

With advances in technology, AEC has developed--and must continue to
develop--regulations,  in advance, so that the problems to be encoun-
tered by the emerging commercial fuel-reprocessing   industry can be re-
solved on a reasonably timely basis.

Although AEC has assigned a high priority      to radloactlve-waste   manage-
ment programs, GAO believes that the level of effort given to these
programs should be increased in view of their extraordlnarlly        complex
charactenstlcs       The problems and delays being experienced are attnb-
utable primarily   to a need for more deflnltlve      technology on such mat-
ters as the relative    merits of alternative    practices and proposals for
interim and long-term storage.

AEC's decision in June 1970 to develop salt mines for potential       use
as a Federal repository       and its announcement in November1970 of waste
management regulations      for private industry are maJor milestones     If
the development of the Federal repository       proceeds on schedule and
proves successful,     private operators should be able to avoid the waste
management problems of the type experienced in the past by AEC when the
lack of technology resulted In the accumulation of large volumes of
high-level   radioactive    liquid wastes.

GAO believes that, to provide greater assurance that appropriate prion-
ties are asslgned to the overall waste management program, AEC should
further develop and consolidate    its plans for resolving waste manage-
ment problems into an overall coordinated plan       Such a plan should
provide the following  information    for each type of radloactlve waste
generated by both AECand private andustry at the various locations      ln-

  --The current status of the waste management program, both interim
     and long-term proJects
      --The specific   actions necessary to resolve         exlstlng   problems and
         achieve acceptable waste-storage goals

      --The time frames over whTch these actlons           can be carried       out

      --The estimated    costs Involved,     by fiscal    year,   In carrying     out these

    The Dlvlsion of Waste and Scrap Management should give its immediate
    attention    to consolldatlng    and lmplementlng the overall radioactlve
    waste management plan described above. GAO believes that, when such a
    plan has been established,       this Division should be assigned responslbll-
    lty (1) for recommending prlorlties           for waste storage methods and for
    coordinating    the conduct of research and development of waste storage
    methods to meet these prlorltles,           (2) for recommending long-term storage
    methods, (3) for establishing        criteria    for interim storage, (4) for re-
    viewing and evaluating       the progress made Sy the program divlslons,          and
    (5) for coordinating      matters affecting       both AEC and private Industry
    waste management practices with AEC program and regulatory             dlvlslons.

    AEC offlclals     Informed GAO that the Dlvislon of Waste and Scrap               Man-
    agement had been assigned the responsibility      for developing and              ample-
    mentlng a plan for the storage of high-level       radioactive   wastes           from
    licensed facilltles      in the proposed Federal repository    in Lyons,            Kansas,
    and for managlng AEC's alpha, or plutonium-contaminated,         wastes              The
    Dlvlslon also has been directed to coordinate the consolldatlon                   of an
    overall AEC plan for radioactive      waste management

   The plan, which ~111 be largely a consolidation      of plans developed
   or being developed by various AEC div1slons,    offices3 and contractors,
   1s expected to be completed early In fiscal year 1972        It IS to be
   updated as required to reflect   maJor needs and developments in waste
   management activities.   AEC stated that the Division of Waste and Scrap
   Management had been or would be given the other responslbIlltles       cited
   in GAO's recommendation.

   The Dlvtslon of Waste and Scrap Management currently     has responslblllty
   for reviewing and approving or disapproving,    In consultation  with cog-
   nizant program and staff dlv1slons,   waste management plans of AEC in-
   stallations    This responslbillty  carries with it the responslblllty
   for monitoring progress toward achieving overall AEC plans and ObJectives.
   (See p 70 >

   Under present    organlzatlonal arrangements,         AEC's Dlvlslon of Production
   ~111 continue    to have primary responslblllty         for the management of

high-level radloactlve wastes from AEC fuel-reprocessing   installations,
1ncl udlng responsebll lty for research and development of long-term-
storage methods for such wastes.

GAO was advised that the Bivislon of Production’s actlvltles       would
be conducted in accordance with the approved overall waste management
plan and that its efforts to develop or improve storage methods would
be coordinated with those of the Dlvlslon of Waste and Scrap Manage-
ment. Various budget and organizat?onal   alternatlves     within AEC also
are being considered with the ObJective of ensuring that the approved
overall waste management plan will be effectively     implemented.



        In accordance with requests made on October 24 and
 December 15,1969, by the Joint Committee on Atomxc Energy,
 Congress of the United States (see apps. I and II>, the
 General Accounting Office has made a review of the Atomic
 Energy Commlssionqs management of high-level          radioactive
waste materials.        The objectives   of our review were to de-
 termine AEC actions      taken after our prior report to the
 Joint Committee on observations       concerning the management of
high-level    radioactive     waste material   (B-164052, P&jL9,
_1968), .

        Our review was directed      primarily  toward evaluating
certain    aspects of ARC's waste management programs at four
ARC field     offices.    We visited    two commercial plants'    one
is generating       and one will generate radioactive     waste.   The
scope of our review is described          in chapter 6.

      The purpose of ARC's waste management policxes               and pro-
cedures IS to ensure that waste management activities                are
conducted in such a manner as to protect

      --the health and safetyof           ARC and ARC-contractor     em-
         ployees and the general          public,

      --the   quality   of the environment,        and

      --private    and public     property.

       The potential       hazards to mankind from radioactive
wastes stem from the basic characteristics            of the wastes'
radloisotopic        contaminants.     Allowing these radioisotopes
to decay naturally         is the only practicable    means of reducing
their    radioactivity       to nonhazardous levels.    Although many
radioisotopes        decay rapidly,    some decay at such a slow rate
that they could represent           a potential hazard to mankind for

     The isotopes   in the waste that are of greatest   concern
to health and safety are generally    those which are highly

toxic and/or have long half-lives,       such as strontium,     ce-
sium, and plutonium.     AEC's radioactive     waste storage tanks
contain strontium-90   and cesium-137,     which require hundreds
of years to decay before they no longer pose a health hazard,
and plutonium-239,   which requires    approximately    500,000
years to decay to an innocuous level.

       The plutonium-239       contained in AEC's solid and liquid
wastes is in such low concentrations               as to be considered
uneconomical to recover.          According to AEC, it would be im-
practicable    to remove enough of the plutonium from the
wastes to have any relative           significance     with regard to the
need to isolate      the plutonium-containing          wastes from the
biosphere.     AEC advised us that plutonium buried in the
ground has little       mobility,     since it is relatively         insol-
uble rn water.       Even if discarded in solutions,            plutonium
is generally     held in the soil close to the point of re-
lease for as long as the soil itself               remains in place.        The
potential    danger would be from ingestion             or inhalation      of
the contaminated       soil or dust.

      Radioactive    wastes vary widely in the concentration        of
radioactive    materials   and radioisotopes.       Such wastes may
be divided into three categories,         as follows:

      1. Low-level   wastes have a radioactive       content suffi-
         ciently   low to permit discharge      into the environ-
         ment after reasonable dilution       or after relatively
         simple processing.      These wastes have no more than
         about 1,000 times the radioactivity         concentrations
         considered   safe for direct    release.     In llquld
         form, low-level    wastes contain less than a micro-
         curie1 of radioactivity      per gallon.

      2. Intermediate-level      wastes have too high a radroac-
         tivity    concentration   to permit release after  simple
         dilution,    yet they are produced in relatively     large

1A microcurle  is one millionth of a curie.   A curie 1s a
 measure of the number of atoms undergoing radioactive       dis-
 . .
 integration  per unit time and is 37 billion  disintegrations
 per second or the rate of decay of one gram of natural
           volumes.     The radioactivity    of these wastes is up
           to 1,000 times higher than that of low-level           wastes,
           and, inallquid       form, they may contain up to a curie
           of radioactivity       per gallon   Intermediate-level
           wastes are disposed of through treatment,           such as
           filtration     or ion exchange, or are buried in the
       3. High-level      liquid   wastes cannot be released into the
          environment       because of their high radioactivity   con-
          centration       (as much as 10,000 curies per gallon).
       Delineation    of the categorzes        is dependent on operat-
ing parameters at each site location,              and therefore   the
categories     are not uniformly      defined.      For waste management
purposes, AEX considers         two levels of radioactive        wastes'
that which must be contained          (high-level     wastes) and that
which can be discharged,         without hazard to the biosphere
and man, after reasonable dilution             or after relatively     slm-
pie processing     (low-level     wastes)        The matters discussed
in this report pertain        to those wastes considered by AEC to
require    some form of containment.

        To confine and isolate         high-level    liquid wastes from
biological     life,    AEC has stored them underground in large
steel-lined,       concrete tanks and in steef tanks within             con-
crete vaults.        Thestorage      of these liquid     wastes in tanks
requires     continual     surveillance      and can be considered only
an interim     solution,     as the release of contaminants          into
the immediate surroundings            can be avoided only so long as
the tanks and their         safety backup systems retain        their     in-

         To provide protection          against the possibility       of inad-
vertent     release of radioactivity           into the environment       in the
event of a failure         in tank integrity,          AEC operations    offices
have been continuing          their efforts       to reduce the mobility
of the wastes by improved methods for safe interim                    storage
and eventual       long-term      storage of radioactive        wastes gener-
ated, or to be generated,             at AEX operational       sites and at
private     industrial     sites.       For example, AEC is working to-
ward limiting        the liquid wastes held in tanks to in-process
wastes-- those wastes which are aging to the extent that
they will become suitable             for the next step in their process-
ing to reduce the mobility              of radioactive     material   by crys-
tallization      or conversion        into solids.
       RadioactIve       wastes contarning    numerous radiolsotope
products have been generated in processing              lrradlated     nu-
clear fuels at the chemical-processing             plants bperated by
AXE's Richland,         Savannah River, and Idaho Operations         Of-
flees as well as at the commercial plant of Nuclear Fuel
Services,    Incorporated,        located in West Valley,       New York.
The Oak Ridge National           Laboratory  has generated high-level
liquid wastes at its radlochemlcal-processing                pilot  plant
and is currently         generating    such wastes at its transuranium-
processing     faclllty        Solid wastes which contain radioactive
materials    are also generated at these lnstallatlons.

         The lrradlated    fuels processed at the three AEC
chemical-processing        plants generally     have been uranium fuels
from MC's plutonium production,           test,     and military  reac-
tors.      Fuels from nuclear-powered       electric    plants using
light-water       reactors   are processed inaeommerclally        operated

       Additional       commercial fuel-reprocessing            plants are
being, or ~111 be, constructed             to meet the reqrurements           for
processing      increasing    amounts of irradiated           fuels which ~111
be generated at nuclear-powered              electric     plants.     ARC's
projected     fuel-reprocessing        requirements       for the civilian
nuclear power industry          indicate     that approxlmatelt        three to
SIX commercial fuel-reprocessing               plants will be required         by
1985 and that an estimated            60 milllon      gallons of high-level
radioactive      liquid    wastes, or about one tenth that quantity
of solidified       residues from processing           the liquid     wastes,
will have been accumulated by the year 2000.

       In addition     to the speclflc   responslbllitles       of the
ARC operations     offices    for managing radloactive       wastes gen-
eratedatthelr      respective     sites, several of ARC's organlza-
tlonal    units have responslbillties       relating     to various   as-
pects of waste management

       The Dlvlsaon of Waste and Scrap Management, which was
established    in May 1970, has overall responsibility for

      --overseeing      the waste management activities            at all    ARC
         operatlonal      sites,

        --coordinating       the operational direction           for   storage
           and burial      of MC's solid wastes,

        --managing       the operation        of Federal   waste repositories,

        --developing       AEC-wide plans for management of scrap
           containing      special nuclear material.

       The Division    of Production   develops and directs       pro-
grams for producing and processing          feed, special nuclear,
and other special materials        and for associated      process de-
velopment.     In con-Junction with this function,         the Division
of Production     coordinates   and directs     programs for high-
level waste management and for long-term            storage of radio-
active waste from the Division's         chemical-processing      opera-

       The Division  of Reactor Development and Technology de-
velops and directs     assigned reactor development and tech-
nology programs.     The Division     directs  also a research and
development program on processes for the treatment             and
storage of high-level     radioactive     waste resulting,     or ex-
pected to result,    from chemical-processing       operations     in
connectlon   wrth the nuclear power industry.

       Other AEC program divisions,   including   the Division   of
Research, Division    of Isotopes Development, and Division      of
Biology and Medicine,    because of the nature of their pro-
grams y also generate some quantities     of radioactive   wastes
which must be contained

         The Division   of Materials        Licensing   is responsible       for
licensing      private  facilities       for reprocessing      irradiated
source and special nuclear material               and therefore      is con-
cerned with the safety of radioactive-waste                 management ac-
tivities     at such facilities.           Since AEC installations        are
not subject to licensing           by this Division,      it is not re-
sponsible for evaluating           the management of AEC's radloactlve
waste.      This responsibility        was previously     assigned to the
Division     of Operational       Safety, but in June 1970 it was as-
signed to the new Division           of Waste and Scrap Management.

      For fiscal year 1970, AEC was authorized  $2 3 billion
for its various programs.   Of this amount, about $28 mil-
lion represented  operating and capital  funds authorized    for
its waste management programs

      The principal  management officials     of AEC responsible
for administration   of activities   discussed in this report
are listed   in appendix III.

     The illustrations   on the following  three pages, which
were provided to us by AEX, show the three AEC installations
at which irradiated-fuel   elements are processed.


                            CHEMICAL    PROCESSING    PLANT
                            AND STORAGE     TANK   FARM  AREA

          BURIAL   GROUND


13   /
    IF                  I                                    I

     100’S   PRODUCTION                   REACTORS
     200’S   CHEMICAL            PROCESSING                 PLANTS
                 AND        TANK     FARMS
     300’S   FUEL       FABRICATION                  AREA
.    400’S   HEAVY          WATER           FACILITIES
     700’S   RESEARCH               AND      DEVELOPMENT
                                CHAPTER 2



       AM: has made progress toward the development of poli-              \
ties and practices      for effectively      managing interim   storage i
of high-level    radioactlve      waste materials    and for their
eventual long-term      storage.     Since our prior report in May
1968, AZC has endeavored to improve the interim-storage              sit-
uation by constructing       improved storage tanks, reducing the
quantity   of liquid    wastes stored in tanks, and proceeding
with the solidification        of the tank-stored     liquid  wastes at
two of its operat+onal       sites.     Also AEC has continued its
research and development efforts           to provide safe long-term-
storage methods.

      Interim,    or short-term,    storage is considered       by AEC to
be the containment       and storage of radioactive      wastes safely
for tens of years pending decisions          on long-term    storage
methods.     Long-term storage 1s considered        to be the contain-,
ment and storage of radioactive         wastes during the hundreds
or thousands of years that this material           will be biologi-
cally hazardous.       In-process   wastes are those radioactive
wastes which are temporarily        aging for a number of years to
permit the decay of their radioactivity           to the extent that
the wastes will become suitable         for the next step in their
processing     to a solid form.

        Richland has been proceeding with in-tank            solidifica-
tion of low-heat liquid        wastes and with removal of the long-
lived heat generators --strontium-90            and cesrum-137--from
high-heat     liquid  wastes.     Removing the cesium and strontium
enables the remaining high-heat          liqstld wastes to decay to
low-heat liquid      wastes within    about 5 years.       Richland 1s
developing a process and plans to construct              a facility      for
solidifying      and encapsulating    the liquid     cesium and stron-
tium concentrates.

      The solidification   of the low-heat   liquid wastes into
salt cakes in the tanks is considered      to be an interim-
storage process until    AEC makes a determination    as to the

acceptability      of in-tank  solidification       as a long-term  stor-
age method.      Also a long-term-storage        location   has not been
selected for     the encapsulated      strontium    and cesium.

        Idaho 1s keeping current with its generation           of liquid
wastes by converting         the wastes, after they have cooled suf-
ficiently,     to a granular     solid calcine.     The calcine is be-
ing stored an stainless-steel          bins in underground concrete
vaults     as an interim-storage      process.    AEC is planning that
these wastes eventually         will be transferred     for long-term
storage in a Federal repository.

      AEC still    has not done sufficient      exploratory   work on
the use of bedrock caverns at Savannah River to determine
whether this concept would be acceptable          for long-term     stor-
age of the Savannah River wastes.          In the meantime, these
wastes are being segregated on the basis of their heat-
generation    rates and are being immobilized        by evaporation     to
salt crystals     and sludges in the tanks to the extent allowed
by their heat-dissipation     capability.

       The concept of using salt mines m bedded salt deposits
for long-term      storage of radioactive       wastes has been ap-
proved, in principle,       by AEC. AEC has selected a location
near Lyons for further        preparatory     work and plans to seek
pzoJect auth orization      in fiscal     year 1972. AEC contemplates
making the Lyons mine the initial           Federal repository  for
high-level    solidified    wastes from commercial fuel-
reprocessing    facilities.

        AEC informed us that the Lyons location            probably could
be used for long-term       storage of AEC's high-level           radioac-
 tive wastes; however, because of the estimated high cost
 (preliminary    estimates   are in the range of $1.5 to 2 bil-
lion) of processing,       packaging,    and shipping the wastes from
Richland and Savannah River to Lyons, efforts               are under way
to determine whether suitable         long-term-storage        locations
and methods can be developed at the two AEC sites.                   AEC be-
lieves that the cost of exploring          and developing a long-
term-storage     method at these sites is justified,             because of
the potential     expense of shipping the large quantities               of
waste at these sites to another location.              AEC advised us
that it probably would not be economically             attractive      for a
commercial plant to make similar          studies for its own loca-
       The following      table summarizes the individual     AEC pro-
duction sites'      interim-storage     methods; the proposed long-
term-storage     plans and their present status;       and the pos-
sible alternative       long-term   solution,   if deemed necessary.

                                  Tme of storage                       Long-term   storage
                         Decades               Centuries                           Alternative
      Site              (interim)            (long term)       Status               solution
Rlchland (note a>    In tank              Intank             Under way        Basalt
   (see p 341        Strontrum-cesium     Strontium-cesium                    Ship to reposi-
                       capsules              capsules        Budgeted           tories (note b)
Idaho (note a>       Calcrne In bins      Ship to reposl-
   (see p 44)                                torle5          Planned
Savannah Rrver
   (note a>          Evaporated                              Ready for         Ship to reposi-
   (see p 41)          crystals           Bedrock              next step         tories (note b>
aStorage of in-process lewd     wastes will always be necessary, as long as fuel-processing
  continues    Rewres high-integrity   system of storage
 AEC has indicated that the wastes can always be shipped, the approach has been to ex-
  haust the posslblllty of long-term onsite storage before movrng thousands of tons of
  contarmnated wastes

      After our prior review, AEC reemphasized the priority
of radioactive    waste management activities.         In May 1968
the AEC General Manager established         a task force,     composed
of assistant    general managers, to make a review of the ade-
~uacy of policies     and organizations     regarding    waste manage-
ment activities    at AEC installations.        The task force re-
view gave priorrty     consideration     to Richland,    Savannah
River, and Idaho waste management activities.

       In its report dated August 8, 1968, the task force
recommended that planning,         programming,     and operating   re-
sponsibilities      of program divxsions        remain as they were but
that staff     responsibilities      be clarified     to provide that the
Drvision     of Operational     Safety:

        --Within   the framework of AEC-approved polxies,     prin-
           ciples,   and plans, develop, recommend, and promul-
           gate policies,    standards, and criteria for waste
          management activities.

         --Exercise    overall cognizance,   evaluation,  and ap-
            praisal   of waste management activities,    specifically
            including   the degree of progress in meeting obJec-
            tives and schedules,    to ensure compliance with AEC
            policies    and approved       waste management plans           for   each
            AEC installation.

         --Serve as a focal point              for external relationships          in
            the area of radioactive             waste management

         Regarding    liquid    wastes     the task     force   recommended

         All liquid   radioactive     wastes not suitable      for routine
         release be suitably       contained with adequate provision
         for control    or recovery in the event of leaks or accr-
         dental spillage.       Storage of such wastes as liquid            in
         storage tanks not be regarded either         as disposal        or as
         an acceptable    practice    for long-term   handling;       rather,
         waste management programs provide for either              (1) reduc-
         tion of such wastes to solid form for long-term                storage
         or (2) transfer     of such wastes to long-term         storage in
         deep underground locations.          Either approach provide
         high assurance of isolation        of wastes from the bio-
         sphere and of resistance        to credible  internal      or exter-
         nal forces.

The task force set a general target date of December 31,
1975, for achieving     its recommendations.  As a result of the
task force report,    each AEC installation  was required to
prepare and maintain plans for management of its radioactive
wastes,   These plans were to include the AEC operational
sites'  spare-tank  criteria,

        At the time of our prior review, we found that,                      for the
 tank-stored     wastes, AEC had no overall            criterion       for deter-
mining the minimum reserve storage capacity,                     or spare tank-
age 3   to  be  maintained     at  all    times  for   emergency       situations.
Subsequently,        the Division      of Production      instructed       the Sa-
vannah River, Richland,           and Idaho Operations           Offices to sub-
mit their minimum-reserve           criteria     and spare-tank         philoso-
PhY*      These  criteria,    which     differed    with    the   conditions       and
resources      available   at each site, were reviewed by AEC for
safety and sufficiency.

      Although these operations   offices'     criteria               were con-
sidered by AEC to provide sufficient       protection,                the Divi-
slon of Production  has considered the possibility                      of a

uniform spare-tank        criteria     and has developed for its own
guidance informal        criteria     which provide that,      as a minimum,
at least one spare tank be maintained               in each integrated
tank-farm    complex.       Although these criteria        currently    could
not be met by all ARC production             sites,   the Division's
planning and budgeting actions were directed                to attaining
the capability     to meet these criteria           at all sites by about
1973.    The flexibility          then would exist to implement uni-
form criteria.

       AEC advised us that, because nearly all the tank-
stored high-level     radioactive      wastes were at the production
sites,   the Division    of Production's       criteria,   if formalized,
would be essentially       agencywide; however, the specific            Am-
plementation    of the criteria      at each site would be dependent
on the availability      of the necessary facilities.           In the
meantime, AEC and its production           sites are reviewing       current
waste-tank-farm     operating    practices     and spare-tank    criteria
to determine whether further         improvements may be desirable.

        We found that in some cases Richland,       Savannah River,
Idaho, and Oak Ridge did not have at least one spare tank
for each integrated       tank-farm    complex as contemplated      by the
Division     of Production's     informal  criteria for reserve tank
storage.       Storage space, however, was available        at the oper-
ational    sites in tanks that were partially       filled.      Also we
were informed by AEC that proJects under way or proposed
would enable Richland and Savannah River to meet the crite-

      AEC has also been upgrading the quality    of its tanks.
According to AEC, the use of improved storage tanks, along
with waste concentration    and volume reduction  proJects,  will
enable the operational   sites to place less dependence on the
need for spare tanks.

       Richland's    and Savannah River's      waste management plans
did not include sufficient       descriptions      of the engineered
systems in use or planned to permit AEC headquarters             divi-
sions to evaluate the adequacy of systems designed to mini-
mize the possibility      of radioactive      wastes escaping into the
environment     through tank leakage or loss of control.

       The Division  of Production's   objectives   and plans for
high-level   waste management at Richland,      Savannah River,
and Idaho are illustrated     on the following    page.  In es-
sence they are:

      1. Improved high-level    waste-storage conditions            for
         the interim   period,  pending the development            and ap-
         proval of safe long-range-storage    locations            and
         systems.    The improved conditions  include:

          a. Immobilization  of the stored liquid  wastes (ex-
             cept for the in-process   wastes) to a retrievable

          b. Upgrading the quality    of the tanks and ancil-
             laries  used for in-process     storage of liquid
             wastes, incorporating    suitable    spare tankage.

      2. Development of a location   and method which will be
         safe and acceptable  for long-term   storage of the
         wastes onsite.

ARC anticipates       that objective   la, except for separated ce-
sium and strontium        at Richland,   tiill be achieved for the
production    wastes at Idaho and Richland by 1976. Also Sa-
vannah River wastes will be solidified           to the extent tech-
nically    permissible.      AM: stated that objective     lb was a
continuing     one.
         The quantity    of wastes stored in tanks has decreased
 since our prior review.           Decreases in volume have resulted
 from evaporation       of the liquid     wastes at all sites,     in-tank
 solidification       at Richland,    and the calcining   process at
 Idaho.      Although these processes have reduced the quantity
of liquid       wastes, large quantities       of highly radioactive
liquid      wastes are still    stored in underground tanks.

       AEC has about 80 million  gallons of radsoactlve   wastes,
most of whxh are in a liquid     form, in Its underground
tanks.    The bulk of such wastes, which were generated at
chemxal-reprocessxng    plants,  was accumulated prior   to the
development of the technology now available     for handling

      AEC advised us that the liquid    wastes In the older
tanks at Rrchland were being solidlfled.      AEC antlclpates
that by about 1976 only the newer tanks of improved design
at Richland will contain liquids,    and these only for storage
of in-process   wastes.


     LIQUID      WASTE

                                                                        ,OFF=SlTE   REPOSITORY,
  CURRENT     BY ,976


      In our prior rtport    llre discussed Interim     tank storage
of high-level   wastes 111 llquld     form at RIchland,     Savannah
River, and Idaho and commented.

      --that      Rlchland was faced with a potentially    serious
          sltuatlon     with respect to the condltlon   of its exist-
          lng tanks and that leaks had been detected in some

      --that     some of the   tanks at Rlchland had been in ser-
          vice 10 years or     more and that a contractor   had es-
          tlmated that the     expected life  of those tanks was
          probably no more     than 20 years.

      --that   a tank leak at Savannah River would be more se-
         rious than at Richland,  because the leakage from a
         Savannah River tank could be expected to migrate Into
          the groundwater.

      --that     Idaho had not experienced    any tank failures and
          that it was contlnulng     to store llquld wastes in
          tanks on an lnterlm    basis, however, Idaho was con-
         vertlng     the liquid wastes into a solld form.

      --that    AEX had not established    a standard criterion     as
          to the reserve storage capacity       necessary to provide
          safe operation   of storage facilities.

       During our current       review we found that steps were
planned and were under way at Rlchland and Savannah River
to evaporate the llquld         wastes to the less mobile solid
residues     and that only tanks of improved design would con-
tain boiling      llquld   wastes at these two lnstallatlons.    The
current    lnterlm-storage      sltuatlon at the AEC operational
sites 1s discussed below.

Tank storage   capacity

       AEC 1s contlnulng to store large quantltles    of llquld
wastes In Its underground storage tanks but 1s working to-
ward having all but In-process     wastes converted into solid
forms.    AEC advised us that,  although  two more tanks at

Richland had developed leaks subsequent to our prior review,
only a nominal amount of radioactive     liquid wastes was re-
leased and that there had been no serious incidents       regard-
 ing tank storage at the Richland,   Idaho, and Savannah River
 sites subsequent to our prior review.      Comments regarding
 the tank storage of liquid  wastes for each site which we
visited  follow.

     Richland   Operations    Office

     The criteria      for reserve storage facilities  included
in Richland's     waste management plan provides that:

      --For self-boiling     wastes (excluding     wastes in the
         tank farm designated      as SX), a minimum of one unoc-
         cupied tank which is ready for use and equipped with
         leak detection    capability   be maintained    in each stor-
         age area at all times.       If the tank designated     as
         the spare tank is one of the previously         used single-
          shell tanks, an additional      reserve capacity   equiva-
         lent to the volume of the spare tank will be main-
          tained in the tank farm for use in the event the
          single-shell   spare tank develops a leak while being

      --For nonboiling   wastes, at least two million    gallons
         of usable storage reserve be maintained    in the tanks
         at all times,

      --The self-boiling       wastes in the SX tank-farm         complex
         exhibit    heat-generation      rates considerably     less than
         those of other waste tanks containing           self-boiling
         wastes.     The supernates rn these tanks, when stored
         separately     from the sludge, will not self-boll           and
         can be safely stored in the usable storage reserve
         maintained     for the nonboiling      wastes.    The sludges
         will not be removed from the tanks and will              be air-
         cooled to maintain        their   temperatures  at safe levels.

        According to Richland officials,    there      are three    in-
 tegrated    tank-farm complexes, as follows:

      --129 tanks    for nonboiling   wastes in 10 tank farms
         connected   by interarea   and interfarm transfer  lines,

     --lo   tanks   for   self-bolllng        wastes   In the SX tank   farm,

     --lo tanks for       self-borllng        wastes   in the A and AX
         tank farms.

     With respect to the available              and planned   reserve   space
in these three Integrated tank-farm              complexes:

     --The tank-farm   complex for nonbolllng wastes had re-
        serve storage space of about lo,5 mrlllon     gallons at
        December 31, 1969, but had no completely     empty tank
        available  as a spare and had no plans to provide an
        empty spare tank for this integrated   tank-farm     com-

     --The SX tank-farm       complex for self-bolllng        wastes has
        one tank designated       as a spare, but on December 31,
        1969, this tank was about one quarter full              of aged
        wastes,      However, Rlchland informed us that the boil-
        ing liquid     wastes 1.n the tanks were aged enough to be
        transferred     to available   space In SX tanks for non-
        boiling    wastes, If necessary.        Richland's    fiscal   year
        1970 budget provided $2 mrlllon          for a transfer      sys-
        tem to remove the bolllng        liquid    wastes from the SX
        tank farm for processing       into salt cakes,         Once this
        project    is completed and the llquld         wastes are trans-
        ferred,    there will be no interim        storage of liquid
        wastes rn this tank-farm       complex.       Rlchland plans to
        have the llquld      wastes transferred       by January 1973.
        This farm system accounts for half of the Richland
        tanks which have leaked.

     --The A and AX tank-farm        complexes had two empty, pre-
        viously used,   single-shell      tanks designated     as spares.
        These tanks were partially        filled     with hot water on
        December 31, 1969, to prevent thermal shock In the
        event of a hot-waste     transfer      into the tanks.     In
        addition,  two of   the  planned      1-mllllon-gallon    double-
        shell design tanks mentioned In our prior report
        were completed in May 1970. When placed in service
        these tanks will be included as part of the A and AX
        tank-farm  complexes.

       RIchland's   waste management plan, which rncluded a de-
scrlptlon    of Its reserve-tank-storage         crlterla,     was sub-
mitted to the Drvlsron      of OperatIonal       Safety In January 1969
for revrew and comment. Me were told by ARC that its Head-
quarters    review of Rachland's      criteria    had not included an
evaluatron     of compliance with uniform spare-tank            criteria
under conslderatron      by the Drvlslon       of Production;      however,
the Rlchland and Savannah River spare-tank-storage                 criteria,
as submltted,     were compared with each other and were found
to be similar.      The Dlvrsion    of Production        advised us that
proJects    planned and under way at Rlchland would provide the
necessary facllltles      to comply with the uniform criteria,
If they were amplemented.

      Savannah River     Operations        OffIce

        The reserve-tank-storage       criteria      Included rn Savannah
River's    waste management plan provides            that,   in each tank-
farm complex, there be maintained             In cooled tanks with good
cooling ~011s spare volume sufficient              to receive the con-
tents of the largest        tank In the tank-farm          complex.    Al-
though this practice        does not comply with the uniform spare-
tank criteria     under consaderatlon         by the Dlvlslon       of Pro-
duction,    Savannah River has storage tanks under construction
which, when completed,         ~111 brrng It into compliance with
these criteria.

       Savannah River has two tank-farm   complexes designated
as the F and H areas.    As of December 1969, eight cooled
tanks were In service rn each tank farm and four new cooled
tanks had been constructed    in the H area and were soon to
be placed In service,    Also, each tank farm had four un-
cooled tanks In service.     Savannah River does not consider
any unused capacity   In the uncooled tanks In determlnlng
whether adequate storage reserve capacity     IS being maln-
talned,   because the needed reserve storage capacity    1s for
waste which has to be kept In cooled tanks.

      When the four recently   constructed cooled tanks are
put In service In the H area, Savannah River can comply with
the Drvrslon  of Production's   proposed spare-tank    crlterla in
this area, If one of the tanks IS designated       as a spare.
No empty tank IS available    as a spare rn the F area, but
compliance with the proposed spare-tank    crlterra    can be

accompllshed If one of the two tanks scheduled             for   comple-
tlon In March 1973 1s designated  as a spare.

       Savannah River was not meeting its own establrshed
reserve-tank-storage-capacity            criteria.    As of December 19,
1969, Savannah River did not have sufflclent               reserve capac-
lty In Its cooled tanks In the F area to hold all the con-
tents of the largest        tank In the area.        We were told, how-
ever, that an Interarea         transfer      line, whreh had been con-
structed    at a cost of about $2.3 mllllon,            could be used to
transfer    waste to avallable        space In the H area In the event
of an emergency In the F area.

       In a January 1969 presentation           to the NatIonal   Academy
of Sciences'     Committee on Radloactlve          Waste Management, Sa-
vannah River contractor's        offlclals      stated that It appeared
feasible,    economical,   and safe for Savannah River to con-
tlnue its interim     tank-storage       practices    until national  pol-
icy and criteria     could be agreed upon for the long-term
storage of high-level      wastes.       We were advised by the Dlvl-
slon of Production,      however, that Savannah River had been
told that It should take necessary steps to have available
one spare tank for reserve storage In each area.

      Idaho   Operations   Office

      Idaho's waste management plan provides that one cooled
300,000-gallon      tank be reserved as emergency storage capac-
lty i-or self-boiling     wastes stored within   its tank-farm  com-
plex.    Idaho has one tank larger     than 300,000 gallons,   how-
ever, we were told that Idaho's criteria       provide that no
tank be filled     with more wastes than cao be transferred     to
the empty tank,

      The Idaho waste management plan showed that Its Test
Area North had two underground 50,000-gallon    tanks for the
storage of llquld  wastes and that no spare tank existed.
At the time of our fieldwork,   one of these tanks was full
and the other contained   about 30,000 gallons of concentrated

      We were told that, due to the high chloride   content,
the wastes stored In the tanks could not be further     evap-
orated and calclned at the Idaho Chemical Processing Plant.

According to Idaho, the remaining tank capacity             is sufflclent
for the foreseeable    future    if a satisfactory      process can be
devised and instituted      for the treatment      of the tank-stored
wastes.   AEC informed us that the chloride          problem had been
studied but that further       action had been deferred because of
funding limitations.

       An Idaho offlclal     advised us that the Test Area North
was not considered       to be a tank-farm     complex.   Another of-
ficial   told us that the tanks were contained          In concrete
saucers which acted as secondary barriers            and had sufficient
capacity    to hold all the liquid      waste should a leak develop
in a tank.     We were told also that the volume of radioactive
wastes stored in Test Area North would be reduced, within               a
period of years, by natural        evaporation    to a point where ex-
tra tank volume would be available          to store wastes.

      Idaho's waste management plan was submitted to ARC
Headquarters  in January 1969.  The Division  of Operational
Safety commented on Idaho's deferral  of disposing  of liquid
wastes stored in Test Area North, as follows:

      "One item on which a decision has been deferred         is
      the 80,000 gallons of Test Area North (TAN) waste
      which is chemically     rncompatlble   with ICPP [Idaho
      Chemical Processing Plant] waste processing.         Since
      there may be problems in funding treatment       of
      wastes from inactive     programs, the next revlsron
      of the ID [Idaho] plans should review, at least
      briefly,  the alternatives     in this case."

       The Division, in commenting on Idaho's plan, did not
discuss the adequacy of Idaho's reserve storage capacities,
We were told that no determination   was made as to whether
Idaho's reserve storage available   in its waste tanks in
Test Area North was acceptable.

      Oak Ridge Operatrons      Office

      The Oak Ridge National   Laboratory's    waste management
plan drd not cite a spare-tank    criterion.     The Oak Ridge
plan states that there are six underground       storage tanks
containing  radioactive  wastes in the Laboratory's      tank farm;
that these tanks have a total    capacity    of over a million

gallons,  about half of which 1s space avallable for emer-
gency storage of wastes; and that the stored wastes can be
pumped from any of the tanks to the others through a system
of pipes and valves.

      We were advlsed by an Oak Ridge offlclal   that the SIX
tanks had unused space but that each of the tanks contained
sludge so that no empty tank was on standby reserve.      We
were advlsed by another offlclal   that Oak Ridge's practxe
was to utilize,   If needed, unused storage capacity  In the
tanks and that this could be cited as the spare-tank     crlte-

Engineered    systems for     transfer        of wastes

        AEC Headquarter's    instructions    provided that the waste
management plans for wastes stored on an interim               basis in
underground tanks include descriptions           of engineered systems
to minimize the possibility         of wastes' escaping from tanks.
The waste management plans of Rrchland,            Savannah River,
Idaho, and Oak Ridge did not include full descriptions                of
the engineered systems in use or planned for transferring
tank-stored      wastes to reserve storage tanks in the event of
tank failures.        We were advised by AEC that Headquarters           of-
ficials    had become aware of the existing         conditions    through
periodic    field   trips.

       The bottom portions        of the cooled tanks at Savannah
River have outer linings          of carbon steel,         to provide saucers
beneath the primary tanks to collect                wastes that may leak
from the tanks        A recycling       capability      from a saucer back
to the tank has been provided,            and, in the event of a leak
in the tank, the wastes would be recycled                  back into the tank
until   they are transferred        to reserve tank storage space
In 1968 Richland began to construct                tanks having a double-
containment    feature    similar     to those used at Savannah River

       At Richland it would normally take about 9 to 10 days
to transfer    the liquid   wastes from one of the largest     tanks,
if it was full of liquid,        to a reserve storage tank in the
event of a tank failure.         At Savannah River it would take
about 9 to 10 days to transfer        the liquid   wastes from one of
the cooled tanks if it was full         of liquid    Depending on the
quantity    of liquid   in the tank, between 3 and 14 days would
be required    to transfer    the contents    from one of the uncooled
tanks at Savannah River.

       We were told by Savannah River that the recycling    capa-
bility   of its tanks was adequate to handle leakages of the
magnitude experienced   in the past and that this recycling
should prevent wastes from escaping while a tank's contents
were being transferred    to other tanks.

       The Richland contractor's    officials             told us that, if
weather conditions    were favorable,      about          2 to 3 days were
required   to install  a pump directly      into          a tank and to make

the necessary transfer-line          connection   changes in an under-
ground routing        box    We were also told by a Richland con-
tractor's    official     that a pump normally would not be In-
stalled   on a windy day, because of the possibility                 of re-
leasing radioactive         material    We were told also that, if a
leak developed In a tank having a pump, the time required
before the wastes could be pumped from the tank would depend
upon the number of transfer-line          connection        changes that
would have to be made in the appropriate              underground routing
box, that, once the pumping began, the liquid wastes could
be transferred        to another tank at the rate of about 100 gal-
lons a minute          A Richland contractor     official      said that
about 1 week would be required          to transfer       the liquid    wastes
from a l-million-gallon         tank, the largest      Rrchland under-
ground storage tank, if the tank was full               of liqusd

      Under the engineered tank-storage      system at Savannah
River, a transfer    Jet has been installed    in each of the four
cooled, double-shelled,     underground storage tanks which had
experienced   leaks     Consequently no setup time is needed be-
fore the wastes can be transferred      from these tanks to re-
serve storage tanks

       A Savannah River official    said that the installed    trans-
 fer Jets and related   equipment could transfer     the wastes at
 about 75 gallons a minute and that,     at that rate,    it would
take about 9 days to transfer     the contents from the largest
of the cooled tanks if the tank was full of liquid.          AEC ad-
vised us that, under its evaporation      program, the liquid     in
many tanks constituted    only 40 percent of the volume; thus,
in such cases, less than half the indicated       time would be
required   to empty a tank.

       The other 12 cooled tanks at Savannah River do not have
the capability    for lmmedlate transfer    of wastes in the event
of an emergency situation,     such as a leak      Before wastes
could be transferred    from these tanks in an emergency, trans-
fer Jets must be set up, which would provide a capability         to
transfer   the wastes at a rate of 75 gallons a minute         We
were advised that it wocrld take about 1 day to install        a
transfer   Jet and about 9 additional    days to transfer   the
wastes from the largest     of these cooled tanks, provided that
the tank was full of liquid        In the interim,   Savannah River

would depend on the saucers and the recycle capabIlIty    to
prevent escape of the leaklng wastes.   We were told that
the high salt content of the llquld wastes mlnlmlzed their

        At the time of our fieldwork,      Savannah River was in-
stalling,      or was planning to install,    permanent-type    waste-
transfer     piping for the eight uncooled waste tanks In the
F and H areas, which would reduce setup tbme needed for in-
stalling     transfer  capablllty.    These uncooled tanks have
pumps that have the capability        of handling a leakage of 20
gallons or less a minute through a recycling          operation   by
means of an underground drainage sump and sump pump

       A Savannah River contractor        official   advised us that
2 days would be required       to Install      a temporary 75 gallon-
a-minute transfer     system and that about 12 additional          days
would be required     to transfer     the contents     from one of the
uncooled tanks       We were informed by the contractor         offlclal
that authorlzatlon      to install    the permanent transfer     capa-
bility   1.n the tank groups had been delayed because of fund-
lng conslderatlons      and that,   If the proJect was lnltlated         In
fiscal   year 1972, the transfer        systems should be operational
by late 1973

      On three occasions within       a 3-week period In September
1969, Idaho inadvertently       discharged   some unprocessed radio-
active solution     krom its chemical-processing     plant directly
Into a 600-foot-deep      discharge well which extends jnto the
acquifer       These discharges were caused by improper opera-
tion of a steam-heat system between a dissolver          vessel and
the service waste line, however, the cause was not ldentlfled
until    after the third   discharge had occurred

        We were advlsed by the Idaho Operations          Office that the
lnltlal     incident    had been undetected    because of the lnslg-
nlflcant      quantity   of radloactlvlty   released and that timely
lnvestlgatlon        to discover the cause of the second discharge
had not been made because of consecutive,            higher priority
alarms triggered        by a power outage.

       During September 1969, the month in which the acclden-
tal   discharges occurred, the average concentration of

strontium-90   (the controlling    radioisotope)        in the dls-
charges into the chemical-processing          plant's     disposal well
was about two times the allowable        limit        We were advlsed
by Idaho that the average yearly concentration               is considered
In determinlng    compliance with release criteria             and that the
average yearly concentration     in this case was within             allow-
able limits

        The Division      of Production      informed US that, prior to
the accidental        discharges,    a proJectforacooling-water          pro-
tection    facility      had been included in the fiscal         year 1971
budget and that the incidents             provided addItiona      impetus
for obtaining       the proJect's     authorization        The facility,
which 1s now under construction              and which is estimated      to
cost approximately         $700,000, will provide radiation           monitors,
valves,    and plplng to divert         the total    flow of contaminated
water to another tank until           the defective      equipment has been
shut down and the system flushed of contamination


        AEC has requrred      each of Its field     operations    offlces
to develop waste management plans and has established                  the
topics to be covered in the plans.             The plans have been re-
viewed by the responsible          AEC Headquarters    dlvlslons,      and
comments thereon have been provided to the field               operations
offices.      It does not appear, however, that the AEC Head-
quarters    reviews of these plans were made In sufflclent
depth to fully       evaluate the plans and differences          among the
operational      sites'   spare-tankage   crlterla    and the need for
a uniform criteria.

       Because of the technical       factors     involved,      we are not
In a posltlon     to comment on the adequacy of the lnterlm
storage practices      at AEC installations.          We were advised by
AEC that operational       sites    waste-transfer         capabllltles   and
available   storage space -Ln the past had provided for ade-
quate operation      of tank storage facllltles.             As the tanks
and engineered systems increase In age and are utlllzed
more because of the accumulation           of new wastes and movement 1
of wastes between tanks, however, there 1s an increased
posslblllty     of tank lncldents     occurring      until    all llquld
wastes are removed from these old tanks,                AEC told us that      '
Rlchland was In the process of replaclng              the older tanks
contalnlng    high-level     liquid  wastes with improved double-
shelled tanks.


      At the time of our prior report to the Joint Committee
In 1968, AEC was taking actions at Rlchland,              Savannah River,
and Idaho to develop methods for the safe long-term                 storage
of radloactlve    wastes.     Rlchland was developing         processes
for solldlfylng     Its liquid    wastes.    Savannah River was con-
ducting research and development on long-term              storage of       _
wastes In the bedrock formatlon         below the Savannah River
plant site.     Idaho was operating       a waste-calclnlng       faclllty
to convert Its liquid      wastes into a solid granular           form for
storage In bins.

      AEC has established  waste management pollcles      pro-
vldlng that storage of high-level     liquid    wastes In tanks 1s
an unacceptable   practice for long-term     storage and that all

but in-process  liquid   wastes should be either  converted into
a solid form or transferred    to deep underground locations
for long-term  storage.

       We were informed by AEC that the salt mines in Kansas
were being considered as a long-term-storage         repository    for
all AEC-generated high-level      waste but that the AEC opera-
tional    sites were following   or developing alternative      stor-
age methods which were more economical and were being con-
sidered by the sites as acceptable       for long-term    storage.
Some of these alternative      methods are extensions     of the
interim-storage    methods being used.      Methods being considered
to provide for long-term-storage       of high-level   wastes at the
sites are discussed below,

Richland     Operations     Office

        At the time of our 1968 report,                Richland had begun
separating       strontium     and ceslum, the long-lived           fission
products,      from the accumulated self-bolllng               wastes (frac-
tionation)       and temporarily       storing     these two radioisotopes
as liquid      concentrates       in the waste fractlonatlon           faclllty
with the intent          of eventually      storing      them as solids in
high-integrity         containers     (encapsulation).         After frac-
tionation,       the remalnlng nonboiling            liquid wastes were be-
ing transferred         to storage tanks for solldiflcation.                  At
that time, Rlchland planned that its currently                     generated
self-boiling        wastes would be treated            for the removal of
strontium      and cesium, after which they would be stored in
tanks to allow short-lived             fission     products to decay,           The
accumulated nonboillng            wastes were being solidified            in
tanks to a salt cake              In 1968 AEC reported that 25 percent
of the nonbolllng          waste accumulated at Rlchland was in
solid form.

        Rlchland has continued to convert its high-level           liquid
wastes to a solid form within       the storage tanks.       We were
advised by Rlchland officials       that Richland would meet the
general target    date of December 31, 1975, for having all
wastes, except in-process     liquid    wastes, solldlfled      in tanks
but that it was anticipated      that a declslon would not be
made for about 10 years as to the acceptability            of in-tank
solidification    as a safe, long-term-storage      method.      They
stated that In the meantime Rlchland would continue to

perform research on alternative        long-term-storage   methods
in the event in-tank    solidlflcatlon       was deemed unacceptable
for long-term  storage.

         From start-up       in March 1965 to December 31, 1969, Rlch-
land spent about $4.9 million            in operating       the rn-tank-
solidification       facilities.       Three different        evaporator    fa-
crlities      are being used for in-tank         solidification.         The
cost of constructing           these three evaporators         was about
$2.1 million      as of December 31, 1969. AEC estimated                 that
about $492,000 more would be spent to complete modifrca-
tions then in process.

          In accordance with its plans to meet the 1975 target
date, Richland requested authorization                 of an additional
$6.3 million       for construction        of in-tank-solldlfrcation       fa-
cilities.       This request was Included in the 1971 authorlza-
tion request,        and the facilities       have been authorized,        Ac-
cording to Richland,          these facllitres       will provide the ad-
ditional      capability    required     to meet AK's target         date of
having all but In-process           liquid    wastes solldifled.

       In January 1968, a Richland contractor          issued a pre-
llmrnary   safety analysis      report on the long-term         hazards of
wastes solidified     in underground tanks.        In the report,        as
revised in January 1970, the contractor           stated that the
wastes would not be transported         into the atmosphere or rnto
the groundwater under foreseeable          environmental      conditions
and that,   if this method of storage was compatible               with
"national   criteria"   --yet to be defined--the        solidified
wastes could be left       in this state indefinitely.

       In June 1969,AEC Headquarters   asked Richland for an
estimate of when a more deflnrtrve,      or a final,    hazard anal-
ysis would be available,      Richland reported    that about 7 to
10 years would be required     to accumulate sufficient      infor-
mation on salt-cake   characteristics    and storage effects        be-
fore an acceptable,   final   safety analysis   could be prepared.

       The Richland contractor's    long-range   cost forecasts
indicated   that the operating    costs of fractionating     the
wastes, encapsulating     the cesium and strontium,      and solidi-
fying wastes in tanks would amount to about $102 million
for the lo-year    period beginning with fiscal      year 1971, He

estimated   that additional       capital   funds of about $37 mullion
would be required     for the same period,        As of December 31,
1969, Richland had spent about $38 million           for operatzng
costs and capital     facilities      toward rmplementrng this pro-
posed long-term-storage         method.

      At the time of our prior review, AEC estimated           that
about $12.5 million     had been, or would be, spent at Rlchland
for constructing    facilities    for the fractionation     process.
As of December 31, 1969, about $15.3 million           had been spent
In constructing   such facllitles     and AEC estimated that
$513,000 additional     would be spent on proJects       in process,

        Rlchland had established           target dates of September
1973 for the removal of strontium                from stored sludge and
September 1974 for the removal               of cesium from the stored
liquid     wastes.    Richland,     however, does not plan to remove
the strontium      from about 792,000 gallons of stored sludge
which is in the oldest tanks for self-boiling                   wastes, some
of which have leaked.           According to ARC, the sludge is con-
sidered essentially         solid.     Richland's       decision to retain
the sludge in the tanks 1s based on a demonstrated proto-
type and on the concept of minimum risk.                   According to
Rlchland,     air cooling the sludge for 25 to 50 years will
cause It. to solidify        satisfactorily         in place without    frac-
tlonation.       The llquld     wastes from these tanks are to be
transferred      to the fractionation          facility    for the removal
of the ceslum, after which the liquid wastes will go to in-
tank solldiflcatlon,

      In its fiscal     year 1970 budget, Rlchland requested
$2 million    to construct     facilities   for the transfer    of
wastes from the tank farm with the oldest self-boiling
wastes to the waste fractionation         facility,    At the time of
our review, the design of these facilities           had begun.     Be-
cause of Presldentlal       funding limitations     on new construc-
tion,   the total   funds were not made available       until  July
1970. AEC told us in January 1971 that the facllltles              were
being constructed.

       As of December 31, 1969, Rlchland was behind schedule
on its programmed rate for strontium    removal, about 811,000
gallons of stored sludge remained to be fractionated

  compared with 700,000 gallons programmed to be remaining at
  that date,       Richland's   program for cesium removal was on
  schedule at December 31, 1969; about 12.7 mlllron             gallons
  of liquid     wastes remained to be fractionated,         According to
  Richland,     planned additions     are necessary to the high-level
  waste-processing        system for waste fractionation     of both
  stored and current wastes to meet the December 31, 1975,
  date for solidification        of all but in-process    liquid    wastes,
  An illustration       of the first   in-tank-solidified    salt cake,
  which was provided to us by ARC, 1s on the following              page.

         In its fiscal     year 1971 budget, Richland requested and
  was authorized     $1.7 million      to provide additional      interim
  storage facrllties       for ceslum and strontium       and to construct
  high-level    waste-transfer     lines and sludge-removal         facili-
  ties.    According to Richland,        this additional     storage in
  the waste fractionation       facility     would provide for the
  storage of ceslum and strontium           concentrates    until   1974
  when It plans to begin waste encapsulation             processrng.

         Rlchland has selected a process for solidifying                 and
  encapsulating     the long-lived        fission    products but does not
  expect to have Its presently            stored inventory       encapsulated
  before 1979.      A facility,       scheduled for completion         in 1973,
1 is being constructed         for solidifying       and encapsulatlng      Ehe
  cesium and strontium.           Richland has stated that,         afLer en-
  capsulation,    these fission        products could be stored on an
  interim    basis in water basins, possibly              as long as 100
  years.     AEC has not selected the method to be used for long-
  term storage of the encapsulated              products.

        As previously      stated,     until     the solidification           and en-
  capsulation   facility      is in operation,            the ceslum and stron-
  tium removed from the wastes are being stored in tanks in-
  side the fractionation        facility.          In March 1970, during an
  attempt to measure the liquid              level In an interim-strontium-
  storage tank In the fractionation                facility      by means of tem-
  porary instrumentation        that has since been removed, there
  was an accidental      release of strontium               from the tank into
  an open 25-acre pond within            the site boundaries.             Water
  samples from the pond reached a strontium                     concentration
  level exceeding ARC's standards for releases of radiation.

        A contamrnated       ditch was completely   screened over and
partially     backfilled,       but the pond remains open, Rlchland
has malntalned        surveillance     of the pond and has used noise
guns In an attempt to prevent the use of the pond by water-
fowl, however, some coots and ducks have landed on the pond.
Rlchland offlclals         advised us that their    analysis had shown
that consumptron by a person of 1 pound of the contaminated
waterfowl     generally      would be expected to result     In that
person's    receiving      an intake of about 1 percent of the maxl-
mum permlsslble        body burden of two mlcrocuries       of strontlum-
90; however, In some waterfowl            the amount of radloactlvlty
from other rsotopes was higher.

      Rlchland offlclals      told us that emergency procedures
have been provided at the fractlonatlon           faclllty      for the
manual dlverslon     of such contaminated      releases      into an
emergency ditch.       Also we were advised that Rlchland
planned to include In Its fiscal         year 1972 budget a re-
quest for a $5.3 mllllon        proJect which would provide the
capabrllty    to divert    contaminated   cooling-water        and chemlcal-
sewer streams from the fractlonatlon          and chemical-processing
plants to underground storage tanks,            This proJect would
provide Rlchland with a dlverslon         capablllty       slmllar  to
that now exlstlng       at the commercial chemical-processing
plant In New York State.          (See p, 56.)

       Both AEC and Rlchland advlsed us that the method for
long-term    storage of encapsulated   ceslum and strontium       had
not been selected and that,      as a result,  Rlchland was un-
certain    as to the number of years of interim      storage that
would be required    before the encapsulated    products    could
be routed to a final     storage site,    AEC antlclpates    that
flnal   storage could be In salt mines.

       In 1969 Rlchland began a study of deep-cavern storage
of radloactlve      wastes as an alternative        to Its proposed
long-term-storage       method of solldlfylng      wastes In tanks.
The obJectlve      of this study 1s to investigate          the feasl-
blllty   of lsolatlng     radlonuclldes      from the biosphere In
caverns mined In the basalt deep beneath the site,                 Under
this storage method, the salt cake resulting              from the In-
tank solldlflcatlon       of liquid     wastes would be removed from
the tanks In a dry state, water would be added In the
transfer     system, and the slurrled        waste would be transported

to underground caverns 2,000 to 4,000 feet below the SUP
face.    According to the Rlchland contractor's   estimates   It
would cost about $150 mllllon    to place the salt slurry   III

       At the time of our fleldwork,               RIchland was conducting
a $1.6 mllllon       project      for drilling       exploratory   wells to
secure geological,        hydrological,        and other physical        data
to be used In evaluating              the sultablllty       of subsurface
formations    for storage of radloactlve               wastes for centuries.
Work on the proJect was scheduled to have been completed by
the end of 1970. The AEC contractor                   for this proJect re-
ported that sufflclent            data had been acquired to Justify
additional    drllllng       to fully     evaluate the area for an
underground-storage          faclllty,

       At the time of our fleldwork,         the contractor       had not
submitted a plan to AEC for the development of the under-
ground caverns.      We were informed,       however, that full       eval-
uation of the hydrological         and geological     characterlstlcs
was to be made.      The   AEC  contractor     had  established     Decem-
ber 1975 as a mllestone        date for acqulrlng       data sufflclent
for reaching a declslon on the feaslblllty              of contlnulng
the lnvestlgatlon     of long-term      storage of wastes In mined
caverns at the Rlchland site,           In forecasting      future ex-
pendstures,     the contractor     estimated    that $7,3 mllllon       ad-
ditional    would have to be spent on studying this method of
long-term    storage through fiscal        year 1975.

Savannah Rover Operations           Offlce

        Since our prior review, essentially              all research at
Savannah River directed            at frndlng    a long-term    solution       for
storing     high-level     radloactlve      wastes has continued to be
on exploring       the feaslblllty       of bedrock-cavern      storage          In
1967 Savannah River reported that the bedrock--cavern-storage
concept for long-term          storage had been developed to a point
where the next maJor step In determInIng                 the feaslblllty         of
this concept was the construction              of an exploratory         shaft,
however, approval has not been obtalned for construction                         of
the exploratory        shaft

       Because of the delay In proving the sultablllty                 of the
bedrock caverns for long-term           storage,    Savannah River (1)
will not meet the December 31, 1975, general target date for
having all but In-process         waste in long-term        storage,     (2)
will have a slgnlflcantly         larger inventory        of radloactlve
waste stored In underground tanks on an lnterlm                 basis,     (3)
may need to construct,        at currently      proJected    rates of waste
generation,     additional    tanks for interim        storage of waste
late in the 1970's, and (4) plans to spend $375,000 1.n the
next few years exploring         an alternative      to Its proposed
long-term-storage       method

       In our prior report,     we noted that AEC planned to re-
quest $1.3 mllllon    for deslgnlng the bedrock-cavern       proJect
In fiscal    year 1970 and, If the proJect     still  appeared fea-
srble,    to request construction     funds in the fiscal  year 1971
and 1972 budgets

         In August 1968, a panel of consultants         began a detailed
analysis     of the bedrock-cavern-storage       concept     In May 1969,
the consultants       reported   that the bedrock-cavern-storage
concept had promise of offering           a permanent solution    to the
crltlcal     waste-handling    problem and stated that definite         as-
surance could be provided only by the actual construction                of
the shaft and several of the exploratory            tunnels.    In July
1969, a proJect to locate the construction             site, lncludlng
necessary drllllng        and preconstructson    design and englneer-
vz,      was authorized    for $1.3 mllllon.

      AX offlclals stated that,  for the bedrock-cavern-
storage proJect to proceed, about $10 mllllon   would be

needed for constructron    of at least the shaft and explor-
atory tunnels.    They stated also that, because of budgetary
conslderatlons,   these funds would not be avaIlable   in 1971
and that the $10 millron    proJect was planned as a fiscal
year 1972 budget submlsslon.

         Savannah River offlclals      stated that,    If fiscal     year
1972 funds were authorized        for the bedrock-cavern         proJect
and if the proJect was successful,           It would be about 1981
before Savannah River could meet the obJectlve              of having
all but In-process        waste In long-term     storage.    In 1963
Savannah River requested $12.5 millron            to provide bedrock-
cavern-storage     facllitles;    however, it currently        estimates
that more than $50 mllllon        will    be needed for the storage
facilities.      The increased estimate        1s due to escalation,
an increase in the size of the cavern, and additional                 engr-
neerrng features.

        Savannah River stated that,          until    it placed its waste
in long-term      storage,     it would continue        to store slgnifi-
cant quantities        of radioactive      solid and llquld wastes in
underground      tanks.     Its waste-inventory         proJections    for fis-
cal years 1970-80 indicate            that a peak inventory         of over 16
million    gallons     of solidified      and llquld wastes would be
stored in tanks during that period,                the Drvlslon     of Produc-
tlon estimates       that more than half of the wastes ~111 be In
the form of salt crystals.              (See photograph on p 43.)

       In September 1969, Savannah River informed the Dlvlslon
of Production      that no additional        waste tanks would be re-
qurred beyond the two then being constructed,                 if the bedrock-
cavern-storage       facllltles       were constructed     and placed In-
service    by fiscal     year 1980 but that,        if the bedrock facllr-
ties were not avarlable            for use by fiscal    year 1980, bud-
geting for additional           tank capablllty     (one or two tanks) In
fiscal   year 1977 might be necessary               This estimate was
based on the assumption that all existing                tanks would maln-
taln their     Integrity

      In the past Savannah River's      program on alternatives
to bedrock-cavern     storage had been to keep current      with the
extensive    research   at other ARC sites on various methods
for solldlfylng     wastes.    In an August 1968 report,    however,
an ARC task force on waste management recommended that

Savannah River develop an alternative              waste management pro-
gram.     As a   result,  Savannah    River   proposed   a program for
addltlonal     research and development to provide a definite
alternative      to bedrock-cavern      storage.     The proposal pro-
vided,    as the principal     alternative       to be consldered,   the
conversion     of wastes into solids and their shipment offsite
for eventual storage in salt mines.               Savannah River esti-
mated that it would cost about $700 mllllon              to solidify    its
wastes and ship them offslte          to salt mines.

        The proposal suggested that research and development
necessary to adopt a calclnatlon            process for these wastes
could be performed by the Oak Ridge National               Laboratory    In
collaboration      with Savannah River.          Savannah River estimated
that funding requirements          for the initial      phases of the
project    through fiscal      year 1972 would be $375,000.           AEC's
Dlvlslon     of Production      suggested to Savannah River that work
on this project       be initiated     in fiscal    year 1970 within
available     funds.    We were informed by AEC that Savannah
River had initiated       work on waste calclnatlon          technology.

Idaho   Operations      Office

       Since    our prior review,          Idaho has continued    to convert
its liquid      wastes into a solid form by calclnlng             for storage
in bins in      underground concrete vaults and has proposed this
method for      long-term       storage,     At December 31, 1969, over
1.8 million       gallons of liquid wastes had been converted             into
solids    and   placed in bins.          Idaho reported    in its waste
management      plan that by fiscal          year 1974 it should be cur-
rent in its       solidification        program.

         AFX informed us that all high-level       wastes accumulated
through 1966 were scheduled to be processed in the calclnlng
faclllty     by about January 1972 and that it should be able
to meet the AEC goal for solidifying          all but in-process        llq-
uld wastes.       AEC informed us also that It was planning to
remove solid alpha wastes (plutonium         bearing)      from the Idaho
site for deposit In salt mines, because that appeared to be
a better method for attaining       long-term     lsolatlon    of these
wastes.      The ma-terra1 to be transferred     would include the
calclned wastes If they meet the as yet undetermined               crlte-
rla (see p. 49) for determining        the wastes to be trans-
ferred.      AEC plans to begin shipments of the alpha wastes

to a salt mine during this decade, and AEC's prellmlnary
estimates  lndlcate  that excavation,   processing,    and shlp-
ment of such wastes,    -Lncludlng the calclned   wastes,  will
cost about $60 mllllon.
Oak Ridge National     Laboratory

      The Oak Ridge National      Laboratory has developed a
method of disposing     of Its nonreleasable   radloactlve      wastes
based on the oil-field     technique of hydraulic     fracturing.
The wastes are mixed with cement and other addltrves             and
are then pumped down a well Into the ground and out Into an
essentially  horizontal    fracture   wlthln a rock formatlon        ad-
~acent to the Laboratory.

       Since the hydraulic-fracturing     faclllty   became opera-
tlonal    In December 1966, more than 700,000 gallons of radlo-
active 1rqul.d wastes, which could not be routinely         released
into the environment,      has been pumped into the ground        Oak
Rldge's calculations     show that the capacity     of the formation
at the exlstlng     well 1s at least four mllllon     gallons of
radloactlve    wastes before there IS any danger of failure         of
rock cover and that the Laboratory       can continue to use the
present facility     for about 20 years.

       Oak Ridge advised us that primary containment          and
shleldlng   of the radloactlve      wastes stored under this method
1s provided by the rock cover and that secondary containment
IS provided by proper selection          of the solldlfylng   additives
but that the removal of these inJected wastes from the rock-
storage location   for relocation,         In the event It was later
required,   was considered     to be extremely     dlfflcult.   We were
advised by AEC that use of this storage method had been dls-
continued pending further        evaluations.


       We recognize      that there are dlfflcultles       involved In
determlnlng      the adequacy of storage methods which must pro-
vlde for safe storage of radloactlve             wastes for hundreds of
years       Delays In determining       long-term-storage     methods,
however, result        In (1) use of lnterlm-storage       methods for
long periods of time, (2) continuous             research on various
alternative      long-term-storage      methods, and (3) a greater
posslblllty      of addltlonal     costs' being incurred      In changing
the physlcal    characterlstlcs      of the waste and constructing
addltronal   lnterlm-storage      facllltles

     We believe that,     to expedite the development of methods
for placing Its high-level     wastes in long-term      lsolatlon,
AEC Headquarters   should place greater emphasis on evaluating
the actions being taken by Its contractors,         determlnlng    the
adequacy of long-term-storage      proposals,    and taking the
steps needed to accomplish long-term        storage

                                 CHAPTER 3


        AEC and its contractors          have recognized      that potential
hazards are associated           with the ground burial         of radioac-
tive solid wastes that could result              in the release of ra-
dioactive     material   into the environment.           According to AEC,
the burial     practices     followed     by Richland,     Savannah River,
Idaho, and Oak Ridge have not resulted                in releases of radio-
activity     beyond the confines of the burial             grounds that ex-
ceed AEC's concentration            guides and exposure limits.          AEC
and rts contractors        told us that radioactive           solid wastes
could continue to be buried safely at AEC operational                    sites,
provided that surveillance            was maintained     over the burial
grounds.      Because of plutonium-239's           long half-life      (24,000
years),    the hazardous concentrations            of plutonium decrease
very slowly,      and there can be no assurance that surveillance
will be maintained       for the hundreds of thousands of years-
during which the plutonium would constitute                 a potential

        Radioactive    solid wastes are radioactive       materials
which are essentially          dry or which contain adsorbed or ab-
sorbed fluids       in sufficiently      small amounts as to be rela-
tively      immobile in the soil.        The AEC-generated radioactive
solid wastes generally          include such items as contaminated
equipment and materials           and residues of production     research
activities.        Most of these wastes have been burled in the
ground.       As of December 31, 1969, the four AEC operational
sites included in our review had utilized             a cumulative    to-
tal of approximately         630 acres of land for burying over
22 million      cubic feet of radioactive       solid wastes.

       Once radioactive solid wastes are burled in the ground,
potential   hazards over the extensive  periods of time that
they must be isolated   include:

      --the leaching      of radioactive   material  from the buried
         solid wastes     and the eventual uncontrolled    migration
         of hazardous     concentrates   of this material   through
         and into the     groundwater,

      --the upward migration       of radioactive    material   through
          the roots of plants,

      --the transport   of radioactive material   resulting from
         the encroachment into the burial   grounds by animals
         or humans, and

      --the soil erosion resulting  in the radioactive           mate-
         rial's being exposed and possibly transported           by the
         air or water.

The last three potential      hazards listed     above would be
likely  to occur only if     proper surveillance     were not main-'

       In October 1969, AEC*s General Manager reestablished
the Task Force on AEC Operational      Radloactlve    Waste Manage-
ment.    The General Manager requested the task force to make
an intensive    study of the policies   and practices    regarding
the ground burial     of radioactive  solid wastes at AEC opera-
tional   sites and to evaluate the adequacy      of such policies
and practices.

       On March 20, 1970, the General Manager issued a policy
statement    implementing      the recommendations of the task
force.    This policy,      applicable    to burial   of all solid
wastes after April 30, 1970, provided,             in general,   that
wastes having known or detectable           contamination     of trans-
uranium nuclides,       which include plutoniarm, be so packaged
and segregated     In the solid-waste       burial   grounds that they
can be readily     retrievable      within a period of 20 years.

     Prior to April 30, 1970, provision        for retrieval   was
not a primary consrderatron     in solid-waste    burials,   and it
would be dlffrcult  to retrieve    those wastes if AEC should
so desire.

       In general,  prior to April 30, 1970, (1) no standard
packaging procedures had been established,       (2) different
burlal   techniques  were used at the various operational
sites,   and (3) records indicating    volumes and exact loca-
tions were not available    for all buried solid wastes.
Packaging of these radioactrve      wastes was designed to main-
tain safety until    It was buried,   but, after burial,    the

ground was relied upon to confine the wastes.       AEC           told us
that the various procedures used at the operational                 sites
were considered  to be adequate but that storage of               the
wastes in a deep underground repository     appeared to             be the
best method for long-term   isolation  of these wastes              from
the biosphere.                                                                :
       The location    of the burial        trenches for solid wastes
containing    transuranium     nuclides vary from several hundred
feet above the water table at Richland to such a proximity
to the water table at Oak Ridge that at certain                  times dur-
ing the year the water table intersects                the wastes buried
in the trenches.       At  Idaho   the    burial    grounds    have been in-
undated on occasions by the water from melting                  snow; how-
ever, measures were being taken to prevent future accumula-
tion of such water on the burial              grounds.     ARC studies have
shown that the movement of buried plutonium                 is minimal be-
cause of its insolubility.           Illustrations        obtained from ARC
that show various ARC burial           sites are on the following

       ARC expects that the Kansas salt mines will be used
for long-term     storage of radioactive       solidified        wastes and
of transuranium-contaminated        solid wastes.         AEC believes
that near-surface-land-burial        practices     offer no current
safety hazard but that a long-term-storage              facility      for
transuranium-contaminated       solid wastes should be available
to accommodate the increasing         amounts of such wastes which
will be generated by the nuclear Industry.                ARC believes
also that the mines will serve as a satisfactory                  solution
for storage of these wastes over the time periods required
and will    reduce surveillance     requirements       because of the
burlal   depth.

       AEC is in the process of determining         a definition     of
the level of contamination        that would distinguish       alpha
wastes (i.e.,    plutonium-bearing      wastes) from other radloac-
tive solid wastes.       Such a definltlon     is necessary,to      estl-
mate the volume of wastes now buried at the AEC operational
sites that might be considered         for transfer     to the salt
mines.    ARC contractors'     preliminary    estimates    indicate
that to relocate     all plutonium-contaminated        wastes that had
been buried at Richland,       Savannah River, Oak Ridge, and
Idaho could cost billions        of dollars.

                                CHAPTER 4


       Reprocessing      of irradiated    nuclear fuel, to recover
usable uranium and the plutonium which has been generated
in the fuel elements during their use, is a necessary part
of the nuclear-fuel         cycle.    Economic considerations,       as
well as the need to conserve natural            resources,   dictate    that
private    industry     recover these valuable      elements existing      in
nuclear fuel that has reached a point where it can no longer
be utilized     efficiently       in a power reactor.

       For a private     firm to build and operate a fuel recovery
plant,    the potential     operator must follow the appropriate
AEC licensing     procedures.       The AEC licensing      procedures are
intended to ensure that the plant is designed, constructed,
operated,    and maintained      in such a manner that both persons
and property    are protected       from radiation    and other health
and safety hazards.         The procedures include AEC reviews of
the prospective      plant site, the proposed process, and the
applicant's    preliminary      safety analysis    report.

        Reviews of the preliminary        safety analysis report are
made by both the Division         of Materials    Licensing    and the
Advisory Committee on Reactor Safeguards.              After these re-
views, the Atomic Safety and Licensing             Board holds a public
hearing on the application          and determlnes,     among other
things,    whether the prior reviews were adequate to support
the issuance of a construction           permit.    Both the decision
of the Board to issue a permit and the permit itself                are
subJect to review by the AEC Commissioners.               Near  the  com-
pletion     of construction    of the plant,     the applicant     1s re-
quired to submit a final         safety analysis report for review
by the AEC staff and by the Advisory Committee.                After all
questions     on health and safety matters have been satlsfac-
torily    resolved,    an operating    license   is issued.

       At the time of our review, the only privately       owned
licensed    commercial fuel-reprocessing     facility where hlgh-
level radioactive     wastes were being accumulated was the
Nuclear Fuel Services plant.        Within the next few years,

that     plant and three other         plants     are scheduled   for   opera-
tion,     as shown below.

                                               Throughput     Estimated date
                                              (metric tons)       to begin
               Company                           a year         operation
Nuclear Fuel Services,          In-
    corporated,       West Valley,
    New York                                  300 to 900a           1966'
General Electric         Company,
   Morris,     Illinois                       300 to 500a           1971
Allied-Gulf        Nuclear Ser-
   vlces9 Barnwell,        South
    Carolina                                      1,500             1973
Atlantic-Richfield         Company,
   Leeds, South Carolina                          1,800             1976

aFuture      expansion   capability.
    Actual   date.

        AEC's forecast   of the demand for addltional  reprocess-
ing capacity      in the United States for the next 30 years is
illustrated     in the chart on the following    page.

        Nuclear Fuel Services2 Allied-Gulf,              and Atlantlc-
Richfield     plan to solidify        their radioactive        wastes follow-
ing a period of interim           storage in waste tanks, using
methods developed by AEC. General Electric,                    however, plans
to depart slightly         from the interim       storage of radioactive
liquids    by providing       for immediate solidification            of the
high-level     liquid    wastes.      In general,     General Electric
plans to utilize        the basic AEC separation           technology,     but
it plans also to provide for in-line               solidlflcation       of
high-level     liquid    wastes rather than initial             storage of the
radioactive      liquid    wastes in a storage tank.

         AEC 1s developrng plans for the acquisition     of a site
and for the construction        and operation  of a demonstration
facility     for long-term   storage in the bedded-salt    forma-
tions In central       Kansas of solidified   high-level liquid
radioactive     wastes and solid wastes contaminated     with

                                    U. S. IRRADIATION       FUEL FORECAST



16                                                                          6

 8      *

                             <                     \

                       I            1.

            1970            1972            1974       1977

long-lived   radioactive   materials.     During the past decade
the Drvlsion    of Reactor Development and Technology and the
Oak Ridge National Laboratory        have made an extensive    study
Into the possible long-term       storage of high-level    radloac-
tlve solrd wastes In salt mines.         The Laboratory   developed
this method of storage as Project        Salt Vault during the pe-
riod 1963-67.


--Nuclear   Fuel Services

      Nuclear Fuel Services plans provide for malntalnlng         at
least one spare carbon-steel         tank for each three such tanks
In use for storing     high-level      radloactlve lfquld wastes and
one spare stalnless-steel        tank for each five such tanks in
use for storing    such wastes.
       Nuclear Fuel Services has an agreement with the State
of New York to accept long-term          surveillance       of the Nuclear
Fuel Services'     storage   tanks  In    the  event   the    plant should
cease to operate.       This concept of a long-term              llquld-waste-
storage tank farm satisfied        AEC health and safety requlre-
ments because of the specific         geological      condltlons         existing
at the plant site.       These condltlons       primarily        involve the
nearly Impermeable ~011, silty         till,    In which the waste
tanks are burled.       Geological    calculations       submitted to AEC
show that groundwater movement 1s extremely               slow In this
silty   till  and that It would take about 40,000 years for
high-level    wastes to move through this silty             till      from the
point of storage to the nearest ravine.

        During our vlslt    to the plant site, we were advised
by the company that It was provldlng             for segregation       of
low- and high-level      solld wastes in Its solld-waste-burlal
practices     but that It was not provldlng           for possible re-
trieval     of wsstes known to contain transuranlum             nuclldes
because of the lmpermeablllty          of the sosl and the lnsolubll-
lty of these types of wastes             We were advised by AEC that,
although Nuclear Fuel Services         I  license did not require re-
trleval     capability,  then-current       studies might result        In
proposed amendments to AEC regulations              ldentlfylng    certain
plutonium-contaminated       wastes as unsuitable          for disposal
onslte or at licensed,       privately      owned ground-burial       facll-

       The plant's    normal disposal system for low-level          llquld
wastes contains monrtorlng       and mechanlcal provlslons        for
mlnlmlzlng    the accldental    discharge of high-level      llquld
wastes through Its ldentlflcatlon          and dlverslon  into the
handling system for high-level        llquld   wastes before a slg-
nlflcant   amount 1s discharged into holding ponds for low-
level llquld     wastes.
General    Electric

        In November 1966 General Electric    applied to AEC for a
lrcense to construct    the Mldwest Fuel Recovery Plant on a
site of approximately     1,300 acres located southwest of
Joliet,    Illinois.  We were informed by General Electric      that
the plant was scheduled to begin operating        late In 1971,

        The plant's   high-level      liquid    wastes are to be calclned
Into solid form and stored under water in sealed containers,
rather than accumulated in steel tanks.                  The plant has been
designed so that no potentially              contaminated      liquid-effluent
stream will be released.           This 1s to be accomplished by
utlllzlng     a closed-loop     system for the recovery and recy-
cling of process water and by providing                a steel-lined        con-
crete vault for the retention            of concentrated         low-level
liquid    wastes as a slurry which will            solidify      on cooling
into a salt cake.        After treatment        for removal of radloac-
tlve iodine and partlculates,            low-level     radloactlve        gaseous
effluents    (krypton    and trltlum)       will be released Into the
atmosphere through the plant's             stack.    For solid-waste          bur-
ial, General Electric        plans to utilize        a stalnless-steel-
lined vault which will contain 9 to 10 years'                    accumulation
of dumped fuel hardware, leached fuel hulls,                   and contaml-
nated small equipment.          General Electric         believes      that this
design provides no barrier          to waste retrieval           and transfer
to separate permanent disposal faclllties.

     In June 1968, General Electric's                construction      permit
was amended by AEC to provide that

       "In the event the Commlsslon establishes             a pol-
       icy and regulations     for ultimate     dlsposltlon      of
       fuel reprocessing    plant radloactlve       wastes, the
       Commlsslon may require       the applicant    to remove
       from the *** [plant]      for storage at a regional
       or national   disposal site designated by the
       Comrnlsslon the radioactive      wastes particularly
       the high activity    wastes stored inside the
       *** [plant]."

     General Electric    agreed to this amendment on the basis
that It recognized    the incentive   for avoiding proliferation
of waste disposal sites.      General Electric    Indicated,

however, that there might be instances where waste transfer
operations      present greater risk than immobilization      and
long-term      protection   at the interim-storage   point.   General
Electric     informed us that any decision to require retrieval
and transfer       of wastes should be based on evaluation       of
relative     risk exposure, made in the light      of the latest

Allled-Gulf    Nuclear   Services
      On November 7,     1968,    Allled Chemical Nuclear Products,
Incorporated  applied     for    a construction   permit to construct
the Barnwell Nuclear      Fuel    Plant-- a 1,500-metric-ton-per-year
reprocessing  plant--    on a    1,706 acre site adJacent to AEC's
Savannah River Plant.

       In March 1970, Allled and Gulf General Atomic,Incor-
porated (renamed Gulf Energy and Environmental           Systems,
Inc.)    formed a partnership    for the construction     and opera-
tion of the plant which was estimated          to cost about $65 mll-
llon.     This  partnership   became   a coapplicant  with Allied
and Gulf Energy under the name of Allied-Gulf          Nuclear Ser-
vices.      Under the agreement between the two companies, Allied
has the prime responsibility        for design, construction,     and
marketing     operations.

       The Barnwell plant is to have controls,           Jointly    with the
AEC plant,     to ensure that routine      low-level    radioactive
effluents   released into the environment          from the two plants
will be within     established    AEC llmlts.      The high-level
wastes resulting       from chemical reprocessing       are to be stored
in acidic form in stalnless-steel          storage tanks which, in
turn, are to be contained in stainless-steel-lined                concrete
vaults     Allied-Gulf     informed us that this method of stor-
age had been selected for the following            reasons.

       --'Ihis   method would allow the company to maintain the
           options to recover potentially  valuable by-products
           from the wastes.

       --Experience       with the storage of radioactive    wastes
          had shown that storage of an acid solution          in
          stainless-steel      tanks was more reliable    than alterna-
          tive storage methods

       --Studies   of the various    alternative     methods      of stor-
          age of high-activity    -wastes had determined          that the
          storage of acid solutions       ir stainless-steel         tanks
          would be the most economical method.

       --Under this method Allied-Gulf           could solidify  the
          wastes at some later  date, if         required  by AEC to do

       Allied-Gulf     also plans to install        additional    stainless-
steel tanks so that at all times there will                be available
enough tank capacity        to allow any tank in use to be emptied
in the event that there are problems with the tank.                   In
addition,     Allied-Gulf    will   install   the tankage required        for
evaporated     intermediate     wastes.     As these wastes are accu-
mulated,     development programs -gill be carried           out to deter-
mine the optimum method of ultimate             disposal

        We were informed by AEC that in April         1970 the AEC reg-
ulatory     staff,    with assistance    of Government consultants,
completed a technical         safety review of Allied-Gulf's       pro-
posed plant based on its amended preliminary            safety analy-
sis report          The amended report    provided rnformatlon     in
response to questions        raised during AEC's review and on
Allied-Gulf's        changes in the process and facility       design
as a result        of its continuing    safety review and discussions
with AEC The construction            permit was issued on Decem,
ber 18, 1970.

Atlantic-Richfield       Company

       In April 1969, the Atlantic-Rlchfleld        Company submitted
a preliminary    srte evaluation   report    to AEC for review of
the suitability     of a site near Leeds for a chemical-
reprocessing    plant.   The proposed site,     which consists  of
approximately    2,500 acres, is located about 60 miles north
of the Savannah River Plant.

      After a review of the preliminary      site evaluation    re-
port and a visit    to the proposed site,    AEC indicated   that,
although the report was not sufflclently        complete for a
formal review,   the proposed reprocessing      plant and site
might be approved If further     evaluations    were made by

Atlantic-RIchfIeld       and lfncorporated  in a prellmlnary safety
analysis     report   submltted  In accordance with AEC regulations.

       Atlantic-RichfIeld         submitted     Its appllcatlon   for a
construction       permit to AEC on October 29, 1970, for the
Atlantic-RichfIeld         Reprocessing       Center.  The accompanying
prellmlnary       safety analysis        report included preliminary       pro-
cess and faclllty         designs which Indicated        that Atlantic-
Rlchfleld     would generally        utlllze    the same technology     as
would the Allied-Gulf          plant.


       In developing policies    for management of radioactive
wastes, AEC has concluded that llquld         storage In near-
ground-level     tanks 1s acceptable   only as an interim       mea-
sure and has considered and investigated          other methods for
long-term    storage.   From the standpoxnt      of safety,    AEC has
decided that solldlficatlon      of hlg'h-level    radioactive    liq-
uid wastes and storage of the solidified          waste in salt for-
mations 1s the best known approach to isolate           t'hls waste
from the biosphere.

Pro.ject   Salt   Vault

      As the result    of the National        Academy of Sciences'
recommendations,     AEC inltlated       studies at Oak Rxdge in 1959
on the disposal of high-level           solid wastes.    The objective
of the Oak Ridge program on radioactxve-waste             disposal   in
underground formations      was to demonstrate        the equipment and
operations   necessary to carry out a safe and economical
disposal   of high-level     solidlfled      wastes in salt mines.

        During the 1960's, &EC's reseaxsh GUMIdevelopment ef-
fort was directed        toward establishing      the suitabllxty    of
utilizing     underground salt formations         for the disposal    of
high-level      sohdLfied     radioactive    wastes.    The research and
development studies included the demonstration               of disposal
of high-level      radioactive      solxds in a bedded salt mine.        As
a result     of these studies,       AEC is of the opinion that salt
disposal     technology has been developed to the point where
confidence      can be placed in engineering         a system which is
practicable      and which will provide assurance of long-term
isolation     of 'high-level     radloactive   wastes from the envlron-

Federal    repository

       In June 1970 AEC announced the tentative              site selection
for an initial     salt mine repository      demonstration         project.
Current plans include site acquisition,              construction,       and
operation   of a demonstration      facility     for long-term        storage
in mined salt vaults     in central      Kansas,      This facility       will
accommodate both solidified      high-level        liquid   wastes and
plutonium-contamlned     solld wastes.

     An illustration  of the demonstratzon            project   provided
to us by AEC is on the following  page.

       AEZ Informed us that over t'he next year geologic and
safety studies would be conducted by the National     Academy
of Scrences' Committee on RadIoactive     Waste Management to
conflrm that all aspects of the operation     at the selected
locatlon   can be performed safely.

        AEC stated that,     on the basis of preliminary        studies,
radloactrve     wastes would be buried in a salt mine 1 square
mile In area and 1,000 feet below the surface.                AEC esti-
mated that,      on the basis of fiscal      year 1971 dollars,       the
lnrtlal    capital    outlay for a facility       to handle waste gen-
erated by commercial reprocessing           plants would amount to
$25 million     and that annual operatrng         and capital   costs
would amount to $150 mlllion        over the first      20 years.       AEC'S
published policy provides that these costs be recovered
from the users of the repository.

        AJX estimates   that preparation        of a salt mine for long-
term storage of radioactive         wastes will require approxi-
mately 4 years after authorized           funds are avallable.        AFC
plans to seek authorization         for the Initiation,       during fis-
cal year 1972, of a demonstration            repository    to provide ad-
ditional    technical   data and experience on operational            metb-
ods and costs of long-term        storage of solldlfied         wastes
which are generated by commercial reprocessing               plants,    AEC
informed us that, although the faclllty              was termed a demon-
stration    repository,    It antlclpated       that the facility     would
be designated as the initial         Federal repository.

                                                      ORNL-DWG   63-23912



        In June 1969, AEC published     its proposed regulations
for the siting    of commercial fuel-reprocessing         plants and
related    waste management facilitres      and lnvlted    comments
from Interested    parties.     The proposed regulations       were de-
veloped with a view to provide industry          with the informa-
tion needed currently       to develop designs consistent       with AEC
requirements    and with the obJective      of lsmltrng    the number
of hrgh-level    waste disposal repositories        in the country.

       The proposed regulations     provided that the high-level
liquid   wastes generated at a reprocessing         plant be stored
at the plant for as long as 5 years before conversion            to
solid form and that shipment of the solid wastes to a Fed-
eral repository    be required   within    10 years after generatlon
of the liquid wastes.       The regulations     provided also that,
upon receipt    of the solid wastes at a designated Federal
waste repository,     the Federal Government assume physlcal         re-
sponsibility    for the material    but that industry     be required
to pay for the costs of perpetual         storage and disposal

       In summary, the companies involved in reprocessing
plants--Nuclear     Fuel Services,      General Electric,      Allied-Gulf
Nuclear Services,      and Atlantic-Richfield--in         commenting to
AEC on its June 1969 proposed regulations,            stated that the
regulations     did not clearly     explain important      safety,    eco-
nomic, and technical      considerations.

        Nuclear Fuel Services expressed the oplnlon that the
proposed regulations,           as stated,     would be illegal        when ap-
plied to exlstlng        licenses.       Allled-Gulf,       Atlantic-RIchfield,
and General Electric          indlcated,ln      general,     that the regula-
tions failed       to clearly     establish     solldlficatron        and trans-
portatlon     crlterla     and repository       charges        The companies
recommended that adoption of the regulations                    be withheld     un-
til   such conslderatlons         were answered

        Offlclals      of Nuclear Fuel Services informed us that the
proposed regulations,          if adopted, would have a substantial
adverse economic effect           on their operations     and would upset
certain      agreements and business arrangements entered into in
good faith        in reliance    upon previously   established   AEC poll-

         In general,     General Electric's       planned operation        of Its
reprocessing        plant ~~11 be In accordance with the proposed
regulations       In that the wastes will be In a solldlfled                 form,
packaged in containers,            and held at its plant pending final
disposal       General Electric        offlcrals     told us that the effect
of AEC's not establrshlng            cask and waste-container         crlterla
had caused problems In determInIng               and deslgnlng what Gen-
eral Electric         considers   to be an Integral        part of reprocess-
Ing plant's      waste faclllties           In addltlon,     they stated that
there was a need for AEC to release background criteria                        for
evaluating     alternative       disposal methods for high-level
wastes and the risk-benefit            relatlonshlp      for onslte disposal
versus offslte         shipment      They lndlcated      that offslte      ship-
plngtobe      utlllzed      during decontamrnatlon         of reprocessing
facllltles     upon decommlssronlng           should be evaluated on the
same basis
        Although Allled-Gulf     and Atlantic-Rlchfleld        had not ob-
tanned construction      permits at the time AEC proposed Its reg-
ulatlons,     both companies apparently       had selected,     as lnterlm
methods of storage,      high-level   llquld-storage       systems that
would include the use of stainless-steel             tanks     We were in-
formed by an AEC offlclal        that both companies had selected
this form of storage,        In part, to allow for enough flexlbll-
lty   to dispose of the high-level       wastes as national       policy

      On November 14, 1970, AEC publlshed       In the Federal Reg-
lster  revised regulations     to be effective   within  90 days
In revising   the regulations,    conslderatlon   was given to the
comments made by industry      on the proposed regulations    pub-
lished In June 1969

        The June 1969 proposed regulations             provided that radio-
active hardware resulting          from operation        of commercial re-
processing        plants be disposed of In the         same manner as solld-
ifled    radloactlve      wastes or at a licensed          Federal or State
burlal     facility;     however, this provlslon        was not included in
the November 1970 regulations             We were      informed by AEC that
further      conslderatlon     was being given to        the alternative
techniques        for dlsposlng   of solid wastes        and that regula-
tlons on these types of wastes would be                forthcoming

       The November 1970 regulations   state that (1) recent
AEC studies had Identified    the bases upon which repository
charges might be developed and had provided prehrmlnary           es-
tlmates and (2) shipments of solidafled      radIoactIve   wastes
should be transported    in accordance with exlstlng     regulations
of AEC and the Department of Transportation

       By letter    dated November 11, 1970, AEC advlsed Nuclear
Fuel Services that its operating           license would be amended
to provide that,       in the future,    kgh-level     radloactlve     llq-
uld wastes generated at its plant must be solidlfled                and
transferred      to a Federal repository,        in accordance with the
new regulations         AEC advised Nuclear Fuel Services also
that, with respect to waste generated prior to the effective
date of the new regulations,          AEC proposed to include provl-
slons in the amendment which would require             the solldiflca-
tlon and transfer        of the wastes by a deflnlte       future date
but on a schedule which would take into account the techni-
cal and economic conslderatlons          involved      AEC requested a
meetrng wrth Nuclear Fuel Services to discuss the appllca-
tlon of the new regulations         and to develop a schedule of
actions to be reflected        in the amendment to the license

        In accordance with AEC's current regulations,             Its reg-
ulatory    dlvlslons    are responsible    for licensing      and revlew-
ing the practices       of commercial reprocessors,        including    the
preparation      of the wastes for transportation        to a Federal
repository        After the commercially      generated wastes are
delivered     to the repository,     AEC's Division    of Waste and
Scrap Management is responsible         for the material

       The users of the Federal repository      are to pay the Fed-
eral Government a charge which, together with interest            on
unexpended balances, will be adequate to defray all costs
of disposal.       According to AEC, followang   authorlzatxon     of
the proJect     (expected in 1972) and the completion       of the de-
tailed   repository     design, a firm schedule of repository
charges will be developed and published.

      AEC regulations   provide that high-level       radloactlve
wastes stored at fuel-reprocessing         plant sites be trans-
ferred to a Federal repository        In the event a plant is de-
commlssloned and that,     for future fuel reprocessmg          plants,
a design obJective    be to facilitate      decontamination     and

removal of all slgnlficant      radioactlve  wastes from the plant
sites In the event of decommlssionlng.         Ultimate disposal   of
high-level  radioactive    waste material   will be permitted    only
on land owned and controlled       by the Federal Government.

                               CHAPTER 5


      In the preceding chapters,    we have discussed AEC's
progress In resolving  its radioactive-waste     management
problems, as well as the difficulties      that still    remain
with respect to both the interam and long-term        storage of
the wastes.

       We have pointed out that AEC installations         have expe-
rienced delays in Improving the capability           for handling
interim-stored       wastes at their    sites and in developing
long-term      (centuries)     storage methods for large volumes of
wastes because of budgetary considerations           and because
long-term-storage         methods have not been defined and ac-

      Although various plans and methods have been or are
being developed,   ARC has not established       an overall  coordi-
nated plan for resolving     Its waste management problems and
achieving   its obJectives   at all installations.       Requests for
the necessary funds to implement waste management plans are
made and considered     on an individual-program     basis.

       We believe that, although ARC has assigned a high pri-
orlty    to radloactlve-waste      management, the level of effort
given to the program should be increased in view of its ex-
traordlnarlly       complex characteristics.        The problems and
delays being experienced         In the lmplementatlon      of ARC's
pollcles      for the management of radioactrve        wastes are prn-
marily attributable        to a need for more definitive        technol-
ogy on such matters as the relative           merits of various prac-
tices and proposals        for interim    and long-term    storage.

         In the past and currently,    ARC management has empha-
sized and has given priority        to the development of technol-
ogy and plans with respect to ARC's weapons, productson,
and reactor development activities        whch result    in the gen-
eration     of radloactrve  wastes and to the safe containment
of radloactive      wastes on an interim   basis..  A lesser degree
of management emphasis and prlorlty        have beengivento    the
actlvltles     dealing with the long-term    management of such
      In view of the large quantrties           of radioactive       wastes
at AEC operational     sites,     the continued generation         of such
wastes at these sites and AEC's forecasts              of the relatively
large volume of such wastes that will be generated by lr-
tensed fuel-reprocessing        plants,    the importance of develop-
ing and implementing      policies      and practrces    for long-term
waste storage cannot be overemphasized.               AEC recogrmzes
that vigorous     management attention        must continue,       to re-
solve existing    problems and reach appropriate            decisions     on
a reasonably   timely basis and to recognize and resolve any
future radioactive-waste        problems as they develop.

       AEC's decision  in June 1970 to develop the salt mines
for potential    use as a Federal repository         for commercially
generated wastes and its announcement In November 1970 of
waste management regulations       for private     industry    are major
milestones.    If the development of a Federal repository
proceeds on schedule and proves successful,the              commercial
operators   should be able to avoid the waste management
problems of the types experienced         in the past by AEC when
the lack of technology    resulted      in the accumulation       of
large volumes of high-level      liquid    wastes.

       We believe that, to provide greater assurance that ap-
propriate    priorities  are assigned to the overall    waste man-
agement program, AEC should further       develop and consolidate
its plans for resolving      waste management problems into an
overallcoordinatedplan.        Such a plan should provide the
following    informatson  for each type of radioactive    waste
generated by both AEC and private      industry   at the various
locations     involved.

      --The current      status of the waste management program,
         both interim     and long-term projects.

      --The specific  actions       necessary       to resolve existing
         problems and achieve       acceptable       waste-storage   goals.

      --The time frames       over which    these     actions    can be
         carried out.

      --The estimated   costs involved,          by fiscal      year,   In
         carrying out these actions.

       We recognize that,    because of geological     and other
conditions    at the various AEC operational      and private    In-
dustry sites and because of the differences          in the types
of wastes, t'he same procedures and practices         may not be
applicable    Ln all cases.    We believe,    however, that the
consolidation     of such plans into a detailed      coordinated
plan would better     serve to Identify    the actlons needed to
resolve existing     waste management problems on a reasonably
timely basis.

       Such a plan would provide both AEC and the Congress
with information    regardrng    the required    funds and, if it is
not feasible    to provide all t'he required       funds, the plan
would enable priorities      to be established,       after conslder-
atlon of the relative     costs and benefits       of the various
alternatlve   uses that can be made of available           funds.   F'ur-
ther, by establishing     specific   target dates for the resolu-
tion of these problems, areas In which firm decisions              are
required would be hghlighted        and consideration        could be
given to the proposed solutions        and actions needed to make
the necessary decisions.

      For instance,     it is our opinion that, wit‘h such a cen-
tral overview,    final    evaluation of the bedrock concept at
Savannah River, which has been under study for about 9 years,
could be expedited and thereby limit        the expenditure      of
funds for the study of alternative       solutions     and minimize
the need for funds to provide additional         interim-storage


      In our May 1968 report,       we recommended that:

      "*** consideration     should be given to the desir-
      ability    of vesting  responsibility      for policy mak-
      lng and overseeing the waste management program
      in a single AEC office      at a level sufficiently
      hgh so that it can efficiently          and economically
      coordinate    the program and assume the authority
      necessary to make decisions         concerning long-
      term storage methods, with all of the implica-
      tions which such decisions        encompass."
Action was taken to implement this recommendation in May
1970, when AEC established  the Division of Waste and Scrap

       We now recommend that the Division              of Waste and Scrap
Management give its immediate attention                to consolidating
and implementing      the overall    radioactive        waste management
plan described above.         We believe that, when such a plan
has been established,       this Divlslon       should be assigned
responsibility     (1) for recommending priorities             for waste
storage methods and for coordinating             the conduct of re-
search and development of waste storage methods to meet
thesepriorities,      (2) forrecommending        long-term     storage
methods, (3) for establlshlng          criteria      for interim     storage,
 (4) for reviewing     and evaluating       the progress made by the
program divisions,      and (5) for coordinating           matters affect-
ing both AEC and private        industry     waste management prac-
txes    with AEC program and regulatory            divisions.

        AEC officials      informed us that the Divxsion of Waste
and Scrap Management had been asslgned the responsiblllty
for developing        and implementing     a plan for the storage of
high-level     radioactive       wastes from licensed     facilities    in
the proposed Federal repository            in Lyons and for managing
AEC's alpha, or plutonium-contamrnated,              wastes throughout
AEC. These officials            stated that the Division       had been
directed    to coordinate        the consolrdation    of an overall     AEC
plan for radioactive          waste management.      They stated also
that the plan, which would be largely              a consolidation    of
plans developed or being developed by various AEC divisions,
offices,    and contractors,         was expected to be completed
early in fiscal        year 1972 and that it would be updated as
required    to reflect      major needs and developments in waste
management activities,

      We were told that the Dlvlsion          had been or would be
assigned the other responsibilities            cited in our recommenda-
tion,    The Division    currently     has responsibility     for review-
ing and approving or disapproving,           in consultation     with
cognizant program and staff dlvislons,             waste management
plans of AEIC installations.          This responsibility     carries
with it the responsibility         for monitoring     progress of per-
formance under such plans, including            progress toward ac'hiev-
ing overall   AEC plans and objectives.

        Under present organizational      arrangements, the Divi-
sion of Production wrll continue to have primary responsi-
brlity for the management of high-level radioactive wastes
from AEC fuel-reprocessing      installations,    fncluding respon-
sibility    for research and development of long-term storage
methods for such wastes.
      AEC advised us that the Division's activities  would
be conducted in accordance with the approved overall waste
management plan and that Its efforts to develop or improve
storage methods would be coordinated with the Division of
Waste and Scrap Management. Also various budget and organi-
zational alternatives  within AEC are being considered to
determine the best method of ensurrng that the approved
overall waste management plan will be effectively   imple-

                               CHAPTER 6

                            SCOPEOF REVIEW

        We examined into the progress made at AEC's Idaho, Rich-
land, and Savannah River Operations            Offrces--located     at
Idaho Falls,      Idaho, RIchland,     Washlngton,     and Alken, South
Carolina,     respectlvely--  In the development and lmplementatlon
of solutions      to problems assocrated with lnterlm           and long-
term storage of high-level         radroactlve     wastes, as discussed
In our prior report to the Joint Committee.                We also made a
llmlted    review of selected aspects of the waste management
actlvltles      at the Oak Ridge National       Laboratory,     Oak Ridge,

        We examined also into AEC's pollcles         and procedures    for
burying radloactlve       solid wastes at the four locations        men-
tioned above.      In addition,    we considered AEC's proposed
regulations    for the management of liquid waste expected to
be generated by the expanding clvlllan           nuclear power lndus-
try and the technology        being developed by AEC for the trea-t-
ment and long-term       storage of these waste materials.         Our
examlnatlon    included dlscusslons      on current and future waste
management activities        with two companies which are operating,
or plan to operate     ,  private  radloactlve-waste     reprocessing

      Nuclear Fuel Services,       Incorporated
      West Valley, New York,       and Wheaton,    Maryland

      General   Electric    Company
      Morris,   Illinois,    and San Jose,    California

      Our review was concerned prlmarlly          with the management
of radioactive   waste generated In the reprocessing           of lrra-
dlated nuclear fuel.      We  did   not  examine    into  the waste
management actlvltles     being carried       out in connection with
the operation   of reactors,     laboratories,      and test facllltles
at the four AEC lnstallatlons        included in our review.


                                  October     24,     1969

Honorable   Elmer    B. Staats
Comptroller    General    of the Unlted            States
U S General     Account-g      Office
Washmgton,     D C

Dear   Mr     Staats

          In conslderatlon        of the Committee’s          contmumg      interest     m radlo-
active waste management             actlvltles     by the Atormc       Energy     Comrmsslon
and because       of the results     of the General       Accounting      Office Review         as
reported    to us on May 29, 1968, we would like your Office to perform
another    review     of this program         to follow up on your prior          findings
However,      before    your Office physically          starts    another    renew,       I think
that you should obtain from the AEC answers                     to the many questions
that were generated          by statements        m the 1968 report           Ths ~111
establish    a common        ground    of what AEC has accomplished                 versus
what they said they hoped to accomplish.

         We have drawn up a tentative     list of questions,    whch   are attached,
When we have the answers,       we should know which areas m the waste
management     field require intensive   exammatlon      and which areas can
be examined    superflclally    We would appreciate       any comments      you
might  care to make on our idea of how to conduct         this reexammatlon
and on the list of questions

                                                    Edward    J   X[kuser


   Page 2

             QUESTIONS       TO THE     ATOMIC  ENERGY                 COMMISSION      ON WASTE
(Page references      are In “Observations     Concerning      the Management       of High-
Level   Radloactlve    Waste Material”,    GAO Report      No B-lb4052,      May 29, 1968,
           1     Page 12, paragraph     1’ Has AEC developid        standard    criteria      for
reserve   storage    cagaclty?    On an agency-wide      basis?    On a specific      location

         2     Page 12, paragraph     1 Has a decision   been made on re-usmg     tanks
which have been emptied?        Why would such tanks be emptied?      Does “emptied”
mean completely     emptied   or drained   to a certam level?   Why IS the ‘%e-usmgl’
of empty  tanks questionable,     what 1s the probable  hazard?

          3    Page 12, paragraph              2 Have any further           data been evolved   which
would indicate   what the true life            of the Hanford tanks         might be--l  e , 10, 15,         or
20 years7

             4     Page 13, paragraph           2 What has the AEC accomplished           since        the
last   review    to
                    a. Advance         the technology   of long-term   storage   at Rlchland
                    and Savannah         Rlvcr?
                    b      Arrive    at “best”   method  for ceslum  and strontium      solldl-
                    flcatlon      and encapsulations

             Page 14, paragraph
             5                        1 What has the AEC done with regard                       to
organlzlng a single offlce with oversight    of the entlre waste management                          pro-
gram at AEC facllltles’    Specifically

                  a     Which dlvlslon        In the AEC has primary        responslblllty     for
                  waste disposal         matters     under the cognizance      of Rxhland     Oper-
                  ations   Office,      Savannah     River  Operations    Office,   and Idaho
                  Operations       Office    respectfully’     [Page 7, paragraph          l]

                  b     Does the Dlvlslon      of Production  (DP) coordinate   through
                  each concerned       Field Office with the Contractors,     or does
                  It dictate  procedures      to the Field Offices,  or IS some other
                  procedure    used?      [Page 7, paragraph      Z]

                        Does the Dlvlslon     of Reactor    Development and Technology
                  ~DRDT) coordmate        with DP, or does DRDT coordinate         anly
                  through    each concerned      Field Office with the contractor7
                  [Page 7, paragraph       41

*Paragraph       numbering     starts   with     first   full   paragraph

                                                                                                     Page 3

                      d    What authority    does the Dlvlslon      of Operational     Safety
                      (DOS) have to enforce      the standards     lt develops?      Hov, do
                      these standards     compare    to Federal     Radiation    Council
                      standards’?    Does DOS work directly         with contractors      or
                      only with Field Offices      or both?    [Page 7, paragraph        33

                      e    Do DOS, DP, or DRDT collectively               or lndlvldually                     ’
                      compare     standards     established     for AEC facllltles       with
                      standards    the Dlrector      of Regulation    establishes     for non-
                      AEC facllltles?       [Page 8, paragraph        l]

             6   Page 14, paragraph         2 Is it contemplated     that an AEC smgle-
point waste management           office would cover both AEC facllltles           and commercial/
mdustrlal/academlc       facllltles3        Would or could such an authority          operate with
the same set of regulations           for all high Level waste   storage   facllltles7

            7         Page 15, paragraph      2 Has the AEC              review     of its   organlzatlonal
structure       for    waste management       been completed7              Are    reports     available?

           8  Page          15, paragraph     3 What reports,      plans,   or research  has the
waste management              panel of the Natlonal  Academy      of Sciences    (NAS) completed
or undertaken   for         the AEC’J     Are any reports   available?

           9    Page 18, last paragraph     Is there                   any slgmficant difference     m waste
generated    by commercial    spent fuel processmg                      plants and AEC plants    processing
fuel elements    from AEC production     reactors?

            10        Page 20, paragraph        1 After         7 or more     years,    why 1s the AEC            still
experimenting           with three or more       methods         of long-range,      high-level  waste

            11 Page 20, paragraph            1 Does the AEC stand behmd the statement
“With respect     to the use of salt structures         for the storage     of its radioactive
wastes,     AEC  has   no   present  plans    to  store   its  high level wastes   In this manner,
even If the program        IS proven     to be feasible     because   the proposed    approaches
appear    to be adequate      and addltlonal     expenses     do not seem necessary        at th1.s
time    “3 (underl.me     IS added for emphasis)

             12       Page 20, paragraph        1 What          were   the   results   of the AEC        salt
mme     storage       experlmentp     Any     reports?

        Page 4

               13     Page 26, paragraph            4, and page 27, paragraph               3 What 13 the
basis for the Dlvlslon              of Production        statement      (Page 27)        ”    bedrock     storage
constitutes        for the Savannah          site a potentially        safe, practical,        and economical
arrangement           from the standpolnt           of providing       a solution     to its long-range       waste
 storage      problem        ”   When    (see   Page    26)   a  maJorlty    of   a  committee     of the    Earth
Sciences        Dlvlslon       of the Natlonal      Academy        of Sciences      in a 1966 report      ex-
pressed        strong     reservations        concerning       the bedrock      concept     of waste    storage
and recommended                that lnvestlgatlons        be dlscontmnued?           What was the AEC
JUStlflCatlOn        for relying       on the minority        concept?

           14      Page 28    Can DP Justify the calculations    which indicate    expenditures
of $lOO-$500       mllllon for other than bedrock  storage    at Savannah   River’

            15    Page 40, paragraph      2 On Page 12 It IS stated that tank service
life could be 10, 15, or 20 years,        on the top of Page 39 It IS stated that carbon
steel tanks might      last 20 to 40 years,    the second paragraph           onPage   40 states
“This matter      1s of concern  because,     according      to AEC, there 1s not enough
experience     with the service   life of exlstlng      storage   tanks to reach experienced
conclusions     I1 Are any of the above listed        statements     correct’      Which=’

                                                                                        Page 5
                                         UN   ITED    STATES

                        ATOMIC           ENERGY          COMMISSION
                                   WASHINGTON           D C    20545

                                                          November     21,   1969

Mr. Dean K. Crowther
AssIstant Dlrector
AEC Audrt Staff,   GAO


Reference    1s made to the letter         from the JCAE to the Comptroller
General    of the Unrted      States,   dated October     24, 1969, requesting
the General     Accountrng     Office   to obtarn    from the Atomrc Energy
Commlsslon    answers      to questions    generated    by statements  in the
1968 GAO Report      on Radroactlve      Waste Management

I am enclosrng     for your rnformatron     and further consrderatron,
AEC's answers    to the lrst   of questions    attached to the letter.
I would appreciate     any comments you may wish to make concernrng
these answers.

                                                      'John     A Erlewlne
                                                        Assistant    General        Manager
                                                             for Operatrons

AEC's Answers      to       Questions,

    Page 6
1.   Q.    Page         12,         paragraph                     1        Has AEC developed                                standard              crlterla                     for

           reserve              storage                    capacity?                   On an agency-wide                             basis?                  On a

           specific-locatlon                                    basis’

     A.   As noted                  rn the                 previous              GAO report                    on waste              management,                        the

           crzterla                 for         reserve                storage               capacity             at        each      site            were             established

          by that               site.                    These         crlterla                were       generally                  the         same at                all

           three          sites                in        provldlng               spare           volume           equivalent                     to     one tank.

          In      the          past        year             the        Division                of Production                        has developed                        crlterla

           for     reserve                 storage                 for        tank-stored                     wastes            in    conJunctlon                        with

          its       long            term             lsolatlon              program               which           it        feels         can be generally

          applicable                      at         all        sites.            The          field           offices           have            been            informally

          instructed                      to        amplement               these              criteria                as soon            as possible.

          Accordingly,                          our        budgeting                   and program                     plans         have         been            consistent

          with          this          developed                    criteria                  which        1s to             be formalized                         in     the

          near          future.                     Line         item       proJects                   have      been          included                 in        FY 1970

          and 1971               budgets                   at      RL at          $10~~           and         slmllar            proJects                   at     SR are

          being          completed.                          The construction                             of     new tanks                  at        RL and             SR and

          the      conversion                            of waste           to         solid          makes        available                    tank         space

          for      increased                        flexlblllty                   in         management                of      the     tank            farm            complex

          to     provide               spare               capacity               in         excess        of      the         criteria                defined

          below.               In      addition                   to      safety,               the       tank         management                     program                 as

          planned              improves                    assurance               of          operating               continuity.                      These             crlterla   are

          a)       At      least               one         spare          tank          will          be malntarned                    in        each             Integrated

                   tank          farm               complex                The spare                    tank       must         have         the        capacity

                   to     receive                    the        contents                of      the       largest              tank        in         the         farm

                   complex             e            In     tank          farms          where          high        heating            wastes                 are         stored,
                                                                                                                                                  Page 7

         the         spare            tank          must         be capable                 of      storing                such     wastes

b)       In addition                      to        the        spare         tank        a total           working                 freeboard

         volume                 of    surge              capacity            of     at      least         one year’s                     operating

         requirements                         in         each        tank     farm          should         be used                 in     the

         scheduling                     of      new tank                 construction.                     The one year                         lead

         time            will         provide                 a reasonable                  margin            for      unforeseen                   delays

         In         construction                         of     tanks.

Because              nearly             all         of        the     tank-stored                  high-level                    wastes          are     at

the      Production                     s ltes,               the     criteria              are        essentially                  agency-wide.

However,                  the        speclflc                 lmplementatlon                     of     the         crlterla              at     each        site

is      dependent                    on the              avallablllty                of      the        necessary                  facilities.

Currently,                      Idaho         can meet                the     general              criteria.

At      Savannah                 River          the           general         crlterla                 can be met                  In H LIea             with

the      four             new double-shell                            tanks         which           are       nearing              completion,

One tank                  1s ready                 for        use     and the             remainder                 will          be completed

within              one or            two months

In F area,                      two new double-shell                                tanks           are       under             construction                 and

are      expected                    to be ready                     by the         first             quarter              of     FY 1973               The

equivalent                      of    one tank                 will         be malntalned                     In the              F area         tanks

until              the     new tanks                     are        completed             (by         evaporation                  of      exlstlng

wastes              or by            transferring                     wastes             to H area              via         the         interarea

line          if         necessary).

   Page 8
          At Hanford,                     there         are     currently                two      single-shell                  spare           tanks

          in both          the        Purex             and Redox            areas.               At Purex             (the       only          active

          tank      farm),            two          new double-shell                       tanks           which        are      under         construction

          are     scheduled                  for        completion              by       the      first        quarter           of      FY 1971.

          Additional                 double-shell                  tanks          are          planned         on a schedule                     to

          maintain             compliance                  with        the      general            criteria.

2.   Q: Has a declslon                        been         made on re-using                        tanks          which         have       been          emptied?

          Why would                 such      tanks            be emptied?                 Does           “emptied”             mean completely

          emptied          or drained                     to    a certain                level7            Why IS the               “re-using”                 of

          empty      tanks            questlonalbe,                      what        1s the          probable              hazard?

     A:   The declslons                     to reuse              single-shell                    tanks        must        be made on a case-

          by-case          basis.                  Although            single-shell                  tanks         will         bz avallable                   for

          use,      our        plans          are         to    store        newly          generated              high-heating                   wastes

          only      in     double-shell                        tanks      when        these          tanks         are        a\,nlldble               since

          these      tanks            are          of     improved           design.               All      of     the        new tank             proJects

          provide          for        double-shell                     tanks         and these              tanks          have       been        designated

          as the          lnterlm             storage             tanks         In    the         current          planning              of      the      overall

          waste      management                     program            at the         sites                Tanks          are    being           emptied             as

          a result             of     a program                 to convert                the      waste          to      a solld          form          for    safer

          interim          or        long          term        storage           (e.g.          fluidbed           calclnatlon                   at      the

          Idaho      Chemical                 Processing                 Plant           (ICPP)           and conversion                   of      llquld

          wastes          to     “salt             cakes”         by repeated                   evaporation-crystalllzatlon

          operations                 at     both          Savannah           River          and Hanford).

                                                                                                                          Page 9

The word           “empt led”            IS used                In an operational                       sense       i.e.,       removing

as much llquld                   as 1s possible                    with            pumps      or      Jets.         A heel           of   up

to    50,000          gallons           might           remain          in      the      tank.         Addlt      lonal

“emptying”             would        be performed                    on an lndlvldual                        basis         depending

upon       whether         the      tank           1s to         be re-used                 or retired            from       service.

Reusing          of    empty        tanks           IS not          necessarily                    questlonabte.                Englneer-

ing      studies          have      shown           that         high-heat               loads        can      impose        considerable

stress         upon       the     single-shell                    tanks,              and as noted               In an earlier

answer,          our      plans         are        to    use      the         new double-shell                    tanks        for

interim          storage           of high-heating                           liquid         wastes,           however,        we could

use these             single-shell                  tanks         that          have        been      tested        for      accept-

ability,           where         necessary                for     newly            generated            high-heat            wastes.

There       is     confidence                 in    the         reuse         of      single-shell               tanks       which

have       stored         only      low-heating                   wastes              and    they       are     being        reused

to     store        the    ITS      product,               new coating                   waste        and      other        low-heating


The stalnless                   steel         tanks        at     Idaho            are      reusable,

  Page 10
3)   Q:   Have any                 further              data        been       evolved           which          would            Indicate            what

          the      true             lrfe         of     the      Hanford           tanks         might          be--I.e.,                10,      15 or

          20 years             7

     A:   No further                   data            that     would          lndlcate               the      “true          life”         of    Hanford

          tanks          for          llquld            storage             have      been       accumulated.                         However,            our

          waste          management                     program             1s removing                1rqul.d          waste           from      tanks

          and      storing                 the         waste        as a solid.                  By about               1975          essentially

          all      but         the         current             waste         ~111       be In          solld           form        and all           llquld

          waste          would             be considered                     as lnterrm                storage              (5-7        years        - prior

          to     solldlflcatlon)                              using         prlmarlly            new tanks                 under         construction

          at     Rlchland                        These         new,         double-shell                    tanks       are        of    Improved

          desrgn          for             safer         handling             of    the     waste             and are             expected            to        last

          longer,              on the             average,             than        previously                 constructed                   tanks,

          Thus,          the         waste             management              program           places             less         emphasis            on long

          life      of         ranks             for      liquid            storage,            also         avallable                tanks       for          liquid

          storage              at      Rlchland                Increase            over         the      next         few        years         to provide

          ample          space             capacity             to     support            the         interim           storage            of     liquid

          waste.               However,                 the      long-range               proJection                  on waste             tank         life

          was a consrderatlon                                  at     the      time       planning              for        the        lnunoblllzatlon

          of wastes                  at     the         AEC sites.

                                                                                                                                                   Page 11

4)   Q:   Page      13,         paragraph                  2:       What           has      the         AEC accomplished                         since      the

          last      review             to      (a)         advance             the        technology                  of     long-term                storage

          at Richland                  and       Savannah                  River?                (b)        arrive         at      the      “best”        method

          for     cesium              and strontium                        solidlflcatlon                       and encapsulation?

     A:   Richland              --     Technical                  studies             have             concentrated                 on supportIng

          and     improvlng                   operation                 of     B plant                 in-tanksohdlflcatlon                              equip-

          ment.         A revised                    analysis                 of     the     hazards                 associated              with        long-term

          storage           of        the      in-tank                 solldlflcatron                         (ITS)        product           LS ln’preparatkon.

          A deep          hole         has been                  drilled             to     explore              the       basalt           formations

          under       the            chemical              processing                 areas             as a possible                     relocation

          alternative                  for       the        tank-stored                     wastes.                  The first              results         of

          the     deep          hole          were         encouraging                     but         more      extensive                lnvestlgatlons

          would       be needed                  to        establish                 feaslblllty                     of     the     concept.              The

          best      method              for      ceslum                and     strontl\,m                   solldlficatlon                   and       encapsulation

          have      been             selected,                  technical             and engineering                             studies         are     provldlng

          support           to        a “design                  only”         proJect                 In     the      FY 1970            Congressional

          budget          for         the      facllltles                     to     solldlfy                 and encapsulate                     cesium          and


          Savannah              River          --      additional                    drilling                 and      selsmlc            studies         have

          been      completed                  to better                   define           the         geology             to     the      southeast

          or the          proposed                  site         for         the     bedrock                shaft          and caverns.                  The data

          collected                  to date           have            been        examined                 by a group               of     consultants

          who has concluded                            that            the     bedrock                 concept             shows         sufficient             promise

          to warrant                  the      next             step,         i.e.         HI situ             exploration                  of     the     bedrock,
  Page 12

     A copy        of        the    consultant’s                 report        (Attachment           3) “Permanent

     Storage            of    Radioactlve                  Separations          Process          Wastes    an Bedrock            on

     the     Savannah              River        Plant          Sateurs       attached.            A ‘IdesIgn        only”   prOJeCt

     in    the     FY 1970              Congressional                 budget        provides       for    design       and sate

     selection               drllllng           of     the      central        shaft      for     which    construction

     funds       will         be sought               later.

     Studies            have       been        inltlated           to     explore        alternatives          to    long-term

     bedrock            storage           of    the        Savannah        River       wastes.

                                                               Page 13
5)   Q. What has the AECdone with regaru to organlzlng a single office
        with overslght of the entire waste managementprogram at AEC
        facllltles?     Speclflca.lly.
        (a) Q: Which dlvlslon In the AEChas primary responslblllty for
                    waste disposal matters under the cognizance of Rlchknd
                    Operations Office, SavannahRiver Operations Office, and
                    Idaho Operations Office, respectively?
             A: The Dlvlslon of qroductlon has primary responslbzkty     Sor
                waste managementoperations at the SavannahRiver and the
                Richland sites, and for tne Idaho Chemical Processing Plant
                 (ICPP) operations at the Xatlonal Reactor Testing Stac;lon
                 (NRTS). The remainder of the waste dlsposjl o>eratlon,
                including the burial gromd at the XRTS, 1s the responslb;Lzy
                of RDT (except for the X3?, which is under Naval Reactors).
               At B'RTS,all llqu~d wastes which cannot be discharged to
                the surroundings are sent to the ICPP for treatment.
        (3) Q: Does the Dlvlslon of ProductIon coordinate through each
               concerned Field Office with the contractors, or does it
               dictate procedures to the Field Offices, or 1s some other
               procedure used?
            A. The Dlvlslon of Production coordinates through the Field
               Offuzes. Program guidance is provided by the Division of
               Production ana the Field Offices are responsible fo=
               conducting programs wiC'nln the guidelines.
        (c) Q: Does the Division of Reactor Development and Technology
               (DRDT) coordinate with DP, or does DRDTcoordinate only
               through each concerned Field Office with the contractor2
            A: The RDT and DP high level waste managementprograms are
               coordinated. This coordination has prlmarlly been at tne
               HQ level and has taken the form of many ~ns"ormal staff
               dlscusslsns and lnformatlon exchanges In areas of mutLca1

   Page 14

           2.nterest.        These exchanges gener,w;r 2.nvolve transmittal
           of special        reports, attendance at K.,c~T;.L,~,L02 JosaL xr,terest
            (NAS comixttee,         etc.)     and, in general,          Bz~~-~I:: each other
           abreast     of slgnlflcant          developments          IA dlvlslonal      waste
           management efforts.
           As part     of this      contlnulng        dla3ogue,       each dlvislon       I”rom
           time to tune sollclts              comments and technical            appraisals
           of slgnlflcant     elements in the programs of the other
           dlvislon.      For example, RDT was requested to comment
           through DP on the long range waste manage;uent plans silomtted
           by the Richland Operations Offlce.       SImllarly, the Dlvislon
           of Production          and Its     contractors       were asked to provide
           technical input and comment on the recently proposea
           Commlsslon policy on the sltlng of commerc&l. fuel
           reprocessing        plants       when this     RDT document was In zhe
           draft    form.      Most recently,           DP and Its      contractors      were
           asked to comment on the scope of work being carried                            out
           In RDT’s Waste Solzdlflcatlon                  Engzneerlng      Prototype      facility
           before    lnltlatzon         of the termxxI.         phase of this         experimental
(d)   Q:   What authority         does the Division            of Operational         Safety    (DOS)
           have to enforce          the standards         It   develops?      How do these
           standards        compare to Federal           Radiation      Councxl standards"
           Does DOS work directly              with     contractors      or only with Field
           Offices or both?
      A.   The standards developed by DOS, when approved by the General
           Manager and publlshed as Manual Chapters, are in fact
           dlrectxons     from the General Manager and enforcement 1s thus a
           responsLblilty      of each member of the management chain of
           command. In its appralsa2. role, DOS essentially      provides
           an internal      audit for the General Manager. DOS standards

                                                             APPENDIX I
                                                                Page 15
                   are comparable for FRC standards on those subJects on
                  which both have publIshed standards, however, DOSstandards
                   In either scope or detail cover subJects whzch the FRC has
                  not gone Into. DOSdoes not appraise contractors dlrectiy
                  nor make direct suggestions or recommendations to cor,tractors
                  on conduct of their safety programs. DOSdoes maintain
                  famlllarxty with contractor actlvltles    throagh plant vlslts
                  and technxcal dlscusslons, usually with Field Offsce safety
                   staff In attendance, as well as through reviews of written
          (e) Q. Do DOS, DP, or RDT collectively    or lndlvldually coapz,re
                  standards established for ARC faclllties    with standards
                  the Dlrector of Regulation establishes for non-ARCfaczhtw:
              A: ARC!Manual. Chapter 0517-025 designates the Director, DOS,
                  as provldlng a central point of coordlnatlon with the Dxrector
                  of Regulation and other groups, committees, or agencies,
                  In the development of codes and standards. Proposed cnarges
                  In. the regulatory code are usually circulated for comments
                  of DOS and of the program dlvlsxons and Field Offices having
                  experience in the subJect areas. The Division of Materials
                 Licensing has also requested DOScomments on safety analysis
                  documents submitted In connection Fnth lxcense applxatlons
                  for fuel reprocessing plants.   RDT, DOS, and Production ali
                 worked with RRGin preparatxon of the proposed ARCpolicy on
                  sxtlng of fuel reprocessing plants recently published uz the
                 Federal Register for comment.
In addltlon to these specific responses to specific questions, the folloxng
also applies to parts b, c, and d of this question. As a resuit of a GM
directive of November15, 1968, each Field Office 1s required to aevelop
detailed site plans for waste managementand to keep these plans updated..
These plans are to be submitted to Headquarters for review by OS and the
programmatic dl&ons      concerned wxth that sxtess operations.

     Page       16
6.   Q.   Page 14, paragraph                  2      Is 1t contam~l GLt~ that an AEC slnglc-

          PO&# waste management offlce                            would cover both AEC iacllltles                        ant

          commerclal/lndustr~al/academ~c                           facalltles?        Would or could such

          an authority              operate        with    the same set of regulations                for all            high-

          level       waste        storage     facllrtlesv

     A.   The question              appears to refer              to a suggestion       In the GAO report

          rather        than       to AX plans.             The concept of a single              office       responsible

          for      waste       management wlthln             AEC was considered           by the General

          Manager's Task Force In 1968                             After   review of this         study,           the

          General Manager concluded                        that    organlzatlonal       responslbllltles

          wzthxn       AEC for waste               management, should reman               essentially              as they

          are      assigned

          We had not            Interpreted          the GAO suggestion             to Include      centrallzrng

          responslblllty              for "commerc~al/lndustr~al/academx                         facllltxs"              as

          well       as AEC facilities.                   The only area currently           under      conslderdtron

          where most of these Interests                           appear to colnclde        1s the proposed

          Federal          repository        for     high-level        radloactlve      wastes         It     1s

          probable          that    all   wastes stored             at such a faclllty           would be sub:ect

          to these          requirements           whether from industry              or from AEC installations.

7.   Q.   Page 15, paragraph 2                       Has the AEC review          of Its     organlzatlonal

          structure            for waste management been completed?                       Are reports


                                                                                         Page 17

7.   A.   As stated       In the answer to Questron 6, the General Kanager's

          Task Force on Operational                 Radloactlve      Waste Management renewed

          this    subJect and reported              (August 1968) that          reorganizatloc        was

          not recommended, although                 certain     functions      of the Dxector,

          Dlvlsion      of OperatIonal        Safety,         were reempbaslzed.        The report

          of this      Task Force (AX         180/43) was provided              to the GAO previously

8.   Q.   Page 15, paragraph 3               What reports,          p lans,    or research     has the

          waste management panel of the Katlonal                         Academy of Sciences          (NAS)

          completed or undertaken             for the AEC3 Are any reports                   available?

     A.   At AEX's request,             the Academy Committee on Radloactlve                  Waste

          Management (CRWN) devoted most of Its                      lnltlal    year to vlslts

          to AEC rnstallatlons            where maJor radloactlve              waste management

          operations      are carried        out.      At AEX's request          the CRWMreviewed

          and commented upon the AK's                  proposed policies          on sltlng      of

          reprocessing        plants.       Copies of these comments have been given

          to GAO and have been sent to the JCAE

          The CRWM1s currently              preparing         a report     to AEC relating       to
          Its    actlvrtres     to date        When recexved,             the report   ~~11 be made

          available      to GAO and JCAE.

    Page 18
9)   Q:   Page      3.8, last   pzagrapn.       Is thtire        any   o~gr~3.2~c3nb         difference

          In waste genzratcd          by co~~ex~ai          spent 2x1            processing          plants

          and AX p&~is           pl ocesslng    fuel     eie; enLs from AX! produczlon


     A:   The wastes f&om the commercial                 p2xts     we’ll have higher

          radloac txvlty        content,    and higher      b.eat generaixon,                per unit

          volume than the corresponding                 AXC ?lh~c wastes,                 but the relatlva

          abundance of the different             r&d;onuclxdes            to one another wxi.l be

          sLmllar .       The commercal        wastes belore           solldxPlcatlon               wxll    have

          less volume per ton of fuel             than AX production                      wastes,     due to

          more advanced processes           and snysxcal          removal of claddlngs                     as

          solids.        Background material.          on -Lh~s general                subJect 1s being

          prepared       for use of the GAO staff.

                                                                                                  Page 19
lo.   Q.   Page 20, paragraph            1        After        7 or more years,         why 1s the AX
           still      experlmentlng        with     three o.c more methods of long-range,

           high-level        waste storage?

      A.   There 1s no single            best solution             for long-range,            high-level

           waste storage           whrch will       take into        account the varletles

           of wastes,        differences          In composltlon         and particular            envlron-

           mental      condltlons       at each of the AisC sites                   storing      radloactlve

           waste.       Therefore,       each site's            waste management program for

           long-term        storage     of Its      radloactlve        wastes has taken a differ-
           ent approach suitable             to the particular               sltuatlon          at that

           plant      or sate.        Idaho 1s using a fluldlzed-bed                     calclner.

           Rlchland       1s employing       the waste fractionation                   in-tank

           solldlflcatlon          and Savannah River               1s considering            caverns mined

           in the bedrock under the site                         The attached         article      (Conslderad

           tlons      for Long-Term Waste Storage and Disposal                           at 7J.S AEC

           Sites,"      Attachment         1 ),     goes into        the reasons in more detarl

           Also,      addltlonal       methods for waste management are under

           development        which would be better                 suited    for     licensed       cbmmerclal

           fuel      reprocessing       operations         and to serve as backup to an AX

           operation        provided     any one of the approaches currently                         being

           taken 1s not found to be acceptable.

   Page 20

11)   Q:   Page 20, paragraph 1.                  Does the AEC stand behlnd the state-

           ment        "With respect        to the use of salt          structures        for     the

           storage      of its     radloactlve        wastes,     ABC has no present            plans

           to store      Its     high level        wastes In this     manner, even if             the

           pr.ogram 1s proven to be feasible                    because the proposed approaches

           appear to be adequate and addltlonal                     expenses do not seem

           necessary at this             time?"

           (underline          1s added for emphasis)

      A    The AEC 1s studying             the feaslblllty         of storing     Its     high-

           level     wastes in salt         structures       but only as alternatives                to

           its     current     plans.      Because of the large volumes of wastes

           stored      at the Commlsslon's            chemical     processing     plant     sites,

           the Commlsslon 1s seeklng                 long-range     high-level     waste management

           solutions         which ~111 leave the wastes at these sites.                          Solldlflca-

           tion     of the AEC's wastes and shipment to salt                     structures          for

           long-term         storage    would be a very expensive            alternatlve           which

           may well      cost as much as $1 billion                to implement.          The programs

           that     the AEC 1s examining             should cost only a fraction                of the

           cost of removing             the wastes from the productlon             sites.

                                                                                                    Page 21
12.   Q.   Page 20, paragraph               1     Uhat were the results                    of the AX salt

           storage       experiment?            Any reports?

      A.   The operation          of ProJect           Salt Vault           (a demonstration           d~sposa?

           of high-level          radloactlve           waste sollds             In a Lyons, Kansas,

           bedded salt          mine, usmg Englneerlng                      Test Reactor         fueA assc-oiles

           In lieu       of actual        solldlfled         wastes) has successfully                    de-~o~~-

           strated      waste-handling            equipment and tecnnlques                     slmllaz      to

           those requrred          In an actual           waste disposal                 operatron.        A total .

           of about 4 mllllon              curies       of flsslon             product     actlvlty      In 21

           containers,          each having an average of about 200,COO curies

           was transferred           to the drsposal                faclllty        m the mine and back

           to the NRTS at the end of the test                                  During     the 19-month opera-

           tlon   of the radroactlve                phase of the demonstration,                       the average

           radratlon       dose to the salt              over the length                 of the fuel       assembly

           container      holes was about 8 x 108 rads,                           and the peak dose was

           about 10' rads.               The lnflnlte         dose to the salt               over the llfetlme

           of the faclllty           1s expected          to be on the order of 1010 rads.

           As antlclpated          from the Laboratory                  studies,          no slgnlflcant

           effects      due to the radlatlon                 were detected.

           ProJect      Salt     Vault     has lndlcated             that       the In situ       heat transfer

           properties          of salt     are sufflclently                 close       to the values

           determined          in the laboratory             that      confidence          can be placed x

           theoretlcal          heat transfer           calculations.               Calculations         to date

           have generally          been approximate                 and on the conservative                 siae,

  Page 22
    but        the       knowledge                   now exists               to permit                 more        precise           calculations

     to be made by zreans                                 of more         complex               computer               programs.

    The most               slgnrflcant                      flndlng           In     the        field          tests            regarding               the     effects

    of      heat         on salt              behavior               1s that              the      lnsertlon               of      heat         sources            In

    the        floor           of     a mine              room       produces              a thermal                stress          whose             effects

    are        instantaneously                            transmltted                around             the        opening          (to         tne      pillars

    and roof).                       These           stresses           produce             rncreased                 plastic             flow          rates

    m       the        salt.

    The combined                      field           and     laboratory                   tests            have     provided               sufflclent

    lnformatlon                     on these               salt       flow         characterlstlcs                         to     allow           the      develop-

    ment        of both               general              and       speclfzc             emplrlcal                 crlterla              for      the        design

    of     a disposal                     faclllty            In almost               any bedded                    salt        deposit.                 These

    crlterla              are         necessary               for      a detailed                     englneerlng                 design           of     an

    actual           disposal                 faclllty.

    To summarize,                      it      may be said                   that         most         of     the      maJor         technical

    problems              regarding                  disposal            In        salt         have        been       resolved.                   The

    feaslblllty                     and       safety          of      handlrng              highly            radloactlve                  materials

    in    an underground                         environment                  have          been        demonstrated                         The

    stability                  of    the       salt         under        the        effects             of heat             and radlatlon

   was shown,                   as well              as the           capablllty                 of     solving             minor          structural

    problems             by standard                      mlnlng         techniques.                        The data              obtaIned              on t%e

    creep         and plastic                    flow         characterastlcs                          of     the      salt        will         make It

   possible              to         arrive           at     a suitable               mine          design            for        an actual

   disposal               facllrty.                    The final              report            on      PrOJeCt             Salt          Vault         ~~11

   be issued               during              this         fiscal        year.

                                                                                          APPENDIX I
                                                                                             Page 23
13) Q: Page 26, paragraph 4, and page 27, paragraph 3                                  What IS the basis

         for    the Drvlsron         of Production          statement      (page 27)
         11. ..bedrock      storage      constitutes         for     the Savannah site       a potentially

         safe , practical,           and economical          arrangement          from the standpoint          of

         provrdlng        a solution      to Its      long-range        waste storage       problem."

         when (page 26) a maJorlty                 of a committee          of the Earth Scrences

         Divlslon        of the Natronal         Academy of Sciences               in a 1966 report

         expressed        strong     reservations          concerning      the bedrock concept of

         waste storage            and recommended that              the lnvestlgatlons       be dlscontlnued?

         What was the AEC Justlflcatlon                     for relying          on the minority      concept?

    A:   The NAS Committee referred                  to,    in Its     1966 report,       stated     that     in

         situ    examination         of the bedrock caverns would provide                    the best

         evidence        that caverns could retain                  the radloactlve       wastes.      However,

         a maJorlty        of the commrttee felt               posltlve     results      from continued

         studies     would be unlikely             and recommended their              termlnatlon,          while

         a   minority      felt     additional       studies        were needed before a declslon                   was

         made to abandon the concept.                      The AEC decided to perform               addltlonal

         studies        because the drfferentlal               In cost between bedrock storage

         and the alternatives             Justified         expenditure          of funds to obtain          this

         information.             The bedrock proJect              consultants      engaged by duPont

         (see reference            3) have examined all              of the data avallable           and have

         concluded        rn situ      exploration         of the bedrock LS Justified               and
         there      is a high probablllty             of producing         evrdence to warrant              com-

         pletion        of the entlre       proJect.         Although      this     panel of consultants             does

         not represent            the NAS, each consultant              IS lndlvldually       a member of the

      Page 24

14)   Q:   Page       28          Can DP Justify                          the     calculations                  which        lndlcate           expendl-

           tures        of       $100-500                mllllon           for         other        than      bedrock         storage           at

           Savannah              River     ?

      A:   The attached                  article               (“A    Look             at    Long     Range          Waste      Management

           Costs        at       USAEC Sites”                   Attachment                   2) provrdes              an estrmate.                   These

           estimates              are      in        1964       dollars                and escalation                 and subsequent

           experience              and         lnformatlon                  would            increase           these       costs       slgnlfr-

           cant ly.              However,                the    relative                magnitudes              and ratros            of    the

           alternatlves                  probably               would            not        be changed.               The duPont            consul-

           tants      ’ report             (Attachment                     3) also             povldes          a srmllar            estimate           of

           $334       million.                 It        should       be noted                 that        these      are     only      prellmrnary

           estimates              which             have       been        made without                    benefit      of      process          develop-

           ment       studies            related               to    adapting                calclnation              processes            to    the

           speclflc          wastes                 at     Savannah              River         and detailed             engineering                  studies

           to better              define             the       facility            requirements.                      The actual            costs        may

           exceed          the     estimates.

                                                                                                                                           Page 25
15)   Q:   Page 40,            paragraph                2:       On page                 12 ri         is      stated         that            tank            service

           lrfe      could          be 10,           15,        or 20 years,                     on the             top     of        page          39 rt             IS

           stated         that        carbon            steel          tanks          might            last         20 to 40 years,                             the

           second         paragraph                on page             40 states:                      “Thrs         matter             is        of         concern

           because,            accordrng                to AEC,             there             is not         enough         experience                        wrth         the

           servrce          lrfe           of     existing             storage                tanks          to reach             experienced                         con-

           elusions.           ”      Are         any      of    the        above-lrsted                       statements                 correct?                     Whrch?

      A:   As covered                by the          AEC’s           answer              to questlon                 83,         the      waste               management

           program          does           not     place         long             term        reliance              on storage                    of         lrquld

           waste       in      tanks.              Srnce         the        AEC 1s moving                       away         from            long            term

           lrquld         storage                and mth             the        PrOJeCted                   space         storage             capacity,                    the

           service          life           of     waste         tanks             1s not         the          same crrtrcal                       factor              Ln

           the      program           as It          would           have          been         had AEC continued                             wrth            llquld


           The service                life         values            presented                  in     the       CA0 report                   are            only

           estimates               based          mostly         upon           measured               corrosron                 rates            and         the

           allowance                (addltlonal                 wall        thrckness)                      made      for        corrosion                    in      the

           tank      design.                 The service                   life          as used              by the         AEC and                   its      contractors

           is     an estrmated                    “average”                value          used         rn planning                     for        replacement

           of     tanks        in      the        event         extended                 rnterLm              storage            of      llqurd               wastes

           1s contemplated.                          Because               of      the         small          number         of        tanks             that

           have       been         constructed                  to handle,                     current           waste,           sufflclent

           statistrcal                experience                 must             awalt         the         accumulation                     of        a larger

           number         of        tank         years,           Because                of     the         rmmobrllzatron                        program,                  the

           tank       years          to         be used         in     any statrstlcal                           analysrs               would                Increase

  Page 26
      slowly     with        time.     As noted     above,     this      lnformatlon   is   now not

     essential          to    the    AEC waste    management          program.

                                                                                           Page 1

                                      ~A!%ING7l-0N.Dc 20510

                                                          December      15, 1969

Honorable   Elmer     B. Staats
Comptroller    General     of the
   United States
U S General      Accountmg      Office
Washington,    D C

Dear    Mr    Staats

          Our letter     of October      24, 1969 requested       that the General        Accountmg
Office perform          a follow-up     review    of the radloactlve     waste management
actlvlizes    of the Atomic         Energy     Commlsslon.       As indicated      m our letter,
we considered         that the areas to be revlewed,            and the depth of review,           should
be predicated        upon the AEC’s         response    to the series     of questions      generated
by your report         of May 28, 1968 on waste management                   The meeting        on
December       8, 1969 of the Jomt Committee               staff with personnel        from    GAO
and AEC did much to clarify               AEC progress        and plans for radloackve           waste
management         by the Government

         It appears       to us that any radioactive            waste management        and control
programs        will,    m the near future,        involve       comprehensive     government-
industry      cooperation,       particularly     if the AEC plan for a 5-year             maximum
storage     period      at non-U     S Government          facllltles     goes into effect      While
the GAO review           will be of Government           facllltles     and plans,  possible     future
relatlonshlps         to the clvlllan     nuclear    program         of waste management        should    be
kept in mmd.

        As part of the       review,   we would like         the   GAO to consider        exammmg
the followmg    aspects        of the AEC’s  program

        1.     The manner  IIY which the AEC organlzatlons         responsible       for
              waste management      actlvltles    dischal ge their  responslbllltles
              with respect  to operations      and research   and development         usmg
              the AEC field offices     and contractors

    Page 2
        2.     The effectiveness     of programs       for developing,     evaluatmg,
               and appraising    methods      of mterlm    and long-term         storage
               for waste generated      J:,f AEC and commercial         faclllties.

        3.     The status of research    and development     programs   being
               carried  out by AEC to develop     a means for long-term
               waste storage   and reasonableness     of establrshed  ObJectives.

         As stated previously,       you may desire,      while conducting     thus renew,
 to consider    the AEC’s proposed         policy statement     dealing with the slkng of
 commercial       fuel reprocessmg      plants and related      waste management      facllllhes
 and to determine      the posltlons    taken by some commerczal          farms who are now
 or w1l.l be dealing with high-level         radloactlve   wastes.

        Your    cooperation     m these     important      matters    wlpp be greatly      appreciated.

                                                        Smcerely     your 8,

                                                        Executive    Director

                                                    APPENDIX III
                                                         Page 1


                          OF THE



                  DISCUSSED IN THIS REPORT

                                        Tenure of offlce
                                        From             To

     Glenn T   Seaborg              Mar.     1951     Present

    R. E. Holllngsworth             Aug.     1964     Present

     Harold L Price                  Sept.   1961     Present

     John A. Erlewlne                Dec.    1964     Present

     George F. Quinn                 Aug.    1961     Present

     George M. Kavanagh              Jan.    1966     Present

     Spofford G. English             Aug.    1961      Present

     Frank P. Baranowskl             Oct.    1961      Present

     Page 2
                                              Tenure of offlce

     Mllton Shaw                           Dec.   1964   Present

     Martin B. Blles                       Nov.   1966   Present

     Henry A. Nowak                        Aug.   1970   Present

     John A. McBride                       Jan.   1965   May     1970
     Lyall E. Johnson (acting)             May    1970   Present

     Idaho Operations   Offlce
          Wlllz.am L. Glnkel               Nov.   1963   Present

     Oak Ridge Operations     Offlce
         S. R. Saplrle                     Feb.   1951   Present

     Rlchland Operations    Office
          Donald G. Wllllams               July   1965   Present

     Savannah River Operation        Of-
          Nathaniel Stetson                Dec.   1965   Present

                                                         U S   GAO   Wash,   D C