Cleaning Up the Remains of Nuclear Facilities: A Multibillion Dollar Problem

Published by the Government Accountability Office on 1977-06-16.

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

                          DOCUMENT RESUME
 02777 - [A1933006]

 Cleaning Up the Remains of Nuclear Facilities: A Multibillion
 Dollar Problem. EMD-77-46; B-164052. June 16, 1977. 28 pp. + 2
 appendices (5 pp.).
 Report to the Conqress; by Elmer B. Staats, Comptroller General.
Issue Area: Energy (1600); Energy: Making Nuclear Fission a
    Substantial Energy Source (1608).
Contact: Energy and Minerals Div.
Budget Function: Natural Resources, Environment, and Energy:
    Energy (305).
Organization Concerned: Energy Research and Development
    Administration; Environmental Protection Agency; Nuclear
    Regulatory Commission.
Congressional Relevance: Congress.
Authority: H.R. 6181 (95th Cong.).

           The disposal of nuclear facilities has become a special
 problem because of the growing number of these facilities and
 the radioactivity associated with them. The Energy Research and
 Development Administration (ERDA) and the Nuclear Regulatory
 Commission (NRC) have the chief responsibilities in this matter
 with help from the Environmental Protection Agency and the
 states. Findings/Conclusions: ERDA, which is responsible for
 disposing of, or decommissioning, its own facilities, has not
 compiled relevant details for assessing problems, and facilities
 in need of decommissioning have been accumulating. NRC,
 responsible for regulating private users of nuclear materials,
 has done little to plan for decommissioning, and does not
require owners of nuclear facilities, except for uranium mills,
to develop plans or nake financial provisions for future
decommissioning. Thus, the State governments can be asked to pay
 for these problems. Only seven States require bonding or advance
accumulation of funds for decommissioning. Before a strategy for
meeting these problems is developed, basic questions must be
answered pertaining to costs, methods of decommissioning,
standards and limits for radiation levels, and the role of the
States. A proposed bill directing ERDA to study decommissioning
comprehensively is a possible vehicle for providing this
information.    Recommendations: Congress should designate NRB as
the lead Federal agency for overall decommissioning strategy.
ERDA should continue research and development efforts to find
alternatives, expand its present program, and plan for future
decommissioning. NRC should plan for decommissioning at the time
of licensing, determine acceptable radiation levels, and
encourage States to follow its lead in adopting comprehensive
planning. (HTW)

· ', ...l   . OF THE UNITED STATES

            Cleaning Up The Remains Of
            Nuclear Facilities--
            A Multibillion Dollar Problem
             Energy Research and Development Administration
             Nuclear Regulatory Commission

            The problem of protecting the public from
            the hazards of radiation lingering at nuclear
            facilities which are no longer operating needs
            Federal attention if a strategy for finding a
            solution is to be developed.
             The solution doubtless will be expensive--but
             the expense should be known so the responsi-
             ble parties can plan for the inevitable cost. A
             strategy to clean up these privately and fed-
             erally owned nuclear facilities, which con-
             tinue to accumulate, cannot be developed
             until basic questions on the magnitude of the
            .problem, such as costs, radioactivity, and
             timing, ha/e been answered.

            EMD-7746                                           JUNE 16, 1977
                          WASHINGTON. D.C.


To the President of the Senate and the
Speaker of the House of Representatives

     This report   discusses the Nuclear Regulatory
Commission's and   the Energy Research and Development
Administration's   programs for disposing of nuclear
facilities after   these facilities are no longer needed.
     We made this review as a part of our evaluation of
the effectiveness of the Commission's regulatory activi-
ties, as required by the Energy Reorganization Act of
1974 (42 U.S.C. 5876). The Administration was included
because of similar program activities.

     We are sending copies of this report to the
Chairman, Nuclear Regulatory Commission, and to the
Administrator, Energy Research and Development
Administration, and to interested committees of the

                                  SgZ~F~ly your

                                  Comptroller General
                                  of the United States
                                          CLEANING UP THE REMAINS OF
                                          NUCLEAR FACILITIES--A MULTI-
                                          BILLION DOLLAR PROBLEM
                                          Nuclear Regulatory Commission
                                          Energy Research and Development
   Sixty-four commercial nuclear
                                   powerplants are now licensed
   to operate in the United States.
   be about 235. The licenses for       By the year 2000, there may
   in areas such as medicine and     commercial   nuclear activities
   19,000. Numbers of other kinds  industry,  now  stands at about
   also been increasing and still    of nuclear facilities have
                                    are.   (See pp. 4 to 8.)
  As with every industry, nuclear
   be shut down, replaced, or becomefacilities and equipment may
   remains of nuclear activities,      obsolete. Cleaning up the
  blems because of radioactivity    however,  presents special pro-
  endanger public health and safety.and contamination which can
  hazardous for thousands of years       Some radioactivity remains
  posal at best a difficult and       making  final and absolute dis-
                                  expensive task.     (See p. 3.)
  Responsibility for seeing that
  with two Federal agencies with this is done rests primarily
                                   additional help from a third
  and the 50 states:

         The Energy
                  Research    and Development Administration
         Is responsible for isposing   of , or decommissioning,
         the radioactive facilities it
         The Nuclear Regulatory Commission
                                             is responsible
         for regulating private users of
         including powerplants, uranium nuclear materials,
                                         mills and processors
         of nuclear fuel.
         The 50 States have traditionally
                                          been responsible for
         controlling the hazards of using
                                          accelerators and radium.
         The Environmental Protection Agenc has
                                                  overall respon-
         sibility for Issuing standards
         the environment from all sources    the protection of
         do this it must have cooperation of  radiation. But to
                                          from the other two
         agencies identified.
     This agency has not paid enough
ties that are now obsolete. It        attention to its facili-
                                has not compiled relevant

IIm.atbat. Upon removal, the report
COe d.shou     be note1 hereoEl.
                                      i              EMD-77-46
details of the facilities it owns--obsolete or operating--
which would permit it to assess the magnitude of the decom-
missioning problems they pose.  (See p. 17.)
Funds for decommissioning have been used for several specific
projects. One project involved sites used for radiological
operations 20 to 30 years ago that were released for unres-
tricted use by the general public. An attempt is being made
now to identify any of these sites that are still contaminated
and to do what is necessary to eliminate remaining radiation.
(See pp. 9 and 10.)

Meanwhile, this agency's facilities in need of decommissioning
have been accumulating. Reliable estimates have not been made
but it seems probable that the cost to decommission federally-
owned nuclear facilities will run into hillions of dollars.
One of its contractors estimated it could cost as much as $4
billion to decommission the facilities at the largest of this
agency's 26 reservations.  (See pp. 17 and 18.)

The Commission has done relatively little to plan for and to
provide guidance for decommissioning of commercial nuclear
facilities. Studies sponsored by the Commission on acceptable
alternative methods to decommission are several years from
completion.  It does not require owners of nuclear facilities--
except for uranium mills--to develop plans or make financial
provisions to cover the cost for future decommissioning.
Consequently, the true cost of nuclear power is not being
reflected in the cost to the consumer o. nuclear power. With-
out this financial provision, the Federal or State Governments
can be asked to pay for problems that rightfullyv should be paid
by private industry.  (See pp. 11, 12, and 15.)
Situations where this has happened, or may, have already arisen.
For example, the Federal Government will pay about $85 million
to clean up residues from inoperative uranium mills that were
privately owned. Also, as much as $600 million may be needed
to decommission a privately owned nuclear fuel reprocessing plant
at West Valley, New York. The State Government is responsible
for cleaning-up the plant but has asked the Federal Government
for assistance. In ;a case at Clinton, Tennessee, the Federal
and State Government- shared the cost--approximately $110,000--
to decontaminate a facility that the owners walked away from in
1l71.  (See p. 15.,
Although cost estimates to decommission private facilities
have not been developed by the Commission, a recently com-
pleted study by a private organization estimated the cost to
decommission a commercial nuclear reactor to be as much as

$39 million. No cost data, evcept for wide-ranging estimates,
is available for decommissioning other facilities, such as
uranium mills or fuel fabrication plants.  (See pp. 13 and 14.)
A conference of State officials has recommended that States
protect themselves irom financial loss should a company not
be able to pay to decommission its facilities. However, only
seven States require some form of bondin. or advance accumu-
latioii of funds for decommissioning. (See p. 23.)
The problem of protecting the public from the hazards of
obsolete nuclear facilities needs Federal attention if a
strategy for finding a solution is to he developed. The solu-
tion, in all likelihood, will be expensive--but the expense
should be known so the responsible parties can plan for the
inevitable cost.
A strategy cannot be developed until certain basic questions have
been answered.
  -- How much will decommissioning cost and who should
  -- How should nuclear reactors be decommissioned?

  --What is the extent of the decommissioning problem
    for accelerators?
  -- Are standards needed for induced radiation?

  -- What should be the limits on acceptable radiation
  -- Whlat more shoul. States do to plan fc. decommissioning?
(See pp. 13 to 24.)
A bill (H.R. 6181) has been proposed directing the Energy
Research and Development Administration to study decommis-
sioning comprehensively. This study should provide basic
information needed to develop a strategy toward solving
decommissioning problems.

Because of the magnitude, cost and time already lost, the
Congress should designate one lead Federal agency--the Nuclear
Regulatory Commission--to approve and monitor an overall decom-
missioning strategy.

Tr Sitiii
The Nuclear Regulatory Commission is uniquely suited for this
role because of its charter to independently regulate commer-
cial nuclear activities to assure public health and safety.
This position is consistent with a previous GAO report and
testimony. Placing this responsibility with the Commission
would, in addition, increase the credibility of Federal
regulation over nuclear energy.
The Energy Research and Development Administration should
continue its research and development efforts aimed at
finding alternatives for decommissioning and decontamination
of nuclear facilities.

The Administrator of the Energy Research and Development
Administration is part of his research and development
responsibility, should

  -- determine alternative methods of decommissioning,
     acceptable levels for induced radiation and surface
     contamination, and the extent of the decommissioning
     problem for accelerators;
  -- expand and accelerate a program to decommission
     nuclear facilities currently excess to its needs;
  -- require that program managers plan for future
     decommissioning and include such cost informa-
     tion in their program budgets.
The Chairman, Nuclear Regulatory Commission, should for those
facilities he regulates
  -- require specific. plans for decommissioning at
     the time of licensing, including the decommis-
     sioning method to be used and a funding mechanism
     to assure that facility owners pay the costs of
 -- determine the acceptable levels for induced
    radiation and surface contamination consistent
    with environmental standards being developed
    by the Environmental Protection Agency; and
 -- encourage States to follow the lead of the
    Commission in adopting comprehensive decommis-
    sioning planning for facilities under States'

The Energy Research and Development Administration was unable
to furnish written comments in time to be finalized in this
report. However, GAO met with Energy Research and Develop-
ment Administration officials and obtained their oral comments
which have been incorporated in this report.  These officials
disagreed with giving the Commission responsibility over Energy
Research and Development Administration facilities. However,
they will consider this matter further and will provide written
comments in the near future.

The Nuclear Regulatory Commission's comments on the report are
contained in a letter dated June 10, 1977.  (See appendix I.)
The letter describes the actions the Commission is taking or
plans to take to develop methods and criteria for decommis-
sioning nuclear facilities.

Because of time constraints and the report's relatively limited
treatment of the Environmental Protection Agency, its comments
were not sought.

                Con tents

DIGEST                                                i

          INTRODUCTION                                1
              Federal and State responsibilities      1
            MUST BE CLEANED UP                        3
              Reactors                                4
              Accelerators                            5
              Fuel fabrication facilities             5
              Uranium mills                           6
              Fuel reprocessing plants                6
              Various users of radioactive
                materials                             6
              Wa&te handling and storage              7
            PROBLEM                                   9
              ERDA's efforts                          9
              NRC's efforts                          1.
              State efforts                          1'
              Decommissioning--how much will it
                cost and who should pay?             13
              Commercial nuclear reactors--how
                should they be decommissioned?       18
              Accelerators--what is the extent
                of the d.commissioning problem?      20
              Are induced radiation standards
                needed?                              20
              Will current radiation standards
                change?                              21
              What about naval reactors?             22
              What should be the States' role
                in decommissioning?                  23
              What does the future hold for
                nuclear power and decommissioning?   23

             RECOMMENDATIONS                         25
               Recommendations to the
                 Congress                            26
               Recommendations for the Admin-
                  istrator, Energy Research and
                 Development Administration and
                 the Chairman, Nuclear Regulatory
                 Commission                          26
               Agency comments                       27
       6   SCOPE OF REVIEW                           28

       I   Letter dated June 10, 1977, con-
             taining NRC comments on this report     29
      II   Principal officials responsible for
             administering activities discussed
             in this report                          33

AEC        Atomic Energy Commission
ERDA       Energy ~!search and Development Administration

GAO        General Accounting Office
NRC        Nuclear Regulatory Commission
                           CHAPTER 1
     Before 1954, nuclear activities were confined largely to
the Federal Government and to military applications.   In that
year, legislation was enacted permitting commercial firms to
use nuclear materials and operate nuclear facilities. The
uses for nuclear material and facilities then began to expand,
reaching farther into such areas as medicine, industry, and
electrical production.

     As the uses increased, so did the equipment and facili-
't;s involved in the uses. Equipment and facilities in the
nuclear industry, as in any other, become obsolete, break
down, or are replaced or abandoned for a variety of reasons.
This report discusses the problems in making sure that the
facilities, equipment, and materials invclved in nuclear
activities are disposed of in a way that precludes any health
or safety hazards--now or in the future.

     The Energy Research and Development Administration (ERDA)
is responsible for the radioactivity in facilities it owns,
leases, and controls. This includes facilities such as
reactors and accelerators located both on nonfederal and on
ERDA-owned property--commonly referred to as ERDA reservations.

     The Nuclear Regulatory Commission (NRC) is responsible
for regulating private uses of nuclear materials. This respon-
sibility covers nuclear powerplants, uranium mills, facilities
which make or process nuclear fuel, and the regulation of users
of source, byproduct, and special nuclear material 1/. NRC
fulfills its responsibility through a system of licensing and

     The Environmental Protection Agency has overall Federal
responsibility for issuing standards for the protection of
the environment from all sources of radiation. To carry out
this responsibility, however, the Environmental Protection
Agency must have the cooperation of other Federal agencies.
Therefore, ERDA and NRC are primarily responsible for

1/Source material is naturally occurring radioactive material
  such as uranium and thorium. Byproduct material is radio-
  active material created during a nuclear reaction. Special
  nuclear material is enriched uranium and plutonium.

developing, implementing, and enforcing radiation standards
for individual nuclear facilities.

     States traditionally have been responsible for protecting
the public health and safety and controlling the hazards of
radium and naturally occurring radioactive materials which
are not subject to NRC control. In addition, 25 States have
signed agreements with NRC whereby they control the source,
byproduct, and small quantities of special nuclear materials
located within their boundaries.

    The remaining chapters of this report discuss

    -- the facilities and activities that present a
    -- the past and current efforts to solve the
    -- the major questions that remain unanswered;
    -- our conclusions, observations, and recommen-

                           CHAPTER 2

                    THAT MUST BE CLEANED UP
     While a nuclear activity is ongoing, the materials,
equipment, and facilities that come into contact with
clear reaction or radioactive material could become    a nu-
inated or radioactive. Once the activity is ended, disposing
of these items Presents special problems. Facilities
used for nuclear activities cannot be abandoned if radioactive
materials remain that present a radiation hazard. Structural
materials or equipment cannot be recycled if they have
made unsafe by contact with a nuclear activity. A nuclear
operations buildinq cannot be reused for other purposes
radioactive materials and contamination have been removedunless
reduced to acceptable levels.                               or

     Many types of nuclear facilities must be prevented from
endangering public health and safety. Each type will
to be handled, or decommissioned, in a different way. have
                                                        A major
factor in determining the best way is the nature of the
ation hazard at the facility.                            radi-

     Two types of hazards could be involved in a nuclear
ity:                                                       facil-
       induced radioactivity and surface contamination. Induced
radioactivity results from a nuclear reaction and is
in the eauioment or material coming into contact with embedded
nuclear reaction. This ind'ced activity cannot be cleaned-up
and can remain dangerous for thousands of years. For
reason, a structure containing induced radioactivity should
dismantled at some point in time. This should be done         be
the structure begins to deteriorate, thus permitting
activity to enter the environment.                    the radio-

     Surface contamination results from facilities
ment coming into contact with radioactive material. or equip-
                                                      As opposed
to induced activity, material having surface contamination
often be cleaned up by scrubbing and washing.               can

     In describing the cleaning-up process, the words decon-
tamination and decommissioning are often used.  In this report,
decontamination denotes the process of cleaning-up surface
contamination. Decommissioning is a term used by NRC
                                                       and ERDA
to indicate the closing or shutting down of a facility
some actions taken to prevent--at least temporarily--health
and safety problems. It does not necessarily denote
manent solution to cleaninq-up the facility.         a per-

     This chapter discusses the major types of nuclear
facilities that will have to be cleaned up.

     Nuclear power reactors, which have an estimated useful
operating life of about 40 years, are a major decommissioning
problem because of their enormous size and their large inven-
tory of induced radioactivity. In May 1977, 64 commercial
nuclear power reactors were licensed to operate. By the year
2000 an additional 175 may be operating. NRC regulates these
commercial reactors.
     NRC also regulates more than 73 other so-called nonpower
reactors, which are used for tests, research, and university
application. ERDA owns about 80 such nonDower reactors. These
are much smaller than the commercial power reactors. The mili-
tary owns an additional 174 reactors, in operation or under
construction. Most of these belong to the Navy and are used
in nuclear submarines and carriers.
     There are generally four recognized methods for decommis-
sioning reactors--dismantlement, entombment, mothballina, and
a combination of either entombment or mothballing with subse-
quent dismantling.
     Dismantlement involves the total removal of the facility
from the site to radioactive waste burial grounds. The land
is then restored to its original condition and released for
unrestricted use. The largest problem involved in immediate
dismantlement is contending with the radiation hazards from
the large amounts of induced activity. To prevent the workers
engaged in the dismantling activities from receiving excessive
doses of radiation, much of the cutting of the reactor parts
must be done by remote-controlled equipment underwater--a
costly and time-consuming process.
     Entombment consists of sealing the reactor with concrete
or steel after all liquid waste, fuel, and surface contami-
nation have been removed and sent to fuel storage facilities
or burial grounds. NRC does not require an entombed facility
to have security systems to protect against intrusion. How-
ever, it does require annual surveillance for possible radi-
ation leaks. Also, periodic maintenance is required to insure
the integrity of the entombed structure.
      Mothballing is simply removing the fuel and radioactive
waste and then placing the facility in protective storage.
A mothballed facility requires a security intrusion system,
an:1ual radiological surveys, and periodic maintenance.

     The fourth method is a combination of either mothballing
or entombment with subsequent dismantlement. This method
offers the advantage of placing the facility in an entombed
or mothballed status for about 65 to 110 years, until the
induced activity decays to a level which permits dismantling
without undue radiation danger to the workers. The entomb-
ment and mothballing methods and, t9 a lesser extent, the
combination methods, would limit the use of the affected land.

     An accelerator is a device used to increase the velocity
and energy of particles like electrons or protons. They are
used in physical, medical, and biological research, as well
as for commercial purposes. Acclerators may be a problem at
the time of decommissioning depending on (1) the type, (2) the
size, and (3) the usage--including length of time operated.
High levels of radioactivity may be induced in target mate-
rials, structural walls, or in the experimental equipmeint
used during the operation of the accelerator. This induced
radiation requires special attention at the time -f decommis-

     Large accelerators may have to be completely dismantled
because of the large amounts of induced activity. For example,
a large, federally owned accelerator located at Carnegie Mellon
University has been dismantled at a cost of about $485,000.

     States are responsible for registering and inspecting
privately owned accelerators. In fiscal year 1968 there were
abeot 580 accelerators reported as owned by various private
concerns and universities under State jurisdiction. This num-
ber had increased to about 1,000 at the end of fiscal year
1975. In addition, ERDA officials told us ERDA now owns about
45 large accelerators.

     Fuel fabrication facilities are usee to process and make
nuclear fuel. These facilities ha',e only surface contamina-
tion to contend with at the time of decommissioning. It seems
probable, therefore, that these facilities could be cleaned-up
at less cost than reactors. However, to our knowledge, no
studies of methods and associated costs to decommission these
facilities have been done.

     There are 21 commercially operating fuel fabrication
plants. We contacted all owners by questionnaire to obtain
comments on anticipated problems and costs to decommission.
Six of the 14 respondents indicated they did not anticipate

significant problems. One thought there could be a problem
 ecause of regulations on decommissioning becoming more
stiingent in the future. The remaining seven had no comment.

     Uranium mills are used to refine and process the uranium
ore that is mined. They too have only surface contamination
to contend with at the time of decommissioning. Therefore,
the plants themselves can be cleaned-up at much less cost than
a reactor. HowEver, uranium mills have a problem with stabi-
lizing uranium mill tailings 1/. This problem is discussed in
more detail in chapter 3.

     To our knowledge, no studies have been made on decommis-
sioning uranium mills. We sent questionnaires to all uranium
mill owners for the 20 licensed mills. Of the 13 who responded,
8 said they did not anticipate any decommissioning problems, 3
said there would be some type of problem because of changing or
uncertain NRC regulations, and 2 had no comment.

     Fuel reprocessing plants are used to separate unused
uranium and plutonium from fuel that has been used in nuclear
reactors. ERDA is now operating three reprocessing plants.
ERDA has one more plant on standby and five plants that were
shutdown in the 1950s and 1960s but that have not been
     The only commercial reprocessing plant that ever operated
in the United States is the Nuclear Fuel Service, Incorporated,
plant at West Valley, New York. This plant was shut down in
1972 and has not yet been decommissioned.
     Various organizations use source, byproduct, and special
nuclear materials for industrial, medical, and educational.
applications. These organizations vary from firms that use
nuclear materials to check the adequacy of welds made on con-
struction projects to physicians and medical organizations
that use radioisotopes for therapeutic and diagnostic purposes.

l/Uranium mill tailings are sand-like radioactive waste
  materials resulting from the extraction of uranium from
  uranium ore.

Decommissioning facilities and equipment in which radioactive
materials were used could be a problem depending on (1) the
type of material and form it was in, (2) how it was used, and
(3) the half-life 1/ of the material. The radiation hazard
is in the form of surface contamination which often can be
cleaned at a fairly low cost by scrubbing and washing with
acids and water.
     The potential for radiation hazard is high if unsealed
radioactive materials were used for manufacturing or research
and development. On the other hand, the potential radiation
hazard is quite small if the user was working only with
sealed sources 2/ or with radioactive materials having short

     As of June 30, 1968, there were 15,913 material licensees
--9,257 under NRC control and 6,656 under agreement State con-
trol. By December 1975 this number had increased to 19,102--
8,468 and 10,634 for NRC and agreement States, respectively.

     Many operations that produce or use nuclear materials
cenerate radioactive waste. This radioactive waste is usually
classified as "high-level" and "low-level". High-level waste
is generated during the chemical reprocessing of used or spent
fuel. High-level waste has intense radiation, aenerates heat
and is very hazardous.
     Low-level waste, in most cases, is l2ss intense but may
contain long-lived radiation. For this reason, it is buried
underground and monitcred indefinitely.

     Both types of waste present a problem. High-level waste
that has already been produced is stored in large tanks which
provide only an interim solution to the disposal problem. At
the end of the tanks' useful lives, the waste must be moved to
other (new) tanks, or be removed, solidified, and transported

1/The time in which half the atoms of a particular radio-
  active substance disintegrate to another nuclear form.
  Measured half-lives vary from millionths of a second
  to billions of years.
2/Sealed source means any radioactive materials that is
  permanently encased in a container or matrix designed
  to prevent the leakage or escape of such radioactive
  material under foreseeable conditions of use and wear.

to burial grounds. The old tanks have to be removed, cut
up, and also transported to burial grounds. ERDA, on its
Hanford reservation alone, has 156 high-level storage tanks.
Some of these tanks have already leaked 1/.
     There are presently six commercial and five Federal
disposal sites containing more than 51 million cubic feet of
other-than-high-level waste. These burial grounds require
monitoring for centuries and may present future costly
     In a January 1976, report 2/ to the Congress we noted
that some radioactive migration has occurred at several of
these burial sites. If the situation worsens, it may entail
exhuming the waste. If this is required it can be quite
expensive running into hundreds of millions of dollars.

1/We are now preparing a report on the subject of high-level
  waste which we expect to issue during the summer of 1977.

2/Improvements Needed in the Land Diaposal of Radioactive
  Wastes--A Problem of Centuries (RED-76-54, January 12, 1976).

                             CHAPTER 3
                  PAST AND CURRENT EFFORTS

                       TO SOLVE THE PROBLEM

     The Nuclear Regulatory Commission and the Energy Research
and Development Administration are aware of the hazardous and
long-term nature of nuclear radioactivity and contamination.
In view of the accumulation of nuclear facilities, what have
these agencies been doing to assure that the facilities do not
endanger public health and safety ne'w or in the future?

     ERDA has sponsored many experimental and demonstration
projects located on nonfederal property. These projects
included power reactors, university reactors, and accelerators.
Some of the more notable power reactors which have been decom-
missioned are listed below. They were decommissioned between
1969 and 1974.
             Decsioned        ERDA power reactors

Facility    Location         electric)        Method       Cost

Piqua       Ohio                 45       Entombment         1.0
Elk River   Minnesota            58       Dismantlement      6.2
BONUS       Puerto Rico          50       Entombment         1.6
These three reactors were funded by the Atomic Energy Commission
(AEC) to demonstrate the feasibility of producing electrical
power by different types of reactors. The plants were operated
by commercial utility companies, but through contractual provi-
sion, AEC was responsible for their decommissioning. These plants
are much smaller than the commercial power reactors now operating
and being built. Most reactors now being built are in the 1,100
megawatt range.
     As noted in the table, only one of the reactors was
dismantled. The other two reactors were entombed. ERDA pro-
vides for radiological monitoring of these entombed plants
and is responsible for any future radiation problem that might

     ERDA has a limited budget for decommissioning activities,
having received a total of $14,300,000 in fiscal years 1976

and 1977. Of this amount, $3,000,000 was used to decommission
a nuclear rocket development station facility in Nevada and
$5,500,000 was used to decommission a sodium reactor experi-
ment in California, which was located on land that is going
to revert to private ownership. Decommissioning work on
these projects is continuing.
     Much of the remaining funds are being spent on planning,
on research, and on past problem &roas. One such problem area
relates to the old facilities or sites used by the Manhattan
Engineering District--which developed the first atomic bomb--
and by AEC for various radiological o}perations. When these
operations ceased, AEC released the si' - feo unrestricted
use. In 1976, ERDA's field offices hi     jentified 49 such
sites and ERDA was planning to survey _em for possible con-
tamination that had not been cleaned up when AEC released
them. ERDA's plan called for completing surveys of all 49
sites in 1980.

     In an April 9, 1976, letter to the ERDA Administrator,
we recommended that ERDA expedite and complete the surveys as
soon as possible to protect the public health and safety. ERDA
agreed. Since it has accelerated its program, ERDA identified
about 35 additional potentially hazardous sites and has com-
pleted surveys at most of them. As a result of the surveys,
ERDA has identified about 10 sites which will require further
effort and remedial actions. ERDA says these 10 sites contain
only low-level radioactivity and do not pose an immediate
hazard to public health.
     ERDA also has two separate programs underway tc remedy a
radioactivity problem resulting from uranium mill tailings.
Unless tailing piles are effectively controlled and stabilized,
radium can be spread to the environment by wind and water
erosion. One program is in Grand Junction, Colorado, where
tailings used in construction were found to be radioactive.
Legislation (Public Law 92-314) authorized $5,000,000 in Fed-
eral funds to provide financial assistance to the State of
Colorado to limit the exposure of individuals to this radiation.
Work under this program is continuing.
     The second program--an offshoot of the Grand Junction
problem--concerns the ra. oactivity associated with 21 inactive
uranium mill tailing sites in the western States. Exact cost
estimates have not been prepared, but ERDA estimates that
stabilizing these tailing piles will cost the Federal Govern-
ment $80,000,000.

     NRC has certain requirements that licensees must follow
at the time of decommissioning. When shutting down a nuclear
reactor, uranium mill, or fuel fabrication facility, the
licensee must submit a plan and make a final radiological
survey. NRC procedures call for visiting the site to confirm
the licensee's survey.

      Upon termination of a materials license (where the
licensee uses source, byproduct, or special nuclear mater-
ials), the licensee certifies that the facility has been
decontaminated to acceptable levels. The acceptable levels
of surface contamination are set forth in NRC's guidelines.
NRC may perform a radiological survey of the site if it is
believed necessary after considering the type of material at
the facility, what was done with it, and the licensee's past
performance under the license. No written procedures exist,
however, for selecting the sites to be surveyed. An NRC offi-
cial told us that a very small percentage of sites, perhaps
less than 1 percent, are surveyed by NRC.

      We performed a limited amount of work to determine if
any contamination problems might still exist at commercial
facilities which were closed down in the late 1950s and early
1960s, in other words, whether a situation existed which was
analogous to ERDA's problem with sites used in the Manhattan
Engineering District. The possibility exists for these situ-
ations because the care and precautions that are now taken
in decontaminating facilities often did not exist in those
earlier years.
     From the information available in NRC's files, we could
not determine whether all defunct commercial facilities had
been properly decontaminated. On September 17, 1976, we sent
a letter to the Chairman, NRC, bringing this matter to his
attention.  In October 1976, NRC responded and stated there
was little chance that any of these commercial facilities
were contaminated but said it would reexamine the files in the
ensuing several months to determine if there were any cases
where a public health and safety problem might exist.

     As of May 1977, NRC had not yet started its reexamination
of the files. An NRC official told us that because of staffing
limitations the work would probably have to be contracted out
and started during fiscal year 1977.

     NRC has contracted with Battelle Pacific Northwest
Laboratories to study various aspects of decommissioning
fuel cycle facilities and commercial power reactors. NRC

plans to use these studies to develop standards and criteria
  r decommissioning.

     Battelle recently completed a draft study on decommis-
sioning a fuel separation facility and has started studies on
the decommissioning of uranium mills and fuel fabrication
facilities. These studies are scheduled for completion in
1 .f79 .

     For the reactor decommissioning study, Battelle is using
information from a large operating reactor.  It is using the
blueprints of the plant, evaluating the structure, inventorying
the volume of material, and considering the transportation of
the material and the waste.  The study's objectives include
estimating the occupational hazards of decommissioning and the
cost of the various decommissioning methods. This study should
be completed by the end of fiscal year 1979.

     Because of the past problems with uranium mill tailings,
NRC is now preparing a generic environmental impact statement
on uranium milling to examine mill tailings reclamation and
financial surety arrangements.  This statement is scheduled
to be issued in August 1978. NRC has also recently instituted
a new procedure to protect the public from the nazards of
these tailings.  NRC will no longer issue a mill license, or
renew an existing license, unless the mill owner submits a
reclamation plan for tailings and a bonding arrangement to
finance the plan when mill operations cease. NRC estimates
that by 1978 all operating mills will be covered by this


     A State may assume responsibility for some of NRC's
regulatory authority---if agreed to by the State and NRC.
There are now 25 agreement States which regulate source, by-
product, and small quantities of special nuclear materials.
According to NRC officials, all agreement States have good
radiological control programs but the nonagreement State
radiological programs vary from virtually nonexistent to very

     Generally, States do not have separate programs or plans
for decommissioning.  Instead, it is a part of their overall
radiation control program. Most agreement States have a
provision in their regulations which requires a licensee to
contact the State and decontaminate the facility to accepted
levels before vacating a site where radiological operations
took place. The State may inspect the facility.   The States'
systems are similar to NRC's systems for closing out licensees.

                             CHAPTER 4
     To begin to grapple with the far-reaching problems of
decommissiciing requires answers to some basic questions.
In our review, we found that the questions listed below and
discussed in the following section have not been answered.

     -- How much will decommissioning cost and who
        should pay?
     -- How shouid nuclear reactors be decommissioned?

     -- What is the extent of the decommissioning problem
        for accelerators?
     -- Are standards needed for induced radiation?
     --What should be the limits on acceptable radiation
     -- What more should States do to plan for

Privately owned facilities

     The total cost to decommission privately owned nuclear
facilities in the United States is unknown. Very few studies
have been made on the subject. In fact, to the best of our
knowledge, only one major study on the cost to decommission
commercial nuclear reactors has been done to date, and another
NRC-sponsored study is in process. A study for fuel fabrica-
tion facilities and uranium mills is also in process but will
not be available until 1979.

     The study on reactors by the Atomic Industrial Forum,
Incorporated 1/, was issued in November 1976. The study
addressed pressurized and boiling light water reactors, as
well as high temperature gas reactors. The cost to decom-
mission each of these three reactor types using the three

l/An international association of utilit]i.      manufacturers,
  labor unions, and oth!r organizations   r- the nuclear area
  that is involved in peaceful uses of nuclear Energy.

primary decommissioning methods and the two combination
alternatives were evaluated. These are: mothballing, entomb-
ment, prompt dismantling, mothballing--delayed dismantling
combination, and entombing--delayed dismantling combination.
     The cost estimates are different for each type of reactor
and vary depending upon the degree of security required. For
example, a mothballed reactor at an isolated location will
require security, whereas a mothballed reactor on a site that
continues to have other ongoing activities will not. Moreover,
an entombed facility will not require additional security.
     The following chart developed from the Atomic Industrial
Forum study provides some idea as to the decommissioning cost
of an average reactor. However, the cost for an individual
reactor will vary because of its unique characteristics. It
is also important to note that these figures do not include
the costs of the burial grounds or waste repositories where
the spent fuel and radioactive materials from the reactors
will have to be sent.
                                           Cost estimate in
Decommissioning method                   1975 constant dollars

Mothballing                                  $ 2.8 to $3.1
  Annual surveillance with security               .21
  Annual surveillance without security            .11

Entombment                                     7.1 to 9.5
  Annual surveillance                             .07

Prompt dismantlement                          33.6 to 39.0

   With security                              35.8 to 39.4
   Without security                           28.5 to 29.3

 dismantling                                  30.0 to 31.0

     Although there has been no generic study, fuel fabrica-
tion facility ,ownersprovided us with their cost estimates
for decommissioning. They ranged from $100,000 to $6,000,000 1/.

l/Because of time constraints, we did not analyze these large
  ranges to determine their relationship to such factors as
  plant size.
Likewise, uranium mill owners provided us with their cost
estimates for decommissioning. They ranged from $71,000 to
$2,000,000 1/.
     The only commercial reprocessing plant ever operated,
Nuclear Fuel Services, Incorporated, at West Valley, New York,
which was shut down in 1972, has not yet been decommis-
sioned. 2/ However, it is estimated that it will cost from
$90,000,00 to $600,000,000 to dispose of all the radio-
active matey:ial, including dismantlement and removal of the

     There is no requirement for and generally no effort being
made today, with the exception of uranium mills, to provide for
the cost of future decommissioning of privately owned nuclear
facilities. The failure to make such provision can result in
the Federal and/or State Governments assuming responsibility
that rightly belongs to private industry. Situations where this
has happened or may happen have already arisen. For example,
the Federal Government will be paying about $85,000,000 to
clean up radioactive tailing piles at all inoperative uranium
mills that were privately owned.
     Another example is the West Valley, New York nuclear fuel
reprocessing plant. When the plant owner decided in 1976 to
transfer control of the site to the New York State Energy
Research and Development Authority, it imposed a large financial
burden on the State. Although the cost will undoubtedly run
anywhere from the tens to the hundreds of millions of dollars,
New York has set aside only $3,000,000 to take care of the
problem. Because of this, the New York Authority has asked
ERDA to completely take over the West Valley site. ERDA has
not accepted this request, but has agreed to discuss the
problem with the Authority.
     We should quickly point out the cost to decommission
private nuclear facilities may nct be as high as these two
unusual cases. There are no other privately owned fuel reproc-
essing plants, and the problem of uranium mill tailing piles
was not discovered until after the mills were shut down.

i/Because of time constraints, we did not analyze these large
  ranges to determine their relationship to such factors as
  plant size.

2/We have issued a report entitled "Issues Related to the
  Closing of the Nuclear Fuel Services, Incorporated, Repro-
  cessing Plant at West Valley, New York"  (EMD-77-27, March
  8, 1977).
      Lesser amounts will be required to decommission smaller
activities. Even so, these smaller activities--often owned by
smaller companies--may be prone to financial difficulties
that can result in the Government paying for the necessary
decommissioning. For example, a company in Clinton, Tennessee
-- a manufacturer of sealed radioactive sources--went out of
business in mid-1971. The owners walked away from the plant
leaving a significantly contaminated area. The Federal and
State Governments shared the cost--approximately $110,000
-- to Jecontaminate the facility.

     Regulations for funding decommissioning
     With the exception of uranium mills, NRC has no require-
ment that licensees make specific financial provisions to cover
the cost of future decommissioning. Instead, it determines,
before issuing a license to operate, whether the licensee is
generally financially responsible. This determination is based
on an evaluation of the company's profit history and the
proposed operating expenses for a facility to be licensed.
NRC considers this information to be indicative of financial
soundness and the ability of the company to pay for future
decommissioning. Therefore, in the case of nuclear reactors,
NRC makes a judgment, even before a powerplant begins to
operate, that a utility can pay for decommissioning costs
which will not be incurred for at least 40 years and possibly
for as much as 150 years. That judgment is not based on a
specific estimate of the anticipated cost of decommissioning.
     Extent of efforts to
     fund decommissioning
     Various approaches could be taken by private industry to
provide today for future costs rather than saddling future
generations with this responsibility. These approaches include:
     -- A direct charge to users or customers in the
        price of a product and depositing such funds
        into an escrow or trust fund.
     -- A system for recovering the cost of decommis-
        sioning nuclear reactors through depreciation
        accounts. This depreciation ccst could then
        be passed on to users. The funds could be set
        up in special accounts to insure their inte-
        grity until needed.
     -- A bonding arrangement to protect the governmental
        bodies from a financial burden should a licensed
        nuclear facility not be able to decommission its

     We sent questionnaires to all companies with operating
uranium mills and fuel fabrication plants and all utilities
with operating or planned nuclear reactors. Of 9 companies
with 11 operating mills, 3 companies are providing some form
of bonding and 1 firm has established a $70,900 fund for future
decommissioning. This company established the fund because of
its inability to obtain bonding. Only 3 of the 14 fuel fabri-
cation companies which responded to our inquires have esta-
blished a fund to cover the cost of decommissioning.
     Thirty-two utilities with 48 operating reactors responded
to our questionnaire. Seventeen stated that they use depre-
ciation accounts to reflect decommissioning costs which
ultimately wind up in utility rates. However, even though
funds collected through this method are an advance recovery
of costs, these funds are not set aside in special accounts.
Instead, the funds are used in current operations in lieu of
borrowing. These utilities expect to be able to pay the even-
tual decommissioning costs from whatever future budget is
affected. The 15 other respondents are presently doing nothing
to accumulate funds for decommissioning.
     Although the cost to decommission a nuclear reactor may
be in the millions of dollars, the utilities do not consider
these costs significant in relation to the construction costs
for a reactor which are now about $1 billion. Consequently,
they do not see a need for advance accumulation of funds.
ERDA-owned facilities

     ERDA conducts most of its nuclear activities at 26 major
sites or reservations. As structures, tanks, etc., become
obsolete or are no longer needed, these facilities are placed
in "excess" by ERDA. An October 1976, ERDA document stated
there were 300 excess facilities and an additional 100 were
expected to become excess by 1981.

     ERDA is developing a computer data system to supply the
information needed to plan for decommissioning its facilities
located at Hanford reservation. The Hanford reservation--l
of the 26 sites--contains most of ERDA's excess facilities.
This computer system, scheduled for completion in June 1977,
will list 537 facilities, both operating and in excess, at
Hanford. The system will include cost estimates for various
decommissioning methods, priority schedules, and other infor-
mation. None of the other reservations were included in the
system because they have relatively small numbers of excess
facilities. These other reservations do, however, include a
significant number of operating facilities, that eventually
have to be decommissioned.

     ERDA officials told us they do not compile relevant details
of the facilities it owns--obsolete or operating--which would
permit it to assess the magnitude of the decommissioning pro-
blems they pose. Such details include the nature and extent of
the radiation problems at these facilities, the decommissioning
methods that would be feasible, the cost of the methods, sched-
ules, and priorities. Efforts to develop these details have been
plagued by a failure of ERDA to develop standard definitions and
rules for the ERDA reservations to use in describing the facili-
ties located there.
     In a memorandum to the Office of Management and Budget,
ERDA estimated it would cost $25,000,000 to $30,000,000 a
year for the next 100 years--or a total of $2,500,000,000 to
$3,000,000,000--to decommission its existing excess facili-
ties. We do not believe this is a credible estimate
     -- ERDA does not have sufficient data to support
        this estimate;
     -- ERDA does not have the information necessary to
        assess the magnitude of the problem posed by its
        excess facilities;
     -- ERDA lacks similar information for its operational
     -- an ERDA contractor estimated in 1972 that it would
        cost as much as $4,000,000,000 to decommission the
        Hanford facilities alone (exclusive of waste); and

     -- ERDA has not developed cost estimates for disposal
        of 71,000,000 gallons of high-level waste. The dis-
        posal of 600,000 gallons of high-level waste at West
        Valley, New York may cost as much as $565,000,000.


     NRC regulatory guides permit three alternatives for
decommissioning a nuclear reactor. It does not require that a
plan for decommissioning be available at the time an operating
license is approved or that a method be selected. Officials
of utility companies told us there is a lot of uncertainty as
to what will actually be required at the time of decommission-
ing some years in the future.

     The Atomic Industrial Forum study recommended a combination
method of temporary protective storage for 65 to 110 years with
later dismantlement. The study showed that immediate dismantlement

 presents a serious occupational radiation hazard to personnel
 doing the dismantling, as well as greater environmental impact.
 The occupational hazard is due primarily to the cobalt-60 in
 the reactor vessel which decays in approximately 100 years.

     While other radionuclides in a reactor require many thou-
sands of years to decay, these radionuclides present a lower
biological hazard. Therefore, if the cobalt-60 is allowed to
decay to safe levels, the radiation hazard would be suffi-
ciently reduced to permit manual removal of the reactor vessel.
The study also showed that temporary protective storage with
delayed dismantling can be from $3,000,000 to $10,000,000
less expensive than immediate dismantlement.

     Although the long-lived radionuclides present a lower
biological hazard, it is important that they remain inacces-
sable to the public until they decay to a safe level. For
this reason, permanent mothballing or entombment are not con-
sidered final or absolute decommissioning alternatives because
of the need for perpetual surveillance and major structural
repairs. Yet, NRC now permits utilities to select these alter-
     A paper presented to the International Atomic Energy
Agency by an ERDA official also concluded that the combina-
tion method is the logical approach to reactor decommissioning.
Preliminary conclusions by a contractor currently studying
decommissioning methods for NRC also support this approach.
This study is expected to be completed in 1979.

     We employed a consultant, a professor of nuclear
physics and an authority on the environmental impact of
nuclear power including waste disposal, to independently
review the Atomic Industrial Forum study. He agreed with
the study's conclusions. He also reviewed data on five
previously decommissioned reactors now :.n protective stor-
age. He concluded that cobalt-60 was the principal contami-
nant of any consequence and that between 70 and 110 years
would be required before radioactivity would decay to safe

     A question arises as to whether the reactor structure
would survive the 70 to 110 years until the primary radioac-
tivity decayed to safe levels. We employed another consultant,
a professor of civil engineering who is an expert on the struc-
tural integrity of concrete, to physically examine a decommis-
sioned reactor to determine whether the structure coIlld be
expected to survive over the life of the cobalt-60. This
consultant concluded that such a facility could easily last
for that period of time.


     The significance and extent of th;e problem of
decommissioning particle accelerators in this country is not
known. A complete inventory by size, type, and usage is not
available, although their use partly determines the radiation
hazard. These uncertainties do not permit adequate control
over the decommissioning of accelerators.
     Accelerators are measured in terms of electron volts and
range in size from desk top models with less than one megavolt
to the recently completed 200,000 megavolt, 4 miles in circum-
ference, accelerator located in Batavia, Illincis.
     Induced radiation causes decommissioning problems in
accelerators and the amount of such radiation is determined
by size, type, and usage. It is generally agreed that most
accelerators 4 mesavolts or less will not emit enough energy
to produce any amount of induced radiation. Those units over
4 megavolts could present a problem, however.
     State health agencies are supposed to submit an annual
inventory of accelerators to the Food and Drug Administration,
Department of Health, Education, and Welfare; but not all States
provide this data. The ones that do, submit only the number of
accelerators, not the size, type, or use.  For fiscal year 1975
the number reported was 1,010.
     We tried to obtain more definitive information, particu-
larly the number of accelerators above or below 4 megavolts,
by sending a questionnaire to each State health agency. Our
efforts were unsuccessful. Some States did not respond. Some
responded but did not provide data, and the data we did receive
could not be reconciled to the Food and Drug Administration data.
For example, one State reported to the Food and Drug Administra-
tion that 127 accelerators were located in the State in fiscal
year 1975. The State officials informed us, however, that
there are 36 accelerators in the State and only 5 have ever been
decommissioned. We also visited several State health agencies
and were advised by State officials that they did not know size,
type, and usage of accelerators in their State.
     NRC and ERDA both have guidelines for the unrestricted
release of facilities and equipment containing surface con-
tamination. These guidelines contain specific radiological
levels to which facilities and equipment must be decontami-
nated before they can be used for any other purpose. However,

neither NRC nor ERDA has standards for unrestricted release
of materials and equipment containing induced activity. This
presents a problem at the time of decommissioning because if
the equipment or materials contain even very low levels of
induced activity, it is not known whether it is safe for
unrestricted release. Generally, the current practice is to
send any equipment or facility to a waste burial ground
if induced activity is above natural radioactivity.
     The dismantlement of an ERDA-owned reactor illustrated
the problems that can occur due to the lack of induced stand-
ards. All concrete with any trace of radioactivity was removed
irom the site and transported to a burial site in another State.
If there had been standards for material and equipment con-
taining induced activity, perhaps much of this concrete could
have been sent to a refuse area within the State at much less
cost. This prcblem is aeneric to any future decommissioning
project where induced activity is present.
     In July 1974, we sent a letter to AEC spelling out prob-
lems presented by the lack of standards for induced radiation.
The specific problems dealt with decommissioning a large accel-
erator. Tons of valuable copper, steel, and stainless steel
containing radiation levels slightly above naturally occurring
background radiation could not be released for unrestricted
use by the general public because there were no standards
for induced radiation.

     AEC officials told us they would have such standards
developed by about September 1975. As of June 1977, however,
these standards had still not been developed. It is apparent
that such standards would permit cost savings and more effec-
tive planning for decommissioning.

     Because man can tolerate only certain amounts of radi-
ation without ill effects, standards have to be set to limit
his exposure from all sources. Since the first radiation
standards were established--as long ago as 1902--they have
grown progressively more restrictive. The first standard was
established to protect against external radiation burns. As
more was learned about the actual hazards of radiation, such
as biological and genetic effects, the standards were changed.
For example, as illustrated in the table below, the standard
for maximum allowable whole body exposure of persons to radi-
ation in restricted areas where radioactive materials are

                                            10 rem 1/ per day
present has been periodically reduced from 1976.
in 1902 to 1.25 rem per calendar auarter in
                    Occupational Standards

         Year                            Standard

         1902                         10.00   rem/day
         1925                           .20   rem/day
         1936                           .10   rem/day
         1950                           .30   rem/week
         1964                          5.00   rem/year
         1976                          1.25   rem/calendar quarter
      Moreover, in January 1977, the Environmental
                               for  setting   standards  for protection
Agency, which is responsible                            issued  regu-
of the environment from all  sources   of  radiation,
                                              rem annually,   the
lations to reduce, from 0.5 rem to 0.025
allowable radiation exposure to    the general   population from
                                       These   standards  are to
all nuclear fuel cycle activities.
be effective December 1, 1979.
      There are currently no Etandards for induced          surface
tivity, but NRC has adopted standards     for  acceptable
                                     these  standards,   by  their
contamination levels. Logically,               exposure  rates   and
very nature, must correlate   to whole   body
                                                     and refined
 therefore have gradually become more stringent
with increased technical knowledge.

      If the historical trenduseforto radiation standards continues,
                                       govern decommissioning
 then the rules that we now                        unsafe years
 and decontamination will likely be considered
 from now.
                                                     Program had
      As of June 1976 the Naval Nuclear Propulsion
                                                         Ships have
 127 reactors in operation and 43 under construction.
                                   and the reactor fuel removed
 been taken out of active status The  ships themselves, which still
 and sent to an ERDA facility.
                      reactors, are in the reserve  fleet in a
 contain the nuclearwhere they are  continuously monitored.
 mothballed status
      It may be that the cost to decommission these reactors
                                             1,100 megawatt
 will not approach the cost for the average to
 power reactor. However, it is  reasonable     assume that the

 1/A rem is a measure of radiation dose to body

170 reactors will ultimately require decommissioning, and just
as with power reactors, there will be a cost and a potential
environmental hazard for this operation.
     Naval program officials told us that they have developed
plans and strategies for decommissioning and decontaminating
naval reactors. They stated, however, that the technical
details of these plans and strategies are classified.
We are currently reviewing the naval plans and strategies
for decommissioning and decontaminatinq reactors.

     The States are responsible for accelerators and naturally
occurring radioactive material. Although many accelerators
will not present a serious decommissioning problem, some of
the large accelerators will. Some States do not have adequate
controls over accelerators. There is also an increasing con-
cern over the control of natural radioactivity such as the
radium problem from uranium mill tailings.

     States generally do not have a separate program for
decommissioning. With few exceptions, there are no provisions
or requirements which would protect the States from financial
loss in the event of default.

     In joint sponsorship with NRC and the Environmental
Protection Agency, the National Conference of Radiation Con-
trol Program Directors investigated options available :o
States to assure licensee financial responsibility in the
event of default. They issued a report in April 1976, which
concluded that bonding for decommissioning and a trust fund
for perpetual care would satisfy many of the situations that
an individual State may encounter. Even though this body of
State representatives made such recommendations over a year
ago, only seven States told us through our questionnaires
that they require an advance accumulation of funds or some
form of bonding for decommissioning. The Conference is also
studying control of natural radiation, and NRC is considering
whether the responsibility for radium--produced by natural
uranium--should be brought under Federal control.


     Until recently, the role of nuclear power as an electri-
cal generating source for the future has been a clear and
unchallenged Government policy. Light water reactors, and
then breeder reactors with their ability to replenish their

own fuel, have been viewed as long-term, almost perpetual,
energy sources.
     The President is now trying to implement an energy pro-
gram that would change the future of nuclear power. It is
his policy to (1) defer the U.S. commitment to advanced nuclear
technologies that are based on the use of plutonium, and
(2) use more of the current light water reactors to meet our

     Light water eactors require a supply of natural uranium.
How much natural uranium exists is a major question that, when
answered, dictates the viability of light water reactors as
an energy source. Estimates of U.S. uranium resources range
between 1.8 and 3.7 million tons. This amount of natural
uranium could fuel 240 large light water reactors--about the
number expected to be operating in the year 2000--for 40 to
85 years.
     Obviously, light water reactors cannot be expected to
continue indefinitely. If another generation of nuclear
reactors cannot be developed or is not needed because another
energy source, such as solar energy, has been introduced, the
end of light water reactors could also be the end of the com-
mercial nuclear power industry.
     The possibility of this industry ending raises questions
as to whether there will be nuclear-related organizations,
nuclear equipment, and individuals expert in the nuclear field
that would be capable of dealing with the decommissioning and
decontamination problems that could remain for about 100 years
after the last reactor is shut down.

                          CHAPTER 5
                    AND RECOMMENDATIONS
     The problems that nuclear-related operations leave behind
are increasing because of the expansion of nuclear technol-
ogies. All of those involved--the Energy Research and Develop-
ment Administration, the Nuclear Regulatory Commission, State
Governments, and industry--are partly to blame for what has
      ERDA has accumulated a large number of excess facilities
which will involve a monumental clean-up effort. At this point
in time, it lacks the necessary information to even plan this
task.   It does not know the radiation and contamination prob-
lems at its facilities, the decommissioning methods that should
be used, the corresponding costs, or priorities. ERDA has begun
to gather this information at one of its reservations, but this
is only the beginning.

     While elimination of these excess facilities is important,
it is also important that ERDA begin to consider and plan for
decommissioning in all future projects. This requires that
decommissioning costs be recognized at the outset of a project.

     Similarly, NRC, which has responsibility on the commercial
side, has not developed cost estimates, acceptable methods, or
standards needed by industry to plan decommissioning or disposal
of their facilities. NRC has not paid much attention to one
of the biggest problems that may confront the public in the
future--that is, who will pay the cost of decommissioning nu-
clear power reactors. It has not made any plans or established
any requirements for advanced accumulation of funds for decom-
missioning reactors or any facilities it licenses with the
exception of uranium mills.
     We believe the cost of decommissioning should be paid by
the current beneficiaries, not by future generations. Just as
ERDA should consider decommissioning costs in its projects,
private companies have an obligation to accumulate funds for
decommissioning during the life of their projects. NRC should
make advance planning for decommissioning mandatory at the
time of licensing, including provision for funding.

     If the States are to maintain their responsibility over
selected nuclear activities, they must be made aware of the
problems with decommissioning and be encouraged to adopt
legislation that will assure that proper decommissioning and
decontamination is carried out.

     Answers to basic questions are missing which preclude
developing a strategy for solving a problem that we are losi,,g
ground on. The solution may very well be expensive--but the
expense should be known so that it can be planned for and paid
for by the responsible parties.

     Although the task of cleaning up the present problem and
preventing future problems will involve a concentrated effort
by all those involved, the Federal sector must lead the way
and set the example. In the pest, the Federal Government has
been shortsighted in its approach to solving decommissioning
problems. The Federal agencies must now view decommissioning
with an eye toward the future, particularly in the areas of
financial responsibility, radiation standards, and capability
to perform the needed decommissioning tasks.

     A bill (H.R. 6181) has been proposed directing ERDA to com-
prehensively study decommissioning. The study needs to be done.
Hopefully it can provide basic information needed to develop
a strategy to sol ? decommissioning problems.

     Because of the magnitude, cost and time already lost, the
Congress should designate one lead Federal agency--the Nuclear
Regulatory Commission--to approve and monitor an overall decom-
missioning strategy. ERDA should continue its research and
development efforts aimed at finding alternatives for decommis-
sioning and decontamination of nuclear facilities. However, we
believe that NRC is uniquely suited for the lead role because
of its charter to independently regulate commercial nuclear
activities to assure public health and safety. This position
is consistent with a previous GAO report and testimony wherein
we advocated independent assessments by the Commission of cer-
tain ERDA operations. In addition, placing this responsibility
with the Commission would, in our view, add to the credibility
of Federal regulation over nuclear energy.

     We recommend that the Administrator, ERDA, as part of his
research and development responsibility

     -- determine the (1) acceptable alternative methods
        of decommissioning, (2) acceptable levels for
        induced radiation and surface contamination, and
        (3) extent of the decommissioning problem for

      -- expand and accelerate a Program
         the nuclear facilities currently to decommission
                                           excess to its
         needs; and
      -- require that program managers plan
                                             for future
         decommissioning and include decommissioning
         cost information in their program
 In addition, we recommend that
 Commission, for those facilitiesthehe Chairman, Nuclear Requlatory
      -- require ,pef ific plans for decommissioning
         the time    licensing, including the decommis-
         sioning metnod to be used and a funding
         to assure that facility owners pay       mechanism
        decommissioning;                     the costs of

     -- determine the acceptable levels
                                         for induced
        radiation and surface contamination
        with environmental standards beinq
        by the Environmental Protection Agency;
     -- encourage States to follow the lead
                                             of the
        Commission in adopting comprehensive
        missioning planning for facilities    decom-
        States' control.                    under


     ERDA was unable to furnish written
                                         comments in time to be
finalized in this report. However,
                                     we met with ERDA officials
and obtained their oral comments which
in this report. ERDA officials disagreedhave been incorporated
responsibility over ERDA facilities.       with giving NRC
sider this matter further and will     However, they will con-
                                   provide written comments in
the near future.
     NRC's comments on the report are contained
dated June 10, 1977.                              in a letter
                       (See app. I.) The letter describes
the actions NRC is taking or plans
                                    to take to develop methods
and criteria for decommissioning nuclear
     Because of time constraints and
limited treatment of the Environmentalthe report's relatively
                                        Protection Agency,
its comments were not sought.

                           CHAPTER 6
                       SCOPE OF REVIEW
     We obtained the information contained in this report by
reviewing documents, studies, reports, correspondence, and
other records, and by interviewing officials at
     -- NRC headquarters, Bethesda, Maryland;

     -- NRC regional offices at Atlanta, Georgia;
        Glen Ellyn, Illinois; King of Prussia,
        Pennsylvania; and Arlington, Texas;
     -- ERD.' Headquarters, Germantown, Maryland; and

     -- ERDA operations offices at Chicago, Illinois;
        and Oak Ridae, Tennessee.
     We also visited various States, utilities, uranium mills,
accelerators, and universities. We sent questionnaires to
all utilities with nuclear reactors currently in operation or
under licensing review, uranium mill owners, fuel fabrication
facilities, State rate-settinq commissions, and State radiation
control units.

     APPENDIX I                                                                   'ENDIX I

        %4G'         {toi                          UNIT"D STATES
                            VA           NUCLEAR REGULATORY COMMISSION
o               M            l                 WASHINGTON, D. C. 20555

    wta'>**_o;                                            June 10, 1977

                    Mr. Monte Canfield, Jr.
                    Director, Energy ana
                      Minerals Division
                    U.S. General Accounting Office
                    Washington, D.C. 20548
                    Dear Mr. Canfield:
                    We have reviewed the GAO draft report entitled "Cleaning Up the
            '       Remains of Nuclear Facilities - A Multi-Billion Dollar Problen;."
                    We provided your representatives with oral comments on this
                    draft report on June 7, 1977. The one day which we were given
                    for our review was insufficient for a thorough review. As you
                    know, due to your schedule for publishing this report, we did
                    not have the opportunity to review a draft that incorporated
                    any changes that were made in response to these oral comments.
                    Therefore, the following comments are based on our understanding
                    of how your final report reflects our oral comments.
                    The reoort as written, and particularly the Digest section, gives
                    the impression that the NRC has done little or nothing to establish
                    acceptable methods or criteria for decommissioning of nuclear
                    facilities over which it has responsibility. In fact, the
                    Commission has established acceptable methods for decommissioning
                    nuclear facilities, i.e , d',mantlement, entombment, mothbdlling,
                    and combinations of these. Furthermore, it is continuing to study
                    the problem to further refine the requirements for decommissioning.
                    Rather conclusive evidence that acceptable methods for decommissioning
                    nuclear facilities have been established is the fact that more than
                    50 reactor facilities have been successfully decommissioned and
                    numerous licenses for other nuclear facilities and activities have
                    been terminated. Furthermore, 10 CFR Part 50 §50.82 provides rules
                    for dismantling a reactor facility and terminating the facility
                    license, and the NRC has published a guide (Regulatory Guide 1.86)
                    which describes conditions and procedures acceptable to the NRC for
                    decommissioning reactor facilities.
                    The Commission is currently sponsoring a study by Battelle Memorial
                    Institute - Pacific Northwest Laboratories (PNL) of the environmental
                    effects, radiological effects, costs and appropriate radioactivity
                    limits for each of the currently accepted methods of decommissioning
                    nuclear reactor and fuel cycle facilities.

APPENDIX I                                                     APPENDIX I

   The NRC staff is now reviewing a report on the results of an
   Atomic Industrial Forum (AIF) study of the environmental effects,
   radiological effects and costs of different methods of decommissioning
   nuclear power facilities. The staff will perform an analysis of
   the AIF decommissioning data as a part of this review. The NRC
   has also initiated a review of the AIF report by Battelle-PNL as
   part of the Battelle-PNL study.
   The GAO report questions who will pay for decommissioning nuclear
   power plants. It is MRC's view that the licensee is to pay for
   this activity. The cost to decommission has been shown by the
   AIF study and our independent evaluation referred to above to be
   a small factor in the overall cost of operating a nuclear power
   plant. The licensee should be able to fund these costs out of
   current revenue. Therefore, we do not perceive the cost of
   decommissioning nuclear power reactors -- which will likely be
   incurred for many reactors several decades from now -- as a crisis
   situation or a problem that requires crash efforts to resolve.
   We do believe that an orderly effort to establish procedures and
   requirements to provide greater assurance that these funds will
   be available should be initiated.
    In addition, the GAO report does not recognize EPA's role in
    the process by which NRC and ERDA develop criteria for acceptable
    levels of contamination. EPA is responsible for developing
    generally applicable environmental standards. Any criteria
    which we develop must be consistent with EPA standards. 1/
    The GAO report discusses nuclear facilities of all types, with
    the implication that all will have large future decommissioning
    problems and costs. Recognition was not given to the large
    variations in complexity among the various nuclear operations
    which range from nuclear power plants to possession of small
    amounts of short-lived radioactive materials for use in industry,
    medicine and education. The great majority of nuclear facilities
    are of the latter category and result in little or no technical
    or financial decommissioning problems for license termination.
    With respect to nuclear power reactors it is true that, with the
    exception of dismantlement, the other methods of decommissioning
    (mothballing and entombment) that have been identified as being
    acceptable to the CcUmissicn are not final, in that they do not
    provide acceptable disposition of the facility for all time.
    However, the use of mothballing and entombment do not relieve
    the licensee of requirements for continued maintenance, access
    control, radiation monitoring, environmental monitoring, and
    inspections until residual activity is removed or decays to

    _/ GAO note.   The report was changed to reflect EPA's role.

                                                                 APPENDIX I

     levels acceptable for unrestricted access. For the large modern
     plants, it is clear that postponing the removal of certain
     components until the radioactivity has decayed to permit
     direct access for dismantlement may prove to be the most more
     alternative with respect to the environment, radiological desirable
     and cost for most facilities. Also, the degree of decommissioning
     effort required to protect the public health and safety and the
     environment will depend significantly on the site specific
     characteristics -- an observation not made in the report.
     The Commission does examine various decommissioning plans and
     their costs and environmental impacts prior to issuance of an
     operating license for a commercial power reactor or test reactor.
     We assure ourselves in each case that feasible deconmissioning
     alternatives, including alternatives for complete dismantling,
     exist and that the applicant either possesses or has reasonable
     assurance of obtaining the necessary funds, as required by our
     Regulations (10 CFR 50.33F). We do not require bonds
    aside of any continjency funds at the operating licenseor stage
    and do not impose Cry particular decommissioning plan as a
    condition of the operating license.
    Federal and State regulatory commissions have historically
    treated plant decommissioning and maintenance costs as allowable
    operating expenses recoverable through rates chargeable
    customers. It is therefor reasonable to assume that the to
    decommissioning and subsequent maintenance costs would be
    charged to operating expenses either in the year they are
    incurred or amortized over a period of years according to the
    policy of the rate making regulatory authorities.
    In the area of nuclear fuel cycle facilities, the NRC is currently
    preparing a Generic Environmental Impact Statement (GEIS) on
    uranium milling. This GEIS is to examine mill tailings reclamation
    and financial surety arrangements and will be the basis for NRC
    regulations and regulatory guides. The draft GEIS is scheduled
    to be issued in August 1978.
     In this area, until the GEIS is issued and new regulations
     implemented, NRC is taking a conservative approach
    to renewing licenses and granting new applications. with respect
                                                          For new
    applications, we are requiring applicants to develop and commit
    to a tailings management plan as a license condition. This
    reduces the impact of the tailings to essentially the same
    impact as occurs at that site with the material in its natural
    state. In addition, NRC is requiring that the applicant provide
    a financial surety arrangement to assure that the tailings
    management plan will be carried out. With regard to existing
    licenses, NRC is requiring that a tailings management plan and
    financial surety arrangement be committed to before license
    renewal as a license condition.

APPENDIX I                                                       APPENDIX I

   Also, for new major fuel cycle licenses and at the time of
   renewal for existing licenses, the licensee is being requested
   to provide decommissioning plans and financial arrangements
   for defraying these expenses. These will be made license
   conditions. Additionally, the staff is exploring what
   statutory or regulatory changes di'e needed.   NRC does not
   plan to firm up details of financial arrangements until
   after a study on financial surety arrangements now being carried
   out as part of the GEIS on uranium milling is completed, since
   most of the considerations dealt with in that study will also
   be applicable to fuel cycle licenses. In addition, NRC feels
   that a few practical cases should be completed prior to rule
   Thanks for the opportunity to comment on the report.


                               /       V. Gossick
                                   Executive Director
                                     for Operations

APPENDIX II                                           APPENDIX II

                      PRINCIPAL OFFICIALS
                   -ACTIVITIE DISCUSSED IN
                            THIS REPORT

                                             Tenure of office
                                            From           To
                 Nuclear Regulatory Commission

     Marcus A. Rowden                   Apr. 1976       Present
     William A. Anders                  Jan. 1975       Apr. 1976
                      Energy Research and
                 Development Administration


     Robert W. Fri (acting)             Jan. 1977      Present
     Robert C. Seamans, Jr.             Jan. 1975      Jan. 1977