oversight

Spent Nuclear Fuel: Accumulating Quantities at Commercial Reactors Present Storage and Other Challenges

Published by the Government Accountability Office on 2012-08-15.

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

              United States Government Accountability Office

GAO           Report to Congressional Requesters




August 2012
              SPENT NUCLEAR
              FUEL
              Accumulating
              Quantities at
              Commercial Reactors
              Present Storage and
              Other Challenges




GAO-12-797
                                           August 2012

                                           SPENT NUCLEAR FUEL
                                           Accumulating Quantities at Commercial Reactors
                                           Present Storage and Other Challenges
Highlights of GAO-12-797, a report to
congressional requesters




Why GAO Did This Study                     The amount of spent fuel stored on-site at commercial nuclear reactors will
                                           continue to accumulate—increasing by about 2,000 metric tons per year and
Spent nuclear fuel, the used fuel          likely more than doubling to about 140,000 metric tons—before it can be moved
removed from nuclear reactors, is one      off-site, because storage or disposal facilities may take decades to develop. In
of the most hazardous substances           examining centralized storage or permanent disposal options, GAO found that
created by humans. Commercial spent        new facilities may take from 15 to 40 years before they are ready to begin
fuel is stored at reactor sites; about     accepting spent fuel. Once an off-site facility is available, it will take several more
74 percent of it is stored in pools of     decades to ship spent fuel to that facility. This situation will be challenging
water, and 26 percent has been             because by about 2040 most currently operating reactors will have ceased
transferred to dry storage casks. The      operations, and options for managing spent fuel, if needed to meet
United States has no permanent
                                           transportation, storage, or disposal requirements, may be limited.
disposal site for the nearly
70,000 metric tons of spent fuel           Studies show that the key risk posed by spent nuclear fuel involves a release of
currently stored in 33 states.             radiation that could harm human health or the environment. The highest-
GAO was asked to examine (1) the           consequence event posing such a risk would be a self-sustaining fire in a drained
amount of spent fuel expected to           or partially drained spent fuel pool, resulting in a severe widespread release of
accumulate before it can be moved          radiation. The Nuclear Regulatory Commission (NRC), which regulates the
from commercial nuclear reactor sites,     nation’s spent nuclear fuel, considers the probability of such an event to be low.
(2) the key risks posed by stored spent    According to studies GAO reviewed, the probability of such a fire is difficult to
fuel and actions to help mitigate these    quantify because of the variables affecting whether a fire starts and spreads.
risks, and (3) key benefits and            Studies show that this low-probability scenario could have high consequences,
challenges of moving spent nuclear         however, depending on the severity of the radiation release. These
fuel out of wet storage and ultimately     consequences include widespread contamination, a significant increase in the
away from commercial nuclear               probability of fatal cancer in the affected population, and the possibility of early
reactors. GAO reviewed NRC                 fatalities. According to studies and NRC officials, mitigating procedures, such as
documents and studies on spent fuel’s      replacement water to respond to a loss of pool water from an accident or attack,
safety and security risks and industry     could help prevent a fire. Because a decision on a permanent means of
data, interviewed federal and state        disposing of spent fuel may not be made for years, NRC officials and others may
government officials and                   need to make interim decisions, which could be informed by past studies on
representatives from industry and other    stored spent fuel. In response to GAO requests, however, NRC could not easily
groups, and visited reactor sites.
                                           identify, locate, or access studies it had conducted or commissioned because it
                                           does not have an agencywide mechanism to ensure that it can identify and
What GAO Recommends                        locate such classified studies. As a result, GAO had to take a number of steps to
To help facilitate decisions on storing    identify pertinent studies, including interviewing numerous officials.
and disposing of spent nuclear fuel        Transferring spent fuel from wet to dry storage offers several key benefits,
over the coming decades, GAO               including safely storing spent fuel for decades after nuclear reactors retire—until
recommends that NRC develop a              a permanent solution can be found—and reducing the potential consequences of
mechanism for locating all classified
                                           a pool fire. Regarding challenges, transferring spent fuel from wet to dry storage
studies. NRC generally agreed with the
                                           is generally safe, but there are risks to moving it, and accelerating the transfer of
findings and the recommendation in
the report.                                spent fuel could increase those risks. In addition, operating activities, such as
                                           refueling, inspections, and maintenance, may limit the time frames available for
                                           transferring spent fuel from wet to dry storage. Once spent fuel is in dry storage,
                                           there are additional challenges, such as costs for repackaging should it be
                                           needed. Some industry representatives told GAO that they question whether the
                                           cost of overcoming the challenges of accelerating the transfer from wet to dry
                                           storage is worth the benefit, particularly considering the low probability of a
                                           catastrophic release of radiation. NRC stated that spent fuel is safe in both wet
View GAO-12-797. For more information,
contact Gene Aloise at (202) 512-3841 or   and dry storage and that accelerating transfer is not necessary given the small
aloisee@gao.gov.                           increase in safety that could be achieved.


                                                                                     United States Government Accountability Office
Contents


Letter                                                                                      1
               Background                                                                   5
               Large Quantities of Spent Nuclear Fuel Are Expected to Remain at
                 Commercial Reactor Sites for Decades                                     19
               The Key Risk of Stored Spent Fuel Is Difficult to Quantify, but
                 Some Mitigating Actions Have Been Taken                                  27
               Transfer of Spent Fuel from Wet Storage Offers Benefits but Also
                 Presents Challenges                                                      37
               Conclusions                                                                47
               Recommendation for Executive Action                                        47
               Agency Comments                                                            47

Appendix I     Scope and Methodology                                                      50



Appendix II    Selected Other Countries’ Spent Fuel Management Programs                   53



Appendix III   Accumulation of Commercial Spent Fuel by State over Time                   57



Appendix IV    Comments from the Nuclear Regulatory Commission                            59



Appendix V     GAO Contact and Staff Acknowledgments                                      61



Tables
               Table 1: Typical Reactor Characteristics and Storage Capacity              22
               Table2: Summary of Commercial Nuclear Programs and Spent Fuel
                        Management Programs for Selected Countries                        53
               Table 3: Cumulative Quantities of Spent Fuel, by State, for 2012,
                        2027, 2032, 2052, and 2067                                        57


Figures
               Figure 1: Commercial Spent Nuclear Fuel Storage Sites                        6



               Page i                            GAO-12-797 Accumulation of Spent Nuclear Fuel
Figure 2: Fuel Pellet and Fuel Rod Assembly for a Commercial
         Nuclear Power Reactor                                                            8
Figure 3: Location of a Spent Nuclear Fuel Pool in a Boiling Water
         Reactor                                                                          10
Figure 4: Spent Nuclear Fuel Pool                                                         11
Figure 5: Canister in a Transfer Cask in a Spent Nuclear Fuel Pool                        15
Figure 6: Spent Fuel in Dry Storage                                                       16
Figure 7: Trends in Accumulation of Spent Nuclear Fuel Overall
         and in Wet and Dry Storage                                                       21
Figure 8: Accumulation of Commercial Spent Fuel by State over
         Time                                                                             24
Figure 9: Growth Trend of Total Spent Fuel Compared with Spent
         Fuel from Decommissioned Reactors                                                27




Abbreviations
DOE         Department of Energy
EPRI        Electric Power Research Institute
NRC         Nuclear Regulatory Commission


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Page ii                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
United States Government Accountability Office
Washington, DC 20548




                                   August 15, 2012

                                   Congressional Requesters

                                   Nuclear fuel that has been used and removed from the reactor core of a
                                   nuclear power plant—known as spent nuclear fuel—is one of the most
                                   hazardous substances created by humans. 1 If not properly contained or
                                   shielded, the intense radioactivity of spent fuel can cause immediate
                                   deaths and environmental contamination and, in lower doses, cause long-
                                   term health hazards, such as cancer. Some radioactive components of
                                   spent fuel remain hazardous for tens of thousands of years. In the United
                                   States, the national inventory of commercial spent nuclear fuel amounts
                                   to nearly 70,000 metric tons. Concerns were heightened about the
                                   vulnerabilities at nuclear power plants to releases of large doses of
                                   radiation into surrounding communities after the terrorist attacks of
                                   September 11, 2001, and the earthquake and tsunami that struck the
                                   Fukushima Daiichi nuclear power plant complex in Japan in March 2011.

                                   Two federal agencies—the Nuclear Regulatory Commission (NRC) and the
                                   Department of Energy (DOE)—are primarily responsible for the regulation
                                   and disposal of the nation’s spent nuclear fuel. NRC regulates the
                                   construction and operation of commercial nuclear power plants and spent
                                   fuel repositories, as well as the storage and transportation of spent fuel.
                                   DOE is charged with investigating sites for a federal geologic repository to
                                   dispose of spent nuclear fuel and high-level nuclear waste from commercial
                                   nuclear power plants and some defense activities under the Nuclear Waste
                                   Policy Act of 1982, as amended. 2 In 1987, however, Congress amended



                                   1
                                    Spent (or used) nuclear fuel can no longer efficiently generate power in a nuclear reactor.
                                   However, it is potentially a resource because it can be reprocessed to separate out
                                   uranium and plutonium to be used as fuel again in a reactor. Reprocessing, however, still
                                   results in nuclear waste that requires disposal. The United States does not reprocess its
                                   spent nuclear fuel, and this fuel, when it is accepted for disposal, is considered to be high-
                                   level waste as defined by the Nuclear Regulatory Commission.
                                   2
                                    This report does not address the about 13,000 metric tons of spent nuclear fuel and high-
                                   level waste DOE manages, which was primarily generated by the nation’s nuclear
                                   weapons program. For example, DOE manages some former commercial spent fuel, such
                                   as spent fuel at a reactor at Fort St. Vrain in Colorado. We reported separately on this
                                   issue. See GAO, DOE Nuclear Waste: Better Information Needed on Waste Storage at
                                   DOE Sites as a Result of the Yucca Mountain Shutdown, GAO-11-230 (Washington, D.C.:
                                   Mar. 23, 2011).




                                   Page 1                                       GAO-12-797 Accumulation of Spent Nuclear Fuel
the act to direct DOE to focus its efforts only on Yucca Mountain, Nevada.
In addition, the act authorized DOE to contract with commercial nuclear
reactor operators to take custody of their spent nuclear fuel for disposal at
the repository beginning in January 1998, but because of a series of delays
due to, among other reasons, state and local opposition to the construction
of a permanent nuclear waste repository in Nevada and technical
complexities, DOE was unable to begin receiving waste by that time. 3
Currently, the status of the proposed repository at Yucca Mountain is
uncertain. DOE and NRC separately suspended their efforts to license this
repository in 2010 and 2011, respectively, and several parties have filed a
petition in federal court seeking to force NRC to resume the licensing
proceeding. 4 In April 2011, we reported on the proposed termination of the
Yucca Mountain repository and recommended actions to assist future
waste management efforts. 5 In that report, we suggested that Congress
might consider a more predictable funding mechanism and an independent
organization, outside DOE, for siting and developing a permanent
repository. NRC concurred with the facts in a draft of that report, and DOE
strongly disagreed with key facts in the draft and our recommendations. No
action has been taken to implement our recommendations. Because it did
not take custody of the spent fuel starting in 1998, DOE reports that as of
September 2011, 76 lawsuits have been filed against it by utilities to
recover claimed damages resulting from the delay. These lawsuits have
resulted in a cost to taxpayers of about $1.6 billion from the U.S. Treasury’s
judgment fund. DOE estimates that future liabilities will total about an
additional $19.1 billion through 2020 and that they may cost about $500
million each year after that. 6

Spent nuclear fuel consists of thumbnail-sized pellets of uranium dioxide
fitted into 12- to 15-foot hollow metal rods, which are bundled together


3
 Some technical complexities, such as DOE’s assessment of how heat from the spent
nuclear fuel might affect the performance of the repository, became the focus of years of
scientific inquiry.
4
 NRC responded to the parties’ petition by stating that it does not have sufficient
appropriated funds to complete action on the license application. On August 3, 2012, the
federal court reviewing the parties’ petition issued an order holding the case in abeyance
pending updates by the parties on the status of fiscal year 2013 appropriations with
respect to the issues presented in the case.
5
 GAO, Commercial Nuclear Waste: Effects of a Termination of the Yucca Mountain
Repository Program and Lessons Learned, GAO-11-229 (Washington, D.C.: Apr. 8, 2011).
6
These costs are in constant 2011 dollars.




Page 2                                      GAO-12-797 Accumulation of Spent Nuclear Fuel
into assemblies. Operators of commercial nuclear power reactors use two
methods to store spent nuclear fuel: wet storage in pools of water or dry
storage in steel and concrete casks. When reactor operators first remove
spent fuel from a reactor, it is thermally hot and intensely radioactive and
must be immersed in deep pools of water, which cools the spent fuel and
shields the environment from the spent fuel. As the inventory of spent fuel
has grown, reactor operators have increased the number of assemblies
stored in the pools—generally 40 feet deep—by replacing existing
storage racks with newer racks holding denser arrangements of
assemblies. Despite the denser arrangements, which can sometimes hold
thousands of assemblies, spent fuel pools have limited capacity.
Beginning in the 1980s, reactor operators began to transfer spent fuel to
dry cask storage systems to free space in the pools for fuel removed from
the reactor. Spent fuel can be transferred to dry storage once it has aged
sufficiently to be cooled by passive air ventilation—generally after about 5
years. Dry cask storage typically consists of a stainless steel canister
placed inside a larger stainless steel or concrete cask, which isolates it
from the environment. Dozens of community action and environmental
groups have advocated that reactor operators accelerate the transfer of
spent fuel from pools to dry storage cask systems, believing the risks of
dry storage are lower than that of wet storage. NRC maintains that spent
fuel is safe and secure in both wet and dry storage systems.

In light of concerns over the nation’s growing quantities of stored spent
nuclear fuel, ongoing security threats, and safety concerns raised by events
in Japan, you asked us to review the safety and security of spent fuel.
Specifically, our objectives were to examine (1) the amount of spent fuel
that is expected to accumulate before it can be moved from commercial
nuclear reactor sites, (2) the key safety and security risks posed by spent
fuel stored at reactor sites and actions to help mitigate these risks, and
(3) key benefits and near- and long-term challenges of transferring spent
nuclear fuel out of wet storage and ultimately away from reactor sites.

To answer these objectives, we reviewed pertinent NRC documents;
analyzed studies on the safety and security of spent fuel; interviewed
officials from federal and state regional organizations and representatives
from industry, academia, and various community action and environmental




Page 3                              GAO-12-797 Accumulation of Spent Nuclear Fuel
groups; and visited selected decommissioned and operating reactor sites. 7
Specifically, to determine the amount of spent fuel projected to accumulate
before it can be moved from individual reactor sites, we obtained a
database on spent fuel projections from the Nuclear Energy Institute, an
industry advocacy organization. We based our estimates for when
centralized storage and permanent disposal facilities might become
available on assumptions from our November 2009 report and on
additional analysis based on reports from various sources, including DOE
and the Electric Power Research Institute (EPRI, a nonprofit research
entity) on centralized storage and permanent disposal. 8 To determine key
safety and security risks of spent fuel and potential mitigation actions, we
reviewed studies from NRC and other groups, including Sandia National
Laboratories, the National Academy of Sciences, and community action
groups. We also reviewed NRC requirements addressing the safety and
security of spent fuel and directives from the nuclear power industry. We
interviewed officials from NRC and DOE and representatives from industry,
academia, and various community groups. We visited the Haddam Neck
decommissioned reactor site and the Millstone reactor in Connecticut, the
Hope Creek and Salem reactors in New Jersey, and the Susquehanna
reactor in Pennsylvania, and we spoke with NRC officials and industry
representatives about spent fuel storage issues at these sites. To
determine the benefits and challenges of transferring spent fuel from wet to
dry storage, we reviewed documents from NRC, DOE, industry, and
community groups. We also interviewed officials from NRC, DOE, and
state regional organizations, and representatives of industry, academia, the
Blue Ribbon Commission on America’s Nuclear Future, 9 and community
groups. Appendix I presents our scope and methodology in more detail.



7
 Our selection of sites was a judgmental sample based on reactor sites that met specific
criteria, including the type of operating reactor, the type of dry storage systems used, and
whether the reactor was operating or decommissioned. We found a group of reactors in
the Northeast meeting these criteria, enabling us to visit sites in a single 1-week trip.
Although our observations on the methods and risks of spent fuel storage are similar at all
reactor sites, each site is sufficiently different that our specific observations at one site
cannot be generalized to all reactor sites.
8
 GAO, Nuclear Waste Management: Key Attributes, Challenges, and Costs for the Yucca
Mountain Repository and Two Potential Alternatives, GAO-10-48 (Washington, D.C.:
Nov. 4, 2009).
9
 In 2010, the administration directed DOE to establish this Blue Ribbon Commission of
recognized experts to study nuclear waste management alternatives. The commission
issued a report in January 2012.




Page 4                                      GAO-12-797 Accumulation of Spent Nuclear Fuel
             We conducted this performance audit from June 2011 to August 2012, in
             accordance with generally accepted government auditing standards.
             Those standards require that we plan and perform the audit to obtain
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.


             In the United States, the national inventory of commercial spent nuclear
Background   fuel amounts to nearly 70,000 metric tons, which is stored at 75 sites in
             33 states (see fig. 1).




             Page 5                              GAO-12-797 Accumulation of Spent Nuclear Fuel
Figure 1: Commercial Spent Nuclear Fuel Storage Sites




                                        Note: Of the 75 sites, 65 have currently operating reactors, 7 have decommissioned reactors, 2 have
                                        reactors being decommissioned, and 1 site was constructed as a storage pool for spent fuel awaiting
                                        reprocessing.




                                        Page 6                                         GAO-12-797 Accumulation of Spent Nuclear Fuel
Commercial Nuclear       Fuel for commercial nuclear power reactors is typically made from low-
Reactor Operations and   enriched uranium fashioned into thumbnail-size ceramic pellets of
Storage of Spent Fuel    uranium dioxide. 10 These pellets are fitted into 12- to 15-foot hollow rods,
                         referred to as cladding, made of a zirconium alloy. 11 The rods are then
                         bound together into a larger assembly. A typical reactor holds about 100
                         metric tons of fuel when operating—generally from 200 to 800 fuel
                         assemblies. The uranium in the assemblies undergoes fission—a process
                         of splitting atoms into fragments and neutrons that then bombard other
                         atoms—resulting in a sustainable chain reaction that creates an
                         enormous amount of heat and radioactivity. The heat is used to generate
                         steam for a turbine, which generates electricity. The fragments created
                         when fission splits atoms, or when bombarding neutrons bond with
                         atoms, include hundreds of radioisotopes, or radioactive substances,
                         such as krypton-90, cesium-137, and strontium-90. Furthermore, the
                         neutron bombardment of uranium can also create heavier radioisotopes,
                         such as plutonium-239. The radioisotopes produced in a reactor can
                         remain hazardous from a few days to many thousands of years; these
                         radioisotopes remain in the fuel assemblies and as components of the
                         resulting spent fuel.

                         Each fuel assembly is typically used in the reactor for 4 to 6 years, after
                         which most of the fuel it contains is spent, and the uranium dioxide is no
                         longer cost-efficient at producing energy. Reactor operators typically
                         discharge about one-third of the fuel assemblies every 18 months to 2
                         years and place this spent fuel in a pool to cool. Water circulates in the
                         pool to remove the enormous heat generated from the radioactive decay
                         of some of the radioisotopes. As long as circulating water continues to
                         remove this heat, pool water temperature is maintained well below
                         boiling, typically below 120 degrees Fahrenheit. If exposed to air,
                         however, recently discharged spent fuel could rise in temperature by
                         hundreds or thousands degrees Fahrenheit. A pool is needed to ensure


                         10
                           Uranium is found naturally in the ground, consisting of about 99.3 percent of the
                         nonfissile uranium-238, with only 0.7 percent fissile uranium-235. In its natural state,
                         uranium is only slightly radioactive and can be handled without shielding. To make fuel for
                         a commercial power reactor, the proportion of uranium-235—which is responsible for a
                         sustainable nuclear chain reaction—must be enriched to 3 to 5 percent, but even this
                         enrichment requires little shielding from heat or radioactivity. It is not until after the
                         uranium is irradiated in a reactor and is bombarded with neutrons that it becomes
                         hazardous because of production of other radioisotopes.
                         11
                           A zirconium alloy is used because of its resistance to corrosion and low absorption of
                         neutrons, meaning it does not interfere with the nuclear chain reaction.




                         Page 7                                     GAO-12-797 Accumulation of Spent Nuclear Fuel
                                        that heat generated from the decay of radioisotopes, particularly
                                        immediately after discharge from a reactor, does not damage fuel rods
                                        and release radioactive material. Figure 2 shows a fuel pellet for a
                                        commercial nuclear reactor and a fuel rod in an assembly.

Figure 2: Fuel Pellet and Fuel Rod Assembly for a Commercial Nuclear Power Reactor




                                        The pools of water are typically about 40 feet deep, with at least 20 feet of
                                        water covering the spent fuel, and the water is cooled and circulated to
                                        keep the assemblies from overheating. These pools are constructed
                                        according to NRC’s requirements, typically 4- to 6-feet thick with steel-
                                        reinforced concrete and a steel liner. The pools must be located inside
                                        what is known as the vital area of a nuclear power reactor, protected by
                                        armed guards, physical barriers, and limited access. Within the vital area,



                                        Page 8                                GAO-12-797 Accumulation of Spent Nuclear Fuel
pools may be in one of two locations, depending on the type of reactor. In
a pressurized water reactor, spent fuel is stored in a pool at or below
ground level, 12 but in a typical boiling water reactor, spent fuel is stored in
a pool well above ground level, near the reactor vessel, as high as three
stories above ground. 13 Figure 3 shows the location of a spent fuel pool
for a boiling water reactor, and figure 4 shows a typical spent fuel pool.




12
  In addition, a pressurized water reactor has two independent loops: one to carry heat to
a steam generator and one to carry nonradioactive steam to a turbine to generate
electricity. In a boiling water reactor, steam generated by the reactor goes directly to a
turbine, and after leaving the turbine, the slightly radioactive steam is condensed into
water and recycled back to the reactor.
13
  The reactors damaged at the Fukushima Daiichi nuclear power plant complex in Japan
were boiling water reactors. The Japanese had difficulty accessing one of the reactor’s
spent fuel pools because of its height above ground. According to NRC, all but 4 of the 35
boiling water reactors in the United States have similar designs. The spent fuel pools at
these 4 boiling water reactors are situated in a separate fuel storage building at or near
ground level.




Page 9                                     GAO-12-797 Accumulation of Spent Nuclear Fuel
Figure 3: Location of a Spent Nuclear Fuel Pool in a Boiling Water Reactor




Page 10                                 GAO-12-797 Accumulation of Spent Nuclear Fuel
Figure 4: Spent Nuclear Fuel Pool




As part of the construction permit and operating license application process
for nuclear reactors, NRC requires companies licensed to operate these
reactors to assess natural hazards, such as earthquakes, floods,
hurricanes, and tidal waves that their reactors might face. Reactor
operators must also show that their proposed pool designs would survive
the most severe natural hazards, or combinations of less severe hazards,
expected for that particular area. 14 Since the Fukushima Daiichi disaster,
NRC has required reactor operators to reevaluate their original design
criteria against more recent seismic information that has been developed
since many of the nuclear power plants were first licensed. According to
NRC documents, NRC developed its requirements with a concept of
“defense-in-depth,” which is a way of designing and operating nuclear



14
 See GAO, Nuclear Regulatory Commission: Natural Hazard Assessments Could Be
More Risk-Informed, GAO-12-465 (Washington, D.C.: Apr. 26, 2012).




Page 11                               GAO-12-797 Accumulation of Spent Nuclear Fuel
power reactors that focuses on creating multiple independent and
redundant layers of defense to compensate for potential human and
mechanical failures so that no single layer, no matter how robust, is
exclusively relied upon. 15

To remove a spent fuel assembly from the reactor, an operator must stop
the nuclear chain reaction, then allow the water in the reactor to
depressurize and cool before accessing the fuel assemblies, a process
that typically takes several days. Once spent fuel is discharged from a
reactor and placed in a pool, the spent fuel continues to decay into other
substances and continues to generate enormous amounts of heat. 16 For
example, plutonium-239—one of the components of spent fuel—decays
into various radioactive substances, such as thorium and radium, and
eventually decays into a stable, nonradioactive form of lead, although the
entire process may take millions of years. As a general rule, the older the
spent fuel, the cooler and less hazardous it is, but the spent fuel still has
enough long-lived components to make it dangerous to humans and the
environment for tens of thousands of years. When in an intact assembly,
these components are dangerous only to nearby persons if the assembly
is not adequately shielded and is only dangerous to the public and
environment if its components are aerosolized and dispersed. Different
components of the spent fuel decay at different rates, but many of the
more hazardous components decay quickly. For example, iodine-131 has
a half-life of 8.04 days and will be virtually gone within 3 months.
(Radioactive iodine can congregate in the thyroid and cause thyroid
cancer. For this reason, some populations living near nuclear power
plants have been given iodine tablets to take if advised to do so during an
event to reduce the likelihood of developing cancer in the event of a




15
  According to NRC, the defense-in-depth concept is not defined in NRC regulations, and
no single, agency-accepted description of the concept exists. Nevertheless, the term
includes the use of access controls, physical barriers, redundant and diverse key safety
functions, and emergency response measures.
16
  All radioactive substances—referred to as radioisotopes—are unstable and
spontaneously transform themselves into more stable isotopes by capturing or emitting
atomic particles or by fission. The time it takes a radioisotope to decay into more stable
substances is measured by a half-life. A half-life is the length of time it takes for one-half
of a particular radioisotope to decay into a new isotope. After two half-lives, one-quarter of
the original radioisotope will be left, but three-quarters will have changed to the new
isotope. After 10 half-lives, only 1/1,000 of the original radioisotope is left.




Page 12                                      GAO-12-797 Accumulation of Spent Nuclear Fuel
nuclear emergency. 17) In contrast, cesium-137 has a half-life of 30.2
years and will take over 300 years to decay to negligible amounts.
Cesium-137 contributes to the decay heat in a spent fuel pool and is a
significant land contaminant if released.

Typically, according to NRC officials, spent fuel must remain in a pool for at
least 5 years to decay enough to remain within the heat limits of currently
licensed dry cask storage systems. Spent fuel cools very rapidly for the first
5 years, after which the rate of cooling slows significantly. Spent fuel can
be sufficiently cool to load into dry casks earlier than 5 years, but doing so
is generally not practical. Some casks may not accommodate a full load of
spent fuel because of the greater heat load. That is, the total decay heat in
these casks needs to be limited to prevent the fuel cladding from becoming
brittle and failing, which could affect the alternatives available to manage
spent fuel in the future, such as retrieval. In recent years, reactor operators
have moved to a slightly more enriched fuel, which can burn longer in the
reactor. Referred to as high-burn-up fuel, this spent fuel may be hotter and
more radioactive coming out of a reactor than conventional fuel and may
have to remain in a pool for as long as 7 years to cool sufficiently.

In the original designs submitted for spent fuel pools, fuel assemblies
were packed in relatively low densities, but operators have replaced these
low-density racks with higher-density racks to store more spent fuel.
According to NRC officials, NRC accepts high-density storage of spent
fuel if certain conditions are met, such as adequate cooling, the
maintenance of structural integrity, and the prevention of a critical chain
reaction. Neutron-absorbing materials can be used to keep closely
packed assemblies from starting a chain reaction. 18 As pools began to fill
in the 1980s, NRC conducted several safety studies on the impact of
increasing the density of spent fuel in pools and determined that the risk
of a potential release from overheating or igniting, or even of a critical
chain reaction from the dense geometric configuration, was small,
particularly if certain steps were taken to reduce the risk. Even with re-


17
  Taking potassium iodine tablets floods the thyroid with nonradioactive iodine so the
thyroid cannot absorb radioactive iodine-131. Children are particularly susceptible to
cancer from iodine-131.
18
  Neutron-absorbing material typically contains boron, which absorbs neutrons and will
help prevent a nuclear chain reaction. NRC has identified some issues with degradation of
the boron plates in boiling water and pressurized water reactors and asked operators to
monitor their condition.




Page 13                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
racking to a dense configuration, however, spent nuclear fuel pools are
reaching their capacities and may contain several thousand assemblies
each.

As reactor operators have run out of space in their spent fuel pools, more
operators have turned to dry cask storage systems. These systems consist
of a steel canister protected by an outer cask made of steel or steel and
concrete to provide shielding from the heat and radiation of spent fuel. In
one typical process of transferring spent fuel to dry storage, reactor
operators place a steel canister inside a larger steel transfer cask and
lower both into a pool. Spent fuel is loaded into the canister, a lid is placed
on the canister, and then both the canister and transfer cask are removed
from the pool. The lid is welded onto the canister, and the water drained.
Then the canister and transfer cask are aligned with a storage cask and the
canister is maneuvered into the storage cask. The storage casks, in either
vertical or horizontal designs, are usually situated on a large concrete pad
surrounded by safety systems and a security infrastructure, such as
radiation detection devices and intrusion detection systems. The transfer
process has become routine at some power plants (see fig. 5).




Page 14                              GAO-12-797 Accumulation of Spent Nuclear Fuel
Figure 5: Canister in a Transfer Cask in a Spent Nuclear Fuel Pool




In addition to regulating the construction and operation of commercial
nuclear power plants, NRC also regulates spent fuel in dry storage. NRC
requires that spent fuel in dry storage be stored in approved systems that
offer protection from significant amounts of radiation. NRC evaluates the
design of passively air-cooled dry storage systems for resistance to
certain natural disasters, such as floods, earthquakes, tornado missiles,
and temperature extremes. NRC may require physical tests of the
systems, or it may accept information derived from scaled physical tests
and computer modeling. For example, dry storage systems must be able
to withstand, among other things, being dropped from the height to which
it would be lifted during operations; being tipped over by seismic activity,
weather, or other forces or accidents; fires; and floods. NRC has also
analyzed the performance of dry storage systems in different terrorist
attack scenarios. Once a dry storage system is approved, NRC issues a
certificate of compliance for a cask design. Currently, NRC may issue a




Page 15                                 GAO-12-797 Accumulation of Spent Nuclear Fuel
cask certificate for a term not to exceed 40 years. 19 Similarly, NRC may
renew a cask certificate for a term not to exceed 40 years (see fig. 6). 20

Figure 6: Spent Fuel in Dry Storage




The length of time that spent fuel can safely be stored in dry casks is
uncertain. We earlier reported that experts agree that spent fuel can be
safely stored for up to about 100 years, assuming regular monitoring and
maintenance. 21 In December 2010, NRC issued a determination and
associated rule stating that spent fuel can be safely stored for up to 60


19
  Cask certificates issued before May 17, 2011, expire 20 years from the date of issuance
and may be renewed for an additional 20 years. In February 2011, NRC amended part 72
to change the 20-year term and renewal period to a term not to exceed 40 years. 76 Fed.
Reg. 8872, 8875-76. (Feb. 16, 2011). 10 C.F.R. § 72.238 (2012).
20
 10 C.F.R § 72.240(a) (2012).
21
 GAO-10-48.




Page 16                                   GAO-12-797 Accumulation of Spent Nuclear Fuel
                              years beyond the licensed life of the reactor in a combination of wet and
                              dry storage. 22 Four states, an Indian community, and environmental
                              groups petitioned for review of NRC’s rule, however, arguing in part that
                              NRC violated the National Environmental Policy Act by failing to prepare
                              an environmental impact statement in connection with the
                              determination. 23 On June 8, 2012, the U.S. Court of Appeals for the
                              District of Columbia Circuit held that the rulemaking did require either an
                              environmental impact statement or a finding of no significant
                              environmental impact and remanded the determination and rule back to
                              NRC for further analysis. NRC has not yet indicated what actions it will
                              take in response to the court’s action. On August 7, 2012, the
                              commissioners voted not to issue final licenses dependent on the
                              determination and rule until it addresses the court’s remand, however, the
                              commission is currently preparing an environmental impact statement on
                              the effects of storing spent fuel for 200 years. In addition, NRC, DOE, and
                              industry are conducting a series of studies to evaluate the regulatory
                              actions or additional engineering measures needed for long-term storage
                              of spent fuel to account for possible degradation of the canisters or the
                              spent fuel in the canisters.


Federal Efforts to Identify   Since the 1950s, even before operation of the first commercially licensed
and Develop a Site for a      nuclear power reactor in the United States, the federal government
Spent Fuel Repository         recognized the need to manage the back end of the fuel cycle—spent
                              nuclear fuel removed from a reactor. A 1957 National Academy of
                              Sciences report endorsed deep geological formations to isolate high-level
                              radioactive waste, which includes spent nuclear fuel, but during the 1950s
                              and 1960s, nuclear waste management received relatively little attention


                              22
                                NRC first issued the determination and rule in 1984 and updated them in 1990. Because
                              the licensed life of a reactor may include the term of a revised or renewed license, which
                              together may extend to 60 years, NRC’s determination extends to 120 years. The
                              determination and rule also state that NRC believes that sufficient mined geologic
                              repository capacity will be available when necessary. 75 Fed. Reg. 81037 (Dec. 23, 2010);
                              10 C.F.R. § 51.23 (2012). NRC has stated that, as a matter of policy, it will not license
                              reactors if it does not have reasonable confidence that the spent fuel can be disposed of
                              safely and that spent fuel, if properly stored and monitored, can be kept safe and secure
                              on site for decades.
                              23
                                The National Environmental Policy Act requires federal agencies to evaluate the likely
                              environmental effects of a proposed project using an environmental assessment or, if the
                              project is likely to significantly affect the environment, a more detailed environmental
                              impact statement evaluating the proposed project and alternatives. 42 U.S.C. §§ 4321-
                              4347 (2006).




                              Page 17                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
from policymakers. The early regulators and developers of nuclear power
viewed waste disposal primarily as a technical problem that could be
solved when necessary by applying existing technology. Attempts were
made to reprocess the spent nuclear fuel—that is, to reuse some useful
elements remaining in a spent fuel assembly after it is discharged from a
reactor, such as unfissioned uranium-235—but this process was not
pursued because of economic issues and concerns that reprocessed
nuclear materials raise proliferation risks. 24

As noted above, the Nuclear Waste Policy Act of 1982 charged DOE with
investigating sites for a federal geologic repository and authorized DOE to
contract with reactor operators to take custody of spent fuel for disposal
at the repository beginning in 1998. In 1987, Congress amended the
Nuclear Waste Policy Act to direct DOE to focus its efforts only on Yucca
Mountain for a repository. DOE did not submit a license application for
Yucca Mountain until 2008, however—10 years after it was supposed to
start taking custody of spent fuel. In 2009, DOE announced that it
planned to terminate its work related to the Yucca Mountain repository,
and in 2010 it filed a motion to withdraw the license application. NRC’s
licensing board denied the motion, but DOE continued to take steps to
dismantle the repository project. In September 2011, the NRC
commissioners considered whether to overturn or uphold the licensing
board’s decision, but they were evenly divided and unable to take final
action on the matter. Instead, the NRC commissioners directed the
licensing board to suspend work by September 30, 2011. NRC’s failure to
consider the application, among other things, is being contested in federal
court. Several parties have filed a petition against NRC asking the federal
court to, among other things, compel NRC to provide a proposed
schedule with milestones and a date for approving or disapproving the
license application. Currently, it remains uncertain whether NRC will have
to resume its license review efforts and whether a repository at Yucca
Mountain will be built. In the interim, in 2010, the administration directed
DOE to establish a Blue Ribbon Commission of experts to study an array
of nuclear waste management alternatives. DOE established the


24
  Over 95 percent of spent fuel consists of uranium and plutonium that can be
reprocessed and reused as fuel in a commercial power reactor. Concerns have been
raised, however, that separating plutonium from other components of spent fuel raises
proliferation risks, since plutonium can be used to make nuclear weapons. See GAO,
Nuclear Fuel Cycle Options: DOE Needs to Enhance Planning for Technology
Assessment and Collaboration with Industry and Other Countries, GAO-12-70
(Washington, D.C.: Oct. 17, 2011).




Page 18                                   GAO-12-797 Accumulation of Spent Nuclear Fuel
                           commission, which studied alternatives including options for interim
                           storage of spent fuel and permanent disposal. In its January 2012 report,
                           the commission recommended that the nation adopt centralized storage
                           of some spent fuel as an interim measure but, at the same time, develop
                           a process to find and license a site for a permanent repository. With
                           nowhere to send the spent fuel, operators must keep it on-site at
                           decommissioned and operating commercial reactors until some option to
                           move it off-site becomes available.

                           Countries other than the United States also produce electricity from
                           nuclear power reactors and have programs to manage their spent nuclear
                           fuel. Some countries, such as France, store their spent fuel in pools until
                           it can be reprocessed, and other countries, such as Canada, use both wet
                           and dry storage systems. Following the accident at Fukushima, Japan
                           temporarily shut down its nuclear reactors, but it has restarted one and
                           may restart others. Several countries have programs to develop
                           permanent disposal facilities. See appendix II for more information on
                           other countries’ programs.


                           The amount of spent fuel accumulating at commercial reactor sites is
Large Quantities of        expected to increase by about 2,000 metric tons each year until it can
Spent Nuclear Fuel         begin to be shipped off-site and, even then, shipping it off-site will be a
                           decades-long process. By then, currently operating reactors will begin to
Are Expected to            retire, dismantling their spent fuel pools and leaving the spent fuel
Remain at                  stranded in dry storage canisters with limited options for repackaging
Commercial Reactor         them, should repackaging be required to replace degraded canisters, or
                           to meet transportation or disposal requirements.
Sites for Decades

Spent Nuclear Fuel Could   The amount of spent fuel is expected to more than double to about
Nearly Double before       140,000 metric tons by 2055, when the last of currently operating reactors
Being Transported to a     is expected to retire, according to the Nuclear Energy Institute, but it may
                           take at least that long to ship the spent fuel off-site. This amount is based
Storage or Disposal        on the assumption that the nation’s current reactors continue to produce
Facility                   spent nuclear fuel at the same rate—about 2,000 additional metric tons
                           annually; that no new reactors are brought online; and that some decline
                           in the generation of spent fuel takes place as reactors are retired. At the
                           end of 2012, over 69,000 metric tons is expected to accumulate at 75




                           Page 19                             GAO-12-797 Accumulation of Spent Nuclear Fuel
sites in 33 states, enough to fill a football field about 17 meters deep. 25
Without central storage options or an available permanent disposal
facility, spent fuel continues to accumulate at the sites where it was
generated.

Current industry practice has been to store the spent fuel in the pools,
with an industry expectation that, at some point, DOE would begin to take
custody of it. In 2011, about 74 percent of commercial spent fuel was
stored in pools, and the remaining 26 percent was in dry storage, but
these proportions will slowly change as more pools fill and the spent fuel
is transferred to dry storage. According to the Nuclear Energy Institute, by
2025, assuming no new reactors, the proportion of spent fuel in wet
storage and dry storage should be roughly equal, about 50,000 metric
tons in each. Shortly after 2055, when the last currently operating
reactors’ licenses are expected to expire, and the reactors are expected
to retire, virtually all the spent fuel arising from the current fleet will have
been moved to dry storage. Figure 7 shows the trend of accumulated
spent fuel and the rate of spent fuel transferred from wet storage to dry
storage through 2067, according to our analysis of Nuclear Energy
Institute data.




25
  The expected accumulation of about 140,000 metric tons of spent fuel by about 2055
does not include spent fuel from new reactors. By 2016, NRC projects it will have received
23 applications to construct 37 new nuclear power reactors. For example, 2 new reactors
are currently under construction in Georgia.




Page 20                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
Figure 7: Trends in Accumulation of Spent Nuclear Fuel Overall and in Wet and Dry Storage




                                        When it became evident that DOE was likely decades behind its deadline
                                        to pick up spent fuel, nuclear power plant operators began transferring
                                        spent fuel to dry storage to retain enough space in their pools to safely
                                        discharge fuel from their reactors. The rate of transfer differs by the
                                        operating and spent fuel characteristics of the reactor—that is, reactor
                                        type and size—as well as the size of the spent fuel pool. In general,
                                        reactor operators must transfer an average of three to six canisters each
                                        year to keep pace with the discharge of spent fuel from their reactors.
                                        Table 1 provides data on reactors and spent fuel and the rate of transfer
                                        anticipated to dry storage.




                                        Page 21                                 GAO-12-797 Accumulation of Spent Nuclear Fuel
Table 1: Typical Reactor Characteristics and Storage Capacity

                                                                                                                                         Typical number of
                                                                                                                                         canisters to be loaded
                                                                                                  Typical capacity of                    to keep pace with
Type of reactor             Typical core size              Typical discharge                      dry storage canister                   discharge
Pressurized water reactor   193 assemblies                 72 to 84 assemblies                    32 assemblies                          3-6 canisters annually
                            (87 metric tons)               every 18 months                        (14.4 metric tons)
                                                           (32 to 38 metric tons)
Boiling water reactor       560 assemblies                 224 assemblies every                   61 assemblies                          4 canisters biennially
                            (101 metric tons)              24 months                              (11 metric tons)
                                                           (40 metric tons)
                                          Sources: GAO analysis of data from the Electric Power Research Institute and the Nuclear Energy Institute.

                                          Note: Estimates were developed by the Electric Power Research Institute and the Nuclear Energy
                                          Institute to represent typical systems.


                                          Reactor operators continue to fill their spent fuel pools until capacity is
                                          reached, in part because the transfer of spent fuel to dry storage is costly
                                          and time-consuming. Specifically, operators must take extensive steps to
                                          ensure that safety precautions to protect workers and the public are met.
                                          Before an operator can transfer a single fuel assembly to dry storage, the
                                          operator must train personnel and practice the procedure. According to
                                          industry representatives, these efforts involve several weeks of mobilization
                                          and demobilization of equipment before and after the transfer. The transfer
                                          of spent fuel to a single canister typically takes at least 1 week.

                                          The amount of spent fuel that accumulates and is stored on-site will also
                                          be affected by the timing of an off-site central storage or permanent
                                          disposal facility, if and when one becomes available. To estimate the
                                          amount of accumulation at commercial nuclear power plants before an
                                          off-site facility becomes available, we considered three scenarios:
                                          (1) Yucca Mountain as a permanent disposal facility, (2) two federally
                                          funded centralized storage facilities, and (3) an alternative permanent
                                          disposal facility. For purposes of our analysis, we assumed that each
                                          storage facility would be licensed by NRC and funded by Congress.
                                          Furthermore, for each scenario, we recognized that multiple factors could
                                          affect the projected time frame. These factors include the siting, licensing,
                                          and construction, and the start of operations of the storage or disposal
                                          facility, as well as the time needed to ship spent fuel to the off-site facility
                                          and reduce the backlog of already-accumulated spent fuel. For each
                                          scenario, we made certain assumptions and incorporated them into our
                                          analyses. We estimated the earliest likely dates that Yucca Mountain, two
                                          federal centralized storage facilities, or a permanent repository could be
                                          opened. Our analysis was based on information from our prior work in



                                          Page 22                                                         GAO-12-797 Accumulation of Spent Nuclear Fuel
analyzing alternatives to a repository at Yucca Mountain, including expert
input to develop assumptions to model the time frames for different
scenarios for spent fuel management. 26 See appendix I for more details
on our methodology for this analysis.

Our analysis showed that regardless of which storage or disposal scenario
was considered, it would take at least 15 years to open an off-site location
and decades to ship the spent fuel once the central storage or disposal
facility became available. The time needed for shipment depends on the
amount of fuel accumulated and assumes a shipment rate of 3,000 metric
tons per year—the rate that DOE developed as part of its plans for Yucca
Mountain. Experts we consulted in our prior work agreed this rate was
reasonable. A faster or slower shipping rate could affect the rate of
continued accumulation or drawdown of the backlog. When we conducted
our analysis in 2009, we reported that Yucca Mountain—the first
scenario—was likely to offer the earliest option for off-site disposal, in 2020.
Since then, the process for licensing Yucca Mountain has stopped, and it is
unclear whether the licensing process will be resumed; in addition, many
key workers who worked on Yucca Mountain have left DOE for other
employment or retirement. If the licensing process for Yucca Mountain
were resumed in 2012, we estimate that DOE would require roughly at
least 15 more years to open the site as a repository, or sometime around
2027. We estimate that the second scenario—for the federal government to
site, license, construct, and open two centralized storage facilities—might
take about 20 years, with completion in 2032, because of the complexities
in siting, licensing, and constructing such facilities. We estimate that the
third scenario—for a potential permanent disposal facility as an alternative
to the Yucca Mountain repository—would take the longest to be realized,
about 40 years, or 2052, because of the additional scientific analysis
required to ascertain the safety of a permanent disposal facility. Figure 8
shows the amount of spent fuel that is expected to accumulate in each
state for the years 2012; 2027 (the earliest likely opening date if the Yucca
Mountain repository were to be licensed and constructed); 2032 (the
earliest a centralized storage facility could be expected to open); 2052 (the
earliest a permanent disposal facility other than Yucca Mountain could be
expected to open); and 2067, when all currently operating commercial
nuclear power reactors are expected to have retired and transferred their
spent fuel to dry storage.



26
 GAO-10-48.




Page 23                               GAO-12-797 Accumulation of Spent Nuclear Fuel
                          Figure 8: Accumulation of Commercial Spent Fuel by State Over Time
    Interactive Graphic


	   Instructions: 	       Online, hover over the state names in the graphic for more information.
		                        For print version, see appendix III, page 57.




                                        Resolving the issue of what to do with commercial spent nuclear fuel will
                                        likely be a decades-long, costly, and complex endeavor. Planning ahead
                                        to allow reactor operators and local communities to make better-informed
                                        and forward-looking decisions is important in such a complex
                                        undertaking. For example, DOE had earlier created designs for a specific
                                        type of canister for disposal at the Yucca Mountain repository, and had
                                        informed reactor operators that all spent fuel destined for Yucca Mountain
                                        needed to be packaged in this specific canister, called a transportation,
                                        aging, and disposal canister. Although the canister had not gone into
                                        Page 24                                GAO-12-797 Accumulation of Spent Nuclear Fuel
                           commercial production, its design specifications had at least informed
                           reactor operators. Now that both DOE and NRC have suspended their
                           licensing efforts for the Yucca Mountain repository, a great deal of
                           uncertainty exists about future spent fuel management. Given this
                           uncertainty, it may be difficult for reactor operators to make decisions
                           about issues such as the rate of transferring spent fuel to dry storage and
                           the type of canister to be used for disposal.


As Many Nuclear Reactors   During the decades it will take to open a storage or disposal facility, many
Begin Closing in 2040,     reactors will be retiring from service, “stranding” their accumulated spent
Growing Quantities of      fuel in a variety of different dry storage systems, with no easy way of
                           repackaging them should repackaging be required to meet storage or
Spent Fuel May Be          disposal requirements. Most U.S. reactors were built during the 1960s
Stranded in Place          and 1970s and, after a 40-year licensing period with a possible 20-year
                           extension, will begin retiring in large numbers by about 2030 and
                           emptying their pools by about 2040. NRC regulations require radioactive
                           contamination to be reduced at a reactor to a level that allows NRC to
                           terminate the reactor license and release the property for other use after
                           a reactor shuts down permanently. This cleanup process—known as
                           decommissioning—costs hundreds of millions of dollars per reactor, and
                           NRC is responsible for ensuring that operators provide reasonable
                           assurance that they will have adequate funds to decommission their
                           reactors. 27 Once a spent fuel pool is removed, reactor operators will have
                           limited options for managing spent fuel. For example, if reactor operators
                           need to repackage their spent fuel because a canister has degraded or
                           because other transportation or disposal requirements must be met, they
                           will have to build a new spent fuel pool or some other dry transfer facility,
                           or they will need to ship their spent fuel to another site with a wet or dry
                           transfer facility.




                           27
                             See GAO, Nuclear Regulation: NRC’s Oversight of Nuclear Power Reactors’
                           Decommissioning Funds Could Be Further Strengthened, GAO-12-258 (Washington,
                           D.C.: Apr. 5, 2012). Decommissioning must generally be completed within 60 years of
                           cessation of reactor operations. Reactor operators may either immediately decontaminate
                           and dismantle their reactor sites or monitor and maintain them as the spent fuel cools and
                           decays over a longer period. In these scenarios, we assumed that operators will
                           immediately decommission their reactors, placing their spent fuel in dry storage and
                           disposing of the rest of their radioactive waste, including the reactor and the spent fuel
                           pool, as either low-level waste or as slightly more radioactive waste called greater-than-
                           class-C waste.




                           Page 25                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
As of January 2012, the United States had nine decommissioned
commercial nuclear power plant sites. Seven of these plants have
completely removed spent fuel from their pools—a total of 1,748 metric
tons—as well as all infrastructure except that needed to safeguard the
spent fuel. 28 The other two sites, which have a total of 5,103 metric tons
of spent fuel in both wet and dry storage, are in the process of emptying
their pools and transferring all their spent fuel to dry storage.

Assuming that no centralized storage or permanent disposal facility
becomes available, our analysis indicates that by 2040, the amount of
stranded spent fuel in closed commercial nuclear power plants will total
an estimated 3,894 metric tons; by 2045, that amount could increase to
28,751 metric tons; and by 2050, the amount could be 62,237 metric tons.
By 2067, nearly all of the 140,000 metric tons of spent fuel could be
stranded in dry storage. Figure 9 shows the expected pattern of growth
for total accumulated spent fuel compared with that of spent fuel from
decommissioned reactors, or stranded spent fuel.




28
  These sites include Big Rock Point in Michigan, Haddam Neck in Connecticut, Humboldt
Bay and Rancho Seco in California, Maine Yankee in Maine, Trojan in Oregon, and
Yankee Rowe in Massachusetts. In addition to these decommissioned sites, an additional
spent fuel pool is located in Morris, Illinois. This pool was built and filled with spent fuel in
anticipation of reprocessing into usable nuclear fuel, but when reprocessing was
suspended, the spent fuel remained in the pool, essentially stranded.




Page 26                                       GAO-12-797 Accumulation of Spent Nuclear Fuel
Figure 9: Growth Trend of Total Spent Fuel Compared with Spent Fuel from Decommissioned Reactors




                                       Note: The data assume that additional spent fuel will not be generated by new reactors or extension
                                       of reactor licenses beyond 60 years.




                                       According to several studies on spent fuel storage, the key risk of storing
The Key Risk of                        spent fuel at reactor sites is radiation exposure from spent fuel that has
Stored Spent Fuel Is                   caught fire when it is stored in a pool, but it is difficult to quantify the
                                       probability of such an event. Nuclear reactor operators have put into
Difficult to Quantify,                 place several efforts to mitigate the effects of such a fire, although
but Some Mitigating                    disagreement exists on the mitigation needed. In contrast to pool storage,
Actions Have Been                      spent fuel in dry storage is less susceptible to severe radiological
                                       releases. Furthermore, NRC has no centralized database to help identify,
Taken                                  locate, and access classified studies on spent fuel.




                                       Page 27                                         GAO-12-797 Accumulation of Spent Nuclear Fuel
Radiological Release from       Radiation exposure—from a minor dose resulting from a work-related
a Pool Fire Is the Key Risk     accident to a severe, widespread release of radiation from a spent fuel
Posed by Spent Fuel             fire—is the key concern about the hazard of storing spent nuclear fuel.
                                According to studies we reviewed and NRC officials and representatives
Storage, but Quantifying        of other groups we spoke with, the worst-case scenario for spent fuel at
This Probability Is Difficult   reactor sites is the possibility of a self-sustaining fire in a spent fuel pool,
                                which could engulf all assemblies in the pool, with significant
                                consequences. According to the analysis in a February 2001 NRC study,
                                assuming a high release of radiation, the release of spent fuel fission
                                products resulting from a pool fire could result in nearly 200 early
                                fatalities, thousands of subsequent cancer fatalities, and widespread land
                                contamination. These early fatalities could be reduced or eliminated,
                                according to the study, if the radiation release was less severe and if
                                there were an early evacuation of the affected population. NRC officials
                                told us that the assumptions used in that study were very conservative
                                and that they believed that a lower release of radiation and an early
                                evacuation are more representative of potential scenarios involving
                                operating nuclear power reactors. A 2006 National Academy of Sciences
                                study also found that a spent fuel fire could release large quantities of
                                radioactive materials into the environment and cause widespread
                                contamination.

                                NRC officials, as well as studies by Sandia National Laboratories
                                (commissioned by NRC) and the National Academy of Sciences (2006),
                                informed us about the conditions that could lead to a fire. Such a fire
                                could occur only if enough water in the spent fuel pool were lost, such as
                                through drainage or boiling away, exposing roughly the top half of the fuel
                                assemblies. 29 Without sufficient water to keep spent fuel covered and
                                cool, it is possible that some of the hotter assemblies—those most
                                recently discharged from a reactor—could ignite. Furthermore, once
                                started, a fire in a spent fuel pool would be very difficult to extinguish
                                because, in such a case, the zirconium alloy making up the metal
                                cladding surrounding the assemblies would react with oxygen and, when


                                29
                                  As reported by the Institute of Nuclear Power Operations (Special Report on the Nuclear
                                Accident at the Fukushima Daiichi Nuclear Power Station, Atlanta, GA, November 2011),
                                Tokyo Electric Power Company personnel determined that water levels in the spent fuel
                                pool at Fukushima Daiichi did not drop below the top of the fuel. An NRC order noted that
                                during the Fukushima event, there was concern that the spent fuel was overheating, and
                                the concern persisted primarily because of a lack of readily available and reliable
                                information on water levels in spent fuel pools. Nevertheless, the water level at Fukushima
                                did not drop to levels at which a fire could start.




                                Page 28                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
a certain temperature was reached, would begin a chemical reaction that
releases energy and raises the temperature. Essentially, the fire becomes
hotter and self-sustaining and, depending upon the density of spent fuel
in the pool, could spread to other assemblies. On the basis of studies
cited by NRC officials and a Sandia National Laboratories study, a fire in
a fully drained pool can start at about 1,830 degrees Fahrenheit (about
1,000 degrees Celsius). A zirconium fire does not involve flames; rather, it
burns like a welding torch.

A zirconium fire can start only if a complex series of conditions occurs.
NRC and other studies indicate that such a fire is not likely. Furthermore,
the physical protection features and mitigation measures at nuclear power
reactors make the probability of a fire in a spent fuel pool very low. First,
there must be an initiating event, 30 such as an earthquake more severe
than the pool was designed to withstand, an accidental drop of a cask
during dry cask loading operations, or a terrorist attack. Second, the
initiating event must result in a critical loss of water, such as through a
breach in the pool wall or floor that would allow water to drain out. Third,
the reactor operator must be unable to respond adequately to a water
loss, such as being unable to replenish lost pool water sufficiently to cool
the assemblies.

Whether a self-sustaining fire starts and spreads depends on additional
variables, according to Sandia National Laboratories studies
commissioned by NRC from 2003 through 2006 to assess the effects of
some of these variables for pool fires. Two important variables are:

•   The age and the heat of the spent fuel. Spent fuel is hottest when first
    discharged from a reactor but cools relatively quickly. The risk of a
    zirconium fire is much greater with recently discharged fuel than with
    older fuel.

•   The size of a hole in the pool and subsequent rate of water drainage.
    A Sandia National Laboratories study analyzed the effects of
    differently sized holes for various fuel assembly configurations, fuel
    ages, ventilation assumptions, and replacement water scenarios, and
    this analysis showed that larger holes and drainage rates, all other


30
  In this report, we use the term “event” to generally describe a situation involving an
accident or attack on a spent fuel pool. We also use the term “initiating event” to specifically
describe the first action that takes place to trigger severe damage to a spent fuel pool.




Page 29                                       GAO-12-797 Accumulation of Spent Nuclear Fuel
    factors being equal, resulted in higher temperatures of the fuel
    assemblies.

NRC officials told us that, from a regulatory perspective, the risks of an
event causing a large release of radiation that endangers public safety
from spent fuel in either wet or dry storage are low enough to be within
acceptable limits of risk. NRC officials also said the agency considers risk
to be the probability of an event occurring multiplied by the consequences
of that event and has determined that a spent fuel fire is a low-probability,
high-consequence event. In 2001, an NRC study estimated the frequency
of having spent fuel pool assemblies uncovered and exposed to the air to
be, on average, an event that occurs once every 420,000 years. 31 NRC
officials told us the agency did not update its quantitative likelihood
estimates after the September 11, 2001, terrorist attacks. Since
Fukushima Daiichi, NRC has been engaged in ongoing initiatives related
to items such as addressing a loss of off-site electricity and seismic
hazard reevaluation. It has been conducting a study on the consequences
of accident scenarios affecting spent fuel pools and is undertaking a
probabilistic risk assessment to quantify spent fuel risk for a selected
reactor site of interest.

Independent studies we reviewed indicate the difficulty of quantifying the
level of risk of stored spent fuel. Examples of these studies follow:

•   The Institute for Resource and Security Studies, a Massachusetts-
    based technical and policy research group, reported in 2009 that the
    methodology needed to estimate the probability of nuclear accidents
    is complex, requiring consideration of internal and external initiating
    events, analyses involving uncertainty, peer review, and estimates of
    radiological consequences.

•   The National Academy of Sciences stated in a 2006 study that the
    probability of a terrorist attack on spent fuel storage cannot be
    assessed quantitatively or comparatively and that it is not possible to
    predict the behavior and motivations of terrorists. This study noted,
    and a National Academy of Sciences official expressed concern, that
    in the NRC-sponsored studies available when the National Academy


31
  Nuclear Regulatory Commission, Technical Study of Spent Fuel Pool Accident Risk at
Decommissioning Nuclear Power Plants, NUREG-1738 (Washington, D.C.:
February 2001).




Page 30                                  GAO-12-797 Accumulation of Spent Nuclear Fuel
                                   of Sciences was performing its work, NRC did not examine some low-
                                   probability scenarios that could result in severe consequences and
                                   that, although unlikely, should be protected against.


Mitigation Efforts Could       Efforts to mitigate safety and security risks could reduce the effects of key
Reduce the Likelihood of       factors in the dynamics of a potential fire in a spent fuel pool, according to
Severe Consequences, but       our analysis of Sandia National Laboratories studies on pool fire
                               scenarios. Still, disagreement exists—largely between community action
Disagreement Exists on         groups and NRC—as to the appropriate density of assemblies in a spent
the Mitigation Needed          fuel pool.

Fuel Assembly Configurations   Storage configurations that disperse the hottest spent fuel assemblies are
and Density in Pools           among the most important mitigation efforts that Sandia National
                               Laboratories has identified. NRC and community action groups differ,
                               however, on the extent to which these efforts should be employed. In
                               2011, Sandia National Laboratories reported on its study of the safety and
                               security benefits presented by five different fuel configurations in a
                               storage pool. According to this study, it is preferable to employ
                               configurations that place the more recently discharged, hotter assemblies
                               away from each other—the farther the better—and intersperse them with
                               older, cooler assemblies or, preferably, with empty adjacent cells. NRC
                               has provided regulatory guidance to reactor sites to take advantage of
                               these safer configurations.

                               Representatives from community action groups we interviewed said that
                               even with NRC’s mitigation efforts, spent fuel pools remain too densely
                               packed and that the total amount of spent fuel in the pools should be
                               reduced by accelerating the transfer of spent fuel into dry storage. In
                               addition, a 2003 study led by a scholar at a community action group
                               proposed open rack storage for spent fuel pools. Under this proposal, 20
                               percent of the pool assemblies would be transferred to dry storage, which
                               would then allow an open channel on each side of the pool. This
                               configuration would help promote air convection between the assemblies
                               and, in turn, reduce the probability of an ignition and subsequent spread
                               to other assemblies. The fewer assemblies that catch fire, the smaller the
                               amount of potential radiation that could be released into the




                               Page 31                              GAO-12-797 Accumulation of Spent Nuclear Fuel
                               atmosphere. 32 Furthermore, in 2006, over 150 community action and
                               environmental groups collaborated to develop a set of principles for
                               safeguarding spent fuel. They advocated spent fuel storage policies,
                               including an open-frame, low-density layout for spent fuel pools and
                               transfer of this fuel to dry storage within 5 years after its removal from a
                               reactor. According to NRC, a state regional organization, and
                               representatives from industry and community action groups, there are
                               trade-offs between the benefits versus the costs and risks of moving
                               spent fuel. Nonetheless, no clear agreement exists—according to Sandia
                               National Laboratories’ analysis and input from community action groups—
                               on the extent to which the density of spent fuel in pools should be
                               reduced.

Replacement Water and Sprays   NRC requires nuclear reactor sites to develop and implement strategies
                               to maintain or restore cooling of reactor cores, containment, and cooling
                               capabilities for spent fuel pools under circumstances due to explosions or
                               fire—a requirement that includes providing sufficient, portable, and on-site
                               cooling equipment. A Sandia National Laboratories study determined that
                               when holes in pool structure cause significant water drainage, reactor
                               operators would generally have from a few hours to a few days to replace
                               lost water or cool spent fuel with sprays in an effort to prevent a fire. If no
                               water drained, such as in a loss-of-power event that caused a loss of
                               cooling and allowed the pool water to boil, reactor operators might have
                               days or weeks. NRC officials said that as spent fuel is uncovered, sprays
                               are efficient and effective in cooling fuel assemblies. They also told us
                               that trade-offs exist between installed and portable spray systems.
                               Installed spray systems can be operated remotely but are susceptible to
                               damage during an event. Portable systems provide adequate spray and
                               are stored at least 100 yards away from the pool in secure places, but in
                               case of an event, reactor operators may not always have access to the
                               pool area to use them because of radiation hazard or physical
                               obstruction. According to a member of a community action group we
                               interviewed, replacement water and sprays may be effective in cooling
                               spent fuel, but replacement water may not contain boron, which is needed
                               to absorb neutrons and prevent a critical chain reaction. This member told
                               us that there is no requirement for reactor operators to keep a supply of


                               32
                                 NRC issued a 2002 order that, according to NRC officials, accomplished a functionally
                               similar action to the open rack proposal. The order, which took several years to
                               implement, required the reactor operator to establish contiguous open areas in the pool for
                               natural air circulation and active heat removal using sprays, if water were lost.




                               Page 32                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
              boron to add to replacement water. According to NRC officials, only
              operators of pressurized water reactors have the option of adding boron
              to the water to prevent a critical chain reaction, but operators of these
              reactors must also show that the assemblies will remain sub-critical
              without the boron. The NRC officials stated that all reactors are required
              to have a 5-percent margin of safety to prevent a critical chain reaction. In
              addition to boron in the water, prevention of a critical chain reaction can
              also be achieved by boron in plates in the racks, spacing among the
              assemblies, and other storage configurations.

              After the Fukushima Daiichi nuclear power reactor accident, NRC in
              March 2012 supplemented existing requirements by issuing an order
              instructing nuclear power operators to install monitoring equipment to
              remotely measure a wider range of water levels in spent fuel pools. NRC
              issued a second order, also in March 2012, that required reactor
              operators to ensure the effectiveness of water mitigation measures. It is
              more difficult to provide sprays and replacement water to boiling water
              reactor pools because they are typically several stories above ground and
              located close to the reactor, 33 whereas spent fuel pools for pressurized
              water reactors are at ground level or partially embedded in the ground. At
              Fukushima Daiichi, cooling flow to the spent fuel pool was lost during the
              loss of off-site power and was not immediately restored with the use of
              emergency diesel generators. Emergency operators did not have remote
              monitoring equipment to determine whether pool water levels had
              dropped enough to expose the spent fuel. Subsequent inspections,
              however, determined that water levels did not drop below the top of the
              fuel assemblies in the pool.

Ventilation   As we stated in our 2003 report, air ventilation can mitigate the likelihood
              of a pool fire in the event of water drainage. Logically, this mitigation
              potential depends upon where the ventilation occurs and how much
              ventilation can be created. A Sandia National Laboratories study found
              that space between assemblies and the pool wall can help promote
              ventilation, as can doors and vents in the room where the pool is located.
              Space under the assemblies can be created at the foot of racks
              supporting fuel assemblies, which allows circulating air to flow up
              between the assemblies and carry heat away with it in the event of



              33
                Mark I and Mark II boiling water reactors are elevated, but Mark III reactors are not,
              because of a different design.




              Page 33                                     GAO-12-797 Accumulation of Spent Nuclear Fuel
                             complete drainage of water from the pool. However, according to a study
                             led by a scholar at a community action group, with assemblies packed in
                             dense configurations in racks at most nuclear reactor pools and boron
                             plates lining the racks of assemblies, ventilation may be reduced.


Spent Fuel in Dry Storage    Spent nuclear fuel in dry storage is less susceptible to a radiological
Is Less Susceptible to a     release of the magnitude of a zirconium fire in a spent fuel pool,
Significant Radiological     according to documents we reviewed and interviews we conducted with
                             officials from NRC, the National Academy of Sciences, and the Nuclear
Release Than Is Spent Fuel   Waste Technical Review Board; officials from industry; and
Stored in Pools              representatives of community action groups. Such a release is less likely
                             for the following reasons:

                             •   Spent fuel cools rapidly, and spent fuel in dry storage—typically at
                                 least 5 years old—has cooled sufficiently so that ignition is less likely.
                                 In addition, passive air cooling in dry cask storage systems is not
                                 affected by the loss of off-site power, and active monitoring—other
                                 than ensuring that air vents are not clogged—is not necessary to
                                 prevent overheating and possible ignition.

                             •   The amount of radioactive material in a dry storage canister is a
                                 fraction of the amount of radiation in a spent fuel pool. According to
                                 the National Academy of Sciences’ 2006 study, each dry storage
                                 canister contains 32 to 68 fuel assemblies—whereas thousands of
                                 assemblies are typically stored in pools—and therefore each canister
                                 has less radioactive material that can be released than the radiation
                                 from a pool. Logically, breaching dozens of spent fuel canisters
                                 simultaneously could result in more severe consequences than a
                                 single breached canister, but breaching dozens of canisters
                                 simultaneously is difficult.

                             •   To trigger any severe off-site radiological release from spent fuel
                                 stored in a canister, the fuel would have to undergo aerosolization,
                                 which would entail breaching the outer and inner shielding units.
                                 Furthermore, any holes would have to be sufficiently large enough to
                                 allow release of the aerosolized spent fuel. It would be difficult to
                                 aerosolize radioactive material in dry storage and difficult to have
                                 some mechanism to transport the radioactive material away from the
                                 reactor site. Such mechanisms would require energy, such as a fire.

                             •   Dry storage is not as susceptible to the buildup of hydrogen as are
                                 spent fuel pools. If an accident or attack involving a spent fuel pool



                             Page 34                              GAO-12-797 Accumulation of Spent Nuclear Fuel
     causes a loss of water, the fuel assemblies can heat up and produce
     steam. This steam can react with the hot zirconium cladding
     surrounding the fuel assemblies, producing hydrogen that, when
     mixed with oxygen, could cause an explosion and structural damage
     to the reactor building.

As we reported in our 2003 study, NRC had concluded before September
11, 2001, that spent fuel in dry cask storage systems was considered
safe and secure. 34 A Sandia National Laboratories study conducted from
2003 through 2005, supplemented by NRC analyses, evaluated several
representative types of dry cask storage designs against airplane and
ground attacks to determine if any other security measures were needed,
in addition to those already issued by order. This work did not find that
any further mitigating or security procedures were needed for nearly all
the scenarios, but it did identify some potential scenarios in which some
radiation could be released.

This study helped inform NRC’s technical evaluation—first discussed
internally at NRC in 2007, according to NRC officials, and published for
solicitation of public comments in 2009. 35 This evaluation included a
proposal to establish a security-based dose limit that would require
owners of spent fuel in dry storage systems to develop site security
strategies to protect against a potential radiological release that exceeds
NRC’s acceptable dose limits at a site boundary. NRC issued this
evaluation for public comment for a proposed rule to revise security
requirements for storing spent fuel away from a reactor. During the public
comment period, NRC received general comments showing a preference
for guarding against a specific threat rather than the dose-based
approach proposed in the technical evaluation. For example, under the
dose-based approach, some owners told NRC that they might have to
increase their security forces to prevent potential radiological releases,
and they raised concerns about the cost of such efforts compared with
the benefit. As a result, according to NRC officials, the agency has
delayed the proposed rule in order to gather more information regarding
the public comments. NRC officials told us the agency plans to


34
  GAO, Spent Nuclear Fuel: Options Exist to Further Enhance Security, GAO-03-426
(Washington, D.C.: Jul. 15, 2003).
35
  See Draft Technical Basis for Rulemaking Revising Security Requirements for Facilities
Storing SNF and HLW; Notice of Availability and Solicitation of Public Comments, 74 Fed.
Reg. 66589 (Dec. 16, 2009).




Page 35                                   GAO-12-797 Accumulation of Spent Nuclear Fuel
                            commission additional studies to help assess the situation and determine
                            the appropriate security strategy.


NRC Has No Centralized      In conducting our work, we found that NRC does not have a mechanism
Mechanism to Help           to ensure that it can easily identify and locate all classified studies
Identify, Locate, and       conducted over the years. When we requested classified and other
                            studies from NRC officials, it was difficult for them to provide us with the
Access Classified Studies   information we requested in a timely manner. Specifically, nearly 5
on Spent Fuel               months elapsed from our initial request for classified studies of wet
                            storage until NRC provided these documents. A National Academy of
                            Sciences official told us that the academy had also experienced difficulty
                            in obtaining some of NRC’s classified studies while performing its 2004
                            study. 36 To identify studies, we interviewed numerous NRC and other
                            officials and identified studies through references in other studies we
                            reviewed. NRC officials said the classified studies are stored in the safes
                            of NRC officials. We also contacted officials from Sandia National
                            Laboratories and requested a list of all their studies on spent fuel safety
                            and security. NRC officials told us that developing and maintaining a
                            classified database covering the most important topics involving spent
                            fuel, as designated by agency management, would not be burdensome.

                            Managing spent fuel until permanently disposed of may take many
                            decades, and NRC and DOE managers and staff and operators with
                            appropriate clearances may need to review an extensive number of
                            classified studies conducted for NRC on the safety and security of spent
                            fuel. Several studies conducted after September 11, 2001, by NRC and
                            other groups referred to NRC studies conducted before that date—some
                            conducted as early as 1979. We also found decades-old NRC studies to
                            still be useful in our review. The nature and characteristics of spent fuel
                            discharged from a reactor likely will not change, and therefore the
                            underlying principles and knowledge of spent fuel safety and security are
                            likely to remain applicable and informative to future scientists and others.
                            Although preserving key scientific and technical studies is important,
                            preservation of information alone is not enough if others may not be
                            aware of a study’s existence or location. Scientists and others rely on
                            mechanisms that allow them to easily identify, locate, and access



                            36
                             The 2004 National Academy of Sciences study is the classified version of its 2006 study,
                            which is unclassified.




                            Page 36                                   GAO-12-797 Accumulation of Spent Nuclear Fuel
                          pertinent information, as well as to prevent unnecessary duplication of
                          research.


                          Transferring spent fuel from wet to dry storage is generally safe and
Transfer of Spent Fuel    offers several key benefits, but any movement of spent fuel entails some
from Wet Storage          level of risk. Accelerating the transfer of spent fuel from wet to dry storage
                          to reduce the inventory of spent fuel in a pool could increase those risks.
Offers Benefits but       Additional operational and other challenges to accelerating the transfer of
Also Presents             spent fuel to dry storage may limit the degree of acceleration that may
                          ultimately be achieved. Once spent fuel is in dry storage, additional
Challenges                challenges may arise, such as costs for repackaging should it be needed.


Transferring Spent Fuel   The transfer of spent fuel from wet to dry storage and long-term storage
from Wet to Dry Storage   at reactor sites, although not originally part of the plan for managing spent
Offers Benefits           fuel, has offered some benefits, according to our analysis of documents
                          and interviews with NRC officials, representatives from industry, and
                          community action and environmental groups. For example, without a
                          permanent means of disposing of spent nuclear fuel for at least several
                          decades, the transfer of spent fuel from pools to dry storage has provided
                          the nation with time to develop a more permanent solution. We previously
                          reported—on the basis of input from experts—that dry storage is
                          considered safe for at least 100 years and is easily retrievable. 37
                          Moreover, because most spent fuel pools are nearly at capacity, reactor
                          operators must transfer as much spent fuel to dry storage as is
                          discharged from the reactor. According to our analysis of input from these
                          officials and representatives, accelerating the transfer of spent fuel from
                          wet to dry storage may offer the following additional benefits:

                          •     Reducing the potential consequences of pool fires. An accelerated
                                transfer of spent fuel to dry storage may return the pools to a low-
                                density, open-frame configuration that could reduce potential
                                consequences should an unintended release of radiation occur from a
                                pool fire. Accelerated transfer has been advocated by more than 150
                                community action and environmental groups.




                          37
                              GAO-10-48.




                          Page 37                              GAO-12-797 Accumulation of Spent Nuclear Fuel
                           •     Potentially increasing the volume of transportation-ready spent fuel.
                                 Accelerating the transfer of spent fuel to dry storage could increase
                                 the volume of readily transportable spent fuel for ease of removal to
                                 an off-site facility for storage, reprocessing, or disposal, with the
                                 caveat that reactor operators take steps to ensure that canisters and
                                 their contents meet transportation requirements.

                           In addition, we note that once a reactor is decommissioned, spent fuel is
                           less expensive to safeguard in dry storage than in wet storage.
                           Specifically, we previously reported that the cost of operating a spent fuel
                           pool at a decommissioned reactor could range from about $8 million to
                           nearly $13 million a year but that the cost of operating a dry storage
                           facility might amount to about $3 million to nearly $7 million per year. 38
                           Nine reactor sites nationwide are currently shut down and partly
                           decommissioned and have already transferred all their spent fuel to dry
                           storage or are in the process of doing so, with plans to remove their spent
                           fuel pools. A tenth site never had an operating reactor but was built as an
                           interim storage pool in anticipation of reprocessing. 39 The operators of
                           this site have not announced any plans to transfer spent fuel to dry
                           storage.


Accelerating Transfer of   Accelerating the transfer of spent fuel from wet to dry storage entails
Spent Fuel from Wet to     some operational challenges, and some industry representatives told us
Dry Storage Presents       that they have questioned whether the cost of overcoming these
                           challenges is worth the benefit, particularly considering the low probability
Challenges and Some Risk   of a catastrophic release of radiation. Furthermore, in a 2003 response to
                           a recommendation by the Institute of Policy Analysis to accelerate the
                           transfer of spent fuel from wet to dry storage to reduce the likelihood and
                           potential consequences of a pool fire, NRC reported that accelerating the
                           transfer of spent fuel is not justified, particularly given the billions of
                           dollars it will cost, with no appreciable increase in safety. In commenting
                           on a draft of this report, NRC reiterated this position, stating that it does
                           not require the accelerated transfer of spent fuel to dry storage,
                           particularly considering the small increase in safety that could be


                           38
                               In constant 2012 dollars. GAO-10-48.
                           39
                             General Electric originally built the pool to store spent fuel intended for reprocessing, but
                           when reprocessing was suspended in the United States—and never resumed—the spent
                           fuel became stranded. In 2007, General Electric transferred ownership of the spent fuel
                           pool to GE-Hitachi Nuclear Energy Americas LLC.




                           Page 38                                      GAO-12-797 Accumulation of Spent Nuclear Fuel
achieved, because it considers both wet and dry storage to be safe under
current regulations.

The studies that NRC provided to us on the safety and security of spent
fuel did not include any comprehensive analysis of the advantages and
disadvantages of accelerating the transfer of spent fuel from wet to dry
storage. However, NRC officials stated that the commission is currently
evaluating accelerated transfer of spent fuel to dry storage as part of a
larger review of lessons learned from the Fukushima event. The officials
stated that the evaluation will allow NRC to determine whether regulatory
action is needed to require accelerated transfer of spent fuel. NRC
officials have stated that they believe they can complete their planned
evaluation within about 5 years. Some of the challenges from accelerating
the transfer of spent fuel include the following:

•   Increasing the need for skilled workers and potential radiation doses
    to those workers. Workers at reactors face radiation exposure during
    routine transfer of spent fuel from wet to dry storage, particularly
    during loading operations, but this risk could increase if transfer were
    accelerated, according to a 2010 analysis by EPRI. The institute
    estimated worker exposure rates, assuming transfer of spent fuel in
    generic reactors both at the rate of current practice and at an
    accelerated rate. At the rate of current practice, EPRI reported,
    workers would collectively receive a dose of 15,836 rem over a nearly
    90-year period associated with transferring the expected inventory of
    about 140,000 metric tons from wet to dry storage, 40 performing
    annual maintenance and inspection of the dry storage systems, and
    constructing additional dry storage systems if additional dry storage
    capacity is needed. Assuming an accelerated rate of transfer after 5
    years of cooling, EPRI calculated that worker dose would increase by
    507 rem, or 3 percent, as a result of the transfer, maintenance and
    inspection, and construction duties performed over the same 90-year
    period. Assuming worker exposure rates would remain roughly the


40
  The rem (roentgen equivalent man) is a unit that measures absorbed dose of radiation
to a human and helps estimate the effects of a given absorbed dose on a human body. To
determine this radiation dosage, an equation is used that multiplies the absorbed dose by
a qualifying factor, which is based on factors such as the rate of exposure and the type of
radiation. For instance, the annual effective dose to the general population in the United
States is about 620 millirem, about half of which comes from natural sources, such as
radon, a naturally occurring radioactive gas produced from the natural radioactive decay
of uranium, that is found in rocks and soil. The remainder comes from medical,
commercial, and industrial activities, such as dental X-rays.




Page 39                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
     same, the additional 507 rem under an accelerated transfer scenario
     would represent the equivalent of an estimated 1,500 workers. 41
     Furthermore, EPRI has reported that industry is moving to high-burn-
     up fuel for greater efficiency. But this high-burn-up fuel is hotter and
     more radioactive than conventional fuel and requires cooling for about
     7 years before it can be safely transferred to dry storage. If transfer is
     accelerated, this high-burn-up fuel could potentially increase worker
     dose.

•    Increasing the potential for accidents. Accelerating the transfer
     process would result in more movements of equipment and, therefore,
     potentially more accidents. Additionally, an industry representative
     said that workers might have to be rotated to reduce worker exposure
     to radiation, increasing the number of workers moving spent fuel,
     including those with less experience. Under normal conditions,
     operators risk accidents every time spent fuel is moved. NRC has not
     reported any accidents with severe consequences during efforts to
     transfer spent nuclear fuel from wet to dry storage, but human and
     mechanical errors sometimes occur. For example, from 1969 to 2002,
     NRC reported 57 events involving load drops at reactor sites. 42
     According to the Nuclear Energy Institute, none of these events
     involved a spent fuel cask or canister, but in 25 instances, one or
     more fuel assemblies were dropped. Accidents are of concern
     because, for example, if a cask is dropped, it can damage other




41
  GAO performed this analysis using EPRI’s data to provide a basis for comparing current
worker exposure rates with future exposure rates, assuming an accelerated transfer rate.
Actual worker exposure rates can be higher or lower depending on work performed. For
example, EPRI assumes a worker dose of 400 millirem during a typical loading campaign,
but it is possible that as high-burn-up spent fuel is transferred to dry storage, worker dose
may be higher. Specifically, EPRI estimated that worker dose would rise by 284 rem for
transferring spent fuel to dry storage, a 7.5 percent increase representing an estimated
increase of 710 workers; a 102 rem increase for performing annual maintenance and
inspection duties, a 1 percent increase representing an estimated increase of 63 workers;
and a 121 rem increase for duties associated with constructing additional dry storage
systems and moving additional loaded dry storage casks to the storage pad, a 7.6 percent
increase representing an estimated increase of 712 workers. In addition, NRC limits
annual radiation exposure for workers. The limits vary depending on the affected part of
the body, but the total annual effective dose equivalent is 5 rem. 10 C.F.R. §
20.1201(a)(1) (2012).
42
  NRC, A Survey of Crane Operating Experience at U.S. Nuclear Power Plants from 1968
through 2002, NUREG-1774 (Washington, D.C.: July 2003).




Page 40                                     GAO-12-797 Accumulation of Spent Nuclear Fuel
     assemblies or the pool liner, potentially leading to water drainage. 43 A
     single fuel assembly from a boiling water reactor weighs about 700
     pounds, and a single fuel assembly from a pressurized water reactor
     weighs about 1,500 pounds; dry storage casks, once fully loaded, can
     weigh from 100 to 180 tons or more. NRC has provided guidance to
     industry to take steps to minimize damage from such a drop, such as
     using overhead cranes with special added safety features so that a
     single failure will not result in dropping a damaging load or developing
     handling routes designed to avoid lifting heavy loads over vulnerable
     equipment. 44, 45

•    Working within time constraints. Timing preferences and operational
     limitations could constrain how much spent fuel is transferred in a
     given year and may present an obstacle to accelerated transfer from
     wet to dry storage. Industry representatives told us that under current
     practice, reactor operators prefer to transfer spent fuel to dry storage
     during periods of time that do not interfere with refueling, receiving
     new fuel, required inspections, and maintenance or other activities
     vital to plant operations. These activities typically consume about 8 to
     9 months of each year’s calendar. A routine dry storage loading
     operation may take 2 months or more, according to industry
     representatives. For example, one industry representative told us that
     it can take about 2 weeks to mobilize workers and equipment before
     the operation and about 2 more weeks to demobilize after the
     operation. Additionally, according to industry representatives at one
     operating reactor site we visited, each canister takes about 1 week to
     load, dry, seal, and move to a storage pad, which limits the number of
     canisters that can be loaded in a given year. In addition, spatial
     limitations—such as space for drying or welding lids onto multiple
     canisters, limited heavy lifting capabilities, and lack of free space in
     spent fuel pools to accommodate more than one cask at a time—may
     make simultaneous loading of canisters difficult. Some industry
     representatives we spoke with told us that there are limits on how
     much acceleration can be achieved in a single year.


43
 NRC, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear
Power Plants, NUREG-1738 (Washington, D.C: February 2001).
44
  NRC, Single-Failure-Proof Cranes for Nuclear Power Plants, NUREG-0554
(Washington, D.C.: May 1979).
45
 NRC, Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical
Activity A-36, NUREG-0612 (Washington, D.C.: July 1980).




Page 41                                 GAO-12-797 Accumulation of Spent Nuclear Fuel
                            •     Increasing costs. The transfer of spent fuel from wet to dry storage is
                                  costly in several ways. We estimated in a November 2009 report that
                                  the transfer cost for about five canisters is about $5.1 million to
                                  $8.8 million. 46 One industry representative told us that if the transfer of
                                  spent fuel to dry storage were accelerated, the associated high up-
                                  front costs could strain some nuclear power plants’ budgets. These
                                  up-front costs, which would be incurred over a longer period without
                                  acceleration, include the construction of a storage pad with
                                  accompanying safety and security features, which, we reported, could
                                  cost about $19 million to $44 million. 47 These costs are initially borne
                                  by ratepayers or plant owners but may be passed on to taxpayers as
                                  a result of industry lawsuits against DOE for failure to take custody of
                                  the spent fuel. Moreover, EPRI reported that as older, cooler spent
                                  fuel is loaded into canisters, reactor operators eventually will be left
                                  with younger, hotter spent fuel to transfer from wet to dry storage.
                                  Spent fuel stored in canisters generally should not exceed about
                                  752 degrees Fahrenheit (400 degrees Celsius), and, as we reported
                                  earlier, spent fuel being discharged from reactors today may have to
                                  cool at least 7 years before it can be placed in dry storage. Given the
                                  heat load requirements for storing spent fuel, EPRI noted that it may
                                  not be possible to fill some canisters to capacity. Specifically, a
                                  canister with a capacity for 60 boiling water reactor assemblies that
                                  would store 60 older, cooler assemblies may be able to contain only
                                  38 younger, hotter assemblies.


Managing Spent Fuel after   Reactor operators had never intended to leave spent fuel on their sites for
Transfer from Wet to Dry    extended periods, but even if the United States began to develop an off-
Storage at Reactor Sites    site centralized storage or disposal facility today, spent fuel—which has
                            already been stored on-site for several decades—would be stored on-site
Presents Additional         for several decades more. As a result, the following challenges could
Challenges                  affect decisions on managing spent fuel.

                            Repackaging stranded spent fuel. Once reactors are decommissioned,
                            reactor operators have limited options for managing the stored spent fuel.


                            46
                                In constant 2012 dollars. GAO-10-48.
                            47
                              In constant 2012 dollars. These costs are not intended to be all-inclusive and represent
                            a generic case for comparative purposes. A storage pad could be used to store multiple
                            vertical or horizontal dry storage systems. For example, at Haddam Neck in Connecticut,
                            43 vertical casks are stored on a single pad. GAO-10-48.




                            Page 42                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
Specifically, once they package the spent fuel in canisters and dry casks,
they are unlikely to have any means of repackaging if the canisters
degrade over the long term, or if the operators have to meet different
storage or disposal requirements. As we previously reported, experts told
us that canisters are likely safe for at least 100 years, but by then the
spent fuel may have to be repackaged because of degradation. 48 By the
time such repackaging might be needed, reactor operators may no longer
have pools or the necessary infrastructure to undertake the repackaging,
as was the case at the Haddam Neck site we visited. Specifically, the
Haddam Neck site had already decommissioned the reactor, transferred
all its spent fuel from wet to dry storage, and dismantled its spent fuel
pool. If the spent fuel at the site needed to be repackaged, a special
transfer facility would need to be built, or the spent fuel would need to be
shipped to a site that had a transfer facility. In addition, to reduce costs,
reactor operators are selecting a variety of dry storage systems that
maximize storage capacity. These varied systems do not raise safety
issues, but they may complicate a transfer to a centralized storage facility
or a permanent disposal facility because different systems require
different handling requirements, such as the type of grappling hook and
the size of the transport cask required. These differences may present
more complex engineering challenges and cost issues as time passes,
and the volume of spent fuel in various systems increases. In addition,
over time, it is possible that handling equipment would not be maintained
and personnel would not continue to be trained. Maximizing storage
capacity may raise additional engineering challenges and cost issues,
particularly since larger canisters may meet storage requirements but not
transportation requirements. The Nuclear Energy Institute has reported
that of all the spent fuel currently in dry storage, only about 30 percent is
directly transportable. It also reported that the remaining spent fuel could
need as much as 10 more years of cooling to meet NRC’s transportation
heat-load requirements to ensure that assemblies can withstand the force
of a potential accident.

Reducing community opposition. As reactors begin to be closed down
and decommissioned, reactor operators will leave spent fuel on sites that
will serve no other purpose than storing that fuel. Continued on-site
storage would likely face increasing community opposition, which could
make it difficult for operators to obtain NRC recertification for storage



48
 GAO-10-48.




Page 43                              GAO-12-797 Accumulation of Spent Nuclear Fuel
sites at reactors, approval for licenses to extend the operating life of other
reactors, or licenses for new reactors. According to officials from a state
regional organization we spoke with, the longer the federal government
defers a permanent disposition pathway for spent fuel, the less likely the
public would be to accept interim solutions, for fear such solutions would
become de facto permanent solutions. Also, in our prior work, experts
noted that many commercial reactor sites are not suitable for long-term
storage and that none have had an environmental review to assess the
impacts of storing spent fuel beyond the period for which the sites are
currently licensed. 49 As discussed above, in June 2012, a federal
appellate court remanded NRC’s waste confidence determination and
rule for the preparation of an environmental impact statement or finding of
no significant environmental impact.

Managing costs. Continued storage of spent fuel may be costly. Because
owners of spent fuel would have to safeguard it beyond the life of
currently operating reactors, decommissioned reactor sites would not be
available to local communities and states for alternative development.
The Blue Ribbon Commission recommended that the nation open one or
more centralized storage facilities and put a high priority on transferring
the so-called stranded spent fuel to free decommissioned reactor sites for
other uses. We previously reported the cost of developing two federal
centralized storage facilities to be about $16 billion to $30 billion, although
this estimate does not include final disposal costs, which could cost tens
of billions of dollars more. 50 In addition, we also previously reported that if
spent fuel needs to be repackaged because of degradation, repackaging
could cost from $180 million to nearly $500 million, 51 with costs




49
  GAO-10-48.
50
   In constant 2012 dollars. Centralized storage poses additional challenges as well.
Provisions in the Nuclear Waste Policy Act of 1982, as amended, that allowed DOE to
arrange for centralized storage have either expired or are unusable because they were
tied to milestones in repository development that have not been met. DOE acknowledged
that it might have authority to arrange for centralized storage of spent fuel through the
Atomic Energy Act of 1954, as amended, but only under certain circumstances, such as
emergencies involving spent fuel that threaten public health. Transportation risks, too, are
associated with centralized storage, since the spent fuel would have to be transported
twice, once to the interim storage site and once to a disposal site.
51
  In constant 2012 dollars.




Page 44                                     GAO-12-797 Accumulation of Spent Nuclear Fuel
depending on the number of canisters to be repackaged and whether a
site has a transfer facility, such as a storage pool. 52

Planning transportation to an off-site facility. The transportation of large
amounts of spent fuel is inherently complex and may take decades to
accomplish, depending on a number of variables including distance,
quantity of material, mode of transport, rate of shipment, level of security,
and coordination with state and local authorities. For example, according
to officials from a state regional organization we talked to and the Blue
Ribbon Commission report, transportation planning could take about 10
years, in part because routes have to be agreed upon, first responders
have to be trained, and critical elements of infrastructure and equipment
need to be designed and deployed. In addition, according to the Nuclear
Energy Institute, some spent fuel in canisters that serve a dual purpose—
both storage and transportation—might not be readily transportable
because NRC’s transportation requirements for heat and radioactivity
may require additional time for cooling and decay. To transport spent fuel
before it is sufficiently cooled, reactor operators might have to repackage
it or place it in more robust transportation casks. Uncertainties also
surround the transportation of high-burn-up fuel. The Blue Ribbon
Commission noted that NRC has not yet certified a shipping cask for the
transport of high-burn-up fuels, 53 which are now commonly being
discharged from reactors. Spent fuel that has been stored for extended
periods may become degraded and require additional handling before it
can be transported. NRC has reported that the zirconium cladding of
high-burn-up fuel is known to become more brittle after long cooling
periods. Once sealed in a canister, the spent fuel cannot easily be
inspected for degradation. If the cladding degrades, there is no assurance
the spent fuel would remain in a safe configuration, potentially leading to
a nuclear reaction if conditions were right. NRC officials told us that if they
determined that a safe geometry could not be maintained during
transportation because of cladding degradation, they would require the
owner of the spent fuel to demonstrate that an uncontrolled critical chain
reaction would not occur and would not issue an approval for
transportation until they could assure a safe geometric configuration. In
addition, NRC expressed concerns about the safe handling of spent fuel


52
  GAO-11-229.
53
  A license is required for delivery of licensed material to a carrier for transport or for the
transport of licensed material. 10 C.F.R. § 71.3 (2012).




Page 45                                       GAO-12-797 Accumulation of Spent Nuclear Fuel
after transportation because of uncertainties over the condition of large
amounts of high-burn-up fuel that might have to be repackaged for
disposal. As a result, NRC stated that until further guidance is developed,
the transportation of high-burn-up fuel will be handled on a case-by-case
basis using the criteria given in current regulations. 54 Without a
standardized cask design for storage, transportation, and disposal, it may
be difficult to design the type of large-scale transportation program
needed to transfer high-burn-up fuel away from reactor sites.

Maintaining security over the long term. Future security requirements for
the extended storage of spent fuel are uncertain and could pose
additional challenges. Specifically, before the September 11, 2001,
terrorist attacks, spent nuclear fuel was largely considered to be self-
protecting for several decades because its very high radiation would
prevent a person from handling the material without incurring health or
life-threatening injury in a very short time, although incapacitating health
impacts may sometimes not occur for up to 16 hours. 55 In addition, as
spent fuel decays over time, it produces less decay heat. A spent fuel
assembly can lose nearly 80 percent of its heat 5 years after it has been
removed from a reactor and 95 percent of its heat after 100 years. Given
the willingness of terrorists in recent years to sacrifice their lives as part of
an attack, the national and international communities have begun to
rethink just how long spent fuel really might be self-protecting. As spent
fuel ages and becomes less self-protecting, additional security
precautions may be required.

Continuing taxpayer liabilities. The continued on-site storage of spent fuel
will not alleviate industry’s lawsuits against DOE for failure to take
custody of the spent fuel in 1998 as required by contracts authorized
under the Nuclear Waste Policy Act of 1982, as amended. DOE estimates
that the federal government’s liabilities resulting from the lawsuits will be
about $21 billion through 2020 and about $500 million each year after
that. These costs are paid for by the taxpayer through the Department of
the Treasury’s Judgment Fund.


54
     These regulations include 10 C.F.R. §§ 71.55, .43(f), and .51.
55
  The International Atomic Energy Agency, DOE, and NRC have considered spent fuel to
be self-protecting with a radiation level exceeding 100 rad—or, radiation absorbed dose, a
unit of measurement—per hour at 1 meter unshielded. After short-term exposure to 250 to
500 rad, about 50 percent of the people coming in contact with the spent fuel would be
expected to die within 60 days.




Page 46                                        GAO-12-797 Accumulation of Spent Nuclear Fuel
                     The decades-old problem of where to permanently store commercial
Conclusions          spent nuclear fuel remains unsolved even as the quantities of spent
                     fuel—in either wet or dry storage—continue to accumulate at reactor sites
                     across the country. It is not yet clear where a repository will be sited, but it
                     is clear that it may take decades more to site, license, construct, and
                     ultimately open a disposal site. In the interim, some scientists,
                     environmentalists, community groups, and others have expressed
                     growing concerns about the spent nuclear fuel that is densely packed in
                     spent fuel pools, especially after the water in the pools at the Fukushima
                     Daiichi nuclear power plant complex in Japan were at risk of being
                     depleted, increasing the risk of widespread radioactive contamination.
                     The chances of a radiation release are extremely low in either wet or dry
                     storage, but the event with the most serious consequences—a self-
                     sustaining fire in a spent fuel pool—could result in widespread radioactive
                     contamination. NRC has studied the likelihood of such an event and has
                     taken a number of steps to prevent a fire, including a number of mitigating
                     measures, though some community action groups have raised questions
                     if those steps are enough, given the severity of consequences.

                     Moreover, because storage or disposal facilities may take decades to
                     develop, in managing spent fuel, NRC and DOE officials and others with
                     appropriate clearances and a need to know may need to review classified
                     studies conducted by and for NRC on the safety and security of spent
                     fuel. These studies are likely to be relevant for decades and, therefore,
                     continue to contribute to institutional knowledge and the ultimate
                     decisions made concerning the handling and storage of spent nuclear
                     fuel. Nevertheless, NRC does not have a mechanism that allows for easy
                     identification and location of classified studies conducted over the years.
                     Without such a mechanism, it may be difficult and time-consuming to
                     access the necessary studies.


                     To help facilitate decisions on storing and disposing of spent nuclear fuel
Recommendation for   over the coming decades, we recommend that the Chairman of the
Executive Action     Nuclear Regulatory Commission direct agency staff to develop a
                     mechanism that allows individuals with appropriate clearances and the
                     need to know to easily identify and access classified studies so as to help
                     ensure that institutional knowledge is not lost.


                     We provided NRC with a draft of this report for review and comment. In
Agency Comments      written comments, which are reproduced in appendix IV, NRC generally
                     agreed with the findings and the recommendation in our report. NRC did


                     Page 47                               GAO-12-797 Accumulation of Spent Nuclear Fuel
note, however, that our characterization of NRC’s position to not require
accelerated transfer of spent fuel to dry storage was factually incorrect.
Specifically, NRC stated that we characterized its position on accelerated
transfer as being solely a cost-benefit decision. NRC stated that it does
not require accelerated transfer because it considers both wet and dry
storage to provide a safe means of storing spent fuel that is in full
conformance with agency regulations. We clarified the report language to
more clearly state NRC’s position. Regarding the recommendation, NRC
stated that it planned to review its internal procedures to determine if any
measures need to be taken to ensure the classified information is readily
available to future decision makers. NRC also provided technical
comments, which we have incorporated as appropriate.


As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies to the Chairman of the
Nuclear Regulatory Commission, the Secretary of Energy, appropriate
congressional committees, and other interested parties. In addition, the
report will be available at no charge on the GAO website at
http://www.gao.gov.

If you or your staff members have any questions about this report, please
contact me at (202) 512-3841 or aloisee@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report are listed in
appendix V.




Gene Aloise
Director
Natural Resources and Environment




Page 48                             GAO-12-797 Accumulation of Spent Nuclear Fuel
List of Requesters

Fred Upton
Chairman
Joe Barton
Chairman Emeritus
Committee on Energy and Commerce
House of Representatives

Cliff Stearns
Chairman
Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
House of Representatives

Ed Whitfield
Chairman
Subcommittee on Energy and Power
Committee on Energy and Commerce
House of Representatives

John Shimkus
Chairman
Subcommittee on Environment and the Economy
Committee on Energy and Commerce
House of Representatives




Page 49                          GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             To determine the amount of spent fuel projected to accumulate before it
             can be moved from individual reactor sites, we obtained data from the
             Nuclear Energy Institute, an industry advocacy organization, on current
             inventories of commercial spent nuclear fuel in wet and dry storage and a
             database on year-to-year projections of on-site spent fuel accumulation in
             wet and dry storage. We developed the projections of this amount on the
             basis of several assumptions, including that all 104 reactors would renew
             their licenses for 20 years, with the early shutdown of Oyster Creek, in
             New Jersey, 10 years before its license expires; that no new reactors are
             brought online; that the nation’s current reactors continue to produce
             spent fuel at the same rate; and that all spent fuel remaining in wet
             storage would be moved to dry storage 12 years after a reactor’s final
             shutdown. As part of our analysis, we obtained information in reports and
             from interviews from the Nuclear Regulatory Commission (NRC); the
             Department of Energy (DOE); the Electric Power Research Institute, a
             nonprofit research entity; and representatives from industry, academia,
             and community action and environmental groups. To assess the reliability
             of existing data, we reviewed available documentation and conducted
             interviews with individuals knowledgeable about the data. On the basis of
             this information, we found these data to be sufficiently reliable for the
             purposes of our report.

             To determine the most likely options for moving spent fuel off-site, we used
             prior work that had analyzed the Yucca Mountain program and its most
             likely alternatives to help us assess three scenarios: (1) Yucca Mountain,
             (2) two federally funded central storage facilities, and (3) a new permanent
             disposal facility. 1 We used assumptions from our prior work, including
             updating dates from our assumptions, and we supplemented these
             assumptions by reviewing documents and interviewing officials from federal
             and state regional organizations and representatives from industry,
             independent groups, and community action and environmental groups.
             Specifically, for the Yucca Mountain option, we asked DOE how long it
             would take for a repository at Yucca Mountain to open if licensing were to
             resume in 2012, assuming the license and funding were both approved.
             DOE told us that the best way to develop a new estimate would be to take
             the estimates that existed before the program was shut down and add the
             time elapsed between when DOE stopped work on licensing and when it
             may resume licensing, which is 10 years. We previously reported, however,



             1
              GAO-10-48.




             Page 50                             GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix I: Scope and Methodology




that DOE’s original estimate for licensing was likely too optimistic.
Furthermore, because all of DOE’s former Yucca Mountain program staff
have been assigned to other offices, left the agency, or retired, some
delays are likely in reassembling a licensing team—as much as 2 years,
according to one former DOE official familiar with the Yucca Mountain
program. 2 Given these challenges, we added 5 additional years to DOE’s
original 10-year estimate of completing Yucca Mountain. If licensing for the
Yucca Mountain program were to resume in 2012, the earliest possible
opening date is roughly 2027. For the two federal centralized storage
facilities, we updated dates we developed for a prior report, in which we
projected when the centralized storage facilities might be built, which was
19 years. 3 Since these are rough estimates, we rounded the time frame to
20 years, meaning that if the process were started in 2012, the earliest that
two federal centralized storage sites could open would be 2032. For a new
repository, we analyzed DOE’s actual and projected time frames for
licensing and opening the Yucca Mountain repository and DOE’s report to
Congress on the time frames necessary to open a second repository. We
also analyzed the time frames necessary to open the nation’s only high-
level radioactive disposal facility, the Waste Isolation Pilot Plant in New
Mexico. On the basis of our analysis, we determined that if a process were
started in 2012 to open a new repository, it could open in about 40 years,
or 2052.

To determine key safety and security risks of spent fuel, as well as
potential mitigation actions, we reviewed NRC-commissioned studies
performed by Sandia National Laboratories and studies by NRC, the
National Academy of Sciences, community action groups, and industry.
Our primary period of focus was post-September 11, 2001, which
included studies from 2002 to 2009, but we also reviewed pre-September
11, 2001, studies dating back to 1979. We identified relevant studies for
review by asking officials from NRC, DOE, and Sandia National
Laboratories, as well as knowledgeable persons whom we interviewed,
and by reviewing the citations in these studies to identify still other
relevant studies. We reviewed studies of spent fuel pools and dry casks
at the classified, NRC safeguards, official use only, and unclassified
levels. In addition, we toured the Haddam Neck decommissioned reactor
site and the Millstone reactor in Connecticut, the Hope Creek and Salem


2
GAO-10-48 and GAO-11-229.
3
GAO-10-48.




Page 51                              GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix I: Scope and Methodology




reactors in New Jersey, and the Susquehanna reactor in Pennsylvania,
and we spoke with NRC officials and industry representatives about wet
and dry spent fuel storage issues, including potential mitigation actions, at
these sites. Our site visits included decommissioned and operating
reactor sites, sites with both pressurized water reactors and boiling water
reactors, sites having both wet and dry storage, and sites using both
vertical and horizontal dry storage systems. We also reviewed NRC
requirements addressing the safety and security of spent fuel, as well as
directives from the nuclear power industry.

To determine the benefits and challenges of transferring spent fuel from
wet to dry storage, including transferring this fuel at an accelerated rate,
we reviewed prior GAO reports and documents from NRC, DOE, the
Nuclear Waste Technical Review Board, the National Academy of
Sciences, the Blue Ribbon Commission on America’s Nuclear Future,
academia, industry, and community action and environmental groups. We
also interviewed officials from NRC, DOE, and state regional
organizations, and representatives of industry, academia, the Blue
Ribbon Commission on America’s Nuclear Future, and community action
and environmental groups. We spoke with industry representatives and
NRC inspectors at the decommissioned and operating reactor sites we
visited. In our interviews, we asked for their views on the benefits and
challenges of transferring spent fuel from wet to dry storage and the
benefits and challenges of accelerating that transfer. To further determine
the cost considerations for transferring spent fuel from wet to dry storage,
we updated cost component estimates developed for our 2009 report to
constant 2012 dollars. In that report, we obtained information from a small
group of experts to develop initial assumptions, which we then provided to
a larger set of nearly 150 experts for comment. 4

We conducted this performance audit from June 2011 to August 2012, in
accordance with generally accepted government auditing standards.
These standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.



4
 For further information on the scope and methodology used, please see appendixes I, II,
and III in GAO-10-48.




Page 52                                   GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix II: Selected Other Countries’ Spent
                                       Appendix II: Selected Other Countries’ Spent
                                       Fuel Management Programs



Fuel Management Programs

                                       Like the United States, other countries produce electricity from nuclear
                                       power reactors and have programs to manage their spent nuclear fuel.
                                       Table 2 provides a brief description of the programs in selected countries.

Table2: Summary of Commercial Nuclear Programs and Spent Fuel Management Programs for Selected Countries

                       Began    Number of Spent fuel Inventory
                  commercial     operating at end of 2007 (tons
Country    nuclear operations     reactors      of heavy metal) Spent fuel management program
Canada                  1968           18                 38,400   •    Does not reprocess spent nuclear fuel.
                                                                   •    Stores spent nuclear fuel at nuclear power reactor sites
                                                                        in both wet and dry storage.
                                                                   •    Does not have an independent centralized interim
                                                                        storage facility.
                                                                   •    Plans to develop an independent centralized interim
                                                                        storage facility in rock formations suitable for shallow
                                                                        underground storage.
                                                                   •    A group that includes Canadian utilities and the
                                                                        Canadian government has recommended a geological
                                                                        repository, but no specific site has been selected.
Japan                   1966          50a                 19,000   •    Reprocesses spent nuclear fuel. Historically, Japan has
                                                                        shipped its spent nuclear fuel to France and the United
                                                                        Kingdom.
                                                                   •    Stores spent nuclear fuel in pools at reactor sites with
                                                                        two reactor sites that also store spent fuel in dry storage.
                                                                   •    Constructed its own reprocessing plant at Rokkasho,
                                                                        Japan. (Uncertainty surrounds the future of Rokkasho as
                                                                        the Japanese government reviews its nuclear policy after
                                                                        the disaster at the Fukushima Daiichi nuclear power
                                                                        plant. No date for operation has been set.)
                                                                   •    Rokkasho contains an interim wet storage pool for spent
                                                                        nuclear fuel. The pool is currently full, awaiting start of
                                                                        reprocessing operations.
                                                                   •    An interim dry storage facility is under construction at
                                                                        Mutsu near the Rokkasho reprocessing plant. The plan
                                                                        is to store spent fuel there until transfer for reprocessing.
                                                                        (Construction at Mutsu has been put on hold following
                                                                        the Fukushima disaster in March 2011.)
                                                                   •    Plans to construct a geological repository but has not
                                                                        selected any sites.
Russia                  1963           33                 17,895   •    Reprocesses some spent nuclear fuel as well as spent
                                                                        fuel from other countries.
                                                                   •    Pools are used to store spent nuclear fuel at reactor
                                                                        sites.
                                                                   •    In 2011, construction was completed on the world’s
                                                                        largest dry storage facility at Zheleznogorsk, Siberia.
                                                                        Zheleznogorsk also houses wet storage pools as part of
                                                                        Russia’s centralized interim storage facilities.
                                                                   •    No formalized plans for a geological repository.




                                       Page 53                                        GAO-12-797 Accumulation of Spent Nuclear Fuel
                                       Appendix II: Selected Other Countries’ Spent
                                       Fuel Management Programs




                      Began    Number of Spent fuel Inventory
                 commercial     operating at end of 2007 (tons
Country   nuclear operations     reactors      of heavy metal) Spent fuel management program
France                 1964            58               13,500 •  Reprocesses its own spent nuclear fuel as well spent
                                                                  fuel from other countries; virtually all of the spent fuel
                                                                  reprocessed today is domestic.
                                                               •  Uses only wet storage for spent nuclear fuel.
                                                               •  Spent nuclear fuel from French reactors is cooled in
                                                                  pools for several years at reactor sites and then
                                                                  transported to the reprocessing plant at La Hague,
                                                                  France. The spent fuel is then stored for several more
                                                                  years in massive pools before reprocessing.
                                                               •  No independent centralized storage facility. La Hague
                                                                  serves as a quasi-centralized storage facility while spent
                                                                  fuel awaits reprocessing.
                                                               •  Plans to develop a geological repository. A tentative site
                                                                  has been selected at Bure, France, but no final plan has
                                                                  been approved.
South                  1978            23               10,900 •  Does not reprocess spent nuclear fuel.
Korea                                                          •  Stores spent nuclear fuel at nuclear power reactor sites
                                                                  in both wet and dry storage systems.
                                                               •  A centralized storage facility for spent nuclear fuel is
                                                                  pending construction by 2016.
                                                               •  Envisions a geological repository but has not selected a
                                                                  site.
Germany                1969             9                5,850 •  Shipped most of its spent nuclear fuel to France and the
                                                                  United Kingdom for reprocessing, until 2005.
                                                               •  Stores the majority of spent nuclear fuel in interim dry
                                                                  storage facilities at reactor sites.
                                                               •  Stores some spent nuclear fuel at sites away from
                                                                  reactors in interim dry storage.
                                                               •  Plans to develop a geological repository for spent
                                                                  nuclear fuel. A site that was tentatively selected has
                                                                  become controversial, and no final decision on a site has
                                                                  been made.
United                 1956            18                5,850 •  Reprocesses its own spent nuclear fuel as well spent
Kingdom                                                           fuel from other countries.
                                                               •  Uses only wet storage for spent nuclear fuel.
                                                               •  Does not have an independent centralized interim
                                                                  storage facility.
                                                               •  Plans to develop a geological repository for spent
                                                                  nuclear fuel but has not selected a site.
Sweden                 1972            10                5,400 •  Does not reprocess spent nuclear fuel.
                                                               •  Stores spent nuclear fuel at reactor sites in pools before
                                                                  transfer to a central interim underground wet storage
                                                                  facility at the Oskarshamn nuclear power plant.
                                                               •  Finalized plans for a geological repository for spent
                                                                  nuclear fuel at the Forsmark nuclear power plant in
                                                                  Sweden. Full construction at the site is scheduled to
                                                                  begin in 2015 and operation in approximately 2023.




                                       Page 54                                        GAO-12-797 Accumulation of Spent Nuclear Fuel
                                       Appendix II: Selected Other Countries’ Spent
                                       Fuel Management Programs




                      Began    Number of Spent fuel Inventory
                 commercial     operating at end of 2007 (tons
Country   nuclear operations     reactors      of heavy metal) Spent fuel management program
Finland                1977             4                1,600 •  Does not reprocess spent nuclear fuel. After collapse of
                                                                  Soviet Union, discontinued sending some of its nuclear
                                                                  fuel to the Soviet Union for reprocessing.
                                                               •  Stores spent nuclear fuel in pools at nuclear power
                                                                  plants until transfer to a deep geological repository.
                                                               •  Finalized plans for a geological repository sited next to
                                                                  its Olkiluoto nuclear power plant. Acceptance of spent
                                                                  nuclear fuel is scheduled to start in approximately 2020.
                                       Sources: For the spent nuclear fuel inventory amounts at the end of 2007, International Panel on Fissile Materials, Managing Spent
                                       Fuel from Nuclear Power Reactors: Experience and Lessons from Around the World (Princeton, NJ: September 2011). The amounts
                                       reflect fuel stored in cooling pools and dry storage. In addition, we used the following sources for the countries listed:


                                       For Canada: International Panel on Fissile Materials, Managing Spent Fuel from Nuclear Power
                                       Reactors; World Nuclear Association, “Country Briefings: Nuclear Power in Canada,” accessed May
                                       2012, http://www.world-nuclear.org; Nuclear Energy Institute, “Global Nuclear Power Development:
                                       Major Expansion Continues” (Washington, D.C.: May 2012); U.S. Nuclear Waste Technical Review
                                       Board, Survey of National Programs for Managing High-Level Radioactive Waste and Spent Nuclear
                                       Fuel: A Report to Congress and the Secretary of Energy (Arlington, VA: October 2009), and
                                       Experience Gained from Programs to Manage High-Level Radioactive Waste and Spent Nuclear Fuel
                                       in the United States and Other Countries: A Report to Congress and the Secretary of Energy
                                       (Arlington, VA: April 2011).
                                       For Japan: World Nuclear Association, “Country Briefings: Nuclear Power in Japan,” accessed May
                                       2012, http://www.world-nuclear.org; Japan Atomic Industrial Forum, “Moves Afoot to Restart Nuclear
                                       Power Plant Operation and Its Related Issues in Japan,” (Tokyo: May 31,2012), accessed May 31,
                                       2012, http://www.jaif.or.jp/english/activities_new.html#purpose; International Panel on Fissile
                                       Materials, Managing Spent Fuel from Nuclear Power Reactors.
                                       For Russia: World Nuclear Association, “Country Briefings: Nuclear Power in Russia,” accessed May
                                       2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing Spent Fuel
                                       from Nuclear Power Reactors; World Nuclear Association, “Radioactive Waste Management,”
                                       Nuclear Fuel Cycle: Nuclear Wastes, accessed April 2012, http://www.world-nuclear.org; International
                                       Panel on Fissile Materials, “Spent Fuel from Nuclear Power Reactors: Overview of a New Study.”
                                       Presentation by Frank von Hippel, hosted by the American Association for the Advancement of
                                       Science, Washington, D.C., June 3, 2011; World Nuclear Association, “Country Briefings: Russia’s
                                       Nuclear Fuel Cycle,” accessed March 2012, http://www.world-nuclear.org.
                                       For France: Embassy of France in Washington, D.C. “Nuclear Energy in France,” accessed March
                                       2008, http://ambafrance-us.org/spip.php?article637; World Nuclear Association, “Country Briefings:
                                       Nuclear Power in France,” accessed February 2012, http://www.world-nuclear.org; International
                                       Panel on Fissile Materials, Managing Spent Fuel from Nuclear Power Reactors and “Spent Fuel from
                                       Nuclear Power Reactors”; World Nuclear Association, “Radioactive Waste Management,” accessed
                                       April 2012, http://www.world-nuclear.org.
                                       For South Korea: World Nuclear Association, “Country Briefings: Nuclear Power in South Korea,”
                                       accessed April 2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing
                                       Spent Fuel from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors.”
                                       For Germany: International Panel on Fissile Materials, Managing Spent Fuel from Nuclear Power
                                       Reactors; EnBW, Uranium Is Energy: The Nuclear Power Plants of EnBW (Karlsruhe: Energy Baden-
                                       Wurttemberg, June 2007); International Panel on Fissile Materials, “Spent Fuel from Nuclear Power
                                       Reactors,”; World Nuclear Association, “Country Briefings: Nuclear Power in Germany,” accessed
                                       April 2012, http://www.world-nuclear.org; U.S. Nuclear Waste Technical Review Board, Survey of
                                       National Programs for Managing High-Level Radioactive Waste.




                                       Page 55                                                        GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix II: Selected Other Countries’ Spent
Fuel Management Programs




For the United Kingdom: World Nuclear Association, “Country Briefings: Nuclear Development in the
United Kingdom,” accessed March 2012, http://www.world-nuclear.org; Nuclear Energy Institute
“Global Nuclear Power Development”; International Panel on Fissile Materials, Managing Spent Fuel
from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors”;World Nuclear
Association, “Radioactive Waste Management”; U.S. Nuclear Waste Technical Review Board, Survey
of National Programs for Managing High-Level Radioactive Waste; World Nuclear Association,
“Country Briefings: Nuclear Power in the United Kingdom”, accessed May 2012,
http://www.world-nuclear.org.
For Sweden: World Nuclear Association, “Country Briefings: Nuclear Power in Sweden,” accessed
April 2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing Spent
Fuel from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors”; World Nuclear
Association, “Radioactive Waste Management,” app. 3, “National Policies,” accessed April 2012,
http://www.world-nuclear.org.
For Finland: World Nuclear Association, “Country Briefings: Nuclear Power in Finland,” accessed
April 2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing Spent
Fuel from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors”; U.S. Nuclear
Waste Technical Review Board, Experience Gained from Programs to Manage High-Level
Radioactive Waste and Spent Nuclear Fuel in the United States and Other Countries.
a
 On May 5, 2012, Japan’s lone operating nuclear power plant ceased operation. All of Japan’s
nuclear power plants were to remain shut down pending the Japanese government’s safety
inspections and support of local Japanese governments to restart nuclear operations. Since May 5,
2012, Japan has restarted one nuclear power plant to full power and may determine restart dates for
other reactors. The disaster at the Tokyo Electric Power Company’s Fukushima Daiichi nuclear power
plant, triggered by the earthquake and tsunami of March 11, 2011, had a debilitating effect on the
operation of Japan’s nuclear power plants. On June 16, 2012, the Japanese government announced
plans to restart two reactors at the Ohi nuclear power plant in July 2012, but the future of the
Japanese nuclear energy program is uncertain, and not all of the 50 reactors listed are expected to
restart.




Page 56                                         GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix III: Accumulation of Commercial
                                          Appendix III: Accumulation of Commercial
                                          Spent Fuel by State over Time



Spent Fuel by State over Time

                                          Our report identified three scenarios in which spent fuel could be moved
                                          to an off-site location. Briefly, the earliest likely opening date if the Yucca
                                          Mountain repository were to be licensed and constructed is about 2027,
                                          the earliest a centralized storage facility could be expected to open is
                                          about 2032, and the earliest a permanent disposal facility that was an
                                          alternative to Yucca Mountain could be expected to open is about 2052.
                                          Table 3 summarizes the amount of spent fuel that is expected to
                                          accumulate in each state for these dates, as well as 2012—the current
                                          spent fuel accumulation—and 2067, when all currently operating
                                          commercial nuclear power reactors are expected to have retired and
                                          transferred their spent fuel to dry storage. The table also shows the rank
                                          for each state in terms of the amount of its accumulated spent fuel in
                                          comparison with the other states.

Table 3: Cumulative Quantities of Spent Fuel, by State, for 2012, 2027, 2032, 2052, and 2067

Metric tons
                      2012                   2027                    2032                      2052                  2067
                    Total                   Total                   Total                   Total                   Total
State             volume     Rank         volume    Rank          volume    Rank          volume      Rank        volume    Rank
Alabama              3,341      5           5,300       5           6,004       5           6,899        4          6,899      4
Arizona              2,041     15           3,331     14            3,761      14           5,108       13          5,108     13
Arkansas             1,377     18           2,117     17            2,369      17           2,659       19          2,659     19
California           3,059      6           4,565       6           5,039       6           6,351        6          6,351      6
Connecticut          2,079     14           2,729     16            2,962      16           3,477       16          3,477     16
Florida              3,035      7           4,319       7           4,847       7           5,467        9          5,467      9
Georgia              2,691     10           4,101       9           4,584       9           5,815        8          5,815      8
Illinois             8,995      1          12,978       1          14,639       1          17,354        1         17,354      1
Iowa                  476      32             692     31              746      31              838      31            838     31
Kansas                685      25           1,075     25            1,192      26           1,593       25          1,593     25
Louisiana            1,288     20           2,062     18            2,275      18           3,035       17          3,035     17
Maine                 542      31             542     32              542      32              542      32            542     32
Maryland             1,379     17           1,979     19            2,179      19           2,451       20          2,451     20
Massachusetts         664      27             888     29            1,046      29           1,046       29          1,046     29
Michigan             2,692      9           4,012     11            4,468      10           5,193       12          5,193     12
Minnesota            1,235     21           1,767     22            1,973      22           2,077       22          2,077     22
Mississippi           805      24           1,215     24            1,379      24           1,805       23          1,805     23
Missouri              679      26           1,059     26            1,211      25           1,553       26          1,553     26
Nebraska              904      23           1,309     23            1,462      23           1,608       24          1,608     24




                                          Page 57                                    GAO-12-797 Accumulation of Spent Nuclear Fuel
                                  Appendix III: Accumulation of Commercial
                                  Spent Fuel by State over Time




                    2012               2027                                2032                          2052                   2067
                   Total            Total                              Total                           Total                   Total
State            volume    Rank   volume        Rank                 volume         Rank             volume     Rank         volume    Rank
New                 586      30        966           28                  1,080             28          1,517      27           1,517     27
Hampshire
New Jersey         2,667     11      4,031           10                  4,419             11          5,390      10           5,390     10
New York           3,726      4      5,423            4                  6,045              4          6,771       5           6,771      5
North Carolina     4,984      3      7,484            3                  8,294              3         10,384       3          10,384      3
Ohio               1,154     22      1,829           21                  2,044             20          2,699      18           2,699     18
Oregon              345      33        345           33                    345             33            345      33             345     33
Pennsylvania       6,272      2      9,408            2                10,410               2         13,082       2          13,082      2
South Carolina     2,898      8      4,308            8                  4,807              8          5,324      11           5,324     11
Tennessee          1,672     16      2,742           15                  3,063             15          4,056      15           4,215     15
Texas              2,199     13      3,759           12                  4,305             12          6,264       7           6,343      7
Vermont             624      29        854           30                    989             30            989      30             989     30
Virginia           2,527     12      3,607           13                  4,031             13          4,471      14           4,471     14
Washington          656      28      1,032           27                  1,126             27          1,500      28           1,500     28
Wisconsin          1,367     19      1,847           20                  2,024             21          2,119      21           2,119     21
                                  Source: GAO analysis of Nuclear Energy Institute data.

                                  Note: The data from this table constitute the underlying data in figure 8.




                                  Page 58                                                       GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix IV: Comments from the Nuclear
             Appendix IV: Comments from the Nuclear
             Regulatory Commission



Regulatory Commission




             Page 59                                  GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix IV: Comments from the Nuclear
Regulatory Commission




Page 60                                  GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix V: GAO Contact and Staff
                  Appendix V: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Gene Aloise, (202) 512-3841 or aloisee@gao.gov
GAO Contact
                  In addition to the individual named above, Janet E. Frisch (Assistant
Staff             Director), Antoinette Capaccio, Virginia Chanley, Ellen W. Chu, Randall
Acknowledgments   Cole, R. Scott Fletcher, Cristian Ion, Mehrzad Nadji, Kevin Remondini,
                  Robert Sánchez, Carol Shulman, Kiki Theodoropoulos, and Franklyn Yao
                  made key contributions to this report.




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                  Page 61                             GAO-12-797 Accumulation of Spent Nuclear Fuel
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