oversight

Nuclear Regulation: The Military Would Benefit From a Comprehensive Waste Disposal Program

Published by the Government Accountability Office on 1990-03-23.

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

-__--   -~   IJnitcvi   States   Gt~nera.1 Accounting   Office

GAO          Report to the Chairman, Cornrnittee on
             Governmental Af’f’airs, U.S. Senate




             NUCLEAR
             REGULATION
             The Military Would
             Benefit From a
             Comprehensive Waste
             Disposal Program
                                                                           ‘g!
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         , ..
      Resources, Community, and
      Economic Development Division

      B-238633

      March 23,199O

      The Honorable John Glenn, Chairman
      Committee on Governmental Affairs
      United States Senate

      Dear Mr. Chairman:

      As a result of an incident at Wright-Patterson Air Force Base, you asked us to examine the
      Nuclear Regulatory Commission’s oversight of the Department of Defense’s use, handling,
      and disposal of radioactive material. On the basis of subsequent discussions with your office,
      we agreed to conduct a detailed examination of the lqw-level radioactive waste disposal
      practices of the Departments of the Army, Air Force, and Navy. This report provides
      information on the three services’ waste disposal practices and legislative uncertainties that
      could benefit or adversely affect them in the future.

      Unless you publicly announce its contents earlier, we plan no further distribution of this
      report until 30 days from the date of this letter. At that time, we will send copies to
      appropriate congressional committees; the Secretary of Energy; and the Director, Office of
      Management and Budget. We will also make copies available to others upon request.

      This work was performed under the direction of Victor S. Rezendes, Director, Energy Issues,
      who can be reached at (202) 275-1441. Other major contributors are listed in appendix III.




  Y   J. Dexter Peach
      Assistant Comptroller General
E$ecutive Summary


   /
                    Because of an accidental release of low-level waste stored at the Wright-
P&pose             Patterson Air Force Base, Ohio, in 1986, several individuals inhaled
   /
   I               small quantities of a radioactive substance. Throughout the Department
                   of Defense (DOD), thousands of individuals in all 50 states and overseas
                   routinely use hundreds of radioactive byproduct materials for academic,
                   research and development, medical diagnosis and treatment, and indus-
                   trial activities. Appropriate precautions must be taken to safely dispose
                   of the low-level radioactive waste generated from these activities. In
                   1988, generators disposed of about 1.4 million cubic feet of such waste,
                   including about 6 percent from federal agencies.

                   The Chairman, Senate Committee on Governmental Affairs, asked GAO
                   to compare the low-level radioactive waste disposal practices of the
                   Departments of the Army, Air Force, and Navy.


                   The Atomic Energy Act of 1954, as amended, requires the Nuclear Regu-
BaLkground         latory Commission (NRC) to issue licenses to qualified individuals or
                   organizations to use and to dispose of radioactive material. Within DOD,
                   NRC has issued licenses to the Army, Air Force, and Navy. Each service
                   has established its own procedures for managing low-level radioactive
                   waste. DOD installations store low-level waste pending its long-term dis-
                   posal in three commercial sites.

                   Under the Low-Level Radioactive Waste Policy Act, as amended, states
                   either separately or through interstate compacts are required to have
                   new sites available by January 1993 so that all waste generated within
                   the boundaries of the compact or state will be disposed of there. DOD will
                   have to send waste to as many as 16 sites. To encourage new site devel-
                   opment, the act established surcharges ranging from $10 to $40 per
                   cubic foot of waste disposed of between July 1986 and December 1992
                   and penalties of up to $120 per cubic foot during calendar year 1992 if
                   the compacts and states have not submitted site applications. The act
                   requires NRC to establish criteria for waste whose radiological impacts
                   would be so low that it could be considered “below regulatory concern”
                   and exempt from the act. NRC expects to issue a final policy during the
                   spring of 1990. (See ch. 1.)


                   No comprehensive WD waste disposal program exists, and none of the
Results in Brief   three services knows the full extent of its low-level radioactive waste
                   disposal problems. As a result, DOD leaves itself open to errors and prob-
                   lems that could lead to adverse publicity and criticism. Throughout the


                   Page 2                      GAO/RCED-99-96 Military Needs a Waste Disposal Program
                             198Os, the Army and Air Force had, on occasion, been banned from dis-
                             posal sites for failing to comply with federal and state requirements.

                             By December 1992, two of the three sites used by DOD to dispose of
                             waste will close, and only a limited number of new sites may be avail-
                             able for several years. In the interim, DOD will incur substantial
                             surcharges to dispose of waste. After January 1993, DOD would have to
                             comply with disposal requirements for as many as 16 sites or store
                             waste on-site pending the availability of the new sites. No provisions
                             exist after that time for disposal of low-level waste generated at DOD
                             overseas locations.

                             DOD needs to take full advantage of the time between now and January
                              1993 to establish a comprehensive low-level radioactive waste disposal
                             program. A comprehensive program could help ensure that the three
                             services (1) identify the types and amount of waste generated and dis-
                             posed of, (2) aggressively pursue volume-reduction techniques, and (3)
                             establish a more cost-effective method to dispose of their waste. In addi-
                             tion, DOD needs to work with the other federal agencies, compacts, and
                             states to determine the feasibility of dedicating a portion of one or more
                             disposal sites for the government’s use.



Principal Findings

Benefits Could Be Realized   A comprehensive low-level radioactive waste disposal program could
From a Comprehensive         help resolve a number of weaknesses that GAO identified. First, none of
                             the three services has complete information on the amounts or types of
Program                      low-level radioactive waste generated or disposed. In 1988, the Navy
                             conducted two surveys to develop this information, but the results were
                             not complete. The Army expects to survey its installations in fiscal year
                             1990. The Air Force surveyed 23 bases in 1987. Although 46 bases bur-
                             ied waste on-site in the 1950s and only limited data exist on the number
                             of sites and the types and amounts of material in them, the Air Force
                             does not plan to conduct additional surveys.

                             Second, the Navy generally stockpiles its waste and has been doing so
                             for many years. Long-term storage increases the potential that another
                             accident similar to Wright-Patterson could occur. The accident, which
                             cost almost $1 million to clean up, could have been avoided if the Air
                             Force had not stored its waste.


                             Page 3                     GAO/RCED99-96 Military Needs a Waste Disposal Program
                              Executive Summary




                              Third, throughout the 19809, the Army and Air Force were banned at
                              one time or another from all three disposal sites for failing to comply
                              with a federal and state packaging and shipping requirements. This may
                              be an increasing problem since after 1993, the services may have to
                              comply with as many as 16 different compact and state disposal
                              requirements. Fourth, differences exist among the waste management
                              practices of the three services, as well as within each service. Some
                              installations have NRC'S approval to store some waste until it decays to a
                              level where it can be disposed of as normal trash; others send all waste
                              for burial. Some crush, compact, or consolidate waste prior to shipment,
                              thereby reducing volumes disposed of and costs; others do not. Consist-
                              ently utilized, these techniques could significantly reduce disposal
                              volumes and, ultimately, costs.

                              A comprehensive DOD program could ensure that the military (1) identi-
                              fies the types and amounts of waste generated, (2) consolidates manage-
                              ment expertise and training to stay current with the different compact
                              and state requirements, (3) consistently utilizes volume-reduction tech-
                              niques to reduce costs, (4) uniformly considers alternatives for disposing
                              of waste that meets NRC'S below-regulatory-concern policy, and (5)
                              establishes a more cost-effective method to dispose of its waste. (See
                              chs. 2 and 3.)


Federal Sites Could Benefit   As of January 1990, basic disposal costs and surcharges were almost
the Military                  equal. DOD now pays almost twice as much as it actually costs to dispose
                              of waste because of surcharges. DOD will continue to pay substantial
                              surcharges each time it disposes of waste-up to $120 per cubic foot
                              over and above disposal costs-through        1993. By December 1992, two
                              of the existing three sites will close. As of January 1990, only one com-
                              pact had submitted an application for a new site. If new sites are not
                              available by January 1993, DOD will be required to store waste or each
                              generator will have to seek an NRC exemption to dispose of waste outside
                              its region. To request an exemption, the generator will have to demon-
                              strate that an imminent public health and safety risk exists. According
                              to NRC staff, it would be rare that such a risk would exist; therefore, NRC
                              will probably grant few exemptions.

                              One or more federal sites could alleviate these and other problems.
                              Working with other federal agencies, DOD can pursue several options.
                              First, two of the existing three sites will close in December 1992, but all
                              three have unfilled capacity. Second, a portion of new sites could be
                              dedicated for federal agencies’ use. Federal sites would (1) allow the


                              Page 4                      GAO/RCED-90-96 Military Needs a Waste Disposal Program
                        Executive Summary




                        military to compact, consolidate, and reduce disposal volumes; (2)
                        reduce the potential for packaging and shipping errors to occur; and (3)
                        ensure that waste generated overseas can be disposed of. After January
                        1993, the compacts and states do not have to dispose of waste generated
                        overseas.

                        Although the compacts or states may need to overcome a number of
                        political issues, such as public opposition to accepting waste from
                        outside their boundaries, GAO believes that the increased efficiencies and
                        cost savings to be derived justify giving serious consideration to this
                        option. Because of the widespread geographic location of its bases, DOD
                        should spearhead the effort with other federal agencies. Although offi-
                        cials from the three services acknowledge that benefits would be
                        derived if a federal site was available, they do not believe that DOD
                        should lead this effort. (See ch. 3.)


                        To ensure that all DOD facilities appropriately dispose of low-level radio-
Recommendationsto       active waste, GAO recommends that the Secretary of Defense
the Secretary of
Defense             l establish a comprehensive low-level radioactive waste disposal program
                      at a high departmental level, establish uniform policies and procedures
                      for the program, and institute a mechanism to ensure compliance
                      throughout DOD with the requirements;
                    . develop an inventory of the amounts and types of low-level radioactive
                      waste that are stored or buried at all DOD installations;
                    l require all DOD installations to institute consistent waste minimization
                      and treatment techniques; and
                    l develop a strategy for dealing with low-level waste after 1992, including
                      working with other federal agencies, compacts, and states to determine
                      the feasibility of dedicating a portion of one or more sites for the gov-
                      ernment’s use and ensuring that low-level radioactive waste generated
                      overseas would be accepted for disposal.


                        GAO discussed the facts presented in this report with NRC, Army, Air
Agency Comments         Force, and Navy officials. They generally agreed with the facts but
                        offered some clarifications that were incorporated where appropriate.
                        As requested, GAO did not ask DOD or NRC to review and comment offi-
                        cially on this report.
         ”




                        Page 6                      GAO/RCED-9096 Military Needs a Waste Disposal Program
C(mtents



Ch/apter 1
Introduction              Military’s Organization to Comply With NRC’s
                                Requirements
                                                                                                           8

                          Legislation Could Have an Impact on the Military’s                              10
                                Program
                          Wright-Patterson Air Force Base Incident                                        11
                          Objectives, Scope, and Methodology                                              12

Chapter 2                                                                                                 16
Military Can Improve      Full Extent of the Military’s Low-Level Radioactive Waste
                               Problems Is Not Known
                                                                                                          16
Its jLow-Level            Army’s Program Has Several Advantages                                           20
Raklioactive Waste        Numerous Management Weaknesses Existed in the                                   23
                               Army’s Program
Didposal Practices
Chkpter 3                                                                                                 27
Uncertainties Exist for   Military Does Not Use Uniform Waste Management
                                Practices
                                                                                                          27
th& Future Disposal of    Legislative Requirements Could Adversely Affect the                             29
DOD’s Low-Level                 Military’s Waste Disposal Efforts
                          Future Regulatory Uncertainties                                                36
Radioactive Waste
Chapter 4                                                                                                40
Conclusions and           Benefits Could Be Realized From a Comprehensive
                              Program
                                                                                                         40
Recommendations           Federal Sites Could Benefit the Military                                       41
                          Recommendations to the Secretary of Defense                                    43

Adpendixes                Appendix I: Some Provisions of the Low-Level                                   44
                              Radioactive Waste Policy Act, as Amended
                          Appendix II: List of Organizations Visited and Officials                       46
                              GAO Contacted
                          Appendix III: Major Contributors to This Report                                48

Tables         L)         Table 2.1: Results of the Navy’s Radioactive Waste                              17
                              Surveys



                          Page 6                      GAO/RCED-90-96 Military Needs a Waste Disposal Program
                  Contents




--.L.------
              I   Table 2.2: Volume and Disposal Costs of the Army and Its                     19
              I
                      Program Participants, Fiscal Years 1985-89
                  Table 3.1: Examples of Waste-Handling Techniques Used                        28
                      by Various Military Installations
                  Table 3.2: Example of Possible Impact of Surcharges on                       34
                      the Military’s Waste Disposal Costs

Figgre            Figure 3.1: Status of Compact Regions, December 1989                         31




                  Abbreviations

                  AMCCOM     Army Armament, Munitions and Chemical Command
                  DOD        Department of Defense
                  DOE        Department of Energy
                  WA         Environmental Protection Agency
                  GAO        General Accounting Office
                  GSA        General Services Administration
                  NRC        Nuclear Regulatory Commission
                  (n‘A       Office of Technology Assessment


                  Page 7                    GAO/RCED90-96 Military Needs a Waste Disposal Program
  C&p&r
    1     1

/ h)troduction


                      Throughout the Department of Defense (DOD), thousands of individuals
                      in all 50 states and overseas routinely use hundreds of radioactive
                      byproduct materials for academic, research and development, medical
                      diagnosis and treatment, and industrial activities. Most of these materi-
                      als emit relatively low levels of radiation, posing little or no threat to the
                      users or the public, but some can result in significant radiation exposure
                      if not properly handled. Therefore, appropriate precautions must be
                      taken to safely dispose of the low-level waste generated from these
                      materials.’ Presently, most low-level waste (except that generated by
                      the Department of Energy (DOE)) is being buried at three sites located in
                      South Carolina, Nevada, and Washington. In 1988, low-level generators
                      disposed of about 1.4 million cubic feet of such waste at these sites,
                      including about 6 percent from government agencies, such as the
                      Departments of Defense and Veterans Affairs, and the National Insti-
                      tutes of Health.


                      Under the Atomic Energy Act of 1954, as amended, and the Energy
  Military’s          Reorganization Act of 1974, as amended, the Nuclear Regulatory Com-
  Otganization to     mission (NRC) is responsible for ensuring that radioactive material is
  Comply With NRC’s   handled safely and does not endanger the users and/or the public.
                      Within NRC, the Office of Nuclear Material Safety and Safeguards is
  Requirements        responsible for issuing licenses to qualified individuals, businesses, and
                      other institutions, including the Departments of the Army, Air Force,
                      and Navy, to handle specific radioactive material according to its regula-
                      tions.” The regulations, as well as a number of NRC policies, also specify
                      the methods that licensees can use to dispose of low-level waste. The
                      methods range from burial in unlined trenches at NRC-licensed sites to
                      disposal as normal trash.

                      The three services hold different types of NRC byproduct licenses, Both
                      the Air Force and Navy have a master material license from NRC. Once
                      issued, these licenses do not have to be renewed, and they allow these
                      two organizations to issue permits to, conduct inspections of, and take
                      enforcement actions against, individual users of radioactive material.
                      The Army does not have a master material license. Instead, each organi-
                      zation must receive a license from NRC that must be renewed every 5
                      years. To carry out their licensed activities and safely dispose of waste,

                      ‘Low-level waste is waste that is not classified as uranium mill tailings, high-level waste, or spent fuel
                      and consists of discarded tools, rags, machinery, paper, sheet metal, glass, and protective clothing.
                      About 3 percent of such waste can remain hazardous for 300 to 500 years or more.

                      2NRC’s regulations are set forth in 10CFR parts 19 through 21,30 through 35,40,50, 70 and 71.



                      Page 8                                 GAO/RCED-90-96 Military Needs a Waste Disposal Program
            Chapter 1
            Introduction




            the three services have established their own organizations and
            procedures.


Arm4        The Army Material Command, Alexandria, Virginia, is responsible for
       ,    overseeing the activities conducted by 61 byproduct licensees; the Office
            of the Surgeon General oversees an additional 26 medical use licensees,
            Both of these offices review new license applications and amendments
            before they are sent to NRC and perform annual inspections of some
            organizations to verify compliance with the license and related require-
            ments. The Army Material Command also oversees the centralized radio-
            active waste disposal program.

             In 1977, the Army transferred its low-level waste disposal program to
            the Army Armament, Munitions and Chemical Command (AMCCOM) in
             Rock Island, Illinois. AMCCOM oversees the safe packaging, transporting,
            and handling of waste from Army bases across the country and manages
            the contracts for its disposal in commercially operated facilities in Barn-
            well, South Carolina; Richland, Washington; and Beatty, Nevada. Under
            the program, the low-level waste generator can (1) ship the waste
            directly to the burial site, (2) request pick-up by a contractor, or (3) ship
            the waste to a contractor-operated facility in South Carolina that consol-
            idates small quantities from numerous generators and ships it directly to
            the disposal site. Since the mid-1980s, the Army has had memoranda of
            understanding with several federal agencies, such as the General Ser-
            vices Administration (GSA), Environmental Protection Agency (EPA), and
            the Uniformed Services University of Health Sciences, to dispose of
            their low-level radioactive waste.


Air Force   To carry out the responsibilities set forth by its license, the Air Force
            established a Radioisotope Committee located at Bolling Air Force Base,
            Washington, D.C. The committee delegated management responsibility
            for day-to-day activities to Brooks Air Force Base, San Antonio, Texas.
            The committee reviews individual organizations’ applications to possess
            and use radioactive material and issues permits to applicants that meet
            NRC and Air Force requirements. In addition, the Inspection and Safety
            Center at Norton Air Force Base, California, has been given inspection
            responsibility for the 192 permit holders.

            In May 1985, the Air Force began to participate in the Army’s program
            and shares 50 percent of some costs. The San Antonio Air Logistics
            Center, Texas, serves as the point of contact with the Army.


            Page 9                      GAO/RCED-96-96 Military Needs a Waste Disposal Program
                        Chapter 1
                        Introduction




Navy                    The Navy also established an oversight committee-Radiation       Safety
                        Committee, Washington, DC. The committee manages the license,
                        reviews applications, issues permits to eligible users, and ensures that
                        inspections of permit holders are conducted. The Navy has two groups
                        that assist the committee-the     Environmental Health Center, Norfolk,
                        Virginia, which oversees 39 medical permit holders; and the Radiological
                        Affairs Support Office, Yorktown, Virginia, which oversees 161 indus-
                        trial permit holders. Both groups perform the same functions for the
                        permittees within their jurisdiction. For example, they review applica-
                        tions; recommend those that should be issued a permit; and conduct
                        inspections of, and take enforcement actions against, the permit holders,

                        Although the Radiological Affairs Support Office also oversees the per-
                        mittees’ radioactive waste disposal activities, the Naval Supply Systems
                        Command establishes the policies for these activities. The command del-
                        egates day-to-day oversight to its Norfolk, Virginia, and Oakland, Cali-
                        fornia, centers. The Oakland center has contracted with a private
                        company to transport and dispose of waste. With the exception of the
                        nuclear propulsion program, which manages its own waste disposal
                        activities, and three Navy permit holders-National     Naval Medical
                        Center, Bethesda, Maryland; Naval Medical Research Institute,
                        Bethesda, Maryland; and Naval Surface Weapons Center, Dahlgren, Vir-
                        ginia-that   participate in the Army’s program, most Navy installations
                        store, rather than dispose of, their waste.


                        In 1980, the Congress passed the Low-Level Radioactive Waste Policy
Legislation Could       Act to encourage states either separately or in conjunction with other
Have an Impact on the   states (compacts) to develop new disposal sites. The underlying premise
Military’s Program      of the act was that all states should be responsible for disposing of low-
                        level radioactive waste generated within their borders. For states with
                        active disposal sites, the act stipulated that they could refuse to accept
                        waste generated outside the state and/or compact region after January
                        1, 1986.

                        Since new waste sites could not be developed by 1986, the Congress in
                        1985 passed the Low-Level Radioactive Waste Policy Amendments Act,
                        which extended the exclusion date from January 1986 to January 1,
                        1993. The amendments also established (1) milestones-the compacts
                        and states were required to submit applications to NRC or an agreement




                        Page 10                    GAO/RCED-90-96 Military Needs a Waste Disposal Program
        i

                        Chapter 1
                        Introduction




    I                   state” by January 1990 or within the 2-year grace period-and (2)
    I                   surcharges and penalties to, in part, encourage new site development
    I                   and volume reduction.

                        Between July 1986 and December 1992, the surcharges range from $10
                        to $40 per cubic foot of waste disposed. During calendar year 1992, pen-
                        alties could triple the surcharges to a maximum of $120 per cubic foot of
                        waste disposed if the compacts and states have not submitted site appli-
                        cations. After that time and until January 1996, a generator granted an
                        NRC exemption to dispose of waste outside the compact or state would
                        pay the $120 per cubic foot surcharge. The act required the three states
                        with existing sites to collect the surcharges and later provide 25 percent
                        to DOE for distribution to the compact regions or states for new site
                        development; the three states would retain the remaining 75 percent. If
                        new sites are not available by January 1993, the funds (25 percent)
                        would be repaid monthly to generators rather than the compacts or
                        states.

                        The amendments also established the three existing commercial low-
                        level waste sites as compact regions until December 31, 1992, and
                        required NRC to establish criteria for waste whose radiological impacts
                        would be so low that it could be considered “below regulatory concern”
                        and exempt from the act. NRC had expected to issue the criteria by
                        November 1989; NRC now expects to do so during the spring of 1990.

                        In addition, the act identified 7 compact regions involving 39 states but
                        also allowed the states to change compact regions, form new ones, or
                        dispose of waste on their own. In the interim, a number of states have
                        exercised the various options. As of December 1989,43 states had
                        formed 9 compact regions; the remaining 7 states (including Puerto Rico
                        and the District of Columbia) were considering options to comply with
                        the act. (Fig. 3.1 shows the status of the compact regions. App. I pro-
                        vides additional information on some of the act’s provisions.)


                        Sometime in the 1970s a nonmilitary NRC licensee transferred amer-
Wtiight-Patterson Air   icium-a highly toxic, potentially hazardous carcinogen-low-level
Fake Base Incident      waste to Wright-Patterson Air Force Base, Ohio. In October 1986, Air
                        Force personnel accidentally opened a drum containing the waste,
                        spilled the material, and contaminated the building in which it was
            *
                        “NRC has formal agreements with 29 states to regulate certain licensees under programs comparable
                        to NRC’s



                        Page 11                             GAO/RCED-90-96 Military Needs a Waste Disposal Program
                        Chapter 1
                        Introduction




                        stored. During the cleanup activities, several individuals inhaled a small
                        quantity of the radioactive material. According to NRC documents, Air
                        Force personnel initially believed that they did not have to report this
                        release. Furthermore, NRC staff could not initially agree whether the Air
                        Force should have reported the spill to NRC. Later, NRC determined that a
                        violation had occurred, and in June 1988 issued a notice of violation and
                        proposed a $102,500 civil penalty against the Air Force. Ultimately, the
                        Air Force spent about $1 million to clean up the contamination and to
                        dismantle the building and in August 1989 paid the civil penalty that
                        NRC imposed.

   I
                        As a result of the Wright-Patterson incident, the Chairman, Senate Com-
Objectives, Scope,and   mittee on Governmental Affairs, asked us to examine NRC'S oversight of
Methodology             DOD'S use of radioactive materials and determine whether the Wright-
                        Patterson incident indicated lax NRC oversight of the military’s handling
                        and storage of radioactive materials. On the basis of subsequent discus-
                        sions with the Chairman’s staff, we agreed to conduct a detailed exami-
                        nation and cost comparison of the Army’s, Navy’s (except the nuclear
                        propulsion program), and Air Force’s low-level radioactive waste dis-
                        posal practices rather than examine NRC'S oversight of DOD'S activities.

                        In conducting this work, we reviewed the Atomic Energy Act, Low-Level
                        Radioactive Waste Policy Act, and NRC regulations related to (1)
                        byproduct material licensing, (2) standards for protection against radia-
                        tion and disposal alternatives for low-level waste, and (3) commercial
                        low-level disposal site licensing. We also interviewed NRC staff in the
                        Offices of Nuclear Materials Safety and Safeguards and Nuclear Regula-
                        tory Research and reviewed NRC'S internal policies, such as Regulatory
                        Guide 10.8 (preparing medical use applications) and Regulatory Guide
                        7.10 (quality assurance programs for radioactive material packaging),
                        and analyses of the impact of the proposed below regulatory concern
                        criteria and the public comments received on them.

                        We also met with a DOE official in the commercial low-level radioactive
                        waste program and reviewed documents, such as Low-Level Radioactive
                        Waste Volume Reduction and Stabilization Technologies Resource Man-
                        ual (nox/LLW-76T, Dec. 1988), which discussed waste volume reduction
                        and alternative disposal methods. We also reviewed two DOE reports,
                        Recommendations for Management of Greater-Than-Class-C Low-Level
                        Radioactive Waste (DOE/NE-0077. Feb. 1987) and 1988 Annual Report
                        on Low-LevelRadioactive Waste hlanagement Progress (wE/NE-O-698,
                        Oct. 1989), which were required by the Low-Level Radioactive Waste


                        Page 12                    GAO/RCED-90-96 Military Needs a Waste Disposal Program
Chapter 1
Introduction




Policy Amendments Act. In addition, we obtained a November 1989
Office of Technology Assessment (OTA) report, Partnerships Under Pres-
sure, on the problems that the compacts and states have encountered.
Furthermore, we met with the Electric Power Research Institute-a
group funded by electric utilities-to  obtain the industry’s views on
NRC'S below regulatory concern criteria and reviewed a March 1989
report, Below Regulatory Concern Owners Group: Cost-Benefit Analysis
of BRC Waste Disposal.


Within the Departments of the Army, Air Force, and Navy, we met with
numerous headquarters and field installation officials (app. II lists the
locations that we visited) to discuss their policies, procedures, and prac-
tices for handling and disposing of low-level waste. We obtained a multi-
plicity of documents to support the oral evidence provided. Some of the
more significant military locations that we visited are discussed below.

To develop an understanding of the Army’s centralized waste program,
we met with the Chief-of-Staff and officials from the Procurement
Directorate, Safety Office, and Transportation and Traffic Management
Directorate at AMCCOM, Rock Island, Illinois. We reviewed applicable poli-
cies, such as the Ionizing Radiation Protection (Licensing, Control,
Transportation, Disposal, and Radiation Safety) Regulation, and other
information concerning the duties and responsibilities of the various
offices involved in the low-level waste program. In addition, we
reviewed the contract between Chem-Nuclear Systems, Inc., and the
Army and delivery orders issued between November 1987 and March
1989. The delivery orders set out the specific activities the contractor
would perform and estimated costs for the services.

We also visited several of the Army’s larger waste generators, such as
Chemical Research, Development, and Engineering Center, Edgewood,
Maryland; Walter Reed Army Medical Center, Washington, D.C.; and
Aberdeen Proving Grounds, Maryland. Although Aberdeen holds an NRC
source rather than byproduct license, we decided to visit this site
because we could observe the packaging, labeling, and loading of waste
for shipment to the Barnwell site. While at Aberdeen, we also toured the
Combat Systems Test Activity and Ballistic Research Laboratory-both
test armor-piercing shells containing depleted uranium.

To obtain additional information concerning the Army’s program, we
met with officials from Chem-Nuclear and U.S. Ecology-the companies
that operate the three licensed low-level waste disposal sites. At Chem-


Page 13                     GAO/RCED-90-96 Militmy Needs a Waste Disposal Program
                  Chapter 1
                  Introduction




                  Nuclear, we reviewed shipping records and waste processing and consol-
                  idation procedures. We also toured the Barnwell, South Carolina, dis-
                  posal site and DOD's consolidation facility, which is adjacent to the site.
                  At U.S. Ecology, we obtained information about its waste processing,
                  consolidation, and disposal capabilities; toured its waste packaging and
                  storage facility; and examined its contract with Oakland Naval Supply
                  Center, California.

                  In addition, to assess the Air Force’s low-level waste program, we met
                  with Radioactive Waste Program Office officials at the San Antonio Air
                  Logistics Center, Texas. We reviewed Air Force regulations on control-
                  ling radioactive material and technical manuals on handling such mate-
                  rial and its disposal. Furthermore, we obtained information about waste
                  shipments and burials made between August 1987 and April 1989,
                  including shipment control numbers, items being shipped, the requester,
                  and shipping and burial dates.

                  At the Navy, we met with officials from the Radiation Safety Commit-
                  tee, Environmental Health Center, and Radiological Affairs Support
                  Office to determine their duties and responsibilities concerning the han-
                  dling and disposal of low-level waste. We obtained regulations, policies,
                  procedures, and the results of surveys conducted in February and April
                  1988 to determine the type and amount of radioactive waste being
                  stored at various Navy bases.


Cost Comparison   To compare waste disposal practices and attendant costs for the three
                  military services, we obtained information on the number of waste ship-
                  ments between November 1984 and September 1989, type and volume
                  of waste shipped, and consolidation and disposal costs. We also obtained
                  data on the funds paid to Chem-Nuclear, calendar year 1987 and 1988
                  adjustments for the company’s charges to all federal agencies in the
                  Army’s program, and costs to construct a new consolidation and com-
                  pactor facility as well as estimated cost savings from using the new
                  facility.

                  On the basis of this information, we have provided some cost data. We
                  could not, however, conduct the cost comparison requested because con-
                  solidated data do not exist on the amount of waste generated, stored, or
                  disposed of by the three services. In addition, individual generators in
                  the three services use different methods to process the waste prior to
                  shipment and different shipping schedules. For example, some genera-
                  tors reduce the volume of waste prior to packaging while others do not.


                  Page 14                    GAO/RCED-90-96 Military Needs a Waste Disposal Program
     i

                    Chapter 1
                    Introduction




                    Also, some generators store waste until they have a full truck load while
                    others ship waste on a quarterly basis, regardless of the amount. Fur-
                    thermore, the number of waste shipments that occurred during the last
                    several years is most likely not representative of historical or future
                    waste disposal activities. For example, since the Wright-Patterson inci-
                    dent, the Air Force has made a concerted effort to clean up its installa-
                    tions. For these reasons, this report presents a limited perspective on the
                    three services current and projected waste disposal costs.


Intetnal Controls   Using information provided by Army, Air Force, and Navy officials, we
Exa ined            conducted a limited assessment of these agencies’ internal controls. For
    P               example, we examined the Army’s procedures to ensure that Chem-
                    Nuclear provided the services specified in the delivery orders and that
                    the contractor’s request for payments was reviewed and verified prior
                    to payment. We also examined the Army’s procedures to review the Air
                    Force’s and three Navy facilities’ requests for contractor’s services,
                    issue delivery orders for them, and ensure that Chem-Nuclear provided
                    the services specified in the delivery orders.

                    We also examined the reporting and accounting systems used by (1) the
                    Army to monitor the funds provided by the Air Force and obtain pay-
                    ment from the Navy and other government agencies under their memo-
                    randa of understanding and (2) Chem-Nuclear to assess service charges
                    to its various governmental customers. At Chem-Nuclear, we also con-
                    ducted a limited examination of time and attendance records, travel
                    vouchers, and equipment purchases to verify that these were valid
                    charges and the Air Force was appropriately assessed its 50 percent of
                    agreed-upon costs.


                    We discussed the facts presented in this report with NRC, Army, Air
                    Force, Navy, and Chem-Nuclear officials. They generally agreed with
                    the information presented but offered some clarifications that were
                    incorporated where appropriate. As requested, we did not ask these
                    groups to review and comment officially on this report. Our work was
                    conducted between May 1988 and November 1989 in accordance with
                    generally accepted government auditing standards.




                    Page 15                    GAO/RCED-99-96 Military Needs a Waste Disposal Program
  M$itary Can Improve Its Low-Level Radioactive
’ Wkte Disposal Practices

                        To improve its management of low-level radioactive waste and effec-
                        tively address future uncertainties, the military needs complete infor-
                        mation on the volumes and types of waste generated and disposed of.
                        None of the three services knows the full extent of their low-level waste
                        disposal problems. In 1988, the Navy conducted two surveys to develop
                        this information, but the results were not complete. The Army expects
                        to survey its installations in fiscal year 1990 to develop an inventory of
                        waste but continues to identify material, such as 4,000 tons of contami-
                        nated steel, requiring disposal. Finally, although 46 Air Force bases bur-
                        ied waste on-site in the 1950s and limited data exist on the number of
                        sites and the types and amounts of waste in them, the Air Force does not
                        plan to survey its bases.

                        The Army has had a low-level waste disposal program for many years,
                        but the Navy does not have a program. Since May 1985, the Air Force
                        has participated in the Army’s program. The program has helped ensure
                        the timely disposal of waste, but we found numerous management weak-
                        nesses that limited its effectiveness and that the Army and Air Force
                        have, on occasion, been temporarily banned from commercial sites for
                        failing to comply with federal and state waste packaging and transpor-
                        tation regulations.


                        The three services have not acted aggressively to identify the volumes
 Full Extent of the     or types of low-level waste generated or disposed of by their various
 Military’s Low-Level   installations, As of December 1989, only the Navy had made a concerted
                        effort to obtain this information; however, the data are not complete.
 Radioactive Waste      During fiscal year 1990, the Army plans to conduct a survey to obtain
 Problems Is Not        an inventory of low-level waste at its bases. The Air Force surveyed 23
 Known                  bases in 1987 and has no plans to conduct additional surveys.


 Navy                   As a result of the Wright-Patterson incident, in February and April 1988
                        the Radiological Affairs Support Office sent questionnaires to Navy
                        installations to determine the type and amount of waste being stored at
                        its bases. The Navy not only wanted to identify waste volumes and loca-
                        tions but also wanted to use the information to develop a timely, cost-
                        effective waste disposal program. Table 2.1 shows the number of ques-
                        tionnaires sent and replies received.




                        Page 16                    GAO/RCED-90-96 Military Needs a Waste Disposal Program
                                   Chapter 2
                                   Military Can Improve Its Low-Level
                                   Radioactive Waste Disposal Practices




Table p.1: Results of the Navy’8
Radlo#ztive Warte Surveys                                                                           Number of
      I
                                                                                                questionnaires Number of replies
                                   Permit holders                                                             135                       118
                                   Nonpermit holdersa                                                         288                        94
                                   %ome items, such as smoke detectors and exit signs, contain radioactive material. For those items,
                                   neither NRC nor the Navy requires the users to obtain a license or permit, respectively.


                                   On the basis of those who responded to the survey, the Navy estimates
                                   that about 9,000 cubic feet of waste is being stored at its installations-
                                   permit holders reported having about 8,000 cubic feet and nonpermit
                                   holders, about 1,000. However, Navy officials do not believe that the
                                   survey results show the full extent of radioactive waste generated or
                                   stored. They noted that the

                                   waste volume for permit holders is only a rough approximation, with a
                                   variance of plus or minus 50 percent;
                                   installations estimated waste volumes differently;
                                   nonpermit holders’ volumes are rough approximations because some
                                   installations may not know that certain devices contain radioactive
                                   material; and
                                   Navy knows that at least 25 percent of the nonpermit holders who did
                                   not respond to the survey store radioactive waste.

                                   For these reasons, the Navy does not precisely know the amount and
                                   types of waste stored or disposed of by its various installations.


Air Force                          Since May 1985, the Air Force has participated in the Army’s program
                                   and has disposed of about 12,000 cubic feet of waste through it. Some of
                                   this waste resulted from the cleanup of 23 bases surveyed in 1987. The
                                   Air Force has no plans to conduct additional surveys but relies on its
                                   inspection program to ensure that its bases properly manage and dis-
                                   pose of low-level waste. Air Force officials estimate that about 7,000
                                   cubic feet will be disposed of in fiscal year 1990.

                                   Further, during fiscal year 1990, the Air Force expects to excavate some
                                   low-level waste that had been buried on 46 bases around the country in
                                   the 1960s.’ In the late 195Os, headquarters directed the Air Force to stop
                                   this practice and use a contractor to dispose of waste. However, the Air


                                   ‘Until January 1981, NRC allowed licensees to bury waste on-site and required the licensee to main-
                                   tain the burial records.



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       Military Can Improve Its Low-Level
       Radioactive Waste Disposal Practices




       Force did not provide its bases with instructions for ensuring the integ-
       rity of the burial sites or maintaining necessary disposal records. In Feb-
       ruary 19’71, after realizing that it did not have disposal records, the
       Radioisotope Committee directed all major commands to report on their
       buried waste sites. The committee found that the Air Force did not have
       complete information on the number of sites or the types and amounts
       of material in them. Subsequently, in 1974 and 1988, the Air Force
       issued policies concerning the maintenance of the sites. However, until
       the Air Force begins to excavate the waste, officials cannot estimate the
       volumes that may need to be disposed of.

       Such projects and other efforts, such as decontamination, are very
       costly. For example, Norton Air Force Base, California,2 expects to
       spend (1) over $200,000 to excavate and dispose of about 360 cubic feet
       of waste and (2) over $180,000 to decontaminate a building and dispose
       of about 460 cubic feet of waste. The Air Force also plans to spend (1)
       about $116,000 to excavate a site and dispose of about 185 cubic feet of
       waste and (2) over $600,000 to develop a plan to decommission a reac-
       tor at Wright-Patterson. The Air Force’s contractor (Chem-Nuclear) esti-
       mates that between $20 million and $40 million will be needed to
       decommission the reactor and dispose of over 100,000 cubic feet of
       waste.


Army   The Army continues to identify additional material that may have to be
       disposed of as low-level waste. For example, the Army has 4,000 tons of
       contaminated steel at Aberdeen Proving Grounds; and Aberdeen and
       three other bases-Jefferson, Lake City, and Yuma-have contami-
       nated soil as a result of testing ammunition containing depleted ura-
       nium. According to Army officials, NRC requires the four bases to
       monitor soil contamination and take corrective actions before exceeding
       contamination limits specified in the licenses. These officials also said
       that they do not expect to assess the extent of, and need to clean up, soil
       contamination at the four locations until a decision is made to close a
       base. Until such assessments are conducted, they could not estimate the
       volume of waste that may need to be disposed of. Since a test site can
       cover as much as 10 acres, the amount of contaminated soil could be
       significant. In fiscal year 1990, the Army plans to survey its installa-
       tions to develop an inventory of waste.

       “Norton Air Force Base and Jefferson Proving Grounds (discussed later) are scheduled to be closed in
       the early 1990s. Such closures could increase the volume of waste to be disposed of. According to
       Army, Air Force, and Navy officials, cleaning up soil contaminated with depleted uranium creates
       large waste volumes that pose a difficult and costly disposal problem.



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                                      Military Can Improve Its Low-Level
                                      Ihlioactive Waste Disposal Practices




                                      During fiscal year 1990, officials estimate that the Army and its pro-
                                      gram participants will dispose of about 35,000 cubic feet of waste. Table
                                      2.2 shows the volumes and costs of waste disposed of by the Army and
                                      its program participants between fiscal years 1985 and 1989.
               Disposal Costs of
y and Its Program Participants,                                                                                       Volume
                                                                                                                   disposed
                                                                                                                    (in c$;           Disposal
                                     Fiscal year                                                                                          cost”
                                     1985
                                     -_I__                                                                           26,331.3          $656,703
                                     1986                                                                            22,687.3           626,623
                                     1987                                                                            44,896.7         1,495,958
                                     1988                                                                            2OJ354.7           736,508
                                     1989                                                                            63,043.3         2,324,406
                                     aBasic disposal cost, excluding packaging, transportation,   labor, materials, taxes, and other charges.


                                     As can be seen from table 2.2, waste disposal volumes vary. Some of the
                                     variance is attributable to unanticipated cleanup activities, such as the
                                     Wright-Patterson incident that generated about 3,200 cubic feet of
                                     waste between November 1986 and December 1987, as well as planned
                                     decontamination projects. For example:

                                   . Until 1976, the Lake City Army Ammunition Plant near Independence,
                                     Missouri, assembled, produced, and tested ammunition containing
                                     depleted uranium. To terminate its NRC license, the Army had to decon-
                                     taminate the buildings. The work was conducted between August 1986
                                     and February 1987 and resulted in the disposal of about 30,200 cubic
                                     feet of waste during fiscal year 1987.
                                   . In 1967, the GSA acquired a facility in Watertown, Massachusetts, which
                                     had been used by the Atomic Energy Commission to package and store
                                     waste and burn depleted uranium scrap, Surveys conducted by DOE in
                                     1983 and Chem-Nuclear in 1988 found contamination that needed to be
                                     cleaned up. Chem-Nuclear decontaminated the site and disposed of
                                     about 4,030 cubic feet of contaminated soil and concrete by November
                                     1988. In June 1989, soil samples identified underground oil contami-
                                     nated with both hazardous and radioactive material. As of January
                                     1990, GSA had not resolved this problem.




                                     Page 19                                GAO/RCED-9086 Military Needs a Waste Diiposal Program
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                        Military Can Improve Its Low-Level
                        Radioactive Waste Disposal Practices




                        Since 1977, AMCCOM has been responsible for overseeing the Army’s
Ar$y’s Program Has      waste disposal program. Under the Army’s regulations for licensing,
Sev/eralAdvantages      controlling, transporting, and disposing of low-level waste, AMCCOM man-
                        ages the contract with Chem-Nuclear, which requires the company to
                        receive, store, open, inspect, consolidate, repack, and solidify waste con-
                        sistent with federal and state regulations.

                        The process begins when one of the Army’s 460 waste generators sub-
                        mits a disposal request to AMCCOM, which reviews the request, assigns a
                        control number, and processes the request. AMCCOM will then contact the
                        generator and specify the packaging, labeling, and shipping require-
                        ments that apply or provide on-site assistance if requested. AMCCOM then
                        prepares a delivery order that authorizes the contractor to dispose of
                        the waste. The delivery order identifies the location of the waste and
                        scope, timing, and cost of the work to be performed.

                       Under the current contract, Chem-Nuclear also consolidates small quan-
                       tities of waste from numerous generators before disposal. According to
                       AMCCOM officials, using the consolidation facility has reduced personnel
                       travel costs and charges to dispose of small quantities of waste. In addi-
                       tion, shipping container utilization has increased because the generators
                       can send the waste to the consolidation facility in a strong tight
                       container, such as a cardboard box, rather than heavy wooden or metal
                       boxes required by the state for disposal. The following three examples
                       illustrate the savings that have been realized from using the consolida-
                       tion facility:

                     9 In July 1989, Eglin Air Force Base, Florida, shipped about 7,530 cubic
                       feet of waste for disposal. Through consolidation, the volume disposed
                       of was about 1,345 cubic feet-saving about $228,000.
                     . In July 1989, three Air Force bases-Tyndall,    Florida; McClellan, Cali-
                       fornia; and Tinker, Oklahoma-shipped      1,851 cubic feet for burial.
                       Through consolidation, the volume disposed of was 388 cubic feet-sav-
                       ing over $80,000.
                     . In September 1989, the Anniston Army Depot, Alabama, shipped about
                       12,430 cubic feet of waste for disposal. Through consolidation, the vol-
                       ume disposed of was 3,847 cubic feet-saving about $316,455.

                       Furthermore, the Army is building a new consolidation facility that will
                       also include a waste compactor. The Army expects the new facility to be
                       in operation by June 1990 and estimates that the program can save over
                       $600,000 during the first year and over $3 million during the first 5
                       years the facility operates. To ensure the effective utilization of the new


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facility, AMCCOM has asked all its program participants to separate mate-
rial that can be compacted from the rest of their waste and store it until
the last half of fiscal year 1990.

In addition to the benefits realized from consolidation and expected to
be realized from the new facility, South Carolina has granted the Army
and its program participants some waste packaging and disposal vari-
ances that have been cost beneficial to the program. For example, when
the Army recently wanted to dispose of two tanks, the state allowed the
tanks to be buried without an exterior container, such as a wooden or
metal box. Since the contamination was contained inside the tanks, the
state authorized direct burial. By receiving the variance, the Army real-
ized savings of about $119,266 for labor, material, and disposal costs.

Also, the state has granted the Army a variance from its prohibition
against disposing of any devices (instruments, gauges, dials, and other
items) containing tritium gas3 Generally, the state does not allow the
disposal of such items at Barnwell. Because the Army’s program partici-
pants use tritium-containing devices in a number of ways (such as gun
sights, exit signs, and runway lights), the Army asked for a variance to
this regulation. In granting the variance, the state required Chem-
Nuclear to seal the devices in concrete or a high-integrity container,
such as polyethylene, to prevent damage to the devices. This variance
has resulted in substantial cost savings to the Army and its program
participants.

For example, between April 1986 and August 1987, Chem-Nuclear
repackaged about 86 shipments containing tritium devices and estimates
that the Army saved about $797,000 in labor, supplies, materials, trans-
portation, and disposal costs. Without the variance, AMCCOM estimates
that disposal costs would have been over $1.3 million because 62 of the
shipments would have had to be sent to Richland, Washington, for
disposal.

As a second example, in September 1989 the Navy wanted to dispose of
five exit signs containing tritium in Nevada. U.S. Ecology estimated that
the cost would be about $4,000 to dispose of the signs. Because of the
cost, the Navy has decided to store the waste. Depending on the number
of these items at various Navy installations, the disposal costs could be
significant. For example, in response to the Navy’s February 1988 sur-
vey, 1 installation reported having 18 such signs. To dispose of the signs

:‘Tritium is a radioactive gas or oxide material with a half-life of about 12.3 years.



Page 21                                GAO/RCED-9686 Military Needs a Waste Disposal Program
                             Chapter 2
                             Military Can Improve Its Low-Level
                             Radioactive Waste Disposal Practices




                             in Nevada, the cost would be about $14,400. According to Army offi-
                             cials, the cost would be about $1,800 under their program because of the
                             variance granted by the state.


r Agencies Participate       Through memoranda of understanding, the Army has provided low-
e Army’s Program             level waste disposal services to such federal agencies as GSA, EPA, Uni-
                             formed Services University of Health Sciences, the Air Force, and three
                             Navy installations. Depending on the services required, AMCCOM will pro-
                             vide written instructions for the transportation of the waste or direct
                             Chem-Nuclear to pick up the material.

                             The Air Force began to participate in the Army’s program in May 1985.
                             The San Antonio Air Logistics Center serves as the point of contact with
                             the Army and functions much like AMCCOM-it receives disposal
                             requests, assigns control numbers, approves requests, and/or provides
                             instructions concerning shipping requirements. In addition, the com-
                             mand submits all requests for contractor assistance to AMCCOM, which
                             prepares the delivery orders. Also, the Air Logistics Command has
                             established two computer systems: one tracks all waste disposal
                             requests; the other lists the items disposed of.

                             Three Navy activities-National    Naval Medical Center, Bethesda, Mary-
                             land; Naval Medical Research Institute, Bethesda, Maryland; and Naval
                             Surface Weapons Center, Dahlgren, Virginia-participate     in the Army’s
                             program. Since February 1985, these organizations have disposed of
                             about 8,000 cubic feet of waste under the program. Almost all other
                             Navy installations store their waste. For example, in 1988,34 installa-
                             tions reported that they were storing almost 7,900 cubic feet of waste.

                             However, officials within the Navy’s Radiological Affairs Support Office
                             believe that the rest of the Navy’s facilities should be part of the Army’s
                             program. At the request of the Naval Sea Systems Command, the office
                             prepared a position paper on the advantages and disadvantages of a
                             consolidated, tri-service waste program. The September 1988 paper
                             noted that:

                         l Navy installations traditionally have stored their waste until the quanti-
                           ties justified a large shipment. Although some economic benefits result
                           from this practice, it has led to a potentially dangerous situation.
                         . During fiscal year 1987, two waste shipments totaling about 250 cubic
                           feet took over 1 year from the receipt of the request by the Naval Sup-
                           ply Systems Command to disposal.


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                              Military Can Improve Its Low-Level
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                          l   A limited test of the effectiveness of the Army’s program by two Navy
                              installations showed that disposal costs were at least $4,500 less than
                              using the Navy’s system and took less than 2 weeks from initiation of
                              the request to disposal.

                              These officials believe the position paper strongly supported the need
                              for the Navy to change its waste disposal practices. In December 1989,
                              the Navy directed the Radiological Affairs Support Office to develop an
                              agreement for participation in the Army’s program. Navy officials
                              expect to finalize the agreement and obtain funding during fiscal year
                              1990.

                              Although the three services are moving toward a consolidated waste dis-
                              posal program, officials from each said they do not believe that DOD
                              oversight is needed. Rather, according to these officials, they need
                              assured and sufficient resources to effectively staff the activities that
                              should be conducted. They also noted that having the three services
                              work together is a better approach than having M)D oversee their
                              efforts, and they believe that each base should retain technical control
                              over its activities. They recognized, however, that this approach does
                              not ensure that sufficient resources would be available.


                              Although the Army has made a concerted effort to have a safe and
Ntierous                      effective low-level waste disposal program, we found that (1) both the
Management                    Army and Air Force have been denied access to commercial waste dis-
WeaknessesExisted in          posal sites and (2) a number of management and internal control weak-
                              nesses raise questions about the program’s effectiveness.
the Army’s Program

Access Denied to Burial       In the past, both the Army and Air Force have been denied access to
Sit&                          commercial waste disposal sites, For example, between September 1980
                              and July 1982, the states of Washington and Nevada banned the Army
                              on three separate occasions from disposing of waste for between 1 and 2
                              months because samples taken by state inspectors showed that the
                              waste did not meet federal and state packaging requirements. In other
                              cases, Chem-Nuclear identified waste shipments that violated federal
                              and state requirements. For example, in July 1986 Chem-Nuclear found
                              significant deficiencies in the packaging of waste shipped from Fort
                              Belvoir, Virginia, and in September 1987 from the New York Army
                              National Guard, Albany, New York. AMCCOM stopped all shipments from
                              these installations until corrective actions were taken.


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                        Furthermore, in May 1985 the state of South Carolina found that waste
                        received from the McClellan Air Force Base, Sacramento, California, did
                        not meet federal and state requirements. As a result, the state told the
                        Air Force that it could no longer dispose of any waste at the Barnwell
                        facility. Following a meeting between Chem-Nuclear, Air Force, and
                        South Carolina Department of Health and Environmental Control offi-
                        cials to discuss these concerns, the state reversed its position.

                        However, during fiscal year 1987, Chem-Nuclear found that three Air
                        Force shipments violated Department of Transportation, NRC, and state
                        regulations. Chem-Nuclear reported its findings to the state, which
                        required the company to repackage the material and return two ship-
                        ments to the point of origin. In response to the state’s action, the Air
                        Force Radioactive Waste Program Office barred the three installations
                        from further shipments, pending verification and approval of the pack-
                        aging process to be followed.

                        To minimize the potential for similar violations in the future, the Air
                        Force began to participate in the Army’s training course on the packag-
                        ing, labeling, and shipping requirements with which it must comply.
                        Also, the Air Force revised its waste disposal policies to more specifi-
                        cally define base-level responsibilities and to ensure that military per-
                        sonnel transferring into these activities are aware of the applicable
                        requirements. Furthermore, in 1989, Army officials suggested that the
                        Air Force institute a procedure to certify all waste packages before ship-
                        ping them to a disposal site.


Internal Con.trol       Generally, the Army’s procedures contain requirements to ensure that
Weaknesses              its installations and contractors carry out their programs in an efficient
                        and effective manner. These internal controls are also intended to
                        ensure that the Army obtains and maintains reliable information to
                        enable it to evaluate the contractors’ activities and identify problem
                        areas requiring its attention. We found, however, that numerous internal
                        control weaknesses existed with the waste disposal program.

                        For example, AMCCOM had no implementing procedures to fulfill its
                        duties and responsibilities and no central office to oversee and monitor
                        the activities conducted. In addition, neither AMCCOM nor Chem-Nuclear
                        followed the procedures set out in the contract. For example, the

                    l   contractor performed work before delivery orders were executed;



                        Page 24                           GAO/lZCED-90-96 Military Needs a Waste Disposal Program
                                Chapter 2
                                Mllltary CM Improve Its Low-Level
                                Radioactive Waste Disposal Prtwtlces




                            l delivery orders did not contain required information, such as time
                              frames to package, transport, and dispose of the waste;
                            . contractor performed work that was not specified in the delivery order;
                            . contractor and AMCCOM did not have a system to ensure that the pro-
                              gram’s participants were appropriately billed for services provided; and
                            . the procurement office within AhHXOM not only wrote the delivery
                              orders but also negotiated the cost for services and authorized the pay-
                              ments to be made.

                                In addition, we found instances in which waste from several installa-
                                tions were shipped together, making it difficult to trace the material dis-
                                posed of and to account for the funds paid. For example, AMCCOM
                                received disposal requests from three installations for solid waste and
                                medical and research vials, but the delivery orders only specified that
                                the vials would be disposed of. According to Chem-Nuclear officials,
                                they disposed of both the vials and solid waste. Although the contrac-
                                tor’s actions resulted in cost savings to the government, they were
                                outside the controls established because AMCCOM did not authorize the
                                disposal of the solid waste, and the Army’s records did not show that
                                the waste had been disposed of.


Army’s Actions to Address       As a result of our review, in May 1989 the Army began to change some
Program Weaknesses              aspects of its program. For example, AMCCOM established the Radioactive
                                Waste Disposal Division within the safety office to manage the program.
                                Many tasks previously performed by the procurement office and con-
                                tractor will be assumed by the new division. AMCCOM also required the
                                safety office to form a committee to oversee the activities of the new
                                division. This committee involves numerous offices and should be an
                                effective mechanism to oversee the program.

                                Following the reorganization, the Radioactive Waste Disposal Division
                                took a number of actions to improve the program and address many of
                                the weaknesses that we identified. For example, the division rather than
                                the contractor will develop a work schedule for each fiscal year. In addi-
                                tion, the division will

                        . interact with and control funds from other federal agencies;
                        . evaluate all disposal requests (both the Army’s and the other program
                          participants’), approve the actions that will be taken, and control trans-
                          action documents; and




                                Page 25                           GAO/RCED-99-96 Military Needs a Waste Disposal Program
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  Mllltary Can Improve Ite Low-Level
  Radioactive Waste Disposal Practices




. establish a separate budget account to better manage program funds
  and a process to certify the actual work performed before payments are
  made.

  According to Army Material Command officials, these and other actions
  taken by AMCCOM have strengthened the program’s internal controls. In
  addition, Chem-Nuclear officials told us that they have initiated some
  new procedures, such as changing the accounting system to provide for
  more detailed billing information on the scope of work conducted.
  Because these changes were made near the end of our work, we could
  not evaluate their impact on the program. If instituted as proposed,
  these actions should enhance the effectiveness of the Army’s program.




  Page 26                           GAO/RCED9O-96 Military Needa a Waste Disposal Program
Chau&r 3

Urkertainties Exist for the Future Disposal of
DbD’s Low-Level Radioactive Wmte

                        Over the next 4 years, several legislative requirements and regulatory
                        changes could benefit and/or adversely affect the military’s low-level
                        radioactive waste disposal efforts. For example, NRC expects to issue cri-
                        teria under which certain waste that is below regulatory concern may
                        no longer have to be sent to a commercial disposal site. This change
                        could reduce the military’s disposal volumes and, ultimately, its cost. On
                        the other hand, by January 1993, states either alone or in conjunction
                        with other states (compacts) are required to have disposal sites for the
                        waste generated within their borders or compacts. This requirement-
                        set out in the Low-Level Radioactive Waste Policy Act, as amended-
                        could adversely affect the military’s waste disposal activities and
                        increase costs. Under the act, the compacts or states could establish sites
                        for federal agencies’ use thereby alleviating these impacts; however, DOD
                        has not pursued this option.

                        In light of these uncertainties, the military could realize significant bene-
                        fits from a centralized waste disposal program. As noted previously,
                        complete information does not exist on the amounts or types of waste
                        generated, stored, or disposed of by the three services. In addition, dif-
                        ferences exist with the waste management practices of the three ser-
                        vices, as well as within each service. For example, some installations
                        send all waste to a commercial disposal site; others allow some waste to
                        decay and dispose of it as normal trash. A centralized program could
                        take full advantage of these and other volume-reduction techniques,
                        consolidate management expertise and training, and reduce costs.


                        Significant differences exist among the waste management practices of
Military Does Not Use   the three services, as well as within each service. For example, some
Uniform Waste           installations have received NRC'S approval to store waste until it decays
Management Practices    to a level where it can be disposed of in the sanitary sewage system
                        (liquids) or as normal trash (solids); others send all waste for burial.
                        Some compact or shred waste to reduce the volume to be disposed of;
                        others do not. If consistently applied, these techniques could signifi-
                        cantly reduce the military’s waste volumes and, ultimately, its disposal
                        costs.

                        In a 1988 report, Low-Level Radioactive Waste Volume Reduction and
                        Stabilization Technologies Resource Manual, DOE assessed a number of
                        volume-reduction techniques, such as compaction, supercompaction, and
                        incineration, The study estimated that compaction reduces waste vol-
                        ume from 4 to 8 times depending on the material involved, and incinera-
                        tion reduces such volume 50 to 100 times. Although the military uses


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                                           Chapter 3                                                                                          .
                                           Uncertainties Exist for the Future Disposal
                                           of DOD’s Low-Level Radioactive Waste




                                           equipment different from what DOE used to reach its conclusions, some
                                           of the volume reduction already realized supports the study’s findings,
                                           For example:

                                        . The Uniformed Services University of Health Sciences shreds its waste.
                                          The hospital uses radioactive material-primarily      iodine-l 25-for vari-
                                           ous diagnostic tests and research purposes. In mid-1987, the hospital
                                          began to shred glass vials and plastic containers and over the last 3 fis-
                                          cal years reduced the amount of waste sent for burial by a factor of
                                           about 7-from 886 to about 113 cubic feet of material.
                                        . Using a compactor, Walter Reed Army Medical Center, Washington,
                                          D.C., reduced the waste sent for disposal over the last several years by
                                          300 percent.
                                        9 To facilitate the disposal of protective clothing, paper, and other items
                                          used to clean up a building contaminated by an accidental release of tri-
                                          tium, Letterkenny Army Depot, Pennsylvania, purchased a compactor.
                                          As a result, an Army official estimated that some waste volumes were
                                          four times less.
                                        . The Army’s Ballistic Research Laboratory, Aberdeen, Maryland, has
                                          used a compactor since 1982 and a shredder since 1986 for filters, pro-
                                          tective clothing, and other solid material. A laboratory official estimates
                                          that the volume of waste has been reduced by a factor of 25. In June
                                          1989, the Combat Systems Test Activity-also       located at Aberdeen-
                                          began to use this equipment to reduce its waste volume. Because this
                                          was a recent activity, officials could not estimate any possible benefits.

                                          Table 3.1 shows several examples of the different waste-handling tech-
                                          niques used by some of the military installations included in our review.

Table 3.1: Examples of Waste-Handling
Techniques Used by Various Military                                                                            Installations*
Installations                                                                                    Air Force      Army          Navy         DOD
                                          Waste management practice                               12            34            5    6          7
                                          Vial crusher/   slicer                                 No    N/A    No    No    No     No         Yes
                                          Compactor/      shredder                               No     No   Yes    No    No     No        Yes
                                          Dispose   of liquid waste   in sanitary   sewer       Yes    N/A   Yes    No   Yes    Yes        Yes
                                          f&Dose    of solid waste    as normal trash           Yes     No   Yes    No   Yes     No        Yes

                                          al = Brooks Air Force Base.
                                          2 = Kelly Air Force Base.
                                          3 = Walter Reed Army Medical Center.
                                          4 I= Chemical Research, Development, and Engineering Center
                                          5 = National Naval Medical Center.
                                          6 = Norfolk Naval Drug Laboratory.
                                          7 = Uniformed Services University of Health Services.
                                          N/A = Not applicable.




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                       If consistently applied, the techniques shown in table 3.1 could signifi-
                       cantly reduce the military’s waste disposal costs. However, some tech-
                       niques are predicated on the availability of, and funding for, specialized
                       equipment and/or sufficient and properly designed storage facilities.
                       For example, the Norfolk Naval Drug Laboratory does not have ade-
                       quate on-site facilities to allow solid waste to decay in storage. As a
                       result, the laboratory has contracted with a private company to remove
                       the waste and allow it to decay.


                       At least five issues related to the implementation of the Low-Level Radi-
Legislative            oactive Waste Policy Act, as amended, could adversely affect the mili-
Requirements Could     tary’s waste disposal activities.’ First, waste may eventually have to be
Adversely Affect the   disposed of in up to 16 different locations rather than the existing 3
                       sites. Second, since the three sites have different disposal requirements,
Military’s Waste       it is likely that the nine compacts and seven states will establish some
Disfiosal Efforts      different requirements. Third, costs will increase from the surcharges
                       and penalties that will be paid until January 1993. Fourth, the number
                       of cost-ineffective small-volume disposals could increase. Finally, the act
                       does not address the disposal of some waste generated overseas.
                       Although an option is available to alleviate these impacts (i.e., sites for
                       the exclusive use of federal agencies), DOD has not pursued this option.

                       In 1979, a series of packaging incidents and a reluctance to be the
                       “dumping grounds” for the entire nation prompted the states of Wash-
                       ington and Nevada to temporarily close their low-level disposal sites and
                       South Carolina to limit the volume of waste to be disposed of in its site.
                       Because the potential loss of disposal capacity had national implica-
                       tions, the Congress began to consider legislation to address these con-
                       cerns. One proposal would have made low-level waste disposal a federal
                       responsibility. The governors of the three states where the existing sites
                       are located opposed federal involvement and testified that all states
                       needed to examine waste disposal alternatives.

                       Under the Low-Level Radioactive Waste Policy Act, as amended, states
                       or compacts are required to have new disposal sites by January 1, 1993.
                       In October 1989, DOE provided its third annual report to the Congress on
                       the compact regions’ and states’ progress to achieve the act’s goals. DOE


                       ‘Other NRC licensees disposed of about 94 percent of all low-level waste in 1988. Although these
                       licensees could be similarly affected by the act, we limited our review to the Army, Air Force, and
                       Navy.



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reported that only four compacts and one state expect to begin site oper-
ations by January 1993, and one state plans to accept waste but place it
in interim storage until its site is available.

Of the six, the report noted that two compacts and one state expected to
submit applications by January 1, 1990; only one compact (Southwest-
ern) did so. DOE also pointed out that several regulatory uncertainties
could further delay new site operations. DOE noted that EPA had not
finalized its groundwater protection standards, NRC had not finalized its
exemption policy for below regulatory concern waste, and disagreement
existed between NRC and EPA concerning the regulatory requirements for
waste that has both radioactive and hazardous constituents (mixed
waste).

NRC expects that about 15 months will be needed to review the applica-
tions and issue licenses for the sites. The compacts and states cannot
begin site construction until they receive a license. However, DOE'S
annual report noted that “it appears likely” that a number of compacts
and states will not meet the act’s milestones, and some states have urged
that the act be amended to allow for the disposal of waste at the three
existing sites beyond January 1993 or realign the existing compacts and
states into larger regions. Also, in a November 1989 report, OTA noted
that most compacts and states have selected disposal designs that have
not been built in this country; therefore, the licensing process could take
longer than expected. Figure 3.1 shows the compact regions as of
December 1989.




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      1.1: Status of Compact Regions, December 1989

            Notihwest             --




      mm    Current host state
            Designated       host state
    ; I
      m     Approved        compact
      0     No plans to develop site




                                          Source: DOE




Impkt on the Military’s                   At least five issues related to the act could significantly affect the three
                                          services’ waste disposal activities. Each is discussed below.
Wa$,e Disposal Efforts
16 v$. 3 DisposalSites                    The exact number of sites that will be available is not currently known,
                                          but at least 12 new sites are expected to be developed and 4 states are
                                          evaluating alternatives to comply with the act. Although MD could con-
                                          tinue to use the consolidation facility, the number of sites where the
                        *                 waste will then have to be sent for disposal could increase costs and
                                          pose an administrative burden on the military. To illustrate, in February



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                                   Chapter 3
                                                                                                                              .
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                                   1989 the Air Force and Army sent 43 waste shipments (about 640 cubic
                                  feet) from 21 states for disposal in South Carolina. If we assume the
                                  organization of compact regions and states shown in figure 3.1, these
                                  shipments-after    consolidation-would    have to be sent to six compact
                                  regions and three states for disposal. The contractor will have to segre-
                                  gate the waste and package it in accordance with the various site
                                  requirements.

                                  In addition., WA'S November 1989 report noted that the volume of waste
                                  disposed of has decreased about 55 percent over the last 9 years
                                  through various waste minimization efforts but disposal costs have
                                  more than tripled. The report also noted that, because many costs asso-
                                  ciated with developing new sites are fixed, disposal costs will vary sig-
                                  nificantly from one site to another, depending in part on the amount
                                  disposed of and land values. According to the report, disposal costs
                                  could range from $50 to $590 per cubic foot,

Different DisposalRequirements The military may have to comply with the disposal requirements of the
                                   16 compacts or states. For environmental and public health and safety
                                  reasons, the three existing sites have some different disposal require-
                                  ments. For example, Washington State will accept liquids that are
                                  absorbed with other material, similar to kitty litter, whereas Nevada
                                  and South Carolina require that all liquids be mixed with concrete and
                                  solidified. Also, Washington will allow the disposal of some solidified
                                  waste that contains organic oils; South Carolina and Nevada do not
                                  allow the disposal of such waste. To illustrate the possible impact of
                                  differing requirements on the military’s activities, in fiscal year 1987
                                  the Navy wanted to dispose of two 55-gallon drums containing radium
                                  dials and five 55-gallon drums containing radium gauges. To meet Wash-
                                  ington State disposal requirements, the material in the 7 drums had to
                                  be sorted and repackaged into 34 drums at a cost of about $101,500,
                                  excluding disposal costs.

                                  In addition, some waste contains both radioactive and hazardous sub-
                                  stances, and NRC and EPA share regulatory responsibility for such mixed
                                  waste. According to ~-A'S report, between 3 and 10 percent of low-level
                                  waste may be mixed waste. Although nine states, including South Caro-
                                  lina and Washington, have been authorized by EPA to dispose of mixed
                                  waste, no site exists to do so. As a result, according to OTA'S report, some
                                  generators are either treating their waste to make it exclusively radioac-
                                  tive or hazardous and acceptable for disposal or storing it on-site. The
                                  report also raised the possibility that some mixed waste may have been



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                         disposed of in unauthorized sites. As of October 1989, only two com-
                         pacts (Central Midwest and Central Interstate) and one state (Texas)
                         expected to dispose of mixed waste.

                         OTA raised a number of other issues concerning the disposal of mixed
                         waste, such as the overlapping regulatory jurisdiction between EPA and
                         NRC and the conflict and inconsistencies with both agencies’ disposal
                         requirements. For example, EPA requires generators to take samples to
                         characterize the substances in the waste; NRC does not have such a
                         requirement, fearing that worker exposures could increase. In addition,
                         EPA requires liners and leachate systems at hazardous waste sites; NRC
                         does not have this requirement for low-level waste sites. The agencies
                         are working to resolve these and other differences; NRC staff could not
                         estimate when these actions would be complete.

Financial Implications   The act established surcharges and financial penalties to encourage the
                         use of volume-reduction techniques and to pay for new site development
                         costs. Between July 1986 and December 1992, the surcharges ranged
                         from $10 to $40 per cubic foot of waste disposed of. To illustrate the
                         impact of the surcharges on the military, in May 1989 the Army initi-
                         ated efforts to dispose of 4,000 tons (about 16,360 cubic feet) of contam-
                         inated steel before January 1, 1990, when the surcharge rate doubled.
                         For this volume of waste, the surcharge would have increased from
                         $327,200 to $654,400-over      and above disposal costs of more than
                         $600,000, excluding about $800,000 in labor, material, and transporta-
                         tion costs. The Army was unable to obtain funding before January 1990
                         and continues to store the contaminated steel at Aberdeen, Maryland.

                         During calendar year 1992, the penalties could triple the surcharges to a
                         maximum of $120 per cubic foot of waste disposed of if the compacts
                         and states have not submitted site applications. If the Army does not
                         dispose of the steel before that time, the surcharge would increase from
                         $654,400 to a maximum of almost $2 million, excluding disposal and
                         other costs discussed above. However, the Army could continue to store
                         the steel until the Appalachian compact, of which Maryland is a mem-
                         ber, has its Pennsylvania site available.

                         Furthermore, as noted in chapter 2, the Navy generally stores its low-
                         level waste. In response to its survey, Navy installations reported hav-
                         ing at least 9,000 cubic feet of waste.2 On the basis of historical data, we

                         2Although the survey results were incomplete, the information reported is useful for illustrative
                         purposes.



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                                           estimate that about 85 percent of the waste disposed of under the
                                           Army’s program was generated outside the existing three compact
                                           regions. If we assume that this same percentage would apply to the
                                           Navy’s waste, about 7,650 cubic feet could be subject to surcharges
                                           ranging from $306,000 to $918,000 (between Jan. 1990 and 1993),
                                           excluding disposal, labor, material, transportation, and packaging costs.
                                           The costs could increase even more, depending on the disposal require-
                                           ments of the various compact regions or states. On the basis of historical
                                           data, the special treatment or packaging requirements of the three
                                           existing sites have doubled or tripled the volume of some types of waste
                                           disposed of.

                                           Because complete information is not available on projected waste dis-
                                           posal volumes for the three services, we have used historical data from
                                           the Army’s program to illustrate the possible affect of the surcharges on
                                           the military’s waste disposal costs. Table 3.2 shows the estimates that
                                           we derived.

Tablg 3.2: Example of Possible Impact of
Surcharges on the Military’s Waste                                         Volume
Dirrposal Costs                                                       disposed (in
                                           Fiscal year                  cubic feet) Disposal costa               Surchargeb                   Total
                                           1985                            26.331.3       $656.703                    $        l          $656.703
                                           1986                            22,687.3        626,623                      96,421             723,044
                                           1987
                                           ---                             44,896.7            1,495,958               381,622           1,677,590
                                           1988                            20,854.7              736,588               354,530           1,091,116
                                           1989                            63.043.3            2.3243406             1.071.736           3.396.142
                                           1990                            35:563.0c           1,376,644d            1:209.142           2,585;766
                                           1991                            35563.0             1,445,636             1,209,142           2,654,778
                                           1992                            35,563.0            1,517,829            3,627,426”           5,145,255
                                           %asic disposal costs, excluding packaging, transportation,   labor, materials, taxes and other charges

                                           ‘Calculated on the basis of historical data showing that about 85 percent of the waste disposed of was
                                           generated outside the three existing compact regions.

                                           ‘Estimated   volume for 1990 through 1992 based on the average of waste disposed of from 1985 through
                                           1989.

                                           dAccording to Chem-Nuclear officials, the base rate is expected to increase 5 percent annually.

                                           ‘Assumes maximum $120 per cubic feet of waste disposed of.


Small-VolumeDisposals                      The number of cost-inefficient small-volume disposals could increase.
                                           Currently, the Army and its program participants send their waste to
                    ”                      South Carolina, where the contractor consolidates small shipments and
                                           repackages the material for disposal. As pointed out in chapter 2, these
                                           activities have been cost beneficial to the program. Once the compacts


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--
                             and states have their disposal sites, some of this benefit may deterio-
                             rate. For example, 27 of the 43 waste shipments by the Air Force and
                             Army in February 1989 (discussed above) were 1 cubic foot or less and
                             may require special treatment and packaging to meet burial site
                             requirements.

Disposal of Overseas Waste   The act does not address the disposal of waste that is generated by the
                             military outside the United States. Currently, overseas bases ship some
                             waste, such as instruments and gauges, to the United States for disposal.
                             In fiscal year 1989, the Air Force sent 22 shipments from Japan, the
                             United Kingdom, Germany, and other locations for disposal, and the
                             Army disposed of about 160 cubic feet of waste from overseas. For fis-
                             cal year 1990, the Army estimates that about 750 cubic feet of waste
                             generated overseas will be disposed of. Although the existing three sites
                             can refuse such waste, South Carolina has allowed its disposal at Barn-
                             well. However, beginning in January 1993, no certainty exists that the
     ,                       compacts and states would accept waste generated overseas.


Option Available to          Taken together, the five issues could impose substantial administrative
Allebiate These Impacts      and cost burdens on the military after January 1993. However, one
                             option exists that could alleviate these burdens. The act gives the com-
                             pacts or states the option to establish sites for the exclusive use of fed-
                             eral agencies, thereby exempting them from the requirement to dispose
                             of waste in the region or state in which it is generated. By December 31,
                             1992, both the South Carolina and Nevada sites will close, and new dis-
                             posal sites are planned for their compacts. Yet, all three existing sites
                             have unfilled capacity that could be committed for the federal govern-
                             ment’s use. As of January 1990, DOD had not contacted other federal
                             agencies to work with the compact regions and states to determine the
                             feasibility of dedicating a portion of one or more sites for federal agen-
                             cies’ use.

                             Nevertheless, officials from the three services believe that a federal
                             repository would result in increased efficiencies and cost savings to DOD.
                             However, they do not believe that DOD has the authority to resolve this
                             issue for ,iI le entire federal government. They suggested that the GSA,
                             NRC, or the Committee on Interagency Radiation Research and Policy
                             Coordination should lead the effort for such a site.




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                    Two regulatory issues can also affect the military’s waste disposal activ-
Futbre Regulatory   ities. The two issues are the (1) timely submission of site applications by
Umptainties         the compacts and states and (2) criteria for the disposal of below regula-
                    tory concern waste.

                    Under the act, the 16 compacts and states were required to submit their
                    site applications by January 1990-only 1 compact met this mile-
                    stone-or January 1992. NRC expects that 15 months will be needed to
                    review an application and issue a license for a site, assuming that (1) EPA
                    issues final regulations for radiation release and groundwater contami-
                    nation limits that the new sites must meet and (2) NRC and EPA resolve
                    the regulatory uncertainties concerning mixed waste. The compacts and
                    states cannot begin site construction until they receive a license.

                    If we assume the worst scenario-the remaining compacts and states do
                    not submit applications until January 1992-it seems unlikely that NRC
                    or the agreement states could review the applications and issue licenses
                    and the sites could be constructed by January 1993. In the event sites
                    are not available, the act requires NRC to consider granting each waste
                    generator temporary access to existing sites to dispose of their waste if
                    an imminent public health and safety risk exists. According to NRC staff,
                    it would be rare that this condition would exist such that NRC would
                    grant temporary access. Therefore, generators may have to store their
                    waste until the regional or state sites are available. This could result in
                    not only the military’s stockpiling waste but also stockpiling by other
                    NRC licensees, including federal agencies (such as the Department of Vet-
                    erans Affairs and the National Institutes of Health), 112 commercial
                    nuclear power plants, and more than 23,000 other organizations. Fur-
                    thermore, if NRC grants access to existing sites, the licensees will have to
                    pay the $120 per cubic foot surcharge.

                    However, another of the act’s requirements could be cost beneficial to
                    the military because it would reduce the amount of waste that would
                    have to be disposed of in the compact regions or states. Section 10
                    required NRC to develop criteria and procedures by July 1986 concerning
                    the information that licensees would have to provide in seeking an
                    exemption for waste that is below specified limits. In August 1986, NRC
                    added a policy statement to its regulations outlining this information. In
                    the policy statement, NRC set out 14 criteria that must be met and said
                    that the licensee must demonstrate that no undue public health and
                    safety risk would result from the alternative selected. However, the pol-
                    icy statement did not establish limits for below regulatory concern
                    waste.


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    As a result, in December 1988 NRC published an advance notice of a pro-
    posed policy in the Federal Register and asked for public comments on
    it. In January 1989, NRC held a public meeting and proposed two crite-
    ria-an individual dose of 10 millirem and a collective population dose
    of 500 person-rem.” Subsequently, in October 1989, the Commission
    directed NRC staff to revise the collective dose to 1,000 person-rem. In
    doing so, the Commission noted that this limit would be sufficiently low
    to be of negligible significance to public health and safety yet practical
    and cost beneficial to achieve. NRC had expected to have a final policy by
    November 1989; NRC now expects to do so during the spring of 1990.
    According to NRC staff, disagreements between NRC and EPA contributed
    to this delay. EPA believes that the annual individual dose should be 4
    millirem rather than the 10 millirem proposed by NRC.

    NRC received over 200 comments as a result of the notice and meeting.
    The comments were almost evenly divided with regard to the need for
    an exemption policy. Those who favored the exemption noted that the
    individual dose of 10 millirem is low compared with the annual expo-
    sure that the public receives from background radiation (which varies
    by location, but, in Denver, Colorado, is about 60 millirem annually),
    their own bodies (30 millirem annually), or flying (5 millirem per 10
    hours of flight time). Others questioned the need for a collective dose
    criterion, stating that the individual dose would be adequate. Still others
    believed that all levels of radiation pose some public health and safety
    risk, and all should be regulated.

    As proposed, a licensee or group of licensees would have to submit a
    petition to NRC to use an alternative method to dispose of below regula-
    tory concern waste. The petition will have to include an analysis of the
    expected benefits to be derived, risk to the public, projected dose limits,
    and method used to ensure that exposures are kept as low as reasonably
    achievable. Also, those granted an exemption will be required to main-
    tain records of waste generated and disposed of and the volume and
    level of radioactivity. NRC expects to grant exemptions through a
    rulemaking procedure but could also do so through a license amend-
    ment. NRC staff could not estimate how long the process could take.




    “Rem (roentgen equivalent man) is a measurement used to quantify the effects of radiation on man. A
    millirem is one-thousandth of a rem.



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                            As of January 1990, NRC had received only one petition from the Rocke-
                            feller University to incinerate some solid waste. NRC rejected the peti-
                            tion, noting that the licensee had not provided sufficient information on
                            the nationwide radiological effects of the requested exemption.

I


    on the Military’s       NRC'S below regulatory concern rule could significantly  reduce the
                            amount of waste disposed of by the three services. We cannot, however,
                            estimate this impact. Since no need previously existed to maintain this
                            information, neither the three services nor their disposal contractors has
                            historic data that would allow us to develop an estimate.

                            However, since 1981, NRC has allowed some licensees involved in
                            research and medical diagnostic and treatment activities, such as the
                            National Institutes of Health and Walter Reed Army Medical Center, to
                            dispose of waste as normal trash or into the sanitary sewage system.
                            According to NRC staff, these same types of licensees as well as nuclear
                            utilities would most likely petition NRC for an exemption under the
                            below regulatory concern rule. Both DOE and OI'A have reported that the
                            rule could reduce the volume of waste requiring disposal. In addition, a
                            March 1989 study by the Electric Power Research Institute estimated
                            that nuclear utilities could save as much as $127 million annually (if all
                            dry activated waste is considered below regulatory concern) in part
                            because sanitary landfills generally charge less than $0.20 per cubic foot
                            cf waste disposed of.

                            Although a number of uncertainties exist concerning the criteria that
                            will be in NRC'S final rule, the activities conducted by some military
                            organizations provide a perspective on the possible impact of it. For
                            example:

                        l During calendar year 1988, Walter Reed disposed of over 1,000 gallons
                          of waste into the sanitary sewage system and 127 bags and 94 boxes
                          (volume unknown) of solid waste as normal trash. The hospital also
                          incinerates animal carcasses. If the waste had been sent to a commercial
                          disposal site, the liquids would have had to be mixed with concrete, and
                          the animal carcasses would have required special packaging prior to
                          burial.
                        . The National Naval Medical Center stores some liquid and solid waste
                          contaminated with iodine-125 and other radioactive material until it
                          decays to background levels. After surveying the material, the center
                          disposes of it into the sanitary sewage system or as normal trash.



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        According to Navy officials, they have used these techniques for many
        years but could not estimate the cost savings that have been realized.
    l   Uniform Services University of Health Sciences stores liquid waste in
        large tanks (that hold several hundreds of gallons) and then disposes of
        the material in the sanitary sewage system.

        In addition, we found that the Army and its program participants have
        disposed of waste that may ultimately meet the below regulatory con-
        cern criteria. For example, records for the third quarter of fiscal year
         1989 showed numerous disposals of material with low radiation levels
        and short half-lives-51    microcuries of iodine-125 and 151 microcuries
        of iodine-131 with a half-life of 60 and 8 days, respectively.4 Also, in
        July and August 1989, the Letterkenny Army Depot shipped 32 drums
        (about 200 cubic feet) of absorbed liquid waste to Richland that con-
        tained about 527 microcuries of tritium and shipped 17 drums (about
        128 cubic feet) of solid waste to South Carolina that contained about 17
        microcuries of tritium. According to NRC staff, this material would merit
        consideration as below regulatory concern waste because the expected
        radioactive releases would be within the 10 millirem and 1,000 person-
        rem criteria under the Commission’s consideration.




        4A curie is a measure of the rate of radioactive decay. A microcurie is equivalent to one-millionth of a
        curie.



        Page 39                               GAO/RCED-90-96 Military Needs a Waste Disposal Program
Chapter 4

Ccjnclusionsand Recommendations


                   The military generates low-level radioactive waste from thousands of
                   activities in all 50 states and at overseas bases. Because of the large
                   number of generators, the military must ensure that the waste is prop-
                   erly handled and disposed of not only to protect its own personnel but
                   also public health and safety. Yet, after January 1993, the military’s
                   waste disposal activities may be stymied by crosscutting federal and
                   state requirements. Furthermore, two of the three sites that the military
                   now uses will close by December 1992, and a likelihood exists that many
                   of the planned new sites will not be available. Therefore, DOD needs to
                   take full advantage of the intervening time to (1) establish a comprehen-
                   sive low-level radioactive waste disposal program with high departmen-
                   tal-level oversight and (2) work with other federal agencies to determine
                   the feasibility of the compacts or states dedicating a portion of one or
                   more sites for the government’s use.

   1


                   The military should not allow another incident like Wright-Patterson to
E@efits Could Be   occur. The accident, which cost almost $1 million to clean up, could have
Realized From a    been avoided if the Air Force had disposed of, rather than stored, its
Comprehensive      waste. Yet, the same situation exists today-the    Navy stockpiles its
                   waste and has been doing so for many years. The military cannot con-
Program            tinue its passive attitude on low-level waste disposal. A comprehensive
                   military waste disposal program could ensure that military installations
                   temporarily store waste until it is shipped for disposal. It could also
                   ensure that each service appropriately identifies the types and amounts
                   of waste generated. Presently, the three services do not have this infor-
                   mation, and they continue to identify material that may need to be dis-
                   posed of. To make matters worse, 46 Air Force bases buried waste in the
                   195Os, but they do not have information on the number of sites or the
                   types and amounts of material in them. In our opinion, the military
                   needs complete information to prudently address its waste disposal
                   needs, establish adequate budgets to meet these needs, and set priorities
                   for waste that should be disposed of first.

                   In addition, without a comprehensive program, the military leaves itself
                   open to errors and problems that could lead to adverse publicity and
                   criticism. Throughout the 198Os, the Army and the Air Force were
                   banned from all three disposal sites at one time or another for failing to
                   comply with federal and state requirements. This may be an increasing
                   problem since after 1993, the 3 services may have to comply with the
                   requirements of up to 16 sites. Because the existing three sites have dif-
                   ferent requirements, a strong likelihood exists that the compact regions
                   and states will each set different requirements to protect the public and


                   Page 40                     GAO/RCEDBO-96 Military Needs a Waste Disposal Program
1   ,
                        Chapter 4
                        Conclusions and Recommendations




                        environment. In addition, a number of controversies and uncertainties
                        exist concerning the disposal of mixed waste. Under a comprehensive
                        program, the military could consolidate existing management expertise
                        and training to stay current with the requirements rather than having
                        thousands of individuals around the country and overseas devoting time
                        and effort to do so under separate programs.

                        Finally, a comprehensive program could ensure that the military aggres-
                        sively pursues volume-reduction techniques and utilizes a centralized
                        facility to compact and consolidate waste, thereby reducing costs. In
                        addition, by consolidating numerous small shipments, the military can
                        reduce the potential that shipments sent by thousands of generators
                        could be lost when sent to the regional or state sites, or worse, improp-
                        erly discarded rather than properly disposed of as radioactive waste.
                        Also, the facility operator would know the disposal requirements of the
                        16 sites, alleviating the need for the military to do so. Furthermore, a
                        comprehensive program could ensure that the three services uniformly
                        consider alternatives for waste that meet NRC'S below regulatory con-
                        cern criteria.

                        Although we found a number of management weaknesses with the
                        Army’s program (incomplete information on the number and cost of
                        waste shipments), we believe that the benefits of a comprehensive pro-
                        gram far outweigh the individual approaches used by the three services
                        and the piecemeal approach used by the Navy. In addition, DOD can
                        establish appropriate internal controls and management oversight for
                        the program and a mechanism to ensure that the controls established
                        are appropriately implemented.


                        The military also’needs to consider the most expeditious and cost-effec-
Federal Sites Could     tive manner to dispose of its waste. As of January 1990, basic waste
Befiefit the Military   disposal costs and surcharge fees at commercial sites were almost equal.
                        In other words, the military now pays almost twice as much as it actu-
                        ally costs to dispose of its waste. In addition, by December 1992, two of
                        the existing three sites will close, and the potential exists that only a
                        limited number of new disposal sites will be available. For example, two
                        compacts and one state had expected to submit applications by January
                        1990; only one did so. The longer the compacts and states wait to submit
                        license applications, the less likely sites will be in operation by 1993. If
                        additional sites are not available, the military will have to store its
                        waste, thereby increasing the potential for another Wright-Patterson
                        incident, or seek an NRC exemption to dispose of waste outside the region


                        Page 41                           GAO/RCED-90.96MilitaryNeeda aWasteDisposalProgram
Chapter 4
Conclusions and Recommendations




or state in which it is generated. Whether NRC will grant the exemption
is uncertain.

If sites were available for the exclusive use of federal agencies, the need
for the military to store waste would be eliminated and significant sav-
ings of taxpayer dollars could occur. Several options exist that DOD,
working with other federal agencies, can pursue. First, two of the
existing three sites will close by December 1992, but all three have
unfilled capacity. Second, a portion of new sites could be dedicated for
federal agencies’ use. We recognize that this approach could be viewed
as providing preferential treatment to federal agencies that dispose of
only a small percentage of low-level waste. On the other hand, federal
sites could reduce the potential for packaging and shipping errors to
occur and could ensure that low-level waste generated overseas can be
safely disposed of. Although other NRC licensees may experience prob-
lems in complying with the act, we believe that the benefits to be
derived-increased     efficiencies and cost savings-justify  giving serious
consideration to federal sites.

Because of the widespread geographical location of bases-50 states
and OVerSeaS--DOD, in our opinion, should spearhead the effort for fed-
eral sites. In doing so, DOD could consider working with the compact
regions or states to (1) use the unfilled capacity at the existing three
sites or (2) dedicate a portion of new sites for federal agencies’ use. If
DOD could obtain a commitment now from one of the states with an
existing site, our previously identified concerns could be resolved. In
addition, if the sites were located in South Carolina or Washington State,
federal agencies may be able to dispose of mixed waste because EPA has
authorized these two states to dispose of such waste. Although officials
from the three services recognize that benefits would be realized if a
federal site was available, they do not believe that DOD should lead this
effort.

We recognize that the compact regions or states could raise a number of
concerns related to such sites. First, under the act, the sites would be
outside the regions’ or states’ control. To resolve this, the compacts or
states could require that the facilities be licensed. Second, the compact
regions or states may need to overcome a number of political issues,
such as public opposition to accepting federal waste from outside their
boundaries. Yet, DOD does not have information on the opposition, if any,
that may be encountered concerning disposal sites for federal agencies’
use.



Page 42                           GAO/RCED-90-96 Military Needs a Waste Disposal Program
*
                         Chapter 4
        I                Conclusions and Recommendationa




                         To ensure that all DOD installations appropriately manage and dispose of
Rec&unendations to       low-level radioactive waste and reduce the potential for another inci-
the Secretary of         dent similar to the one at Wright-Patterson, we recommend that the Sec-
Defdnse                  retary of Defense

                     . establish a comprehensive low-level radioactive waste disposal program
                       at a high departmental level;
    I                . establish uniform policies and procedures for the program and institute
                       a mechanism to ensure compliance throughout DOD with the
                       requirements;
    I                . develop an inventory of the amounts and types of low-level radioactive
                       waste that are stored or buried at all installations;
    /                . require all DODinstallations to institute consistent waste minimization
                       and treatment techniques; and
                     . develop a strategy for dealing with low-level waste after 1992, including
                       working with other federal agencies, compacts, and states to determine
                       the feasibility of dedicating a portion of one or more sites for the gov-
                       ernment’s use. In these discussions, DOD should ensure that low-level
                       radioactive waste generated overseas would be accepted for disposal.




                         Page 43                           GAO/RCED90~96 Military Needs a Waste Disposal Program
Appendix I
   /
@me Provisions of the Low-Level Radioactive
V&&e Policy Act, as Amended

                  The Low-Level Radioactive Waste Policy Act, as amended, established a
                  federal policy that the safest and most efficient way to dispose of low-
                  level waste would be on a regional basis. To ensure consistency among
                  the compact regions, the act incorporated NRC’S low-level waste defini-
                  tion-waste that is not classified as uranium mill tailings, high-level
                  waste, or spent fuel.’ The act also

              .    established milestones, surcharges, and penalties to encourage-and
                   fund-the development of new disposal sites by January 1,1993.
                   Between July 1986 and December 1987, the surcharges were $10 per
                   cubic foot of waste disposed of; in 1988 and 1989, $20; and between
                   1990 and 1992, $40. Also, during calendar year 1992, the surcharge
                   could be as much as $120 per cubic foot of waste disposed of if the com-
                  pacts and states have not submitted site applications.
                   established the three existing sites in Barnwell, South Carolina; Beatty,
                  Nevada; and Richland, Washington, as compact regions until December
                  31, 1992 and limited the amount of waste that could be disposed of in
                  them until that time.
                  required the three states with existing sites to collect the surcharges and
                  later to provide 25 percent to DOE for distribution to the compact regions
                  or states for new site development; the three states would retain the
                  remaining 75 percent. If new sites are not available by January 1993,
                  the funds (25 percent) will be repaid monthly to generators rather than
                  to the compacts or states.
                  called for 7 compact regions and identified 39 states that would be mem-
                  bers of them but also allowed the states to select the compact in which
                  they wanted to participate, to change compacts, or to dispose of waste
                  on their own.
                  required the compacts to identify a host state and develop a site plan by
                  January 1,1988 (New Hampshire, North Dakota, Puerto Rico, Rhode
                  Island, Vermont, and Washington, D.C., did not meet this milestone).
                  required the compact regions and states to file certifications by January
                   1990 and license applications by that date or within a 2-year grace
                  period (Jan. 1992). As of Janua.ry 1990, only one compact-Southwest-
                  ern-had submitted an application.
                  required NRC and the agreement states to review applications and issue
                  licenses to the sites within 15 months of receiving the application.
                  allowed NRC, after January 1993, to grant each waste generator (from
                  outside the compact regions) temporary access to disposal sites if an
                  imminent public health and safety hazard exists.

                  ‘NRC has established three classes of low-level waste that are based in part on the half-lives of the
                  material and the types of radiation emitted.



                  Page 44                               GAO/RCED-90-96 Military Needs a Waste Disposal Program
    Appendix I
    Some Provisions of the Low-Level Radioactive
    Waste Policy Act, as Amended




l required NRC to establish criteria for below regulatory concern waste
  that would be exempt from the act.
. identified certain waste that is the responsibility of the federal govern-
  ment, including waste generated by (1) DOE, (2) the Navy from decom-
  missioning its nuclear vessels, and (3) the private sector that exceeds
  NRC’S Class C limits.”




    ZGrcater than Class C waste is discarded material contaminated with long-lived radioactive elements
    having concentrations greater than those specified in 10 CFR Part 61.



    Page 45                              GAO/RCED-90-90 Military Needs a Waste Disposal Program
Appendix II

List of Organizations Visited and Officials
GAO Contacted

-

                 Name of Organization               Location                        Title of Officials Contacted
                 Air Force __
                 Radioisotope Committee             San Antonio, Tex.               Executive Secretarv
                 Brooks Air Force Base              San Antonio, Tex.               Radiation Safety Officer and
                                               --                                   three other officials
                 Kelly Air Force Base               San Antonio, Tex.               Radioactive Waste Manager
                                                                                    and one other official
                 Army
                 --
                 Armament, Munitions and            Rock Island, Ill.               Chief of Staff and 13 other
                 Chemical Command                                                   officials
                 Army Material Command              Alexandria, Va.                 Chief, Safety Office, and one
                                                                                    other official
                 Surgeon General’s Office           Falls Church, Va.               Radiological Hygiene
                                                                                    Consultant
                 Walter Reed Army Medical         Washington, D.C.                  Chief of Staff and seven other
                 Center                                                             officials
                 Brooks Army Medical Center       San Antonio, Tex.                 Commander and three other
                 --___...                                                           officials
                 Health Services Command          Fort Sam Houston, Tex.            Commander and five other
                 __________~~~__. ~~-._~-._-.__-.-~~..-- __-                        officials
                 Chemical Research,               Edgewood, Md.                     Commander and three other
                 Development, and                                                   officials
                 Engineering Center
                               ---_                                                  -I
                 Environmental Hygiene            Edgewood, Md.                     Chief of Staff and six other
                 Agency                                                             officials              ____~~.
                 Ballistic Research Laboratory    Aberdeen, Md.                     Safety Manager and one
                            ___ ..~__ ..-.~~~. ~__ .--___-_                         other official -__    ---.-
                 __-
                 Test and Evaluation              Aberdeen, Md.                     Deputy Commander and
                 Command                                                            three other officials
                 Combat Systems Test              Aberdeen, Md.                     Safety Manager and three
                 Activity                                                           other officials
                 Navy                                                            __.__.
                 Radiation Safety Committee         Crystal City, Va.               Executive Secretary and six
                                                                                    other   officials
                                                                                        .__-__
                Naval Sea Systems                   Crystal City, Va.               Deputy Director, Radiological
                Command                                                             Controls Program   --.. Office
                                                                                                                --..---
                Navy Environmental Health           Norfolk, Va.                    Head, Radiation Division and
                Center                                            ___               one other ._____..
                                                                                                  official
                -.- -----.--    ~~._----.           .--.-----
                Radiological Affairs Support        Yorktown, Va.                   Commander and two other
                Office
                ..- -____-.                                                         officials
                National Naval Medical              Bethesda, Md.                   Deputy Commander and
                Center                                                              three other officials
                Naval Medical Research              Bethesda, Md.                   Deputy Commander and two
                Institute                                               ___..       other officials
                                                                                __-___..
                Mare Island Naval Shipyard          Vallejo, Calif.                 Director of Radiation Control
                                                                                    and three other officials
                Oakland Naval Supply Center         Oakland, Calif.                 Commanding Officer and
                                                                                    seven other officials
                                                                                                            (continued)



                Page 46                                GAO/RCED-90-96 Miitmy     Needs a Waste Disposal Program
*
    Appe*      II
    List of Organizations Visited and Of’flcials
    GAO Ckmb&ed




    Name of Oraanization              Location                     Title of Officials Contacted
    Norfolk Naval Drug                Norfolk, Va.                 Commanding Officer
    Laboratory
    Department of Defense
    --
    Uniformed Services                Bethesda, Md.                Acting Radiation Safety
    University of Health Sciences                                  Officer and one other official




    Page 47                             GAO/RCED-90-96 Military Needs a Waste Disposal Program
     I
 Apjwndix
    ,     III

 lkfqjor Contributors to This Report


                        Mary Ann Kruslicky, Assistant Director
R$sources,
C&nrnunity , and
Edonomic
D&eloprnent Division,
Wbhington, D.C.

                        Robert L. Coleman, Evaluator-in-Charge
                        C. Douglas Mills, Jr., Site Senior
                        Lisa J. Kreisel, Member




(301843)                Page 48                   GAO/RCED-96-96 Military Needs a Waste Disposal Program
?