Nuclear Waste Cleanup: Preliminary Observations on DOE's Cleanup 
of the Paducah Uranium Enrichment Plant (06-DEC-03, GAO-04-278T).
                                                                 
In 1988, radioactive contamination was found in the drinking	 
water wells of residences located near the federal government's  
uranium enrichment plant in Paducah, Kentucky, which is still in 
operation. In response, the Department of Energy (DOE) began a	 
cleanup program to identify and remove contamination in the	 
groundwater, surface water, and soil located within and outside  
the plant. In 2000, GAO reported that DOE faced significant	 
challenges in cleaning up the site and that it was doubtful that 
the cleanup would be completed as scheduled by 2010, and within  
the $1.3 billion cost projection. GAO was asked to testify on (1)
how much DOE has spent on the Paducah cleanup and for what	 
purposes, and the estimated total future costs for the site; (2) 
the status of DOE's cleanup effort; and (3) the challenges DOE	 
faces in completing the cleanup. This testimony is based on	 
ongoing work, and GAO expects to issue a final report on this	 
work in April 2004.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-278T					        
    ACCNO:   A08973						        
  TITLE:     Nuclear Waste Cleanup: Preliminary Observations on DOE's 
Cleanup of the Paducah Uranium Enrichment Plant 		 
     DATE:   12/06/2003 
  SUBJECT:   Environmental monitoring				 
	     Hazardous substances				 
	     Radioactive pollution				 
	     Uranium						 
	     Land management					 
	     Water pollution					 
	     Cost analysis					 
	     Contamination					 
	     Paducah (KY)					 

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GAO-04-278T

United States General Accounting Office

GAO Testimony

Before the Committee on Energy and

Natural Resources, U.S. Senate

For Release on Delivery Expected at 9:00 a.m. CST

Saturday, December 6, 2003 	NUCLEAR WASTE CLEANUP

  Preliminary Observations on DOE's Cleanup of the Paducah Uranium Enrichment
                                     Plant

Statement of Robin M. Nazzaro, Director Natural Resources and Environment

GAO-04-278T

Highlights of GAO-04-278T, testimony before the Committee on Energy and
Natural Resources, U.S. Senate

In 1988, radioactive contamination was found in the drinking water wells
of residences located near the federal government's uranium enrichment
plant in Paducah, Kentucky, which is still in operation. In response, the
Department of Energy (DOE) began a cleanup program to identify and remove
contamination in the groundwater, surface water, and soil located within
and outside the plant. In 2000, GAO reported that DOE faced significant
challenges in cleaning up the site and that it was doubtful that the
cleanup would be completed as scheduled by 2010, and within the $1.3
billion cost projection.

GAO was asked to testify on (1) how much DOE has spent on the Paducah
cleanup and for what purposes, and the estimated total future costs for
the site; (2) the status of DOE's cleanup effort; and (3) the challenges
DOE faces in completing the cleanup.

This testimony is based on ongoing work, and GAO expects to issue a final
report on this work in April 2004.

December 6, 2003

NUCLEAR WASTE CLEANUP

Preliminary Observations on DOE's Cleanup of the Paducah Uranium Enrichment
Plant

Since 1988, DOE has spent $823 million, adjusted to fiscal year 2002
constant dollars, on the Paducah cleanup program. Of this total, DOE spent
$372 million (45 percent) for a host of operations activities, including
general maintenance and security; $298 million (36 percent) for actions to
clean up contamination and waste; and almost $153 million (19 percent) for
studies to assess the extent of contamination and determine what cleanup
actions were needed. DOE currently projects that the cleanup will take
until 2019 and cost $2 billion to complete-nine years and $700 million
more than its earlier projection. The $2 billion, however, does not
include the cost of other DOE activities required to close the site after
the uranium enrichment plant ceases operations, including final
decontamination and decommissioning of the plant and long-term
environmental monitoring. DOE estimates these activities will bring the
total cost to over $13 billion through 2070.

DOE has made some progress in cleaning up contamination and waste at
Paducah, but the majority of the work remains to be done. For example,
while DOE has removed over 4,500 tons of scrap metal, over 50,000 tons of
contaminated scrap metal remain. Similarly, while DOE's pilot test of a
new technology for removing the hazardous chemical trichloroethylene (TCE)
from groundwater at the site had promising results, the technology will
not be fully implemented for over a year.

DOE's key challenge in completing the Paducah cleanup is achieving
stakeholder agreement on the cleanup approach. For example, differences
between DOE and the regulatory entities-the Commonwealth of Kentucky and
the U.S. Environmental Protection Agency-over the cleanup scope and time
frames resulted in an almost 2-year dispute, from June 2001 to April 2003,
that disrupted progress. All three parties are working to develop an
accelerated cleanup plan, but continued cooperation will be required in
order to advance the cleanup.

Drum Mountain, 2,500 tons of crushed drums that once held depleted
uranium, and the site after its removal in 2000.

www.gao.gov/cgi-bin/getrpt?GAO-04-278T.

To view the full product, click on the link
above.
For more information, contact Robin Nazzaro
at (202) 512-3841 or [email protected].

Senator Bunning:

We are pleased to be here today to discuss the Department of Energy's
(DOE) efforts to clean up contamination and waste at its Paducah,
Kentucky, uranium enrichment plant. The plant, which continues to operate
under a lease to a private company, the United States Enrichment
Corporation (USEC), enriches uranium for commercial nuclear power plants.
DOE began a cleanup program at the site in 1988, after contaminated
groundwater was found in nearby residents' drinking water wells, and
contaminated surface water and soils were identified within and outside
the site. In August 1999, in response to allegations that past plant
activities had endangered employees' health, DOE's Office of Oversight
conducted an independent investigation that identified improper disposal
of hazardous and radioactive materials on- and off-site and the release of
contaminated water into streams and drainage ditches.1 In 2000, prompted
by continuing congressional concerns, we reported that DOE faced
significant challenges, such as obtaining stakeholder concurrence with its
approach in cleaning up the Paducah site and that it was doubtful that the
cleanup would be completed as scheduled by 2010 and within the $1.3
billion cost projection.2 Our statement today describes the preliminary
results of our ongoing work, directed by the conference report for DOE's
2003 appropriations, on DOE's cleanup efforts at the Paducah plant.3
Specifically, we will discuss (1) how much DOE has spent on the cleanup
program and for what purposes, and the estimated total future costs for
the site; (2) the status of DOE efforts to clean up the contamination at
the site; and (3) the challenges DOE faces in completing the cleanup.

In summary:

o  	Since 1988, DOE has spent $823 million, adjusted to fiscal year 2002
constant dollars, on the Paducah site. Of this total, DOE spent about $372
million (45 percent) to pay for operations at the site, including
construction, security, general maintenance, and litigation; $298 million

1Department of Energy, Office of Oversight, Office of Environment, Safety,
and Health, Phase I: Independent Investigation of the Paducah Gaseous
Diffusion Plant (Washington, D.C., Oct. 1999).

2U.S. General Accounting Office, Nuclear Waste Cleanup: DOE's Paducah Plan
Faces Uncertainties and Excludes Costly Cleanup Activities, GAO/RCED-00-96
(Washington, D.C.: Apr. 28, 2000).

3H.R. Conf. Rep. No. 108-10, at 895 (2003).

(36 percent) on actions to clean up contamination and remove waste; and
almost $153 million (19 percent) for studies to assess the extent of the
contamination and determine what cleanup actions were necessary. Although
DOE estimated in January 2000 that the cleanup would be complete by 2010
and cost $1.3 billion, DOE now estimates that completing the cleanup will
take at least until 2019 and cost almost $2 billion. The $2 billion,
however, does not include the cost of other DOE activities required to
close the site, including final decontamination and decommissioning of the
buildings, equipment, and materials used in the uranium enrichment process
after operations cease at the plant, as well as long-term environmental
monitoring at the site. Completing these activities will bring the total
cost of closing the uranium enrichment plant to over $13 billion through
2070.

o  	DOE has made some progress in cleaning up contamination and waste at
Paducah since 1988, but much of the work remains to be done. For example,
DOE has removed over 4,500 tons of scrap metal, but over 50,000 tons
remain. Similarly, although DOE has tested a new technology for removing
the hazardous chemical trichloroethylene (TCE) from groundwater at the
site with promising results, the test removed only about 1 percent of the
estimated amount of TCE, and the technology will not be fully implemented
for over a year. DOE also plans to conduct a number of studies to
determine if other cleanup actions, in addition to those already planned,
are necessary. For example, DOE will test the groundwater near several
areas where waste is buried to determine if contamination is leaking and,
if so, what corrective action will be needed.

o  	DOE's key challenge in completing the cleanup at Paducah is achieving
stakeholder agreement on the cleanup approach, including scope and time
frames. For almost 2 years, from June 2001 to April 2003, DOE and the
regulators-the U.S. Environmental Protection Agency (EPA) and the
Commonwealth of Kentucky-were unable to agree on cleanup scope and time
frames, disrupting cleanup progress. DOE, EPA, and Kentucky are currently
negotiating approval of an accelerated cleanup plan; however, the success
of the plan will depend on the parties' ability to agree on the scope and
time frames for individual projects as the cleanup moves forward. In
addition, DOE's proposed plan is only the latest of several attempts to
resolve problems at the site since 1999. Given the parties' past
difficulties in resolving disputes over cleanup scope and time frames, and
the number of decisions that remain to be made, it is unclear whether DOE
will be successful in accelerating the cleanup.

Background

The Paducah uranium enrichment plant is located on about 3,500 acres in
western Kentucky, about 3 miles south of the Ohio River and about 10 miles
west of the city of Paducah. The plant-formerly operated by DOE and now
operated by USEC-enriches uranium for commercial nuclear power reactors.
Plant operations have contaminated the site over time with radioactive and
hazardous chemical wastes, including technetium-99 (a radioactive fission
product); polychlorinated biphenyls (PCBs); uranium; and volatile organic
compounds such as TCE, which was used as a degreaser.

Responsibility for management of the Paducah site is divided between two
DOE offices. The Office of Environmental Management has overall
responsibility for the site cleanup being performed by its contractor,
Bechtel Jacobs. The Office of Nuclear Energy acts as the site's landlord,
with responsibilities for maintaining roads, grounds, and facilities not
leased to USEC.

EPA and Kentucky cooperate in regulating the cleanup under the federal
facility agreement, which integrates the requirements of two federal
environmental statutes governing the cleanup of the Paducah site-the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980, as amended, and the Resource Conservation and Recovery Act of 1976,
as amended. Respectively, these statutes provide broad federal authority
to respond directly to releases or threatened releases of hazardous
substances that may endanger public health or the environment and to
regulate the safe management and disposal of hazardous or other solid
wastes.

In addition to the federal facility agreement, DOE uses two other
documents to manage the cleanup. The site management plan, which is a
cleanup strategy document developed annually by DOE and subject to
approval by EPA and Kentucky, includes timetables, deadlines, and
projected activities for the cleanup. DOE uses the lifecycle baseline to
manage the cleanup; it contains detailed information on cleanup projects,
cost estimates, and time frames for completion and is updated frequently
by DOE's contractor to reflect the evolving nature of the cleanup process.

DOE's cleanup plan for the Paducah site divides the cleanup into seven
major categories:

o  	Groundwater-About 10 billion gallons of groundwater are contaminated
with radioactive and hazardous materials.

o  	Surface water-Contaminated surface water has been discovered in creeks
and ditches leaving the site. One of the main sources of this
contamination is rain runoff from the thousands of tons of contaminated
scrap metal stored at the site.

o  	Surface soils-Both on- and off-site soils and sediments have been
contaminated by water runoff, spills, and buried waste.

o  	Legacy waste-Low-level radioactive or hazardous waste generated before
2001 remains stored in various locations at the site.

o  	DOE material storage areas-160 indoor and outdoor storage areas
contain a variety of radioactive, hazardous, and other materials. These
areas have been added to the cleanup scope since our 2000 report.

o  	Burial grounds-12 burial grounds contain a variety of waste, including
barrels of materials with low levels of radioactivity and hazardous
chemicals.

o  	Decontamination and decommissioning of 17 unused buildings and
structures-These facilities were contaminated during earlier operations;
15 have been added to the cleanup scope since our 2000 report.

  DOE Has Spent $823 Million on the Paducah Cleanup Program, and Billions More
  Will be Required for Final Site Closure

From 1988 through 2003, DOE spent $823 million, adjusted to fiscal year
2002 constant dollars, at the Paducah site. As figure 1 shows, $372
million (45 percent) was spent on operations at the site such as providing
security, performing general maintenance, providing municipal water for
nearby residents, maintaining almost 38,000 cylinders of depleted uranium
hexafluoride,4 constructing storage and other facilities, and carrying out
activities related to litigation; $298 million (36 percent) was spent on
cleanup actions, including waste removal and treatment; and $153 million
(19 percent) was spent on studies to assess the contamination and
determine what cleanup actions were necessary. These percentages are
similar to those DOE's Office of Environmental Management found for all of
its cleanup programs: only about one-third of the environmental management
program budget goes toward actual cleanup and risk reduction work, with
the remainder going to maintenance, fixed costs, and miscellaneous
activities, contributing to a lack of risk reduction and raising costs for
DOE's cleanups.5

4Uranium hexafluoride, a byproduct of the uranium enrichment process, must
be handled in leakproof containers because when it comes into contact with
water, such as water vapor in the air, it forms corrosive hydrogen
fluoride and a uranium-fluoride compound called uranyl fluoride.

5Department of Energy, A Review of the Environmental Management Program
(Washington, D.C., Feb. 4, 2002).

Figure 1: Expenditures at Paducah by Category, Fiscal Years 1988-2003

Note: Total cleanup expenditures for fiscal years 1988-2003, adjusted to
fiscal year 2002 dollars, were $823 million. The individual dollar figures
noted above may not total $823 million because of rounding.

DOE's current estimate for completing the cleanup is almost $2 billion-a
$700 million increase over its 2000 estimate-and the completion date has
moved from 2010 to 2019. The cost increase is attributable to an expanded
project scope as well as millions of dollars for site operations for each
of the 9 additional years of cleanup. However, the cleanup estimate does
not represent DOE's total responsibilities at the site: In addition to the
cleanup program, DOE will build and operate a facility to convert the
depleted uranium hexafluoride stored at the site to a more stable form and
carry

out final decontamination and decommissioning (D&D) of the uranium
enrichment process buildings, equipment, and materials once USEC ceases
plant operations. Furthermore, after the cleanup, D&D, and uranium
hexafluoride conversion, DOE will continue to incur long-term stewardship
costs at the site for such activities as monitoring groundwater and
surface water for residual contamination. Completing these activities will
bring the total cost of closing the uranium enrichment plant to over $13
billion through 2070.

  While DOE Has Made Some Progress, the Bulk of the Cleanup Remains

Since 1988, DOE has made some progress in cleaning up the contamination
and waste at Paducah, but much of the cleanup work remains to be done.
Some of DOE's accomplishments since our 2000 report as well as tasks
remaining follow:

o  	Groundwater-DOE has treated about 710 million gallons of groundwater
to remove TCE and technetium-99 and prevent off-site contamination. DOE's
pilot test of technology for removing TCE sources-large concentrations of
accumulated TCE-had promising results. However, the test removed only
about 1 percent of the estimated 180,000 gallons of TCE that had leaked
into the ground, and the system will not be fully implemented until at
least 2005, according to DOE contractor officials.6 The estimated
completion date for removing TCE from the two major sources at the site is
2010.

o  	Surface water-To prevent contaminated runoff, DOE has removed about
4,500 tons of scrap metal from the site-primarily crushed drums that
previously had contained uranium and aluminum ingots. An estimated 50,500
tons of scrap metal remains to be removed from the site. At the
north-south diversion ditch, a key wastewater conduit from the plant,
surface water discharges and runoff have been rerouted and piped to bypass
contaminated areas, and DOE has begun excavation work to remove
contaminated soil from the first of five sections of the ditch. DOE plans
to complete excavation of sections one and two by 2005. The estimated
completion date for all surface water cleanup activities is 2017.

6According to DOE, this estimate is based on the assumptions that TCE was
used at the site from 1953 to 1993 and that a fixed amount was released to
the ground each day. A high degree of uncertainty surrounds this estimate,
and the actual amount of TCE released cannot be verified.

o  	Surface soils-DOE has assessed all surface soils at the site to
identify radioactive contamination and protect plant workers. In addition,
DOE has removed 2,500 cubic yards of contaminated soils-enough to cover a
football field 17 inches deep. However, because soil contamination
represents a lower risk for exposure and migration than, for example,
groundwater, and because other work, such as removal of scrap metal, must
be performed before some soils can be reached, this category is a lower
priority. DOE estimates that a total of 90,000 cubic yards of soils will
be removed and disposed by 2015.

o  	Legacy waste-DOE has performed initial characterization of all of this
waste-the equivalent of 52,000 55-gallon barrels-for on-site storage, and
disposed of over 7,000 barrels off-site. Another 6,000 have been
repackaged and are ready for disposal. The remaining legacy waste- over
38,000 barrels-will be characterized and disposed of by 2010.

o  	DOE material storage areas (DMSA)-DOE has ranked the 160 DMSAs at the
Paducah site on the basis of their potential to contain hazardous
materials or contaminate the environment: 33 are high priority, 11 are
medium priority, and 116 are low priority. DOE has characterized and
removed materials from 9 high-and 15 low-priority DMSAs and has completed
characterization of an additional 17 high-priority DMSAs. DOE still needs
to remove materials from these 17 and characterize and remove materials in
the remaining 119 DMSAs. According to DOE officials, only 0.01 percent of
the materials characterized to date have been determined to be hazardous
waste. DOE plans to complete characterization by the end of fiscal year
2009 and dispose of all materials from the DMSAs by 2013.

o  	Burial grounds-To date, DOE's activities at the 12 burial grounds have
consisted of studies and environmental monitoring and maintenance.
Currently, DOE plans to cap-cover with a layer of soil-the burial grounds
and monitor groundwater to evaluate the effectiveness of the caps. If the
burial grounds are found to be leaking TCE or other hazardous substances,
some burial grounds may need to be excavated. Groundwater monitoring will
be ongoing through 2019.

o  	Decontamination and decommissioning of 17 buildings and structures
that are no longer used for the uranium enrichment process-DOE has
completed its assessment of the contamination and has begun removing the
infrastructure of one of the buildings. The remaining 16 are scheduled to
be completed by 2017.

After operations cease at the plant, DOE will decontaminate and
decommission the uranium enrichment process buildings and equipment. 7
During D&D, DOE will also address, as necessary, those areas where
additional studies are being done.

  Reaching Agreement on Cleanup Scope and Time Frames Remains the Key Challenge
  to Cleanup Progress

DOE's most difficult challenge has been, and could likely remain,
obtaining stakeholder agreement on the cleanup approach, including scope
and time frames. According to DOE officials, reaching agreement has been
more difficult at Paducah than at other DOE cleanup sites. For example,
from June 2001 to April 2003, DOE, EPA, and Kentucky were in dispute over
the 2001 site management plan because they could not agree on the cleanup
scope and time frames. Specifically, in response to congressional concern
about the lack of cleanup progress prior to hearings held in 1999, DOE,
Kentucky, and EPA drafted a site management plan to expedite cleanup
actions at the site. According to Kentucky officials, technical staff of
all three parties agreed to this plan. However, DOE headquarters officials
later abandoned the plan, citing budgetary constraints and their belief
that the risk did not warrant all the planned cleanup actions.

DOE and Kentucky have also had difficulty agreeing on the details of
specific cleanup projects. For example, it took the two parties 5 months
to reach agreement on the amount and type of data required to confirm that
soil from the north-south diversion ditch could be appropriately disposed
of in an onsite landfill. DOE and Kentucky also had difficulties resolving
DOE's regulatory violations at the site, which, according to DOE
officials, slowed cleanup progress.

DOE and the regulators have recently resolved a number of differences that
were delaying cleanup actions. For example, in October 2003 DOE and
Kentucky agreed to a settlement that resolved outstanding regulatory
violations related to, among other things, DOE's management of hazardous
waste at the site. In addition, all three parties are currently
negotiating approval of the 2004 site management plan, which will provide
a framework for accelerating the cleanup. While we are encouraged by these
recent events, the success of the plan, once approved, will depend on the
parties' ability to reach agreement on the scope and time frames for
individual projects as the cleanup moves forward. Furthermore,

7No schedule currently exists for full-scale D&D of the operating plant.

agreement on an accelerated cleanup plan may not preclude future disputes
between DOE and the regulators. For example, DOE and the state of
Washington have had an accelerated plan in place since March 2002, but
they only recently completed a lengthy negotiation over time frames for
disposal of mixed radioactive and toxic wastes at the Hanford cleanup
site.

In addition, as table 1 shows, the accelerated cleanup plan will be only
the latest of several cleanup plans for the site since 1999, all of which
have differed significantly in cost, scope, and time frame for cleanup and
were intended as solutions to problems at the site. For example, DOE's
Assistant Secretary for Environmental Management testified in July 2000
that a solid and effective working relationship had been established with
Kentucky and EPA and a process was in place that would lead to mutually
supported cleanup decisions.8 Ten months later, DOE was in dispute with
the regulators over the site management plan.

Table 1: DOE Estimates of Paducah Plant Cleanup Costs and Completion
Schedule

Dollars in billions

                                               Estimated Estimated completion 
            Date and source of DOE estimate cleanup cost                 date 
                October 1999 appropriations         $0.7                 2012 
                                    hearing              
            January 2000 lifecycle baseline          1.3                 2010 
              Amended fiscal year 2003 site          2.5                 2030 
                            management plan              
           Fiscal year 2004 site management          2.0                 2019 
                                       plan              

Sources: GAO and DOE.

Given DOE's past difficulties in reaching agreement with its regulators
and the details that remain to be agreed upon, it is unclear whether DOE
will be successful in accelerating the cleanup.

These are our observations to date. We will continue to further assess
DOE's progress and challenges in cleaning up the Paducah site and plan to
issue our final report in April 2004.

8July 12, 2000, testimony of Dr. Carolyn Huntoon before the House Budget
Committee Task Force on Natural Resources and the Environment.

Thank you, Senator Bunning. This concludes my prepared statement. I will
be pleased to respond to any questions that you may have.

Contact and For further information on this testimony, please contact me
at (202) 5123841. Individuals making key contributions to this testimony
includedAcknowledgments Nancy Crothers, Chris Ferencik, Kerry Dugan
Hawranek, Kurt Kershow, and Sherry McDonald.

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