Low-Level Radioactive Wastes: Department of Energy Has Opportunities to
Reduce Disposal Costs (Letter Report, 04/12/2000, GAO/RCED-00-64).

Pursuant to a congressional request, GAO reviewed the Department of
Energy's (DOE) management and disposal of its low-level radioactive
wastes, focusing on: (1) the factors that influence DOE's decisions
about the treatment, storage, and disposal of the wastes; and (2) DOE's
costs to treat, store, and dispose of these wastes and the
cost-effectiveness of DOE's disposal decisions.

GAO noted that: (1) the limited availability of disposal alternatives is
the principal factor influencing DOE's decisions about the treatment,
storage, and disposal of its low-level and mixed wastes; (2) four of
DOE's six disposal sites are restricted to disposing almost exclusively
of their own wastes because of limits on their remaining disposal
capacity and unfavorable site conditions; (3) the other two disposal
sites have relatively dry climates and enough capacity to dispose of
nearly all the low-level and mixed wastes generated at DOE's nuclear
facilities nationwide; (4) some waste-generating sites have been able to
use a commercial disposal facility, but the only facility that is
readily available can accept only wastes that are very lightly
contaminated with radioactivity; (5) on February 25, 2000, DOE adopted a
new policy that will make the disposal facilities at the Nevada Test
Site and the Hanford Site available to all of its waste-generating
sites, for both low-level and mixed wastes; (6) however, there are
roadblocks to fully implementing this policy--the states that host the
disposal facilities may oppose increases in waste disposal at the sites,
and DOE needs to obtain environmental permits from these states to
dispose of mixed wastes; (7) from fiscal year (FY) 1997 through FY 1999,
DOE spent over $700 million to prepare, treat, store, and dispose of its
low-level and mixed wastes; (8) treatment and storage costs increased
during this 3-year period while waste generators waited for DOE to issue
its new policy making the Hanford and Nevada disposal facilities
available to them; (9) when DOE fully implements this new policy, waste
managers will have at least two disposal options and may be able to
lower their waste disposal costs; (10) however, these managers currently
lack complete information and guidance from the Department for making
cost-effective disposal decisions; (11) the fees charged to waste
generators by some DOE disposal facilities are not based on all of the
facilities' costs to dispose of wastes; (12) moreover, the disposal
facilities do not use uniform cost accounts in developing their
respective fees; and (13) DOE has not developed full life-cycle costs
for its six waste disposal facilities or established guidance to ensure
that its waste managers base their disposal decisions on considerations
of cost-effectiveness for DOE's entire program rather than on each
site's annual budgetary interests.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-64
     TITLE:  Low-Level Radioactive Wastes: Department of Energy Has
	     Opportunities to Reduce Disposal Costs
      DATE:  04/12/2000
   SUBJECT:  Radioactive waste disposal
	     Nuclear waste management
	     Cost effectiveness analysis
	     Cost control
	     Hazardous substances
	     Nuclear facilities
	     Interagency relations
	     Life cycle costs
	     Environmental monitoring
	     Nuclear waste storage
IDENTIFIER:  Idaho
	     New Mexico
	     Tennessee
	     South Carolina
	     Washington
	     Nevada
	     DOE Nuclear Waste Management Program

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GAO/RCED-00-64

Appendix I: Decisions to Establish On-Site CERCLA Disposal
Facilities or Dispose of Cleanup Wastes at Existing Disposal
Facilities

32

Appendix II: Waste Volumes and Disposal Preparation Activities
and Costs for DOE's Major Waste-Generating Sites

44

Appendix III: DOE's Disposal Facilities for Low-Level and
Mixed Wastes

47

Appendix IV: Scope and Methodology

59

Appendix V: GAO Contact and Staff Acknowledgments

61

62

Table 1: Current Estimated Cost of Disposing of Low-Level
and Mixed Wastes in Planned or Operating CERCLA Facilities 38

Table 2: Summary of Fernald's Disposal Decisions for Low-Level
and Mixed Wastes, Fiscal Years 1997-99 43

Table 3: Past and Future Disposal Volumes of Low-Level and
Mixed Wastes for DOE's 20 Major Waste-Generating Sites 45

Table 4: Low-Level and Mixed Waste Disposal Preparation
Costs at 15 Major Waste-Generating Sites, Fiscal Years 1997-99 46

Table 5: Waste Disposal Volumes and Remaining Capacity at
DOE's Six Active Waste Management Disposal Facilities 48

Table 6: Waste Storage, Treatment, and Disposal Costs at DOE's
Six Active Waste Management Disposal Facilities,
Fiscal Years 1997-99 49

Figure 1: Estimated Volume of Low-Level and Mixed Wastes
for Disposal at DOE's Facilities 7

Figure 2: DOE's Major Low-Level and Mixed Waste-Generating
Sites and Disposal Facilities 9

Figure 3: Aboveground Disposal Facilities at Savannah River
and Oak Ridge 10

Figure 4: Disposal in Subsidence Craters at NTS and Mixed Waste
Disposal Trench at Hanford 12

Figure 5: Estimated Disposal Volumes and 3-Year Costs to Manage
and Dispose of Mixed and Low-Level Wastes at Six DOE Sites
With Disposal Facilities 22

Figure 6: Six DOE Disposal Sites' Costs to Store, Treat, and
Dispose of Mixed and Low-Level Wastes, Fiscal Years 1997-99 23

Figure 7: Diagram of a Typical Closure Cap for a Waste
Disposal Facility 26

Figure 8: CERCLA On-Site Disposal Facility at DOE's Fernald Site 40

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

DOE Department of Energy

EPA Environmental Protection Agency

GAO General Accounting Office

INEEL Idaho National Engineering and Environmental Laboratory

IWMF Interim Waste Management Facility

NTS Nevada Test Site

RCRA Resource Conservation and Recovery Act

RWMC Radioactive Waste Management Complex

TSCA Toxic Substances Control Act

Resources, Community, and
Economic Development Division

B-284389

April 12, 2000

The Honorable Frank Murkowski
Chairman, Committee on Energy
and Natural Resources
United States Senate

The Honorable Wayne Allard
Chairman, Subcommittee on
Strategic Forces
Committee on Armed Services
United States Senate

As the Cold War drew to a close, the Department of Energy (DOE) shifted its
focus from producing nuclear weapons to cleaning up the contaminated
facilities where it had produced them. During the 1990s, DOE spent hundreds
of millions of dollars to treat, store, and dispose of radioactive wastes
generated at over 50 of its nuclear facilities around the country. Some of
these wastes, including spent (used) fuel and liquid wastes from chemically
processing spent fuel, are highly radioactive. By volume, however, most of
DOE's radioactive wastes are classified as "low-level wastes," that is,
wastes contaminated with relatively small amounts of radioactivity. Some
low-level wastes also contain components such as lead that are hazardous in
their own right; these wastes are called "mixed wastes." DOE generates these
low-level and mixed wastes as by-products of its research and nuclear
weapons missions. Cleanup activities at contaminated facilities also produce
low-level wastes in the form of contaminated soils, debris from dismantled
buildings, and other materials. Many of these wastes can be disposed of
on-site in designated facilities. However, over the next several decades,
DOE expects to permanently dispose of about 2.1 million cubic meters of
low-level and mixed wastes at six locations where it operates disposal
facilities. This volume of waste would fill an area the size of a football
field stacked to nearly one and a half times the height of the Empire State
Building.

Concerned that DOE may not be managing and disposing of its low-level and
mixed wastes as cost-effectively as possible, you asked us to review (1) the
factors that influence DOE's decisions about the treatment, storage, and
disposal of low-level and mixed wastes and (2) DOE's costs to treat, store,
and dispose of these wastes and the cost-effectiveness of DOE's disposal
decisions.

The limited availability of disposal alternatives is the principal factor
influencing DOE's decisions about the treatment, storage, and disposal of
its low-level and mixed wastes. Four of DOE's six disposal sites--the Idaho
National Engineering and Environmental Laboratory; Los Alamos National
Laboratory, New Mexico; Oak Ridge Reservation, Tennessee; and Savannah River
Site, South Carolina--are restricted to disposing almost exclusively of
their own wastes because of limits on their remaining disposal capacity
and/or unfavorable site conditions, such as proximity to groundwater or
relatively wet climates. The other two disposal sites--the Hanford Site in
Washington State and the Nevada Test Site--have relatively dry climates and
enough capacity to dispose of nearly all the low-level and mixed wastes
generated at DOE's nuclear facilities nationwide. Access to the disposal
facilities at these two sites has, however, been limited in three ways.
First, DOE formerly directed most of its waste-generating sites to use one,
but not both, of the two facilities. Second, some of DOE's waste-generating
sites did not have access to either disposal facility because DOE stopped
granting new access to the two facilities in 1990 pending the completion of
an environmental review of its waste programs, which was recently completed.
Third, neither the Hanford nor the Nevada facility currently disposes of
mixed wastes generated at DOE sites in other states. Some waste-generating
sites have been able to use a commercial disposal facility, but the only
facility that is readily available can accept only wastes that are very
lightly contaminated with radioactivity. With such limited access to
disposal facilities, DOE's waste managers have had few opportunities to
consider costs when making disposal decisions. On February 25, 2000, DOE
adopted a new policy that will make the disposal facilities at the Nevada
Test Site and the Hanford Site available to all of its waste-generating
sites, for both low-level and mixed wastes. However, there are roadblocks to
fully implementing this policy: The states that host the disposal facilities
may oppose increases in waste disposal at the sites, and DOE may need to
obtain environmental permits from these states to dispose of out-of-state
mixed wastes.

From fiscal year 1997 through fiscal year 1999, DOE spent over $700 million
to prepare, treat, store, and dispose of its low-level and mixed wastes.
Treatment and storage costs increased during this 3-year period while waste
generators waited for DOE to issue its new policy making the Hanford and
Nevada disposal facilities available to them. When DOE fully implements this
new policy, waste managers will have at least two disposal options and may
be able to lower their waste disposal costs. However, these managers
currently lack complete information and guidance from the Department for
making cost-effective disposal decisions. The fees charged to waste
generators by some DOE disposal facilities are not based on all of the
facilities' costs to dispose of wastes. Moreover, the disposal facilities do
not use uniform cost accounts in developing their respective fees. Finally,
DOE has not developed full life-cycle costs for its six waste disposal
facilities or established guidance to ensure that its waste managers base
their disposal decisions on considerations of cost-effectiveness for DOE's
entire program rather than on each site's annual budgetary interests.
Therefore, GAO is recommending that DOE (1) develop the ability to compare
the complete costs of disposing of wastes at its own and at commercial
disposal facilities and (2) provide waste managers with guidance for
considering these costs in their waste management and disposal decisions.

DOE defines low-level waste as all radioactive waste that does not fall
within other classifications, such as high-level waste and spent (used)
nuclear fuel. Mixed waste is low-level radioactive waste with hazardous
components, such as lead and mercury. Low-level wastes can range from barely
contaminated soil and debris to waste with enough radioactivity to require
remote handling. The wastes can include items such as contaminated
equipment, protective clothing, rags, and packing material.

DOE's low-level and mixed wastes are regulated under several statutes and
authorities, depending on their content and where they are disposed of. The
Atomic Energy Act of 1954, as amended, gives DOE authority to regulate the
treatment, storage, and disposal of low-level wastes. The hazardous
components of mixed wastes are regulated by the Environmental Protection
Agency (EPA) or by a state authorized by EPA to establish its own program,
in place of EPA's, under the Resource Conservation and Recovery Act of 1976,
as amended (RCRA). For a facility that disposes of wastes containing
hazardous components, a RCRA permit issued by EPA or an authorized state
sets out, among other things, the detailed conditions under which the
facility may operate. The act provides that a facility that was in existence
in November 1980 may continue to operate under "interim status" as long as
it applies for a RCRA permit and complies with general-facility and
unit-specific standards until EPA or the host state issues or denies the
RCRA permit. EPA also oversees the on-site treatment, storage, and disposal
of both low-level and mixed wastes resulting from DOE's cleanup of
contaminated sites under the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (CERCLA).

Finally, the National Environmental Policy Act of 1969, as amended, requires
a federal agency to prepare a detailed environmental impact statement for
every major federal action that may significantly affect the quality of the
human environment. Such a statement includes a discussion of alternatives to
the action and of measures to avoid or minimize any adverse effects of the
action. In May 1997, DOE issued a final environmental impact statement
addressing its programs for managing and disposing of various types of
wastes, including low-level and mixed wastes, at all of its facilities. DOE
completed this environmental impact statement process on February 25, 2000,
for low-level and mixed wastes, by issuing its Record of Decision on key
policies for managing and disposing of these wastes.

DOE manages its low-level and mixed wastes through two separate
organizational programs within its Office of Environmental Management: The
Environmental Restoration program manages wastes from cleanup activities
under CERCLA, while the Waste Management program generally manages wastes
produced from previous operations and wastes from current mission
activities. The Environmental Restoration program's cleanup activities can
generate large volumes of wastes. Many of these wastes can be disposed of
on-site in disposal facilities developed for a CERCLA cleanup action. (App.
I discusses DOE's process for establishing on-site CERCLA disposal
facilities, including the estimated costs of constructing, operating, and
closing them.) If CERCLA cleanup wastes cannot be disposed of on-site in a
CERCLA facility, they are generally transferred to the Waste Management
program or to a commercial facility for disposal.

DOE estimates that it has or, over the next several decades, will have over
34 million cubic meters1 of low-level and mixed wastes at its sites
throughout the country; however, it expects to leave almost three-quarters
of these wastes, largely contaminated soils, in place.2 The remaining wastes
will be retrieved and disposed of in one of two ways. First, most wastes
that will be generated from cleanup activities are expected to be disposed
of in designated on-site CERCLA disposal facilities. Second, wastes from
operations and cleanup wastes that cannot be disposed of in on-site CERCLA
disposal facilities (about 2.1 million cubic meters) must be disposed of at
the six DOE sites with existing disposal facilities for low-level and/or
mixed wastes, or at a commercial disposal facility. See figure 1. This
second category of wastes is the focus of this report.

Figure 1: Estimated Volume of Low-Level and Mixed Wastes for Disposal at
DOE's Facilities

Cubic meters in millions

Note: The volume estimated for disposal in CERCLA and existing DOE disposal
facilities includes some wastes that may be disposed of commercially.

Source: GAO's presentation of data provided by DOE.

Waste Treatment, Storage, and Disposal Options

For 20 years, DOE's disposal policies, together with constraints on the
disposal facilities themselves, have limited the availability of disposal
options for DOE's waste-generating sites. Moreover, the one commercial
disposal site that is readily available to DOE can accept only low-level and
mixed wastes that contain very low concentrations of radioactivity. As a
result, with few options available, most of DOE's waste managers had little
opportunity to consider costs when making their waste disposal decisions. On
February 25, 2000, DOE issued a new waste disposal policy, making the
low-level and mixed waste disposal facilities at two of its sites--the
Nevada Test Site (NTS) and the Hanford Site--available to all of its
waste-generating sites. But before DOE can fully implement this new policy,
it will need to secure the cooperation of Nevada and Washington State.

Over 50 DOE sites generate low-level and/or mixed wastes, but 20 of these
sites are expected to generate almost all of DOE's low-level and mixed
wastes.3 DOE requires its waste-generating sites to dispose of their
low-level and mixed wastes on the site where they are generated or at
another DOE site, unless it is not practicable or cost-effective to do so.
In some instances, DOE grants exemptions from these requirements for
disposal at a commercial facility.

Six of DOE's 20 major waste generators have on-site disposal facilities. Of
the six, only Hanford and NTS can dispose of all the low-level and mixed
wastes that they themselves generate, as well as low-level wastes from other
sites. The other four sites−the Idaho National Engineering and
Environmental Laboratory, Idaho; the Los Alamos National Laboratory, New
Mexico; the Oak Ridge Reservation, Tennessee; and the Savannah River Site,
South Carolina--cannot dispose of any mixed wastes and can only dispose of
some or all of their own low-level wastes.4 Figure 2 shows the location of
DOE's 20 major waste-generating sites, including the 6 sites with disposal
facilities. (See app. II for the volumes of wastes estimated for these 20
sites.)

Figure 2: DOE's Major Low-Level and Mixed Waste-Generating Sites and
Disposal Facilities

Source: GAO's presentation of data provided by DOE.

Variation in the size and physical characteristics of the six disposal
sites, as well as in the type and design of their disposal facilities,
limits the quantities and types of wastes the facilities can dispose of. For
example, Oak Ridge and Savannah River are located in humid, rainy climates,
where contaminants can readily leach into groundwater, which is located near
the surface. Therefore, most of the active facilities for disposing of
low-level wastes at these sites are aboveground, are expensive to construct,
and have limited capacity (see fig. 3). Savannah River recently spent $1.6
million on a supercompactor to reduce waste volumes and extend the life of
one of its aboveground disposal vaults. Oak Ridge has only one aboveground
facility (expected to close in 2003), which it has reserved for its
high-radioactivity, short-lived low-level wastes. The site does not have
disposal facilities for its remaining low-level wastes.

Figure 3: Aboveground Disposal Facilities at Savannah River and Oak Ridge

Source: DOE.

Waste acceptance criteria established by DOE for each of the six disposal
sites--dictated in part by the physical characteristics of the disposal
facilities--also limit the disposal options available to DOE's
waste-managers. These criteria identify the requirements, terms, and
conditions under which the facilities will accept wastes for disposal. The
criteria specify, among other things, the allowable types and quantities of
radioactive materials; the types of containers required; and any
restrictions on specific wastes, materials, or containers. At Savannah
River, for example, an open trench can be used to dispose of only mildly
radioactive wastes, such as lightly contaminated rubble and soil.

Of the six disposal sites, Hanford and NTS afford the greatest flexibility.
They have the greatest current and potential disposal capacity and are both
large enough and remote enough to isolate their disposal facilities. Located
in arid regions where evaporation exceeds precipitation, they are positioned
high above groundwater, allowing for the use of low-cost, open trenches.
Compared with Oak Ridge and Savannah River, Hanford and NTS pose few
concerns about contaminants leaching into groundwater. NTS disposes of
low-level wastes in trenches and in subsidence craters created by previous
underground weapons testing.5 In addition, both NTS and Hanford have
facilities for disposing of mixed wastes generated on-site or in state.
Neither site currently disposes of mixed wastes from sites outside its
respective state. Figure 4 shows subsidence craters used for disposal at NTS
and one of Hanford's two mixed waste disposal trenches. Further information
about DOE's disposal facilities appears in appendix III.

Figure 4: Disposal in Subsidence Craters at NTS and Mixed Waste Disposal
Trench at Hanford

Source: DOE.

While Hanford and NTS have the characteristics and capacity needed to
dispose of nearly all the low-level and mixed wastes that DOE generates
nationwide, DOE's policies have limited the waste-generating sites' access
to the two sites' disposal facilities. For example, in 1979, when the
Department essentially stopped using commercial disposal facilities because
of uncertainties over their continued operation, DOE directed most of its
waste-generating sites to use either Hanford or NTS, but not both, for
off-site disposal. Specifically, it directed its sites with wastes from
defense-related activities to use NTS and those with wastes from
non-defense-related activities (e.g., energy research) to use Hanford.

Before DOE's waste-generating sites could ship their low-level wastes to NTS
or Hanford for disposal in accordance with DOE's 1979 policy decision, they
had to obtain approval from NTS or Hanford. NTS and Hanford based their
approval on reviews of the waste-generating sites' waste management
programs--reviews assessing the adequacy of the sites' quality assurance and
waste characterization activities and the compatibility of the sites' wastes
with NTS' or Hanford's waste acceptance criteria. By October 1990, NTS had
approved the disposal of wastes from 15 waste-generating sites, and Hanford
had approved the disposal of wastes from 26 other sites. Several sites,
including the Idaho, Oak Ridge, and Savannah River sites, had not obtained
approval from either NTS or Hanford. In October 1990, DOE stopped NTS and
Hanford from approving additional sites to avoid prejudicing the outcome of
the environmental impact statement on its waste management programs that it
had agreed to conduct as part of a legal settlement.6 The environmental
impact statement, which was issued in May 1997, was designed to demonstrate,
on a national basis, the environmental effects of alternative approaches to
managing and disposing of DOE's wastes, including low-level and mixed
wastes. As a result, since October 1990, the sites that had not obtained
approval to dispose of their wastes at NTS or Hanford before that
date−including the Idaho, Oak Ridge, and Savannah River sites--have
had to store any low-level wastes that they could not dispose of on-site.
Also, a December 1996 decision on an NTS-related environmental impact
statement limited access for the disposal of low-level wastes at NTS to
already approved waste generators until DOE completed the low-level and
mixed waste part of its waste management environmental impact statement.

Limited

While DOE sometimes authorizes disposal at a commercial facility, few
commercial facilities are in operation, and only one is a viable option for
most of DOE's waste-generating sites.7 To grant an exemption for disposal at
a commercial facility, DOE must determine that the use of commercial
disposal is cost-effective and in the "best interest" of DOE, after taking
into account, among other factors, life-cycle disposal costs, potential
liability to DOE, and the protection of public health and the environment.
Since 1988, DOE orders have authorized exemptions for the use of commercial
disposal facilities that meet specific criteria. According to DOE, its field
managers evaluate the cost-effectiveness of available disposal options. If
commercial disposal is more advantageous, the managers can approve
exemptions and ensure that proper permits are in place and notifications
completed.

Three commercial disposal facilities are in operation. One of them, operated
by US Ecology, is located at DOE's Hanford Site on land leased by DOE to the
state of Washington, which subleases it to the facility operator. Washington
and seven other western states, which formed a compact to manage commercial
low-level wastes within that compact's region, control access to this
disposal facility.8 DOE (or any waste generator not located within the
region) would have to obtain the approval of Washington, and of the compact,
before it could dispose of its low-level wastes at this commercial facility.
Another facility, Barnwell Waste Management near Savannah River, accepts a
wide range of low-level wastes, excluding mixed wastes, but is very
expensive. Over the last 3 years, only 1 of the 20 sites we contacted
reported shipping wastes to Barnwell−a small quantity of wastes too
radioactive for other commercial facilities to accept. Envirocare of Utah,
Inc. is licensed to treat and dispose of some of DOE's wastes−but only
low-level and mixed wastes that are only lightly contaminated with specific
radionuclides.9 The facility's license also restricts the chemical
properties of the wastes.

DOE has issued contracts for low-level and mixed waste disposal at
Envirocare that are available to all of its waste generators, and these
waste generators have been sending low-level and/or mixed wastes to
Envirocare since 1992. Over the last 3 years, for example, 9 of the 20 major
waste-generating sites sent low-level wastes to Envirocare, and 15 sent
mixed wastes. According to DOE's Office of Environmental Management,10 from
1992 through September 1998, DOE sites shipped 31,430 cubic meters of mixed
wastes to Envirocare for disposal--an amount equal to about 10 percent of
the nearly 300,000 cubic meters of mixed wastes DOE estimates its Waste
Management program will have to dispose of between 1998 and 2070.

Disposal Costs

The limited disposal options available to DOE's waste generators have given
them few opportunities to consider cost-effectiveness in their waste
management and disposal decisions. Generally, the waste managers we
contacted at DOE's 20 major waste-generating sites said that the policies
and other constraints described above play significant roles in their
disposal decisions. For their different waste streams, these waste managers
reported considering the availability of disposal facilities, the
facilities' waste acceptance criteria, and the costs of disposal. They also
said they consider other factors, such as transportation risks,
stakeholders' willingness to accept the wastes, and regulatory agreements
and milestones. Finally, they said, cost comparisons of the disposal
alternatives were relevant only when more than one disposal option existed.

Occasionally, when the costs of disposal seemed too high, a site's waste
manager decided against off-site disposal. For example, Lawrence Livermore
National Laboratory in California decided to continue storing radioactively
contaminated solvents when it learned that incineration would cost $1
million. Similarly, the Idaho National Engineering and Environmental
Laboratory decided not to ship some remote-handled low-level wastes off-site
when it determined that the packaging and transportation costs would be too
high.

The factors cited by DOE's waste managers were similar to those cited in a
September 1998 DOE Inspector General's report, which stated that DOE
generally did not dispose of low-level and mixed wastes as cost-effectively
as possible because factors other than cost played an integral role in
disposal decisions.11 These factors included environmental impact,
transportation routes, state equity, litigation involving disposal sites,
interaction with the public and regulators, and funding limitations. The
Inspector General estimated that, had cost been the only criterion in sites'
disposal decisions, DOE could have reduced its low-level waste disposal
costs by $5.3 million at three sites from fiscal year 1993 through fiscal
year 1996. According to the report, officials from DOE's Office of
Environmental Management were of the view that political and environmental
sensitivities sometimes outweigh simple cost comparisons in making the most
effective decisions for their programs.

Although DOE's February 25, 2000, Record of Decision designated Hanford and
NTS as the primary locations for off-site disposal of the Department's
low-level and mixed wastes, DOE may not be able to fully implement its
decision until it has met all relevant regulatory requirements, such as
those for obtaining RCRA permits from Washington and Nevada for its mixed
waste disposal facilities. In addition, the Los Alamos and Oak Ridge sites
will continue to dispose of their own low-level wastes to the degree
practicable, and the Idaho and Savannah River sites will continue to dispose
of their own low-level wastes and those from the Naval Nuclear Propulsion
Program. The nearly 3-year delay between the May 1997 issuance of the final
environmental impact statement on waste management and the February 2000
issuance of the Record of Decision naming specific sites for low-level and
mixed waste disposal occurred, according to DOE's Assistant Secretary for
Environmental Management, to fulfill DOE's commitment to have further
discussions with states, stakeholders, and tribal entities before making the
decision. DOE officials from the Environmental Management program said these
discussions were designed to help prevent political and legal problems after
the decision was issued.

Even after issuing the Record of Decision, DOE may not be able to implement
its new disposal policy immediately, and its sites may not have access to
disposal facilities for all of their low-level and mixed wastes. DOE may
still have to meet regulatory requirements that will allow the designated
disposal facilities to function as intended under the decision. For example,
before the designated mixed waste disposal facilities can dispose of mixed
wastes from other sites, they must meet the requirements of, and obtain the
permits needed under, RCRA. Hanford must obtain a RCRA permit from
Washington, NTS from Nevada. Currently, neither site has obtained the
required RCRA permit for its mixed waste disposal facility. Instead, both
facilities are operating under RCRA's interim status provisions and
standards. Interim status has enabled the two sites' facilities to dispose
of on-site mixed wastes while the sites seek to obtain RCRA permits.

DOE does not expect to begin disposing of off-site mixed wastes at Hanford
until April 2001, at the earliest, when it expects to complete an
environmental review of the management of solid wastes at the site. DOE
officials have stated that Hanford's interim status does not preclude the
disposal of mixed wastes from other DOE sites, because there is no
restriction on the source of the wastes. However, the Governor of Washington
has publicly vowed to fight DOE's plan to increase shipments of low-level
and mixed wastes to Hanford if DOE does not agree to set and meet deadlines
for cleaning up the site. For example, although Hanford's mixed waste
disposal facilities are designed to comply with RCRA's requirements--the
facilities are lined and have leachate collection systems--the state could
limit the site's disposal capacity for future trenches when it issues the
RCRA permit. Hanford officials expect the state to issue the RCRA permit
sometime after June 2002, the date the state has asked DOE to submit its
application for a permit.

NTS uses an unlined pit for disposing of mixed wastes generated on-site and
currently does not dispose of mixed wastes from sites outside the state.12
The site is limited to disposing of mixed wastes generated on-site or
elsewhere within the state of Nevada, for which DOE's Nevada Operations
Office has responsibility. NTS' mixed waste disposal facility operates under
interim RCRA status. To receive a RCRA permit from the state, the facility
must either be modified to meet certain general requirements--for example,
incorporation of liners, a leachate collection system, and a leak detection
program−or demonstrate alternative methods of meeting the RCRA
permitting requirements. The site first applied to the state for a RCRA
permit in 1992 and has revised its application several times, most recently
in November 1999. DOE does not expect the state to issue a RCRA permit for
the facility for another 1 to 2 years.

Nevada is taking the position that it has already done more than any other
state in support of the nation's nuclear weapons development and testing and
nuclear waste disposal. In addition, the state vigorously opposes DOE's
efforts to determine if Yucca Mountain, located adjacent to NTS, is suitable
for use as a geologic repository for the permanent disposal of highly
radioactive wastes. In early February 2000, for example, Nevada's state
engineer denied DOE's application for a permit to use water to build and
operate a nuclear waste repository at Yucca Mountain. Thus, we believe the
state may oppose NTS' designation as a primary disposal site for DOE's
low-level and mixed wastes, especially if DOE continues to move forward on
the Yucca Mountain project despite the state's objections.

DOE's experiences with the state of Tennessee illustrate the types of
problems the Department could face in implementing its new disposal policy.
Tennessee has blocked DOE from incinerating some mixed wastes containing
hazardous and toxic components at DOE's Oak Ridge incinerator−the only
DOE incinerator with a permit for treating radioactive wastes with certain
hazardous or toxic materials, such as PCBs.13 The incinerator destroys
essentially all of the PCBs and hazardous constituents, allowing most of the
ash to be disposed of at a commercial disposal facility. Since 1997,
Tennessee, by rejecting DOE's plans for burning wastes in the incinerator,
has effectively imposed a moratorium on the receipt of most out-of-state DOE
wastes−except for some wastes from sites formerly under Oak Ridge's
operations. The state has rejected DOE's plans because DOE (1) has not
incinerated Oak Ridge's wastes as planned, (2) has not provided Oak Ridge
with access to NTS for the disposal of existing and future low-level waste
inventories, and (3) has repeatedly reduced funding levels for Oak Ridge's
cleanup activities. With the issuance of the recent Record of Decision on
low-level waste disposal, DOE expects that Tennessee will lift its
restrictions on out-of-state wastes in the near future.

The lack of an available option for disposing of DOE's mixed wastes
(including those with PCBs that could be incinerated at Oak Ridge), the
almost 3-year delay in issuing the Record of Decision, and the additional
time that DOE may need to develop a mixed waste disposal facility could
significantly affect at least one of the DOE waste-generating
sites−Rocky Flats--that expects to finish its cleanup activities by
the end of 2006. The site continues to store a number of waste streams,
known as "orphan wastes," which do not yet have identified treatment or
disposal options because of technical and/or regulatory concerns. Site
officials said that while none of these waste streams is particularly large
on a relative scale, all must be addressed before the site can be closed.14
When we asked the officials about their management and disposal of low-level
and mixed wastes, they said they do not anticipate that mixed waste disposal
facilities at NTS or Hanford will be available in time for Rocky Flats to
meet its 2006 closure schedule.15

Information and Guidance for Making Cost-Effective Disposal Decisions

DOE spent over $700 million over the last 3 fiscal years to manage and
dispose of its low-level and mixed wastes.16 These costs, particularly for
waste storage, may have been higher than they would have been without DOE's
restrictions on disposal options−all but two waste-generating sites
have had to store their mixed wastes while awaiting DOE's policy decision on
the management and disposal of low-level and mixed wastes. Although this
decision would, if fully implemented, give all of DOE's waste managers at
least two disposal options, these managers do not have all of the
information on costs and guidance from DOE that they will need to make
cost-effective disposal decisions. DOE's waste managers track the annual
costs of treating, storing, and disposing of their sites' low-level and
mixed wastes. However, DOE has not developed estimates of the life-cycle
costs of its waste disposal facilities, including the costs to close and
monitor them.17 Therefore, these costs cannot be factored into disposal
decisions. In addition, DOE's waste managers typically base their waste
management and disposal decisions on their sites' annual budgetary
interests, without taking into account the complete costs of disposal or
determining whether decisions are cost-effective for DOE as a whole.

For fiscal years 1997 through 1999, DOE's waste-generating and disposal
sites reported spending about $705 million to manage and dispose of their
low-level and mixed wastes. This amount included about $525 million to
treat, store, or otherwise prepare these wastes for disposal and about $180
million to dispose of the wastes. At least one-fourth of the disposal costs
were spent on disposal at a commercial facility. Mixed wastes, by volume,
represent a small fraction of DOE's projected low-level wastes. Yet, of the
$378 million spent by DOE's six sites with disposal facilities, most of the
expenditures were on mixed, rather than low-level, wastes. (See fig. 5.)

Figure 5: Estimated Disposal Volumes and 3-Year Costs to Manage and Dispose
of Mixed and Low-Level Wastes at Six DOE Sites With Disposal Facilities

Source: GAO's presentation of data provided by DOE.

Moreover, as shown in figure 6, DOE spent more at its six sites with
disposal facilities over the 3-year period to treat and store its relatively
small volume of mixed wastes than it did to treat, store, and dispose of its
much larger volume of low-level wastes. Storage and treatment costs were
high for mixed wastes because four of the six sites had no disposal options
for many of these wastes. For example, Oak Ridge, which has about one-half
of DOE's mixed waste inventory, spent $53 million over 3 years to store
these wastes. In contrast, DOE spent $33 million to store low-level wastes
at all six of its disposal sites. Thus, while the majority of the costs for
mixed wastes were for treatment and storage, the majority of the costs for
low-level wastes were for disposal. (See app. III for the waste management
and disposal costs at DOE's six disposal sites.)

Figure 6: Six DOE Disposal Sites' Costs to Store, Treat, and Dispose of
Mixed and Low-Level Wastes, Fiscal Years 1997-99

Source: GAO's presentation of data provided by DOE.

In addition to the 3-year costs incurred at the 6 disposal sites, 15 of
DOE's 20 major waste-generating sites reported spending $280 million to
prepare, store, and ship their low-level and mixed wastes over the same
period.18 In fiscal year 1999, for example, DOE's Fernald site in Ohio spent
$23 million on waste characterization, repackaging, treatment, and storage
and $15 million on shipping, including large-volume rail shipments. The
waste-generating sites also reported spending a total of $47 million to
dispose of some of their wastes at commercial facilities (primarily
Envirocare). (App. II presents information on the disposal preparation
activities and costs reported by the waste-generating sites.)

With the additional disposal options that may be created by DOE's recent
Record of Decision, the costs of disposal options will become more important
to disposal decision-making. However, DOE does not have complete and
comparable information for considering these costs. For example, some of
DOE's disposal sites charge fees to the waste-generating sites. These fees
are not consistent among the disposal sites and do not include all of each
site's annual disposal costs. Moreover, DOE does not have a policy on
whether its disposal facilities should charge fees for disposal services.19
And finally, because DOE does not have adequate estimates of the total costs
to develop, operate, close, and monitor its disposal facilities--called
life-cycle costs--not all of these costs are being considered in disposal
decisions.

Four of DOE's six disposal sites currently charge disposal fees to their on-
and/or off-site waste generators. The fees, which are generally expressed in
the cost per unit of waste, are based on a portion of the costs of
regulatory compliance and operations that are funded out of the current
year's operating budget, together with estimates of waste volumes. The fees
charged by the four sites do not, however, capture complete costs, nor are
the bases for the fees charged comparable across the four sites. As a
result, waste generators do not have comparable cost information for
evaluating their waste disposal options.

The fees charged by DOE's disposal facilities are not complete because they
do not reflect all of the fixed or long-term costs that are a part of the
disposal facilities' total life-cycle costs. According to officials at some
of the disposal facilities, the fees should not include all fixed costs,
such as the costs to maintain existing disposal trenches, because DOE will
continue to incur these costs regardless of the rate of future disposal
activity. Furthermore, the DOE officials pointed out, the federal
government's annual budget process does not provide a mechanism for DOE to
set aside funds from each year's budget to cover future costs at its
disposal facilities. Therefore, according to the officials, the fees should
cover only current costs. However, commercial facilities can and do set
aside funds to cover fixed and other long-term costs, and their fees reflect
these costs. The fees that Envirocare charges, for example, are designed to
cover all of the costs of developing, operating, and closing its disposal
facility. Until DOE includes these same cost categories, it cannot compare
the costs of disposal at its own facilities with the costs at commercial
facilities.

To develop cost estimates that reflect the life-cycle costs of its disposal
facilities (as commercial facilities must do to charge disposal fees to
recover their past, present, and future costs), DOE needs to accurately
estimate the future costs of closing its existing disposal facilities and of
monitoring them over the long term. Closure requires the construction of
caps over the disposal facilities and of other barriers to prevent
deterioration or intrusion at the sites. The design of a disposal facility's
closure cap may be affected by, among other things, the final size of the
disposal facility, decisions on neighboring cleanup areas, and timing.
Officials at NTS, for example, said their closure estimates do not account
for disposal volumes beyond those predicted for the sites currently
disposing of their wastes at NTS. Hanford officials said the cost of a
closure cap over Hanford's disposal facilities would depend on whether
existing roads will have to be moved or can stay in place until the entire
site is closed and the roads are no longer needed. Figure 7 illustrates a
typical closure cap for a waste disposal facility, based on the design of
the cap for the CERCLA disposal facility at Hanford.

Figure 7: Diagram of a Typical Closure Cap for a Waste Disposal Facility

Source: DOE.

In July 1999, DOE required the operators of its six disposal sites to
develop preliminary closure plans.20 Among other things, these plans are
intended to address how the disposal facilities will be closed to achieve
long-term stability and minimize the need for active maintenance, as well as
estimate the waste volumes to be disposed of at each facility over its
expected operational life. However, estimates of the costs of closure
activities are not required.

In addition to the costs of constructing closure caps, DOE will incur what
it refers to as long-term stewardship costs after it closes its disposal
sites. DOE has not estimated these costs. Long-term stewardship covers
activities required to protect human health and the environment from hazards
remaining after cleanup is complete. Such activities include maintaining
records of contamination, maintaining and repairing closure caps, monitoring
and treating environmental contamination and precipitation run-off, erecting
and maintaining barriers, and enforcing land-use restrictions. DOE recently
reported that, for sites where cleanups do not reduce contamination to a
level suitable for unrestricted use, the costs of stewardship activities are
unknown.21 In October 1999, DOE announced a study on long-term stewardship,
which it anticipates will be issued in late fall 2000.

The Congress has expressed interest in understanding the future costs of
DOE's disposal facilities. The Senate Committee on Armed Services' report
accompanying the National Defense Authorization Act for Fiscal Year 2000
directs the Secretary of Energy to

"submit a report to the defense committees of Congress not later than March
1, 2000, on the life-cycle cost comparisons of on-site versus off-site
disposal of low-level radioactive wastes. The report shall assess the
potential costs to the federal government for long-term monitoring and
maintenance at DOE-owned disposal sites."22

DOE issued its report in March 2000. Relying on data from studies previously
prepared for other purposes, DOE estimated that the life-cycle cost to
dispose of its low-level and mixed wastes either primarily or exclusively at
its disposal facilities would slightly exceed $4 billion (in fiscal year
1998 dollars). In contrast, DOE estimated that using only commercial
disposal facilities would cost over $7 billion. The report does not provide
the projected life-cycle costs for individual disposal facilities. Thus, the
report does not provide managers at DOE's waste-generating sites or other
program officials with the kind of disposal cost data that would be useful
in making disposal decisions. DOE recognized this limitation in the report
by pointing out that, without additional and more detailed analysis, efforts
to estimate and compare the life-cycle costs of DOE and commercial
facilities remain uncertain.

DOE's decentralized management approach encourages site-level
decision-making on waste treatment, storage, and disposal. Waste managers
need consider only the effects of their decisions on their site's annual
budget and may not consider the immediate or future costs of the decisions
to the Department. Furthermore, because the costs for storage, treatment,
and disposal are interdependent, managers may−without DOE
guidance−make decisions in their site's interests that could result in
higher costs for other sites or for DOE as a whole. For example, the fees
that one of DOE's waste disposal facilities would charge a waste-generating
site would add to that site's waste management costs. Higher waste
management costs could, in turn, encourage the site to assign higher
priority in its budget to other cleanup or operational activities. By
contrast, the absence of disposal fees could encourage the same
waste-generating site to assign higher priority to waste disposal
activities.

The lack of a DOE-wide policy on charging fees for disposal services has
given the Department's existing disposal sites wide latitude in deciding
whether to charge fees and, if so, what components of their disposal costs
should be included in the fee structure. The disposal sites' fee decisions
are intertwined, however, with the disposal decisions of other DOE sites.
The fees set by some of DOE's disposal facilities are sensitive to increases
or decreases in disposal volumes. Therefore, a decision by one
waste-generating site to dispose of its wastes elsewhere could raise the
unit cost and, in turn, the fees charged to other waste-generating sites. A
site's decision to use the Envirocare disposal facility, for example, would
decrease the amount of waste disposed of at a DOE disposal facility. In such
a case, that facility might raise the fees it charges to DOE's other
waste-generating sites. In addition, according to officials at one DOE
disposal facility, a waste-generating site's use of a commercial facility
means that DOE "pays twice" for disposal services--once to maintain its
disposal facilities in support of its waste-generating sites and again to
dispose of wastes at a commercial facility. However, DOE has not assessed
the effects of the use of commerical disposal facilities on its overall
waste management and disposal costs.

According to some site officials, charging disposal fees to waste-generating
sites may, in some instances, reduce efficiencies. For example, officials at
NTS stated that their disposal fees encourage an end-of-year shipping rush
by waste-generating sites anxious to use funds by the end of the fiscal
year. The result may be higher costs both for continuing to store the wastes
at the waste-generating sites during the year and for operating
inefficiencies at the disposal facilities caused by workflow fluctuations.
Overestimating waste volumes could also result in fees that were too low to
cover a disposal facility's operating costs. During a pilot program in
fiscal year 1998, for example, Savannah River incurred a $4 million
shortfall by relying on waste generators' estimates of waste volumes that
were twice as high as the actual volumes. Conversely, underestimating waste
volumes could result in fees that were too high, producing excess
collections that might need to be returned to the generators.

Disposal decisions made at DOE headquarters and at individual DOE
waste-generating and disposal sites can affect the entire complex of nuclear
facilities. As discussed, storage costs were high, especially for mixed
wastes, during the years that DOE was preparing to designate NTS and Hanford
as its primary disposal sites. In addition, satisfying a particular
facility's waste acceptance criteria can be burdensome and costly. The Idaho
site, for example, did not have the authority to dispose of any of its
wastes at an off-site DOE disposal facility. To meet its restrictive
criteria for on-site disposal and to conserve disposal space, from August
1994 through December 1997, the site's operator shipped 5,200 cubic meters
of one type of low-level waste to a commercial facility for incineration and
ash compaction.23 The waste volume was reduced by a ratio of 400 to 1, and
the compacted ash was returned to the Idaho site for disposal. Waste
treatment, storage, and disposal decisions can also affect other on-site
activities. Without an off-site DOE disposal option, the Oak Ridge site has
not been able to remove a large pile of contaminated scrap metal that
occupies an area the state of Tennessee wants cleaned up.

Until DOE meets remaining regulatory requirements for its mixed waste
disposal facilities at NTS and Hanford, it cannot fully implement its new
policy for managing and disposing of its low-level and mixed wastes. Once
these two disposal facilities are made available, waste managers will have
new opportunities to factor the costs of alternative disposal options into
their disposal decisions, which may reduce DOE's waste disposal costs. At
present, however, DOE does not have complete, comparable, and consistent
information on the life-cycle costs of each of its six sites' disposal
facilities so that accurate cost comparisons can be made. Similarly, DOE has
not determined if it is in the Department's best interests for the disposal
sites to charge fees to waste-generating sites for disposal services.
Finally, DOE has not assessed the effects of using commercial disposal
facilities on the costs of operating its own disposal facilities. Until DOE
addresses these issues, it will not have the information it needs to make
cost-effective agencywide decisions about treating, storing, and disposing
of its low-level and mixed wastes.

To improve the effectiveness, efficiency, and economy of DOE's management
and disposal of low-level and mixed wastes, we recommend that the Secretary
of Energy develop criteria and guidance for DOE's waste managers to use in
making decisions on the best available options within DOE and at commercial
facilities for treating, storing, and disposing of their wastes.
Specifically, the Secretary should

ï¿½ develop reasonable and consistent estimates of the life-cycle costs of
each of DOE's disposal facilities, including the costs to close, monitor,
and maintain each facility;

ï¿½ decide if the operators of DOE's disposal facilities should charge
waste-generating sites fees for disposal services;

ï¿½ if charging disposal fees is the preferred policy, provide the operators
of disposal facilities with guidance on how to develop and use fees and what
those fees should include;

ï¿½ if charging fees is not the preferred policy, provide DOE's
waste-generating sites with guidance on how to compare the costs of
disposing of their wastes at each available DOE and commercial disposal
facility, including consideration of the estimated life-cycle costs of those
facilities; and

ï¿½ assess the effects of using commercial waste disposal facilities on the
costs of operating DOE's disposal facilities and develop guidance on how to
compare and consider the total costs of using both types of disposal
facilities in disposal decision-making.

We provided DOE with a draft of this report for its review and comment. DOE
stated that our report, in general, is factual and reflects several of the
disposal issues that it identified in its recent report to the Congress on
its disposal costs. DOE also provided technical clarifications that we
incorporated as appropriate.

We performed our review at the Department of Energy's headquarters in
Washington, D.C., and offices in Germantown, Maryland, as well as at the
following seven DOE sites: Hanford Site, Washington State; Idaho National
Engineering and Environmental Laboratory, Idaho; Los Alamos National
Laboratory, New Mexico; Nevada Test Site, Nevada; Oak Ridge Reservation,
Tennessee; Rocky Flats Environmental Technology Site, Colorado; and Savannah
River Site, South Carolina. We also contacted 13 other DOE waste-generating
sites to gather additional data. We conducted our review from May 1999
through April 2000 in accordance with generally accepted government auditing
standards. (See app. IV for details of our scope and methodology, including
the identification of the 20 waste-generating sites that provided
information.)

As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days after
the date of this letter. At that time, we will send copies to the Honorable
Bill Richardson, the Secretary of Energy, and other interested parties. We
will also make copies available upon request. If you or your staff have any
questions about this report, please call me at (202) 512-3841. Key
contributors to this report are listed in appendix V.

(Ms.) Gary L. Jones
Associate Director, Energy,
Resources, and Science Issues

Decisions to Establish On-Site CERCLA Disposal Facilities or Dispose of
Cleanup Wastes at Existing Disposal Facilities

Of the 8.9 million cubic meters of low-level and mixed wastes that the
Department of Energy (DOE) expects to retrieve and dispose of, about 2.1
million cubic meters will be disposed of in existing disposal facilities
operated by DOE's Waste Management program at six sites, according to DOE's
estimates. The remaining 6.8 million cubic meters of wastes--the subject of
this appendix--will be generated from cleanup activities, such as digging up
contaminated soils and dismantling buildings and other structures, conducted
under the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (CERCLA). DOE expects to dispose of the majority of
these cleanup wastes at the sites where they are generated in disposal
facilities dedicated to on-site cleanup wastes--known as CERCLA disposal
facilities.

Under CERCLA, which is administered by the Environmental Protection Agency
(EPA), a site's cleanup wastes can be disposed of at a dedicated on-site
disposal facility if on-site disposal meets public health and environmental
protection criteria tailored to the site by EPA and DOE. DOE has already
constructed a CERCLA disposal facility at Hanford and has decided to
construct CERCLA disposal facilities at the Idaho National Engineering and
Environmental Laboratory (INEEL) and Oak Ridge. Furthermore, DOE considered
developing a CERCLA disposal facility at Savannah River but decided not to
do so. These four sites also have low-level waste disposal facilities
operated by DOE's Waste Management program. In addition, DOE has constructed
a CERCLA disposal facility at the Fernald Environmental Management Project
in Ohio, the only site that does not have a Waste Management disposal
facility for low-level or mixed wastes.24 At all five of these sites, DOE
considered the comparative costs of on-site and off-site disposal when
deciding whether to build a CERCLA disposal facility.

The Congress enacted CERCLA to clean up the nation's most severely
contaminated hazardous waste sites. The act directs, among other things,
that cleanup remedies be permanent, to the maximum extent practicable, and
cost-effective. CERCLA does not require the complete elimination of risks or
of all known or anticipated effects. With respect to DOE's contaminated
sites, the Department and EPA, which is responsible for administering the
act, assess the current and potential risks to health and the environment
posed by each site's contamination to determine what remediation steps are
necessary to adequately protect against such risks. The two agencies, in
conjunction with the appropriate state regulatory agencies, then select
remedies intended to reduce the threats from radioactive, hazardous, and/or
toxic contaminants at a particular site. EPA's policy states that risks
greater than 1 in 10,000 for carcinogens and greater than 1 for
noncarcinogens are considered serious enough to require cleanup action.
CERCLA states that cleanups must meet "legally applicable" or "relevant and
appropriate" requirements, including applicable or relevant federal and
state environmental regulations.

CERCLA disposal facilities are generally designed to take large quantities
of soil and debris. The facilities are built with liners, water collection
systems, and leak detection systems. These facilities do not require a
permit under the Resource Conservation and Recovery Act (RCRA). Because RCRA
permits are not required for CERCLA disposal facilities, a CERCLA disposal
facility can accept only CERCLA cleanup wastes (low-level and mixed wastes)
from the site where the facility is located. It cannot accept either cleanup
wastes from another site or any wastes that are not cleanup wastes. A CERCLA
disposal facility can be used only for the disposal of wastes that are
within the waste acceptance criteria set out in the Record of Decision for
the facility. If one or more types of cleanup waste do not meet these
criteria, those wastes must be disposed of at one of DOE's Waste Management
disposal facilities or at a commercial disposal facility, such as
Envirocare.

With Low-Level Waste Disposal Facilities

DOE considered developing CERCLA disposal facilities at four sites that have
low-level waste disposal facilities operated by the Department's Waste
Management program. For each of these sites--Hanford, INEEL, Oak Ridge, and
Savannah River--DOE's decision-making included an analysis of the estimated
costs for on-site and off-site disposal of the site's cleanup wastes.
According to DOE, it also considered factors such as the quantity of cleanup
wastes requiring disposal and site-specific features, such as proximity to
the public.

The Hanford Site's CERCLA disposal facility has been in operation since July
1996 and, as of May 1999, had disposed of almost 700,000 cubic meters of
cleanup wastes. The facility is being used primarily to dispose of
contaminated soils and debris removed from cleanup areas near the Columbia
River. The facility is located relatively high above groundwater and is in
the same general area as DOE's low-level and mixed waste disposal facilities
and the US Ecology facility, which disposes of commercially generated
low-level wastes. DOE estimated that the life-cycle cost--for the
construction, operation, and eventual closure--of Hanford's CERCLA disposal
facility would be about $275 million.25 This estimate includes about $45
million to close the facility and $7.5 million--$250,000 per year for 30
years--to monitor and maintain the closed facility. The estimate does not
include about $160 million projected as needed to transport wastes from
around the Hanford Site itself to the disposal facility.

According to DOE, the unit cost to dispose of cleanup wastes at the Hanford
CERCLA facility, excluding on-site transportation costs, is about $63 per
cubic meter. In contrast, DOE estimated that Envirocare's fees for disposing
of mixed wastes would range from about $416 to $660 per cubic meter
(depending on the condition of the wastes). To dispose of low-level wastes,
some of DOE's waste generators paid Envirocare fees of about $207 per cubic
meter of waste in 1999. (These commercial disposal fees do not include the
costs of shipping the low-level and mixed wastes to Envirocare's Utah
facility.) Also in fiscal year 1999, DOE's low-level waste disposal facility
at Hanford charged the DOE waste-generating sites authorized to use that
facility $496 per cubic meter or more, depending on the types of wastes, to
dispose of their wastes.

While DOE has decided to develop a CERCLA disposal facility at INEEL, it has
not begun constructing the facility. The design of the planned facility,
according to DOE, will (1) meet RCRA's substantive standards for the
treatment and disposal of mixed wastes, (2) provide the "best available
technology" for protecting the sole-source Snake River Plain Aquifer beneath
the site, and (3) accommodate the types of wastes that will be generated
throughout INEEL by CERCLA remediation activities. These wastes include
low-level and mixed wastes, as well as limited quantities of wastes with
toxic and other substances regulated under the Toxic Substances Control Act
of 1976 (TSCA). In September 1998, the Department estimated that the planned
low-level and mixed waste treatment and disposal facility, which would have
a total capacity of about 390,000 cubic meters of wastes, would cost about
$239 million to construct, operate, close, and then monitor. This estimate,
equal to about $613 per cubic meter of waste, does not include the cost of
transporting the wastes to the treatment facility but does include the cost
of transportation from the treatment facility to the disposal facility. DOE
also estimated that treating and disposing of these wastes at the Envirocare
facility would cost about $1,854 per cubic meter. The scope of DOE's cost
estimate study did not include estimates of the cost to dispose of these
wastes at the existing disposal facilities for low-level and mixed wastes at
Hanford and the Nevada Test Site (NTS).

At Oak Ridge, as at INEEL, DOE plans to develop a CERCLA disposal facility
for the site's mixed and low-level cleanup wastes but has not yet
constructed the facility. DOE estimated that a facility designed to dispose
of 273,000 cubic meters of wastes would cost about $101 million ($370 per
cubic meter),26 while a facility designed to dispose of 1.3 million cubic
meters of wastes would cost about $170 million ($131 per cubic meter). Each
estimate includes the costs of constructing, operating, and closing a
proposed facility and then providing surveillance and maintenance of the
facility for 100 years. Neither estimate includes the costs of retrieving
and transporting wastes to the proposed facility. The estimated closure
costs, depending on the volume of wastes disposed, range from $12 million to
$59 million. The planned facility would be constructed above groundwater and
would have leachate detection and collection systems. Alternatively, DOE
considered the costs of disposing of the majority of these wastes at the
Envirocare facility and of storing wastes that could not be disposed of at
Envirocare at Oak Ridge until another disposal option became available. DOE
estimated that this alternative would cost about $135 million for disposing
of 216,000 cubic meters of wastes ($625 per cubic meter) at Envirocare and
about $456 million for disposing of 1 million cubic meters of wastes ($456
per cubic meter) at Envirocare. Transportation costs accounted for about 32
percent of each of these cost estimates for disposal at Envirocare.

Finally, DOE considered developing a CERCLA disposal facility at the
Savannah River Site for low-level--but not mixed--cleanup wastes in the form
of radioactive soils and debris. DOE rejected that option as too expensive
for disposing of the limited quantity of qualifying wastes. In a May 1997
report addressing the potential for developing an on-site CERCLA disposal
facility or shipping wastes off site, DOE and its operating contractor at
the site identified 20 separate areas on the site with low-level cleanup
soils and debris.27 DOE determined which of these 20 areas' soils and debris
were candidates for cleanup and consolidation in an on-site CERCLA disposal
facility. The criteria used to determine whether the wastes should be
cleaned up and consolidated were the location and future use of each area
and the extent to which cleanup and consolidation would (1) reduce the area
of the site that must remain restricted because of radioactivity, (2) reduce
the site's risks, and (3) contribute to increased groundwater contamination.
DOE concluded that the wastes in 16 of the 20 areas should not be retrieved,
primarily because of their proximity to nuclear fuel production reactors,
nuclear materials separation facilities, or underground tanks containing
high-level radioactive wastes.

DOE also determined that wastes in the remaining four areas at Savannah
River, estimated to contain about 62,400 cubic meters of soil and debris,
were candidates for retrieval and disposal in existing on-site or off-site
disposal facilities. On the basis of its contractor's modeling of
groundwater, DOE concluded that a large volume of the wastes would require
treatment prior to disposal in an on-site CERCLA facility. DOE also
concluded that the wastes in these four areas do not warrant the
construction of a new on-site disposal facility for contaminated soil and
debris. Therefore, DOE considered disposing of at least some of the
low-level wastes from the four areas in the site's existing trenches or
vaults, which were developed for the disposal of low-level wastes, and
disposing of other wastes at NTS and/or Envirocare. According to the
operating contractor's May 1997 report, excavating and then disposing of
these wastes on-site in existing trenches or vaults would cost about $348
($357 in 1999 dollars) or $1,435 ($1,473 in 1999 dollars), respectively, per
cubic meter.28 In contrast, excavating, packaging, transporting, and
disposing of the wastes at NTS or Envirocare would cost about $1,365 or
$467, respectively, per cubic meter. Savannah River now plans to ship
approximately 4,250 cubic meters of low-level soil and debris from CERCLA
cleanup actions to Envirocare for disposal. This plan is designed to
segregate CERCLA wastes from other types of low-level wastes and maintain
clear regulatory lines of authority. The shipment is scheduled to begin in
the summer of calendar year 2000 if sufficient funding is available. Also,
according to DOE, the costs to treat these wastes, combined with the on-site
disposal costs, made off-site disposal cost-effective.

In February 2000, DOE's Office of Environmental Restoration issued a report
assessing the expected life-cycle costs of the Hanford, INEEL, and Oak Ridge
CERCLA disposal facilities, the Fernald facility (discussed below), and the
two CERCLA facilities where DOE disposes of uranium mill tailings. Table 1
presents the estimated disposal volumes and unit costs for the four disposal
facilities.

Table 1: Current Estimated Cost of Disposing of Low-Level and Mixed Wastes
in Planned or Operating CERCLA Facilities

 Volume in cubic meters

 CERCLA facility             Estimated    Estimated     Estimated cost per
                             waste volume total cost    cubic meter
 Hanford Site                4,370,000    $275 million  $63
 INEEL (planned)             356,020      $148 million  $377
 Oak Ridge Reservation
 (planned)                   840,000      $216 million  $183
 Fernald Environmental
 Management Project          1,900,000    $259 million  $136

Source: GAO's presentation of data from DOE's Cost Engineering Report on
Environmental Restoration Waste Disposal Facilities (Feb. 2000).

Fernald Site

Unlike the other sites discussed in this appendix, DOE's Fernald
Environmental Management Project (Fernald) did not already have a facility
for disposing of low-level and/or mixed wastes from nuclear operations when
the Department developed an on-site CERCLA disposal facility. DOE is
cleaning up the Fernald site and has established a goal of completing the
cleanup by 2006. The cleanup has generated both low-level and mixed wastes,
some of which will be disposed of in the on-site CERCLA facility and others
of which must be disposed of off-site. After considering several
alternatives for treating and disposing of the site's low-level and mixed
cleanup wastes, including estimates of the costs of each alternative, DOE
decided, in February 1996, to develop a CERCLA disposal facility on-site.
Low-level wastes that do not meet the criteria for disposal in this facility
are disposed of at NTS or Envirocare. Mixed wastes that do not meet criteria
for disposal at Fernald or Envirocare are stored until DOE can dispose of
these wastes at NTS.29

Fernald's project, under CERCLA, is to clean up DOE's former Feed Materials
Production Center, a uranium metal production facility that operated on-site
from the early 1950s until 1989. The 1,050-acre Fernald site is located
about 18 miles northwest of Cincinnati, Ohio. The land adjacent to Fernald
is primarily devoted to agriculture and recreation. Residential areas are
concentrated northeast of Fernald, and an estimated 23,000 residents live
within a 5-mile radius of the site.

In 1986, DOE and EPA entered into a Federal Facility Compliance Agreement,
in which DOE agreed to comply with various federal and state laws, including
RCRA and CERCLA. In 1991, DOE and EPA signed a final consent agreement
establishing revised milestones for completing required studies and
activities for managing hazardous wastes. Subsequently, in 1996, DOE, its
operating contractor, and Ohio's Environmental Protection Agency signed an
agreement that, among other things, integrated and streamlined the
remediation and closure requirements under CERCLA and RCRA. The agreement
recognized that under CERCLA, EPA oversees the cleanup of the site's
radioactive wastes while under RCRA, the state of Ohio regulates the
treatment, storage, and disposal of the site's hazardous wastes. The
agreement required DOE and its contractor to prepare one remediation plan to
comply with the requirements of both acts. Under CERCLA, the Fernald site
has been divided into five "operable units" for cleanup. The on-site CERCLA
disposal facility is designed for cleanup wastes generated from operable
units 2, 3, and 5. The formal decision to develop the on-site disposal
facility was made as part of the plan for remediating operable unit 5, which
also encompasses the treatment of contaminated water contained in the Great
Miami Aquifer under the Fernald site.

The Fernald on-site disposal facility, which began receiving wastes in late
1997, has the capacity to dispose of about 1.9 million cubic meters of
contaminated soil and debris generated through environmental restoration and
facility decontamination and decommissioning activities. (See fig. 8 for a
picture of the Fernald disposal facility.) Soil and soil-like material will
make up about 85 percent of the wastes disposed of in the facility, while
the remainder will consist of debris from the demolition of the site's
buildings. The disposal facility covers about 140 acres and includes the
disposal area, which consists of a series of disposal cells, and a buffer
zone around the disposal area. When all of the planned disposal cells have
been constructed, the facility will be about 800 feet wide, 3,700 feet long,
and 65 feet high. The facility will be reserved for the disposal of wastes
generated during the cleanup at Fernald and will remain under federal
control after the cleanup has been completed and the disposal facility
closed. The primary engineering features of the facility include a
5-foot-thick multilayered liner system under the waste materials, a leak
detection system beneath the primary liner, and an 8.75-foot-thick
multilayered cap system, to be constructed over the waste materials upon
closure. The facility is located adjacent to the site's former production
area, which has the best geology on the Fernald site for protecting the
sole-source Great Miami Aquifer. Wells for monitoring water in this aquifer,
which serves over 600,000 people in southwestern Ohio, are also part of the
facility.

Figure 8: CERCLA On-Site Disposal Facility at DOE's Fernald Site

Source: DOE.

In one of five CERCLA Records of Decision documenting the selection of
various remedial actions for the Fernald Site, DOE elected to excavate
contaminated soil at the site, place the soil in an on-site disposal
facility, and restore the Great Miami Aquifer to its full beneficial use. In
reaching this decision, DOE compared the estimated costs of eight on-site
and off-site disposal options (including one "no action" option). DOE also
compared the eight options to assess their overall protection of human
health and the environment; attainment of "applicable or relevant and
appropriate" environmental requirements; long-term effectiveness and
performance; reduction of toxicity, mobility, or volume through treatment;
and feasibility of implementation.

DOE expressed the estimated cost of each alternative in terms of the
"present worth" of the cost to achieve a range of risks embodied in EPA's
goal for reducing the threat from carcinogenic contaminants. For example,
DOE estimated that the preferred alternative of constructing the on-site
CERCLA disposal facility and related actions to clean up the underlying
aquifer would cost from $606 million, to achieve EPA's least protective
standard for acceptable risk to individuals, to $658 million, to achieve
EPA's most protective standard. All other on-site and off-site alternatives
affording similar levels of protection were estimated to cost at least $731
million. For example, the estimated cost of excavating and disposing of all
soils and sediments at one or more off-site facilities, in terms of present
worth, was over $1 billion and $4 billion, respectively, to achieve EPA's
least protective and most protective levels of acceptable risk to
individuals. DOE estimates that the cost to develop, operate, close, and
provide long-term stewardship of the on-site disposal facility will total
about $267 million.

The criteria in the Record of Decision for determining which wastes may be
disposed of in Fernald's on-site disposal facility and which wastes must be
disposed of off-site are based on achieving compliance with health and
environmental standards established in federal and state environmental laws.
Under CERCLA, on-site cleanup facilities are not required to obtain any
federal, state, or local permits. Although permits are not required, EPA's
National Contingency Plan30 requires that CERCLA activities meet the
technical requirements of RCRA and other federal and state environmental
requirements that are "applicable" or "relevant and appropriate."
Accordingly, the consent agreement between EPA and DOE exempts the
Department from permit requirements established in statutes such as RCRA. At
the same time, the agreement specifies that DOE must satisfy all federal and
state standards, requirements, criteria, or limitations that would have been
included in any permit otherwise required. The Fernald CERCLA disposal
facility was designed to meet the requirements of RCRA for hazardous waste,
of Ohio's regulations for solid waste, and of the Uranium Mill Tailings
Remedial Action Program for radioactive waste.

The Fernald CERCLA disposal facility's waste acceptance criteria include
limits on concentrations of specific radioactive elements and chemicals,
limits on the size of contaminated materials, and a list of prohibited
items. These criteria are stringent because they were developed to provide
long-term protection for the Great Miami Aquifer, which is the sole source
of local drinking water. Furthermore, according to DOE's Record of
Decision--agreed to by EPA and the state of Ohio--the design of the CERCLA
disposal facility and the waste acceptance criteria protect human health to
risk levels that are within the range specified by the National Contingency
Plan.

DOE has disposed of over 260,000 cubic meters of cleanup wastes at the
Fernald Site's CERCLA disposal facility since its opening in late 1997. In
addition, DOE has shipped over 56,000 cubic meters of low-level and mixed
cleanup wastes that did not meet the criteria for on-site disposal to
disposal facilities at NTS and Envirocare. Mixed wastes that do not meet the
criteria for on-site disposal are either treated and disposed of at
Envirocare or stored on-site until they can be disposed of at NTS or
Hanford.

We included Fernald in our survey of DOE's 20 largest generators of
low-level and mixed wastes, and DOE's Ohio Field Office−which is
responsible for overseeing the site−provided information on the
volumes of low-level and mixed wastes requiring disposal and the costs of
their disposal. Waste managers at the site also provided information on
their disposal options and disposal decision-making process.

According to DOE's Ohio Field Office, decisions about disposal are based on
a combination of technical factors, cost, and input from stakeholders
(regulators and the local community). Wastes from the site's cleanup that
meet the criteria for on-site disposal are disposed of in the CERCLA
facility. Wastes that exceed these criteria are sent off-site for disposal
at either NTS or Envirocare, if possible. Which of these two facilities is
chosen depends on their waste acceptance criteria, disposal costs,
utilization rates and disposal capacities, and regulators' and citizens'
concerns. On the basis of these factors, according to DOE's Ohio Field
Office, for fiscal years 1997 through 1999, the Fernald site disposed of its
low-level wastes and some of its mixed wastes as shown in table 2.

Table 2: Summary of Fernald's Disposal Decisions for Low-Level and Mixed
Wastes, Fiscal Years 1997-99

 Volume in cubic meters and price in dollars per cubic meter
 Type of     Disposal                                           Disposal
 waste       facility       Reason location selected   Volume   price

 Low-level   Fernald        On-site disposal least     261,330  $131
                            expensive
                            Accepted bulk wastes that
                            did not meet criteria for
 Low-level   Envirocare     on-site disposal;          35,091   207
                            economical rail transport
                            available
                            Preferred choice for bulk
 Low-level   NTS            waste containers (in 1997  17,342   265
                            before on-site disposal
                            facility began operating)
                            Accepted wastes in bulk
 Low-level   NTS            containers that did not    3,365    265
                            meet criteria for on-site
                            disposal
                            Only choice for disposal
 Mixed       Envirocare     of mixed wastes that do    459      777
                            not meet criteria for
                            on-site disposal

Source: GAO's presentation of data provided by DOE.

As the table indicates, the estimated cost per cubic meter for the on-site
disposal of low-level wastes in the CERCLA facility at Fernald was about
half as much as Fernald paid to dispose of low-level wastes at NTS or
Envirocare. Moreover, most of the wastes disposed of by the Fernald site
over the 3-year period were disposed of on-site. Furthermore, the
availability of rail transportation for shipments of bulk low-level wastes
to Envirocare resulted in the lowest off-site disposal costs for Fernald's
low-level wastes. DOE does not have direct rail access to NTS. Finally, the
cost of off-site commercial disposal for mixed wastes was approximately
three times as great as the cost of either commercial or DOE off-site
disposal of low-level wastes.

Waste Volumes and Disposal Preparation Activities and Costs for DOE's Major
Waste-Generating Sites

According to DOE's May 1997 Final Waste Management Programmatic
Environmental Impact Statement, 20 of the Department's waste-generating
sites are expected to generate about 99.6 percent of its low-level and mixed
wastes, taking into account its existing inventories and anticipated
generation for a 20 year period. These 20 sites will generate most of the
2.1 million cubic meters of wastes that DOE estimated, in a 1998 report, may
be disposed of at its six sites that operate disposal facilities for
low-level and/or mixed wastes.31

We obtained more current estimates of waste volumes from DOE's 20 major
waste-generating sites. (See table 3.) These estimates may differ from DOE's
1998 estimates if the generators made different assumptions or included
volumes of wastes that will be disposed of commercially. According to these
20 waste-generating sites, they have already disposed of over 1.9 million
cubic meters of low-level wastes and over 46,000 cubic meters of mixed
wastes. Although cleanup wastes are being generated and disposed of in the
existing on-site CERCLA disposal facilities at Hanford and Fernald (and are
expected to be disposed of at INEEL and Oak Ridge), these wastes, except for
those from Fernald, are not included in the table.

Table 3: Past and Future Disposal Volumes of Low-Level and Mixed Wastes for
DOE's 20 Major Waste-Generating Sites

 Volume in cubic meters
               Low-level waste                Mixed waste

 DOE site      Disposal   Disposal  Total     Disposal   Disposal Total   Total
               completed  planned             completeda planned
 Argonne
 National
 Laboratory    886        623       1,509     25         62       87      1,596
 East, IL
 Bettis Atomic
 Power         12,254     3,642     15,896    Less than 127       27      15,923
 Laboratory, PA
 Brookhaven
 National      1,403      b         1,403     20         b        20      1,423
 Laboratory, NY
 Fernald
 Environmental
 Management    439,017    2,173,271 2,612,288 5,011      14,855   19,866  2,632,154
 Project, OH
 Hanford Site,
 WAc           495,049    128,707   623,756   182        72,589   72,771  696,527
 INEEL, ID     98,500     26,000    124,500   82         1,440    1,522   126,022
 Knolls Atomic
 Power         5,763      6,267     12,030    Less than 181       81      12,111
 Laboratory, NY
 Lawrence
 Livermore
 National      5,641      6,350     11,991    1,959      1,217    3,176   15,167
 Laboratory, CA
 Los Alamos
 National      223,400    273,000   496,400   b          b        b       496,400
 Laboratory, NM
 Mound Plant,
 OH            54,798     103,321   158,119   Less than 119       19      158,138

 NTS, NVd      243,000    119,983   362,983   270        Less     270     363,253
                                                         than 1
 Oak Ridge
 Reservation,  4,253      579,191   583,444   20,526     114,471  134,997 718,441
 TN
 Paducah
 Gaseous
 Diffusion     b          11,000    11,000    b          5,600    5,600   16,600
 Plant, KY
 Pantex Plant,
 TX            3,070      b         3,070     213        b        213     3,283
 Portsmouth
 Gaseous
 Diffusion     978        14,387    15,365    2,033      8,717    10,750  26,115
 Plant, OH
 RMI Titanium
 Company, OH   44         10,477    10,521    Less than 1735      735     11,256
 Rocky Flats
 Environmental
 Technology    9,424      157,436   166,860   16,499     45,146   61,645  228,505
 Site, CO
 Sandia
 National
 Laboratories, 2,047      4,220     6,267     29         660      689     6,956
 NM
 Savannah River
 Site, SC      353,911    407,000   760,911   0          6,216    6,216   767,127
 West Valley
 Demonstration 11,988     56,634    68,622    4          283      287     68,909
 Project, NY
 Total         1,965,426  4,081,509 6,046,935 46,853     272,118  318,971 6,365,906

Note: The volumes of wastes in this table were provided by the 20 sites in
1999.

aSince Hanford and NTS have the only disposal facilities for on-site mixed
wastes and currently cannot dispose of mixed wastes from other sites, any
other sites that disposed of mixed wastes did so at a commercial facility.

bInformation was not readily available from this site.

cThe quantities for Hanford include only DOE wastes; they exclude Department
of Defense wastes disposed of at the site.

dThe amounts disposed of at NTS are approximate. In addition, the total
volume of low-level and mixed wastes that could be disposed of at NTS
depends on future decisions on regulatory, technical, or management issues
(e.g., final negotiated soil cleanup levels, funding gaps in site baseline
budgets, etc.).

Source: GAO's presentation of data provided by DOE.

1997-99

Fifteen of DOE's 20 major waste-generating sites reported incurring total
costs of about $280 million to prepare low-level and mixed wastes for
disposal. For the most part, the costs of waste preparation at the six sites
with low-level and/or mixed waste disposal facilities were either reported
as part of the disposal facilities' costs (see app. III) or were not readily
available. INEEL officials identified approximately $4 million in waste
preparation costs that were in addition to the costs reported for the site's
waste disposal facility. These costs for INEEL are included in the total
costs of the 15 major waste-generating sites' activities presented in table
4.

Table 4: Low-Level and Mixed Waste Disposal Preparation Costs at 15 Major
Waste-Generating Sites, Fiscal Years 1997-99

                            Dollars in thousands

 Disposal preparation activity      Costs for       Costs for
                                low-level wastes   mixed wastesTotal costs
 Storage                       $30,446             $42,408     $72,854
 Treatment                     23,171              44,897      68,068
 Shipping                      43,566              7,480       51,046
 Assay/characterization        20,626              18,435      39,061
 Repackaging                   5,928               2,650       8,578
 Other                         28,266              12,245      40,511
 Total                         $152,003            $128,115    $280,118

Source: GAO's presentation of data provided by DOE.

DOE's Disposal Facilities for Low-Level and Mixed Wastes

DOE has six sites with active disposal facilities for low-level and/or mixed
wastes generated from past and current mission operations and cleanup wastes
that cannot be disposed of in on-site CERCLA disposal facilities. DOE
projects that up to 2.1 million cubic meters of low-level and mixed wastes
will be disposed at these six locations. All six sites are located where DOE
and its predecessor agencies generated low-level and mixed wastes through a
variety of activities, from producing nuclear weapons, to operating nuclear
reactors, to conducting nuclear research. The sites historically disposed of
their low-level wastes in burial grounds, many of which are currently
undergoing environmental cleanup and remediation. Over time, and with
advances in technology and environmental concerns, the sites' disposal
activities have evolved into the current disposal facilities. These active
facilities manage the sites' wastes with the intent to contain the
contaminated materials and protect human health and the environment. Table 5
lists the six active disposal facilities, the volumes of wastes disposed of
at each facility, and each facility's current capacity for additional waste
disposal.32

Table 5: Waste Disposal Volumes and Remaining Capacity at DOE's Six Active
Waste Management Disposal Facilities

 Volume in cubic meters

                                        Disposed waste
                                        volume
                                                             Remaining
 Disposal facility    DOE site          Low-level   Mixed    disposal
                                        waste       waste    capacity
 Hanford 200 Area
 Low-Level Burial     Hanford Site      380,500     182      934,000
 Groundsa
 Radioactive Waste
 Management Complex   INEEL             98,500      b        64,300
 Area G of Technical  Los Alamos
 Area-54 Material     National          223,400     b        273,000
 Disposal Area        Laboratory
 Radioactive Waste
 Management Sites     NTS               551,000     8,300    2,400,000
 Areas 3 and 5
 Interim Waste        Oak Ridge
 Management Facility  Reservation       3,640       b        1,760
 E-Area Low-Level
 Waste and Saltstone  Savannah River    29,911      b        133,300
 Disposal Facilities  Site
 Total                                  1,286,951   8,482    3,806,360

Note: Volumes and disposal capacities were provided by the sites in 1999.

aThe quantities for Hanford include only DOE wastes; they exclude Department
of Defense wastes disposed of at the site.

bNot applicable.

Source: GAO's presentation of data provided by DOE.

Table 6 shows the storage, treatment, and disposal costs at the six sites
with active Waste Management disposal facilities from fiscal year 1997
through fiscal year 1999.

Table 6: Waste Storage, Treatment, and Disposal Costs at DOE's Six Active
Waste Management Disposal Facilities, Fiscal Years 1997-99

 Dollars in thousands
 Waste type                   Los               Oak      Savannah
 and activity Hanford  INEELa Alamos   NTS      Ridge    River     Total
 Low-level
 waste
 Disposal     23,034   5,430  7,723    38,124b  9,692    8,506     92,509
 Treatment    0        3,608  2,515    0        3,047    14,584    23,754
 Storage      0        114    1,525    274      23,813   7,212     32,938
 Total        23,034   9,152  11,763   38,398   36,552   30,302    149,201
 Mixed waste
 Disposal     7,634    3,399  12,523   b        16,567   89        40,212
 Treatment    9,209    25,324 4,698    2,124    45,902   13,811    101,068
 Storage      23,111   4,026  2,776    36       52,995   4,715     87,659
 Total        39,954   32,749 19,997   2,160    115,464  18,615    228,939
 Grand total  62,988   41,901 31,760   40,558   152,016  48,917    378,140

Note: Columns may not total because of rounding.

aINEEL provided data only for fiscal years 1998 and 1999.

bNTS combines its costs for disposing of a small amount of mixed waste with
its costs for low-level waste disposal.

Source: GAO's presentation of data provided by DOE contractors managing the
disposal facilities.

The six sites with active Waste Management disposal facilities differ in
ways that affect the types and amounts of waste they can accept, as well as
their disposal costs. The following brief descriptions of the sites and
their facilities highlight any significant issues or features.

Located in southeastern Washington State, DOE's Hanford Site occupies 560
square miles of semi-arid land bounded on one side by the Columbia River.
This nuclear weapons production site, established in 1942, fabricated
nuclear fuel and operated nine reactors and five chemical separation
facilities over a period of almost 50 years. The legacy of these
activities−over 2,300 waste sites and contaminated facilities,
including 177 underground storage tanks containing high-level nuclear
waste−is now the focus of a massive DOE cleanup effort. Under DOE's
current plans, cleanup activities are expected to continue at Hanford
through 2046.

Hanford's Active Low-Level Burial Grounds covers about 1 square mile in the
middle of the Hanford Site. It includes eight active low-level burial
grounds that are dispersed among other cleanup sites on a plateau
approximately 200 feet above the water table. The site's average annual
rainfall (about 6 inches) is less than the amount of evaporation, thus
limiting the downward migration of contaminants. However, the Columbia River
is about 10 miles away, and the city of Richland, Washington, lies
downstream about 25 miles from the burial grounds. Stakeholders in the
community take an interest in Hanford's operations largely because of the
Columbia River's importance to agriculture and the life cycle of salmon.

Each burial ground comprises a number of trenches, which will be filled with
wastes contained, for the most part, in wooden boxes or drums. Most of the
trenches are used to dispose of DOE's wastes, but one is reserved for
contaminated reactors from naval vessels operated by the Department of
Defense. These reactors will be buried 15 to 20 feet below the surface. Two
RCRA-compliant trenches are designed for mixed waste disposal and have
liners and rainwater collection systems. Until recently, the site used these
trenches to store mixed wastes, but in September 1999, it began to operate
one of the trenches as a mixed waste disposal facility, collecting leachate
in accordance with RCRA. However the state of Washington has not issued a
final RCRA permit for the site's mixed waste disposal facility. According to
site officials, the permit, when issued, could limit the site's capacity for
mixed waste disposal in future trenches. The site has developed performance
assessments that demonstrate its disposal operations are protective of human
health and the environment.

The Hanford Low-Level Burial Grounds can accept virtually all types of
low-level wastes, including remote-handled wastes that are transported and
buried in containers with extra radioactive shielding. The burial grounds
also have approximately 38,000 containers of transuranic wastes,33 which
site officials plan to recharacterize. They expect that after the
recharacterization, about half of these wastes will be reclassified as
low-level and mixed wastes, suitable for on-site disposal. In 1998, DOE
estimated that Hanford had the capacity to dispose of all low-level wastes
projected for disposal at the facility for at least the next 70 years.
However, this projection predated the February 2000 Record of Decision
designating Hanford as a primary disposal facility for DOE's low-level and
mixed wastes. The site's ability to dispose of projected volumes of mixed
wastes depends on the terms of the final RCRA permit issued by the state.

INEEL occupies about 890 square miles of dry, cool desert in southeastern
Idaho. Originally established as the National Reactor Testing Station, the
site once had as many as 52 active nuclear reactors. It also reprocessed
spent nuclear fuel for decades. In addition to the wastes generated from
these activities, large volumes of transuranic and low-level wastes from the
Rocky Flats Plant were buried or stored at INEEL. Currently, the site's
primary missions include storing spent nuclear fuel and treating and
eventually disposing of transuranic wastes off-site.

The site's Radioactive Waste Management Complex (RWMC) covers roughly 144
acres and is used for the interim storage of transuranic wastes and the
disposal of low-level wastes. The four active low-level waste disposal pits
are conjoined and cover about 6 acres adjacent to the transuranic waste
storage areas. The pits are also adjacent to previously filled waste burial
grounds managed by the Environmental Restoration program. As a result, the
disposal facility's closure plans must be coordinated with these other
activities. The site is fairly remote and dry (the average annual rainfall
is 9 inches), with the groundwater about 700 feet below the surface.
However, the site is located above a sole-source aquifer that empties into
the Snake River. Downstream populations depend on the river and the aquifer
for agriculture and drinking water, making waste management activities at
the complex a political issue.

RWMC disposes primarily of low-level wastes in containers such as large
(primarily 4- x 4- x 8-foot) wood and metal boxes, which are stacked 20 feet
high in the unlined pits. To conserve disposal capacity and to increase the
long-term stability of the disposal facility, low-level wastes are sized and
compacted at the site's Waste Experimental Reduction Facility prior to
disposal. Smaller quantities of remote-handled low-level wastes are disposed
of in special concrete vaults in one area within the disposal pits.
Additional vaults may be constructed, but, according to site officials, the
pits will not require expansion.

RWMC does not dispose of any mixed wastes, but on- and off-site mixed wastes
can be treated at the Waste Experimental Reduction Facility's incinerator.
Any remaining ash that contains hazardous components is shipped back to the
waste-generating site or to an off-site disposal facility. Because of newly
imposed air quality requirements, the incinerator is being evaluated to
determine its future use in mixed waste treatment. All low-level wastes
disposed of at RWMC are from INEEL. In fiscal year 1999, the facility
disposed of about 6,000 cubic meters of waste, almost eliminating the site's
backlog of stored low-level wastes. DOE's current plans assume the disposal
facility will accept contact-handled low-level waste through 2006 and
remote-handled waste through 2008.

Material Disposal Area

The Los Alamos National Laboratory, located with the town of Los Alamos
approximately 35 miles northwest of Santa Fe, occupies 43 square miles in
northern New Mexico. Developed as part of the Manhattan Project to create
atomic weapons, the laboratory also produced nuclear weapons components.
Today the laboratory's central mission is enhancing global security by
ensuring the safety and reliability of the U.S. nuclear weapons stockpile;
reducing threats to U.S. security; cleaning up the legacy of the Cold War;
and providing technical solutions to energy, environment, infrastructure,
and health security problems. As a result, research and development
activities at Los Alamos are expected to generate over 273,000 cubic meters
of various radioactive wastes through 2070.

Before 1957, the laboratory used numerous small waste disposal areas
scattered throughout the site. Most of these areas are now being stabilized
and/or cleaned up under the Environmental Restoration program. The current
low-level waste disposal facility, Area G, located in Technical Area-54
(TA-54), began routinely accepting wastes in about 1959. This area occupies
approximately 64 acres on top of a mesa adjacent to the highway between the
laboratory and the nearby community of White Rock. The relatively dry
climate (with an average annual rainfall of 14 inches in Area G) and
volcanic bedrock combine to limit the potential migration of contaminants
from the disposal facility. The water table lies 800 feet below the top of
the mesa. The edges of the mesa ultimately limit the disposal facility's
potential for expansion, but additional acreage could be developed beyond
the area currently used. Area G operates under a DOE-approved performance
assessment, which demonstrates the long-term safety of the facility to the
public.

The facility disposes of low-level wastes using shallow land disposal in
either pits or shafts. Approximately 40 disposal pits have been used in Area
G, four of which are currently active. The unlined pits, which are no more
than 65 feet deep, are filled with, on average, 10 to 12 tiers of tightly
stacked wastes. The layers of waste are covered with backfill to build the
tiers. During waste emplacement, pipes are installed for environmental
sampling during operations and after closure. The area also has over 180
shafts ranging from 1 foot to 16 feet in diameter and up to 65 feet in
depth. The shafts are used for higher-activity and special waste forms that
require additional confinement. To optimize its disposal capacity, the
facility uses a compactor to reduce the volumes of some low-level wastes by
as much as 8 to 1. The facility accepts low-level wastes but cannot dispose
of those that are most radioactive. Specific limitations are detailed in the
facility's performance assessment and waste acceptance criteria.

The Los Alamos site does not have a mixed waste disposal facility. Some of
its mixed wastes are shipped off-site for treatment and/or disposal, and the
remainder are stored pending a disposal option. Until the site began
shipping mixed wastes to off-site facilities in 1995, some mixed wastes were
stored outside because TA-54 did not have sufficient storage capacity.
Currently, containers of mixed wastes are stored in storage domes in TA-54,
as are some transuranic wastes. TA-54 also provides storage for some
nonradioactive hazardous wastes.

Most of the site's low-level wastes and mixed wastes come to TA-54 from over
2,000 on-site generators, although a limited amount of off-site waste is
accepted on a case-by-case basis−mostly from Los Alamos scientists
working at other locations. Because Los Alamos expects to continue its
current missions in the foreseeable future, it is attempting to conserve the
site's limited disposal capacity for on-site wastes anticipated in future
years.

NTS covers approximately 1,375 square miles of federally owned land in
southeastern Nevada, approximately 65 miles northwest of Las Vegas. The
populated area closest to the site's disposal facilities is the small town
of Indian Springs, Nevada, 34 miles to the southeast. Public exclusion areas
owned and used by the U.S. Air Force surround the site on the east, west,
and north. Established in 1950, NTS was used to conduct atmospheric and
underground tests of nuclear explosives in connection with weapons research
and development. From 1951 through 1992, DOE and its predecessor agencies
conducted 928 nuclear tests at the site, 100 atmospheric and 828
underground. Because of the widely dispersed plutonium and other
radionuclides resulting from the explosions, many of the testing areas will
require long-term institutional controls to prevent inadvertent exposure to
residual contamination. Although it is technically feasible to remediate
identified hot spots of surface contamination, the cost of remediating the
hundreds of contaminated acres across the site would be prohibitive.

NTS' disposal facilities are located in two areas--Area 5 and Area 3--which
are well within the boundaries of the site. Both disposal areas are arid,
receiving 4 to 6 inches of rain per year. There is no surface water near
either disposal area, and the water table is approximately 800 feet below
the Area 5 site and 1,600 feet below the Area 3 site. NTS has developed
performance assessments that demonstrate its disposal operations are
protective of human health and the environment. The Area 5 disposal site,
located near the site of the first atmospheric test in the 1950s, comprises
732 acres, 92 of which are currently used for shallow-land disposal. The
wastes are accepted in boxes, drums, or soft packages and are stacked in a
stair-step manner within 22 engineered and excavated disposal trenches. As
the trenches fill, the wastes are covered with clean soil until the facility
can be permanently closed. The Area 5 disposal site also has 13 boreholes
intended for the disposal of wastes requiring greater confinement, as well
as one trench reserved for mixed wastes. Although the site's mixed waste
disposal trench satisfies RCRA's interim status requirements, it requires
modifications (such as a liner, leachate collection system, and leak
detection system) to meet the standards for a RCRA permit. The facility
currently does not dispose of mixed wastes from DOE sites in other states.

The Area 3 disposal site covers about 120 acres and currently disposes of
low-level wastes in seven subsidence craters34 that resulted from
underground nuclear tests. The subsidence craters require little excavation
before being used for disposal, in contrast to the engineered trenches at
Area 5 and other DOE sites. Low-level bulk wastes destined for disposal in
Area 3 arrive in large cargo containers or in soft containers, some of which
can be rolled off hydraulic truck beds, reducing necessary handling.

Although NTS has been disposing of low-level wastes from other sites since
the 1960s, the site did not begin accepting significant quantities of
off-site low-level wastes for disposal until the mid-1970s. Off-site wastes
represented approximately 57 percent of the total volume of low-level wastes
disposed at NTS from 1974 through 1997. During the last 5 years of this
period, off-site wastes accounted for approximately 95 percent of the total
volume of low-level wastes disposed of at the site. In fact, NTS accepted
more than 41 percent of all low-level wastes disposed in DOE's shallow-land
disposal facilities from 1987 through 1996. DOE studies reported that waste
capacity is not a limitation at NTS' disposal areas and that there are no
limits on the volumes of wastes, only on the concentrations of contaminants.

Oak Ridge Reservation occupies approximately 55 square miles in eastern
Tennessee, near Knoxville. In 1942, the federal government selected the Oak
Ridge site for uranium enrichment facilities, displacing four small
communities. The town of Oak Ridge was established nearby to house the
workers who built and operated the facilities. Today, the residential
section of the city of Oak Ridge forms the northern boundary of the Oak
Ridge Reservation. Three major facilities operated at the reservation
beginning in the early 1940s: (1) the K-25 site supplied enriched uranium
for nuclear weapons production; (2) the Y-12 Plant, originally established
to separate uranium isotopes, later enriched lithium and fabricated and
stored nuclear weapons components; and (3) the Oak Ridge National Laboratory
produced the first gram quantities of plutonium and developed the prototype
production reactor later built at the Hanford Site. All of these activities
resulted in large quantities of wastes being disposed of or stored at Oak
Ridge. Although cleaning up wastes and contaminated facilities is a central
mission at the Oak Ridge Reservation today, the site has other ongoing
missions. The laboratory supports radioisotope production and research and
continues to generate a variety of radioactive wastes. The Y-12 Plant
continues to support defense programs by managing special nuclear materials.

Although the Oak Ridge site was selected, in part, because there was nearby
water transportation for production materials, the same hydrogeologic
conditions make the site unsuitable for the shallow-land disposal of
radioactive wastes. The climate at Oak Ridge is humid, with an average
rainfall of 55 inches. Depth to groundwater is shallow (less than 20 feet in
some areas and averaging 20 to 50 feet) and groundwater is discharged to the
surface in some areas, to on-site streams and springs. The Clinch River and
six tributaries run through the reservation, and a major aquifer lies under
the site.

Because of this wet environment, Oak Ridge's only low-level waste disposal
facility, the Interim Waste Management Facility (IWMF), is an aboveground,
high-cost engineered facility. Modular concrete vaults are filled with
low-level wastes encapsulated in concrete. The vaults are placed on concrete
pads, and grout is used to fill void spaces within the vaults. A concrete
lid with a seal is placed on each vault following the grouting operation.
IWMF has a total of six 18-meter-by-27-meter concrete pads, a leachate
collection system, and a monitoring capability. The facility is expensive,
and its use for long-term disposal has been questioned.

No significant amount of waste was disposed of in IWMF during fiscal year
1999 for two reasons. First, the high disposal costs at the facility mandate
optimizing the use of its capacity, and operations were suspended pending a
full evaluation of candidate waste streams against the facility's waste
acceptance criteria and the projected costs of off-site disposal. Second,
the facility's performance assessment and waste acceptance criteria are
being reevaluated. The site will eventually load vaults onto the pads that
are already constructed. These vaults will be filled primarily with wastes
containing high-activity, short-lived isotopes like cesium and strontium.
The facility cannot accept much of the low-level waste generated at the
site, and its disposal capacity is limited to 5,400 cubic meters. Mixed
waste cannot be disposed of in IWMF. The Oak Ridge Reservation's incinerator
treats some mixed and hazardous wastes; however, the residual ash is
generally shipped to Envirocare for disposal.

The Savannah River Site encompasses approximately 325 square miles bordering
the Savannah River in the humid climate of western South Carolina, near
Aiken, South Carolina, and Augusta, Georgia. The site was constructed in the
early 1950s to produce, separate, purify, and process plutonium, tritium,
and other radioisotopes for nuclear weapons programs and other purposes. The
site fabricated fuel, operated five reactors and two chemical separation
plants, and conducted research and development. While much of DOE's focus
has shifted to cleaning up the site and managing the wastes from previous
production work, Savannah River has ongoing missions, including those
stemming from a recent DOE decision to build and operate several facilities
for disposition of the nation's surplus weapons plutonium.

The Savannah River Site's active disposal facilities are located primarily
at the E-Area in the center of the site. The E-Area covers about 200 acres,
and the active disposal facilities occupy about 100 acres. The groundwater
at Savannah River is only 50 to 60 feet below the surface and is therefore
of great concern in waste disposal, as well as in environmental remediation
decisions. In addition, the site's climate is humid, with average annual
rainfall of 48 inches, increasing concerns about the migration of
contaminants. The site's concrete aboveground E-Area disposal vaults were
built to comply with a 1987 departmental directive that new disposal
facilities in humid climates be physically separated from the groundwater
table. Expanding these facilities would be costly, given the requirement for
expensive engineered aboveground disposal dictated by the site's hydrology.

The site disposes of wastes in two vault facilities and a trench area
located near the old waste burial grounds. (Many of the old burial grounds
are being remediated under CERCLA.) The Low-Activity Waste Vault is a
concrete, aboveground vault with 12 cells for containerized lower-activity,
low-level wastes. This vault also contains a waste-sorting area and a
supercompactor to reduce waste volumes to maximize the use of the vault's
limited capacity. The Intermediate-Level Vault consists of concrete, partly
underground vaults, for higher-activity low-level wastes, including some
wastes that contain tritium and are placed in special silos. In the trench
area, unlined slit trenches are used for slightly contaminated containerized
and bulk wastes, such as soil, rubble, wood, and concrete. In addition, the
site places large naval reactor components on open gravel pads until they
can be mounded over with dirt.

The Savannah River Site also has two large vaults used to dispose of
contaminated wastes converted to grout at the site's Saltstone facility,
which processes liquid low-level wastes from other programs at the site that
manage tank wastes and other liquids. The Saltstone facility turns the
liquid wastes into a grout that can be pumped into the concrete vaults,
which will eventually be capped. Although plans for the site include up to
17 more of these vaults, according to site officials, Saltstone is currently
inactive while decisions are being made about the tank waste programs.35
Savannah River does not have any disposal facilities for its mixed wastes,
which remain in storage until a disposal pathway becomes available.

The disposal facilities at Savannah River are used primarily to dispose of
low-level wastes from various on-site processing facilities. The facilities
also dispose of low-level wastes from a few sites in the Naval Nuclear
Propulsion Program. Under the site's current plans−which assume the
use of waste-reduction treatments−the existing Low-Activity and
Intermediate Level Vaults will be filled by 2010 and 2029, respectively. The
trenches may be filled in 2 years; however, additional trenches may be
constructed. Finally, the site operates the Consolidated Incinerator
Facility, which, together with the supercompactor, reduces low-level waste
volumes but is primarily designed to destroy the hazardous components of
mixed wastes.

Scope and Methodology

The Chairman of the Senate Committee on Energy and Natural Resources and the
Chairman of the Subcommittee on Strategic Forces, Senate Committee on Armed
Services, asked us to review (1) the factors that influence DOE's decisions
about the treatment, storage, and disposal of low-level and mixed wastes and
(2) DOE's costs to treat, store, and dispose of these wastes and the
cost-effectiveness of DOE's disposal decisions. We performed our audit work
through interviews and document reviews at DOE headquarters in Washington,
D.C., and offices in Germantown, Maryland, as well as at DOE field offices
and sites operating waste management disposal facilities. Our review covered
seven sites: the Hanford Site in Washington, Idaho National Engineering and
Environmental Laboratory in Idaho, Los Alamos National Laboratory in New
Mexico, Nevada Test Site in Nevada, Oak Ridge Reservation in Tennessee, and
Savannah River Site in South Carolina, as well as the Rocky Flats Field
Office at the Rocky Flats Environmental Technology Site in Colorado.

In addition to the officials we interviewed at these seven sites, we
contacted DOE officials at 13 other sites by telephone, fax, and/or
electronic mail: Argonne National Laboratory-East in Illinois, Bettis Atomic
Power Laboratory in Pennsylvania, Brookhaven National Laboratory in New
York, Fernald Environmental Management Project in Ohio, Knolls Atomic Power
Laboratory in New York, Lawrence Livermore National Laboratory in
California, Mound Plant in Ohio, Paducah Gaseous Diffusion Plant in
Kentucky, Pantex Plant in Texas, Portsmouth Gaseous Diffusion Plant in Ohio,
RMI Titanium Company in Ohio, Sandia National Laboratory in New Mexico, and
West Valley Demonstration Project in New York. These 13 sites, in addition
to the 7 sites visited, accounted for almost all of DOE's projected
low-level and mixed wastes, according to DOE's existing inventories and
anticipated generation for a 20-year period.

To determine the factors that influence DOE's decisions about the treatment,
storage, and disposal of low-level and mixed wastes, we obtained and
analyzed the regulations and DOE policies pertaining to the disposal of
low-level and mixed wastes. We reviewed DOE's Final Waste Management
Programmatic Environmental Impact Statement
and gathered testimonial evidence on the then pending Record of Decision on
low-level and mixed wastes, on delays in its issuance, and on its potential
impact through interviews with DOE and contractor officials at DOE
headquarters in Washington, D.C., and offices in Germantown, Maryland, as
well as DOE field offices and sites operating waste management disposal
facilities. We obtained the waste acceptance criteria and other information
on the available DOE and commercial disposal facilities. We asked officials
at the waste-generating sites to describe how they make low-level and mixed
waste disposal decisions and what factors influence these decisions.

To review DOE's costs to treat, store, and dispose of these wastes and the
cost-effectiveness of DOE's disposal decisions, we interviewed DOE and
contractor officials, and we requested, obtained, and analyzed cost data for
the treatment, storage, and disposal of low-level and mixed wastes from each
site with disposal facilities. Because disposal options are often limited,
we decided that excluding storage costs would grossly underreport the costs
of managing the sites' wastes. Also, because the nature of many wastes or
the characteristics of many disposal facilities necessitate treatment, we
decided to include treatment costs. Therefore, the costs reported here are
for the storage, treatment, and disposal of the sites' solid low-level and
mixed wastes. We obtained the data on the disposal facilities from the
contractors operating the facilities because they were able to sort the data
by the type of activity and could separate the costs of managing and
disposing of low-level and mixed wastes from the costs of managing other
types of wastes at the sites. In most cases, the contractors provided
cost-accounting reports that detailed storage, treatment, and disposal costs
by waste type. For accounts that accumulated costs for multiple activities,
the contractors distributed the costs to the appropriate waste types and
activities. All contractors included their overhead charges. Although we did
not independently verify the disposal facilities' cost data, the cost
reports were generated from financial systems approved and audited under
DOE's authority. We also requested and analyzed data on disposal costs and
additional waste preparation costs from DOE site officials with oversight of
the 20 major waste-generating sites. In general, we relied on the
information these officials provided and did not independently verify its
accuracy. Our requests for cost data from the disposal sites and the
waste-generating sites covered fiscal years 1997 through 1999. We conducted
our review from May 1999 through April 2000 in accordance with generally
accepted government auditing standards.

GAO Contact and Staff Acknowledgments

Dwayne E. Weigel (202) 512-3841

In addition, Pamela J. Timmerman, Patricia J. Rennie, John E. Cass, Krislin
M. Nalwalk, Elizabeth R. Eisenstadt, Doreen S. Feldman, Susan W. Irwin, and
Richard P. Johnson made key contributions to this report.

Related GAO Products

Low-Level Radioactive Wastes: States Are Not Developing Disposal Facilities
(GAO/RCED-99-238, Sept. 17, 1999).

Nuclear Waste Cleanup: Progress Made but DOE Management Attention Needed to
Increase Use of Innovative Technologies (GAO/T-RCED-99-190, May 26, 1999).

Department of Energy: Cost Estimates for the Hanford Tank Waste Remediation
Project (GAO/RCED-99-188R, May 19, 1999).

Nuclear Regulation: Better Oversight Needed to Ensure Accumulation of Funds
to Decommission Nuclear Power Plants (GAO/RCED-99-75, May 3, 1999).

Department of Energy: Accelerated Closure of Rocky Flats: Status and
Obstacles (GAO/RCED-99-100, Apr. 30, 1999).

Nuclear Waste: DOE's Accelerated Cleanup Strategy Has Benefits but Faces
Uncertainties (GAO/RCED-99-129, Apr. 30, 1999).

Nuclear Waste: Process to Remove Radioactive Waste From Savannah River Tanks
Fails to Work (GAO/RCED-99-69, Apr. 30, 1999).

Nuclear Waste: Corps of Engineers' Progress in Cleaning Up 22 Nuclear Sites
(GAO/RCED-99-48, Feb. 26, 1999).

Nuclear Waste: Department of Energy's Hanford Tank Waste Project--Schedule,
Cost, and Management Issues (GAO/RCED-99-13, Oct. 8, 1998).

Department of Energy: Alternative Financing and Contracting Strategies for
Cleanup Projects (GAO/RCED−98-169, May 29, 1998).

Nuclear Waste: Understanding of Waste Migration at Hanford Is Inadequate for
Key Decisions (GAO/RCED-98-80, Mar. 13, 1998).

Nuclear Waste: Department of Energy's Project to Clean Up Pit 9 at Idaho
Falls Is Experiencing Problems (GAO/RCED-97-180, July 28, 1997).

Radioactive Waste: Interior's Continuing Review of the Proposed Transfer of
the Ward Valley Waste Site (GAO/RCED-97-184, July 15, 1997).

Department of Energy: Management and Oversight of Cleanup Activities at
Fernald (GAO/RCED-97-63, Mar. 14, 1997).

Nuclear Waste: Uncertainties About Opening Waste Isolation Pilot Plant
(GAO/RCED-96-146, July 16, 1996).

Radioactive Waste: Status of Commercial Low-Level Waste Facilities
(GAO/RCED-95-67, May 5, 1995).

(141305)

Table 1: Current Estimated Cost of Disposing of Low-Level
and Mixed Wastes in Planned or Operating CERCLA Facilities 38

Table 2: Summary of Fernald's Disposal Decisions for Low-Level
and Mixed Wastes, Fiscal Years 1997-99 43

Table 3: Past and Future Disposal Volumes of Low-Level and
Mixed Wastes for DOE's 20 Major Waste-Generating Sites 45

Table 4: Low-Level and Mixed Waste Disposal Preparation
Costs at 15 Major Waste-Generating Sites, Fiscal Years 1997-99 46

Table 5: Waste Disposal Volumes and Remaining Capacity at
DOE's Six Active Waste Management Disposal Facilities 48

Table 6: Waste Storage, Treatment, and Disposal Costs at DOE's
Six Active Waste Management Disposal Facilities,
Fiscal Years 1997-99 49

Figure 1: Estimated Volume of Low-Level and Mixed Wastes
for Disposal at DOE's Facilities 7

Figure 2: DOE's Major Low-Level and Mixed Waste-Generating
Sites and Disposal Facilities 9

Figure 3: Aboveground Disposal Facilities at Savannah River
and Oak Ridge 10

Figure 4: Disposal in Subsidence Craters at NTS and Mixed Waste
Disposal Trench at Hanford 12

Figure 5: Estimated Disposal Volumes and 3-Year Costs to Manage
and Dispose of Mixed and Low-Level Wastes at Six DOE Sites
With Disposal Facilities 22

Figure 6: Six DOE Disposal Sites' Costs to Store, Treat, and
Dispose of Mixed and Low-Level Wastes, Fiscal Years 1997-99 23

Figure 7: Diagram of a Typical Closure Cap for a Waste
Disposal Facility 26

Figure 8: CERCLA On-Site Disposal Facility at DOE's Fernald Site 40
  

1. A cubic meter equals about 35.3 cubic feet.

2. Many of these wastes will be remediated in place. For example, some will
be covered with a clay cap.

3. This projection is based on existing waste inventories and the waste
generation anticipated for a 20-year period. See DOE's Final Waste
Management Programmatic Environmental Impact Statement (May 1997).

4. The Savannah River and Idaho sites also dispose of low-level wastes from
the Naval Nuclear Propulsion Program.

5. A "subsidence crater" results when the earth settles into a cavity caused
by an underground explosion.

6. Some exceptions have been made through DOE headquarters decisions,
primarily for unique wastes and wastes from work done previously by others
for DOE (i.e., laboratory work).

7. For information on commercial low-level waste disposal facilities, see
Low-Level Radioactive Wastes: States Are Not Developing Disposal Facilities
(GAO/RCED-99-238 , Sept. 17, 1999).

8. The Low-Level Radioactive Waste Policy Act of 1980, as amended in 1985,
authorized states to form compacts for the purpose of regulating the
management and disposal of commercially generated low-level radioactive
wastes. Compact agreements must be approved by the Congress before they take
effect.

9. Envirocare is licensed for "Class A" wastes under the Nuclear Regulatory
Commission's division of commercially generated nuclear wastes. In November
1999, Envirocare asked Utah for an amendment to its license that would allow
for the disposal of wastes with higher radioactivity levels. Envirocare also
has to submit a siting application. To dispose of higher-level wastes,
Envirocare would have to build a more complex disposal facility.

10. Commercial Disposal Policy Analysis for Low-Level and Mixed Low-Level
Wastes (DOE/EM, Mar. 1999).

11. Disposal of Low-Level and Low-Level Mixed Waste (DOE/IG-0426, Sept.
1998).

12. Before May 1990, NTS disposed of mixed wastes from other
sites−primarily from the Rocky Flats Plant.

13. The treatment, storage, and disposal of PCBs fall under the Toxic
Substances Control Act of 1976 (TSCA). The Oak Ridge incinerator operates
under a TSCA authorization issued by EPA Region IV and a RCRA permit issued
by the state of Tennessee.

14. For information on issues that could affect Rocky Flats' closure, see
Department of Energy: Accelerated Closure of Rocky Flats: Status and
Obstacles (GAO/RCED-99-100 , Apr. 30, 1999).

15. Rocky Flats officials believe that either NTS' or Hanford's mixed waste
disposal facility must be available by 2003 if Rocky Flats is to meet its
closure schedule. Of particular concern are mixed wastes with activity
levels too high for disposal at Envirocare. Rocky Flats could be ready to
ship these wastes to the selected DOE mixed waste disposal facility or
facilities as early as 9 to 12 months after DOE issued its Record of
Decision.

16. These include DOE's costs to manage wastes from past operations, wastes
from ongoing missions, and cleanup wastes transferred from DOE's
Environmental Restoration program.

17. A 1997 cost report on DOE's disposal facilities provided annual--but not
life-cycle--facility and waste generator cost estimates. A primary
conclusion of the report was that generators' costs make up two-thirds of
the total costs to dispose of low-level wastes.

18. While not all of these sites routinely track and report their costs for
waste preparation prior to disposal, 15 of the 20 largest waste-generating
sites reported these costs to us.

19. DOE developed draft guidance in an effort to standardize the costs that
would be covered by disposal fees. However, this guidance was never
finalized.

20. See the implementation manual for DOE's 1999 Order 435.1, Radioactive
Waste Management.

21. From Cleanup to Stewardship: A Companion Report to Accelerating Cleanup:
Paths to Closure (DOE/EM-0466, Oct. 1999).

22. S. Rep. No. 106-50, at 452 (1999).

23. The on-site volume reduction facility was not available at that time.

24. In addition to the CERCLA facilities discussed in this report, DOE
constructed such facilities at its Weldon Spring Site and Monticello Mill
Site (largely for uranium mill tailings) and is considering constructing a
CERCLA facility for the Paducah Gaseous Diffusion Plant. Sandia National
Laboratory has a small CERCLA Corrective Action Management Unit limited to
the disposal of cleanup waste, such as soil and debris, with very low
tritium contamination.

25. Unless otherwise noted, all dollar amounts in this appendix are
expressed in 1999 dollars.

26. DOE derived these costs from a life-cycle cost analysis model developed
by the National Institute of Standards & Technology in 1995.

27. Alternative Screening Report, Radioactive Soil/Debris Consolidation
Facility/Off Unit Disposal, Westinghouse Savannah River Company (RP-96-893,
May 1997).

28. In fiscal year 1999, according to DOE, the cost per cubic meter to
dispose of low-level waste on-site in trenches and vaults was $86 and $497,
respectively.

29. Because Fernald is considered a defense facility, it received approval
to ship its wastes to NTS, but not to Hanford. Under DOE's recent Record of
Decision, though, Hanford could become an option.

30. The National Contingency Plan is the federal government's blueprint for
responding to oil spills and hazardous substance releases.

31. Current and Planned Low-Level Waste Disposal Capacity Report, Revision 1
(Sept. 18, 1998).

32. This report addresses the facilities' volume capacity rather than their
radiological capacity. However, DOE's Current and Planned Low-level Waste
Disposal Capacity Report indicates that the Department has sufficient
complexwide radiological capacity through 2070 for low-level and mixed
wastes, according to a radiological analysis performed for the active
disposal facilities included in table 5.

33. Transuranic waste contains more than 100 nanocuries of radioactive
elements whose atomic numbers are higher than uranium's.

34. The seven craters make up five disposal units. In two cases, the area
between craters was excavated to make two craters into a single disposal
unit.

35. For information on problems with Savannah River's In-Tank Precipitation
Program, see Nuclear Waste: Process to Remove Radioactive Waste From
Savannah River Tanks Fails to Work (GAO/RCED-99-69 , Apr. 30, 1999).
*** End of document. ***