Nuclear Waste Cleanup: DOE's Paducah Plan Faces Uncertainties and
Excludes Costly Cleanup Activities (Letter Report, 04/28/2000,
GAO/RCED-00-96).

Pursuant to a congressional request, GAO reviewed the Department of
Energy's (DOE) Paducah plant cleanup plan, focusing on: (1) the planned
activities, cost, and schedule DOE has for cleaning up the site; (2) the
challenges that exist in accomplishing the current cleanup plan; and (3)
whether the cleanup plan includes all areas at the site requiring
cleanup.

GAO noted that: (1) DOE's plan for addressing the contamination at the
Paducah site focuses on six major cleanup categories; (2) four of these
address the physical contamination on the site: (a) groundwater; (b)
surface water; (c) soils; and (d) buried waste; (3) two other major
categories of cleanup work include treating and disposing of the
equivalent of about 52,000 barrels of waste stored on site and
decontaminating and removing two unused, contaminated uranium process
buildings; (4) the cleanup plan includes cost and schedule estimates for
characterizing the contamination in each cleanup category and for using
technologies to treat, remove, and dispose of the contamination; (5) the
current plan estimates the cost of completing the cleanup at $1.3
billion from fiscal years 2000 through 2010; (6) DOE faces many
challenges to completing its cleanup as planned; (7) uncertainties about
the extent, source, and nature of contamination yet to be cleaned up
could affect the cleanup plan; (8) DOE also faces several technical
risks, including the planned use of technologies that are unproven or
perhaps not well suited to the site's conditions; (9) also underpinning
the plan are assumptions that annual federal funding will increase to an
average of $124 million through 2010; (10) if the planned increase in
funding does not occur, the project could take longer to complete; (11)
these issues make it uncertain that DOE will be able to accomplish the
cleanup within its estimated timeframe and cost; (12) even when the
planned cleanup has been carried out, billions of dollars and many years
will be needed to address areas at the Paducah site that are not in the
cleanup plan; (13) four areas at the site that will need cleaning up
are: (a) large amounts of waste and scrap materials; (b) various unused
buildings and structures; (c) thousands of tons of depleted uranium; and
(d) the buildings and equipment that are now being used in the
enrichment process but that will have to be cleaned up when the plant
closes; (14) the additional materials, buildings, and structures are
excluded from the cleanup plan because they fall under the purview of a
different departmental program; and (15) according to the DOE official
responsible for these areas, they are not in the cleanup plan because
DOE is hesitant to transfer any more areas to the Office of
Environmental Management, which already has a large workload and limited
funding for cleanup.

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

 REPORTNUM:  RCED-00-96
     TITLE:  Nuclear Waste Cleanup: DOE's Paducah Plan Faces
	     Uncertainties and Excludes Costly Cleanup Activities
      DATE:  04/28/2000
   SUBJECT:  Nuclear waste management
	     Radioactive waste disposal
	     Radioactive pollution
	     Strategic planning
	     Occupational safety
	     Obsolete facilities
	     Industrial facilities
	     Uranium
	     Water pollution control
IDENTIFIER:  Paducah (KY)
	     EPA National Priorities List

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GAO/RCED-00-96

Appendix I: Cleanup Plan Focuses on Six Major Categories
of Effort

36

Appendix II: Comments From the Department of Energy

44

Table 1: DOE's Estimated Cost and Schedule for Six Cleanup
Categories at the Paducah Site, as of January 2000 14

Figure 1: Aerial View of the Paducah, Kentucky, Uranium
Enrichment Plant 7

Figure 2: Scrap Metal Stored on Site, With a Close-up View
of "Drum Mountain" (30 to 40 feet in height) 11

Figure 3: Two Unused, Contaminated Buildings to Be
Demolished During Cleanup 13

Figure 4: Contaminated Groundwater Plumes at the Paducah Site 19

Figure 5: DMSAs Contain a Variety of Contaminated Equipment,
Scrap, and Waste Materials, Including Some Posted
as Posing Nuclear Criticality Safety Concerns 26

DMSA DOE material storage area

DOE Department of Energy

EPA Environmental Protection Agency

NRC Nuclear Regulatory Commission

PCBs polychlorinated biphenyls

TCE tricholorethene

USEC United States Enrichment Corporation

Resources, Community, and
Economic Development Division

B-284388

April 28, 2000

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

The Honorable Jim Bunning
The Honorable Mitch McConnell
United States Senate

In 1988, radioactive contamination was found in the drinking water wells of
residences near the federal government's uranium enrichment plant in
Paducah, Kentucky.1 In response, the Department of Energy (DOE) connected
local residences to municipal water supplies and began a cleanup program to
identify and remove contamination in the groundwater, surface water, and
soils located within and outside the plant's boundaries. Sources of the
hazardous chemical and radioactive contamination included spills, leaks from
contaminated buildings, buried waste, scrap yards, and waste lagoons. From
1988 through 1999, DOE spent about $388 million on these cleanup efforts.

In August 1999, in response to a number of allegations that past activities
at the Paducah plant had endangered the health of employees, the Secretary
of Energy, among other things, directed the Office of Oversight within DOE's
Office of Environment, Safety, and Health to conduct an independent
investigation at Paducah.2 This investigation addressed issues such as
improperly disposing of hazardous and radioactive materials on-site and
off-site, releasing contamination into streams and drainage ditches,
inadequately posting and controlling contaminated areas, exposing workers to
radioactive material, and ineffectively communicating hazards to workers.
The resulting October 1999 report stated that limited progress had been made
in cleaning up source areas of contamination, such as landfills, burial
grounds, and waste and scrap piles. The report also noted that large
quantities of waste were stored in conditions that increased the risk of
spreading contamination. In addition, the report noted that the funding
available for cleanup had been much less than requested. Most of the site's
cleanup funding had been devoted to characterizing contamination (that is,
identifying its nature and extent); operating and maintaining the site
infrastructure; meeting regulatory requirements; and implementing measures
in reaction to immediate threats. According to DOE officials, cleanup at the
site, including the removal of contaminated scrap metal and low-level waste
disposal, was delayed because of funding limitations.

The plant, which operates today under a lease to a private company, the
United States Enrichment Corporation, enriches uranium for nuclear power
plants. DOE's Office of Environmental Management has overall responsibility
for the site cleanup being performed by its contractor, Bechtel Jacobs,
while the Office of Nuclear Energy, Science, and Technology (Office of
Nuclear Energy) is generally responsible for maintaining the site's
infrastructure. DOE's cleanup plan for the Paducah site seeks to assess the
extent of radioactive and chemical contamination from past uranium
enrichment activities at the site and to treat and dispose of this
contamination. Overseeing the cleanup in a regulatory role are the
Environmental Protection Agency (EPA) and the Commonwealth of Kentucky.

Concerned about the reportedly slow progress that has occurred to date in
the plant's cleanup, you asked us to (1) describe the planned activities,
cost, and schedule DOE has for cleaning up the Paducah site; (2) identify
the challenges that exist in accomplishing the current cleanup plan; and (3)
determine whether the cleanup plan includes all areas at the site requiring
cleanup.

In conducting our work, we met with DOE and contractor officials, reviewed
agency documents, and visited the Paducah site on three separate occasions.
We focused primarily on examining the January 26, 2000, Lifecycle Baseline,
which provides details on the planned cleanup approach, schedule, and
estimated costs. We also met with federal and state regulators as well as
the site advisory board to obtain views from local citizens.

The Department's plan for addressing the contamination at the Paducah site
focuses on six major cleanup categories. Four of these address the physical
contamination on the site: groundwater; surface water (for example, in
ditches and creeks); soils; and buried waste. Two other major categories of
cleanup work include treating and disposing of the equivalent of about
52,000 barrels of waste currently stored on site and decontaminating and
removing two unused, contaminated uranium process buildings. The cleanup
plan includes cost and schedule estimates for characterizing the
contamination in each cleanup category and for using technologies to treat,
remove, and dispose of the contamination. The current plan estimates the
cost of completing the cleanup at $1.3 billion from fiscal year 2000 through
fiscal year 2010.

DOE faces many challenges to completing its cleanup as planned.
Uncertainties about the extent, source, and nature of contamination yet to
be cleaned up could affect the cleanup plan; the outcome of such
uncertainties could increase cleanup costs. DOE also faces several technical
risks, including the planned use of technologies that are unproven or
perhaps not well suited to the site's conditions. Also underpinning the plan
are assumptions that annual federal funding will increase to an average of
$124 million through 2010. This assumed average annual funding level is
considerably higher than the $43 million average annual funding DOE has
received over the last 7 years--since the Congress established a fund for
cleaning up contamination at DOE's three uranium enrichment sites. If the
planned increase in funding does not occur, the project could take longer to
complete. In addition, the plan contains optimistic assumptions about
reaching timely agreement with EPA and state regulators on issues such as
cleanup levels, strategies, and priorities. Collectively, these issues make
it uncertain that the Department will be able to accomplish the cleanup
within its estimated time frame and cost.

Even when the planned cleanup has been carried out, billions of dollars and
many years will be needed to address areas at the Paducah site that are not
in the cleanup plan. More specifically, four areas at the site, currently
under the responsibility of the Office of Nuclear Energy, will need to be
cleaned up. These areas are (1) large amounts of waste and scrap materials,
(2) various unused buildings and structures, (3) thousands of tons of
depleted uranium, and (4) the buildings and equipment that are now being
used in the enrichment process but that will have to be cleaned up when the
plant closes. The materials and structures include nearly a million cubic
feet of waste and scrap in areas known as DOE Material Storage Areas and 16
unused and inactive buildings and structures. Some of this waste and scrap
material poses a risk of an uncontrolled nuclear reaction that could
threaten worker safety. Such a reaction produces a burst of radiation that
generally lasts several hours; it is, however, a localized event that would
not result in an explosion or release of radioactivity to the atmosphere.
The additional materials, buildings, and structures are excluded from the
cleanup plan not because they require no action, but because they fall under
the purview of a different departmental program. According to the DOE
official responsible for these areas, they are not in the cleanup plan
because DOE is hesitant to transfer any more areas to the Office of
Environmental Management, which already has a large workload and limited
funding for cleanup. The programmatic distinction between the Department's
Office of Environmental Management and its Office of Nuclear Energy prevents
the Paducah cleanup managers from assessing risk or planning cleanup on a
comprehensive, sitewide basis and distorts the picture of the cleanup task
at hand.

Regarding the depleted uranium, DOE recently announced plans to build and
operate a facility at Paducah to convert the 496,000 tons of this material
on site to a more stable form and remove it from the site. DOE officials
estimated that it may cost between $1.8 billion and $2.4 billion to operate
the conversion facility at Paducah for nearly 25 years and to store and
dispose of the unused converted material. Finally, according to DOE's
January 1998 estimate, another $1 billion would be needed for final
decontamination and decommissioning activities, when the plant ceases
operations and is returned to DOE's ownership. The current plant operator
can terminate its lease if it gives 2 years' notice under certain
circumstances or if it is unable to maintain certain financial conditions.
To ensure that cleanup priorities are established on a comprehensive,
sitewide basis, we are making recommendations to the Secretary of Energy to
include in the cleanup plan all materials that are potential health hazards
to workers and the public.

The Paducah uranium enrichment plant, shown in figure 1, is located on about
3,400 acres in western Kentucky, just south of the Ohio River and about 10
miles west of the city of Paducah. The plant enriches uranium for commercial
power reactors. Over its 50-year operating lifetime, the Paducah plant has
processed, or enriched, more than a million tons of uranium.

Figure 1: Aerial View of the Paducah, Kentucky, Uranium Enrichment Plant

Source: DOE.

Plant operations have introduced to the site radioactive and hazardous
chemical wastes, including technetium-99, polychlorinated biphenyls (PCBs),
uranium, and volatile organic compounds such as trichloroethene. In past
years, a cleaning solvent containing trichloroethene--much like that used by
drycleaners--was used to degrease parts and equipment. In the plant's half
century of operations, these various waste materials have contaminated the
area's groundwater, surface water, soils, and air.

The Paducah site cleanup is funded through the Uranium Enrichment
Decontamination and Decommissioning Fund, which was established by the
Energy Policy Act of 1992. Money comes into the fund from both annual
federal appropriations and assessments on commercial utilities. Through
1998, the federal government had contributed a total of about $1.5 billion
to the fund, and commercial utilities had contributed a total of about $954
million. Through fiscal year 2000 (as of mid-April 2000), the Paducah site
has received from the fund annual cleanup amounts ranging from $35.9 million
to $52.3 million.

The Comprehensive Environmental Response, Compensation, and Liability Act of
1980, commonly known as Superfund, governs the cleanup of sites placed on
the National Priorities List--EPA's list of contaminated sites designated as
highest priority for cleanup. Paducah was placed on the list in 1994.
Superfund provides broad federal authority to respond directly to releases
or threatened releases of hazardous substances that may endanger public
health or the environment. It stresses the importance of permanent cleanup
remedies and innovative treatment technologies, and it encourages citizen
participation in deciding on how sites should be cleaned up.

The Resource Conservation and Recovery Act of 1976 also comes into play in
governing the Paducah cleanup. While Superfund deals with cleaning up
inactive and abandoned hazardous waste sites, this act governs the safe
management and disposal of the huge amounts of hazardous or other solid
wastes that are generated nationwide and are currently destined for disposal
or recycling. The act permits states, rather than EPA, to assume primary
responsibility for implementing its requirements.

At Paducah, the key documents governing the cleanup are a federal facility
agreement, the site management plan, and the lifecycle baseline. The federal
facility agreement--between DOE, EPA, and the Commonwealth of
Kentucky--coordinates the requirements of both Superfund and the Resource
Conservation and Recovery Act for cleanup activities at Paducah. This
agreement includes a site management plan, which includes timetables,
deadlines and projected activities. Bechtel Jacobs, the cleanup contractor
for Paducah since April 1998, prepares a lifecycle baseline, which includes
specific cleanup strategies, their cost estimates, and time frames for
completion over the life of the cleanup.

The lifecycle baseline, according to DOE and contractor officials, is a
"living document;" it is updated frequently to reflect the evolving nature
of the cleanup process. Revisions to the lifecycle baseline are made to
incorporate such things as changes in funding; updated cost estimates for
specific studies, tests, and cleanup tasks; and changes in project approach
or scope necessitated by study results. Such revisions affect estimates of
the total cleanup cost and schedule. For this report, we examined
activities, costs, and schedules contained in the January 26, 2000, version
of the lifecycle baseline.

Since 1996, the plant has been operated under lease from DOE by the United
States Enrichment Corporation (USEC), which was created by the Energy Policy
Act of 1992 and was a first step in the process of privatizing the
government's uranium enrichment enterprises. The Nuclear Regulatory
Commission (NRC) granted USEC a certificate to operate the plant in November
1996 and received responsibility for the regulatory oversight of enrichment
operations from DOE in March 1997. As a result of an initial public
offering, USEC was privatized as an investor-owned corporation in July 1998.
USEC recently announced a workforce reduction to offset low market prices
for uranium.

DOE's management of the Paducah site is divided between two offices. The
Office of Environmental Management is responsible for the site cleanup plan,
including characterizing, treating, and disposing of waste and contamination
identified during site cleanup. The Office of Nuclear Energy acts as the
"landlord," with responsibilities for maintaining roads, grounds, and
facilities not leased to USEC, and managing material storage areas and the
cylinders of depleted uranium stored on site.

Paducah has a Site Specific Advisory Board, which provides DOE with
recommendations and advice on major policy issues regarding environmental
restoration, waste management, and related activities at the site. Sixteen
members of the local community are on the board. Representatives of DOE,
EPA, and the Commonwealth of Kentucky serve as ex-officio representatives on
the board.

2010 at a Cost of About $1.3 Billion

DOE's January 2000 plan for addressing the variety of radioactive and
hazardous chemical wastes that have contaminated the Paducah site and
surrounding area divides the cleanup work into six major categories. Four of
the cleanup categories are concerned directly with the physical
contamination--the groundwater aquifer, ditches and water release areas that
contribute to surface water pollution running off-site, surface soils, and
waste burial grounds. Two other categories address the treatment and
disposal of approximately 52,000 barrels of accumulated wastes from past
plant operations and the decontamination and removal of two unused,
contaminated uranium process buildings. The plan includes estimates of the
costs and time frames for characterizing and assessing the severity of the
contamination and the costs of selected technologies and strategies to treat
or remove it. DOE estimates that it will accomplish the planned cleanup by
2010, at a cost of approximately $1.3 billion.

The following describes the six cleanup categories included in DOE's plan
for the Paducah site. See appendix I for details on the cleanup tasks
accomplished and planned in each of the categories and the estimated costs
and time frames for each.

ï¿½ Groundwater in an aquifer below the plant is contaminated with radioactive
and hazardous chemicals. About 10 billion gallons of contaminated water are
spreading off the site in three different plumes, at least one of which may
have reached the Ohio River, about 3 miles north of the plant. The interim
measures DOE has taken to address this contamination include connecting
nearby residences to municipal drinking water supplies and constructing two
groundwater pump-and-treat systems to reduce the concentration of
contaminants in the two major plumes. Additional assessments are being
conducted to identify other contamination sources or plumes, and several
cleanup technologies are being considered for treating the groundwater.
Pilot studies of these technologies are planned to determine their ability
to (1) remove the source of groundwater contamination and (2) clean the
groundwater plumes as they leave the site. DOE estimates that the planned
groundwater cleanup activities will be completed in 2006.

ï¿½ Surface water contamination has been discovered in surrounding creeks and
ditches and in sludge lagoons. One of the main sources of this contamination
is the thousands of tons of contaminated scrap metal that DOE has stored on
site. During storms, contamination washes from the scrap metal, and the
runoff carries contaminated soils and sediments into the ditches and creeks.
Another source of contamination is the discharge of wastewater from plant
operations. Some interim measures have been taken to address the wastewater
contamination, including treating some of the wastewater and installing
pipes that route some of the wastewater discharges around areas in the
ditches that are highly contaminated. DOE is finishing its characterization
of the contamination found both on and off-site. By the end of 2000, DOE
also plans to have removed that portion of the contaminated scrap metal
called "Drum Mountain," which is made up of about 8,000 tons of crushed
drums that contained depleted uranium (see fig. 2). The remaining planned
cleanup tasks include removing the remaining 57,000 tons of scrap metal that
contribute to the contamination, dredging ditches and creeks both on and
off-site, and installing four basins to catch and treat contaminated water.
DOE estimates that the planned surface water cleanup activities will be
completed in 2007.

Figure 2: Scrap Metal Stored on Site, With a Close-up View of "Drum
Mountain" (30 to 40 feet in height)

Source: DOE.

ï¿½ Surface soils on and off-site have been contaminated by water runoff,
spills, and buried waste. DOE has identified 72 areas with contaminated
soils and has taken interim measures, such as installing erosion control
fences, to prevent further migration of the contamination. DOE is finishing
its characterization of the contamination on and off-site. The planned
cleanup tasks include removing contaminated soil and, in one highly
contaminated area, continuing the use of an innovative technology to clean
the soil. DOE estimates completing the planned work on contaminated soils in
2007.

ï¿½ Burial grounds, of which there are 12, contain a variety of waste,
including buried barrels of materials with low levels of radioactivity
and/or hazardous chemicals, and pyrophoric uranium.3 DOE is in the process
of analyzing sampling data to determine the extent to which these burial
grounds are contributing to groundwater contamination. The planned cleanup
strategy is to excavate four or five of the burial grounds and to install a
protective cover, or cap, over the remaining ones to prevent water from
seeping in. DOE estimates completing the planned cleanup of the burial
grounds by 2010.

ï¿½ Fifty-two thousand barrels of waste, the majority of which contain
materials that have low levels of radioactivity and/or hazardous chemicals,
are stored in various locations at Paducah.4 More than 12,400 barrels of
this waste are stored outdoors; many have severely degraded, and some have
leaked.5 DOE has disposed of approximately 750 barrels of waste since 1990.
In addition to requiring storage and monitoring, nearly all of the remaining
barrels will require additional characterization to determine their
suitability for off-site disposal. Owing to a number of factors, including
the aged condition of some barrels, transportation requirements, and
treatment requirements for waste disposal, the cleanup plan assumes that 80
percent of the 52,000 barrels will need to be "overpacked" (placed inside
another barrel) to make them suitable for disposal. DOE's plan calls for
removing the barrels by 2010.

ï¿½ Two contaminated process buildings that have not been used as part of the
uranium enrichment process since 1977 will be decontaminated and removed.
These two buildings are heavily contaminated from earlier operations. DOE
recently decided to plan for the removal of the buildings by 2008. Figure 3
shows the two buildings.

Figure 3: Two Unused, Contaminated Buildings to Be Demolished During Cleanup

Source: DOE.

Cleanup by 2010

DOE's January 2000 plan estimated that it would take approximately $1.3
billion through 2010 to complete cleanup activities in the six categories.
Table 1 shows the estimated cost of cleanup in each of the six categories.
In addition to the direct cleanup activities, about $91 million of this
amount will be used to conduct monitoring and maintenance activities (such
as repairing fences, replacing warning signs, and conducting required
inspections). The $1.3 billion cost represents an 85-percent increase from
DOE's October 1999 estimate of $700 million, which had a completion date of
2012.6 Revisions to the plan since October, decided upon in conjunction with
federal and state regulators, have increased costs partly because of the
need to (1) dispose of contaminated scrap metal that DOE had previously
assumed could be recycled, (2) decontaminate and remove two unused process
buildings, and (3) expand the scope of a number of cleanup actions. Although
DOE plans to complete the cleanup by 2010, a few activities (such as
preparing post-cleanup reports) will continue through 2011, at a cost of
about $13 million.

Table 1: DOE's Estimated Cost and Schedule for Six Cleanup Categories at the
Paducah Site, as of January 2000

 Dollars in thousands
 Cleanup area             Cleanup cost  Completion date
 Groundwater              $ 162,100     2006
 Surface water            162,300       2007
 Surface soils            19,000        2007
 Burial grounds           535,400       2010
 Waste barrels (52,000)   228,100       2010
 Unused process buildings 92,100        2008
 Othera                   104,200       2011
 Total                    $1,303,200

aIncludes approximately $91 million for monitoring and maintaining the site
and about $13 million for other activities in 2011, such as preparing
post-cleanup reports.

Note: DOE's estimated costs have been adjusted for inflation.

Source: DOE.

A number of technical, financial, and regulatory factors associated with the
implementation of the cleanup plan make it uncertain whether DOE can
complete the cleanup in accordance with its plan. Uncertainties exist about
the nature and extent of contamination and the feasibility of available
cleanup technologies. In addition, assumptions about the availability of
federal funding and the timeliness of stakeholders' agreement with cleanup
levels and strategies may affect DOE's ability to meet the plan's
milestones. Collectively, the number and nature of the uncertainties and
assumptions make it doubtful that Paducah's cleanup will be completed by
2010, as scheduled, within the $1.3 billion cost projection.

May Increase Costs

Uncertainties about the nature, extent, and sources of contamination yet to
be cleaned up could affect the cleanup plan; the outcome of such
uncertainties could increase cleanup costs. For example, the extent of
contamination in the surface water and soils within and outside the plant
boundaries remains to be determined and could affect cleanup strategies,
including the number of sedimentation basins that will need to be installed.
The basins would be installed at various points to collect and hold storm
water runoff, thus allowing treatment of the contaminants the runoff may
contain. The state has expressed its preference for installing eight or nine
sedimentation basins, so as to prevent the further spread of soil
contamination off-site. DOE has agreed to consider installing basins as
needed but is deferring any specific installation plans until it has
finished investigating the nature and extent of contamination. DOE officials
told us they are concerned that the money needed for installing
sedimentation basins could be better used to accelerate the cleanup of the
contaminated soil. Nevertheless, for budgeting purposes, the DOE plan
assumes that four basins will be installed, at a cost of about $14 million.
DOE plans to conduct an engineering evaluation and cost analysis in 2000,
with the installation of any needed basins to be completed in fiscal year
2003. EPA officials find DOE's approach unacceptable; they want the
installment of the sedimentation basins to coincide with the removal of the
scrap metal, which is scheduled to begin in 2000. Removal of the scrap
metal, according to EPA officials, will release contaminated sediments that
will migrate off-site, via surface water runoff, into adjoining creeks, thus
harming the ecosystem. As a result, the ultimate cleanup costs could vary
considerably from the current estimate, depending in part on the number of
sedimentation basins installed. At an installation cost averaging $4 million
per basin, the addition or deletion of basins from the current plan would
change the cost estimates.

Furthermore, the identification and mitigation of all the groundwater
contamination sources are uncertain and are likely to have the greatest
implications for cleanup efforts. One of the principal groundwater
contaminants--trichloroethene--migrates down through the soil and aquifer,
as is its nature, until it reaches an impermeable layer, where it lays in a
mass and slowly contaminates the water. DOE officials suspect that leaks and
spills from the building formerly used for degreasing machinery (the C-400
building) caused pockets of this contaminant, which constitutes a major
source of groundwater contamination. The highest concentrations of
trichloroethene at the site have been found near building C-400: 700,000
parts per billion in the groundwater and 11 million parts per billion in the
soils. The drinking water standard for trichloroethene, in contrast, is 5
parts per billion. Other spills and dumping are known to have occurred in
other areas across the site and may also have formed pockets contributing to
the groundwater contamination.

The difficult task of locating and eliminating these pockets of
contamination, perhaps 100 feet underground, could affect DOE's ability to
complete its planned groundwater activities within the estimated cost and
schedule. For several reasons, according to an August 1996 DOE technology
summary, the problem posed by pockets of highly contaminated substances such
as trichloroethene is one of the most difficult environmental challenges
facing the nation.7 First, because of the toxicity of most chlorinated
solvents, their unique physical properties, and their poorly understood
movement underground, it is very difficult to determine the location and
distribution of these source areas with any degree of certainty at most
sites. In addition, owing to their limited solubility in water, these source
pockets are capable of contaminating large quantities of groundwater and can
continue to be a source of contamination for many decades. Furthermore,
currently available treatment and remediation technologies are generally
incapable of completely removing contamination from the source area.
Incomplete removal means that the residual contamination will continue to be
a long-term source of groundwater contamination.

Project success also depends upon successfully using technologies not
previously used extensively at sites like Paducah. Many of the technologies
included in the plan or contemplated for the cleanup are emerging
technologies, and others, while not new, remain untested for the specific
environment in which they are to be applied. For example, it is uncertain
whether the primary treatment strategy planned for addressing the
contaminated groundwater plumes will be successful. The strategy is to place
thousands of feet of permeable treatment barriers across the paths of the
contaminated groundwater plumes. No treatment is contemplated for the
portions of the plumes that will extend beyond the treatment barriers. The
placement of a barrier involves injecting into the aquifer--at depths up to
120 feet--a gelatinous, gummy substance called guar gel. The guar gel
contains iron filings for treating the contamination. This technology is
quite new; it is being used at only a few sites across the nation, and the
potential for its success at the Paducah site is uncertain. It was selected
for the Paducah site because it is one of a very few available technologies
that might be able to treat both of the principal
contaminants--trichloroethene (TCE) and technetium-99. Yet the barrier's
success depends on numerous factors, including the rate of groundwater flow,
the length of time the water resides in the treatment zone, the level of
contamination, and the permeability of the treatment barrier compared to
that of the geologic structure into which it is placed. If the groundwater
flows too quickly through the barrier and thus spends too little time in the
treatment zone, the iron filings might not have time to fully treat the TCE.
In that case, the actions of the barrier's treatment zone might only change
the contaminant to vinyl chloride, which is more toxic than TCE.
Furthermore, it is uncertain how long the other principal contaminant,
technetium-99, will adhere (through adsorption) to the iron filings in the
barrier. DOE and its contractors are aware of these uncertainties and plan
to test the technology to help determine its suitability for the Paducah
site.

Technical uncertainties exist as well with the strategies currently
contemplated to address the sources of groundwater contamination. DOE
believes that the previously mentioned pockets of concentrated TCE cause
much of the groundwater contamination. If these sources cannot be removed or
isolated, they will continue to contaminate the groundwater, hindering
cleanup efforts. However, eliminating the sources of the contamination will
be difficult. Some technologies for doing so are relatively new, and some
may not be appropriate for use at the Paducah site. Accordingly, DOE is
considering and testing several innovative technologies for treatment. One
such technology is referred to as dynamic underground stripping with
dual-phase extraction. This process involves injecting steam into the
aquifer to volatilize the TCE and cause it to rise to the surface, where it
is extracted. According to EPA officials, however, difficulties with steam
injection were encountered with this technology at another site, and there
are considerable questions about whether the technology will work at Paducah
because of the complexities of the geologic formation underlying the site.

These various technical uncertainties may increase the costs of cleaning up
the site. First, should the technologies now planned for use prove
infeasible, additional costs will be incurred to test and implement
alternative technologies. And second, until the technologies for treating
both the plumes and the sources have been tested, put into place, and proven
effective, DOE will continue to incur the costs of operating the two
systems--at about $2.1 million annually--that pump water out of the aquifer
and then treat it (commonly called pump-and-treat systems) and of providing
municipal water to nearby residents and businesses. The cleanup plan assumes
that DOE will discontinue operation of the two pump-and-treat systems in
fiscal year 2005 (after a year or so of operating the permeable barriers),
but the plan presumes that the barriers will have been successful in
treating the contaminated groundwater plumes. The barriers' success depends
in part on the success of other strategies, such as the steam injection
method, in treating the contamination sources. Figure 4 shows the
contaminated groundwater plumes, the pump-and-treat wells in place, the
planned placement of the permeable treatment barriers, and the planned pilot
test of the dynamic underground stripping technology.

Figure 4: Contaminated Groundwater Plumes at the Paducah Site

Source: DOE, from May 1998 data.

As shown in figure 4, the permeable treatment barriers are not planned to
intersect the entire breadth of the groundwater plumes. Rather, the plan is
to place them in the path of the highest concentrations of contamination
within the plumes. As planned, the parts of the plumes that contain TCE
concentrations greater than 99 parts per billion will pass through a
permeable treatment barrier for remediation. In theory, as the groundwater
moves through the iron filings that constitute the barrier's treatment zone,
the TCE will be rendered harmless. Lesser concentrations of TCE--in areas of
the plume not intersected by a permeable barrier--will be left untreated to
make their way toward the river. Similarly, the portions of the plumes that
are located between the barriers and the river (referred to as the off-site
plumes) will be left untreated. For the parts of the plumes with lesser
concentrations and off-site plumes, the theory is that the TCE will
attenuate over time, and will become diluted as it mixes with the sand and
gravel near the river.

Not shown in figure 4 is the technetium-99 contamination in the groundwater.
This contamination occurs only within the northwest plume. The planned
permeable treatment barrier for the northwest plume is intended to intercept
the highest concentrations of technetium-99, which generally range from 900
to 3,789 picocuries per liter. (The drinking water standard for
technetium-99 is 900 picocuries per liter.) In theory, as the groundwater
moves through the barrier's treatment zone, the iron filings will adsorb
(i.e., attract and hold) the technetium-99 so that none of it can exit the
barrier. As with the TCE, though, the large areas of lesser concentrations
of technetium-99 contamination, ranging mainly from 25 to 899 picocuries per
liter, will be left untreated; they too are expected to attenuate over time.

While DOE's cleanup plan calls for the groundwater cleanup to be completed
by 2006, the costs of providing municipal water to nearby residences and
businesses could continue for years beyond that date, depending on the
effectiveness of the cleanup strategies. Currently, DOE pays about $78,000 a
year for the municipal water provided to approximately 100 residences and
businesses near enough to the plant to potentially be affected by the
contaminated groundwater. As the northeast groundwater plume approaches more
residences and businesses, DOE may have to connect additional homes and
businesses to municipal water supplies. DOE plans to continue providing
water to the affected residences and businesses indefinitely--until the
groundwater is safe to drink.

Finally, the permeable treatment barriers will likely require maintenance in
the future, but DOE has not included any maintenance cost in its cleanup
plan. Although the technology is too new for the length of the barriers'
efficacy to have been definitively determined, their useful life is
estimated to be between 10 and 20 years. According to a July 1999 study of a
pilot-scale permeable treatment barrier's performance over a 16-month
period,8 scientists theorize that after some period of time, the iron
filings intended to adsorb and treat the two major contaminants will lose
their effectiveness and will need to be replaced or regenerated.
Consequently, the study recommends that entities plan to replace the iron
every 10 years; the study also estimates that the replacement cost would be
about one-fourth of the original purchase cost of the iron.9 Additionally,
according to the December 1999 draft report of the technical advisory group
that has worked with the Paducah site on technology issues, the useful life
of a permeable treatment barrier is between 10 and 20 years.10 Yet in its
cleanup plan, DOE has not included any long-term operation and maintenance
costs for the treatment barriers, even though they are intended to remain in
place for 70 years. According to site officials at Paducah, because they had
no reasonable basis for estimating what such costs would be, they included
none.

Funding constraints have always been an issue, according to DOE, contractor,
and regulatory officials, and their recurrence could delay the project and
add to its ultimate costs. DOE has been criticized in the past for not
requesting the funding it needs for cleanup. Accordingly, beginning in
fiscal year 2001, site officials said their budget requests will more
closely resemble the amounts actually needed to accomplish the planned
cleanup. For fiscal years 2001 through 2010, DOE's estimates for cleaning up
the site range from a low of $78 million in 2001 to a high of $307 million
in 2008, or an average of $124 million a year. In contrast, in the 7 fiscal
years since appropriations were made from the Decontamination and
Decommissioning Fund, the site has received funding levels ranging from
about $36 million to about $52 million, an average of $43 million each year.

For fiscal year 2000, the site has received supplemental funding to
accelerate the cleanup. The amount originally appropriated for the site's
cleanup was about $37.5 million; subsequent congressional and departmental
funding actions (as of April 2000) raised that amount to about $50
million--about $14 million more than the previous year's funding.11 For
fiscal year 2001, the budget request includes about $78 million for the
site's cleanup activities. If the planned increase in funding does not
occur, the project could be delayed and its costs increased.

Optimistic

The plan's assumptions about the timely achievement of regulatory and
stakeholder agreement on cleanup levels, strategies, and priorities are
optimistic. If the assumptions are not achieved, the completion date and
costs of cleaning up the site could be affected.

During the decision-making process in cleaning up the site, regulators have
disagreed with DOE's proposed approaches. For example, an earlier version of
the cleanup plan called for constructing impermeable barriers, called caps,
over the 12 burial grounds to prevent water from entering them. However,
Kentucky disagreed with that strategy, and, as a result, DOE's current plan
is to excavate four burial grounds and possibly a fifth. In another case,
DOE cleaned up an area with PCBs in the soils to EPA's standard of 25 parts
per million for open or unoccupied space. Kentucky objected, however, saying
that it wanted the PCBs in the soils cleaned up to 1 part per million, EPA's
standard for industrial or residential use. That dispute remains unresolved,
but the parties agreed to defer its resolution until DOE has submitted its
plans for cleaning up the surface water. Kentucky has put DOE on notice,
however, that it wants a stringent cleanup level for the surface water in
order to protect the ecosystem. If DOE adopts a more stringent cleanup level
than currently planned, its costs to complete the effort will grow.

In addition, DOE has not reached agreement with regulators and stakeholders
on some issues that may prove to be contentious. For example, while DOE's
plan assumes that the site will be used for a mix of industrial and
recreational purposes after the plant has ended operations and the site has
been cleaned up, DOE has not reached consensus with the regulators and the
public on the future use of the site. According to the plan, this step would
not be taken until near the end of the planned cleanup and would become part
of the final regulatory action at the site. Yet many of the cleanup
decisions hinge on what future use is assumed. For example, a decision about
whether to cover a waste burial ground with a cap or to excavate it depends,
in part, on how that portion of the site is to be used in the future.
Assumptions about regulators' agreement with the planned disposition of all
buried waste could also affect cleanup costs. For example, although the
current cleanup plan assumes the excavation of 4 of the 12 burial grounds,
the regulators are still contemplating excavation of a fifth burial ground,
which would increase costs.

Without firm regulator and stakeholder agreement on future land use, cleanup
levels may continue to be a contentious issue and could result in additional
work, at additional cost. DOE's plan presumes that future use will be the
same as current use--predominantly industrial. However, the plan's map of
the current use includes many acres of agricultural and rural residential
land that are located directly over one of the contaminated groundwater
plumes. Residential and agricultural land must be cleaned up to more
stringent levels than industrial land. For these acres in particular, then,
the regulators may require more stringent cleanup levels for contaminated
soils and surface water. And, until the vexing problem of groundwater
contamination has been resolved, DOE will have to continue to provide
municipal water to residences and businesses located on these acres.

Adherence to DOE's cleanup schedule will also be a challenge because the
plan assumes that the regulators will comment on only one draft of
regulatory documents (such as remedial investigation reports and feasibility
study reports) and that the revised draft, with comments addressed, will be
satisfactory to all parties. In the past, however, as many as four drafts
have been required to address regulators' comments. Unless this "comment and
revise, comment and revise" cycle is broken, according to EPA officials,
scheduled milestones might be missed. These officials have suggested that
DOE bring in a technical facilitator to work with the three parties (DOE,
EPA, and Kentucky) to ensure that discussions are held and consensus reached
before the regulatory drafts are prepared. According to an EPA official,
this process was used at the Savannah River Site and was quite successful in
streamlining the site's cleanup efforts.

Public participation is also important to the success of DOE's cleanup plan,
but the public's involvement can hinder DOE's ability to meet its completion
targets. Citizens can challenge DOE plans and decisions in the courts or
through the regulatory process, and have done so. For example, DOE's plan to
demonstrate a technology, called VORTEC, to treat some types of hazardous
and radioactive wastes was challenged in the courts by a citizen who was
concerned that DOE had not adequately assessed the environmental effects of
the technology's operation. As a result of this action, DOE halted the
demonstration project until an environmental assessment could be completed.
The environmental assessment was completed in December 1999 and approved by
the Oak Ridge Operations Office in March 2000. The cleanup plan calls for
the demonstration project to treat about 865 cubic meters of waste.

Even when the planned cleanup has been carried out, billions of dollars and
many years will be needed to address areas at the Paducah site that are not
in the cleanup plan. More specifically, four areas at the site, which are
currently the responsibility of the Office of Nuclear Energy, will need to
be cleaned up. These four areas are (1) large amounts of waste and scrap
materials, (2) various unused building and structures, (3) thousands of tons
of depleted uranium, and (4) the buildings and equipment currently being
used in the enrichment process that will require cleanup when the plant
closes. The materials and structures include nearly a million cubic feet of
waste and scrap contained in DOE material storage areas (some of which pose
a risk of an uncontrolled nuclear reaction) and 16 unused and inactive
buildings and structures.12 The materials and structures are excluded from
the cleanup plan not because they require no action, but because they fall
under the purview of a different departmental program. According to the DOE
official responsible for these areas, a transfer of this area to the Office
of Environmental Management has not occurred because DOE is hesitant to
transfer any more areas to this office, which already has a large workload
and limited funding for cleanup. This programmatic distinction between the
Department's Office of Environmental Management and its Office of Nuclear
Energy prevents the Paducah cleanup managers from assessing risk or planning
cleanup on a comprehensive, sitewide basis and distorts the picture of the
cleanup task at hand. As a result, the cost and time needed to clean up this
additional material has not been estimated or included in the $1.3 billion
cleanup plan. In addition, the cleanup schedule could be impeded because
some of this material is located in areas that could interfere with the
planned cleanup. Regarding the depleted uranium, DOE recently announced
plans to build and operate a facility at Paducah to convert the 496,000 tons
of this material to a more stable form--at an estimated cost of $1.8 billion
to $2.4 billion. Finally, when USEC ceases plant operations, DOE will become
responsible for decontaminating and decommissioning the plant's numerous
remaining facilities--a process that could cost about another $1 billion.

Cleanup Schedule

Nearly 1 million cubic feet of uncharacterized waste and scrap materials not
included in DOE's cleanup plan are located on the Paducah site in what are
referred to as DOE material storage areas (DMSA). These areas, managed by
the Office of Nuclear Energy, were created in 1996 when DOE accepted
responsibility for large amounts of material stored in USEC-leased buildings
and outdoor areas. DOE accepted responsibility for these material areas to
expedite the process USEC used to obtain an operating certificate. The 148
DMSAs are in a variety of locations across the site--133 are inside eight
USEC-leased buildings; the other 15 are outdoors. The materials in these
areas include thousands of barrels of low-level radioactive waste and PCB
wastes, barrels labeled as asbestos waste, contaminated process equipment,
various items and containers whose contents are unknown, and scrap metal.
DOE has not yet determined the exact nature and extent of contamination in
these areas. Figure 5 illustrates the waste and scrap materials contained in
DMSAs across the site.

Figure 5: DMSAs Contain a Variety of Contaminated Equipment, Scrap, and
Waste Materials, Including Some Posted as Posing Nuclear Criticality Safety
Concerns

Source: DOE.

One of DOE's primary concerns with the DMSAs is that some of them might
contain radioactive material, which, in the right quantity and
configuration, could cause an uncontrolled nuclear reaction--a localized
event referred to as an inadvertent criticality. Of the 148 DMSAs, DOE has
designated 73 as having inadvertent criticality concerns. DOE's October 1999
report noted that uncharacterized radioactive and chemical equipment,
materials, and waste in DMSAs continue to present unnecessary and avoidable
risk to workers and the environment. DOE officials explained that they have
a verbal agreement to pay USEC about $4.8 million to conduct a nuclear
criticality safety review on the 10 DMSAs that have the highest risk for an
inadvertent criticality. The estimated completion date for this work is July
2000. However, this agreement does not address the need for a review of the
other 63 DMSAs that DOE has identified as having nuclear criticality safety
concerns. The schedule also does not address the characterization needed for
all 148 DMSAs to determine whether they contain material regulated under
federal environmental statutes.

According to the DOE official responsible for these areas, the DMSAs have
not been transferred to the Office of Environmental Management because DOE
is hesitant to transfer any more areas to it. The Office of Environmental
Management already has a large workload, and funding for cleanup is limited.
Because the materials in the DMSAs have not been transferred to the Office
of Environmental Management, these materials could impede the progress of
the cleanup schedule. For example, approximately 9,700 barrels of waste that
are already part of the cleanup plan are stored with uncharacterized waste
material in many of the DMSAs. At least 1,300 of these barrels are stored in
DMSAs that pose an inadvertent criticality safety concern.13 DOE procedures
prevent access to these areas without first resolving the nuclear
criticality concerns. As a result, these waste barrels cannot be retrieved
until these concerns are resolved, and the cleanup plan does not include
cost or schedule estimates for resolving the nuclear criticality issues in
these DMSAs. In addition, the location of some DMSAs could impede the
cleanup schedule. For example, three DMSAs are located outside in the same
location as much of the site's scrap yards and burial grounds, which are
expected to be cleaned up by 2010. One of these DMSAs is located on top of a
burial ground included in the cleanup plan, but, again, the cleanup plan
does not include cost or schedule estimates for removing the DMSA material.
Furthermore, DOE and contractor officials could not provide any assurances
that the material in the DMSAs, if not characterized and removed prior to
the completion of the site cleanup, would not recontaminate any cleaned up
areas.

The exclusion of DMSAs from the Office of Environmental Management's cleanup
plan has also precluded the assessment of risks on a comprehensive, sitewide
basis. From the onset of efforts to assess the site in the late 1980s, DOE's
cleanup plan and activities have been predicated on risk. The risks
posed--to area residents, to workers, and to the environment--by the various
types and sources of contamination have been assessed and addressed in order
of priority. Yet throughout the last decade, because the materials in the
DMSAs have not been characterized, the risks they pose have been excluded
from such assessments. Accordingly, DOE cannot demonstrate that it has taken
into account the comparative risks posed by all contaminated materials on
site.

Are Not Included in the Cleanup Plan

Although DOE's cleanup plan includes the decontamination and decommissioning
of two unused contaminated buildings, it does not include 16 other unused
buildings and structures. These other buildings and structures are currently
monitored and maintained by DOE's Office of Nuclear Energy. These buildings
and structures, which were originally used as part of the enrichment
process, include a 120,000-gallon sludge lagoon, two 250,000-gallon water
storage tanks, a nitrogen generation plant, and an incinerator previously
used for disposing of contaminated items. DOE and contractor officials
explained that several of these buildings and structures probably contain
some contamination. According to DOE and contractor officials, lack of
funding and higher priorities have prevented these 16 buildings and
structures from being transferred to the Office of Environmental
Management's cleanup plan. These officials explained that the two buildings
to be decontaminated and removed were probably transferred to the cleanup
plan several years ago because they are the largest and most contaminated of
the unused buildings and thus presented the highest risk to worker safety
and the environment. As with the DMSAs, because they have not been
transferred to the cleanup program, the remaining 16 buildings and
structures have not been included in a comprehensive, sitewide risk
assessment.

Addressed

Approximately 496,000 tons of depleted uranium hexafluoride, the majority of
which is currently stored on site in 14-ton capacity cylinders, are not
included in the cleanup plan. This material resulted from many years of
uranium enrichment operations and is managed by the Office of Nuclear
Energy. In addition to being radioactive, uranium is a heavy metal that can
have toxic chemical effects. This material also poses risks if released to
the atmosphere because the compounds that are formed in the air are
chemically toxic. The advanced age of some of the steel cylinders and the
way in which they were originally arranged--sometimes too close together to
permit inspection; sometimes in direct contact with the ground, leading to
enhanced cylinder corrosion--have created a potential environmental and
safety hazard. The October 1999 DOE report noted that these cylinders
constitute a radiological exposure hazard and a potential threat to worker
and public health in the event of fire and rupture. The Defense Nuclear
Facilities Safety Board recommended in 1995 that DOE improve the storage and
maintenance of the cylinders.14

DOE issued a plan in July 1999 to convert depleted uranium hexafluoride
stored at Paducah, Portsmouth, and Oak Ridge.15 The plan is consistent with
the preferred cleanup strategy selected in the environmental impact
statement prepared for the conversion plan.16 The strategy specified that
the conversion of the depleted uranium hexafluoride inventory to uranium
oxide, to uranium metal, or a combination of both, should begin as soon as
possible.17 It includes the construction and operation of conversion
facilities at the Paducah and Portsmouth sites. DOE expects to issue a
request for proposals to construct the conversion facilities in October
2000. DOE has estimated a lifecycle cost of its conversion plan--including
operating the facilities for nearly 25 years, storage, and disposing of the
unused converted material--at between $3 billion and $4 billion. Paducah's
share of this cost is between $1.8 billion and $2.4 billion. DOE has not
identified any significant uses for this material once it has been
converted. DOE recognizes that this plan represents a major new undertaking
and involves a significant investment of resources beyond amounts available
in the current budget.

Decontamination and Decommissioning

DOE's cleanup plan does not reflect the costs of decontamination and
decommissioning that will be required after USEC ceases plant operations and
terminates its lease with DOE. The lease includes process buildings and
areas outside these buildings. In a January 1998 report, DOE estimated a
cost of approximately $1 billion to decontaminate and decommission the
buildings and associated equipment and materials.18 This estimate, however,
did not include costs for removing any of the site's four large process
buildings. Rather, it assumed that these facilities would be decontaminated
and reused for industrial purposes. The estimate also did not include the
$1.8 billion to $2.4 billion associated with Paducah's share of the
disposition of the depleted uranium, which is addressed in DOE's uranium
conversion plan discussed above. DOE is currently revising the
decontamination and decommissioning cost estimate to more accurately assess
numerous assumptions, including the extent to which materials from the site
could be recycled and the extent to which site facilities could be reused.

DOE faces significant challenges in cleaning up the Paducah site. First,
given the many uncertainties and optimistic assumptions inherent in the
cleanup plan, there is reason to doubt that the Department will complete its
planned cleanup actions by 2010 within the estimated $1.3 billion cost.
Furthermore, if the cleanup plan is carried out as currently envisioned,
billions of dollars and many years will be required to address areas not
included in the current cleanup plan. For example, additional costs and time
will be required to address about 1 million cubic feet of waste and
contaminated scrap that is contained in DOE's material storage areas, 16
unused buildings, and other structures that will remain on site. Since these
areas are not in the cleanup plan, no estimates of the cost or time to clean
up these areas have been included in the plan. The additional materials,
buildings and structures are excluded from the cleanup plan not because they
require no action, but because they fall under the purview of a different
departmental program. According to the DOE official responsible for these
areas, these areas have not been included in the cleanup plan because DOE is
hesitant to transfer any more areas to the Office of Environmental
Management, which already has a large workload and limited funding for
cleanup. This programmatic distinction between the Department's Office of
Environmental Management and its Office of Nuclear Energy prevents the
Paducah cleanup managers from assessing risk or planning cleanup on a
comprehensive, sitewide basis and distorts the picture of the cleanup task
at hand. In addition, DOE officials estimated that it might cost between
$1.8 billion and $2.4 billion to operate the conversion facility at Paducah
for nearly 25 years and to store and dispose of the unused converted
material. Finally, according to DOE's January 1998 estimate, another $1
billion would be needed for final decontamination and decommissioning
activities when the plant ceases operations and is returned to DOE.

To ensure that priorities are established on a comprehensive, sitewide basis
to clean up and dispose of materials that are potential health hazards and
that a more comprehensive picture of cleanup is presented to the Congress,
we recommend that the Secretary of Energy transfer the responsibility for
the material storage areas and the unused structures from its Office of
Nuclear Energy to its Office of Environmental Management. In addition, we
recommend that the Secretary direct the Office of Environmental Management
to address in the cleanup plan, regardless of the current organizational
responsibility, any and all materials at the site that are potential health
hazards and to reexamine the sitewide contamination risks and cleanup
priorities, costs, and schedules.

We provided a draft of this report to DOE for its review and comment. DOE
raised two general issues about our draft report. First, DOE believes that
while the draft report provides a detailed description of waste and
materials that need to be cleaned up at the Paducah site, it did not account
for ongoing work and improvements at the site. Second, DOE stated that the
draft report describes many of the uncertainties that DOE recognizes will
affect cleanup progress, but notes that the report did not offer specific
alternatives or recommendations regarding planning assumptions and targets
for completing work. The full text of DOE's comments are in appendix II.

We disagree with DOE's characterization that our draft report does not
account for progress made in cleaning up the site. We believe that the
report clearly describes the actions taken by DOE to date and discusses the
status of each of the areas for early action that DOE identified. We pointed
out in our draft report that the cleanup actions on each of these areas are
in the early stages, will not be completed for years, and will face
challenges as they proceed. In addition, the draft report stated that DOE
and the regulators have been discussing planned cleanup activities and
approaches. However, it should be noted that there are still areas of
disagreement between DOE and the regulators, and that cleanup of many of
these areas is just beginning or has not yet begun.

We agree that our draft report did not offer planning assumptions or targets
for DOE to complete its cleanup work. This was not an objective of our work
nor is it our role. Our objective was to provide the Congress with an
understanding of the scope and cost of the cleanup and the challenges and
uncertainties that will affect DOE's ability to accomplish it. We have
included a number of examples of where DOE's plans will face challenges or
uncertainties and point out that delays and additional costs could occur
depending on the decisions made. For example, the draft report noted that
there is disagreement with regulators regarding the cleanup levels for PCBs,
the timing and number of sedimentation basins to be built, the number of
waste burial grounds to excavate, and the future land use at the site. The
cost and timing of the site cleanup will not be known until the areas of
disagreement are resolved.

DOE also provided technical clarifications to the draft report. In these
clarifications, DOE stated that the draft report's recommendation to
transfer management responsibility for the DOE material storage areas and
unused buildings should be revised to recognize the need for advance
planning to ensure safety risks are identified and addressed prior to any
transfer. DOE also believed that the draft report's recommendation for a
sitewide review of cleanup priorities should be revised to acknowledge the
role of regulators and the review currently being conducted by DOE, EPA, and
the Commonwealth of Kentucky. We recognize that, as with most significant
changes to programs, that prior planning will need to be conducted and that
participation by various parties may be required. We would expect DOE to use
good management practices in implementing such changes. As a result, we made
no changes to the recommendations. DOE's other technical clarifications were
incorporated, as appropriate.

To determine the cleanup plan's cost, schedule, and activities, we
interviewed officials from DOE's offices of Environmental Management;
Nuclear Energy; and Environment, Safety, and Health. In addition, during
three visits, we interviewed officials from DOE's Oak Ridge Operations
Office, which is responsible for managing the Paducah site, reviewed
documents related to the cleanup, and toured the Oak Ridge uranium
enrichment cleanup site. During three visits to the Paducah site, we
interviewed managers responsible for Environmental Management and Nuclear
Energy and toured the site on two separate occasions to examine specific
areas of cleanup. We also toured the USEC facility to increase our
understanding of the uranium enrichment process. Also at the site, we
interviewed representatives from Bechtel Jacobs responsible for the six
categories of cleanup, finance, and planning, and reviewed site-specific
documents, including the fiscal year 2000 and the January 26, 2000,
Lifecycle Baselines; the Federal Facility Agreement, including the Site
Management Plan; the Site Treatment Plan for Low-level Mixed Waste; the Oak
Ridge Operations Office Integrated Priorities List; and DOE's draft report
entitled 1999 Paths To Closure.

To identify the challenges facing DOE in accomplishing its cleanup plan and
to determine whether the plan includes all areas at the site that require
cleanup, we interviewed officials from DOE's offices of Environmental
Management; Nuclear Energy; and Environment, Safety, and Health. In
addition, during three visits, we interviewed officials from DOE's Oak Ridge
Operations Office, which is responsible for managing the Paducah site, and
toured the Oak Ridge uranium enrichment cleanup site. During three visits to
the Paducah site, we interviewed managers of DOE's offices of Environmental
Management and Nuclear Energy and toured the site on two separate occasions.
We also interviewed representatives from Bechtel Jacobs responsible for the
six categories of cleanup, finance, and planning. In addition, we
interviewed officials from EPA Region IV, the Commonwealth of Kentucky's
Department for Environmental Protection, and an official from the Office of
the Governor of Kentucky. We also interviewed the chairman of the Paducah
Site Specific Advisory Board and attended one of the board's monthly
meetings. We reviewed studies of various cleanup technologies, site-specific
progress reports and plans for each category, and testimony from
congressional hearings.

We conducted our review from October 1999 through April 2000 in accordance
with generally accepted government auditing standards.

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 interested
congressional committees; the Honorable Bill Richardson, Secretary of
Energy; the Honorable Carol M. Browner, Administrator, Environmental
Protection Agency; the Honorable Jacob J. Lew, Director, Office of
Management and Budget; the Honorable Paul Patton, Governor of the
Commonwealth of Kentucky; Mr. James E. Bickford, Secretary, Kentucky Natural
Resources and Environmental Protection Cabinet; and other interested
parties. We will also make copies available to others on request.

If you have any questions about this report, please call me at (202)
512-3841. Key contributors to this report were Erin Barlow, Daniel Feehan,
Glen Trochelman, and Pam Tumler.

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

Cleanup Plan Focuses on Six Major Categories of Effort

The Department of Energy's (DOE) cleanup plan for the Paducah site addresses
the cleanup of four contaminated media: groundwater, surface water, soils,
and burial grounds. It also includes two other categories of effort: the
site's treatment and disposition of about 52,000 barrels of waste that are
stored on-site, and the removal of two contaminated, unused buildings. As of
January 2000, DOE estimates that the cleanup will be finished by 2010, at a
total cost of $1.3 billion.

Contaminated Water

Through investigations beginning in 1988, when hazardous and radioactive
contamination was found in the drinking water wells of residences near the
Paducah plant, DOE discovered that plumes of contaminated groundwater were
heading north of the plant toward the Ohio River. A major source of the
contamination was later found to be the C-400 building, where a toxic
solvent called trichloroethene, or TCE, had been used for years to degrease
parts and equipment. Upon discovering the contamination, DOE took a number
of steps to minimize the danger to human health and the environment. For
example, it provided safe drinking water to neighboring homes and
businesses, undertook efforts to determine the extent of the contamination,
and began a program to pump out some of the water and treat it (commonly
called a pump-and-treat system). DOE's long-range cleanup plan calls for two
cleanup strategies--one to reduce the sources of the contamination and the
other to trap and neutralize the highest concentrations of contaminants in
the plumes.

DOE estimates that about 10 billion gallons of groundwater has been tainted
with TCE, and 250 million gallons with radioactive technetium-99, a fission
product. The levels of concentration have been found in places to far exceed
the Environmental Protection Agency's (EPA) drinking water standards. The
TCE contamination in groundwater has been identified in two major plumes
covering more than 3.75 square miles, one heading northwest of the plant and
the other heading northeast. Another smaller plume, discovered in about
January 1999, heads southwest and then turns toward the north. According to
DOE officials, the contaminated groundwater plumes are estimated to be
moving at about a foot per day toward the Ohio River (3 miles north of the
plant). DOE cannot say with certainty whether the leading edges of the
plumes have reached the river; however, officials believe that the
technetium-99 plume (heading northwest from the plant) has possibly reached
the river. Results from recent samples did not show significant amounts of
either contaminant in the river.

DOE has taken a number of actions since the discovery of the groundwater
contamination. Citizens affected by the contaminated groundwater were
provided with safe drinking water and were connected, at DOE's expense, to
the municipal water system. As of January 2000, DOE had connected over 100
residences and businesses to the municipal water supply, at a capital cost
of about $1 million and continuing monthly water costs of about $6,500.

In addition, since the discovery of the contamination, a number of studies
have been done to determine the extent and nature of the contamination in
the groundwater. For example, DOE has identified a degreasing and equipment
cleaning building (the C-400 building) as a primary source of TCE
contamination. DOE is currently evaluating the data available from
groundwater sampling.

As an interim measure, DOE installed two pump-and-treat systems to remove
some of the contaminated groundwater, which is then treated. The
pump-and-treat system on the northwest plume began operating in August 1995.
By June 1999, it had processed about 385 million gallons of water. The
pump-and-treat system on the northeast plume began operating in January 1997
and by June 1999 had processed about 213 million gallons of water. The
estimated capital cost (that is, design and construction) for the two
systems was about $20 million. For fiscal year 1999, the estimated
operations and maintenance cost for both systems was $2.1 million. Once a
final cleanup strategy has been selected and proven effective, DOE's plan
calls for removing the pump-and-treat systems.

DOE's planned cleanup strategy involves the use of two technologies. These
technologies are designed to (1) remove the sources of contamination and (2)
treat the contaminated groundwater plumes as they move off-site. To remove
the source of the contamination, DOE's plan calls for the use of a process
called dynamic underground stripping, with dual-phase extraction. In
essence, this process injects steam into the ground so the contaminants
rise, then extracts and treats the contaminants. Other processes for
removing the contamination sources will be considered and pilot-tested as
well. To clean the water in the plumes, the planned strategy is to use
permeable treatment barriers. This technology involves installing about
4,300 feet of barriers (or possibly as many as 6,000 feet) by injecting into
the aquifer--at a depth between 60 and 120 feet--a gummy substance, called
guar gel, containing iron filings. These permeable barriers, which will be
placed across the paths of the highest concentrations of contamination in
the plumes, will allow the groundwater to pass through, but the iron filings
in the barriers will adsorb the technetium-99 and treat the TCE. DOE plans
to conduct a pilot test of the permeable treatment technology in 2000 and,
if the pilot test proves successful, to then begin constructing the
full-scale barriers. Construction is planned for completion in 2003. The
total cost of cleaning up the groundwater is estimated at $162 million and
is expected to be completed by 2006.

DOE has discovered surface water contamination in creeks, ditches and sludge
lagoons. Two streams flank the plant: Bayou Creek to the west and Little
Bayou Creek to the east. Stormwater runoff and wastewater from plant
operations discharge to these streams through a series of ditches. Each
discharge point is monitored to ensure that the effluent entering the stream
is within the parameters of the discharge permit issued by the Commonwealth
of Kentucky. Contaminants of concern are technetium-99, solid uranium
tetrafluoride ("green salt"), uranium-contaminated silts and sediments,
radionuclides, metals, and polychlorinated biphenyls (PCBs).

One of the principal sources of this contamination is the approximately
65,000 tons of scrap metal stored in the northwest portion of the site. Much
of the scrap metal was placed there over the years. Part of this scrap
includes a pile of about 8,000 tons of crushed drums--commonly called Drum
Mountain--that were once used to store depleted uranium. Although the drums
were emptied before being crushed, residual uranium (known as green salt)
remains on or in them.

DOE has conducted a number of assessments and taken some interim measures to
minimize surface water contamination. The assessments have included taking
radiation readings in the creeks and ditches inside and outside the plant
and monitoring the water being released off-site. As an interim measure, DOE
has taken steps to reduce the amount of contamination leaving the site. For
example, it installed a gabion (a cage filled with rocks) to reduce the
migration of contaminated sediments when it rains. Also, some wastewater
from the United States Enrichment Corporation's (USEC) operations is now
diverted away from the most contaminated portion of a main ditch, the
north-south diversion ditch. In another action, DOE constructed two settling
lagoons that collect contaminants from wastewater before releasing it
off-site. Still another interim action involved installing a system, within
an active USEC process building, to treat technetium-99. Process water
tainted with high levels of technetium-99 is routed through the treatment
system, over and over again, until the system can reduce the contaminant
level no further. DOE officials say this action has accomplished its
objective, as have the other actions, because the process water is not only
treated but also no longer discharged into the north-south diversion ditch.
Instead, it is discharged into a USEC-controlled ditch on DOE property.
Nevertheless, the treatment system has been unable to treat the
technetium-99 to drinking water standards since October 1998, when USEC
restarted its cylinder washing program in the building that houses the
treatment system. Since October 1998, the levels of technetium-99 in the
wastewater being discharged onto DOE property have at times been quite high.
In one instance, the levels exceeded 17,000 picocuries per liter, nearly 20
times the drinking water standard of 900.

DOE's plan for addressing the surface water contamination includes removing
the scrap metal (including Drum Mountain), conducting additional
assessments, and taking steps to clean up the existing contamination in the
ditches and other locations. DOE's plan for the scrap metal is to have a
contractor remove and dispose of Drum Mountain by December 2000 at a cost of
about $7.1 million. The remainder of the scrap metal is to be removed by
2003, according to the federal facility agreement. But the DOE plan
contemplates completing removal of the remaining scrap metal in fiscal year
2004, at a cost of about $74 million. Planned cleanup activities include
excavating at least four contaminated ditches and various other areas,
installing up to four sedimentation basins to catch contaminated surface
water runoff from the plant, and installing a new storm sewer segment. The
total cost for cleaning up the surface water has been estimated at more than
$162 million, with a completion date of 2007.

DOE has identified 72 areas on the site that contain contaminated soil. The
primary contaminants are PCBs and radionuclides. To date, DOE has focused
primarily on assessing the extent of the problem and using an innovative
technology to clean one area of heavily contaminated soil. DOE's plan for
cleaning up the surface soil includes conducting additional assessments and
excavating contaminated soils. However, some of the cleanup work will have
to be deferred until the plant has closed because some of the contaminated
areas, such as the electrical switchyards, are in use by USEC. The deferred
work will be addressed during the final decontamination and decommissioning
of the plant after its closure.

DOE has employed an innovative technology to remediate some of the most
heavily contaminated soil. As a result of past cylinder drop-testing
operations at one area on the site, about 1.7 acres in size, an estimated
430 gallons of TCE leaked into the site's shallow soil and groundwater. At
this area, to reduce the potential for contaminant migration, DOE conducted
demonstrations from 1995 through 1997 of an innovative technology called
LASAGNA.19 This technology uses electroosmosis to move shallow groundwater
and contaminants through in-ground treatment zones. (The technology is named
for its layered structure of electrodes and treatment zones.) In
demonstrations, the LASAGNA technology reduced TCE concentration levels from
hundreds of parts per million to less than 2 parts per million. DOE selected
LASAGNA for full-scale remediation of the area, and the LASAGNA cleanup is
expected to be completed by 2003.

DOE's other planned activities include conducting additional assessments and
excavating and disposing of contaminated soils. The additional assessments
are to be completed by 2005 at a cost of about $8.7 million. DOE plans to
excavate about 35,000 cubic yards of soil, at average depths of 1 to 3 feet,
but as deep as 16 feet when necessary. The total surface soil cleanup is
expected to be completed by 2007 at a cost of about $19 million.

DOE's cleanup plan includes estimates for excavating the material from 4 of
its 12 burial grounds, and DOE is contemplating the excavation of a fifth
burial ground. DOE considers the other burial grounds to pose less of a
risk--these other burial grounds include closed landfills that are included
in DOE's long-term monitoring program. Previous investigations of two burial
grounds identified a variety of contaminants, including uranium, PCBs,
arsenic, benzene, beryllium, cadmium, copper, nickel, tricholoroethene,
toluene, and zinc. DOE's cleanup plan estimates approximately $535 million
for the cleanup of these areas with a completion date of 2010. The majority
of these costs stem from the cost of disposing of the excavated material.

DOE made a preliminary assessment of the risk posed to worker safety and the
environment for each of 12 burial grounds at the Paducah site and divided
them into three risk categories--principal threat, moderate threat, and low
threat. This assessment was the result of discussions between DOE, EPA, and
Kentucky officials that began in November 1999. DOE designated four of the
burial grounds, and a portion of another, as posing a principal threat to
worker safety and the environment--the current cleanup plan includes
estimates for excavating these areas. The estimated contents of one of the
principal-threat burial grounds include 270 tons of uranium (most of it
pyrophoric), 59,000 gallons of oils, and 450 gallons of trichloroethene.20
DOE has designated three other burial grounds as posing a moderate threat,
including one that DOE is still considering excavating. 21 The cleanup plan
includes placing a protective cap over these areas to mitigate the spread of
contamination. DOE designated the remaining five burial grounds as low
threat--three of these burial grounds are closed landfills that have a
protective cap and are under DOE's long-term monitoring program; a
protective cap is planned for the fourth burial ground, and the fifth burial
ground is the site's operating landfill.

Paducah has the equivalent of 52,000 55-gallon barrels of waste stored in
various locations on the site. Most of the barrels contain materials that
have a low level of radioactivity. To date, DOE has been assessing the
contents of the barrels and containers. Since 1990, DOE has shipped from the
site the equivalent of 754 barrels of low-level waste. DOE's plan calls for
disposing of the waste off-site after it has been characterized and treated
or repacked if necessary.

The majority of the 52,000 barrels of waste were generated before the
production facilities were leased to USEC, but some waste continues to be
generated by DOE's cleanup activities. The 52,000 barrels are located
throughout the site and contain a variety of waste (radioactive and
hazardous). More than 12,400 barrels of low-level waste are stored outside
and are in deteriorating condition.22 There are about 20,300 barrels of
mixed low-level waste, consisting mainly of PCB waste, and 31,200 barrels of
low-level waste, which is mainly soil and debris.23 In addition, Paducah has
21 barrels with higher levels of radioactivity (called transuranic waste).
The site also has about 142 metric tons of hazardous waste, some of which
must be incinerated and cleaned of radioactive contamination before it can
be shipped off-site.

Federal law and regulations require that the barrel contents be identified
for proper storage and disposal. The characterization of waste in barrels
has been completed for on-site storage and for the waste barrels that have
been shipped to off-site facilities for disposal. But 1,760 barrels require
additional characterization to meet a recent EPA storage requirement.

DOE currently plans to ship off-site all waste that cannot be put in the
on-site landfill. Additional characterization is needed for over 42,000
barrels of mixed and low-level waste before they can be treated and shipped
off-site. DOE has estimated that about 80 percent of its waste will meet the
waste acceptance criteria of a private waste disposal contractor
(Envirocare, in Utah) and that only the remaining wastes that exceed these
criteria will likely be sent to DOE's Hanford facility in Washington State.

DOE revised the cleanup plan to accelerate the removal of certain wastes by
fiscal year 2006. As a part of this action, it gave priority removal of
low-level waste stored outdoors. Because of the deteriorated condition of
some of these barrels, DOE has determined that it will be necessary to
repack some of them before they can be shipped off-site. The disposal of the
52,000 barrels is expected to be completed in 2010 at a cost of $228
million. DOE's lifecycle baseline also includes a demonstration project to
treat, before disposal, some of the waste that contains both hazardous
materials and low levels of radioactive materials. This assumption is
predicated on the successful use of the technology, permitting of the
project, and an assessment of its environmental impact. The project is
currently on hold; however, by the end of fiscal year 2002, the cleanup plan
calls for the demonstration project to treat about 865 cubic meters of
waste.

the Site and Removing Two Contaminated Buildings

DOE's cleanup plan includes monitoring and maintaining the site area and
facilities before, during, and after remedial activities and continuing to
monitor as necessary to support future cleanup actions. As part of the
monitoring and maintenance activities, the plan calls for demolishing two
contaminated, unused buildings on the site.

The two contaminated buildings were originally used to produce the uranium
materials and to fabricate metal. The buildings were transferred from DOE's
Office of Nuclear Energy to its Office of Environmental Management several
years ago. General maintenance has been done on the buildings; however, a
recent DOE investigation found that large volumes of low-level waste are
stored inside the buildings and that contamination within the buildings is
spreading.

In December 1999, DOE decided to include in the cleanup plan the
decontamination and demolition of the two buildings. DOE estimates that $92
million will be needed to remove these buildings by 2008.

As part of DOE's long-term stewardship responsibilities, monitoring and
maintenance activities will continue long past the 2010 cleanup completion
target. The costs for this long-term stewardship are not included in the
$1.3 billion cleanup estimate. Planned long-term activities include routine
maintenance activities, such as mowing grass, replacing signposts,
maintaining groundwater monitoring wells, repairing fences, and conducting
and reporting on periodic inspections. DOE officials said that long-term
stewardship could continue through 2070.

Comments From the Department of Energy

141396

Table 1: DOE's Estimated Cost and Schedule for Six Cleanup
Categories at the Paducah Site, as of January 2000 14

Figure 1: Aerial View of the Paducah, Kentucky, Uranium
Enrichment Plant 7

Figure 2: Scrap Metal Stored on Site, With a Close-up View
of "Drum Mountain" (30 to 40 feet in height) 11

Figure 3: Two Unused, Contaminated Buildings to Be
Demolished During Cleanup 13

Figure 4: Contaminated Groundwater Plumes at the Paducah Site 19

Figure 5: DMSAs Contain a Variety of Contaminated Equipment,
Scrap, and Waste Materials, Including Some Posted
as Posing Nuclear Criticality Safety Concerns 26
  

1. The uranium enrichment process prepares uranium for use as a nuclear
reactor fuel by converting natural uranium into a mixture richer in the
fissionable isotope uranium-235.

2. The Office of Oversight conducts integrated safety management
evaluations, special reviews and studies, and follow-up reviews. Phase I:
Independent Investigation of the Paducah Gaseous Diffusion Plant (Office of
Oversight; Office of Environment, Safety and Health; Department of Energy;
Oct. 1999).

3. Pyrophoric uranium has a tendency to spontaneously combust in the
presence of oxygen.

4. This waste is stored in a variety of containers, such as 55-, 85-, and
110-gallon barrels. The total volume of waste stored at Paducah is
equivalent to the volume of about 52,000 55-gallon barrels.

5. DOE's October 1999 report identified about 8,500 barrel equivalents of
this waste. During our review, DOE identified another approximately 3,900
barrel equivalents of waste stored outdoors.

6. The DOE Assistant Secretary for Environmental Management provided this
estimate in an Oct. 26, 1999, hearing before the Subcommittee on Energy and
Water Development, Senate Committee on Appropriations.

7. Technology Summary: Subsurface Contaminants Focus Area; Department of
Energy; Aug. 1996.

8. ESTCP Cost and Performance Report: Permeable Reactive Wall Remediation of
Chlorinated Hydrocarbons in Groundwater, Environmental Security Technology
Certification Program; Department of Defense; July 1999.

9. For the study report's subject barrier, the purchase cost of the iron was
$450 per ton, and 75 tons were required for the barrier's treatment section,
which was 10 feet long, 6 feet thick, and 22 feet deep. In contrast, the
treatment barriers planned for the Paducah site will be at least 4,300 feet
long.

10. Draft Report, Paducah Project Innovative Technology Review, Technical
Advisory Group, Paducah Project, Innovative Treatment Remediation
Demonstration Program; Sandia National Laboratories; Albuquerque, New
Mexico; Dec. 1999.

11. As of April 19, 2000, an additional supplemental request for $8 million
had not been approved, according to DOE officials.

12. According to DOE, this type of an event, referred to as an inadvertent
criticality, includes a burst of radiation and generally lasts several
hours. DOE describes this event as a worker safety issue rather than a
public health or safety issue. It is a localized event that would not result
in an explosion, release of radioactivity to the atmosphere, or--in the case
of Paducah--damage to the uranium enrichment process.

13. These 9,700 barrels (approximately 4,500 barrels of low level waste and
5,200 barrels of radioactive PCB waste) represent approximately 7 percent of
the 1 million cubic feet of material in the DMSAs.

14. The Defense Nuclear Facilities Safety Board is an independent agency
created by the Congress in 1988 to oversee DOE's defense nuclear facilities
and to ensure that public health and safety are protected.

15. Final Plan for the Conversion of Depleted Uranium Hexafluoride, Office
of Nuclear Energy, Science and Technology; Department of Energy; July 1999.

16. Final Programmatic Environmental Impact Statement for Alternative
Strategies for the Long-Term Management and Use of Depleted Uranium
Hexafluoride, DOE/EIS-0269; Office of Nuclear Energy, Science and
Technology; Department of Energy; Ap. 1999.

17. In addition to the depleted uranium hexafluoride stored on-site at
Paducah, approximately 218,000 tons are stored at the Portsmouth plant and
another approximately 62,000 tons are stored at the Oak Ridge plant.

18. D&D Estimate of Gaseous Diffusion Facilities Incorporating Site
Reindustrialization, prepared for DOE by Lockheed Martin Energy Systems,
Inc.; Jan. 1998.

19. The term LASAGNA has been trademarked by Monsanto.

20. This pyrophoric uranium, which has a tendency to spontaneously combust
in the presence of oxygen, was usually placed in drums with petroleum-based
or synthetic oils used to stabilize the waste.

21. DOE also designated the 65,000 tons of scrap metal being addressed under
the surface water portion of the cleanup plan as a moderate threat. The
cleanup plan includes estimates for placing a protective cap over these
areas.

22. DOE's October 1999 report identified the equivalent of approximately
8,500 55-gallon barrels of waste stored outdoors. During our review, DOE
identified another approximately 3,900 barrels of waste stored outdoors.

23. A Becthel Jacobs official responsible for waste management explained
that these figures might be underestimated because the waste is stored in a
variety of containers, and he had to calculate the barrel equivalents. He
recommended that we use 52,000 barrels for the total stored on site.
*** End of document. ***