Nuclear Cleanup: Completion of Standards and Effectiveness of Land Use
Planning Are Uncertain (Letter Report, 08/26/94, GAO/RCED-94-144).

During 50 years of nuclear weapons production, the Energy Department
(DOE) and its predecessor agencies have generated huge amounts of
radioactive wastes that have contaminated soil and groundwater. As a
result, DOE faces a massive, complex, and costly cleanup effort. During
the next several years, DOE and the Environmental Protection Agency
(EPA) will decide on methods to be used for environmental cleanup at DOE
sites. Standards for "how clean is clean enough" and information about
future land uses of DOE sites would help in selecting appropriate
remedial actions. Past efforts to develop cleanup standards for
radioactive substances were unsuccessful. This report determines (1) how
cleanup levels are now determined for DOE sites, (2) the status and the
likelihood of success of EPA's efforts to develop cleanup standards for
radioactive substances, (3) the status of DOE's land use planning
efforts, and (4) what hurdles would need to be overcome if land use
planning were to be effectively implemented in determining cleanup
levels.

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

 REPORTNUM:  RCED-94-144
     TITLE:  Nuclear Cleanup: Completion of Standards and Effectiveness 
             of Land Use Planning Are Uncertain
      DATE:  08/26/94
   SUBJECT:  Standards evaluation
             Radiation exposure hazards
             Interagency relations
             Land management
             Environmental engineering
             Radioactive waste disposal
             Environmental monitoring
             Cost control
             Hazardous substances
             Pollution control
IDENTIFIER:  EPA National Priorities List
             Colorado
             Washington
             Ohio
             DOE Hanford Future Site Uses Study
             South Carolina
             Idaho
             Nevada
             Texas
             
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Cover
================================================================ COVER


Report to the Chairman, Committee on Governmental Affairs, U.S. 
Senate

August 1994

NUCLEAR CLEANUP - COMPLETION OF
STANDARDS AND EFFECTIVENESS OF
LAND USE PLANNING ARE UNCERTAIN

GAO/RCED-94-144

Nuclear Cleanup Standards


Abbreviations
=============================================================== ABBREV

  ARARs - applicable or relevant and appropriate requirements
  CERCLA - Comprehensive Environmental Response, Compensation, and
     Liability Act
  DOE - Department of Energy
  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  NRC - Nuclear Regulatory Commission

Letter
=============================================================== LETTER


B-256595

August 26, 1994

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

Dear Mr.  Chairman: 

During 50 years of nuclear weapons production, the Department of
Energy (DOE) and its predecessor agencies have generated large
volumes of radioactive wastes that have resulted in the contamination
of soil, groundwater, and surface water.  As a result, DOE faces a
massive, complex, and costly cleanup effort.  Over the next several
years, DOE and the Environmental Protection Agency (EPA) will decide
on methods to be used for environmental remediation at DOE's various
sites.  Standards for "how clean is clean enough" and information
about future land uses of DOE's sites would be beneficial in
selecting appropriate remedial actions.\1 Previous efforts to develop
cleanup standards for radionuclides (radioactive substances) were not
successful. 

In light of upcoming remediation decisions and past delays in
developing cleanup standards for radionuclides, you asked us to
review DOE's and EPA's progress in determining cleanup standards and
land uses.  Specifically, you asked us to determine (1) how cleanup
levels are currently determined for DOE's sites, (2) the status and
likelihood of success of EPA's efforts to develop cleanup standards
for radionuclides, (3) the status of land use planning efforts at
DOE, and (4) what hurdles would need to be overcome if land use
planning were to be effectively implemented in determining cleanup
levels. 


--------------------
\1 We use the term standards to apply to any possible type of
regulatory criteria for cleanup of radioactive contaminants,
including (1) a limit on the cancer risk level or radiation dose from
radioactive contamination remaining after cleanup or (2)
concentration levels limiting contaminants in soil and/or water. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

In the absence of comprehensive federal standards specifically
designed for cleaning up radioactive contamination, EPA uses other
federal and state environmental standards it considers to be relevant
and appropriate when selecting a remedial action for DOE's sites. 
The current process for identifying what standards will be used can
be time-consuming and result in varying cleanup levels at different
sites.  Furthermore, the lack of cleanup standards for radionuclides
makes it very difficult for DOE to plan and estimate costs for its
cleanup program and disposal of waste.  Realistic goals for cleanup
are particularly critical for DOE because of the magnitude of its
contamination problems and the technological difficulties associated
with treating radioactive contamination and disposing of radioactive
wastes.  Cleanup costs are estimated to be at least $300 billion. 

An interagency group led by EPA and including DOE, Nuclear Regulatory
Commission (NRC), and Department of Defense officials has been
working since December 1992 to develop cleanup standards for
radionuclides.  EPA expects to publish a proposed rule in the fall of
1994 but has not set a specific time frame for issuing a final rule. 
Previous interagency efforts to establish standards were not
successful because of a lack of resources and low priority.  While
the current effort has been assigned greater priority and resources,
its success is still uncertain because of the complexity and
controversial nature of the issues that must be resolved. 

A 1991 study by the Advisory Committee on Nuclear Facility Safety to
DOE recommended that land use planning be used to help identify
realistic cleanup levels.  As a result, DOE has begun land use
planning efforts.  DOE completed a future site uses study in December
1992 for the Hanford (Washington) site, and similar studies are
beginning at DOE's Rocky Flats (Colorado) and Fernald (Ohio) sites. 
DOE set a goal of completing land use plans for its sites by the end
of 1995. 

Some hurdles need to be overcome if land use planning is to be
effectively implemented.  First, EPA generally assumes that land will
be used for residential purposes, which results in the most stringent
environmental requirements being imposed on every cleanup project. 
EPA is seeking congressional direction and clarification on how it
could consider other land uses in selecting remedies and setting
cleanup levels.  Second, where cleanups do not achieve a level
appropriate for residential use, residual contamination may be left
on site, and restrictions on land use may be needed.  Although the
Comprehensive Environmental Response, Compensation, and Liability Act
of 1980, as amended (CERCLA), requires periodic reviews of sites with
residual contamination, EPA's guidance for such reviews does not
adequately address restrictions on land use. 


   BACKGROUND
------------------------------------------------------------ Letter :2

DOE is responsible for environmental cleanup and waste management at
more than 130 contaminated installations in 34 states and
territories.  Nineteen of DOE's installations/sites are on the CERCLA
National Priorities List, which identifies the most hazardous
inactive waste sites.  Contaminants at DOE's sites include substances
that can cause cancer, birth defects such as mental retardation, and
toxic effects to the nervous system, eyes, and other organs.  Cleanup
activities will need to address wastes, soil, surface water,
groundwater, and structures contaminated by hazardous and/or
radioactive substances.  For example, at DOE's Hanford site, the
disposal of more than 440 billion gallons of radioactive and
hazardous liquid waste in trenches, ponds, and underground cribs
(underground structures designed to allow liquid waste to percolate
to the soil) has resulted in soil and groundwater contamination.  At
DOE's Rocky Flats site, preliminary assessments have identified
nitrates, solvents, and radioactive elements in groundwater as
possibly requiring cleanup.  As of April 1994, DOE estimated that
cleaning up all its contaminated sites will cost about $300 billion. 

DOE's cleanup is governed by several statutes and interagency
agreements.  Under the Atomic Energy Act of 1954, as amended, EPA has
authority to set generally applicable standards for the protection of
the environment from radioactive materials, which could include
cleanup standards.  CERCLA, or Superfund as it is commonly known,
authorizes EPA to clean up hazardous waste sites and to compel the
parties responsible for the hazardous wastes to assist in or pay for
the cleanup.  In 1986, the Congress passed the Superfund Amendments
and Reauthorization Act, which emphasized cleanup remedies that
treat--rather than simply contain--contaminated waste to the maximum
extent practicable.  The 1986 amendments also required that remedial
actions attain federal or state environmental requirements that are
applicable or relevant and appropriate, and specifically applied the
act to the remediation of federal facilities.\2 Sixteen of the 19 DOE
sites on the National Priorities List have interagency agreements
between DOE and EPA and, in some cases, the state for meeting CERCLA
requirements.  (Three sites that were added to the National
Priorities List in May 1994 do not yet have interagency agreements
under CERCLA.) In 1990, the Congress reauthorized CERCLA and
authorized additional funds without making any substantive changes to
the program.  CERCLA is again scheduled for reauthorization in 1994. 

To determine how best to clean up a site, CERCLA requires DOE to
perform a remedial investigation, which characterizes contamination,
and a feasibility study, which develops and analyzes remedial
alternatives, both of which are subject to EPA's review.  Early in
this process, DOE and EPA identify potentially applicable or relevant
and appropriate requirements (ARARs), and the feasibility study
discusses whether remedial alternatives would achieve compliance with
ARARs.  DOE and EPA finalize ARARs when they select a remedy.  If the
agencies disagree, CERCLA authorizes EPA to make the final
determination regarding the selection of a remedy.  If the remedy
will result in contaminants' remaining at a site after remedial
action is completed, CERCLA requires that a review be conducted every
5 years after initiating action to ensure that the remedy still
protects human health and the environment.  The remedy, the reasons
for its selection, and the need for 5-year reviews (if required) are
documented in a record of decision.  (App.  I provides further
details about the CERCLA cleanup process.)


--------------------
\2 Applicable requirements are those cleanup standards and other
requirements that specifically address a hazardous substance at a
CERCLA site.  Relevant and appropriate requirements are standards
that, while not legally applicable at the CERCLA site, address
problems or situations that are sufficiently similar to those
encountered at the site that their use is well suited to the
particular site. 


   COMPREHENSIVE CLEANUP STANDARDS
   DO NOT EXIST BUT ARE NEEDED
------------------------------------------------------------ Letter :3

Comprehensive standards designed specifically for the cleanup of
radionuclides do not exist.  The only standards designed for the
cleanup of radionuclides are those for land and buildings
contaminated by uranium mill tailings at inactive uranium-processing
sites.  In the absence of applicable cleanup standards for
radionuclides, EPA and DOE identify other federal and state
environmental standards that are relevant and appropriate for DOE
cleanups.  This process for determining cleanup requirements can be
time-consuming and contentious and can result in varying levels of
cleanup and public protection.  Comprehensive cleanup standards are
needed to allow DOE to plan and estimate costs for its cleanup
program, particularly in light of upcoming decisions on cleanups. 


      CLEANUP LEVELS ARE DRAWN
      FROM OTHER REQUIREMENTS
---------------------------------------------------------- Letter :3.1

Currently, other environmental standards for radionuclides are used
for DOE's remedial actions, once the standards are identified through
the CERCLA process as relevant and appropriate requirements.  For
example, federal standards that might be used include drinking water
standards, Clean Air Act standards, and cleanup standards for soil
near inactive uranium-processing sites.  State standards may be used
if they are more stringent than federal ARARs.  For example, Colorado
has a standard, considered a potential ARAR by state and EPA regional
officials, of 0.05 picocuries\3 per liter for plutonium in surface
water that is adjacent to or immediately downstream of DOE's Rocky
Flats site. 

However, other existing environmental standards do not cover all
radionuclides and media.  For instance, apart from standards for
uranium mill tailings, no federal standards exist for cleaning up
radionuclides in soil.  In addition, while existing standards such as
those set under the Safe Drinking Water Act might be used as levels
for cleaning up groundwater, drinking water standards do not exist
for some radionuclides.  If no federal or state standards exist for a
given contaminant, CERCLA regulations state that residual
contamination should generally not result in a lifetime cancer risk
to an individual that exceeds a range of approximately 1 in 1 million
to 1 in 10,000.  EPA's guidance specifies methods for estimating
cancer risk from residual contamination. 


--------------------
\3 A picocurie is equivalent to one-trillionth of a curie.  A curie
is a measure of the rate of radioactive decay. 


      CURRENT PROCESS CAN BE
      PROBLEMATIC
---------------------------------------------------------- Letter :3.2

The process for identifying what requirements will be used can be
time-consuming and contentious.  Cleanup requirements are generally
established separately for each individual operable unit undergoing
cleanup at DOE's sites.\4 An environmental restoration official at
DOE's Chicago Field Office noted that even sitewide standards would
decrease the time and effort spent in negotiating with EPA and state
regulatory agencies; currently, negotiations about ARARs may
separately address each operable unit within a site.  According to
available data on operable units, nine of DOE's sites have a total of
245 operable units. 

Setting individual standards can take time.  For example, DOE and EPA
debated for 3 years over which standards should be used for one
operable unit at Fernald--material in the K-65 silos.  No existing
standards clearly applied to the management and disposal of the
concentrated uranium ore by-products in Fernald's K-65 silos.  EPA
Region V (Chicago) and DOE (Fernald) initially selected different
environmental requirements as relevant and appropriate.  EPA's and
DOE's staff time was used in researching and writing numerous letters
to each other on this issue.  In accordance with CERCLA, the
agreement between EPA and DOE governing Fernald's cleanup states that
EPA will make the final determination regarding what standards will
be used.  DOE listed the requirements that EPA chose in its September
1993 feasibility study for the K-65 silos. 

Furthermore, because the question "How clean is clean enough?" is
answered anew at each DOE operable unit slated for remediation,
cleanup levels and levels of protection for citizens may vary from
site to site.  In 25 situations where cleanup levels have been set
for radionuclides at 49 of DOE's sites, 6 situations (such as levels
for uranium in soil) had different standards for the various sites.\5
For example, at seven sites where natural uranium contaminated the
soil, five different cleanup levels--ranging from 35 to 150
picocuries per gram of soil--were established.  While information on
why various cleanup levels were used at different sites was not
complete, the information available to us indicated that varying
cleanup levels resulted from the use of different methodologies for
determining cleanup levels and from differences in where
contamination was located. 


--------------------
\4 Operable units are usually specific geographical portions of a
site. 

\5 Our analysis is based on DOE's data for 49 sites for which cleanup
levels have been set for radionuclides.  The 49 sites include uranium
mill tailings sites, sites formerly utilized by DOE, and several
separate restoration projects.  These sites involved 25 different
combinations of contaminants and media (a combination is uranium in
soil; another combination is tritium in groundwater; etc.).  Of these
25 situations requiring cleanup levels, 6 had different cleanup
levels, 8 had identical cleanup levels for more than one site, and 11
were found at only one location. 


      NEED EXISTS FOR CLEANUP
      STANDARDS IN NEAR FUTURE
---------------------------------------------------------- Letter :3.3

The need for comprehensive federal cleanup standards has been
identified by DOE, EPA, congressional oversight committees, and the
Office of Technology Assessment.  For instance, the Office of
Technology Assessment's 1991 report stated that without knowledge of
the cleanup levels to be achieved, DOE cannot develop reliable cost
estimates for the total cleanup.\6 DOE's Assistant Secretary for
Environmental Management has similarly testified that without cleanup
standards as goals, planning and cost estimating for cleanup programs
become virtually impossible.\7

The need for cleanup standards is becoming particularly urgent.  DOE
will shortly face a large "wave" of decision points for its remedial
actions, for which it will need information about cleanup levels. 
According to a DOE analysis, approximately 100 preliminary or final
restoration decision points will occur in 1996 and 1997; these
decision points include remedial investigation plans, remedial
investigations and risk assessments, feasibility studies and other
assessments of alternatives, and final remedial action decisions.\8
Figure 1 illustrates the timing and numbers of upcoming decision
points for remedial action. 

   Figure 1:  Preliminary and
   Final Remedial Action Decisions
   at DOE's Sites

   (See figure in printed
   edition.)

Source:  GAO figure based on DOE data. 

Two bills to amend CERCLA that are supported by the Clinton
administration (H.R.  3800 and S.  1834) originally proposed that EPA
establish national goals and national cleanup levels for remedial
action.  In testifying on the bills, EPA's Administrator noted that
inconsistent cleanup goals and remedies contribute to uncertainty,
protracted site-by-site evaluation, and higher cleanup costs.\9
National cleanup levels for contaminants commonly found at sites were
to be based on the goals in order to provide for consistent
protection to all communities.  As of June 1994, subsequent
amendments had deleted the requirement for national cleanup levels
and proposed that EPA promulgate a national risk protocol for
determining site-specific cleanup levels that would meet the national
goals, while reflecting factors that vary from site to site.  As of
June 1994, it was unclear how radiation cleanup standards (being
developed) would relate to national cleanup goals, according to
officials in EPA's offices of General Counsel and Radiation and
Indoor Air. 


--------------------
\6 Complex Cleanup:  The Environmental Legacy of Nuclear Weapons
Production, Office of Technology Assessment (Washington, D.C.:  U.S. 
Government Printing Office [GPO], Feb.  1991). 

\7 Statement of Thomas P.  Grumbly, Assistant Secretary for
Environmental Management, before the U.S.  Senate, Committee on
Governmental Affairs (Sept.  21, 1993).  (Mr.  Grumbly's title at
that time was Assistant Secretary for Environmental Restoration and
Waste Management.)

\8 Only the decision point occurring first was counted; subsequent
decision points for each operable unit or project were not included. 
The DOE analysis included all sites. 

\9 Statement of Carol M.  Browner, EPA Administrator, before the
House of Representatives, Committee on Energy and Commerce,
Subcommittee on Transportation and Hazardous Materials (Feb.  3,
1994). 


   SUCCESS OF RENEWED EFFORT TO
   DEVELOP CLEANUP STANDARDS IS
   UNCERTAIN
------------------------------------------------------------ Letter :4

Since December 1992, the Interagency Radiation Cleanup Information
and Technology Committee has been working to develop cleanup
standards for radionuclides, which EPA would issue as a regulation. 
The Committee is led by EPA, and includes DOE, NRC, and Department of
Defense officials.  Although the current effort to develop cleanup
standards has been assigned a greater priority than prior efforts and
has made some progress, the difficulty of the issues that must be
resolved makes success uncertain. 

Previous attempts to develop federal cleanup standards were
prolonged, intermittent, and unsuccessful.  A previous interagency
group consisting of officials from EPA, DOE, NRC, and other agencies
worked intermittently from 1984 to 1990 without successfully
developing cleanup standards for radionuclides.  By 1990, the working
group had completed draft guidance for radiation exposure to the
general public but had not developed cleanup standards for
radionuclides.  As we previously reported, the primary reason that
standards were not completed was that resources were lacking.\10
Additional reasons were the lack of a clear mandate and a low
priority. 

Recently, the development of federal cleanup standards has taken on a
new sense of urgency, as evidenced by additional resources and
congressional interest.  To assist EPA in developing standards, DOE
and EPA signed an interagency agreement in April 1993.  DOE agreed to
provide EPA with funding for seven full-time personnel and for other
functions, such as technical support for developing cleanup
standards.  The interagency agreement provided EPA with $1.5 million
and runs through January 31, 1995. 


--------------------
\10 Radioactive Waste:  EPA Standards Delayed by Low Priority and
Coordination Problems (GAO/RCED-93-126, June 3, 1993). 


      STATUS OF EFFORTS TO DEVELOP
      STANDARDS
---------------------------------------------------------- Letter :4.1

EPA estimates that it will publish a proposed rule to set standards
for cleaning up radiation sites in the spring of 1995.\11 EPA has not
established a specific time frame for issuing the final rule.  As of
June 1994, EPA and the interagency group had completed the following
steps toward that goal: 

  Identified and analyzed issues that need to be settled to develop
     cleanup standards for radionuclides, which resulted in an issue
     paper. 

  Published an advance notice of proposed rulemaking on October 21,
     1993, requesting public input. 

  Received advice and comments from a subcommittee of the National
     Advisory Council on Environmental Policy and Technology that was
     established to provide environmental policy information and
     advice to EPA on cleaning up radiation sites.  (The subcommittee
     consists of individuals from a wide variety of governmental
     agencies, industry, and public interest groups.)

  Developed a preliminary draft in May 1994 of a proposed rule for
     cleaning up sites contaminated with radiation. 

EPA has not yet published a proposed rule in the Federal Register but
staff have developed a preliminary working draft specifying a
radiation dose limit of 15 millirem\12 per year above natural
background radiation.  The 15-millirem dose limit corresponds to an
estimated cancer risk of less than 3 in 10,000 over 30 years of
exposure.  The dose limit could be achieved either by cleanup such
that doses resulting from unrestricted land use would be below the
limit or through a combination of cleanup and controls, such as land
use restrictions.  The preliminary draft also specified that remedial
actions should ensure that groundwater affected by a site does not
exceed limits for drinking water set under the Safe Drinking Water
Act.  The draft is expected to change before it is issued as a
proposed rule and is being used primarily to facilitate public
discussion and comment. 

EPA plans that guidance to accompany the final rule would cover how
to determine concentration levels for residual contamination in soil
that meet the radiation dose limit.  According to the Radiation
Studies Branch Chief, EPA plans that the guidance include soil
concentration levels for at least two land uses (residential and
industrial/commercial) as well as a model for determining
concentration levels on the basis of site-specific conditions. 

In addition to the interagency working group's efforts to develop
generally applicable cleanup standards for radionuclides, NRC and DOE
are each developing standards for certain aspects of their
operations.  These activities are described in appendix II. 


--------------------
\11 Later and under a separate effort, EPA plans to address the
development of waste management regulations and/or guidance for the
disposal of radioactive waste generated during the remediation of
sites.  EPA is also exploring the feasibility of recycle/reuse
regulations for buildings and equipment contaminated with low levels
of radioactivity. 

\12 A millirem is a thousandth of a rem.  A rem is a unit of
measurement for radiation dosage to humans. 


      DIFFICULT ISSUES REMAIN TO
      BE ADDRESSED
---------------------------------------------------------- Letter :4.2

Discussion of EPA's preliminary draft proposed rule by the
subcommittee of the National Advisory Council on Environmental Policy
and Technology (described above) indicates that controversial and
technically complex issues remain.  In its May 1994 meeting, the
subcommittee had questions and concerns about acceptable risk levels,
the practical and cost implications of the dose limits, the technical
capability to measure the radiation levels indicated by the dose
limits, local government involvement in land use decisions, the
enforceability and longevity of land use controls, and the
practicality of applying the rule to nonfederal sites. 

EPA has discussed its planned approach to the rule with the other
agencies in the interagency group.  However, the approach was still
under review by the interagency group as of June 1994, according to
the Chief of EPA's Radiation Studies Branch.  The approaches that
agencies have traditionally used have differed.  For instance, EPA,
DOE, and NRC have historically considered different risk levels to be
acceptable and have used different approaches for risk assessment. 
DOE had not yet provided comments to EPA on the preliminary draft
proposed rule as of June 1994. 


   STATUS OF DOE'S EFFORTS TO
   UTILIZE LAND USE PLANNING IN
   SETTING CLEANUP LEVELS
------------------------------------------------------------ Letter :5

As a result of a 1991 report to DOE by the Advisory Committee on
Nuclear Facility Safety, DOE has decided to utilize land use planning
as part of its cleanup effort.  Potential advantages of land use
planning include reducing cleanup costs, identifying community needs,
and helping cleanups to progress.  DOE has developed guidance for
identifying future land uses, completed a future land use report for
Hanford, and begun such efforts at several other sites. 


      LAND USE PLANNING IS
      POTENTIALLY ADVANTAGEOUS
---------------------------------------------------------- Letter :5.1

Land use planning could be a tool for identifying realistic cleanup
goals.  In its 1991 final report to the Secretary of Energy, the
Advisory Committee on Nuclear Facility Safety stated that it is
widely understood that taxpayers cannot afford to return all of DOE's
contaminated land to pristine conditions and recommended a land use
planning approach.  The Advisory Committee reported that under
current assumptions of unrestricted use, the most stringent
environmental requirements are imposed on every cleanup project. 
However, if a land use plan identified certain areas for restricted
uses, then different cleanup criteria could result in a less costly
cleanup that still protects the public, workers, and the environment,
according to the Advisory Committee report. 

DOE's Assistant Secretary for Environmental Management recently
testified that incorporating realistic land use assumptions in the
selection process for a remedy could result in substantial cost
savings.  He stated that changes to CERCLA (supported by the
administration)-- establishing national cleanup goals, cleanup levels
reflecting anticipated future land uses, generic remedies and
expedited remedy selection where feasible, and a national protocol
for risk assessments--could result in cost savings to DOE in the
range of $200 million to $600 million a year, with the largest
component of savings resulting from basing the selection of a remedy
on future land uses.\13

Comparative cost estimates, where available, illustrate that basing
cleanup levels on expected land use has the potential to save
money.\14 In December 1992, DOE estimated the costs of various
degrees of cleanup for four of Fernald's five operable units on the
basis of an initial screening of remedial alternatives.  DOE
estimated that it would cost $3.9 billion to clean up these four
units to a level that would allow people to reside and farm there,
which is a very stringent cleanup level because residential farming
results in many possible avenues of exposure to contaminants.  Three
other alternatives representing varying degrees of restrictions on
land use were estimated to cost from $500 million to $2.7 billion. 
The least costly alternative would involve capping and containing
certain wastes, which would require restrictions on the use of land
areas containing the wastes.  The more costly of these three
alternatives would involve more waste removal and treatment but would
still dispose of remaining waste on-site; the disposal area would be
set aside for restricted use.  The cost estimates are preliminary and
are not tied to particular land uses, as Fernald does not yet have a
land use plan. 

Other advantages of tying cleanup levels to expected land uses are
that remedial decisions could be based on better information about
community needs and that more feasible cleanup goals might help
cleanups to progress.  For example, the Hanford Future Site Uses
Study, which was based on extensive community involvement, identified
certain relatively uncontaminated areas as having high future use
value and recommended that they be cleaned up and released for other
uses sooner than DOE planned.  DOE and EPA agreed to the earlier
cleanup of these areas.  In addition, DOE's Assistant Secretary for
Environmental Management has advocated changing to more feasible
near-term goals to make what progress is possible in this
generation.\15 He stated that some remedial actions do not progress
beyond the study phase because no technology exists to meet standards
for unrestricted land use. 


--------------------
\13 Statement of Thomas P.  Grumbly, Assistant Secretary for
Environmental Management, before the U.S.  Senate, Committee on
Energy and Natural Resources (Mar.  24, 1994). 

\14 Such data are not available at many DOE sites because the sites
have not progressed far enough in the cleanup process to have
alternative remedies and cost estimates. 

\15 Statement of Thomas P.  Grumbly, Sept.  21, 1993. 


      DOE PLANS TO IMPLEMENT LAND
      USE PLANNING
---------------------------------------------------------- Letter :5.2

Citing the 1991 report by the Advisory Committee on Nuclear Facility
Safety, DOE's 5-year plan for environmental restoration and waste
management states that land use planning with participation from
affected parties will be used to reduce health risks, control costs,
and build consensus.\16 Because of the large number of upcoming
decision points, the Assistant Secretary for Environmental Management
set a goal of establishing future land use plans for DOE's sites by
the end of 1995.  (A list of sites that DOE has initially identified
as needing such plans is in app.  III.)

To support land use planning efforts, DOE developed guidance for its
field sites, which was issued in final draft form in January 1994. 
Regarding public involvement, the guidance specifies that
participants in land use planning can include regulatory agencies,
affected Indian tribes, state and local government officials,
representatives of those who may be affected economically (such as
business, labor, and agriculture representatives), environmental and
public interest groups, and concerned citizens.  Land use planning
groups are to evaluate information on sites to determine preferred
future land uses for major geographic areas of each site.  These
groups are to designate future land uses under the following
categories:  industrial and commercial (including waste management),
residential, agricultural, recreational, Native American, and open
space/wilderness. 

Prior to the guidance's issuance, land use planning had been
conducted at one of DOE's sites.  Specifically, at the Hanford site,
a future site-uses report was completed in December 1992 by a group
including representatives of local and state governments, Indian
tribes, environmental groups, labor unions, and other local
interests.  The report identified a number of potential uses for six
geographic areas of Hanford and defined levels of access related to
the land use.  The levels of access used were (1) unrestricted use
(areas clean enough for any human use), (2) restricted use (areas
with limited use, such as industrial use, due to remaining
contamination), and (3) exclusive use and buffer zones (areas that
DOE continues to use for waste and some surrounding land). 

The Hanford future site-uses report also made some general
recommendations regarding cleanup, some of which DOE and EPA are
starting to implement.  The recommendations included placing a high
priority on protecting the Columbia River, dealing realistically and
forcefully with groundwater contamination, giving priority to
cleaning up areas with a high use value, and consolidating wastes
from throughout the complex to one area in order to minimize the
amount of land devoted to waste or contaminated by waste.  According
to DOE's Hanford and EPA's Region X (Seattle) officials, these
recommendations were incorporated into the renegotiation of the
agreement between EPA, DOE, and the Washington State Department of
Ecology that governs Hanford's cleanup. 

Certain of DOE's other sites are in the beginning stages of
developing land use plans with involvement from citizens.  Both Rocky
Flats and Fernald have established site-specific citizens' groups to
study future site uses.  Several other sites, including Savannah
River (South Carolina), Idaho National Engineering Laboratory, Nevada
Test Site, and Pantex Plant (Texas), have begun the process of
planning their land use projects and setting up citizens' groups. 


--------------------
\16 Environmental Restoration and Waste Management Five-Year Plan: 
Fiscal Years 1994-1998, Vol.  I, DOE (Jan.  1993). 


   EFFECTIVE IMPLEMENTATION OF
   LAND USE PLANNING IS UNCERTAIN
------------------------------------------------------------ Letter :6

Efforts to consider future land uses in determining cleanup levels
and selecting remedial actions are just beginning, and their
effectiveness is uncertain.  EPA's practice has been to generally
assume residential land use, and the agency is seeking congressional
direction and clarification of its authority to consider other land
uses.  Effective implementation also depends on addressing (1)
potential difficulties in restricting land use and (2) concerns about
public involvement and writing off contaminated land too readily. 


      CURRENT CERCLA PRACTICE MAY
      MAKE IMPLEMENTING LAND USE
      PLANNING DIFFICULT
---------------------------------------------------------- Letter :6.1

While future land uses could potentially be considered in the CERCLA
process, EPA's current practice is to generally assume one land
use--residential.  Because residential use can result in greater
exposure to contamination, such use requires a stringent cleanup. 
Thus EPA considers cleanups for residential use to protect human
health.  Although EPA's policy allows assessing other land uses if
the probability of future residential use is small, this does not
occur often in practice, according to testimony by EPA's Deputy
Administrator: 

     In practice, future land use has often been assumed to be
     residential.  In some of these cases, the existing and prior use
     of the land was not residential.  Unrealistic assumptions about
     future land use could significantly increase the costs of
     cleanup without commensurate benefits.\17

In addition, while CERCLA does not specifically address considering
future land use, the law states that cleanup alternatives that
permanently treat contaminants are preferred.  Similarly, EPA's
regulations provide that EPA may use controls restricting land or
water use as a component of a remedy but also that these controls
shall not generally substitute for more active remedies. 

Proposed legislation to amend CERCLA (H.R.  3800 and S.  1834) would
specifically authorize consideration of land use.  According to a
staff attorney in EPA's Office of General Counsel, EPA is seeking
clearer congressional direction through the legislation about how, to
what extent, and in what circumstances to use its existing discretion
under CERCLA to consider land use.  Under the proposed legislation, a
working group from the affected community would recommend future land
uses for EPA consideration. 


--------------------
\17 Statement of Robert M.  Sussman, EPA Deputy Administrator, before
the House of Representatives, Committee on Energy and Commerce,
Subcommittee on Transportation and Hazardous Materials (June 23,
1993). 


      RESTRICTING LAND USE MAY
      PRESENT DIFFICULTIES
---------------------------------------------------------- Letter :6.2

Considerable uncertainty exists in forecasting future land uses.  For
instance, heavily industrialized areas may later be developed as
residential communities.  Concern exists that institutional controls,
such as restrictions on land or water use, may not be effective over
the long periods that some radioactive contamination persists.  DOE's
Assistant Secretary for Environmental Management testified that
linking the degree of remediation to land use would raise profound
implications regarding society's ability to control long-term land
use and obligation to make decisions respecting future
generations.\18 Other knowledgeable officials have also expressed
concern about land use restrictions.  At a DOE workshop on land use
planning guidance, an Air Force official involved in base closures
stated that deed restrictions, zoning, and building permits are not
controls designed to protect health and the environment over the
long-term and that exceptions are frequently made to zoning and
permits.  The Director of the Energy Research Foundation in South
Carolina told us that the public will not accept institutional
controls as part of remedial actions unless there is a system to
maintain and monitor the controls over time. 

If a remedy will result in contaminants' remaining at a site after
remedial action is completed, section 121(c) of CERCLA requires that
a review be conducted every 5 years after initiating action to ensure
that the remedy still protects human health and the environment. 
Section 121(c) also authorizes action under other CERCLA authorities
if judged appropriate on the basis of the review.  EPA's guidance for
5-year reviews states that reviews are to include a review of
documented operation and maintenance of the site, a visit to the
site, and a limited analysis of the site's conditions.  Also, new or
modified federal and state environmental laws are to be analyzed to
see if they are ARARs and if they call into question the
protectiveness of the remedy. 

In our recent review of EPA's systems for continuing oversight of
sites where cleanup has been completed, we found that institutional
controls, such as restrictions on land or water use, imply an
indefinite enforcement period.\19 Ensuring the continued efficacy of
institutional controls is difficult, according to EPA headquarters
and regional officials we contacted in the course of this review.  In
addition, containment remedies and barriers require maintenance to
ensure continued effectiveness.  For example, our report noted that a
draft 5-year review of one private site found that no one had
maintained the fence at the site or inspected and maintained the cap
over solidified contaminated material.  Trees had begun growing on
the cap, and their roots threatened the cap's integrity.  As a result
of the 5-year review, the parties responsible for the cleanup began
to maintain the fence and cap. 

While 5-year reviews could be a mechanism for ensuring the continued
effectiveness of land use restrictions, EPA's current guidance for
these reviews does not provide sufficient detail about reviewing and
maintaining land use restrictions.  Such guidance is important
because DOE will conduct reviews of its sites and other parties may
have a role in maintaining restrictions.  Specifically, EPA's current
guidance for 5-year reviews has four weaknesses. 

  The guidance does not clearly require a review of potential changes
     in land use.  According to EPA's guidance, the review may
     consider pending changes in zoning or land uses that would
     undermine institutional controls that were part of the remedy;
     if appropriate, EPA is to notify the local government that
     proposed changes might compromise the remedy.  However, the
     guidance does state that all remedies requiring access controls
     or land use restrictions will be reviewed, including
     confirmations that institutional controls are in place. 

  The guidance does not provide details on how to ensure that
     controls over land use are maintained by the various parties
     involved.  DOE's work to date in identifying potential future
     land uses indicates that some land may continue under DOE's
     control, some land may be used for wilderness or recreation
     areas, and some land may be released to private ownership. 
     Thus, use of DOE's remediated sites might be controlled by DOE,
     other federal agencies, or a state or local government.  The
     Director of DOE's Future Use Project Office told us that
     maintaining land use restrictions over long periods is a
     significant issue that should be discussed by DOE, EPA, and
     state and local governments. 

  The guidance does not mention reviewing technological advances that
     may make further cleanup at DOE's sites more feasible.  As some
     radioactive contamination persists for many generations,
     technological advances are likely to occur. 

  The guidance does not specify who is to conduct or approve such
     reviews for federal sites, like DOE's. 

EPA is currently drafting a supplement to its 5-year review guidance
clarifying that an executive order specifies federal agencies'
responsibilities for 5-year reviews of their sites.  For DOE, the
executive order and draft supplemental guidance state that the
Department is delegated authority for reviews of its sites, whether
or not a site is on the National Priorities List.  The draft
supplemental guidance also states that for sites on the National
Priorities List, federal agencies should submit to the EPA regional
office (1) drafts certifying the continued protectiveness of remedies
and (2) supporting information; this office's concurrence should be
obtained in accordance with existing interagency legal agreements. 
However, the draft supplemental guidance does not correct the other
problems noted above.  According to Hazardous Site Control Division
staff working on the supplemental guidance, EPA expects to issue the
guidance in the summer of 1994. 


--------------------
\18 Statement of Thomas P.  Grumbly, Sept.  21, 1993. 

\19 Superfund:  Cleanups Nearing Completion Indicate Future
Challenges (GAO/RCED-93-188, Sept.  1, 1993). 


      LAND USE PLANNING PRESENTS
      OTHER CONCERNS
---------------------------------------------------------- Letter :6.3

Viable public participation in land use planning was a concern of
several parties commenting on DOE's 5-year plan for environmental
restoration and waste management.  For instance, Oregon's Department
of Energy commented that in reaching a consensus decision on land
use, "It is vital that this consensus be based on ALL of the parties
involved, with extensive public involvement throughout the process."
At a DOE workshop on land use planning guidance, the Vice Chair of
the Sierra Club National Committee expressed concern that in the
process of implementing public participation, environmental and peace
organizations sometimes are left out, and the resulting decisions can
lack credibility. 

Finally, some organizations have expressed concern that land use
planning could be used as a means for DOE to write off land that
could be more fully restored.  The Subcommittee on Radiation Site
Cleanup Regulations of the National Advisory Council on Environmental
Policy and Technology advised EPA that it should ensure that future
use considerations do not become a "crutch for not cleaning up." In
comments on the 5-year plan, the Colorado Department of Health stated
that DOE should use care in linking cleanup levels to land use and
asked, "Is the rhetoric throughout the document an attempt to justify
avoiding cleanup to any level?"


   CONCLUSIONS
------------------------------------------------------------ Letter :7

DOE faces numerous major cleanup decisions in the near future. 
Comprehensive federal cleanup standards for radionuclides could help
provide for better-informed cleanup plans and cost estimates.  While
the current effort of the interagency group to develop cleanup
standards for radionuclides has greater priority and resources than
past efforts, the group's success is uncertain because of the
complexity and controversial nature of issues that it must resolve. 
If standards are developed after remedial actions for DOE's sites
have been selected and finalized, cleanup remedies might not meet the
standards or remedies might need to be redesigned, resulting in
delays and additional expense. 

The effectiveness of efforts to implement future land use planning is
uncertain in light of EPA's current practice of generally assuming
residential land use.  The agency supports amendments to CERCLA that
provide for greater consideration of future land use and would prefer
more specific congressional direction before changing its practices. 
If CERCLA and/or EPA's practices concerning land use are not changed,
some of the cost savings expected from land use planning may not be
realized. 

Potential difficulties in maintaining land use restrictions must be
addressed to help ensure continued protection of public health from
persistent radioactive contamination.  The 5-year reviews required by
CERCLA could help ensure the effectiveness of land use restrictions
for the foreseeable future.  However, current EPA guidance for 5-year
reviews does not sufficiently address the review and maintenance of
land use restrictions.  If DOE is to conduct 5-year reviews of its
sites, more specific guidance, which clearly requires the review of
potential changes in land use and discusses the roles of the various
governmental agencies potentially involved in maintaining
restrictions, is necessary.  In addition, EPA's 5-year review
guidance does not address considering technological advances that are
likely to occur over the many years that contamination can persist at
DOE's sites. 

Meaningful public participation can reduce concerns about including
all relevant parties and help ensure that land is not too readily
written off as being infeasible to clean up.  We encourage DOE to
continue in its current path of early and extensive public
participation in land use planning through site-specific citizens'
groups, so that any decisions to clean up land to a level less than
that needed for unrestricted land use have public support. 


   MATTER FOR CONGRESSIONAL
   CONSIDERATION
------------------------------------------------------------ Letter :8

If the Congress agrees with DOE's and EPA's plans to utilize land use
planning, the Congress could consider amending CERCLA to provide more
specific direction about incorporating future land uses when
determining cleanup levels and selecting remedial actions. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :9

To provide standards before many decisions about DOE's cleanups are
made, we recommend that the Administrator, EPA, with other members of
the interagency group, complete the work of the Interagency Radiation
Cleanup Information and Technology Committee by the end of 1995. 

To help overcome potential disadvantages of a land use planning
approach, we recommend that the Administrator, EPA, provide more
detailed guidance for 5-year reviews of sites not returned to
unrestricted use and communicate this guidance to DOE.  The guidance
should (1) specify that such reviews address whether land use
patterns are changing or likely to change in the near future and (2)
discuss responsibilities for maintaining land use restrictions.  If
such guidance would involve responsibilities of state and local
governments, EPA should consult with them in developing the guidance. 
We further recommend that the Administrator, EPA, specify in records
of decision for DOE's sites with residual contamination that 5-year
reviews be supplemented by the consideration of advances in
technology that may make more extensive cleanup feasible. 


   AGENCY COMMENTS
----------------------------------------------------------- Letter :10

We discussed the facts presented in the report with DOE and EPA
headquarters officials in relevant offices.  These included the
Directors of the Regulatory Integration Division and the Future Use
Project Office in DOE's Office of Environmental Management, and the
Director of the Air, Water, and Radiation Division in DOE's Office of
Environment, Safety, and Health.  At EPA, officials with whom we
discussed the report's facts included the Chief of the Radiation
Studies Branch in the Office of Radiation and Indoor Air, the Chief
of the Remedial and Operations Guidance Branch in the Office of Solid
Waste and Emergency Response, a chemical engineer from the Office of
Federal Facilities Enforcement, and attorneys from the Office of
General Counsel.  Except as noted below, they generally agreed with
the factual material in this report and offered several updates and
technical clarifications that have been incorporated where
appropriate.  Officials in EPA's Office of Solid Waste and Emergency
Response, while agreeing that more information about maintaining land
use restrictions was needed, disagreed with our assessment that EPA's
current guidance for 5-year reviews was not adequate and that 5-year
review guidance was an appropriate vehicle to address the maintaining
of restrictions.  Because DOE rather than EPA will be responsible for
5-year reviews of DOE's sites and will rely on EPA's guidance in
conducting reviews, we believe that EPA's guidance should be revised
to include the items that we noted were lacking.  Furthermore, as
5-year reviews might identify a need for actions to reinforce land
use restrictions, we believe that guidance for the reviews is a
logical vehicle to discuss the maintaining of restrictions.  As
requested, we did not obtain written agency comments on a draft of
this report. 


--------------------------------------------------------- Letter :10.1

We performed our review between January 1993 and June 1994 in
accordance with generally accepted government auditing standards. 
Appendix IV describes our objectives, scope, and methodology in
detail. 

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies to the Secretary of Energy; Administrator, EPA; and
Director, Office of Management and Budget.  We will make copies
available to others on request. 

Please call me at (202) 512-3841 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
V. 

Sincerely yours,

Victor S.  Rezendes
Director, Energy and Science Issues


THE CERCLA CLEANUP PROCESS
=========================================================== Appendix I



   (See figure in printed
   edition.)

Legend

ARARs = applicable or relevant and appropriate requirements.
CERCLA = Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended. 


NRC'S AND DOE'S STANDARD-SETTING
ACTIONS
========================================================== Appendix II

The Nuclear Regulatory Commission (NRC) is pursuing enhanced
participatory rulemaking (a means of obtaining extensive public
involvement) for standards on decommissioning for its licensees.  NRC
expects to publish a proposed rule in July 1994 and a final rule in
May 1995.  According to the Director of the Environmental Protection
Agency's (EPA) Office of Radiation and Indoor Air, EPA will closely
coordinate with NRC in developing cleanup standards.  Under a 1992
memorandum of understanding between the two agencies, should EPA
conclude that NRC's standards for its licensees provide a sufficient
level of protection, then EPA will publish this conclusion in the
Federal Register for notice and comment and propose that NRC's
licensees be exempted from EPA's cleanup standards. 

In order to enhance the enforcement of the Price-Anderson Amendments
Act of 1988,\1 the Department of Energy (DOE) is proceeding to codify
its order on radiation protection for the public and the environment
into a regulation that provides enforcement provisions.  DOE issued
its proposed rule in March 1993 and expects to publish the final rule
in mid-1994.  DOE proposed limiting the acceptable combined radiation
dose to the public from most sources, including DOE's production and
cleanup activities and radiation remaining after cleanup, to 100
millirem per year or to levels that are as low as reasonably
achievable below the 100- millirem maximum.  However, EPA wrote
comments to DOE objecting to including cleanup in the rule in light
of EPA's effort to develop cleanup standards.  According to officials
in DOE's Office of Environment, Safety, and Health, DOE will revise
its rule to conform to EPA's standards should DOE's standards be
inconsistent with or different from cleanup standards subsequently
developed by EPA. 


--------------------
\1 To ensure that DOE's contractors, in performing nuclear
activities, protect human health and safety and the environment, this
act authorized DOE to develop and issue nuclear safety regulations
and required the imposition of penalties for violations of these
regulations. 


DOE'S SITES REQUIRED TO IDENTIFY
FUTURE USE OPTIONS
========================================================= Appendix III

Operations office/
location            Site location\a
------------------  ----------------------------------------
Albuquerque/        Kansas City Plant, Mo.
Kansas
City, Mo.

Albuquerque/Los     Los Alamos National Laboratory, N. Mex.
Alamos, N. Mex.

Albuquerque/        Mound Plant, Ohio
Dayton,
Ohio

Albuquerque/        Pantex Plant, Tex.
Amarillo,
Tex.

Albuquerque/        Pinellas Plant, Fla.
Pinellas,
Fla.

Albuquerque/        Sandia National Laboratory-Livermore,
Kirtland,           Calif.
N. Mex.

Albuquerque/        Sandia National Laboratory-
Kirtland,           Albuquerque,
N. Mex.             N. Mex.

Albuquerque/        Inhalation Toxicology Research
Kirtland,           Institute,
N. Mex.             N. Mex.

Chicago/Argonne,    Argonne National Laboratory (East), Ill.
Ill.

Chicago/            Brookhaven National Laboratory, N.Y.
Brookhaven,
N.Y.

Chicago, Ill.       Fermi National Accelerator
                    Laboratory, Ill.

Idaho               Idaho National Engineering Laboratory

Nevada              Nevada Test Site

Oak Ridge/          Fernald Environmental Management
Fernald, Ohio       Project, Ohio

Oak Ridge, Tenn.    Oak Ridge Reservation (K-25, X-10, Y-
                    12), Tenn.

Oak Ridge/          Paducah Gaseous Diffusion Plant, Ky.
Paducah, Ky.

Oak Ridge/          Portsmouth Gaseous Diffusion Plant, Ohio
Portsmouth,
Ohio

Richland, Wash.     Hanford Reservation, Wash.\b

Denver, Colo.       Rocky Flats Plant, Colo.

San Francisco,      Lawrence Livermore National Laboratory,
Calif.              Calif.

Savannah River,     Savannah River Site, S.C.
S.C.
------------------------------------------------------------
\a Other sites may be added as needed on a case-by-case basis. 

\b Future use options have already been identified for Hanford. 


OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================== Appendix IV

The Chairman, Senate Committee on Governmental Affairs, asked us to
examine DOE's and EPA's efforts to develop cleanup standards for
radionuclides and relate expected land uses to cleanup levels. 
Specifically, we were asked to review (1) how cleanup levels are
currently determined for DOE's sites, (2) the status and likelihood
of success of EPA's efforts to develop cleanup standards for
radionuclides, (3) the status of land use planning efforts at DOE,
and (4) what hurdles would need to be overcome if land use planning
were to be effectively implemented in determining cleanup levels. 

To determine how cleanup levels are currently established for DOE's
sites, we obtained guidance on determining cleanup levels under the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) and documentation of preliminary cleanup levels at several
of DOE's sites.  Our work concentrated primarily on how cleanup
levels are established under CERCLA.  To determine the status and
prospects of efforts to develop cleanup standards for radionuclides,
we interviewed EPA and DOE staff participating in the interagency
work group for radionuclide standards and obtained documentation of
the work group's efforts. 

To determine the status of land use planning efforts at DOE, we
interviewed DOE officials working to develop guidance for land use
planning and obtained guidance drafts and records of the status of
land use efforts at DOE's sites.  We obtained information about the
Hanford (Washington) future site uses study from DOE's Hanford
officials, Westinghouse Hanford Corporation (a contractor to DOE),
the Washington Department of Ecology, EPA Region X (Seattle), and
several interest groups involved in the study. 

To determine possible barriers to effectively implementing land use
planning, we analyzed provisions of CERCLA and CERCLA regulations,
reviewed CERCLA guidance documents, and interviewed attorneys with
EPA's Office of General Counsel.  In order to determine the
advantages and disadvantages of a land use planning approach, we
reviewed prior studies, attended a DOE-sponsored workshop on land use
planning, and interviewed headquarters and field officials of DOE and
EPA, representatives of several interest groups, and environmental
officials for Ohio and Washington State. 

This review included standards for radionuclides but not for
hazardous chemicals in its scope.  Our review concentrated primarily
on activities regarding CERCLA.  The scope was limited to cleanup
standards for environmental media (soil, surface water, and
groundwater).  DOE's data on established cleanup levels were not
verified.  DOE's data on costs associated with various cleanup levels
were limited and preliminary; we did not independently verify the
cost data.  More detailed information was obtained about the Hanford
and Fernald (Ohio) sites.  Hanford was selected for study because it
was the one DOE location that had completed a future land use study,
while Fernald was studied because the process of identifying cleanup
levels had proceeded further there than at many of DOE's sites. 

Our review was conducted from January 1993 through June 1994 at DOE
and EPA headquarters, Hanford, and Fernald.  We collected data by
phone from several other DOE field locations and from several states
and EPA regions. 


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Jim Wells, Associate Director
James Noï¿½l, Assistant Director
Rachel J.  Hesselink, Evaluator-in-Charge
William M.  Seay, Staff Evaluator

OFFICE OF THE GENERAL COUNSEL

Doreen Stolzenberg Feldman, Assistant General Counsel
Susan W.  Irwin, Staff Attorney
