Nuclear Waste: Greater Use of Removal Actions Could Cut Time and Cost for
Cleanups (Letter Report, 05/23/96, GAO/RCED-96-124).

Pursuant to a congressional request, GAO reviewed the Department of
Energy's (DOE) use of removal actions to reduce the cost and accelerate
the pace of environmental restoration projects.

GAO found that: (1) removal actions save money and time compared with
other remediation planning approaches; (2) the use of removal actions
may provide information that is useful for other types of remediation,
reduce the cumulative risk to human health and the environment, and
reduce the size of sites under DOE control; (3) the use of removal
actions at DOE facilities varies; (4) the use of removal actions is
limited because removal actions are not part of interagency agreements
with regulators or DOE contractors; (5) some officials believe that
removal actions are intended for emergency situations or for planning
small remediation projects; (6) officials at some sites are
concentrating on streamlining Comprehensive Environmental Response,
Compensation, and Liabilities Act (CERCLA) and interim remedial planning
approaches, but planning and evaluation will still take significantly
longer under simpler CERCLA processes; and (7) limited planning may
increase the risk that an incorrect remedy will be chosen.

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

 REPORTNUM:  RCED-96-124
     TITLE:  Nuclear Waste: Greater Use of Removal Actions Could Cut 
             Time and Cost for Cleanups
      DATE:  05/23/96
   SUBJECT:  Nuclear waste management
             Radioactive wastes
             Nuclear facilities
             Nuclear waste disposal
             Cost control
             Nuclear weapons plants
             Tanks (containers)
             Strategic planning
             Interagency relations
             Environmental policies

             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Military Procurement,
Committee on National Security, House of Representatives

May 1996

NUCLEAR WASTE - GREATER USE OF
REMOVAL ACTIONS COULD CUT TIME AND
COST FOR CLEANUPS

GAO/RCED-96-124

DOE's Use of Removal Actions

(302157)


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

  DOE -
  INEL -
  CERCLA -
  RCRA -
  EPA -

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


B-271641

May 23, 1996

The Honorable Duncan Hunter
Chairman, Subcommittee on
 Military Procurement
Committee on National Security
House of Representatives

Dear Mr.  Chairman: 

Since 1989, the Department of Energy (DOE) has received about $10
billion for environmental restoration projects at its 130 facilities
across the country.  These projects are aimed at cleaning up more
than 10,500 individual waste sites, which contain hazards ranging
from highly radioactive wastes to more common industrial chemicals
and solvents in soil, groundwater, and burial pits.  To date, much of
the $10 billion has gone to study waste sites and develop an approach
to their remediation, as required by environmental laws, rather than
to actually clean them up.  Recently, DOE has been criticized for its
lack of progress in remediation at the same time as its
appropriations for environmental restoration have declined. 

In some cases, DOE has successfully placed more emphasis on
remediation and less on planning by using "removal actions," which
shorten or eliminate some of the planning steps normally required
before remediation can begin.  Removal actions have been used for,
among other things, treating groundwater and surface water,
excavating and disposing of contaminated soil, or leaving waste in
place and covering it with a protective barrier.  Removal actions
have been used at federal facilities to respond to emergencies or
other urgent circumstances--to remove leaking barrels that threatened
to contaminate the Columbia River, for example--but they can also be
used in nonemergency situations.  As agreed with your office, we
examined DOE's use of removal actions to reduce the cost and
accelerate the pace of environmental restoration.  Specifically, we
examined whether removal actions have been successful as an
alternative to other environmental restoration processes in reducing
time, reducing costs, or providing other benefits.  We also examined
the extent to which DOE is using removal actions at its facilities
and the factors that limit the greater use of this approach. 

We focused our review on five DOE facilities--Hanford in Washington
State, Savannah River in South Carolina, Oak Ridge in Tennessee,
Rocky Flats in Colorado, and the Idaho National Engineering
Laboratory (INEL) in Idaho.  In March 1995, DOE projected\1 that
environmental restoration at its facilities would cost about $65
billion--including $61 billion at the five sites we reviewed.\2


--------------------
\1 Estimating the Cold War Mortgage:  The 1995 Baseline Environmental
Management Report, Office of Environmental Management (Mar.  1995). 

\2 The cost of environmental restoration includes the cost of
remediating waste sites and decommissioning and decontaminating DOE's
facilities, but it does not include DOE's waste management, nuclear
material and facility stabilization, or other related programs.  When
these programs are included, the total cost of the environmental
management program is estimated at $230 billion. 


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

Where removal actions have been used, they have reduced the overall
time and cost of planning for the remediation of DOE's waste sites. 
At the three DOE facilities we reviewed where comparative time and
cost data were readily available, removal actions took from about 70
to 90 percent less time, on average, than other planning approaches. 
Because removal actions substantially reduce the requirements that
must be met before remediation can begin, they are also less
expensive.  At the three facilities, the cost to prepare for
remediation through the removal action approach was from over 80 to
90 percent less than through other approaches.  Removal actions may
also provide other benefits, such as reducing continued risks to the
environment by moving projects more quickly to actual cleanup,
thereby reducing the opportunity for hazardous materials to spread
further into the environment. 

DOE's use of removal actions varies by facility.  Two of the five DOE
facilities we examined--Rocky Flats and INEL--have vigorously pursued
removal actions.  Oak Ridge plans to increase its use of removal
actions, but Hanford and Savannah River plan a more limited role for
the process even though many of their untreated sites are similar to
sites where removal actions have been used successfully.  Although
DOE's policy guidance encourages the greater use of removal actions,
DOE officials gave several reasons for not using removal actions more
often.  They noted that the interagency agreements and contracts
governing DOE's environmental restoration do not encourage the use of
removal actions, and they expressed a preference for using removal
actions only in urgent situations.  While not all waste sites may
best be addressed through removal actions, there are still
opportunities to accelerate DOE's environmental restoration through
wider use of this approach. 


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

DOE is the steward of a nationwide complex of facilities created
during World War II to research, produce, and test nuclear weapons. 
Now that the United States is reducing its nuclear arsenal, DOE has
shifted its focus towards cleaning up the enormous quantities of
radioactive and hazardous waste resulting from weapons production. 
This waste totals almost 30 million cubic meters--enough to cover a
football field 4 miles deep.  DOE expects that environmental
restoration will continue until 2070 before all of its problems have
been addressed. 

Remediation activities at DOE's facilities are governed by the
Comprehensive Environmental Response, Compensation, and Liabilities
Act (CERCLA) of 1980, as amended, and the Resource Conservation and
Recovery Act (RCRA) of 1976, as amended.\3 These laws lay out
requirements for identifying waste sites, studying the extent of
their contamination and identifying possible remedies, and involving
the public in making decisions about the sites.  At each facility we
visited, DOE has signed an interagency agreement with the
Environmental Protection Agency (EPA) and state regulators laying out
the facility's schedule for meeting the requirements of CERCLA and
other environmental laws. 

CERCLA offers three methods for determining how a waste site will be
remediated:  the full CERCLA process, interim remedial measures, and
removal actions.  For each of these methods, table 1 shows the key
documents and related activities required before remediation can
begin.  Generally, DOE's guidance recommends that EPA and state
regulators be involved at each of these steps.  In addition, other
documents not requiring regulatory approval frequently may supplement
the documents shown.  For example, for the full CERCLA process, DOE
often issues reports for each phase of the remedial investigation for
a group of waste sites, and before embarking on a remedial design,
DOE generally prepares a remedial design work plan. 



                                Table 1
                
                Comparison of Required Steps Leading to
                  Cleanups Under Three CERCLA Planning
                               Processes

Key steps                           Purpose
----------------------------------  ----------------------------------
Full CERCLA process
----------------------------------------------------------------------
Work plan                           Provides background information, a
                                    sampling and analysis plan, and a
                                    road map for preparing the rest of
                                    the documents

Remedial investigation              Thoroughly characterizes the waste

Feasibility study                   Examines different options for
                                    remediation

Proposed plan                       Tentatively selects a remedy and
                                    puts it forward for public comment

Record of decision                  Documents the selected remedy and
                                    authorizes the cleanup

Remedial design study               Engineers cleanup procedures


Interim remedial measure
----------------------------------------------------------------------
Limited field investigation         Characterizes the waste

Focused feasibility study           Examines different options for
                                    remediation

Proposed plan                       Tentatively selects a remedy and
                                    puts it forward for public comment

Interim record of decision          Documents the selected remedy and
                                    authorizes the cleanup

Remedial design study               Engineers cleanup procedures


Removal action
----------------------------------------------------------------------
Engineering evaluation/cost         Characterizes the waste, examines
assessment                          different options for remediation,
                                    tentatively selects a remedy, and
                                    obtains public comment

Action memorandum                   Documents the selected remedy and
                                    authorizes the cleanup
----------------------------------------------------------------------
Removal actions are the most abbreviated of the three planning
processes.  A removal action can be used to plan for remediating a
waste site to the point that no further action is needed, or it can
serve as a stopgap measure for a waste site that presents an urgent
threat to the public or the environment.  At some point after the
remediation is concluded, a removal action, like an interim remedial
measure, requires a record of decision to certify that the site is
clean and no further action is required.  Because removal actions
generally require much less characterization and planning than other
approaches except in emergency situations, they are most effective at
sites where the contaminants and the probable remedy are relatively
well known.  Although removal actions in the private sector are
limited to projects costing $2 million or less and taking 12 months
or less, these limits do not apply at federal facilities. 


--------------------
\3 Some DOE installations use RCRA in addition to CERCLA to clean up
waste sites.  While RCRA differs from CERCLA in that it also
regulates active waste facilities, the two laws generally address
inactive waste sites similarly.  For simplicity, we use CERCLA's
terminology in this report. 


   REMOVAL ACTION PLANNING TAKES
   LESS TIME, COSTS LESS, AND CAN
   PROVIDE OTHER BENEFITS
------------------------------------------------------------ Letter :3

Available data indicate that removal actions save time and money
compared with other planning approaches.  Furthermore, removal
actions have been used across a wide variety of environmental
restoration projects, including the same kinds of projects that have
been planned using the other approaches.  Removal actions may also
provide other benefits, such as reducing continued risks to the
environment by moving projects more quickly to actual cleanups. 


      REMOVAL ACTION PLANNING HAS
      GENERALLY PROVED TO BE
      FASTER AND LESS COSTLY
---------------------------------------------------------- Letter :3.1

Through January 1996, the five facilities we reviewed had a total of
39 removal actions either completed or under way.  Three facilities
(INEL, Hanford, and Rocky Flats) provided data allowing some
comparisons of the relative time and cost involved in removal actions
and other types of planning efforts.  As figure 1 shows, at all three
facilities the average time needed for planning was considerably
shorter under removal actions than under the other approaches.  At
INEL, for example, planning for cleanups under removal actions
averaged 4.4 months, compared with 15.2 months under interim remedial
measures and 25.6 months under the full CERCLA process. 

   Figure 1:  Comparison of Time
   for Cleanup Planning Processes

   (See figure in printed
   edition.)

Note:  Rocky Flats' interim actions followed a different process.  We
did not include them in our analysis. 

Cost comparisons show the same pattern.  As figure 2 shows, at INEL
and Rocky Flats, under removal actions, the cost for characterization
and studies before cleanup averaged $140,000, compared with almost $2
million under either interim remedial measures or the full CERCLA
process. 

More limited data for Hanford support the same conclusion.  The last
five removal actions\4 cost an average of about $790,000 for cleanup
planning.  These sites are now clean, or remediation is under way. 
In contrast, for the 18 areas along the Columbia River where Hanford
plans to use interim remedial measures to manage the cleanup, the
cost of preparation averaged $4.4 million per area between October
1991 and September 1995.  Remediation has not begun at any of these
areas. 

   Figure 2:  Comparison of Cost
   for Cleanup Planning Processes

   (See figure in printed
   edition.)

Notes:  Rocky Flats' interim actions followed a different process. 
We did not include them in our analysis. 

Hanford's data are based on the last five removal actions initiated. 

Hanford's costs for the full CERCLA process could not be determined. 

When examined on a project-by-project basis, planning for removal
actions also appears to be cheaper and faster than planning at
comparable sites for the other environmental restoration processes. 
Many of DOE's waste sites fit into one of three categories:  burial
grounds, contaminated soil, or contaminated water. 

Burial grounds may contain radioactive and/or hazardous solid and/or
liquid waste.  Buried in them are such things as barrels of chemicals
and other material and equipment from DOE facilities.  (See fig.  3.)

   Figure 3:  Excavation at a
   Hanford Burial Ground

   (See figure in printed
   edition.)

   Source:  DOE.

   (See figure in printed
   edition.)

Soil may have been contaminated by leaks or spills or by using liquid
waste disposal facilities, such as trenches and waste ponds, to
disperse contaminated liquids.  (See fig.  4.)

   Figure 4:  Cleanup of a Hanford
   Liquid Waste Disposal Facility

   (See figure in printed
   edition.)

   Source:  DOE.

   (See figure in printed
   edition.)

Surface water or groundwater may have been contaminated by
radioactive or hazardous materials leaching through the soil from
spills and leaks or through normal operations.  (See fig.  5.)

   Figure 5:  Treatment Facility
   for Removal of Strontium From
   Groundwater Near the Columbia
   River at Hanford

   (See figure in printed
   edition.)

   Source:  DOE.

   (See figure in printed
   edition.)

At Hanford and INEL, where more complete comparative information was
available, we analyzed the removal actions that fell into these
categories.  We found four instances in which removal actions had
been used at sites where conditions were reasonably comparable to
those at sites that had been addressed under interim remedial
measures (see table 2).  In each case, planning for the remediation
was accomplished much more quickly and at substantially less cost
using a removal action.  While the projects being compared are not
identical, their similarities provide a reasonable basis for
comparing the relative time and cost required to complete the
planning that precedes remediation. 



                                        Table 2
                        
                        Comparison of Removal Actions With Other
                                       Processes

              Common features of
              waste                     Outcome under           Outcome under other
Location      sites being compared      removal action          process
------------  ------------------------  ----------------------  ----------------------
Hanford       Remediation of disposal   Planning cost an        Planning will cost an
              facilities contaminated   average of $146,000     average of about
              by such liquid wastes as  per site and took 2     $773,000 per site and
              low-level radioactive     months. Cleanup has     take 5 years. Cleanup
              wastes and hazardous      been completed.         will begin in July
              chemicals. Cleanup                                1996.
              methods selected were
              similar and involved
              excavating and removing
              the soil.

Hanford       Projects are removing     Planning cost $1.6      Planning cost $6.2
              contaminants from         million and took 2      million and has
              groundwater near the      years. System is        already taken 5 years.
              Columbia River using      currently operating.    Only a test system is
              pump-and-treat                                    operating. The final
              technology. In the                                system is not expected
              removal action, the                               until April 1997.
              contaminant is
              strontium-90; in the
              interim remedial
              measure, it is chromium.

INEL          Projects located and      Planning cost $500,000  Planning cost $1
              removed old ammunition    for a $2.4 million      million for a $2
              and excavated soil        project and took 4      million project and
              contaminated with         months.                 took 1 year.
              explosive chemicals.
              Standards developed
              under the interim
              remedial measure were
              used to expedite the
              planning of the removal
              action.

Hanford       Projects use pump-and-    Planning for the        As of October 1995,
              treat technology to       removal of vapor from   groundwater removal
              clean up carbon           soil cost $3.2 million  preparations have
              tetrachloride disposed    and took 13 months.     already cost $7.8
              of in the soil near an                            million. Full
              old processing facility.                          operation will not
                                                                begin until June 1996,
                                                                41 months after
                                                                planning began.
--------------------------------------------------------------------------------------

--------------------
\4 Because of a change in contractors, data from earlier removal
actions were too limited to separately identify project preparation
costs. 


      REMOVAL ACTIONS CAN PROVIDE
      VALUABLE INFORMATION, REDUCE
      RISKS, AND DEMONSTRATE
      RESULTS
---------------------------------------------------------- Letter :3.2

The relative speed of removal actions can provide other advantages to
DOE.  Because removal actions progress to actual cleanup more quickly
than other CERCLA processes, removal actions can provide information
about waste sites that is useful in focusing other types of
remediation.  For example, one removal action at Hanford involved
cleaning up a liquid disposal area near one of the shutdown reactors. 
The project manager for the removal action said important information
obtained during the removal action on the extent and spread of
contamination through the soil will be used to plan and conduct
cleanups near other shutdown reactors, saving both time and money. 

Removal actions may also reduce the cumulative risk to human health
and the environment.  For example, Hanford's removal action in a
trench near the Columbia River reduced the concentration of uranium
in the groundwater from up to 28 times the drinking water standard to
below the drinking water standard.  Without the removal action,
uranium would have continued to leach into the groundwater for at
least 3 years before a planned water treatment facility was
completed.  At Oak Ridge, the EPA region 4 administrator praised a
recent removal action that successfully reduced radioactive strontium
releases by about 40 percent.  He noted that the projects were
completed in less time, at less cost, and with equal or greater
effectiveness than the "typical" decision-making process would have
allowed.  He also attributed the results to teamwork and cooperation
between DOE and the regulators. 

Finally, removal actions may allow DOE to "pull in its fences" by
cleaning up isolated waste sites on the outskirts of a facility and
thereby reduce the number of acres requiring DOE's control.  For
example, two removal actions addressing waste sites on remote
portions of the Hanford reservation allowed DOE to complete the
remediation of 27 percent, or 153 square miles, of Hanford's total
land area.  In February 1996, a record of decision was issued
requiring no further cleanup for these areas. 


   SEVERAL FACTORS LIMIT DOE'S USE
   OF REMOVAL ACTIONS
------------------------------------------------------------ Letter :4

Although DOE's guidance calls for using removal actions where
appropriate, the use of these actions varies widely by facility--from
greater use at two locations, to increasing use at one location, to
very limited use at the remaining two locations.  While many
contaminated waste sites are similar in type to those already
remediated through removal actions, DOE officials have given several
reasons for not using removal actions more often.  They have noted,
for example, that the interagency agreements and contracts governing
DOE's environmental restoration do not encourage the use of removal
actions, and they expressed a preference for using removal actions
only in urgent situations.  Not all waste sites may best be addressed
through removal actions; however, there are still additional
opportunities to accelerate the progress of DOE's environmental
restoration through wider use of this approach. 


      FACILITIES' EFFORTS TO
      IDENTIFY POTENTIAL REMOVAL
      ACTIONS VARY
---------------------------------------------------------- Letter :4.1

In August 1994, DOE and EPA adopted a policy encouraging the use of
streamlined approaches to remediate waste sites.  The policy
encourages DOE managers to use removal actions, among other tools,
when doing so "will achieve results comparable to a remedial action,
but which may be completed in less time." The policy recommends that
managers give strong consideration to using removal actions in
nonemergency situations.  DOE issued further guidance to its
facilities in November 1995, reiterating that removal actions and
other accelerated approaches should be based on consensus between DOE
and its regulators.\5

At the five facilities we reviewed, the response to DOE's policy has
varied.  Three facilities are adjusting their environmental
restoration strategies to make greater use of removal actions, while
the other two continue to plan only a limited role for the approach. 


--------------------
\5 In May 1995, DOE adopted a policy that also encouraged the use of
removal actions rather than other statutory approaches in
decommissioning and decontaminating facilities.  Because our
objective was to examine the relative efficiency of CERCLA's cleanup
processes, we did not address decontamination and decommissioning in
this report. 


         ROCKY FLATS AND INEL HAVE
         LOOKED FOR OPPORTUNITIES
         TO USE REMOVAL ACTIONS
-------------------------------------------------------- Letter :4.1.1

Both Rocky Flats and INEL are planning to use removal actions to
address significant portions of their waste sites.  A Rocky Flats
manager responsible for cleanup estimates that 27 waste sites will
require remediation, and she plans to use removal actions for about
half of them.  She said using removal actions will be important to
accomplishing remediation milestones because DOE officials at Rocky
Flats proposed a new interagency agreement requiring several waste
sites to be remediated each year.  These specific remediation goals
were also reflected in DOE's contract with the contractor responsible
for the remediation at Rocky Flats.  For example, in fiscal year 1996
the contractor is required to clean up three high-priority waste
sites at the plant.  The contractor's manager responsible for
environmental restoration said that without using removal actions,
these goals would be difficult or impossible to achieve.  The state
regulator for Rocky Flats added that removal actions will permit DOE
to do more with fewer resources.  DOE and regulatory officials said
that the old interagency agreement focused almost exclusively on
completing milestones required under the full CERCLA planning
process.  As a result, they said, the old agreement made it difficult
to use removal actions. 

At INEL, DOE officials have the flexibility under their agreement to
use removal actions where appropriate.  Since 1993, INEL has
reallocated funds and has conducted nine removal actions, including
remediating contaminated soil at several sites.  INEL has three other
removal actions planned, including removing almost 300,000 cubic
yards of contaminated soil, recovering ammunition and other ordnance
scattered over several square miles, and removing 11 underground
storage tanks of up to 50,000 gallons each.  DOE's Director for
Environmental Restoration at INEL said the facility uses removal
actions to maximize the cleanup that can be achieved with available
funds.  However, she noted that at some point the results of the
removal action still need to be evaluated under the CERCLA process to
ensure that no further action is required. 

Managers from Idaho's Department of Health and Welfare who oversee
environmental restoration at INEL said they consider removal actions
to be effective and to save both time and money.  They said that if
DOE asked to use removal actions instead of other more extensive
CERCLA planning processes, they would consider removal actions an
acceptable alternative. 


         OAK RIDGE IS SHIFTING TO
         GREATER USE OF REMOVAL
         ACTIONS
-------------------------------------------------------- Letter :4.1.2

While Oak Ridge has not relied extensively on removal actions in the
past, officials at the facility now expect to use removal actions
more frequently.  Between fiscal years 1991 and 1995, Oak Ridge
conducted seven removal actions.  However, Oak Ridge has four removal
actions planned for fiscal year 1996 and has compiled a list of 10
candidate removal actions to be carried out in the next 2 fiscal
years.  DOE officials believe that removal actions should be used
when they can be done quickly and cost-effectively. 


         HANFORD AND SAVANNAH
         RIVER ARE MAKING ONLY
         LIMITED USE OF REMOVAL
         ACTIONS
-------------------------------------------------------- Letter :4.1.3

Compared to the other three facilities, Hanford and Savannah River
plan to rely less on the use of removal actions.  At Hanford,
officials previously pursued removal actions actively, but they are
no longer doing so.  In 1991, Hanford issued a cleanup strategy
(called the Past Practice Strategy) proposing that all waste sites be
considered as potential candidates for the removal action approach. 
Hanford had a contractor group dedicated to selecting, planning, and
conducting removal actions.  This group identified about 25 projects
as candidates for removal actions.  Seven actions were initiated
before the group was dissolved in 1993 as part of a reorganization of
responsibilities.  Since then, although the Past Practice Strategy
encouraging the use of removal actions has remained in effect,
Hanford has initiated only one removal action.  DOE, EPA, and state
regulators have agreed to pursue interim remedial measures as the
primary CERCLA planning process at the installation. 

Likewise, Savannah River has made only limited use of removal
actions.  Since fiscal year 1991, Savannah River has performed seven
removal actions.  None of these actions has been intended to serve as
the final remediation for the waste site.  Savannah River staff plan
three additional removal actions for fiscal year 1996, but these
projects, much like the removal actions carried out in the past, are
stopgap measures, designed to control vegetation on three waste
sites, and are not intended to be final actions. 


      MANY UNTREATED SITES SHARE
      KEY CHARACTERISTICS WITH
      REMOVAL ACTION SITES
---------------------------------------------------------- Letter :4.2

Of the more than 3,000 waste sites located at the five facilities,
many are similar to those that have been addressed through removal
actions.  The 39 removal actions we studied addressed 4 burial
grounds, 5 cases of groundwater or surface water contamination, and
21 instances of soil contamination.  While many untreated sites may
require no cleanup, hundreds will require further action.  Many
involve liquid waste disposal facilities, burial grounds,
contaminated soil, and contaminated groundwater--conditions similar
to those at waste sites that DOE has addressed through removal
actions.  For example, of the 498 identified waste sites along the
Columbia River at Hanford, 54 are burial grounds and 108 are liquid
waste disposal facilities. 


      VARIOUS FACTORS ARE LIMITING
      THE USE OF REMOVAL ACTIONS
---------------------------------------------------------- Letter :4.3

Our analysis and discussions with DOE and regulatory officials at the
facilities we visited suggest that six factors limit the wider use of
removal actions. 

Removal actions are not part of the agreements with regulators or DOE
contractors.  Generally, interagency agreements have not included
removal actions.  Instead, these agreements have often incorporated
the steps included in lengthier CERCLA planning processes.  The
extensive planning and evaluation processes characteristic of the
full CERCLA and interim remedial approaches, including the
preparation of work plans and various reports, were specified in each
of the agreements we reviewed.  For example, at Savannah River, DOE
and its regulators established milestones for fiscal year 1996
calling for the submission of almost 50 documents required under
CERCLA, such as remedial investigation reports and proposed plans. 

Like the interagency agreements, DOE's contracts emphasize completing
steps in the process rather than performing cleanup actions, and they
provide few specific incentives for remediation.  For example, at
Savannah River the incentive goal is tied to meeting the interagency
agreement milestones on time and doing the work at less cost. 
Similarly, at Hanford, over half of the incentive is tied to
improving the contractor's operating processes, and less than 20
percent is tied solely to performing the actual remediation. 

In contrast, in order to accomplish remediation more quickly, DOE and
the regulators at Rocky Flats are revising their agreement to
establish remediation-based instead of process-based milestones.  In
the interim, they have agreed to remediate two trenches in fiscal
year 1996.  DOE is already implementing this change with its Rocky
Flats contractor.  In fiscal year 1996, the contractor will remediate
the two trenches and one other waste site as directed by DOE.  The
contractor said this results-oriented strategy will force the greater
use of removal actions because none of the other planning approaches
can be used to complete the work on schedule. 

At Oak Ridge, officials attribute their more frequent use of removal
actions to a change in their interagency agreement.  The agreement
now requires regulators to be involved in removal actions.  Oak Ridge
officials believe the change has increased the regulators' acceptance
of removal actions. 

Perceptions about when removal actions should be used are incorrect. 
Some DOE and regulatory officials told us that they believe removal
actions are intended for emergency situations or for planning
relatively small, uncomplicated remediation projects, not for
"mainstream" cleanups.  For example, at Hanford, DOE conducted a
time-critical action to remove buried barrels containing solvents
because the barrels were leaking and threatened to contaminate the
Columbia River.  A deputy director of environmental restoration at
Hanford said that he would consider using a removal action in the
future if a waste site were continuing to release contamination that
posed a significant threat to human health or the environment. 
However, he does not view removal actions as appropriate for
Hanford's normal cleanup operations at sites where no urgent threat
exists. 

The view that removal actions should be limited to urgent or small,
uncomplicated remediation projects is not supported by DOE's and
EPA's guidance or by experiences at the sites we visited.  As
discussed above, DOE and EPA jointly issued policy in 1994
encouraging the use of removal actions in nonemergency situations as
long as CERCLA's regulations were followed.  Furthermore, DOE has
successfully used removal actions when an urgent threat has not
existed or when large or complex problems have required attention. 

Preference is given to streamlining full CERCLA and interim remedial
planning approaches.  As a way to shorten the time before remediation
can begin, officials at some sites are concentrating on shortening
the steps of lengthier CERCLA planning processes.  These officials
estimate that the streamlining will reduce the time required in
various planning steps.  For example, DOE officials at Savannah River
estimate that by streamlining the full CERCLA process they will be
able to reduce the average time required to plan for a cleanup from 4
years to 3 years. 

However, planning and evaluation will still take significantly longer
under streamlined CERCLA processes than under removal actions.  At
Oak Ridge, for example, the expedited CERCLA process laid out in the
site's interagency agreement is expected to take 6 years.  In some
cases, Oak Ridge officials expect to further shorten the full CERCLA
process to about 3.5 years.  However, under Oak Ridge's interagency
agreement, removal actions are scheduled to take only 14 months.  At
Savannah River, the streamlined planning process is expected to take
3 years, whereas removal actions are estimated to require only 6 to
12 months.  At Hanford, DOE and its regulators have agreed to
eliminate certain documents required by the interim remedial process,
but they were unable to estimate how much time and money would be
saved. 

Planning has progressed too far to benefit from the simpler removal
action process.  Several DOE officials at these facilities said that,
for many waste sites, the investigative studies for the full CERCLA
and interim remedial processes have progressed so far that there
would be little benefit from switching to removal actions.  For
example, officials at Hanford pointed out that they expect most
high-priority waste sites in the environmentally sensitive area next
to the Columbia River to be ready for cleanup in 1 to 3 years, making
removal actions unnecessary. 

We found instances, however, in which the use of removal actions has
been effective even after planning for remediation under lengthier
processes has been partially completed.  Officials at Rocky Flats and
INEL used information gathered under lengthier CERCLA processes as
the basis for removal actions, thereby accomplishing these actions
more quickly than they would otherwise have done.  For example, INEL
officials used the remedial investigation report from the full CERCLA
process as the engineering evaluation for a removal action to remove
radioactively contaminated soil from six waste sites.  INEL officials
estimate that changing to a removal action speeded the actual
remediation by several years and saved $2.6 million.  At Oak Ridge,
the state regulator said that at some sites cleanups now under the
full CERCLA process may be converted to removal actions.  He said
that Oak Ridge's focus is increasingly on getting into the field. 

Limited planning may increase the risk that an incorrect remedy will
be chosen.  Frequently, contamination at DOE waste sites is not well
known.  Of the 39 removal actions we reviewed, 1 incurred added or
unnecessary costs because the actual conditions at the site were
different from the expected ones.  At Hanford, DOE conducted a
removal action to excavate old drums thought to contain residues of a
hazardous chemical.  Upon excavation, DOE found no significant
contamination in the pit.  Fuller characterization before excavating
the site might have helped to avoid the expense of excavation. 
However, a state regulator at Hanford said that full characterization
of the burial ground would have cost more than the excavation. 

A removal action may not be the final solution.  A final issue that
was raised at several facilities was that, in contrast to the full
CERCLA process, a removal action is an interim solution that must be
documented through a record of decision after the action has been
completed.  EPA officials said that potential problems with final
decisions could be significantly reduced by encouraging public
participation and close cooperation between the regulators and DOE. 
DOE officials at INEL also stressed the importance of securing the
regulators' agreement with the proposed removal actions, particularly
at sites where little is known of the contamination and the
effectiveness of the planned remedial technology is unclear.  DOE
officials also expressed concern that when the final decision is
proposed to the public and the regulators, additional remediation
could be required.  Of the 39 removal actions we studied, 26 were
intended to be the final solution.  None of the 26 is expected to
require additional remediation when the record of decision is
completed, but only one record of decision covering 4 removal actions
at Hanford has been completed.  In addition, interim remedial
measures, which are widely used by DOE, also require a record of
decision after the measures have been implemented. 


   CONCLUSIONS
------------------------------------------------------------ Letter :5

More extensive use of removal actions would provide a means for
speeding the planning process and devoting more environmental
restoration dollars to actual remediation at sites.  We recognize
that not every waste site is appropriate for the abbreviated planning
that takes place under removal actions; however, the successful use
of removal actions at a variety of environmental restoration sites
throughout the DOE complex indicates that additional opportunities
exist to employ this cost- and time-saving approach. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :6

We recommend that the Secretary of Energy direct the managers of
DOE's facilities, working with their regulators, to reevaluate their
environmental restoration strategies to ensure the maximum possible
use of removal actions.  Where appropriate, this action may include

  -- systematically evaluating each waste site where actual cleanup
     has not yet begun, including those sites where a lengthier
     assessment process is under way, to identify the sites where
     using a removal action would be feasible and cost-effective;

  -- seeking agreement to eliminate requirements in existing
     interagency agreements that favor lengthier review and
     assessment processes in exchange for a commitment to achieving
     significant cleanup progress through removal actions; and

  -- identifying and implementing incentives for DOE's contractors
     that would increase the emphasis on, and the reward for,
     pursuing removal actions where appropriate. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :7

We provided a draft of this report to DOE and EPA for their review
and comment.  We discussed the report with officials from DOE's
Office of Environmental Restoration, including the Director of the
Office of Program Integration, and with officials from EPA's Federal
Facilities Enforcement Office, including the Senior Enforcement
Counsel.  Overall, the officials agreed that the report was accurate. 
Both agencies provided some technical comments that we have
incorporated in the report.  DOE agreed with our conclusion that
removal actions can be completed in less time and are less costly
than other approaches.  However, DOE said that the report implies
that DOE has more discretion to initiate removal actions than the
Department believes that it has.  DOE said that the report did not
give enough emphasis to the barriers, such as the requirements in
interagency agreements, that the Department faces in using removal
actions at more waste sites.  DOE also noted that it is supporting
revisions to CERCLA to increase its flexibility.  We have modified
our report to reflect DOE's concerns; however, we continue to believe
that DOE can do more to overcome these barriers. 

EPA said that it generally supports the increased use of removal
actions where it and/or state regulators have had the opportunity to
coordinate with DOE.  EPA suggested that removal actions could be
enhanced by closer cooperation between regulators and DOE through the
use of teams and early efforts to include the public in decisions
about using removals.  EPA also suggested that DOE document the
savings in time and cost from using removal actions by collecting
comparative data to improve the public's and regulators' acceptance
of removal actions.  We agree that these are steps that DOE should
consider. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :8

We conducted our review at Hanford in Washington State, INEL in
Idaho, Oak Ridge Reservation in Tennessee, Savannah River in South
Carolina, and Rocky Flats in Colorado.  We selected these facilities
because DOE estimates that they will account for about 94 percent of
the total cost of restoring the DOE complex. 

To determine whether removal actions have been successful in speeding
cleanups, reducing costs, and providing other benefits, we attempted
at each facility to gather data on the time spent and the costs
incurred to plan waste sites' remediation using both removal actions
and lengthier CERCLA processes.  We reviewed projects' files, toured
various sites restored through the removal action process, analyzed
official records, and reviewed various reports.  At Oak Ridge,
Savannah River, and Hanford, cost data were not available on all
projects.  At those facilities, we obtained the cost data that were
readily available.  We also discussed the advantages and
disadvantages of removal actions with DOE and contractor officials. 

To identify additional opportunities for DOE to use removal actions,
we compared untreated waste sites to waste sites that had been
successfully treated through removal actions.  We also interviewed
officials at each location and reviewed lists of potential removal
actions that had been prepared at some sites.  To identify potential
barriers to the greater use of removal actions, at each location we
reviewed agreements with regulators, as well as selected contracts
and incentives provided to DOE contractors.  We also reviewed
relevant statutes and regulations, as well as EPA's and DOE's
guidance, and discussed the Department's guidance with DOE's Office
of Environmental Guidance.  To obtain the Department's perspective on
the role of removal actions, we discussed the approach with DOE's
Office of Environmental Restoration.  We also interviewed state and
EPA regulators responsible for activities at the five facilities and
EPA officials from the Federal Facilities Enforcement Office. 

We conducted our work from July 1995 to April 1996 in accordance with
generally accepted government auditing standards. 


---------------------------------------------------------- Letter :8.1

As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 10 days
from the date of this letter.  At that time, we will send copies of
this report to the appropriate congressional committees, the
Secretary of Energy, and other interested parties.  We will also 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
I. 

Sincerely yours,

Victor S.  Rezendes
Director, Energy, Resources,
 and Science Issues


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I


   ENERGY, RESOURCES, AND SCIENCE
   ISSUES
--------------------------------------------------------- Appendix I:1

Chris Abraham
Robert Lilly
James Noel
Delores Parrett
Angela Sanders
Bernice Steinhardt
Stanley Stenersen
William Swick


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