Nuclear Waste Cleanup: DOE's Cleanup Plan for the Paducah, Kentucky Site
Faces Uncertainties and Excludes Costly Activities (Testimony,
06/27/2000, GAO/T-RCED-00-225).

Pursuant to a congressional request, GAO discussed the Department of
Energy's (DOE) efforts to clean up its Paducah, Kentucky, uranium
enrichment plant, focusing on: (1) DOE's planned activities, cost, and
schedule for cleaning up the site; (2) the challenges in accomplishing
the cleanup plan; and (3) whether the cleanup plan includes all areas at
the site requiring cleanup.

GAO noted that: (1) DOE expects to complete the cleanup by 2010 at a
cost of about $1.3 billion; (2) DOE's cleanup plan focuses on six major
categories of cleanup; (3) four of these address the physical
contamination at the site--about 10 billion gallons of groundwater
contaminated with radioactive and hazardous materials, contaminated
surface water in creeks and ditches leaving the site, contamination in
soils that may be spread by rain, and tons of buried waste; (4) the two
other major categories include treating and disposing of the equivalent
of about 52,000 barrels of waste and decontaminating and removing two
unused process buildings; (5) numerous technical, funding, and
regulatory uncertainties present challenges to DOE's ability to complete
the cleanup as planned; (6) technical uncertainties include the planned
use of technologies that are unproven or perhaps not well suited to the
site's conditions; (7) also underpinning the plan is the assumption that
federal funding for cleanup at Paducah will increase to an average of
$124 million annually over the next decade, compared with the last 7
years' annual average funding of $43 million; (8) the plan also includes
optimistic assumptions about reaching agreement with regulators on
issues such as cleanup levels, strategies, and priorities; (9) even when
the planned cleanup has been carried out, billions of dollars and many
years will be needed to address areas at the Paducah site that are not
in the cleanup plan; (10) the plan excludes nearly a million cubic feet
of waste and scrap in areas known as DOE Material Storage Areas and 16
unused and inactive buildings and structures; (11) the additional
materials, buildings, and structures are excluded from the plan not
because they require no action but because they fall under the purview
of a different departmental program; and (12) this programmatic
distinction prevents the Paducah cleanup managers from assessing risk or
planning a cleanup on a comprehensive, sitewide basis, and distorts the
picture of the cleanup task at hand.

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

 REPORTNUM:  T-RCED-00-225
     TITLE:  Nuclear Waste Cleanup: DOE's Cleanup Plan for the Paducah,
	     Kentucky Site Faces Uncertainties and Excludes
	     Costly Activities
      DATE:  06/27/2000
   SUBJECT:  Nuclear waste management
	     Uranium
	     Water pollution control
	     Strategic planning
	     Radioactive pollution
	     Industrial facilities
	     Federal/state relations
	     Radioactive waste disposal
	     Cost control
IDENTIFIER:  Paducah (KY)
	     Superfund Program

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GAO/T-RCED-00-225

NUCLEAR WASTE CLEANUP

DOE's Cleanup Plan for the Paducah, Kentucky Site Faces Uncertainties and
Excludes Costly Activities Statement of Ms. Gary L. Jones, Associate
Director, Energy, Resources, and Science Issues, Resources, Community, and
Economic Development Division

United States General Accounting Office

GAO Testimony Before the Subcommittee on Energy Research,

Development, Production and Regulation, Committee on Energy and Natural
Resources, U. S. Senate

For Release on Delivery Expected at 2: 30 p. m. EDT Tuesday June 27, 2000

GAO/ T- RCED- 00- 225

GAO/ RCED- T- 00- 225 1

Mr. Chairman and Members of the Subcommittee: We are pleased to be here
today to discuss the Department of Energy's (DOE) efforts to clean up its
Paducah, Kentucky, uranium enrichment plant. Recent allegations that past
activities at the plant endangered the health of employees led to renewed
interest in DOE's efforts to clean up the site- efforts that began in 1988,
when contamination was discovered in the drinking water wells of residences
near the plant. Allegations include the improper disposal of hazardous and
radioactive materials, release of contamination into streams and drainage
ditches, and exposure of workers to radioactive materials. In an October
1999 report on Paducah, DOE found that limited progress has been made in
cleaning up the source areas of contamination at the site, such as
landfills, waste burial grounds, and waste and scrap piles. 1

Our statement today, based on our April 28, 2000, report, 2 addresses three
issues: (1) DOE's planned activities, cost, and schedule for cleaning up the
site; (2) the challenges in accomplishing the current cleanup plan; and (3)
whether the cleanup plan includes all areas at the site requiring cleanup.

In summary:

ï¿½ DOE expects to complete the cleanup by 2010 at a cost of about $1.3
billion (in addition to the nearly $400 million spent over the past decade
on the characterization of the contamination on site and mitigation efforts,
such as connecting residences with contaminated drinking water to municipal
water). DOE's cleanup plan focuses on six major categories of cleanup. Four
of these address the physical contamination at the site: about 10 billion
gallons of groundwater contaminated with radioactive

1 Phase I: Independent Investigation of the Paducah Gaseous Diffusion Plant
(Office of Oversight; Office of Environment, Safety and Health; Department
of Energy; Oct. 1999). 2 Nuclear Waste Cleanup: DOE's Paducah Plan Faces
Uncertainties and Excludes Costly Cleanup Activities (GAO/ RCED- 00- 96,
Apr. 28, 2000).

GAO/ RCED- T- 00- 225 2

and hazardous materials, contaminated surface water in creeks and ditches
leaving the site, contamination in soils that may be spread by rain, and
tons of buried waste. The two other major categories include treating and
disposing of the equivalent of about 52,000 barrels of waste and
decontaminating and removing two unused process buildings.

ï¿½ Numerous technical, funding, and regulatory uncertainties present
challenges to DOE's ability to complete the cleanup as planned. Technical
uncertainties include the planned use of technologies that are unproven or
perhaps not well suited to the site's conditions. Also underpinning the plan
is the assumption that federal funding for cleanup at Paducah will increase
to an average of $124 million annually over the next decade, compared with
the last 7 years' annual average funding of $43 million. The plan also
includes optimistic assumptions about reaching agreement with regulators on
issues such as cleanup levels, strategies, and priorities.

ï¿½ Finally, even when the planned cleanup has been carried out, billions of
dollars and many years will be needed to address areas at the Paducah site
that are not in the cleanup plan. For example, almost 500,000 tons of
depleted uranium will need to be converted to a more stable form and removed
from the site. In addition, the plan excludes nearly a million cubic feet of
waste and scrap in areas known as DOE Material Storage Areas (DMSA) and 16
unused and inactive buildings and structures. Some of the waste and scrap
material pose a risk of an uncontrolled nuclear reaction that could threaten
worker safety. Such a reaction produces a burst of radiation that generally
lasts several hours; it is, however, a localized event that would not result
in an explosion or release of radioactivity into the atmosphere. The
additional materials, buildings and structures are excluded from the plan
not because they require no action but because they fall under the purview
of a different departmental program. The DMSAs and the 16 excess buildings
and structures are the responsibility of DOE's Office of Nuclear Energy,
Science, and Technology (Office of Nuclear Energy), while the site cleanup
is the Office of Environmental Management's

GAO/ RCED- T- 00- 225 3

responsibility. This programmatic distinction prevents the Paducah cleanup
managers from assessing risk or planning cleanup on a comprehensive,
sitewide basis, and distorts the picture of the cleanup task at hand. As a
result, we recommended in our report that these areas be transferred from
the Office of Nuclear Energy to the Office of Environmental Management. We
also recommended that the cleanup plan address all materials at the site
that are potential health hazards, regardless of organizational
responsibility, and that sitewide contamination risk and cleanup priorities,
cost, and schedules be reexamined.

Background

The Paducah uranium enrichment plant is located in western Kentucky, about 3
miles south of the Ohio River and about 10 miles west of the city of
Paducah. The plant- formerly run by DOE and now operated by a private
company, the United States Enrichment Corporation (USEC)- enriches uranium
for commercial nuclear power plants. Plant operations have contaminated the
site over time with radioactive and hazardous chemical wastes, including
technetium- 99 (a radioactive fission product), polychlorinated biphenyls
(PCBs), uranium, and volatile organic compounds such as trichloroethene
(used as a degreaser).

DOE's management of the Paducah site is divided between two offices. The
Office of Environmental Management is responsible for the site's cleanup,
while the Office of Nuclear Energy acts as the site's
“landlord,” with responsibilities for maintaining roads,
grounds, and facilities not leased to USEC and for managing material storage
areas and cylinders of depleted uranium. Cleanup activities are managed
under contract by Bechtel Jacobs. Other stakeholders include the
Environmental Protection Agency (EPA) and the Commonwealth of Kentucky, both
of which have regulatory responsibilities and participate in cleanup
decisions.

GAO/ RCED- T- 00- 225 4

Two federal environmental statutes govern the cleanup of the Paducah site.
The Comprehensive Environmental Response, Compensation, and Liability Act of
1980, commonly known as Superfund, provides broad federal authority to
respond directly to releases or threatened releases of hazardous substances
that may endanger public health or the environment. The Resource
Conservation and Recovery Act of 1976 applies to the safe management and
disposal of hazardous or other solid wastes.

Specific cleanup strategies, their cost estimates, and time frames for
completion are included in lifecycle baselines prepared by the site
contractor, Bechtel Jacobs. The lifecycle baseline, according to DOE and
contractor officials, is a “living document;” it is updated
frequently to reflect the evolving nature of the cleanup process. Revisions
to the lifecycle baseline are made to incorporate such things as changes in
funding; updated cost estimates for specific studies, tests, and cleanup
tasks; and changes in project approach or scope necessitated by study
results. Such revisions can affect estimates of the total cost and schedule.
We examined activities, costs, and schedules contained in the January 26,
2000, version of the lifecycle baseline.

DOE Plans to Clean Up Six Major Categories by 2010 at a Cost of About $1.3
Billion

DOE's January 2000 plan divides cleanup activities into six major
categories- groundwater, surface water, surface soils, burial grounds,
52,000 barrels of accumulated wastes, and removal of two unused process
buildings. DOE plans to complete its cleanup by 2010 at a cost of
approximately $1.3 billion. Table 1 shows, by cleanup category, the planned
cleanup cost and completion date.

GAO/ RCED- T- 00- 225 5

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

Dollars in thousands Cleanup category Cleanup cost Completion date

Groundwater $ 162,100 2006 Surface water 162,300 2007 Surface soils 19,000
2007 Burial grounds 535,400 2010 Waste barrels (52,000) 228,100 2010 Unused
process buildings 92,100 2008 Other a 104,200 2011

Total $1,303,200

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

Source: DOE.

Taken together, the scope of the planned cleanup activities for the six
categories is immense. First, three plumes of groundwater contaminated with
radioactive and hazardous materials is flowing toward the Ohio River. The
plumes contain an estimated 10 billion gallons of groundwater tainted with
trichloroethene and 250 million gallons tainted with radioactive technetium-
99, a fission product. Trichloroethene in the groundwater has been found at
levels of up to 700,000 parts per billion; the drinking water standard is 5
parts per billion. DOE has connected nearby residences to municipal drinking
water and constructed groundwater pump- and- treat systems to reduce the
contamination of two of the plumes. DOE is considering the use of cleanup
technologies to remove the sources of groundwater contamination and to
remove the contamination from the groundwater.

Second, surface water contamination has been discovered in surrounding
creeks and ditches. One of the main sources of this contamination is the
thousands of tons of contaminated scrap metal that DOE has stored on site.
During rainstorms, contamination washes from the scrap metal, and the runoff
carries contaminated soils and sediments into the ditches and creeks.
Contamination also stems from the discharge of wastewater from plant
operations. Interim measures have included treating some

GAO/ RCED- T- 00- 225 6

wastewater and rerouting wastewater around contaminated ditches. DOE's
planned cleanup tasks include removing the 65,000 tons of scrap metal,
dredging ditches and creeks, and installing basins to catch, and thus allow
treatment of, the contaminated water.

Third, surface soils on- and off- site have been contaminated by water
runoff, spills, and buried waste. DOE has identified 72 areas with
contaminated soils and has taken interim measures, such as installing
erosion control fences, to prevent further migration of the contamination.
DOE's planned cleanup tasks include excavating and disposing of about 35,000
cubic yards of soil and continuing the use of an innovative technology to
clean the soil at one highly contaminated area.

The fourth cleanup category consists of 12 waste burial grounds that contain
a variety of contaminants, including arsenic, beryllium, PCBs,
trichloroethene, and pyrophoric uranium, which has a tendency to
spontaneously combust in the presence of oxygen. The estimated contents of
one of these burial grounds include 450 gallons of trichloroethene, 59,000
gallons of oils, and 270 tons of uranium. DOE is planning to excavate four
or five of these areas and install a protective cover, or cap, over the
remaining areas.

The fifth category consists of the equivalent of 52,000 barrels of waste
stored in various locations. 3 The majority of these barrels contain
hazardous chemicals or materials with low levels of radioactivity. Over
12,000 of these waste barrels are stored outdoors and are deteriorating. DOE
has disposed of only about 750 barrels of waste in the past 10 years. Before
it can ship the remaining barrels offsite, DOE must characterize and repack
most of them to make the barrels suitable for disposal.

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

GAO/ RCED- T- 00- 225 7

Finally, two process buildings that have not been used as part of the
uranium enrichment process since 1977 will be decontaminated and removed.
These two buildings are heavily contaminated from earlier operations.

DOE Faces Challenges in Achieving Its Cleanup Plan

A number of technical, financial, and regulatory factors associated with the
implementation of the cleanup plan make it uncertain whether DOE can
accomplish the Paducah cleanup within the targeted costs and time frames.
Uncertainties exist about the nature and extent of contamination and the
feasibility of cleanup technologies. In addition, assumptions about the
availability of federal funding and the timeliness of stakeholders'
agreement with cleanup levels and strategies may affect DOE's ability to
meet the plan's milestones.

Uncertainties about the nature, extent, and sources of contamination could
affect the cleanup plan; the outcome of such uncertainties could increase
cleanup costs. For example, the full extent of contamination in the surface
water and soils within and outside the plant boundaries remains to be
determined and could affect cleanup strategies, including the number of
sedimentation basins that will need to be installed. The basins are intended
to collect storm water runoff and will allow the treatment of any
contaminants the runoff may contain. The state has expressed its preference
for installing eight or nine sedimentation basins, while DOE has only
budgeted for four of them and is deferring installation plans until it has
finished investigating the extent of contamination. Similarly, although
DOE's plan calls for excavating four waste burial grounds, a recent report
from the Commonwealth of Kentucky has recommended excavating seven burial
grounds. 4

Technical uncertainties related to the use of cleanup technologies also
exist. Some of the technologies contemplated for use are emerging
technologies, and others remain

4 Report of the Commonwealth of Kentucky's Task Force Examining State
Regulatory Issues at the Paducah Gaseous Diffusion Plant. Commonwealth of
Kentucky, Apr. 2000.

GAO/ RCED- T- 00- 225 8

untested for the specific environment found at Paducah. For example, it is
uncertain whether the primary treatment planned for groundwater
contamination will be successful. DOE plans to implement two key strategies
for groundwater cleanup: (1) remove or reduce the sources of the
contamination and (2) treat the contaminated groundwater as it migrates
offsite. To treat the sources of groundwater contamination, DOE plans to use
a technology called dynamic underground stripping. This technology injects
steam into the aquifer to volatilize the trichloroethene and cause it to
rise to the surface, where it is extracted. According to EPA officials,
however, difficulties with steam injection were encountered at another site,
and there are questions about whether the technology will work at the
Paducah site because of the complex geologic formation.

DOE's ability to treat the contaminated groundwater plumes is also
uncertain. DOE plans to install over 4,000 feet of permeable treatment
barriers across the paths of the highest concentrations of contamination
within the plumes. Installing barriers involves injecting a gelatinous,
gummy substance called guar gel- at depths of up to 120 feet- into the
aquifer. The gel contains iron filings that serve as the treatment zone. In
theory, as the groundwater moves through a barrier's treatment zone, the
iron filings will chemically react with the trichloroethene, rendering it
harmless, and will attract and hold the technetium- 99. As planned, the
barriers will intercept portions of the groundwater plume with high levels
of contaminants while portions of the plume with lesser concentrations will
be left untreated.

The permeable treatment barrier technology is quite new, and the potential
for its success at the Paducah site is uncertain. The success of the barrier
depends on numerous factors, including the rate of groundwater flow, the
length of time the water resides in the treatment zone, the level of
contamination, and the permeability of the barrier compared to that of the
surrounding geologic structure. If groundwater flows too quickly through the
barrier and thus spends too little time in the treatment zone, the iron
filings might not have time to fully treat the trichloroethene. In that
case, the actions of the barrier's treatment zone could change the
contaminant to vinyl chloride, which is

GAO/ RCED- T- 00- 225 9

more toxic than trichloroethene. Furthermore, it is uncertain how long the
other principal contaminant, technetium- 99, will adhere to the iron filings
in the barrier.

In addition to the technical uncertainties, the cleanup plan is also built
on some optimistic financial assumptions. For example, the plan assumes DOE
will receive funding for cleanup that is considerably higher than it had
received in the past. According to DOE, contractor, and regulatory
officials, funding constraints have always been an issue, and their
recurrence could delay the project and add to its ultimate costs. For fiscal
years 2001 through 2010, DOE cleanup estimates range from a low of $78
million in 2001 to a high of $307 million in 2008, or an average of $124
million a year. In contrast, over the past 7 fiscal years, the site has
received funding ranging from about $36 million to about $52 million, and
averaging $43 million each year. Figure 1 compares DOE's funding projections
through 2010 with this average funding.

Figure 1: Funding Estimates for Fiscal Years 2001 Through 2010, Compared to
Previous Average

Dollars in millions 0 50

100 150

200 250

300 350

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Fiscal year

Average funding level, fiscal years 1994 through 2000

Source: GAO's analysis of DOE's data.

GAO/ RCED- T- 00- 225 10

The cleanup plan also contains optimistic assumptions about the timely
achievement of regulatory and stakeholder agreement on cleanup levels,
strategies, and priorities. The lack of timely agreement could slow the
cleanup and increase the costs. In the past, regulators and stakeholders
have disagreed with various aspects of DOE's cleanup plan, and the
disagreements have resulted in alterations that have been time- consuming
and at times costly. For example, DOE cleaned up an area with PCBs in the
soils to EPA's standard of 25 parts per million for open or unoccupied
areas. Kentucky objected, however, saying that it wanted the PCBs in the
soils cleaned up to 1 part per million, EPA's standard for occupied areas
(e. g. industrial or residential use). The parties agreed to defer the
resolution of this issue until DOE submits its plans for surface water
cleanup. The state has put DOE on notice, however, that it wants a stringent
cleanup level for the surface water in order to protect the ecosystem. If
DOE adopts a more stringent cleanup level than currently planned, its costs
to complete the effort will grow.

Cleanup Plan Does Not Address All Areas that Require Cleanup

Even when the planned cleanup has been carried out, billions of dollars and
many years more will be needed to address areas at the site not currently
included in the cleanup plan. These areas are excluded not because they
require no action but because they fall under the managerial jurisdiction of
DOE's Office of Nuclear Energy rather than its Office of Environmental
Management. This programmatic distinction between the two offices prevents
the Paducah cleanup managers from assessing risk or planning cleanup on a
comprehensive sitewide basis. Specifically, four areas are excluded from the
plan and will need to be addressed before site cleanup can be considered
complete: (1) large amounts of waste and scrap materials, (2) various unused
buildings and structures, (3) thousands of tons of depleted uranium, and (4)
the buildings and equipment currently being used in the enrichment process
that will require cleanup when the plant closes.

The cleanup plan excludes nearly a million cubic feet of waste and scrap
contained in 148 DOE Material Storage Areas, or DMSAs, located across the
site- some indoors, some outdoors. The materials in these areas include
thousands of barrels of low- level

GAO/ RCED- T- 00- 225 11

radioactive waste, PCB waste, and asbestos waste; contaminated process
equipment; various items and containers whose contents are unknown; and
scrap metal. DOE has not yet determined the exact nature and extent of
contamination in these areas, but it has identified 73 of them as posing a
risk of an uncontrolled nuclear reaction (a burst of radiation that
generally lasts several hours). DOE officials said they plan to pay USEC
nearly $5 million to conduct a nuclear criticality safety review on the 10
DMSAs posing the highest risk. However, this does not address the need for a
review of the other DMSAs that DOE has identified as having nuclear
criticality safety concerns. Nor are cost or schedule estimates in place for
characterizing all the DMSAs to determine whether they contain material
regulated under federal environmental statutes. According to the DOE
official responsible for these areas, the DMSAs have not been transferred to
the Office of Environmental Management because DOE is hesitant to transfer
any more areas to it. The Office of Environmental Management already has a
large workload, and funding for cleanup is limited. However, because the
DMSAs have not been transferred to the Office of Environmental Management,
they could impede the progress of the cleanup schedule. For example, one of
the DMSAs is located on top of a burial ground included in the cleanup plan,
but the cleanup plan does not include cost or schedule estimates for
removing the DMSA material. Furthermore, DOE officials could not provide any
assurances that the material in the DMSAs, if not characterized and removed
prior to the completion of the site cleanup, would not recontaminate any
cleaned up areas.

The cleanup plan also excludes 16 unused buildings and structures. These
buildings and structures, which were originally used as part of the
enrichment process, include a sludge lagoon, two water storage tanks, a
nitrogen generation plant, and an incinerator. According to DOE officials,
lack of funding and higher priorities have prevented these buildings and
structures from being transferred to the Office of Environmental Management
for cleanup.

GAO/ RCED- T- 00- 225 12

Before the site is considered cleaned up, nearly half a million tons of
depleted uranium hexafluoride stored at the site, mostly in 14- ton-
capacity cylinders, will need to be addressed. This material is the by-
product of the uranium enrichment process and poses potential health risks.
In July 1999, DOE announced plans to build and operate- for 25 years- a
facility at Paducah to convert this material to a more stable form at an
estimated cost of $1.8 billion to $2.4 billion. However, DOE has not
identified any significant uses for the material once it has been converted.

Finally, DOE's cleanup plan does not reflect the costs of decontamination
and decommissioning that will be required after USEC ceases plant operations
and terminates its lease with DOE. DOE has estimated in January 1998 the
cost of this additional cleanup at about $1 billion.

Mr. Chairman, as I have stated, even if DOE's January 2000 cleanup plan is
followed, billions of dollars and many more years will be required to
address contaminated or potentially hazardous areas that are not included in
the current cleanup plan. The exclusion of these areas from the plan
prevents the Congress and other stakeholders from easily ascertaining the
full scope and cost of the actual cleanup task at hand. We are also
concerned that if DOE does not transfer responsibility for the material
storage areas and the unused structures to its Office of Environmental
Management, as we recommended in our report to you, a comprehensive sitewide
assessment of risks and priorities cannot be effectively completed. The
Congress and stakeholders undoubtedly have expected that when the current
cleanup plan has been accomplished, the site will be clean. It will not.

--- Mr. Chairman, this concludes my prepared statement. I will be pleased to
respond to any questions that you or Members of the Committee may have.

GAO/ RCED- T- 00- 225 13

Contact and Acknowledgement

For future contacts regarding this testimony, please contact Ms. Gary L.
Jones on (202) 512- 3841. Individuals making key contributions to this
testimony include Erin Barlow, Daniel Feehan, Glen Trochelman, and Pam
Tumler.

(141447)

GAO/ RCED- T- 00- 225 14

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