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
1 GAO/RCED-T-00-225

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,2addresses 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:

• 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).
2 GAO/RCED-T-00-225

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.

• 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.

• 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
3 GAO/RCED-T-00-225

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.
4 GAO/RCED-T-00-225

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.
5 GAO/RCED-T-00-225

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

Othera104,200 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
6 GAO/RCED-T-00-225

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.
7 GAO/RCED-T-00-225

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.
8 GAO/RCED-T-00-225

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
9 GAO/RCED-T-00-225

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.
10 GAO/RCED-T-00-225

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
11 GAO/RCED-T-00-225

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.
12 GAO/RCED-T-00-225

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.
13 GAO/RCED-T-00-225

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)
14 GAO/RCED-T-00-225

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