United States Government Accountability Office

GAO Report to the Subcommittee on Energy 

and Water Development, Committee on 

Appropriations, House of Representatives

NUCLEAR WASTE

Plans for Addressing 

Most Buried 

Transuranic Wastes 

Are Not Final, and 

Preliminary Cost 

Estimates Will Likely 

Increase 

June 2007 

 

GAO-07-761 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2007

NUCLEAR WASTE

Plans for Addressing Most Buried 

Transuranic Wastes Are Not Final and 

Preliminary Cost Estimates Will Likely 

Increase 

Highlights of GAO-07-761, a report to the 

Subcommittee on Energy and Water 

Development, Committee on 

Appropriations, House of Representatives

Since the 1940s, the development 

of nuclear weapons technologies

has generated transuranic wastes—

materials contaminated by certain 

man-made radioactive elements. 

These wastes can remain

dangerous for thousands of years.

Until 1970, the Department of

Energy’s (DOE) predecessors 

buried these wastes in shallow pits

and trenches. Today, state officials 

and communities near DOE’s major

disposal sites have expressed 

concerns that such wastes might

contaminate important ground and 

surface water resources. 

GAO was asked to (1) determine

the legal requirements and policies 

affecting DOE’s efforts to address 

transuranic wastes buried before 

1970, (2) determine what DOE is

doing to address sites where these 

transuranic wastes are buried, and 

(3) assess the reliability of DOE’s 

estimated costs to address these 

sites. 

We met with federal and state 

officials at five DOE sites

containing buried transuranic 

wastes, reviewed environmental

laws and guidance, and obtained

buried waste cleanup cost

estimates from each site. 

In commenting on this report, DOE 

generally agreed with our findings,

and provided some clarifying 

comments. 

What GAO Recommends

GAO is not making

recommendations at this time. 

Cleanup agreements with federal and state agencies require DOE to 

investigate and clean up the five major DOE sites where transuranic and 

other hazardous wastes were buried. While DOE has long considered pre1970s buried wastes permanently disposed, in 1989, the sites where most of 

these wastes are buried were listed as “Superfund” sites subject to the 

Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERCLA). CERCLA requires that DOE determine the nature and 

extent of contamination at each waste site and determine what cleanup 

action, if any, is needed to protect human health and the environment. All 

five disposal sites are scheduled to have cleanup completed by 2025. 

DOE is addressing the transuranic wastes buried at two sites, but it is still 

investigating cleanup options at the other three locations. At Oak Ridge and 

Savannah River, DOE is leaving the transuranic wastes in place under an 

earthen cap designed to prevent the wastes from migrating and taking steps 

to prevent animal and human access to the sites. In contrast, DOE is still 

investigating cleanup options at the Idaho National Laboratory, the Hanford 

Site, and the Los Alamos National Laboratory––where about 90 percent of 

DOE’s transuranic wastes are buried. DOE has begun to remove a small 

amount of waste at the Idaho and Hanford sites, but how much buried 

transuranic wastes eventually will be removed or treated in place at these

sites is currently undetermined. 

DOE’s preliminary estimate of the cost to address the five waste sites where

transuranic wastes are buried is about $1.6 billion in 2006 dollars, but the 

estimate is likely to increase for several reasons. For example, the estimates 

reflect the costs of leaving most waste under earthen barriers—typically the 

least expensive approach. If DOE is required to retrieve substantial portions 

of these wastes, costs would increase dramatically. In addition, the 

estimates exclude unknown costs, such as the cost of disposing wastes offsite, if necessary. For example, DOE’s lifecycle cost estimate to remove

transuranic wastes buried near the Columbia River at the Hanford site could 

triple once options and costs for disposal are fully evaluated. As DOE 

further evaluates the risks, benefits, and costs of cleanup options, its policies 

require it to improve the reliability of cost estimates. Thus, GAO is not 

making recommendations at this time. 

www.gao.gov/cgi-bin/getrpt?GAO-07-761.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact James 

Cosgrove, 202-512-3841 or

cosgrovej@gao.gov. 
Contents 

Letter 1

Results in Brief 3

Background 5

Cleanup Agreements Require DOE to Address Sites Where 

Transuranic Wastes Are Buried 7 

DOE Is Containing Buried Transuranic Wastes in Place at Two 

Sites but Is Still Developing Cleanup Plans at the Largest Waste 

Sites 11

Estimated Costs to Address Waste Disposal Areas in Which 

Transuranic Wastes Are Buried Will Likely Increase 19 

Agency Comments and Our Evaluation 23 

Appendix I Scope and Methodology 25 

Appendix II Comments from the Department of Energy 27 

Appendix III Contact Information and Staff Acknowledgments 28 

Tables 

Table 1: Interagency Agreement Schedule for Addressing DOE 

Sites Containing Buried Transuranic Wastes 11 

Table 2: Summary of DOE Estimated Lifecycle Costs to Address 

Disposal Areas Containing Buried Transuranic and Other 

Hazardous Wastes 20 

Figures 

Figure 1: Typical Disposal of Transuranic and Other Wastes in 

Unlined Trench at the Hanford Site Prior to 1970 8 

Figure 2. Example of an Engineered Barrier Constructed over a 

Burial Ground Containing Radioactive or Hazardous 

Wastes 13

Figure 3: Aerial View of an Engineered Barrier under Construction 

at Oak Ridge 15 

Page i GAO-07-761 DOE Disposition of Transuranic Wastes
Abbreviations 

CERCLA Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980, as 

amended 

DOE Department of Energy 

EPA Environmental Protection Agency 

RCRA Resource Conservation and Recovery Act of 1976, 

 as amended 

WIPP Waste Isolation Pilot Plant 

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reproduce this material separately. 

Page ii GAO-07-761 DOE Disposition of Transuranic Wastes
United States Government Accountability Office

Washington, DC 20548 

June 22, 2007 

The Honorable Peter J. Visclosky 

Chairman 

The Honorable David L. Hobson 

Ranking Member 

Subcommittee on Energy and Water Development 

Committee on Appropriations 

House of Representatives 

Since the 1940s, the Department of Energy (DOE) and its predecessors 

have operated a nationwide complex of facilities used to research, design, 

and manufacture nuclear weapons and related technologies. While these 

activities are important for national defense, they have left a legacy of 

radioactive and other hazardous wastes that have contaminated or could 

contaminate the environment. Among them is a large quantity of 

transuranic wastes—typically, discarded rags, tools, equipment, soils, or 

other solid materials that have been contaminated by man-made 

radioactive elements, such as plutonium or americium. Transuranic wastes 

remain radioactive for extremely long periods—hundreds of thousands of 

years, in some cases. Inhaling or ingesting even miniscule quantities of 

some transuranic elements can cause cancer in humans. 

According to DOE, the department has buried or stored approximately 

238,000 cubic meters of transuranic wastes (equal to the volume of about 

100 Olympic-sized swimming pools) at its sites. About 111,000 cubic 

meters of these wastes were generated mostly after 1970, and then stored

at various locations with the bulk of these wastes intended for transfer to 

the Waste Isolation Pilot Plant (WIPP)—a deep geologic repository in New 

Mexico designed for permanent disposal of transuranic wastes.1

 The other 

127,000 cubic meters of transuranic wastes were disposed of, generally

before 1970, when DOE buried these wastes in shallow pits and trenches, 

 1

This report refers to wastes that were generated after 1970 and subsequently stored for

deep geologic disposal at WIPP as “stored” transuranic wastes. At some locations, these 

stored wastes were placed in containers and then buried underground. 

Page 1 GAO-07-761 DOE Disposition of Transuranic Wastes
often with other radioactive and hazardous wastes.2

 DOE estimates that 

most of these transuranic wastes are buried at its Hanford Site in 

Washington state and the Idaho National Laboratory, while almost all of 

the remaining transuranic wastes are buried at the Los Alamos National 

Laboratory in New Mexico, the Oak Ridge National Laboratory in 

Tennessee, and the Savannah River Site in South Carolina. 

In addition to the threats that buried transuranic wastes may pose, the 

other radioactive and hazardous wastes buried with them may pose 

additional threats. Some of these wastes emit skin-penetrating radiation 

and cannot be directly handled by humans. Other wastes, such as organic

solvents and toxic metals, are volatile. In some cases, these wastes can 

migrate readily through soil, especially if exposed to water, and may 

contaminate surface waters and groundwater. 

Given the potential long-term threat that buried transuranic and other 

radioactive and hazardous wastes may pose to human health and the 

environment, including their potential to contaminate water resources, 

state environmental protection officials and communities adjacent to these 

disposal sites have expressed concerns about these wastes. You asked us 

to (1) determine the legal requirements and policies governing DOE’s 

efforts to address transuranic wastes buried before 1970, (2) determine 

what DOE is doing to address sites where these transuranic wastes are 

buried, and (3) assess the reliability of DOE’s estimated costs to address 

these sites. 

To conduct our work, we visited the five DOE sites that contain most of 

DOE’s transuranic wastes buried before 1970. We met with local DOE 

officials at these five largest burial sites, which include the Hanford Site, 

the Idaho National Laboratory, the Los Alamos National Laboratory, the 

Savannah River Site, and the Oak Ridge National Laboratory. To determine 

the legal requirements and policies governing DOE’s efforts to address its 

buried transuranic wastes, we reviewed federal environmental laws and 

regulations; DOE guidance concerning hazardous and radioactive wastes; 

 2

Transuranic waste was first identified as a separate waste category in 1970, and its original

statutory definition was revised in 1982. For ease of discussion, this report refers to all 

wastes contaminated with transuranic elements as transuranic wastes, regardless when it 

was generated or disposed or whether it meets the current statutory definition. Transuranic 

wastes that were disposed of at shallow or intermediate depths before issuance and 

implementation of a 1970 directive prohibiting this practice are referred to as “buried 

transuranic wastes.” 

Page 2 GAO-07-761 DOE Disposition of Transuranic Wastes
Federal Facility Agreements and Orders; a May 2006 federal district court 

decision; and internal DOE, federal, and private studies on the storage and 

disposition of transuranic wastes. To better understand these laws, 

regulations, agreements, and policies we interviewed state environmental 

protection officials and Environmental Protection Agency (EPA) officials 

that oversee each of the buried waste locations. To determine what DOE is 

doing to address sites where transuranic wastes are buried, we reviewed 

waste cleanup planning documents that DOE prepared for these sites. In 

this context, we also interviewed scientific experts, DOE site project 

managers, state environmental regulatory officials, and EPA officials 

providing management and oversight at buried waste locations. Finally, to

assess the reliability of DOE’s estimates of the cost of addressing sites 

where transuranic wastes are buried, we analyzed each DOE field 

location’s fiscal year 2006 estimates for projects that included cleaning up 

buried transuranic wastes. A more detailed description of our scope and 

methodology is presented in appendix I. We performed our work between 

May 2006 and May 2007 in accordance with generally accepted 

government auditing standards. 

Cleanup agreements entered into with federal and state environmental 

agencies require DOE to investigate and, as necessary, clean up sites 

where radioactive and other hazardous wastes, including transuranic 

wastes, were buried from the 1940s through 1970s. While DOE considered 

transuranic wastes buried prior to 1970 to have been permanently 

disposed of, the sites where most of these wastes are buried have since 

become subject to the Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980, as amended (CERCLA), also 

known as “Superfund,” and other environmental laws. Under CERCLA, 

EPA evaluates waste sites for possible inclusion on the National Priorities 

List—EPA’s list of the nation’s most serious contaminated sites that 

contain radioactive or other hazardous substances. In 1989, EPA placed 

the sites where DOE buried most of its transuranic wastes on the National

Priorities List (Hanford Site, Idaho National Laboratory, Oak Ridge 

National Laboratory, and the Savannah River Site). CERCLA requires DOE 

to determine the nature and extent of contamination at each of these sites; 

identify options for addressing the wastes and the relative risks, 

effectiveness, and costs of each option; and to enter into a cleanup 

agreement with EPA for the expeditious completion of all necessary 

cleanup actions. DOE has entered into agreements with EPA and the 

affected states for carrying out cleanup activities at these four sites. In 

addition, the Los Alamos National Laboratory, which is not listed on the 

National Priorities List, is being cleaned up in accordance with similar 

Results in Brief 

Page 3 GAO-07-761 DOE Disposition of Transuranic Wastes
agreements with New Mexico under other environmental laws. The 

agreements for the five sites set milestones by which DOE is expected to 

complete cleanups at the sites. Of the five sites, the latest scheduled 

completion date is for the Idaho National Laboratory in 2025.

DOE has made cleanup decisions and is addressing the transuranic wastes 

buried at Oak Ridge and Savannah River, but it is still investigating 

cleanup options at the other three locations. At Oak Ridge and Savannah 

River, where about 10 percent of DOE’s transuranic wastes are buried, 

DOE is leaving the transuranic wastes in place under a man-made barrier 

constructed of layered vegetation, soil, clay, and synthetic liners designed

to prevent water from reaching the wastes and causing them to migrate 

through the soil. DOE is also implementing controls, such as perimeter 

fencing, to prevent animal intrusion and control human access to the 

burial sites. DOE officials, in conjunction with the federal and state 

environmental agencies, decided to contain the buried wastes in place 

after concluding that it would be as safe or safer for workers and the 

environment and less costly than removing the wastes from the ground. 

Federal and state environmental agencies agreed with DOE’s decisions. 

DOE finished constructing the barriers at Oak Ridge in September 2006 

and expects to complete the barrier at Savannah River by summer 2007. In 

contrast, at the other three sites––the Idaho National Laboratory, the 

Hanford Site, and the Los Alamos National Laboratory––where about 90 

percent of DOE’s transuranic wastes are buried, DOE is in varying stages 

of investigating cleanup options. A federal district court ruled in May 2006 

that a 1995 agreement between DOE and Idaho requires DOE to remove all 

of the stored and buried transuranic wastes at the Idaho site. DOE has 

appealed this ruling, and, as an interim action, is removing a small amount 

of transuranic wastes from the site. In the meantime, DOE is evaluating 

cleanup options for the site and expects to select a cleanup approach by 

2009. At Los Alamos and Hanford, DOE is still in the early stages of 

investigating waste areas and plans to evaluate cleanup options; a cleanup 

approach will be decided for these sites by 2007 and 2013, respectively. At

Hanford, DOE has already agreed to remove a small amount of buried 

transuranic waste that threatens the Columbia River. In general, state 

environmental agencies have expressed concern that leaving the 

transuranic wastes in place at the three sites, even with additional controls 

to limit intrusion, may not adequately prevent the buried contaminants 

from spreading to the environment in the long term. How much, if any, 

buried transuranic wastes will eventually be removed from these sites is 

undetermined, and final decisions are years away. 

Page 4 GAO-07-761 DOE Disposition of Transuranic Wastes
DOE’s preliminary estimate of the cost to address the five waste sites 

where transuranic wastes are buried is about $1.6 billion (in fiscal year 

2006 dollars), but this estimate will likely increase substantially for two 

principal reasons. First, DOE’s estimate reflects the costs of leaving most 

of the waste in place under engineered barriers, as DOE is doing at 

Savannah River and Oak Ridge. This is typically the least expensive 

approach for addressing buried waste. However, if DOE is required by 

EPA or state environmental agencies to remove substantial portions of 

these wastes, costs are likely to increase dramatically. For example, at 

Idaho, where DOE and the state disagree over the extent to which DOE 

must remove buried transuranic wastes, preliminary DOE cost estimate 

indicates that removing all of the transuranic wastes would increase costs 

from about $1 billion to about $8.2 billion. Second, DOE’s estimate 

excludes unknown costs, such as the cost of disposing wastes off-site, if 

necessary. For example, some wastes scheduled for exhumation may not 

meet the waste acceptance criteria established for on-site disposal 

facilities and may have to be packaged and transported elsewhere, which 

would increase costs. According to DOE’s Inspector General, the $113 

million estimate to remove transuranic wastes buried near the Columbia 

River at Hanford could triple once options and costs for disposal are fully 

evaluated. As DOE moves these projects forward and further evaluates the 

risks, benefits, and costs of various cleanup options, its project 

management policies require it to revise these cost estimates to improve 

their reliability. Thus, we are not making recommendations at this time. 

We provided a draft of this report to DOE for its review and comment. 

Overall, DOE generally agreed with our findings. However, with regard to

the volume of transuranic wastes intended for disposal at WIPP, DOE 

stated that it regularly adjusts its forecasts and does not currently project 

that waste volumes will exceed WIPP capacity. While we agree that DOE’s 

current projections do not indicate WIPP capacity will fall short of future 

requirements, cleanup decisions are still pending at the Hanford Site and 

the Idaho National Laboratory, which together comprise the bulk of DOE’s 

total inventory of buried transuranic wastes. If substantial portions of the 

transuranic wastes at these sites must be exhumed and disposed of offsite, WIPP’s authorized capacity may be insufficient. DOE also provided 

technical clarifications, which we have incorporated in this report as 

appropriate.

DOE’s current and former nuclear weapons complex includes dozens of 

sites nationwide containing nuclear reactors, chemical processing 

buildings, plants, laboratories, and maintenance facilities that

Background 

Page 5 GAO-07-761 DOE Disposition of Transuranic Wastes
manufactured thousands of nuclear warheads and together conducted 

more than one thousand nuclear explosion tests. The environmental 

legacy of nuclear weapons production includes contaminated buildings, 

soils, water resources, and large volumes of radioactive and hazardous 

wastes that require treatment, stabilization to prevent migration, and 

disposal. DOE estimated in 2006, that the future cost to clean up, dispose, 

and provide long-term oversight of all wastes will be more than $230 

billion over the next 75 years. 

Among the sites requiring environmental cleanup are the five sites 

addressed in this report. The Hanford Site is located on the arid east side 

of Washington state near Richland and adjacent to the Columbia River. 

The site was established to produce plutonium for nuclear weapons during 

World War II and, according to DOE, subsequently produced the majority 

of the nation’s plutonium during the Cold War. The Idaho National 

Laboratory, located near Idaho Falls in the southeastern Idaho desert, was 

established in 1949 as the National Reactor Testing Station and was the 

site of the largest concentration of nuclear reactors—52—in the world. 

Los Alamos National Laboratory, located in a mountainous area of 

northern New Mexico, was established in 1943 and played a central role in

researching the advanced technologies required for nuclear weapons 

manufacture. It is where the first atomic bomb was assembled. The Oak 

Ridge National Laboratory near Knoxville, Tenn., was established in 1943 

to pilot the processing of uranium during World War II. The Savannah 

River Site, near Aiken, S.C., was built in the 1950s to produce basic 

materials needed in nuclear weapons manufacture, such as tritium and 

plutonium. 

DOE’s Office of Environmental Management is responsible for cleaning up 

contamination left behind at these sites after decades of nuclear 

production and research. Environmental management officials at DOE 

field sites plan and oversee the cleanup activities at those sites, but the 

work itself is carried out primarily by private firms contracted by DOE. 

Officials from EPA, as well as environmental agency officials from the 

states in which DOE sites are located, enforce federal and state 

environmental laws and oversee and advise DOE on its cleanup efforts. 

Transuranic elements, which have an atomic weight greater than uranium, 

are man-made radioactive elements produced in nuclear reactors. 

Transuranic wastes are created when materials such as clothing and tools 

come into contact with plutonium and other transuranic elements during 

processing activities and cannot be reused for other purposes. They were 

first generated during operations to produce and recover plutonium for 

Page 6 GAO-07-761 DOE Disposition of Transuranic Wastes
nuclear weapons manufacture and are still being produced in small 

quantities at laboratories where nuclear research continues today. Federal 

law currently defines transuranic waste as waste containing more than 100 

nanocuries of alpha-emitting transuranic elements (radiation) per gram 

and with half-lives greater than 20 years with certain exceptions.3

 A halflife is the amount of time required for an element to decay by half, and 

nanocuries are a measure of radioactivity. Alpha-emitting radiation cannot

pass through objects, including human skin, but is extremely dangerous if

inhaled or ingested. Some buried wastes contaminated with transuranic 

elements may not meet the current legal definition of transuranic wastes. 

For ease of discussion in this report, however, we refer to these wastes as 

buried transuranic wastes. 

The cleanup agreements DOE entered into with federal and state 

environmental agencies require DOE to investigate and take action as 

necessary to clean up sites where transuranic and other wastes were 

buried. The legal and regulatory framework governing management and 

disposal of transuranic wastes has changed significantly over the past 50

years, particularly in 1970. Before 1970, there was no separate category for 

what is now defined as transuranic waste. Consequently, the federal 

government managed this waste as low-level radioactive waste, which it 

buried along with hazardous wastes in unlined, shallow pits and trenches,

as shown in figure 1. 

Cleanup Agreements 

Require DOE to 

Address Sites Where 

Transuranic Wastes 

Are Buried 

 3

The definition of transuranic waste specifically excludes (1) high-level radioactive waste; 

(2) waste that DOE has determined with the concurrence of EPA, does not need the degree

of isolation required by the disposal regulations; or (3) waste that the Nuclear Regulatory 

Commission has approved for disposal on a case by case basis in accordance with 10 

C.F.R. part 61. See Waste Isolation Pilot Plant Land Withdrawal Act, Pub. L.No. 102-579, § 

2(20), 106 Stat. 4777-79 (1992). 

Page 7 GAO-07-761 DOE Disposition of Transuranic Wastes
Figure 1: Typical Disposal of Transuranic and Other Wastes in Unlined Trench at 

the Hanford Site Prior to 1970 

Source: DOE.

In 1970, in response to concerns that transuranic elements remain 

radioactive for an extremely long time and scientific research 

recommending deep geologic disposal for this waste, the Atomic Energy 

Commission––a DOE predecessor––directed sites that generated 

transuranic wastes to begin segregating them from other wastes and 

storing them in retrievable packages for an interim period of 20 years, 

pending disposal in a repository.4

 In late 1979, Congress authorized DOE to 

develop a deep geologic repository in New Mexico to permanently dispose 

of transuranic wastes, including these stored transuranic wastes.5

 In 

October 1992, Congress gave DOE management responsibility for the land,

 4

U.S. Atomic Energy Commission, Immediate Action Directive, IAD No. 0511-21, March 20, 

1970. 

5

Department of Energy National Security and Military Applications of Nuclear Energy 

Authorization Act of 1980, Pub. L. No. 96-164, 93 Stat. 1259, 1265 (1979). 

Page 8 GAO-07-761 DOE Disposition of Transuranic Wastes
and gave EPA substantial responsibility for regulating many of DOE’s 

activities at the repository.6

 This repository, known as the Waste Isolation 

Pilot Plant (WIPP), began operating in the late 1990s and, in 1999, received

its first shipment of transuranic wastes generated after the 1970 directive 

to segregate and store such wastes. 

The Atomic Energy Commission’s 1970 directive did not apply to 

transuranic wastes buried prior to 1970, and DOE considered these wastes 

permanently disposed. However, the sites where these wastes are buried 

have since become subject to CERCLA and other environmental laws. In 

particular, section 120 of CERCLA7

 requires EPA to evaluate federal waste 

sites for possible inclusion on the National Priorities List. In 1989, EPA 

included on this list, the waste sites that contain most of DOE’s buried 

transuranic wastes—Hanford, Idaho, Oak Ridge, and Savannah River.8

With this designation, CERCLA requires DOE to evaluate the nature and 

extent of contamination at these sites and determine what cleanup 

actions, if any, are necessary to protect human health and the 

environment. The buried transuranic waste sites at Los Alamos were 

evaluated but were not placed on the list. Cleanup of Los Alamos is being 

carried out under other authorities. At Los Alamos, the cleanup is being 

conducted under agreements with New Mexico—implementing the 

Resource Conservation and Recovery Act of 1976, as amended (RCRA) 

and state law—and under DOE’s Atomic Energy Act authority. The 

provisions of the Los Alamos cleanup agreements are similar to those 

under CERCLA requirements, including a schedule for conducting the 

cleanup. Los Alamos has multiple waste sites that contain buried 

transuranic wastes, and DOE’s agreements with the state of New Mexico 

address each waste area separately.

To carry out the cleanup of its National Priorities List sites under 

CERLCA, DOE must follow a process that includes extensive consultation 

between DOE, EPA, and state environmental agencies, as well as 

opportunities for public participation, to reach a decision on how DOE 

should clean up the respective site. The process begins with DOE 

consulting EPA and state environmental agencies and investigating the 

 6

Waste Isolation Pilot Plant Land Withdrawal Act, Pub. L. No. 102-579, 106 Stat. 4777 

(1992), as amended by the Waste Isolation Pilot Plant Land Withdrawal Amendment Act,

Pub. L. No. 104-201, 110 Stat. 2851 (1996). 

7

42 U.S.C. § 9620. 

8

See 54 Fed. Reg. 48184 (Nov. 21, 1989). 

Page 9 GAO-07-761 DOE Disposition of Transuranic Wastes
nature and extent of contamination at each site and undertaking a 

feasibility study to identify and evaluate possible approaches for cleaning 

up each site. After evaluating the approaches, DOE selects a “preferred 

alternative” that meets CERCLA requirements and presents, for public 

comment, a proposed plan explaining its preferred approach for cleaning 

up the wastes. DOE considers the public’s comments and consults with 

EPA and the state environmental agency to determine a cleanup approach. 

Once the parties have reached agreement, the approach and the rationale

for selecting it are published in a legally binding Record of Decision. In 

addition, DOE must enter into an interagency agreement with EPA that 

includes, among other things, a schedule for completing cleanup of the 

site. The environmental agency in the affected state is also a party to the 

agreements for Hanford, Idaho, Oak Ridge, and Savannah River. If the 

selected cleanup approach will involve leaving hazardous substances at 

the site, DOE must monitor the effectiveness of the approach and review 

the action every 5 years to determine whether any additional actions are

necessary to protect human health and the environment.9

 The provisions 

of the agreements, including the milestones, are legally enforceable and 

can be revised, as necessary, to incorporate new information and address 

changing conditions. As shown in table 1, DOE is currently scheduled to 

complete cleanup actions at all five sites by 2025. 

 9

CERCLA, § 121(c), 42 U.S.C. § 9621(c). Under Executive Order 12580, DOE is responsible 

for conducting 5-year reviews at DOE sites.

Page 10 GAO-07-761 DOE Disposition of Transuranic Wastes
Table 1: Interagency Agreement Schedule for Addressing DOE Sites Containing

Buried Transuranic Wastes 

Estimated 

volume of buried

transuranic 

waste

(in cubic 

meters)

Site 

investigation

completed

Alternatives

proposed 

Remedy 

selected

Remedial 

action

completed

Oak Ridge 

National 

Laboratorya

7,450 1997 1998 2000 2006

Savannah 

River Sitea

4,530 1994 2001 2002 2008

Los Alamos 

National 

Laboratoryb

11,800 2006 2007 2007 2015

Hanford Site 66,700 2011 2011 2013 2024

Idaho 

National 

Laboratory 36,800 2006 2007 2008 2025

Source: Data provided by DOE. 

a

For Oak Ridge and Savannah River, the dates for completing site investigation, proposing 

alternatives, selecting a remedy and completing remediation are actual, rather than scheduled. In 

addition, the remedy implemented at Oak Ridge is considered interim, until a final cleanup decision—

expected in 2015—is reached. The final cleanup decision could involve additional remedial action to 

address transuranic wastes buried there. 

b

The dates in the table represent the latest date by which Los Alamos is scheduled to complete 

cleanup of the final buried transuranic waste site, Material Disposal Area G. 

DOE has made cleanup decisions and is addressing transuranic wastes at 

Oak Ridge and Savannah River, but the department is still investigating 

cleanup options at the other three locations where most of DOE’s 

transuranic wastes are buried. DOE plans to leave transuranic wastes 

buried at Oak Ridge and Savannah River in place under an engineered 

barrier and take additional measures to prevent intrusions that could 

expose humans and the environment to the buried contaminants. In 

contrast, DOE is still evaluating cleanup options at the Idaho National 

Laboratory, Hanford Site and Los Alamos National Laboratory, where 

about 90 percent of its buried transuranic wastes are located. The extent 

to which DOE will be required to retrieve buried wastes or will be allowed

to manage these wastes in place is currently unknown, and cleanup 

decisions for the majority of these wastes are several years away. 

However, DOE has agreed to retrieve some of the wastes buried at 

DOE Is Containing 

Buried Transuranic 

Wastes in Place at 

Two Sites but Is Still 

Developing Cleanup 

Plans at the Largest 

Waste Sites 

Page 11 GAO-07-761 DOE Disposition of Transuranic Wastes
Hanford and Idaho, because the wastes may threaten nearby surface 

waters and groundwater. 

Cleanup Agreements at 

Oak Ridge and Savannah 

River Call for Containing 

Buried Transuranic Wastes 

in Place 

In accordance with CERCLA’s requirements, DOE evaluated a number of 

approaches for addressing transuranic wastes buried at Oak Ridge and 

Savannah River. At both sites, DOE had originally disposed of the wastes 

in near-surface burial pits and trenches, often with other radioactive or 

hazardous wastes, including cesium, strontium, and volatile organic 

compounds. The two sites contain about 10 percent of the estimated 

127,000 cubic meters of transuranic wastes buried across the five DOE 

sites. DOE officials at both sites considered several cleanup options, 

ranging from managing the wastes in place to removing them from the 

ground and disposing of any exhumed transuranic wastes at WIPP. 

DOE, EPA, and state environmental agencies at both sites agreed that 

DOE should manage the buried wastes in place, because doing so would 

be equally or more protective of human health and the environment, and 

less costly than removing the wastes. Because DOE lacked adequate

information on the specific location, condition, or concentration of the 

wastes in the burial sites, DOE and environmental agency officials said 

they were concerned that workers attempting to remove buried wastes 

would expose themselves to harmful contaminants or release 

contaminants into the environment. DOE and environmental agency

officials told us that without adequate information on the location, 

condition or concentration of the wastes, efforts to mitigate the risks 

associated with retrieving the wastes would have been costly, requiring 

specialized enclosures for the waste areas, protective suits for workers, 

frequent rotation of workers to minimize their potential exposure, or other 

measures. According to these officials, attempts to determine the specific 

locations and other characteristics of the buried contaminants would 

likely expose workers and the environment to these same risks, because

workers would be required to dig into the burial grounds in order to 

sample buried wastes. Furthermore, the officials were concerned that 

sampling buried wastes would not yield reliable information. 

As a result, DOE, EPA, and state environmental agencies at the two sites 

agreed that DOE should manage the wastes in place by constructing 

engineered barriers over the top of the burial grounds and implementing 

additional controls to limit access to the burial grounds and help ensure 

the barriers’ effectiveness. The barriers’ overall purpose is to prevent 

rainwater, animals, or other intrusions from entering the burial ground and 

potentially causing wastes to migrate into the air, groundwater, or nearby

surface waters. Barriers are generally composed of multiple layers of 

Page 12 GAO-07-761 DOE Disposition of Transuranic Wastes
earthen and synthetic materials (see fig. 2), depending on the site-specific 

conditions. Surface vegetation and soil function to absorb moisture, 

promote evaporation, and prevent water from filtering down to the wastes 

beneath the barrier. A diversion ditch carries surface water away from the 

waste site. Layers of rock, clay, and synthetic fabrics redirect moisture 

away from the buried wastes—and protect the wastes from burrowing 

animals. 

Figure 2. Example of an Engineered Barrier Constructed over a Burial Ground

Containing Radioactive or Hazardous Wastes

Bedrock 

Groundwater 

Soil 

Source: DOE. 

Vegetation 

Rock 

Synthetic fabric 

Outslope (3-8%) 

Clay layer 

Diversion ditch 

Buried waste 

Note: This figure depicts a barrier intended to remediate a waste site in a wet climate. Barriers 

constructed at arid sites may differ. 

DOE finished constructing the engineered barriers at Oak Ridge in 

September 2006 and expects to complete construction at Savannah River

by summer 2007 (see fig. 3). The Oak Ridge barriers are considered an 

interim measure under CERCLA, in part because DOE and the state are 

still assessing the conditions under which long-lived radioactive wastes, 

including transuranic wastes, should be permanently disposed of in-place. 

DOE officials at Oak Ridge said they expect a final cleanup decision by 

2015, at which time additional remedial actions to address the buried 

transuranic wastes could be required. 

In addition to the barriers, DOE plans to establish physical and long-term 

administrative controls at the two sites aimed at limiting access to areas 

where buried wastes were left in place. For example, DOE plans to install 

perimeter fencing and gates at both sites and restrict activities to 

maintenance of the engineered barriers. DOE also plans to prohibit certain

Page 13 GAO-07-761 DOE Disposition of Transuranic Wastes
types of land uses in these areas, such as residential use. It will transfer 

land-use restrictions at Savannah River to any future occupants, should 

the federal government decide to sell or lease land that includes the burial 

grounds. Furthermore, DOE officials from both sites will evaluate and 

repair the cap, as needed, and provide physical controls or sampling of the 

groundwater or surface waters in these areas for evidence of 

contamination. DOE conducts formal reviews of the barriers and related 

controls every 5 years. If EPA determines the measures are not fully 

effective, DOE may be required to take further actions, including removing 

some or all of the buried wastes. 

Page 14 GAO-07-761 DOE Disposition of Transuranic Wastes
Figure 3: Aerial View of an Engineered Barrier under Construction at Oak Ridge 

Source: DOE.

Page 15 GAO-07-761 DOE Disposition of Transuranic Wastes
DOE is still evaluating cleanup options for most of the waste at the three 

remaining sites––the Hanford Site, the Idaho National Laboratory, and the 

Los Alamos National Laboratory––where about 90 percent of DOE’s 

transuranic wastes are buried. 

The Hanford Site contains about 66,700 cubic meters of buried transuranic 

wastes, or about 53 percent of DOE’s total inventory of such wastes. These 

wastes were primarily disposed of in trenches in a 272-acre area located in

the central portion of the site and near the Columbia River. DOE is in the 

early stages of site investigations to determine the extent and type of 

contamination for most of its burial sites, and according to DOE, the 

department is scheduled to evaluate cleanup options and determine its 

preferred cleanup approach by 2013. However, DOE officials said that 

about 1,100 of the estimated 66,700 cubic meters of buried transuranic 

wastes are located in another area of the Hanford site closer to the 

Columbia River than other sites. In 2001, DOE agreed to remove the 

transuranic wastes buried in this area, as part of an interim effort to 

mitigate a plume of tritium, a radioactive (but not transuranic) 

contaminant that is migrating and could contaminate the Columbia River. 

Cleanup is scheduled for completion by 2012. Overall, although a cleanup 

decision for most of Hanford’s buried transuranic wastes is years away, 

EPA and Washington state environmental officials have expressed 

concern that leaving much of the buried transuranic and other hazardous 

wastes in place under engineered barriers––even with additional controls

to limit intrusion––may not provide adequate long-term protection for 

human health and the environment, and some removal of these wastes 

may be necessary. Citizen groups, such as the Hanford Advisory Council 

expressed similar concerns regarding the risks of leaving long-lived 

radioactive wastes, such as transuranic wastes, in place. 

The Idaho National Laboratory contains about 36,800 cubic meters of 

buried transuranic wastes, or about 29 percent of DOE’s inventory of such 

wastes. DOE officials at the Idaho site have prepared a draft feasibility 

study identifying possible alternatives for cleaning up the subsurface 

disposal area—a 97-acre area where transuranic, as well as other 

radioactive and hazardous wastes, are buried—which the department 

submitted to EPA and state environmental officials for review in March 

2007. The alternatives described in the draft study ranged from containing 

most of the buried wastes in place under an engineered barrier to 

DOE Is Still Developing 

Cleanup Plans at the Three 

Locations Where Most 

Transuranic Wastes Are 

Buried, but Some Waste 

Removal Is Already Under 

Way 

Hanford Site 

Idaho National Laboratory

Page 16 GAO-07-761 DOE Disposition of Transuranic Wastes
retrieving some or all of the wastes and permanently disposing of the 

transuranic portion at WIPP. DOE, EPA, and the state environmental 

agency are scheduled to document the selected cleanup approach in a 

record of decision by 2008. In 2005, DOE began removing some 

transuranic and other wastes buried in a 3-acre section of the 97-acre 

disposal area. DOE agreed to remove the wastes to prevent the 

contaminants from migrating to the Snake River aquifer, a drinking water 

source located about 580 feet below the disposal area. 

Although a cleanup approach has not yet been determined for most of the 

97-acre disposal area, DOE may be required to remove a significant 

portion of the buried transuranic wastes that remain. DOE and Idaho state 

officials have a long-standing disagreement regarding the amount of 

transuranic wastes that DOE had agreed to remove from the Idaho site 

under a 1995 settlement agreement with the state, in a case concerning 

shipments of spent nuclear fuel into Idaho. The state of Idaho

subsequently sought to enforce terms of the agreement in court, and in 

2006, a federal district court ruled that DOE is obligated under the 

agreement to remove all the transuranic wastes at the Idaho National 

Laboratory site.10 DOE has appealed the district court’s decision,11 but, in 

accordance with CERCLA requirements and the cleanup agreement for the 

site, the department is continuing to work with EPA and the state 

environmental agency to decide on a cleanup approach for most of the 

wastes buried at the site.

Los Alamos National Laboratory has about 12,000 cubic meters of buried 

transuranic wastes, or almost 10 percent of DOE’s inventory of such 

wastes. These wastes, which also include hazardous wastes, such as 

volatile organic compounds, according to DOE, are in four disposal areas 

that comprise about 85 acres of the Los Alamos site. DOE is currently 

conducting site investigations to determine the extent and nature of 

Los Alamos National 

Laboratory 

 10Public Service Company of Colorado v. Kempthorne, CV 91-035-S-EJL (D. Idaho, May 25, 

2006). The court stated that unless something is encountered that would prohibit its 

removal, the 1995 agreement obligates the United States to remove all transuranic wastes, 

with the buried transuranic waste being on a time schedule dictated by CERCLA and the 

Federal Facility Agreement and Compliance Order. The court further stated that should 

EPA ultimately conclude that removal of certain waste is too dangerous and Idaho 

disagrees, the court would necessarily have to resolve that dispute and retained jurisdiction 

to do so. 

11United States v. Andrus, No. 06-35661 (9th Cir. filed July 24, 2006). 

Page 17 GAO-07-761 DOE Disposition of Transuranic Wastes
contamination at the disposal areas and plans to evaluate cleanup options

for those areas. 

Unlike the other four DOE sites containing buried transuranic wastes, Los 

Alamos was not included on the National Priorities List and, therefore, 

transuranic wastes buried there are not being addressed through the 

CERCLA process. Instead, cleanup of the buried waste sites is being 

carried out under a combination of other federal and state environmental 

laws and internal DOE orders. 

Hazardous wastes buried at Los Alamos are being addressed through 

RCRA. RCRA requires owners and operators of facilities that treat, store, 

or dispose of hazardous wastes to obtain a permit from EPA, or an 

authorized state, specifying how the facilities will safely manage that 

waste. RCRA further authorizes EPA (or an authorized state) to require

facilities holding or seeking permits to clean up contamination at those 

facilities. As provided under RCRA, EPA has authorized New Mexico to 

carry out a RCRA hazardous waste program under state law in lieu of the 

federal program. The cleanup process under the RCRA program is 

generally similar to CERCLA, including an investigation of contaminated

areas and evaluation of cleanup options to select a cleanup approach. 

DOE will address radioactive wastes, which have been commingled with 

hazardous wastes at Los Alamos, under provisions of the Atomic Energy 

Act of 1954, as amended, which allows DOE to direct the process of 

investigating and cleaning up radioactive contamination according to its 

own regulations and internal directives. DOE has an agreement with the 

state environmental agency that it would investigate its buried waste sites 

containing transuranic wastes by 2006 and complete any cleanup actions 

by 2015.12

 12Radionuclides are regulated under DOE Order 5400.5, Radiation Protection of the Public

and the Environment, and DOE Order 435.1, Radioactive Waste Management. 

Page 18 GAO-07-761 DOE Disposition of Transuranic Wastes
DOE’s preliminary cost estimates for addressing the five waste sites where 

transuranic and other hazardous wastes have been buried total about $1.6 

billion (in fiscal year 2006 dollars). Because these wastes are commingled, 

the cost of addressing just the buried transuranic wastes cannot be 

separately determined. DOE’s estimates are based on the costs of 

managing most of these wastes in place rather than removing them for offsite disposal. However, DOE cautions these estimates are preliminary and 

not entirely reliable because some wastes may need to be retrieved and

disposed of off-site, which would increase costs substantially. In addition, 

some costs are not included because they are not yet known. As DOE 

moves these projects forward to further evaluate its various cleanup 

options, DOE’s policies require it to revise cost estimates, accordingly. 

DOE has not separately estimated the costs to address only buried 

transuranic wastes, but estimates that the costs to address the burial 

grounds in which transuranic and other hazardous wastes have been 

disposed are about $1.6 billion through 2035. The specific costs associated 

with addressing only transuranic wastes cannot be determined because 

DOE’s Office of Environmental Management, which is charged with 

cleaning up the disposal areas that include transuranic wastes, defines 

cleanup projects by geographic waste disposal areas, rather than by 

contaminant types. This is because many types of wastes and 

contaminants were disposed together in a specific geographic area; and in 

general, the Office of Environmental Management intends to address 

various wastes buried in each geographic disposal area as a group. The 

estimates to address the burial grounds reflect the “lifecycle” of each 

project—that is the total estimated expenditures for all aspects of 

managing a cleanup project from start to finish. These cost estimates are 

reported in DOE’s annual budget request to the Congress and comprise a 

portion of DOE’s environmental liabilities estimate included in its annual 

financial statement. 

Estimated Costs to 

Address Waste 

Disposal Areas in 

Which Transuranic 

Wastes Are Buried 

Will Likely Increase 

DOE Has Developed Cost 

Estimates to Address 

Geographic Areas 

Containing Transuranic 

and Other Waste 

As shown in table 2, DOE’s estimated lifecycle baseline costs to address 

the burial grounds containing transuranic wastes range from $36 million at 

the Savannah River Site—where officials are in the final stages of 

completing construction of a cap to contain the wastes—to $1 billion at 

the Idaho National Laboratory, where DOE has begun to remove selected

wastes for disposal off-site, but is still evaluating options to address most 

of the remaining buried waste. 

Page 19 GAO-07-761 DOE Disposition of Transuranic Wastes
Table 2: Summary of DOE Estimated Lifecycle Costs to Address Disposal Areas Containing Buried Transuranic and Other 

Hazardous Wastes

In constant 2006 dollars 

Location 

Total waste 

disposal area 

containing

transuranic 

wastes (in

acres) 

Estimated total 

lifecycle cost to

address disposal 

areas containing

transuranic wastes

(in millions of 

dollars)a

Remedy assumed by

DOE for cost estimation

purposes 

Year cleanup 

action will be

completed

Estimated percent 

of total transuranic 

waste volume

buried at each

location

Oak Ridge 

Laboratory, Oak 

Ridge, TN

140 $90.3bSurface cap and land use 

controls 

2006 6

Savannah River 

Site, Aiken, SC

76 36.1 Surface cap and

institutional controls 

2008 4

Idaho National 

Laboratory, Idaho 

Falls, ID 

97c1,027.4 Retrieval of hazardous 

and radioactive wastes 

from targeted 3-acre area, 

surface cap, organic 

vapor extraction, 

institutional controls 

2025 29

Hanford Site, 

Richland, WA

272 320dRetrieval of some wastes 

from targeted 13-acre 

area, surface capping, 

and institutional controls 

2035d52

Los Alamos 

National Laboratory, 

Los Alamos, NM 

85 113.9 Surface cap designed for 

arid conditions and 

institutional controls 

2015 9

Total 670 $1,587.7 100

Source: Data provided by DOE. 

a

Costs largely exclude those associated with long-term oversight of the waste site, which are costs 

that will be assumed by the long-term steward, rather than the Office of Environmental Management. 

Such costs are included, however, as part of the DOE estimate for environmental liabilities reported 

to the Congress, and elsewhere. See A Report to Congress on Long-Term Stewardship, DOE/EM0563, January 2001. 

b

Cleanup has been completed at an actual cost of $90.3 million. 

c

Only 17 acres of the 97-acre burial site at Idaho is suspected of containing transuranic wastes. 

d

Cleanup is scheduled to be completed before 2025. This date is when the Office of Environmental 

Management will transfer final control of the property to the long-term steward. Cost estimate includes

maintenance and monitoring of the buried waste sites until 2035. 

Page 20 GAO-07-761 DOE Disposition of Transuranic Wastes
DOE’s lifecycle cost estimates for addressing buried waste sites are 

preliminary because DOE is still evaluating and choosing cleanup options 

for the majority of its buried waste, and some of the probable costs 

associated with cleanup efforts are currently unknown. DOE has stated 

that it is only 50 percent confident that its lifecycle estimates accurately

reflect the costs of addressing buried waste sites. DOE’s estimates will 

likely increase, perhaps substantially, for several reasons. 

Cost Estimates Are 

Preliminary and Likely 

Understate the Actual Cost 

of Addressing Buried 

Wastes

First, the estimates are based upon treatment and remedy assumptions 

that may be different from the final cleanup decision. The estimates are 

based on DOE’s assumption that it will manage most of the buried wastes 

in place under engineered barriers and will monitor these barriers’ 

effectiveness for as long as necessary to ensure protection of human 

health and the environment. This is typically the lowest-cost approach for 

addressing buried waste. DOE cost estimates are preliminary until an 

actual cleanup decision has been reached, at which time the cost estimates 

are revised to reflect that decision. If DOE is required to retrieve 

substantial portions of the buried transuranic wastes and dispose of it offsite at WIPP or elsewhere, costs could increase dramatically. For example 

if DOE must retrieve all the buried transuranic from the Idaho National 

Laboratory site, the department estimates that costs would increase from 

about $1 billion to about $8.2 billion. According to DOE, the substantially 

higher costs are the result of activities to excavate wastes and the 

associated construction and operation of new facilities to treat and 

dispose of formerly buried wastes and new wastes created by the retrieval 

process. 

Second, the authorized capacity of the WIPP is currently insufficient to 

allow emplacement of large volumes of buried transuranic wastes beyond 

those being exhumed at the Idaho site. Specifically, WIPP is statutorily 

authorized to receive a maximum of 175,600 cubic meters of transuranic 

wastes. The majority of that capacity has been reserved for about 108,000

cubic meters of transuranic wastes that were generated and placed in

storage at various DOE sites after 1970 and had not yet been emplaced at 

WIPP as of 2002, the most recent year for which data are available. About 

8,000 cubic meters of waste had already been emplaced at WIPP by 2002. 

Wastes DOE has agreed to exhume from the Idaho National Laboratory 

are expected to consume another 17,000 cubic meters of WIPP capacity. In

addition, DOE expects to generate about 17,000 cubic meters of additional

transuranic wastes from future nuclear research and waste cleanup 

activities, and these wastes also are intended for disposal at WIPP. In total, 

DOE estimates that stored wastes, newly generated wastes and the wastes 

being exhumed currently at Idaho together will consume about 150,000 

Page 21 GAO-07-761 DOE Disposition of Transuranic Wastes
cubic meters of WIPP’s authorized capacity, leaving only about 25,600 

cubic meters for disposal of other transuranic wastes. DOE has estimated 

that if current plans to manage most wastes in place change and buried 

transuranic wastes across the weapons complex must be exhumed and

disposed of off-site, up to 85,000 additional cubic meters could potentially 

require disposal at the WIPP. Developing alternative disposal paths for the 

estimated 60,000 cubic meters of transuranic wastes exceeding current 

WIPP capacity could further increase costs. 

Third, other assumptions DOE has incorporated into its cost estimates 

may also be incorrect, causing DOE’s cost estimates to increase. For 

example, DOE’s preliminary cost estimates assume that installing a barrier 

over one of the Los Alamos burial grounds will safely contain buried 

wastes. However, DOE reports that if further analysis shows this 

assumption is incorrect and a more complex solution, such as grouting or 

vitrification is required, then cost estimates would increase significantly. 

Grouting is a process that uses concrete to bind wastes together and 

impede their migration through soil. Vitrification immobilizes the wastes in 

glass. At two other locations, DOE has assumed that federal and state 

regulators will not require further characterization or excavation. 

However, if additional characterization is required, DOE reports that costs 

could increase. 

Finally, DOE has not included in its estimate some probable cost amounts 

that are currently unknown. For example, at DOE’s Hanford site, highly 

radioactive and hazardous wastes were buried under 10 to15 feet of earth

in vertical pipes and other containers at a site that is near the Columbia 

River. DOE has reported that the lifecycle cost to remove these wastes is 

about $113 million. However, according to DOE’s Inspector General, this 

estimate does not include all potential costs to store, monitor, and dispose 

of this waste once it has been removed, which could increase the cost to 

more than $300 million.13 According to DOE officials, DOE had not yet 

evaluated methods for retrieving and disposing of the waste and, as a 

result, the costs for these actions were unknown. In addition, both 

Hanford and the Idaho National Laboratory lifecycle cost estimates 

exclude administrative costs and management fees that will eventually be

negotiated with the private firms contracted to manage the cleanup effort. 

 13U.S. Department of Energy, Office of Inspector General, Remediation of the Waste Burial 

Grounds at the Hanford Site, Washington, D.C.: October 2006; DOE/IG-0743. 

Page 22 GAO-07-761 DOE Disposition of Transuranic Wastes
Since contracts have not yet been awarded for much of the buried waste 

cleanup, those costs have yet to be determined. 

As DOE moves forward to further evaluate the risks, benefits, and costs of 

various buried waste cleanup options, DOE’s cost estimating and project 

management policies expect staff to refine the estimates.14According to 

DOE guidance, the cost uncertainty is greatest during the period that site 

investigations and evaluations of cleanup options are being conducted. 

Typically, DOE includes what it calls an “unfunded contingency” in its 

lifecycle estimates to account for unanticipated future events, but officials 

said they do not include the contingency at a project level that includes 

buried waste cleanup estimates. DOE expects cost estimates to become 

somewhat more accurate during the design phase of a project and to 

become substantially more accurate once a cleanup remedy has been 

chosen and construction has been authorized. 

We provided a draft of this report to the DOE for its review and comment. 

In its comments, the department generally agreed with our report. The 

department agreed that uncertainties surround the disposition of buried

transuranic wastes and that the volume of such wastes intended for WIPP

could increase. However, the department stated that EPA’s recertification 

process for WIPP, which occurs every 5 years, includes a forecast of waste 

disposal volumes and that current projections do not indicate insufficient 

WIPP capacity. The department further stated that it is prepared to 

manage the uncertainties regarding the future disposition of these wastes. 

While we agree that current projections do not indicate WIPP capacity will 

fall short of future requirements, at the time of our review, cleanup 

decisions were still pending at the Hanford Site and the Idaho National 

Laboratory. These two sites comprise over 80 percent of DOE’s total 

estimated inventory of buried transuranic wastes and it is unclear how 

much of these buried wastes ultimately must be exhumed. As we stated in 

our report, if substantial volumes of the transuranic wastes at these sites 

must be exhumed and disposed of off-site, WIPP’s authorized capacity 

could be inadequate. 

Agency Comments 

and Our Evaluation 

DOE provided additional technical comments, including clarifications on 

terminology and ongoing litigation at the Idaho National Laboratory. We 

 14DOE G 430.1-1, Cost Estimating Guide; DOE G 430.1-1X, Cost Estimating Guide for 

Program and Project Management. 

Page 23 GAO-07-761 DOE Disposition of Transuranic Wastes
incorporated these clarifications as appropriate. DOE’s comments are 

presented in appendix II.

We will send copies of this report to the Secretary of Energy, and we also 

will make copies available to others on request. In addition, the report will 

be available at no charge on the GAO Web site at http://www.gao.gov. 

If you, or your staff, have any questions about this report or need 

additional information, please contact me at (202) 512-3841 or 

cosgrovej@gao.gov. Contact points for our Office of Congressional 

Relations and Public Affairs can be found on the last page of this report. 

Other staff contributing to this report can be found in appendix III. 

James Cosgrove 

Acting Director, Natural Resources and Environment 

Page 24 GAO-07-761 DOE Disposition of Transuranic Wastes
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To conduct our work, we visited buried waste landfills and stored waste 

facilities, and we met with local Department of Energy (DOE) officials at 

each of DOE’s five largest transuranic waste burial sites––the Hanford 

Site, the Idaho National Laboratory, the Los Alamos National Laboratory, 

the Savannah River Site, and the Oak Ridge National Laboratory. We also 

reviewed studies and scientific reports by DOE and other federal agencies 

and the National Academy of Sciences on the storage and disposition of 

transuranic wastes, and interviewed experts in the field. 

To determine the extent to which legal requirements and policies govern 

DOE’s efforts to address buried transuranic wastes, we reviewed the 

Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980, as amended (CERCLA), the Resource Conservation and Recovery 

Act of 1976, as amended (RCRA), the Atomic Energy Act of 1954, as 

amended, and Environmental Protection Agency (EPA) and DOE 

regulations and guidance concerning radioactive and hazardous wastes. 

We also reviewed the Federal Facility Agreements and Orders between 

DOE, EPA, and each state with a site where DOE has buried transuranic 

wastes, as well as a May 2006 federal district court decision interpreting an

agreement between DOE and the state of Idaho concerning DOE’s 

obligation to remove buried transuranic wastes from the Idaho National 

Laboratory site. To better understand the implementation of these laws, 

regulations, policies, and agreements at DOE sites, we interviewed state 

environmental regulatory officials and EPA officials that oversee each of 

the buried waste locations. We did not interview EPA officials in New 

Mexico because EPA has authorized the state of New Mexico to carry out 

a state RCRA program under state law in lieu of the federal program. 

To determine how DOE plans to address buried waste at each of its sites, 

we reviewed the planning documents DOE has prepared to comply with 

CERCLA or RCRA requirements, feasibility studies describing remediation 

alternatives, records of decision for sites that have selected a remedy for 

buried waste, and internal DOE reports regarding buried transuranic 

wastes, and interviewed the project managers and engineers responsible 

for overseeing the remediation of each buried waste site. 

To determine DOE’s estimated costs for addressing disposal sites 

containing buried transuranic wastes and to evaluate the accuracy of 

those estimates, we analyzed each field location’s fiscal year 2006 lifecycle 

baseline estimates for specific projects that included cleaning up 

previously disposed transuranic wastes. Because DOE has generally 

defined cleanup projects by geographic waste disposal areas rather than 

by waste types, we were unable to determine the specific costs associated 

Page 25 GAO-07-761 DOE Disposition of Transuranic Wastes
Appendix I: Scope and Methodology 

DOE Disposition of Transuranic Wastes

with addressing only transuranic wastes. To better understand the 

lifecycle cost estimates, we reviewed DOE cost estimating and project 

management guidance and interviewed officials responsible for preparing 

and reporting cost estimates to DOE. All cost estimates in this report are 

in constant 2006 dollars.

In reporting the volumes of transuranic wastes buried at DOE sites, we 

relied on estimates made by DOE in 1999 and reported in 2000, the most 

recent available comprehensive inventory of such wastes.1

 In reporting the 

inventory of buried transuranic wastes, we included wastes buried at both 

shallow depths (less than 100 feet) and intermediate depths (between 100

and 1,000 feet). In addition, we adjusted the buried waste inventory 

reported for Los Alamos and Hanford because officials there had 

subsequently developed more accurate inventory data that showed a 

somewhat lower volume than had been reported in 2000. At other 

locations, DOE officials said they believed the 2000 report reflected the 

most accurate data available. With regard to the inventory of stored 

transuranic wastes reported in 2000, we used data from a 2001 DOE 

report.2

 Some of that waste has now been disposed of permanently at the 

Waste Isolation Pilot Plant (WIPP) in New Mexico. The inventory of the 

remaining volume of transuranic wastes currently in storage at DOE sites 

continues to change because of ongoing shipments to WIPP for permanent 

disposal and was not available from DOE. 

We performed our work between May 2006 and May 2007 in accordance 

with generally accepted government auditing standards. 

 1

Department of Energy, Buried Contaminated Transuranic Waste Information for U.S.

Department of Energy Facilities, June 2000. 

2

Department of Energy, Summary Data on the Radioactive Waste, Spent Nuclear Fuel

and Contaminated Media Managed by the U.S. Department of Energy, April 2001. 

Page 26 GAO-07-761
Appendix II: Comments from the Department Appendix II: Comments from the Department of Energy 

of Energy 

Page 27 GAO-07-761 DOE Disposition of Transuranic Wastes
Appendix III: Contac

A

t Information and Staff 

cknowledgments 

Page 28 GAO-07-761

Appendix III: Contact Information and Staff 

Acknowledgments 

James Cosgrove, (202) 512-3841 

Gene Aloise, (202) 512-3841 

In addition to the individuals named above, Bill Swick, Assistant Director; 

Doreen Feldman; Michael Meleady; Mehrzad Nadji; James Noel; Alison 

O’Neill; Jeff Rueckhaus; and Ginny Vanderlinde made key contributions to 

this report. 

DOE Disposition of Transuranic Wastes

GAO Contacts 

Staff 

Acknowledgments 

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Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

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