United States General Accounting Office 

GAO Testimony 

Before the Committee on Energy and 

Natural Resources, U.S. Senate 

For Release on Delivery 

Expected at 9:00 a.m. CST 

Saturday, December 6, 2003 	 NUCLEAR WASTE 

CLEANUP 

Preliminary Observations 

on DOE’s Cleanup of the 

Paducah Uranium 

Enrichment Plant 

Statement of Robin M. Nazzaro, Director 

Natural Resources and Environment 

GAO-04-278T 

Highlights of GAO-04-278T, testimony 

before the Committee on Energy and 

Natural Resources, U.S. Senate 

In 1988, radioactive contamination 

was found in the drinking water 

wells of residences located near 

the federal government’s uranium 

enrichment plant in Paducah, 

Kentucky, which is still in 

operation. In response, the 

Department of Energy (DOE) 

began a cleanup program to 

identify and remove contamination 

in the groundwater, surface water, 

and soil located within and outside 

the plant. In 2000, GAO reported 

that DOE faced significant 

challenges in cleaning up the site 

and that it was doubtful that the 

cleanup would be completed as 

scheduled by 2010, and within the 

$1.3 billion cost projection. 

GAO was asked to testify on (1) 

how much DOE has spent on the 

Paducah cleanup and for what 

purposes, and the estimated total 

future costs for the site; (2) the 

status of DOE’s cleanup effort; and 

(3) the challenges DOE faces in 

completing the cleanup. 

This testimony is based on ongoing 

work, and GAO expects to issue a 

final report on this work in April 

2004. 

December 6, 2003 

NUCLEAR WASTE CLEANUP 

Preliminary Observations on DOE’s 

Cleanup of the Paducah Uranium 

Enrichment Plant 

Since 1988, DOE has spent $823 million, adjusted to fiscal year 2002 constant 

dollars, on the Paducah cleanup program. Of this total, DOE spent $372 

million (45 percent) for a host of operations activities, including general 

maintenance and security; $298 million (36 percent) for actions to clean up 

contamination and waste; and almost $153 million (19 percent) for studies to 

assess the extent of contamination and determine what cleanup actions 

were needed. DOE currently projects that the cleanup will take until 2019 

and cost $2 billion to complete—nine years and $700 million more than its 

earlier projection. The $2 billion, however, does not include the cost of 

other DOE activities required to close the site after the uranium enrichment 

plant ceases operations, including final decontamination and 

decommissioning of the plant and long-term environmental monitoring. 

DOE estimates these activities will bring the total cost to over $13 billion 

through 2070. 

DOE has made some progress in cleaning up contamination and waste at 

Paducah, but the majority of the work remains to be done. For example, 

while DOE has removed over 4,500 tons of scrap metal, over 50,000 tons of 

contaminated scrap metal remain. Similarly, while DOE’s pilot test of a new 

technology for removing the hazardous chemical trichloroethylene (TCE) 

from groundwater at the site had promising results, the technology will not 

be fully implemented for over a year. 

DOE’s key challenge in completing the Paducah cleanup is achieving 

stakeholder agreement on the cleanup approach. For example, differences 

between DOE and the regulatory entities—the Commonwealth of Kentucky 

and the U.S. Environmental Protection Agency—over the cleanup scope and 

time frames resulted in an almost 2-year dispute, from June 2001 to April 

2003, that disrupted progress. All three parties are working to develop an 

accelerated cleanup plan, but continued cooperation will be required in 

order to advance the cleanup. 

Drum Mountain, 2,500 tons of crushed drums that once held depleted uranium, and the site 

after its removal in 2000. 

www.gao.gov/cgi-bin/getrpt?GAO-04-278T.


To view the full product, click on the link 


above. 


For more information, contact Robin Nazzaro 


at (202) 512-3841 or NazzaroR@gao.gov. 

Senator Bunning: 

We are pleased to be here today to discuss the Department of Energy’s 

(DOE) efforts to clean up contamination and waste at its Paducah, 

Kentucky, uranium enrichment plant. The plant, which continues to 

operate under a lease to a private company, the United States Enrichment 

Corporation (USEC), enriches uranium for commercial nuclear power 

plants. DOE began a cleanup program at the site in 1988, after 

contaminated groundwater was found in nearby residents’ drinking water 

wells, and contaminated surface water and soils were identified within and 

outside the site. In August 1999, in response to allegations that past plant 

activities had endangered employees’ health, DOE’s Office of Oversight 

conducted an independent investigation that identified improper disposal 

of hazardous and radioactive materials on- and off-site and the release of 

contaminated water into streams and drainage ditches.1

 In 2000, prompted 

by continuing congressional concerns, we reported that DOE faced 

significant challenges, such as obtaining stakeholder concurrence with its 

approach in cleaning up the Paducah site and that it was doubtful that the 

cleanup would be completed as scheduled by 2010 and within the $1.3 

billion cost projection.2

 Our statement today describes the preliminary 

results of our ongoing work, directed by the conference report for DOE’s 

2003 appropriations, on DOE’s cleanup efforts at the Paducah plant.3 

Specifically, we will discuss (1) how much DOE has spent on the cleanup 

program and for what purposes, and the estimated total future costs for 

the site; (2) the status of DOE efforts to clean up the contamination at the 

site; and (3) the challenges DOE faces in completing the cleanup. 

In summary: 

• 	 Since 1988, DOE has spent $823 million, adjusted to fiscal year 2002 

constant dollars, on the Paducah site. Of this total, DOE spent about 

$372 million (45 percent) to pay for operations at the site, including 

construction, security, general maintenance, and litigation; $298 million 

1

Department of Energy, Office of Oversight, Office of Environment, Safety, and Health, 

Phase I: Independent Investigation of the Paducah Gaseous Diffusion Plant (Washington, 

D.C., Oct. 1999). 

2

U.S. General Accounting Office, Nuclear Waste Cleanup: DOE’s Paducah Plan Faces 

Uncertainties and Excludes Costly Cleanup Activities, GAO/RCED-00-96 (Washington, 

D.C.: Apr. 28, 2000). 

3

H.R. Conf. Rep. No. 108-10, at 895 (2003). 

Page 1 GAO-04-278T 
(36 percent) on actions to clean up contamination and remove waste; 

and almost $153 million (19 percent) for studies to assess the extent of 

the contamination and determine what cleanup actions were 

necessary. Although DOE estimated in January 2000 that the cleanup 

would be complete by 2010 and cost $1.3 billion, DOE now estimates 

that completing the cleanup will take at least until 2019 and cost almost 

$2 billion. The $2 billion, however, does not include the cost of other 

DOE activities required to close the site, including final 

decontamination and decommissioning of the buildings, equipment, 

and materials used in the uranium enrichment process after operations 

cease at the plant, as well as long-term environmental monitoring at the 

site. Completing these activities will bring the total cost of closing the 

uranium enrichment plant to over $13 billion through 2070. 

• 	 DOE has made some progress in cleaning up contamination and waste 

at Paducah since 1988, but much of the work remains to be done. For 

example, DOE has removed over 4,500 tons of scrap metal, but over 

50,000 tons remain. Similarly, although DOE has tested a new 

technology for removing the hazardous chemical trichloroethylene 

(TCE) from groundwater at the site with promising results, the test 

removed only about 1 percent of the estimated amount of TCE, and the 

technology will not be fully implemented for over a year. DOE also 

plans to conduct a number of studies to determine if other cleanup 

actions, in addition to those already planned, are necessary. For 

example, DOE will test the groundwater near several areas where 

waste is buried to determine if contamination is leaking and, if so, what 

corrective action will be needed. 

• 	 DOE’s key challenge in completing the cleanup at Paducah is achieving 

stakeholder agreement on the cleanup approach, including scope and 

time frames. For almost 2 years, from June 2001 to April 2003, DOE and 

the regulators—the U.S. Environmental Protection Agency (EPA) and 

the Commonwealth of Kentucky—were unable to agree on cleanup 

scope and time frames, disrupting cleanup progress. DOE, EPA, and 

Kentucky are currently negotiating approval of an accelerated cleanup 

plan; however, the success of the plan will depend on the parties’ 

ability to agree on the scope and time frames for individual projects as 

the cleanup moves forward. In addition, DOE’s proposed plan is only 

the latest of several attempts to resolve problems at the site since 1999. 

Given the parties’ past difficulties in resolving disputes over cleanup 

scope and time frames, and the number of decisions that remain to be 

made, it is unclear whether DOE will be successful in accelerating the 

cleanup. 

Page 2 GAO-04-278T 
Background The Paducah uranium enrichment plant is located on about 3,500 acres in 

western Kentucky, about 3 miles south of the Ohio River and about 10 

miles west of the city of Paducah. The plant—formerly operated by DOE 

and now operated by USEC—enriches uranium for commercial nuclear 

power reactors. 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 TCE, which was used as 

a degreaser. 

Responsibility for management of the Paducah site is divided between two 

DOE offices. The Office of Environmental Management has overall 

responsibility for the site cleanup being performed by its contractor, 

Bechtel Jacobs. The Office of Nuclear Energy acts as the site’s landlord, 

with responsibilities for maintaining roads, grounds, and facilities not 

leased to USEC. 

EPA and Kentucky cooperate in regulating the cleanup under the federal 

facility agreement, which integrates the requirements of two federal 

environmental statutes governing the cleanup of the Paducah site—the 

Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980, as amended, and the Resource Conservation and Recovery Act of 

1976, as amended. Respectively, these statutes provide broad federal 

authority to respond directly to releases or threatened releases of 

hazardous substances that may endanger public health or the environment 

and to regulate the safe management and disposal of hazardous or other 

solid wastes. 

In addition to the federal facility agreement, DOE uses two other 

documents to manage the cleanup. The site management plan, which is a 

cleanup strategy document developed annually by DOE and subject to 

approval by EPA and Kentucky, includes timetables, deadlines, and 

projected activities for the cleanup. DOE uses the lifecycle baseline to 

manage the cleanup; it contains detailed information on cleanup projects, 

cost estimates, and time frames for completion and is updated frequently 

by DOE’s contractor to reflect the evolving nature of the cleanup process. 

DOE’s cleanup plan for the Paducah site divides the cleanup into seven 

major categories: 

• 	 Groundwater—About 10 billion gallons of groundwater are 

contaminated with radioactive and hazardous materials. 

Page 3 GAO-04-278T 
• 	 Surface water—Contaminated surface water has been discovered in 

creeks and ditches leaving the site. One of the main sources of this 

contamination is rain runoff from the thousands of tons of 

contaminated scrap metal stored at the site. 

• 	 Surface soils—Both on- and off-site soils and sediments have been 

contaminated by water runoff, spills, and buried waste. 

• 	 Legacy waste—Low-level radioactive or hazardous waste generated 

before 2001 remains stored in various locations at the site. 

• 	 DOE material storage areas—160 indoor and outdoor storage areas 

contain a variety of radioactive, hazardous, and other materials. These 

areas have been added to the cleanup scope since our 2000 report. 

• 	 Burial grounds—12 burial grounds contain a variety of waste, including 

barrels of materials with low levels of radioactivity and hazardous 

chemicals. 

• 	 Decontamination and decommissioning of 17 unused buildings and 

structures—These facilities were contaminated during earlier 

operations; 15 have been added to the cleanup scope since our 2000 

report. 

Page 4 GAO-04-278T 
DOE Has Spent $823 

Million on the 

Paducah Cleanup 

Program, and Billions 

More Will be Required 

for Final Site Closure 

From 1988 through 2003, DOE spent $823 million, adjusted to fiscal year 

2002 constant dollars, at the Paducah site. As figure 1 shows, $372 million 

(45 percent) was spent on operations at the site such as providing security, 

performing general maintenance, providing municipal water for nearby 

residents, maintaining almost 38,000 cylinders of depleted uranium 

hexafluoride,4

 constructing storage and other facilities, and carrying out 

activities related to litigation; $298 million (36 percent) was spent on 

cleanup actions, including waste removal and treatment; and $153 million 

(19 percent) was spent on studies to assess the contamination and 

determine what cleanup actions were necessary. These percentages are 

similar to those DOE’s Office of Environmental Management found for all 

of its cleanup programs: only about one-third of the environmental 

management program budget goes toward actual cleanup and risk 

reduction work, with the remainder going to maintenance, fixed costs, and 

miscellaneous activities, contributing to a lack of risk reduction and 

raising costs for DOE’s cleanups.5 

4

Uranium hexafluoride, a byproduct of the uranium enrichment process, must be handled 

in leakproof containers because when it comes into contact with water, such as water 

vapor in the air, it forms corrosive hydrogen fluoride and a uranium-fluoride compound 

called uranyl fluoride. 

5

Department of Energy, A Review of the Environmental Management Program 

(Washington, D.C., Feb. 4, 2002). 

Page 5 GAO-04-278T 
Figure 1: Expenditures at Paducah by Category, Fiscal Years 1988-2003 

Note: Total cleanup expenditures for fiscal years 1988-2003, adjusted to fiscal year 2002 dollars, 

were $823 million. The individual dollar figures noted above may not total $823 million because of 

rounding. 

DOE’s current estimate for completing the cleanup is almost $2 billion—a 

$700 million increase over its 2000 estimate—and the completion date has 

moved from 2010 to 2019. The cost increase is attributable to an expanded 

project scope as well as millions of dollars for site operations for each of 

the 9 additional years of cleanup. However, the cleanup estimate does not 

represent DOE’s total responsibilities at the site: In addition to the cleanup 

program, DOE will build and operate a facility to convert the depleted 

uranium hexafluoride stored at the site to a more stable form and carry 

Page 6 GAO-04-278T 
out final decontamination and decommissioning (D&D) of the uranium 

enrichment process buildings, equipment, and materials once USEC 

ceases plant operations. Furthermore, after the cleanup, D&D, and 

uranium hexafluoride conversion, DOE will continue to incur long-term 

stewardship costs at the site for such activities as monitoring groundwater 

and surface water for residual contamination. Completing these activities 

will bring the total cost of closing the uranium enrichment plant to over 

$13 billion through 2070. 

While DOE Has Made 

Some Progress, the 

Bulk of the Cleanup 

Remains 

Since 1988, DOE has made some progress in cleaning up the 

contamination and waste at Paducah, but much of the cleanup work 

remains to be done. Some of DOE’s accomplishments since our 2000 

report as well as tasks remaining follow: 

• 	 Groundwater—DOE has treated about 710 million gallons of 

groundwater to remove TCE and technetium-99 and prevent off-site 

contamination. DOE’s pilot test of technology for removing TCE 

sources—large concentrations of accumulated TCE—had promising 

results. However, the test removed only about 1 percent of the 

estimated 180,000 gallons of TCE that had leaked into the ground, and 

the system will not be fully implemented until at least 2005, according 

to DOE contractor officials.6

 The estimated completion date for 

removing TCE from the two major sources at the site is 2010. 

• 	 Surface water—To prevent contaminated runoff, DOE has removed 

about 4,500 tons of scrap metal from the site—primarily crushed drums 

that previously had contained uranium and aluminum ingots. An 

estimated 50,500 tons of scrap metal remains to be removed from the 

site. At the north-south diversion ditch, a key wastewater conduit from 

the plant, surface water discharges and runoff have been rerouted and 

piped to bypass contaminated areas, and DOE has begun excavation 

work to remove contaminated soil from the first of five sections of the 

ditch. DOE plans to complete excavation of sections one and two by 

2005. The estimated completion date for all surface water cleanup 

activities is 2017. 

6

According to DOE, this estimate is based on the assumptions that TCE was used at the site 

from 1953 to 1993 and that a fixed amount was released to the ground each day. A high 

degree of uncertainty surrounds this estimate, and the actual amount of TCE released 

cannot be verified. 

Page 7 GAO-04-278T 
• 	 Surface soils—DOE has assessed all surface soils at the site to identify 

radioactive contamination and protect plant workers. In addition, DOE 

has removed 2,500 cubic yards of contaminated soils—enough to cover 

a football field 17 inches deep. However, because soil contamination 

represents a lower risk for exposure and migration than, for example, 

groundwater, and because other work, such as removal of scrap metal, 

must be performed before some soils can be reached, this category is a 

lower priority. DOE estimates that a total of 90,000 cubic yards of soils 

will be removed and disposed by 2015. 

• 	 Legacy waste—DOE has performed initial characterization of all of this 

waste—the equivalent of 52,000 55-gallon barrels—for on-site storage, 

and disposed of over 7,000 barrels off-site. Another 6,000 have been 

repackaged and are ready for disposal. The remaining legacy waste— 

over 38,000 barrels—will be characterized and disposed of by 2010. 

• 	 DOE material storage areas (DMSA)—DOE has ranked the 160 DMSAs 

at the Paducah site on the basis of their potential to contain hazardous 

materials or contaminate the environment: 33 are high priority, 11 are 

medium priority, and 116 are low priority. DOE has characterized and 

removed materials from 9 high- and 15 low-priority DMSAs and has 

completed characterization of an additional 17 high-priority DMSAs. 

DOE still needs to remove materials from these 17 and characterize 

and remove materials in the remaining 119 DMSAs. According to DOE 

officials, only 0.01 percent of the materials characterized to date have 

been determined to be hazardous waste. DOE plans to complete 

characterization by the end of fiscal year 2009 and dispose of all 

materials from the DMSAs by 2013. 

• 	 Burial grounds—To date, DOE’s activities at the 12 burial grounds have 

consisted of studies and environmental monitoring and maintenance. 

Currently, DOE plans to cap—cover with a layer of soil—the burial 

grounds and monitor groundwater to evaluate the effectiveness of the 

caps. If the burial grounds are found to be leaking TCE or other 

hazardous substances, some burial grounds may need to be excavated. 

Groundwater monitoring will be ongoing through 2019. 

• 	 Decontamination and decommissioning of 17 buildings and structures 

that are no longer used for the uranium enrichment process—DOE has 

completed its assessment of the contamination and has begun 

removing the infrastructure of one of the buildings. The remaining 16 

are scheduled to be completed by 2017. 

Page 8 GAO-04-278T 
After operations cease at the plant, DOE will decontaminate and 

decommission the uranium enrichment process buildings and equipment. 7 

During D&D, DOE will also address, as necessary, those areas where 

additional studies are being done. 

Reaching Agreement 

on Cleanup Scope and 

Time Frames Remains 

the Key Challenge to 

Cleanup Progress 

DOE’s most difficult challenge has been, and could likely remain, 

obtaining stakeholder agreement on the cleanup approach, including 

scope and time frames. According to DOE officials, reaching agreement 

has been more difficult at Paducah than at other DOE cleanup sites. For 

example, from June 2001 to April 2003, DOE, EPA, and Kentucky were in 

dispute over the 2001 site management plan because they could not agree 

on the cleanup scope and time frames. Specifically, in response to 

congressional concern about the lack of cleanup progress prior to 

hearings held in 1999, DOE, Kentucky, and EPA drafted a site management 

plan to expedite cleanup actions at the site. According to Kentucky 

officials, technical staff of all three parties agreed to this plan. However, 

DOE headquarters officials later abandoned the plan, citing budgetary 

constraints and their belief that the risk did not warrant all the planned 

cleanup actions. 

DOE and Kentucky have also had difficulty agreeing on the details of 

specific cleanup projects. For example, it took the two parties 5 months to 

reach agreement on the amount and type of data required to confirm that 

soil from the north-south diversion ditch could be appropriately disposed 

of in an onsite landfill. DOE and Kentucky also had difficulties resolving 

DOE’s regulatory violations at the site, which, according to DOE officials, 

slowed cleanup progress. 

DOE and the regulators have recently resolved a number of differences 

that were delaying cleanup actions. For example, in October 2003 DOE 

and Kentucky agreed to a settlement that resolved outstanding regulatory 

violations related to, among other things, DOE’s management of hazardous 

waste at the site. In addition, all three parties are currently negotiating 

approval of the 2004 site management plan, which will provide a 

framework for accelerating the cleanup. While we are encouraged by these 

recent events, the success of the plan, once approved, will depend on the 

parties’ ability to reach agreement on the scope and time frames for 

individual projects as the cleanup moves forward. Furthermore, 

7

No schedule currently exists for full-scale D&D of the operating plant. 

Page 9 GAO-04-278T 
agreement on an accelerated cleanup plan may not preclude future 

disputes between DOE and the regulators. For example, DOE and the state 

of Washington have had an accelerated plan in place since March 2002, but 

they only recently completed a lengthy negotiation over time frames for 

disposal of mixed radioactive and toxic wastes at the Hanford cleanup 

site. 

In addition, as table 1 shows, the accelerated cleanup plan will be only the 

latest of several cleanup plans for the site since 1999, all of which have 

differed significantly in cost, scope, and time frame for cleanup and were 

intended as solutions to problems at the site. For example, DOE’s 

Assistant Secretary for Environmental Management testified in July 2000 

that a solid and effective working relationship had been established with 

Kentucky and EPA and a process was in place that would lead to mutually 

supported cleanup decisions.8

 Ten months later, DOE was in dispute with 

the regulators over the site management plan. 

Table 1: DOE Estimates of Paducah Plant Cleanup Costs and Completion Schedule 

Dollars in billions 

Estimated Estimated completion 

Date and source of DOE estimate cleanup cost date 

October 1999 appropriations hearing $0.7 2012 

January 2000 lifecycle baseline 1.3 2010 

Amended fiscal year 2003 site 2.5 2030 

management plan 

Fiscal year 2004 site management plan 2.0 2019 

Sources: GAO and DOE. 

Given DOE’s past difficulties in reaching agreement with its regulators and 

the details that remain to be agreed upon, it is unclear whether DOE will 

be successful in accelerating the cleanup. 

These are our observations to date. We will continue to further assess 

DOE’s progress and challenges in cleaning up the Paducah site and plan to 

issue our final report in April 2004. 

8

July 12, 2000, testimony of Dr. Carolyn Huntoon before the House Budget Committee Task 

Force on Natural Resources and the Environment. 

Page 10 GAO-04-278T 
Thank you, Senator Bunning. This concludes my prepared statement. I will 

be pleased to respond to any questions that you may have. 

Contact and For further information on this testimony, please contact me at (202) 512­

3841. Individuals making key contributions to this testimony included

Acknowledgments Nancy Crothers, Chris Ferencik, Kerry Dugan Hawranek, Kurt Kershow, 

and Sherry McDonald. 

(360405) Page 11 GAO-04-278T 
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