GAO

United States General Accounting Office

Report to Congressional Requesters

April 2000 NUCLEAR WASTE

CLEANUP

DOE’s Paducah Plan

Faces Uncertainties

and Excludes Costly

Cleanup Activities

GAO/RCED-00-96

Page 1 GAO/RCED-00-96 Paducah Cleanup Plan

Contents

Letter 3

Appendixes Appendix I: Cleanup Plan Focuses on Six Major Categories

of Effort 36

Appendix II: Comments From the Department of Energy 44

Tables Table 1: DOE’s Estimated Cost and Schedule for Six Cleanup

Categories at the Paducah Site, as of January 2000 14

Figures Figure 1: Aerial View of the Paducah, Kentucky, Uranium

Enrichment Plant 7

Figure 2: Scrap Metal Stored on Site, With a Close-up View

of “Drum Mountain” (30 to 40 feet in height) 11

Figure 3: Two Unused, Contaminated Buildings to Be

Demolished During Cleanup 13

Figure 4: Contaminated Groundwater Plumes at the Paducah Site 19

Figure 5: DMSAs Contain a Variety of Contaminated Equipment,

Scrap, and Waste Materials, Including Some Posted

as Posing Nuclear Criticality Safety Concerns 26

Abbreviations

DMSA DOE material storage area

DOE Department of Energy

EPA Environmental Protection Agency

NRC Nuclear Regulatory Commission

PCBs polychlorinated biphenyls

TCE tricholorethene

USEC United States Enrichment Corporation
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United States General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-284388 Letr

April 28, 2000

The Honorable Frank H. Murkowski

Chairman, Committee on Energy

and Natural Resources

United States Senate

The Honorable Jim Bunning

The Honorable Mitch McConnell

United States Senate

In 1988, radioactive contamination was found in the drinking water wells of

residences near the federal government’s uranium enrichment plant in

Paducah, Kentucky.1 In response, the Department of Energy (DOE)

connected local residences to municipal water supplies and began a

cleanup program to identify and remove contamination in the groundwater,

surface water, and soils located within and outside the plant’s boundaries.

Sources of the hazardous chemical and radioactive contamination included

spills, leaks from contaminated buildings, buried waste, scrap yards, and

waste lagoons. From 1988 through 1999, DOE spent about $388 million on

these cleanup efforts.

In August 1999, in response to a number of allegations that past activities at

the Paducah plant had endangered the health of employees, the Secretary

of Energy, among other things, directed the Office of Oversight within

DOE’s Office of Environment, Safety, and Health to conduct an

independent investigation at Paducah.2 This investigation addressed issues

such as improperly disposing of hazardous and radioactive materials onsite and off-site, releasing contamination into streams and drainage ditches,

inadequately posting and controlling contaminated areas, exposing

workers to radioactive material, and ineffectively communicating hazards

to workers. The resulting October 1999 report stated that limited progress

1

The uranium enrichment process prepares uranium for use as a nuclear reactor fuel by

converting natural uranium into a mixture richer in the fissionable isotope uranium-235.

2

The Office of Oversight conducts integrated safety management evaluations, special

reviews and studies, and follow-up reviews. Phase I: Independent Investigation of the

Paducah Gaseous Diffusion Plant (Office of Oversight; Office of Environment, Safety and

Health; Department of Energy; Oct. 1999).
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had been made in cleaning up source areas of contamination, such as

landfills, burial grounds, and waste and scrap piles. The report also noted

that large quantities of waste were stored in conditions that increased the

risk of spreading contamination. In addition, the report noted that the

funding available for cleanup had been much less than requested. Most of

the site’s cleanup funding had been devoted to characterizing

contamination (that is, identifying its nature and extent); operating and

maintaining the site infrastructure; meeting regulatory requirements; and

implementing measures in reaction to immediate threats. According to

DOE officials, cleanup at the site, including the removal of contaminated

scrap metal and low-level waste disposal, was delayed because of funding

limitations.

The plant, which operates today under a lease to a private company, the

United States Enrichment Corporation, enriches uranium for nuclear

power plants. DOE’s Office of Environmental Management has overall

responsibility for the site cleanup being performed by its contractor,

Bechtel Jacobs, while the Office of Nuclear Energy, Science, and

Technology (Office of Nuclear Energy) is generally responsible for

maintaining the site’s infrastructure. DOE’s cleanup plan for the Paducah

site seeks to assess the extent of radioactive and chemical contamination

from past uranium enrichment activities at the site and to treat and dispose

of this contamination. Overseeing the cleanup in a regulatory role are the

Environmental Protection Agency (EPA) and the Commonwealth of

Kentucky.

Concerned about the reportedly slow progress that has occurred to date in

the plant’s cleanup, you asked us to (1) describe the planned activities,

cost, and schedule DOE has for cleaning up the Paducah site; (2) identify

the challenges that exist in accomplishing the current cleanup plan; and (3)

determine whether the cleanup plan includes all areas at the site requiring

cleanup.

In conducting our work, we met with DOE and contractor officials,

reviewed agency documents, and visited the Paducah site on three separate

occasions. We focused primarily on examining the January 26, 2000,

Lifecycle Baseline, which provides details on the planned cleanup

approach, schedule, and estimated costs. We also met with federal and

state regulators as well as the site advisory board to obtain views from

local citizens.
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Results in Brief The Department’s plan for addressing the contamination at the Paducah

site focuses on six major cleanup categories. Four of these address the

physical contamination on the site: groundwater; surface water (for

example, in ditches and creeks); soils; and buried waste. Two other major

categories of cleanup work include treating and disposing of the equivalent

of about 52,000 barrels of waste currently stored on site and

decontaminating and removing two unused, contaminated uranium

process buildings. The cleanup plan includes cost and schedule estimates

for characterizing the contamination in each cleanup category and for

using technologies to treat, remove, and dispose of the contamination. The

current plan estimates the cost of completing the cleanup at $1.3 billion

from fiscal year 2000 through fiscal year 2010.

DOE faces many challenges to completing its cleanup as planned.

Uncertainties about the extent, source, and nature of contamination yet to

be cleaned up could affect the cleanup plan; the outcome of such

uncertainties could increase cleanup costs. DOE also faces several

technical risks, including the planned use of technologies that are

unproven or perhaps not well suited to the site’s conditions. Also

underpinning the plan are assumptions that annual federal funding will

increase to an average of $124 million through 2010. This assumed average

annual funding level is considerably higher than the $43 million average

annual funding DOE has received over the last 7 years—since the Congress

established a fund for cleaning up contamination at DOE’s three uranium

enrichment sites. If the planned increase in funding does not occur, the

project could take longer to complete. In addition, the plan contains

optimistic assumptions about reaching timely agreement with EPA and

state regulators on issues such as cleanup levels, strategies, and priorities.

Collectively, these issues make it uncertain that the Department will be

able to accomplish the cleanup within its estimated time frame and cost.

Even when the planned cleanup has been carried out, billions of dollars

and many years will be needed to address areas at the Paducah site that are

not in the cleanup plan. More specifically, four areas at the site, currently

under the responsibility of the Office of Nuclear Energy, will need to be

cleaned up. These areas are (1) large amounts of waste and scrap materials,

(2) various unused buildings and structures, (3) thousands of tons of

depleted uranium, and (4) the buildings and equipment that are now being

used in the enrichment process but that will have to be cleaned up when

the plant closes. The materials and structures include nearly a million cubic

feet of waste and scrap in areas known as DOE Material Storage Areas and
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16 unused and inactive buildings and structures. Some of this waste and

scrap material poses a risk of an uncontrolled nuclear reaction that could

threaten worker safety. Such a reaction produces a burst of radiation that

generally lasts several hours; it is, however, a localized event that would

not result in an explosion or release of radioactivity to the atmosphere. The

additional materials, buildings, and structures are excluded from the

cleanup plan not because they require no action, but because they fall

under the purview of a different departmental program. According to the

DOE official responsible for these areas, they are not in the cleanup plan

because DOE is hesitant to transfer any more areas to the Office of

Environmental Management, which already has a large workload and

limited funding for cleanup. The programmatic distinction between the

Department’s Office of Environmental Management and its Office of

Nuclear Energy prevents the Paducah cleanup managers from assessing

risk or planning cleanup on a comprehensive, sitewide basis and distorts

the picture of the cleanup task at hand.

Regarding the depleted uranium, DOE recently announced plans to build

and operate a facility at Paducah to convert the 496,000 tons of this

material on site to a more stable form and remove it from the site. DOE

officials estimated that it may cost between $1.8 billion and $2.4 billion to

operate the conversion facility at Paducah for nearly 25 years and to store

and dispose of the unused converted material. Finally, according to DOE’s

January 1998 estimate, another $1 billion would be needed for final

decontamination and decommissioning activities, when the plant ceases

operations and is returned to DOE’s ownership. The current plant operator

can terminate its lease if it gives 2 years’ notice under certain

circumstances or if it is unable to maintain certain financial conditions. To

ensure that cleanup priorities are established on a comprehensive, sitewide

basis, we are making recommendations to the Secretary of Energy to

include in the cleanup plan all materials that are potential health hazards to

workers and the public.

Background The Paducah uranium enrichment plant, shown in figure 1, is located on

about 3,400 acres in western Kentucky, just south of the Ohio River and

about 10 miles west of the city of Paducah. The plant enriches uranium for

commercial power reactors. Over its 50-year operating lifetime, the

Paducah plant has processed, or enriched, more than a million tons of

uranium.
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Figure 1: Aerial View of the Paducah, Kentucky, Uranium Enrichment Plant

Source: DOE.

Plant operations have introduced to the site radioactive and hazardous

chemical wastes, including technetium-99, polychlorinated biphenyls

(PCBs), uranium, and volatile organic compounds such as trichloroethene.

In past years, a cleaning solvent containing trichloroethene—much like

that used by drycleaners—was used to degrease parts and equipment. In

the plant’s half century of operations, these various waste materials have

contaminated the area’s groundwater, surface water, soils, and air.

The Paducah site cleanup is funded through the Uranium Enrichment

Decontamination and Decommissioning Fund, which was established by

the Energy Policy Act of 1992. Money comes into the fund from both annual

federal appropriations and assessments on commercial utilities. Through

1998, the federal government had contributed a total of about $1.5 billion to

the fund, and commercial utilities had contributed a total of about $954

million. Through fiscal year 2000 (as of mid-April 2000), the Paducah site

has received from the fund annual cleanup amounts ranging from $35.9

million to $52.3 million.

The Comprehensive Environmental Response, Compensation, and Liability

Act of 1980, commonly known as Superfund, governs the cleanup of sites

placed on the National Priorities List—EPA’s list of contaminated sites

designated as highest priority for cleanup. Paducah was placed on the list
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in 1994. Superfund provides broad federal authority to respond directly to

releases or threatened releases of hazardous substances that may endanger

public health or the environment. It stresses the importance of permanent

cleanup remedies and innovative treatment technologies, and it encourages

citizen participation in deciding on how sites should be cleaned up.

The Resource Conservation and Recovery Act of 1976 also comes into play

in governing the Paducah cleanup. While Superfund deals with cleaning up

inactive and abandoned hazardous waste sites, this act governs the safe

management and disposal of the huge amounts of hazardous or other solid

wastes that are generated nationwide and are currently destined for

disposal or recycling. The act permits states, rather than EPA, to assume

primary responsibility for implementing its requirements.

At Paducah, the key documents governing the cleanup are a federal facility

agreement, the site management plan, and the lifecycle baseline. The

federal facility agreement—between DOE, EPA, and the Commonwealth of

Kentucky—coordinates the requirements of both Superfund and the

Resource Conservation and Recovery Act for cleanup activities at Paducah.

This agreement includes a site management plan, which includes

timetables, deadlines and projected activities. Bechtel Jacobs, the cleanup

contractor for Paducah since April 1998, prepares a lifecycle baseline,

which includes specific cleanup strategies, their cost estimates, and time

frames for completion over the life of the cleanup.

The lifecycle baseline, according to DOE and contractor officials, is a

“living document;” it is updated frequently to reflect the evolving nature of

the cleanup process. Revisions to the lifecycle baseline are made to

incorporate such things as changes in funding; updated cost estimates for

specific studies, tests, and cleanup tasks; and changes in project approach

or scope necessitated by study results. Such revisions affect estimates of

the total cleanup cost and schedule. For this report, we examined

activities, costs, and schedules contained in the January 26, 2000, version of

the lifecycle baseline.

Since 1996, the plant has been operated under lease from DOE by the

United States Enrichment Corporation (USEC), which was created by the

Energy Policy Act of 1992 and was a first step in the process of privatizing

the government’s uranium enrichment enterprises. The Nuclear Regulatory

Commission (NRC) granted USEC a certificate to operate the plant in

November 1996 and received responsibility for the regulatory oversight of

enrichment operations from DOE in March 1997. As a result of an initial
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public offering, USEC was privatized as an investor-owned corporation in

July 1998. USEC recently announced a workforce reduction to offset low

market prices for uranium.

DOE’s management of the Paducah site is divided between two offices. The

Office of Environmental Management is responsible for the site cleanup

plan, including characterizing, treating, and disposing of waste and

contamination identified during site cleanup. The Office of Nuclear Energy

acts as the “landlord,” with responsibilities for maintaining roads, grounds,

and facilities not leased to USEC, and managing material storage areas and

the cylinders of depleted uranium stored on site.

Paducah has a Site Specific Advisory Board, which provides DOE with

recommendations and advice on major policy issues regarding

environmental restoration, waste management, and related activities at the

site. Sixteen members of the local community are on the board.

Representatives of DOE, EPA, and the Commonwealth of Kentucky serve

as ex-officio representatives on the board.

DOE’s Paducah Plan

Focuses on Cleaning

Up Six Major

Categories by 2010 at a

Cost of About $1.3

Billion

DOE’s January 2000 plan for addressing the variety of radioactive and

hazardous chemical wastes that have contaminated the Paducah site and

surrounding area divides the cleanup work into six major categories. Four

of the cleanup categories are concerned directly with the physical

contamination—the groundwater aquifer, ditches and water release areas

that contribute to surface water pollution running off-site, surface soils,

and waste burial grounds. Two other categories address the treatment and

disposal of approximately 52,000 barrels of accumulated wastes from past

plant operations and the decontamination and removal of two unused,

contaminated uranium process buildings. The plan includes estimates of

the costs and time frames for characterizing and assessing the severity of

the contamination and the costs of selected technologies and strategies to

treat or remove it. DOE estimates that it will accomplish the planned

cleanup by 2010, at a cost of approximately $1.3 billion.

DOE’s Plan Addresses Six

Cleanup Categories

The following describes the six cleanup categories included in DOE’s plan

for the Paducah site. See appendix I for details on the cleanup tasks

accomplished and planned in each of the categories and the estimated

costs and time frames for each.
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• Groundwater in an aquifer below the plant is contaminated with

radioactive and hazardous chemicals. About 10 billion gallons of

contaminated water are spreading off the site in three different plumes,

at least one of which may have reached the Ohio River, about 3 miles

north of the plant. The interim measures DOE has taken to address this

contamination include connecting nearby residences to municipal

drinking water supplies and constructing two groundwater pump-andtreat systems to reduce the concentration of contaminants in the two

major plumes. Additional assessments are being conducted to identify

other contamination sources or plumes, and several cleanup

technologies are being considered for treating the groundwater. Pilot

studies of these technologies are planned to determine their ability to

(1) remove the source of groundwater contamination and (2) clean the

groundwater plumes as they leave the site. DOE estimates that the

planned groundwater cleanup activities will be completed in 2006.

• Surface water contamination has been discovered in surrounding

creeks and ditches and in sludge lagoons. One of the main sources of

this contamination is the thousands of tons of contaminated scrap metal

that DOE has stored on site. During storms, contamination washes from

the scrap metal, and the runoff carries contaminated soils and

sediments into the ditches and creeks. Another source of contamination

is the discharge of wastewater from plant operations. Some interim

measures have been taken to address the wastewater contamination,

including treating some of the wastewater and installing pipes that route

some of the wastewater discharges around areas in the ditches that are

highly contaminated. DOE is finishing its characterization of the

contamination found both on and off-site. By the end of 2000, DOE also

plans to have removed that portion of the contaminated scrap metal

called “Drum Mountain,” which is made up of about 8,000 tons of

crushed drums that contained depleted uranium (see fig. 2). The

remaining planned cleanup tasks include removing the remaining 57,000

tons of scrap metal that contribute to the contamination, dredging

ditches and creeks both on and off-site, and installing four basins to

catch and treat contaminated water. DOE estimates that the planned

surface water cleanup activities will be completed in 2007.
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Figure 2: Scrap Metal Stored on Site, With a Close-up View of “Drum Mountain” (30

to 40 feet in height)

Source: DOE.

• Surface soils on and off-site have been contaminated by water runoff,

spills, and buried waste. DOE has identified 72 areas with contaminated

soils and has taken interim measures, such as installing erosion control

fences, to prevent further migration of the contamination. DOE is

finishing its characterization of the contamination on and off-site. The

planned cleanup tasks include removing contaminated soil and, in one

highly contaminated area, continuing the use of an innovative
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technology to clean the soil. DOE estimates completing the planned

work on contaminated soils in 2007.

• Burial grounds, of which there are 12, contain a variety of waste,

including buried barrels of materials with low levels of radioactivity

and/or hazardous chemicals, and pyrophoric uranium.3 DOE is in the

process of analyzing sampling data to determine the extent to which

these burial grounds are contributing to groundwater contamination.

The planned cleanup strategy is to excavate four or five of the burial

grounds and to install a protective cover, or cap, over the remaining

ones to prevent water from seeping in. DOE estimates completing the

planned cleanup of the burial grounds by 2010.

• Fifty-two thousand barrels of waste, the majority of which contain

materials that have low levels of radioactivity and/or hazardous

chemicals, are stored in various locations at Paducah.4 More than 12,400

barrels of this waste are stored outdoors; many have severely degraded,

and some have leaked.5 DOE has disposed of approximately 750 barrels

of waste since 1990. In addition to requiring storage and monitoring,

nearly all of the remaining barrels will require additional

characterization to determine their suitability for off-site disposal.

Owing to a number of factors, including the aged condition of some

barrels, transportation requirements, and treatment requirements for

waste disposal, the cleanup plan assumes that 80 percent of the 52,000

barrels will need to be “overpacked” (placed inside another barrel) to

make them suitable for disposal. DOE’s plan calls for removing the

barrels by 2010.

• Two contaminated process buildings that have not been used as part

of the uranium enrichment process since 1977 will be decontaminated

and removed. These two buildings are heavily contaminated from earlier

operations. DOE recently decided to plan for the removal of the

buildings by 2008. Figure 3 shows the two buildings.

3

Pyrophoric uranium has a tendency to spontaneously combust in the presence of oxygen.

4

This waste is stored in a variety of containers, such as 55-, 85-, and 110-gallon barrels. The

total volume of waste stored at Paducah is equivalent to the volume of about 52,000 55-

gallon barrels.

5

DOE’s October 1999 report identified about 8,500 barrel equivalents of this waste. During

our review, DOE identified another approximately 3,900 barrel equivalents of waste stored

outdoors.
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Figure 3: Two Unused, Contaminated Buildings to Be Demolished During Cleanup

Source: DOE.

DOE Estimates a Cost of

Approximately $1.3 Billion

to Complete the Cleanup by

2010

DOE’s January 2000 plan estimated that it would take approximately $1.3

billion through 2010 to complete cleanup activities in the six categories.

Table 1 shows the estimated cost of cleanup in each of the six categories. In

addition to the direct cleanup activities, about $91 million of this amount

will be used to conduct monitoring and maintenance activities (such as

repairing fences, replacing warning signs, and conducting required

inspections). The $1.3 billion cost represents an 85-percent increase from

DOE’s October 1999 estimate of $700 million, which had a completion date

of 2012.6 Revisions to the plan since October, decided upon in conjunction

with federal and state regulators, have increased costs partly because of

the need to (1) dispose of contaminated scrap metal that DOE had

previously assumed could be recycled, (2) decontaminate and remove two

unused process buildings, and (3) expand the scope of a number of cleanup

actions. Although DOE plans to complete the cleanup by 2010, a few

6

The DOE Assistant Secretary for Environmental Management provided this estimate in an

Oct. 26, 1999, hearing before the Subcommittee on Energy and Water Development, Senate

Committee on Appropriations.
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activities (such as preparing post-cleanup reports) will continue through

2011, at a cost of about $13 million.

Table 1: DOE’s Estimated Cost and Schedule for Six Cleanup Categories at the

Paducah Site, as of January 2000

a

Includes approximately $91 million for monitoring and maintaining the site and about $13 million for

other activities in 2011, such as preparing post-cleanup reports.

Note: DOE’s estimated costs have been adjusted for inflation.

Source: DOE.

DOE Faces Challenges

in Achieving Its

Cleanup Plan

A number of technical, financial, and regulatory factors associated with the

implementation of the cleanup plan make it uncertain whether DOE can

complete the cleanup in accordance with its plan. Uncertainties exist about

the nature and extent of contamination and the feasibility of available

cleanup technologies. In addition, assumptions about the availability of

federal funding and the timeliness of stakeholders’ agreement with cleanup

levels and strategies may affect DOE’s ability to meet the plan’s milestones.

Collectively, the number and nature of the uncertainties and assumptions

make it doubtful that Paducah’s cleanup will be completed by 2010, as

scheduled, within the $1.3 billion cost projection.

Uncertainties About the

Nature, Extent, and Sources

of Contamination May

Increase Costs

Uncertainties about the nature, extent, and sources of contamination yet to

be cleaned up could affect the cleanup plan; the outcome of such

uncertainties could increase cleanup costs. For example, the extent of

contamination in the surface water and soils within and outside the plant

Dollars in thousands

Cleanup area Cleanup cost Completion date

Groundwater $ 162,100 2006

Surface water 162,300 2007

Surface soils 19,000 2007

Burial grounds 535,400 2010

Waste barrels (52,000) 228,100 2010

Unused process buildings 92,100 2008

Othera 104,200 2011

Total $1,303,200
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boundaries remains to be determined and could affect cleanup strategies,

including the number of sedimentation basins that will need to be installed.

The basins would be installed at various points to collect and hold storm

water runoff, thus allowing treatment of the contaminants the runoff may

contain. The state has expressed its preference for installing eight or nine

sedimentation basins, so as to prevent the further spread of soil

contamination off-site. DOE has agreed to consider installing basins as

needed but is deferring any specific installation plans until it has finished

investigating the nature and extent of contamination. DOE officials told us

they are concerned that the money needed for installing sedimentation

basins could be better used to accelerate the cleanup of the contaminated

soil. Nevertheless, for budgeting purposes, the DOE plan assumes that four

basins will be installed, at a cost of about $14 million. DOE plans to

conduct an engineering evaluation and cost analysis in 2000, with the

installation of any needed basins to be completed in fiscal year 2003. EPA

officials find DOE’s approach unacceptable; they want the installment of

the sedimentation basins to coincide with the removal of the scrap metal,

which is scheduled to begin in 2000. Removal of the scrap metal, according

to EPA officials, will release contaminated sediments that will migrate offsite, via surface water runoff, into adjoining creeks, thus harming the

ecosystem. As a result, the ultimate cleanup costs could vary considerably

from the current estimate, depending in part on the number of

sedimentation basins installed. At an installation cost averaging $4 million

per basin, the addition or deletion of basins from the current plan would

change the cost estimates.

Furthermore, the identification and mitigation of all the groundwater

contamination sources are uncertain and are likely to have the greatest

implications for cleanup efforts. One of the principal groundwater

contaminants—trichloroethene—migrates down through the soil and

aquifer, as is its nature, until it reaches an impermeable layer, where it lays

in a mass and slowly contaminates the water. DOE officials suspect that

leaks and spills from the building formerly used for degreasing machinery

(the C-400 building) caused pockets of this contaminant, which constitutes

a major source of groundwater contamination. The highest concentrations

of trichloroethene at the site have been found near building C-400: 700,000

parts per billion in the groundwater and 11 million parts per billion in the

soils. The drinking water standard for trichloroethene, in contrast, is 5

parts per billion. Other spills and dumping are known to have occurred in

other areas across the site and may also have formed pockets contributing

to the groundwater contamination.
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The difficult task of locating and eliminating these pockets of

contamination, perhaps 100 feet underground, could affect DOE’s ability to

complete its planned groundwater activities within the estimated cost and

schedule. For several reasons, according to an August 1996 DOE

technology summary, the problem posed by pockets of highly

contaminated substances such as trichloroethene is one of the most

difficult environmental challenges facing the nation.7 First, because of the

toxicity of most chlorinated solvents, their unique physical properties, and

their poorly understood movement underground, it is very difficult to

determine the location and distribution of these source areas with any

degree of certainty at most sites. In addition, owing to their limited

solubility in water, these source pockets are capable of contaminating large

quantities of groundwater and can continue to be a source of

contamination for many decades. Furthermore, currently available

treatment and remediation technologies are generally incapable of

completely removing contamination from the source area. Incomplete

removal means that the residual contamination will continue to be a longterm source of groundwater contamination.

Technical Uncertainties May

Also Increase Costs

Project success also depends upon successfully using technologies not

previously used extensively at sites like Paducah. Many of the technologies

included in the plan or contemplated for the cleanup are emerging

technologies, and others, while not new, remain untested for the specific

environment in which they are to be applied. For example, it is uncertain

whether the primary treatment strategy planned for addressing the

contaminated groundwater plumes will be successful. The strategy is to

place thousands of feet of permeable treatment barriers across the paths of

the contaminated groundwater plumes. No treatment is contemplated for

the portions of the plumes that will extend beyond the treatment barriers.

The placement of a barrier involves injecting into the aquifer—at depths up

to 120 feet—a gelatinous, gummy substance called guar gel. The guar gel

contains iron filings for treating the contamination. This technology is quite

new; it is being used at only a few sites across the nation, and the potential

for its success at the Paducah site is uncertain. It was selected for the

Paducah site because it is one of a very few available technologies that

might be able to treat both of the principal contaminants—trichloroethene

(TCE) and technetium-99. Yet the barrier’s success depends on numerous

7

Technology Summary: Subsurface Contaminants Focus Area; Department of Energy; Aug.

1996.
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factors, including the rate of groundwater flow, the length of time the water

resides in the treatment zone, the level of contamination, and the

permeability of the treatment barrier compared to that of the geologic

structure into which it is placed. If the groundwater flows too quickly

through the barrier and thus spends too little time in the treatment zone,

the iron filings might not have time to fully treat the TCE. In that case, the

actions of the barrier’s treatment zone might only change the contaminant

to vinyl chloride, which is more toxic than TCE. Furthermore, it is

uncertain how long the other principal contaminant, technetium-99, will

adhere (through adsorption) to the iron filings in the barrier. DOE and its

contractors are aware of these uncertainties and plan to test the technology

to help determine its suitability for the Paducah site.

Technical uncertainties exist as well with the strategies currently

contemplated to address the sources of groundwater contamination. DOE

believes that the previously mentioned pockets of concentrated TCE cause

much of the groundwater contamination. If these sources cannot be

removed or isolated, they will continue to contaminate the groundwater,

hindering cleanup efforts. However, eliminating the sources of the

contamination will be difficult. Some technologies for doing so are

relatively new, and some may not be appropriate for use at the Paducah

site. Accordingly, DOE is considering and testing several innovative

technologies for treatment. One such technology is referred to as dynamic

underground stripping with dual-phase extraction. This process involves

injecting steam into the aquifer to volatilize the TCE and cause it to rise to

the surface, where it is extracted. According to EPA officials, however,

difficulties with steam injection were encountered with this technology at

another site, and there are considerable questions about whether the

technology will work at Paducah because of the complexities of the

geologic formation underlying the site.

These various technical uncertainties may increase the costs of cleaning up

the site. First, should the technologies now planned for use prove

infeasible, additional costs will be incurred to test and implement

alternative technologies. And second, until the technologies for treating

both the plumes and the sources have been tested, put into place, and

proven effective, DOE will continue to incur the costs of operating the two

systems—at about $2.1 million annually—that pump water out of the

aquifer and then treat it (commonly called pump-and-treat systems) and of

providing municipal water to nearby residents and businesses. The cleanup

plan assumes that DOE will discontinue operation of the two pump-andtreat systems in fiscal year 2005 (after a year or so of operating the
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permeable barriers), but the plan presumes that the barriers will have been

successful in treating the contaminated groundwater plumes. The barriers’

success depends in part on the success of other strategies, such as the

steam injection method, in treating the contamination sources. Figure 4

shows the contaminated groundwater plumes, the pump-and-treat wells in

place, the planned placement of the permeable treatment barriers, and the

planned pilot test of the dynamic underground stripping technology.
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Figure 4: Contaminated Groundwater Plumes at the Paducah Site

Source: DOE, from May 1998 data.

2000 0 2000 feet

Pilot

permeable

treatment barrier

plant

north true

north

20 ̊

N

Northwest and northeast pump-and-treat wells 

active as of 3/00

Planned permeable treatment barriers

Permeable 

treatment 

barriers 

Plant fence

Dynamic underground stripping

Concentrations of groundwater 

contamination with trichloroethene

5-99

0-4

100-999

1,000-99,999

10,000-99,999

100,000-higher

The state drinking water standard is 

5 parts trichloroethene per billion or less.
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Page 20 GAO/RCED-00-96 Paducah Cleanup Plan

As shown in figure 4, the permeable treatment barriers are not planned to

intersect the entire breadth of the groundwater plumes. Rather, the plan is

to place them in the path of the highest concentrations of contamination

within the plumes. As planned, the parts of the plumes that contain TCE

concentrations greater than 99 parts per billion will pass through a

permeable treatment barrier for remediation. In theory, as the groundwater

moves through the iron filings that constitute the barrier’s treatment zone,

the TCE will be rendered harmless. Lesser concentrations of TCE—in

areas of the plume not intersected by a permeable barrier—will be left

untreated to make their way toward the river. Similarly, the portions of the

plumes that are located between the barriers and the river (referred to as

the off-site plumes) will be left untreated. For the parts of the plumes with

lesser concentrations and off-site plumes, the theory is that the TCE will

attenuate over time, and will become diluted as it mixes with the sand and

gravel near the river.

Not shown in figure 4 is the technetium-99 contamination in the

groundwater. This contamination occurs only within the northwest plume.

The planned permeable treatment barrier for the northwest plume is

intended to intercept the highest concentrations of technetium-99, which

generally range from 900 to 3,789 picocuries per liter. (The drinking water

standard for technetium-99 is 900 picocuries per liter.) In theory, as the

groundwater moves through the barrier’s treatment zone, the iron filings

will adsorb (i.e., attract and hold) the technetium-99 so that none of it can

exit the barrier. As with the TCE, though, the large areas of lesser

concentrations of technetium-99 contamination, ranging mainly from 25 to

899 picocuries per liter, will be left untreated; they too are expected to

attenuate over time.

While DOE’s cleanup plan calls for the groundwater cleanup to be

completed by 2006, the costs of providing municipal water to nearby

residences and businesses could continue for years beyond that date,

depending on the effectiveness of the cleanup strategies. Currently, DOE

pays about $78,000 a year for the municipal water provided to

approximately 100 residences and businesses near enough to the plant to

potentially be affected by the contaminated groundwater. As the northeast

groundwater plume approaches more residences and businesses, DOE may

have to connect additional homes and businesses to municipal water

supplies. DOE plans to continue providing water to the affected residences

and businesses indefinitely—until the groundwater is safe to drink.
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Finally, the permeable treatment barriers will likely require maintenance in

the future, but DOE has not included any maintenance cost in its cleanup

plan. Although the technology is too new for the length of the barriers’

efficacy to have been definitively determined, their useful life is estimated

to be between 10 and 20 years. According to a July 1999 study of a pilotscale permeable treatment barrier’s performance over a 16-month period,8

scientists theorize that after some period of time, the iron filings intended

to adsorb and treat the two major contaminants will lose their effectiveness

and will need to be replaced or regenerated. Consequently, the study

recommends that entities plan to replace the iron every 10 years; the study

also estimates that the replacement cost would be about one-fourth of the

original purchase cost of the iron.9 Additionally, according to the December

1999 draft report of the technical advisory group that has worked with the

Paducah site on technology issues, the useful life of a permeable treatment

barrier is between 10 and 20 years.10 Yet in its cleanup plan, DOE has not

included any long-term operation and maintenance costs for the treatment

barriers, even though they are intended to remain in place for 70 years.

According to site officials at Paducah, because they had no reasonable

basis for estimating what such costs would be, they included none.

Funding Assumptions Drive

the Cleanup Plan

Funding constraints have always been an issue, according to DOE,

contractor, and regulatory officials, and their recurrence could delay the

project and add to its ultimate costs. DOE has been criticized in the past for

not requesting the funding it needs for cleanup. Accordingly, beginning in

fiscal year 2001, site officials said their budget requests will more closely

resemble the amounts actually needed to accomplish the planned cleanup.

For fiscal years 2001 through 2010, DOE’s estimates for cleaning up the site

range from a low of $78 million in 2001 to a high of $307 million in 2008, or

an average of $124 million a year. In contrast, in the 7 fiscal years since

8

ESTCP Cost and Performance Report: Permeable Reactive Wall Remediation of

Chlorinated Hydrocarbons in Groundwater, Environmental Security Technology

Certification Program; Department of Defense; July 1999.

9

For the study report’s subject barrier, the purchase cost of the iron was $450 per ton, and 75

tons were required for the barrier’s treatment section, which was 10 feet long, 6 feet thick,

and 22 feet deep. In contrast, the treatment barriers planned for the Paducah site will be at

least 4,300 feet long.

10Draft Report, Paducah Project Innovative Technology Review, Technical Advisory Group,

Paducah Project, Innovative Treatment Remediation Demonstration Program; Sandia

National Laboratories; Albuquerque, New Mexico; Dec. 1999.
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appropriations were made from the Decontamination and

Decommissioning Fund, the site has received funding levels ranging from

about $36 million to about $52 million, an average of $43 million each year.

For fiscal year 2000, the site has received supplemental funding to

accelerate the cleanup. The amount originally appropriated for the site’s

cleanup was about $37.5 million; subsequent congressional and

departmental funding actions (as of April 2000) raised that amount to about

$50 million—about $14 million more than the previous year’s funding.11 For

fiscal year 2001, the budget request includes about $78 million for the site’s

cleanup activities. If the planned increase in funding does not occur, the

project could be delayed and its costs increased.

Assumptions About

Regulatory and Stakeholder

Agreement Are Optimistic

The plan’s assumptions about the timely achievement of regulatory and

stakeholder agreement on cleanup levels, strategies, and priorities are

optimistic. If the assumptions are not achieved, the completion date and

costs of cleaning up the site could be affected.

During the decision-making process in cleaning up the site, regulators have

disagreed with DOE’s proposed approaches. For example, an earlier

version of the cleanup plan called for constructing impermeable barriers,

called caps, over the 12 burial grounds to prevent water from entering

them. However, Kentucky disagreed with that strategy, and, as a result,

DOE’s current plan is to excavate four burial grounds and possibly a fifth.

In another case, DOE cleaned up an area with PCBs in the soils to EPA’s

standard of 25 parts per million for open or unoccupied space. Kentucky

objected, however, saying that it wanted the PCBs in the soils cleaned up to

1 part per million, EPA’s standard for industrial or residential use. That

dispute remains unresolved, but the parties agreed to defer its resolution

until DOE has submitted its plans for cleaning up the surface water.

Kentucky has put DOE on notice, however, that it wants a stringent cleanup

level for the surface water in order to protect the ecosystem. If DOE adopts

a more stringent cleanup level than currently planned, its costs to complete

the effort will grow.

In addition, DOE has not reached agreement with regulators and

stakeholders on some issues that may prove to be contentious. For

11As of April 19, 2000, an additional supplemental request for $8 million had not been

approved, according to DOE officials.
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example, while DOE’s plan assumes that the site will be used for a mix of

industrial and recreational purposes after the plant has ended operations

and the site has been cleaned up, DOE has not reached consensus with the

regulators and the public on the future use of the site. According to the

plan, this step would not be taken until near the end of the planned cleanup

and would become part of the final regulatory action at the site. Yet many

of the cleanup decisions hinge on what future use is assumed. For example,

a decision about whether to cover a waste burial ground with a cap or to

excavate it depends, in part, on how that portion of the site is to be used in

the future. Assumptions about regulators’ agreement with the planned

disposition of all buried waste could also affect cleanup costs. For

example, although the current cleanup plan assumes the excavation of 4 of

the 12 burial grounds, the regulators are still contemplating excavation of a

fifth burial ground, which would increase costs.

Without firm regulator and stakeholder agreement on future land use,

cleanup levels may continue to be a contentious issue and could result in

additional work, at additional cost. DOE’s plan presumes that future use

will be the same as current use—predominantly industrial. However, the

plan’s map of the current use includes many acres of agricultural and rural

residential land that are located directly over one of the contaminated

groundwater plumes. Residential and agricultural land must be cleaned up

to more stringent levels than industrial land. For these acres in particular,

then, the regulators may require more stringent cleanup levels for

contaminated soils and surface water. And, until the vexing problem of

groundwater contamination has been resolved, DOE will have to continue

to provide municipal water to residences and businesses located on these

acres.

Adherence to DOE’s cleanup schedule will also be a challenge because the

plan assumes that the regulators will comment on only one draft of

regulatory documents (such as remedial investigation reports and

feasibility study reports) and that the revised draft, with comments

addressed, will be satisfactory to all parties. In the past, however, as many

as four drafts have been required to address regulators’ comments. Unless

this “comment and revise, comment and revise” cycle is broken, according

to EPA officials, scheduled milestones might be missed. These officials

have suggested that DOE bring in a technical facilitator to work with the

three parties (DOE, EPA, and Kentucky) to ensure that discussions are held

and consensus reached before the regulatory drafts are prepared.

According to an EPA official, this process was used at the Savannah River

Site and was quite successful in streamlining the site’s cleanup efforts.
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Public participation is also important to the success of DOE’s cleanup plan,

but the public’s involvement can hinder DOE’s ability to meet its

completion targets. Citizens can challenge DOE plans and decisions in the

courts or through the regulatory process, and have done so. For example,

DOE’s plan to demonstrate a technology, called VORTEC, to treat some

types of hazardous and radioactive wastes was challenged in the courts by

a citizen who was concerned that DOE had not adequately assessed the

environmental effects of the technology’s operation. As a result of this

action, DOE halted the demonstration project until an environmental

assessment could be completed. The environmental assessment was

completed in December 1999 and approved by the Oak Ridge Operations

Office in March 2000. The cleanup plan calls for the demonstration project

to treat about 865 cubic meters of waste.

Cleanup Plan Does Not

Address All Areas That

Require Cleanup

Even when the planned cleanup has been carried out, billions of dollars

and many years will be needed to address areas at the Paducah site that are

not in the cleanup plan. More specifically, four areas at the site, which are

currently the responsibility of the Office of Nuclear Energy, will need to be

cleaned up. These four areas are (1) large amounts of waste and scrap

materials, (2) various unused building and structures, (3) thousands of tons

of depleted uranium, and (4) the buildings and equipment currently being

used in the enrichment process that will require cleanup when the plant

closes. The materials and structures include nearly a million cubic feet of

waste and scrap contained in DOE material storage areas (some of which

pose a risk of an uncontrolled nuclear reaction) and 16 unused and inactive

buildings and structures.12 The materials and structures are excluded from

the cleanup plan not because they require no action, but because they fall

under the purview of a different departmental program. According to the

DOE official responsible for these areas, a transfer of this area to the Office

of Environmental Management has not occurred because DOE is hesitant

to transfer any more areas to this office, which already has a large

workload and limited funding for cleanup. This programmatic distinction

between the Department’s Office of Environmental Management and its

Office of Nuclear Energy prevents the Paducah cleanup managers from

12According to DOE, this type of an event, referred to as an inadvertent criticality, includes a

burst of radiation and generally lasts several hours. DOE describes this event as a worker

safety issue rather than a public health or safety issue. It is a localized event that would not

result in an explosion, release of radioactivity to the atmosphere, or—in the case of

Paducah—damage to the uranium enrichment process.
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assessing risk or planning cleanup on a comprehensive, sitewide basis and

distorts the picture of the cleanup task at hand. As a result, the cost and

time needed to clean up this additional material has not been estimated or

included in the $1.3 billion cleanup plan. In addition, the cleanup schedule

could be impeded because some of this material is located in areas that

could interfere with the planned cleanup. Regarding the depleted uranium,

DOE recently announced plans to build and operate a facility at Paducah to

convert the 496,000 tons of this material to a more stable form—at an

estimated cost of $1.8 billion to $2.4 billion. Finally, when USEC ceases

plant operations, DOE will become responsible for decontaminating and

decommissioning the plant’s numerous remaining facilities—a process that

could cost about another $1 billion.

Exclusion of DOE Material

Storage Areas From Plan

Could Impede Cleanup

Schedule

Nearly 1 million cubic feet of uncharacterized waste and scrap materials

not included in DOE’s cleanup plan are located on the Paducah site in what

are referred to as DOE material storage areas (DMSA). These areas,

managed by the Office of Nuclear Energy, were created in 1996 when DOE

accepted responsibility for large amounts of material stored in USECleased buildings and outdoor areas. DOE accepted responsibility for these

material areas to expedite the process USEC used to obtain an operating

certificate. The 148 DMSAs are in a variety of locations across the site—133

are inside eight USEC-leased buildings; the other 15 are outdoors. The

materials in these areas include thousands of barrels of low-level

radioactive waste and PCB wastes, barrels labeled as asbestos waste,

contaminated process equipment, various items and containers whose

contents are unknown, and scrap metal. DOE has not yet determined the

exact nature and extent of contamination in these areas. Figure 5 illustrates

the waste and scrap materials contained in DMSAs across the site.
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Page 26 GAO/RCED-00-96 Paducah Cleanup Plan

Figure 5: DMSAs Contain a Variety of Contaminated Equipment, Scrap, and Waste Materials, Including Some Posted as Posing

Nuclear Criticality Safety Concerns
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Page 27 GAO/RCED-00-96 Paducah Cleanup Plan

Source: DOE.
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Page 28 GAO/RCED-00-96 Paducah Cleanup Plan

One of DOE’s primary concerns with the DMSAs is that some of them might

contain radioactive material, which, in the right quantity and configuration,

could cause an uncontrolled nuclear reaction—a localized event referred to

as an inadvertent criticality. Of the 148 DMSAs, DOE has designated 73 as

having inadvertent criticality concerns. DOE’s October 1999 report noted

that uncharacterized radioactive and chemical equipment, materials, and

waste in DMSAs continue to present unnecessary and avoidable risk to

workers and the environment. DOE officials explained that they have a

verbal agreement to pay USEC about $4.8 million to conduct a nuclear

criticality safety review on the 10 DMSAs that have the highest risk for an

inadvertent criticality. The estimated completion date for this work is July

2000. However, this agreement does not address the need for a review of

the other 63 DMSAs that DOE has identified as having nuclear criticality

safety concerns. The schedule also does not address the characterization

needed for all 148 DMSAs to determine whether they contain material

regulated under federal environmental statutes.

According to the DOE official responsible for these areas, the DMSAs have

not been transferred to the Office of Environmental Management because

DOE is hesitant to transfer any more areas to it. The Office of

Environmental Management already has a large workload, and funding for

cleanup is limited. Because the materials in the DMSAs have not been

transferred to the Office of Environmental Management, these materials

could impede the progress of the cleanup schedule. For example,

approximately 9,700 barrels of waste that are already part of the cleanup

plan are stored with uncharacterized waste material in many of the DMSAs.

At least 1,300 of these barrels are stored in DMSAs that pose an inadvertent

criticality safety concern.13 DOE procedures prevent access to these areas

without first resolving the nuclear criticality concerns. As a result, these

waste barrels cannot be retrieved until these concerns are resolved, and

the cleanup plan does not include cost or schedule estimates for resolving

the nuclear criticality issues in these DMSAs. In addition, the location of

some DMSAs could impede the cleanup schedule. For example, three

DMSAs are located outside in the same location as much of the site’s scrap

yards and burial grounds, which are expected to be cleaned up by 2010.

One of these DMSAs is located on top of a burial ground included in the

cleanup plan, but, again, the cleanup plan does not include cost or schedule

13These 9,700 barrels (approximately 4,500 barrels of low level waste and 5,200 barrels of

radioactive PCB waste) represent approximately 7 percent of the 1 million cubic feet of

material in the DMSAs.
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estimates for removing the DMSA material. Furthermore, DOE and

contractor officials could not provide any assurances that the material in

the DMSAs, if not characterized and removed prior to the completion of the

site cleanup, would not recontaminate any cleaned up areas.

The exclusion of DMSAs from the Office of Environmental Management’s

cleanup plan has also precluded the assessment of risks on a

comprehensive, sitewide basis. From the onset of efforts to assess the site

in the late 1980s, DOE’s cleanup plan and activities have been predicated

on risk. The risks posed—to area residents, to workers, and to the

environment—by the various types and sources of contamination have

been assessed and addressed in order of priority. Yet throughout the last

decade, because the materials in the DMSAs have not been characterized,

the risks they pose have been excluded from such assessments.

Accordingly, DOE cannot demonstrate that it has taken into account the

comparative risks posed by all contaminated materials on site.

Numerous Unused

Buildings and Structures

Are Not Included in the

Cleanup Plan

Although DOE’s cleanup plan includes the decontamination and

decommissioning of two unused contaminated buildings, it does not

include 16 other unused buildings and structures. These other buildings

and structures are currently monitored and maintained by DOE’s Office of

Nuclear Energy. These buildings and structures, which were originally used

as part of the enrichment process, include a 120,000-gallon sludge lagoon,

two 250,000-gallon water storage tanks, a nitrogen generation plant, and an

incinerator previously used for disposing of contaminated items. DOE and

contractor officials explained that several of these buildings and structures

probably contain some contamination. According to DOE and contractor

officials, lack of funding and higher priorities have prevented these 16

buildings and structures from being transferred to the Office of

Environmental Management’s cleanup plan. These officials explained that

the two buildings to be decontaminated and removed were probably

transferred to the cleanup plan several years ago because they are the

largest and most contaminated of the unused buildings and thus presented

the highest risk to worker safety and the environment. As with the DMSAs,

because they have not been transferred to the cleanup program, the

remaining 16 buildings and structures have not been included in a

comprehensive, sitewide risk assessment.
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About 496,000 Tons of

Depleted Uranium Will Also

Need to Be Addressed

Approximately 496,000 tons of depleted uranium hexafluoride, the majority

of which is currently stored on site in 14-ton capacity cylinders, are not

included in the cleanup plan. This material resulted from many years of

uranium enrichment operations and is managed by the Office of Nuclear

Energy. In addition to being radioactive, uranium is a heavy metal that can

have toxic chemical effects. This material also poses risks if released to the

atmosphere because the compounds that are formed in the air are

chemically toxic. The advanced age of some of the steel cylinders and the

way in which they were originally arranged—sometimes too close together

to permit inspection; sometimes in direct contact with the ground, leading

to enhanced cylinder corrosion—have created a potential environmental

and safety hazard. The October 1999 DOE report noted that these cylinders

constitute a radiological exposure hazard and a potential threat to worker

and public health in the event of fire and rupture. The Defense Nuclear

Facilities Safety Board recommended in 1995 that DOE improve the

storage and maintenance of the cylinders.14

DOE issued a plan in July 1999 to convert depleted uranium hexafluoride

stored at Paducah, Portsmouth, and Oak Ridge.15 The plan is consistent

with the preferred cleanup strategy selected in the environmental impact

statement prepared for the conversion plan.16 The strategy specified that

the conversion of the depleted uranium hexafluoride inventory to uranium

oxide, to uranium metal, or a combination of both, should begin as soon as

possible.17 It includes the construction and operation of conversion

facilities at the Paducah and Portsmouth sites. DOE expects to issue a

request for proposals to construct the conversion facilities in October 2000.

DOE has estimated a lifecycle cost of its conversion plan—including

operating the facilities for nearly 25 years, storage, and disposing of the

14 The Defense Nuclear Facilities Safety Board is an independent agency created by the

Congress in 1988 to oversee DOE’s defense nuclear facilities and to ensure that public health

and safety are protected.

15Final Plan for the Conversion of Depleted Uranium Hexafluoride, Office of Nuclear

Energy, Science and Technology; Department of Energy; July 1999.

16Final Programmatic Environmental Impact Statement for Alternative Strategies for the

Long-Term Management and Use of Depleted Uranium Hexafluoride, DOE/EIS-0269; Office

of Nuclear Energy, Science and Technology; Department of Energy; Ap. 1999.

17In addition to the depleted uranium hexafluoride stored on-site at Paducah, approximately

218,000 tons are stored at the Portsmouth plant and another approximately 62,000 tons are

stored at the Oak Ridge plant.
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unused converted material—at between $3 billion and $4 billion. Paducah’s

share of this cost is between $1.8 billion and $2.4 billion. DOE has not

identified any significant uses for this material once it has been converted.

DOE recognizes that this plan represents a major new undertaking and

involves a significant investment of resources beyond amounts available in

the current budget.

Another Billion Dollars

Needed for Final Site

Decontamination and

Decommissioning

DOE’s cleanup plan does not reflect the costs of decontamination and

decommissioning that will be required after USEC ceases plant operations

and terminates its lease with DOE. The lease includes process buildings

and areas outside these buildings. In a January 1998 report, DOE estimated

a cost of approximately $1 billion to decontaminate and decommission the

buildings and associated equipment and materials.18 This estimate,

however, did not include costs for removing any of the site’s four large

process buildings. Rather, it assumed that these facilities would be

decontaminated and reused for industrial purposes. The estimate also did

not include the $1.8 billion to $2.4 billion associated with Paducah’s share

of the disposition of the depleted uranium, which is addressed in DOE’s

uranium conversion plan discussed above. DOE is currently revising the

decontamination and decommissioning cost estimate to more accurately

assess numerous assumptions, including the extent to which materials

from the site could be recycled and the extent to which site facilities could

be reused.

Conclusions DOE faces significant challenges in cleaning up the Paducah site. First,

given the many uncertainties and optimistic assumptions inherent in the

cleanup plan, there is reason to doubt that the Department will complete its

planned cleanup actions by 2010 within the estimated $1.3 billion cost.

Furthermore, if the cleanup plan is carried out as currently envisioned,

billions of dollars and many years will be required to address areas not

included in the current cleanup plan. For example, additional costs and

time will be required to address about 1 million cubic feet of waste and

contaminated scrap that is contained in DOE’s material storage areas, 16

unused buildings, and other structures that will remain on site. Since these

areas are not in the cleanup plan, no estimates of the cost or time to clean

18D&D Estimate of Gaseous Diffusion Facilities Incorporating Site Reindustrialization,

prepared for DOE by Lockheed Martin Energy Systems, Inc.; Jan. 1998.
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up these areas have been included in the plan. The additional materials,

buildings and structures are excluded from the cleanup plan not because

they require no action, but because they fall under the purview of a

different departmental program. According to the DOE official responsible

for these areas, these areas have not been included in the cleanup plan

because DOE is hesitant to transfer any more areas to the Office of

Environmental Management, which already has a large workload and

limited funding for cleanup. This programmatic distinction between the

Department’s Office of Environmental Management and its Office of

Nuclear Energy prevents the Paducah cleanup managers from assessing

risk or planning cleanup on a comprehensive, sitewide basis and distorts

the picture of the cleanup task at hand. In addition, DOE officials estimated

that it might cost between $1.8 billion and $2.4 billion to operate the

conversion facility at Paducah for nearly 25 years and to store and dispose

of the unused converted material. Finally, according to DOE’s January 1998

estimate, another $1 billion would be needed for final decontamination and

decommissioning activities when the plant ceases operations and is

returned to DOE.

Recommendations To ensure that priorities are established on a comprehensive, sitewide basis

to clean up and dispose of materials that are potential health hazards and

that a more comprehensive picture of cleanup is presented to the Congress,

we recommend that the Secretary of Energy transfer the responsibility for

the material storage areas and the unused structures from its Office of

Nuclear Energy to its Office of Environmental Management. In addition, we

recommend that the Secretary direct the Office of Environmental

Management to address in the cleanup plan, regardless of the current

organizational responsibility, any and all materials at the site that are

potential health hazards and to reexamine the sitewide contamination risks

and cleanup priorities, costs, and schedules.

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

raised two general issues about our draft report. First, DOE believes that

while the draft report provides a detailed description of waste and

materials that need to be cleaned up at the Paducah site, it did not account

for ongoing work and improvements at the site. Second, DOE stated that

the draft report describes many of the uncertainties that DOE recognizes

will affect cleanup progress, but notes that the report did not offer specific

alternatives or recommendations regarding planning assumptions and
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targets for completing work. The full text of DOE’s comments are in

appendix II.

We disagree with DOE’s characterization that our draft report does not

account for progress made in cleaning up the site. We believe that the

report clearly describes the actions taken by DOE to date and discusses the

status of each of the areas for early action that DOE identified. We pointed

out in our draft report that the cleanup actions on each of these areas are in

the early stages, will not be completed for years, and will face challenges as

they proceed. In addition, the draft report stated that DOE and the

regulators have been discussing planned cleanup activities and

approaches. However, it should be noted that there are still areas of

disagreement between DOE and the regulators, and that cleanup of many

of these areas is just beginning or has not yet begun.

We agree that our draft report did not offer planning assumptions or targets

for DOE to complete its cleanup work. This was not an objective of our

work nor is it our role. Our objective was to provide the Congress with an

understanding of the scope and cost of the cleanup and the challenges and

uncertainties that will affect DOE’s ability to accomplish it. We have

included a number of examples of where DOE’s plans will face challenges

or uncertainties and point out that delays and additional costs could occur

depending on the decisions made. For example, the draft report noted that

there is disagreement with regulators regarding the cleanup levels for

PCBs, the timing and number of sedimentation basins to be built, the

number of waste burial grounds to excavate, and the future land use at the

site. The cost and timing of the site cleanup will not be known until the

areas of disagreement are resolved.

DOE also provided technical clarifications to the draft report. In these

clarifications, DOE stated that the draft report’s recommendation to

transfer management responsibility for the DOE material storage areas and

unused buildings should be revised to recognize the need for advance

planning to ensure safety risks are identified and addressed prior to any

transfer. DOE also believed that the draft report’s recommendation for a

sitewide review of cleanup priorities should be revised to acknowledge the

role of regulators and the review currently being conducted by DOE, EPA,

and the Commonwealth of Kentucky. We recognize that, as with most

significant changes to programs, that prior planning will need to be

conducted and that participation by various parties may be required. We

would expect DOE to use good management practices in implementing
B-284388

Page 34 GAO/RCED-00-96 Paducah Cleanup Plan

such changes. As a result, we made no changes to the recommendations.

DOE’s other technical clarifications were incorporated, as appropriate.

Scope and

Methodology

To determine the cleanup plan’s cost, schedule, and activities, we

interviewed officials from DOE’s offices of Environmental Management;

Nuclear Energy; and Environment, Safety, and Health. In addition, during

three visits, we interviewed officials from DOE’s Oak Ridge Operations

Office, which is responsible for managing the Paducah site, reviewed

documents related to the cleanup, and toured the Oak Ridge uranium

enrichment cleanup site. During three visits to the Paducah site, we

interviewed managers responsible for Environmental Management and

Nuclear Energy and toured the site on two separate occasions to examine

specific areas of cleanup. We also toured the USEC facility to increase our

understanding of the uranium enrichment process. Also at the site, we

interviewed representatives from Bechtel Jacobs responsible for the six

categories of cleanup, finance, and planning, and reviewed site-specific

documents, including the fiscal year 2000 and the January 26, 2000,

Lifecycle Baselines; the Federal Facility Agreement, including the Site

Management Plan; the Site Treatment Plan for Low-level Mixed Waste; the

Oak Ridge Operations Office Integrated Priorities List; and DOE’s draft

report entitled 1999 Paths To Closure.

To identify the challenges facing DOE in accomplishing its cleanup plan

and to determine whether the plan includes all areas at the site that require

cleanup, we interviewed officials from DOE’s offices of Environmental

Management; Nuclear Energy; and Environment, Safety, and Health. In

addition, during three visits, we interviewed officials from DOE’s Oak

Ridge Operations Office, which is responsible for managing the Paducah

site, and toured the Oak Ridge uranium enrichment cleanup site. During

three visits to the Paducah site, we interviewed managers of DOE’s offices

of Environmental Management and Nuclear Energy and toured the site on

two separate occasions. We also interviewed representatives from Bechtel

Jacobs responsible for the six categories of cleanup, finance, and planning.

In addition, we interviewed officials from EPA Region IV, the

Commonwealth of Kentucky’s Department for Environmental Protection,

and an official from the Office of the Governor of Kentucky. We also

interviewed the chairman of the Paducah Site Specific Advisory Board and

attended one of the board’s monthly meetings. We reviewed studies of

various cleanup technologies, site-specific progress reports and plans for

each category, and testimony from congressional hearings.
B-284388

Page 35 GAO/RCED-00-96 Paducah Cleanup Plan

We conducted our review from October 1999 through April 2000 in

accordance with generally accepted government auditing standards.

As arranged with your offices, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 30 days after the

date of this letter. At that time, we will send copies to interested

congressional committees; the Honorable Bill Richardson, Secretary of

Energy; the Honorable Carol M. Browner, Administrator, Environmental

Protection Agency; the Honorable Jacob J. Lew, Director, Office of

Management and Budget; the Honorable Paul Patton, Governor of the

Commonwealth of Kentucky; Mr. James E. Bickford, Secretary, Kentucky

Natural Resources and Environmental Protection Cabinet; and other

interested parties. We will also make copies available to others on request.

If you have any questions about this report, please call me at (202) 512-

3841. Key contributors to this report were Erin Barlow, Daniel Feehan,

Glen Trochelman, and Pam Tumler.

(Ms.) Gary L. Jones

Associate Director, Energy,

Resources, and Science Issues
Page 36 GAO/RCED-00-96 Paducah Cleanup Plan

Appendix I

Cleanup Plan Focuses on Six Major Apendxies

Categories of Effort ApendxiI

The Department of Energy’s (DOE) cleanup plan for the Paducah site

addresses the cleanup of four contaminated media: groundwater, surface

water, soils, and burial grounds. It also includes two other categories of

effort: the site’s treatment and disposition of about 52,000 barrels of waste

that are stored on-site, and the removal of two contaminated, unused

buildings. As of January 2000, DOE estimates that the cleanup will be

finished by 2010, at a total cost of $1.3 billion.

Groundwater Cleanup

to Address More Than

10 Billion Gallons of

Contaminated Water

Through investigations beginning in 1988, when hazardous and radioactive

contamination was found in the drinking water wells of residences near the

Paducah plant, DOE discovered that plumes of contaminated groundwater

were heading north of the plant toward the Ohio River. A major source of

the contamination was later found to be the C-400 building, where a toxic

solvent called trichloroethene, or TCE, had been used for years to degrease

parts and equipment. Upon discovering the contamination, DOE took a

number of steps to minimize the danger to human health and the

environment. For example, it provided safe drinking water to neighboring

homes and businesses, undertook efforts to determine the extent of the

contamination, and began a program to pump out some of the water and

treat it (commonly called a pump-and-treat system). DOE’s long-range

cleanup plan calls for two cleanup strategies—one to reduce the sources of

the contamination and the other to trap and neutralize the highest

concentrations of contaminants in the plumes.

DOE estimates that about 10 billion gallons of groundwater has been

tainted with TCE, and 250 million gallons with radioactive technetium-99, a

fission product. The levels of concentration have been found in places to

far exceed the Environmental Protection Agency’s (EPA) drinking water

standards. The TCE contamination in groundwater has been identified in

two major plumes covering more than 3.75 square miles, one heading

northwest of the plant and the other heading northeast. Another smaller

plume, discovered in about January 1999, heads southwest and then turns

toward the north. According to DOE officials, the contaminated

groundwater plumes are estimated to be moving at about a foot per day

toward the Ohio River (3 miles north of the plant). DOE cannot say with

certainty whether the leading edges of the plumes have reached the river;

however, officials believe that the technetium-99 plume (heading northwest

from the plant) has possibly reached the river. Results from recent samples

did not show significant amounts of either contaminant in the river.
Appendix I

Cleanup Plan Focuses on Six Major

Categories of Effort

Page 37 GAO/RCED-00-96 Paducah Cleanup Plan

DOE has taken a number of actions since the discovery of the groundwater

contamination. Citizens affected by the contaminated groundwater were

provided with safe drinking water and were connected, at DOE’s expense,

to the municipal water system. As of January 2000, DOE had connected

over 100 residences and businesses to the municipal water supply, at a

capital cost of about $1 million and continuing monthly water costs of

about $6,500.

In addition, since the discovery of the contamination, a number of studies

have been done to determine the extent and nature of the contamination in

the groundwater. For example, DOE has identified a degreasing and

equipment cleaning building (the C-400 building) as a primary source of

TCE contamination. DOE is currently evaluating the data available from

groundwater sampling.

As an interim measure, DOE installed two pump-and-treat systems to

remove some of the contaminated groundwater, which is then treated. The

pump-and-treat system on the northwest plume began operating in August

1995. By June 1999, it had processed about 385 million gallons of water. The

pump-and-treat system on the northeast plume began operating in January

1997 and by June 1999 had processed about 213 million gallons of water.

The estimated capital cost (that is, design and construction) for the two

systems was about $20 million. For fiscal year 1999, the estimated

operations and maintenance cost for both systems was $2.1 million. Once a

final cleanup strategy has been selected and proven effective, DOE’s plan

calls for removing the pump-and-treat systems.

DOE’s planned cleanup strategy involves the use of two technologies.

These technologies are designed to (1) remove the sources of

contamination and (2) treat the contaminated groundwater plumes as they

move off-site. To remove the source of the contamination, DOE’s plan calls

for the use of a process called dynamic underground stripping, with dualphase extraction. In essence, this process injects steam into the ground so

the contaminants rise, then extracts and treats the contaminants. Other

processes for removing the contamination sources will be considered and

pilot-tested as well. To clean the water in the plumes, the planned strategy

is to use permeable treatment barriers. This technology involves installing

about 4,300 feet of barriers (or possibly as many as 6,000 feet) by injecting

into the aquifer—at a depth between 60 and 120 feet—a gummy substance,

called guar gel, containing iron filings. These permeable barriers, which

will be placed across the paths of the highest concentrations of

contamination in the plumes, will allow the groundwater to pass through,
Appendix I

Cleanup Plan Focuses on Six Major

Categories of Effort

Page 38 GAO/RCED-00-96 Paducah Cleanup Plan

but the iron filings in the barriers will adsorb the technetium-99 and treat

the TCE. DOE plans to conduct a pilot test of the permeable treatment

technology in 2000 and, if the pilot test proves successful, to then begin

constructing the full-scale barriers. Construction is planned for completion

in 2003. The total cost of cleaning up the groundwater is estimated at $162

million and is expected to be completed by 2006.

Surface Water Cleanup

Includes Removing

65,000 Tons of Scrap

Metal

DOE has discovered surface water contamination in creeks, ditches and

sludge lagoons. Two streams flank the plant: Bayou Creek to the west and

Little Bayou Creek to the east. Stormwater runoff and wastewater from

plant operations discharge to these streams through a series of ditches.

Each discharge point is monitored to ensure that the effluent entering the

stream is within the parameters of the discharge permit issued by the

Commonwealth of Kentucky. Contaminants of concern are technetium-99,

solid uranium tetrafluoride (“green salt”), uranium-contaminated silts and

sediments, radionuclides, metals, and polychlorinated biphenyls (PCBs).

One of the principal sources of this contamination is the approximately

65,000 tons of scrap metal stored in the northwest portion of the site. Much

of the scrap metal was placed there over the years. Part of this scrap

includes a pile of about 8,000 tons of crushed drums—commonly called

Drum Mountain—that were once used to store depleted uranium. Although

the drums were emptied before being crushed, residual uranium (known as

green salt) remains on or in them.

DOE has conducted a number of assessments and taken some interim

measures to minimize surface water contamination. The assessments have

included taking radiation readings in the creeks and ditches inside and

outside the plant and monitoring the water being released off-site. As an

interim measure, DOE has taken steps to reduce the amount of

contamination leaving the site. For example, it installed a gabion (a cage

filled with rocks) to reduce the migration of contaminated sediments when

it rains. Also, some wastewater from the United States Enrichment

Corporation’s (USEC) operations is now diverted away from the most

contaminated portion of a main ditch, the north-south diversion ditch. In

another action, DOE constructed two settling lagoons that collect

contaminants from wastewater before releasing it off-site. Still another

interim action involved installing a system, within an active USEC process

building, to treat technetium-99. Process water tainted with high levels of

technetium-99 is routed through the treatment system, over and over again,

until the system can reduce the contaminant level no further. DOE officials
Appendix I

Cleanup Plan Focuses on Six Major

Categories of Effort

Page 39 GAO/RCED-00-96 Paducah Cleanup Plan

say this action has accomplished its objective, as have the other actions,

because the process water is not only treated but also no longer discharged

into the north-south diversion ditch. Instead, it is discharged into a USECcontrolled ditch on DOE property. Nevertheless, the treatment system has

been unable to treat the technetium-99 to drinking water standards since

October 1998, when USEC restarted its cylinder washing program in the

building that houses the treatment system. Since October 1998, the levels of

technetium-99 in the wastewater being discharged onto DOE property have

at times been quite high. In one instance, the levels exceeded 17,000

picocuries per liter, nearly 20 times the drinking water standard of 900.

DOE’s plan for addressing the surface water contamination includes

removing the scrap metal (including Drum Mountain), conducting

additional assessments, and taking steps to clean up the existing

contamination in the ditches and other locations. DOE’s plan for the scrap

metal is to have a contractor remove and dispose of Drum Mountain by

December 2000 at a cost of about $7.1 million. The remainder of the scrap

metal is to be removed by 2003, according to the federal facility agreement.

But the DOE plan contemplates completing removal of the remaining scrap

metal in fiscal year 2004, at a cost of about $74 million. Planned cleanup

activities include excavating at least four contaminated ditches and various

other areas, installing up to four sedimentation basins to catch

contaminated surface water runoff from the plant, and installing a new

storm sewer segment. The total cost for cleaning up the surface water has

been estimated at more than $162 million, with a completion date of 2007.

Surface Soil Cleanup to

Address 72

Contaminated Areas

DOE has identified 72 areas on the site that contain contaminated soil. The

primary contaminants are PCBs and radionuclides. To date, DOE has

focused primarily on assessing the extent of the problem and using an

innovative technology to clean one area of heavily contaminated soil.

DOE’s plan for cleaning up the surface soil includes conducting additional

assessments and excavating contaminated soils. However, some of the

cleanup work will have to be deferred until the plant has closed because

some of the contaminated areas, such as the electrical switchyards, are in

use by USEC. The deferred work will be addressed during the final

decontamination and decommissioning of the plant after its closure.
Appendix I

Cleanup Plan Focuses on Six Major

Categories of Effort

Page 40 GAO/RCED-00-96 Paducah Cleanup Plan

DOE has employed an innovative technology to remediate some of the

most heavily contaminated soil. As a result of past cylinder drop-testing

operations at one area on the site, about 1.7 acres in size, an estimated 430

gallons of TCE leaked into the site’s shallow soil and groundwater. At this

area, to reduce the potential for contaminant migration, DOE conducted

demonstrations from 1995 through 1997 of an innovative technology called

LASAGNA.1 This technology uses electroosmosis to move shallow

groundwater and contaminants through in-ground treatment zones. (The

technology is named for its layered structure of electrodes and treatment

zones.) In demonstrations, the LASAGNA technology reduced TCE

concentration levels from hundreds of parts per million to less than 2 parts

per million. DOE selected LASAGNA for full-scale remediation of the area,

and the LASAGNA cleanup is expected to be completed by 2003.

DOE’s other planned activities include conducting additional assessments

and excavating and disposing of contaminated soils. The additional

assessments are to be completed by 2005 at a cost of about $8.7 million.

DOE plans to excavate about 35,000 cubic yards of soil, at average depths

of 1 to 3 feet, but as deep as 16 feet when necessary. The total surface soil

cleanup is expected to be completed by 2007 at a cost of about $19 million.

Several Burial Grounds

Are Planned to Be

Excavated

DOE’s cleanup plan includes estimates for excavating the material from 4

of its 12 burial grounds, and DOE is contemplating the excavation of a fifth

burial ground. DOE considers the other burial grounds to pose less of a

risk—these other burial grounds include closed landfills that are included

in DOE’s long-term monitoring program. Previous investigations of two

burial grounds identified a variety of contaminants, including uranium,

PCBs, arsenic, benzene, beryllium, cadmium, copper, nickel,

tricholoroethene, toluene, and zinc. DOE’s cleanup plan estimates

approximately $535 million for the cleanup of these areas with a

completion date of 2010. The majority of these costs stem from the cost of

disposing of the excavated material.

1

The term LASAGNA has been trademarked by Monsanto.
Appendix I

Cleanup Plan Focuses on Six Major

Categories of Effort

Page 41 GAO/RCED-00-96 Paducah Cleanup Plan

DOE made a preliminary assessment of the risk posed to worker safety and

the environment for each of 12 burial grounds at the Paducah site and

divided them into three risk categories—principal threat, moderate threat,

and low threat. This assessment was the result of discussions between

DOE, EPA, and Kentucky officials that began in November 1999. DOE

designated four of the burial grounds, and a portion of another, as posing a

principal threat to worker safety and the environment—the current

cleanup plan includes estimates for excavating these areas. The estimated

contents of one of the principal-threat burial grounds include 270 tons of

uranium (most of it pyrophoric), 59,000 gallons of oils, and 450 gallons of

trichloroethene.2 DOE has designated three other burial grounds as posing

a moderate threat, including one that DOE is still considering excavating. 3

The cleanup plan includes placing a protective cap over these areas to

mitigate the spread of contamination. DOE designated the remaining five

burial grounds as low threat—three of these burial grounds are closed

landfills that have a protective cap and are under DOE’s long-term

monitoring program; a protective cap is planned for the fourth burial

ground, and the fifth burial ground is the site’s operating landfill.

About 52,000 Barrels of

Waste Require

Treatment and

Disposal

Paducah has the equivalent of 52,000 55-gallon barrels of waste stored in

various locations on the site. Most of the barrels contain materials that

have a low level of radioactivity. To date, DOE has been assessing the

contents of the barrels and containers. Since 1990, DOE has shipped from

the site the equivalent of 754 barrels of low-level waste. DOE’s plan calls for

disposing of the waste off-site after it has been characterized and treated or

repacked if necessary.

2

This pyrophoric uranium, which has a tendency to spontaneously combust in the presence

of oxygen, was usually placed in drums with petroleum-based or synthetic oils used to

stabilize the waste.

3

DOE also designated the 65,000 tons of scrap metal being addressed under the surface

water portion of the cleanup plan as a moderate threat. The cleanup plan includes estimates

for placing a protective cap over these areas.
Appendix I

Cleanup Plan Focuses on Six Major

Categories of Effort

Page 42 GAO/RCED-00-96 Paducah Cleanup Plan

The majority of the 52,000 barrels of waste were generated before the

production facilities were leased to USEC, but some waste continues to be

generated by DOE’s cleanup activities. The 52,000 barrels are located

throughout the site and contain a variety of waste (radioactive and

hazardous). More than 12,400 barrels of low-level waste are stored outside

and are in deteriorating condition.4 There are about 20,300 barrels of mixed

low-level waste, consisting mainly of PCB waste, and 31,200 barrels of lowlevel waste, which is mainly soil and debris.5 In addition, Paducah has 21

barrels with higher levels of radioactivity (called transuranic waste). The

site also has about 142 metric tons of hazardous waste, some of which must

be incinerated and cleaned of radioactive contamination before it can be

shipped off-site.

Federal law and regulations require that the barrel contents be identified

for proper storage and disposal. The characterization of waste in barrels

has been completed for on-site storage and for the waste barrels that have

been shipped to off-site facilities for disposal. But 1,760 barrels require

additional characterization to meet a recent EPA storage requirement.

DOE currently plans to ship off-site all waste that cannot be put in the onsite landfill. Additional characterization is needed for over 42,000 barrels of

mixed and low-level waste before they can be treated and shipped off-site.

DOE has estimated that about 80 percent of its waste will meet the waste

acceptance criteria of a private waste disposal contractor (Envirocare, in

Utah) and that only the remaining wastes that exceed these criteria will

likely be sent to DOE’s Hanford facility in Washington State.

DOE revised the cleanup plan to accelerate the removal of certain wastes

by fiscal year 2006. As a part of this action, it gave priority removal of lowlevel waste stored outdoors. Because of the deteriorated condition of some

of these barrels, DOE has determined that it will be necessary to repack

some of them before they can be shipped off-site. The disposal of the 52,000

barrels is expected to be completed in 2010 at a cost of $228 million. DOE’s

4

DOE’s October 1999 report identified the equivalent of approximately 8,500 55-gallon

barrels of waste stored outdoors. During our review, DOE identified another approximately

3,900 barrels of waste stored outdoors.

5

A Becthel Jacobs official responsible for waste management explained that these figures

might be underestimated because the waste is stored in a variety of containers, and he had

to calculate the barrel equivalents. He recommended that we use 52,000 barrels for the total

stored on site.
Appendix I

Cleanup Plan Focuses on Six Major

Categories of Effort

Page 43 GAO/RCED-00-96 Paducah Cleanup Plan

lifecycle baseline also includes a demonstration project to treat, before

disposal, some of the waste that contains both hazardous materials and low

levels of radioactive materials. This assumption is predicated on the

successful use of the technology, permitting of the project, and an

assessment of its environmental impact. The project is currently on hold;

however, by the end of fiscal year 2002, the cleanup plan calls for the

demonstration project to treat about 865 cubic meters of waste.

Plan Includes

Monitoring and

Maintaining

the Site and Removing

Two Contaminated

Buildings

DOE’s cleanup plan includes monitoring and maintaining the site area and

facilities before, during, and after remedial activities and continuing to

monitor as necessary to support future cleanup actions. As part of the

monitoring and maintenance activities, the plan calls for demolishing two

contaminated, unused buildings on the site.

The two contaminated buildings were originally used to produce the

uranium materials and to fabricate metal. The buildings were transferred

from DOE’s Office of Nuclear Energy to its Office of Environmental

Management several years ago. General maintenance has been done on the

buildings; however, a recent DOE investigation found that large volumes of

low-level waste are stored inside the buildings and that contamination

within the buildings is spreading.

In December 1999, DOE decided to include in the cleanup plan the

decontamination and demolition of the two buildings. DOE estimates that

$92 million will be needed to remove these buildings by 2008.

As part of DOE’s long-term stewardship responsibilities, monitoring and

maintenance activities will continue long past the 2010 cleanup completion

target. The costs for this long-term stewardship are not included in the $1.3

billion cleanup estimate. Planned long-term activities include routine

maintenance activities, such as mowing grass, replacing signposts,

maintaining groundwater monitoring wells, repairing fences, and

conducting and reporting on periodic inspections. DOE officials said that

long-term stewardship could continue through 2070.
Page 44 GAO/RCED-00-96 Paducah Cleanup Plan

Appendix II

Comments From the Department of Energy ApendxiI
Appendix II

Comments From the Department of Energy

141396 Letr Page 45 GAO/RCED-00-96 Paducah Cleanup Plan
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