Nuclear Waste: Plans for Addressing Most Buried Transuranic Wastes Are Not Final, and Preliminary Cost Estimates Will Likely Increase
Published: 2007-06-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Since the 1940s, the development of nuclear weapons technologies has generated transuranic wastes--materials contaminated by certain man-made radioactive elements. These wastes can remain dangerous for thousands of years. Until 1970, the Department of Energy's (DOE) predecessors buried these wastes in shallow pits and trenches. Today, state officials and communities near DOE's major disposal sites have expressed concerns that such wastes might contaminate important ground and surface water resources. GAO was asked to (1) determine the legal requirements and policies affecting DOE's efforts to address transuranic wastes buried before 1970, (2) determine what DOE is doing to address sites where these transuranic wastes are buried, and (3) assess the reliability of DOE's estimated costs to address these sites. We met with federal and state officials at five DOE sites containing buried transuranic wastes, reviewed environmental laws and guidance, and obtained buried waste cleanup cost estimates from each site. In commenting on this report, DOE generally agreed with our findings, and provided some clarifying comments.
section_title: What GAO Found
paragraphs: Cleanup agreements with federal and state agencies require DOE to investigate and clean up the five major DOE sites where transuranic and other hazardous wastes were buried. While DOE has long considered pre-1970s buried wastes permanently disposed, in 1989, the sites where most of these wastes are buried were listed as "Superfund" sites subject to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). CERCLA requires that DOE determine the nature and extent of contamination at each waste site and determine what cleanup action, if any, is needed to protect human health and the environment. All five disposal sites are scheduled to have cleanup completed by 2025. DOE is addressing the transuranic wastes buried at two sites, but it is still investigating cleanup options at the other three locations. At Oak Ridge and Savannah River, DOE is leaving the transuranic wastes in place under an earthen cap designed to prevent the wastes from migrating and taking steps to prevent animal and human access to the sites. In contrast, DOE is still investigating cleanup options at the Idaho National Laboratory, the Hanford Site, and the Los Alamos National Laboratory--where about 90 percent of DOE's transuranic wastes are buried. DOE has begun to remove a small amount of waste at the Idaho and Hanford sites, but how much buried transuranic wastes eventually will be removed or treated in place at these sites is currently undetermined. DOE's preliminary estimate of the cost to address the five waste sites where transuranic wastes are buried is about $1.6 billion in 2006 dollars, but the estimate is likely to increase for several reasons. For example, the estimates reflect the costs of leaving most waste under earthen barriers--typically the least expensive approach. If DOE is required to retrieve substantial portions of these wastes, costs would increase dramatically. In addition, the estimates exclude unknown costs, such as the cost of disposing wastes off-site, if necessary. For example, DOE's lifecycle cost estimate to remove transuranic wastes buried near the Columbia River at the Hanford site could triple once options and costs for disposal are fully evaluated. As DOE further evaluates the risks, benefits, and costs of cleanup options, its policies require it to improve the reliability of cost estimates. Thus, GAO is not making recommendations at this time.

section_title: Letter
paragraphs: Since the 1940s, the Department of Energy (DOE) and its predecessors  have operated a nationwide complex of facilities used to research, design,  and manufacture nuclear weapons and related technologies. While these  activities are important for national defense, they have left a legacy of  radioactive and other hazardous wastes that have contaminated or could  contaminate the environment. Among them is a large quantity of  transuranic wastes—typically, discarded rags, tools, equipment, soils, or  other solid materials that have been contaminated by man-made  radioactive elements, such as plutonium or americium. Transuranic wastes  remain radioactive for extremely long periods—hundreds of thousands of  years, in some cases. Inhaling or ingesting even miniscule quantities of  some transuranic elements can cause cancer in humans.
According to DOE, the department has buried or stored approximately  238,000 cubic meters of transuranic wastes (equal to the volume of about  100 Olympic-sized swimming pools) at its sites. About 111,000 cubic  meters of these wastes were generated mostly after 1970, and then stored  at various locations with the bulk of these wastes intended for transfer to  the Waste Isolation Pilot Plant (WIPP)—a deep geologic repository in New  Mexico designed for permanent disposal of transuranic wastes. The other  127,000 cubic meters of transuranic wastes were disposed of, generally  before 1970, when DOE buried these wastes in shallow pits and trenches,  often with other radioactive and hazardous wastes. DOE estimates that  most of these transuranic wastes are buried at its Hanford Site in  Washington state and the Idaho National Laboratory, while almost all of  the remaining transuranic wastes are buried at the Los Alamos National  Laboratory in New Mexico, the Oak Ridge National Laboratory in  Tennessee, and the Savannah River Site in South Carolina.
In addition to the threats that buried transuranic wastes may pose, the  other radioactive and hazardous wastes buried with them may pose  additional threats. Some of these wastes emit skin-penetrating radiation  and cannot be directly handled by humans. Other wastes, such as organic  solvents and toxic metals, are volatile. In some cases, these wastes can  migrate readily through soil, especially if exposed to water, and may  contaminate surface waters and groundwater.
Given the potential long-term threat that buried transuranic and other  radioactive and hazardous wastes may pose to human health and the  environment, including their potential to contaminate water resources,  state environmental protection officials and communities adjacent to these  disposal sites have expressed concerns about these wastes. You asked us  to (1) determine the legal requirements and policies governing DOE’s  efforts to address transuranic wastes buried before 1970, (2) determine  what DOE is doing to address sites where these transuranic wastes are  buried, and (3) assess the reliability of DOE’s estimated costs to address  these sites.
To conduct our work, we visited the five DOE sites that contain most of  DOE’s transuranic wastes buried before 1970. We met with local DOE  officials at these five largest burial sites, which include the Hanford Site,  the Idaho National Laboratory, the Los Alamos National Laboratory, the  Savannah River Site, and the Oak Ridge National Laboratory. To determine  the legal requirements and policies governing DOE’s efforts to address its  buried transuranic wastes, we reviewed federal environmental laws and  regulations; DOE guidance concerning hazardous and radioactive wastes;  Federal Facility Agreements and Orders; a May 2006 federal district court  decision; and internal DOE, federal, and private studies on the storage and  disposition of transuranic wastes. To better understand these laws,  regulations, agreements, and policies we interviewed state environmental  protection officials and Environmental Protection Agency (EPA) officials  that oversee each of the buried waste locations. To determine what DOE is  doing to address sites where transuranic wastes are buried, we reviewed  waste cleanup planning documents that DOE prepared for these sites. In  this context, we also interviewed scientific experts, DOE site project  managers, state environmental regulatory officials, and EPA officials  providing management and oversight at buried waste locations. Finally, to  assess the reliability of DOE’s estimates of the cost of addressing sites  where transuranic wastes are buried, we analyzed each DOE field  location’s fiscal year 2006 estimates for projects that included cleaning up  buried transuranic wastes. A more detailed description of our scope and  methodology is presented in appendix I. We performed our work between  May 2006 and May 2007 in accordance with generally accepted  government auditing standards.
subsections: section_title: Background
paragraphs: DOE’s current and former nuclear weapons complex includes dozens of  sites nationwide containing nuclear reactors, chemical processing  buildings, plants, laboratories, and maintenance facilities that  manufactured thousands of nuclear warheads and together conducted  more than one thousand nuclear explosion tests. The environmental  legacy of nuclear weapons production includes contaminated buildings,  soils, water resources, and large volumes of radioactive and hazardous  wastes that require treatment, stabilization to prevent migration, and  disposal. DOE estimated in 2006, that the future cost to clean up, dispose,  and provide long-term oversight of all wastes will be more than $230  billion over the next 75 years.
Among the sites requiring environmental cleanup are the five sites  addressed in this report. The Hanford Site is located on the arid east side  of Washington state near Richland and adjacent to the Columbia River.  The site was established to produce plutonium for nuclear weapons during  World War II and, according to DOE, subsequently produced the majority  of the nation’s plutonium during the Cold War. The Idaho National  Laboratory, located near Idaho Falls in the southeastern Idaho desert, was  established in 1949 as the National Reactor Testing Station and was the  site of the largest concentration of nuclear reactors—52—in the world.  Los Alamos National Laboratory, located in a mountainous area of  northern New Mexico, was established in 1943 and played a central role in  researching the advanced technologies required for nuclear weapons  manufacture. It is where the first atomic bomb was assembled. The Oak  Ridge National Laboratory near Knoxville, Tenn., was established in 1943  to pilot the processing of uranium during World War II. The Savannah  River Site, near Aiken, S.C., was built in the 1950s to produce basic  materials needed in nuclear weapons manufacture, such as tritium and  plutonium.
DOE’s Office of Environmental Management is responsible for cleaning up  contamination left behind at these sites after decades of nuclear  production and research. Environmental management officials at DOE  field sites plan and oversee the cleanup activities at those sites, but the  work itself is carried out primarily by private firms contracted by DOE.  Officials from EPA, as well as environmental agency officials from the  states in which DOE sites are located, enforce federal and state  environmental laws and oversee and advise DOE on its cleanup efforts.
Transuranic elements, which have an atomic weight greater than uranium,  are man-made radioactive elements produced in nuclear reactors.  Transuranic wastes are created when materials such as clothing and tools  come into contact with plutonium and other transuranic elements during  processing activities and cannot be reused for other purposes. They were  first generated during operations to produce and recover plutonium for  nuclear weapons manufacture and are still being produced in small  quantities at laboratories where nuclear research continues today. Federal  law currently defines transuranic waste as waste containing more than 100  nanocuries of alpha-emitting transuranic elements (radiation) per gram  and with half-lives greater than 20 years with certain exceptions. A half- life is the amount of time required for an element to decay by half, and  nanocuries are a measure of radioactivity. Alpha-emitting radiation cannot  pass through objects, including human skin, but is extremely dangerous if  inhaled or ingested. Some buried wastes contaminated with transuranic  elements may not meet the current legal definition of transuranic wastes.  For ease of discussion in this report, however, we refer to these wastes as  buried transuranic wastes.
section_title: Cleanup Agreements Require DOE to Address Sites Where Transuranic Wastes Are Buried
paragraphs: The cleanup agreements DOE entered into with federal and state  environmental agencies require DOE to investigate and take action as  necessary to clean up sites where transuranic and other wastes were  buried. The legal and regulatory framework governing management and  disposal of transuranic wastes has changed significantly over the past 50  years, particularly in 1970. Before 1970, there was no separate category for  what is now defined as transuranic waste. Consequently, the federal  government managed this waste as low-level radioactive waste, which it  buried along with hazardous wastes in unlined, shallow pits and trenches,  as shown in figure 1.
In 1970, in response to concerns that transuranic elements remain  radioactive for an extremely long time and scientific research  recommending deep geologic disposal for this waste, the Atomic Energy  Commission––a DOE predecessor––directed sites that generated  transuranic wastes to begin segregating them from other wastes and  storing them in retrievable packages for an interim period of 20 years,  pending disposal in a repository. In late 1979, Congress authorized DOE to  develop a deep geologic repository in New Mexico to permanently dispose  of transuranic wastes, including these stored transuranic wastes. In  October 1992, Congress gave DOE management responsibility for the land,  and gave EPA substantial responsibility for regulating many of DOE’s  activities at the repository. This repository, known as the Waste Isolation  Pilot Plant (WIPP), began operating in the late 1990s and, in 1999, received  its first shipment of transuranic wastes generated after the 1970 directive  to segregate and store such wastes.
The Atomic Energy Commission’s 1970 directive did not apply to  transuranic wastes buried prior to 1970, and DOE considered these wastes  permanently disposed. However, the sites where these wastes are buried  have since become subject to CERCLA and other environmental laws. In  particular, section 120 of CERCLA requires EPA to evaluate federal waste  sites for possible inclusion on the National Priorities List. In 1989, EPA  included on this list, the waste sites that contain most of DOE’s buried  transuranic wastes—Hanford, Idaho, Oak Ridge, and Savannah River.  With this designation, CERCLA requires DOE to evaluate the nature and  extent of contamination at these sites and determine what cleanup  actions, if any, are necessary to protect human health and the  environment. The buried transuranic waste sites at Los Alamos were  evaluated but were not placed on the list. Cleanup of Los Alamos is being  carried out under other authorities. At Los Alamos, the cleanup is being  conducted under agreements with New Mexico—implementing the  Resource Conservation and Recovery Act of 1976, as amended (RCRA)  and state law—and under DOE’s Atomic Energy Act authority. The  provisions of the Los Alamos cleanup agreements are similar to those  under CERCLA requirements, including a schedule for conducting the  cleanup. Los Alamos has multiple waste sites that contain buried  transuranic wastes, and DOE’s agreements with the state of New Mexico  address each waste area separately.
To carry out the cleanup of its National Priorities List sites under  CERLCA, DOE must follow a process that includes extensive consultation  between DOE, EPA, and state environmental agencies, as well as  opportunities for public participation, to reach a decision on how DOE  should clean up the respective site. The process begins with DOE  consulting EPA and state environmental agencies and investigating the  nature and extent of contamination at each site and undertaking a  feasibility study to identify and evaluate possible approaches for cleaning  up each site. After evaluating the approaches, DOE selects a “preferred  alternative” that meets CERCLA requirements and presents, for public  comment, a proposed plan explaining its preferred approach for cleaning  up the wastes. DOE considers the public’s comments and consults with  EPA and the state environmental agency to determine a cleanup approach.
Once the parties have reached agreement, the approach and the rationale  for selecting it are published in a legally binding Record of Decision. In  addition, DOE must enter into an interagency agreement with EPA that  includes, among other things, a schedule for completing cleanup of the  site. The environmental agency in the affected state is also a party to the  agreements for Hanford, Idaho, Oak Ridge, and Savannah River. If the  selected cleanup approach will involve leaving hazardous substances at  the site, DOE must monitor the effectiveness of the approach and review  the action every 5 years to determine whether any additional actions are  necessary to protect human health and the environment. The provisions  of the agreements, including the milestones, are legally enforceable and  can be revised, as necessary, to incorporate new information and address  changing conditions. As shown in table 1, DOE is currently scheduled to  complete cleanup actions at all five sites by 2025.
section_title: DOE Is Containing Buried Transuranic Wastes in Place at Two Sites but Is Still Developing Cleanup Plans at the Largest Waste Sites
paragraphs: DOE has made cleanup decisions and is addressing transuranic wastes at  Oak Ridge and Savannah River, but the department is still investigating  cleanup options at the other three locations where most of DOE’s  transuranic wastes are buried. DOE plans to leave transuranic wastes  buried at Oak Ridge and Savannah River in place under an engineered  barrier and take additional measures to prevent intrusions that could  expose humans and the environment to the buried contaminants. In  contrast, DOE is still evaluating cleanup options at the Idaho National  Laboratory, Hanford Site and Los Alamos National Laboratory, where  about 90 percent of its buried transuranic wastes are located. The extent  to which DOE will be required to retrieve buried wastes or will be allowed  to manage these wastes in place is currently unknown, and cleanup  decisions for the majority of these wastes are several years away.  However, DOE has agreed to retrieve some of the wastes buried at  Hanford and Idaho, because the wastes may threaten nearby surface  waters and groundwater.
subsections: section_title: Cleanup Agreements at Oak Ridge and Savannah River Call for Containing Buried Transuranic Wastes in Place
paragraphs: In accordance with CERCLA’s requirements, DOE evaluated a number of  approaches for addressing transuranic wastes buried at Oak Ridge and  Savannah River. At both sites, DOE had originally disposed of the wastes  in near-surface burial pits and trenches, often with other radioactive or  hazardous wastes, including cesium, strontium, and volatile organic  compounds. The two sites contain about 10 percent of the estimated  127,000 cubic meters of transuranic wastes buried across the five DOE  sites. DOE officials at both sites considered several cleanup options,  ranging from managing the wastes in place to removing them from the  ground and disposing of any exhumed transuranic wastes at WIPP.
DOE, EPA, and state environmental agencies at both sites agreed that  DOE should manage the buried wastes in place, because doing so would  be equally or more protective of human health and the environment, and  less costly than removing the wastes. Because DOE lacked adequate  information on the specific location, condition, or concentration of the  wastes in the burial sites, DOE and environmental agency officials said  they were concerned that workers attempting to remove buried wastes  would expose themselves to harmful contaminants or release  contaminants into the environment. DOE and environmental agency  officials told us that without adequate information on the location,  condition or concentration of the wastes, efforts to mitigate the risks  associated with retrieving the wastes would have been costly, requiring  specialized enclosures for the waste areas, protective suits for workers,  frequent rotation of workers to minimize their potential exposure, or other  measures. According to these officials, attempts to determine the specific  locations and other characteristics of the buried contaminants would  likely expose workers and the environment to these same risks, because  workers would be required to dig into the burial grounds in order to  sample buried wastes. Furthermore, the officials were concerned that  sampling buried wastes would not yield reliable information.
As a result, DOE, EPA, and state environmental agencies at the two sites  agreed that DOE should manage the wastes in place by constructing  engineered barriers over the top of the burial grounds and implementing  additional controls to limit access to the burial grounds and help ensure  the barriers’ effectiveness. The barriers’ overall purpose is to prevent  rainwater, animals, or other intrusions from entering the burial ground and  potentially causing wastes to migrate into the air, groundwater, or nearby  surface waters. Barriers are generally composed of multiple layers of  earthen and synthetic materials (see fig. 2), depending on the site-specific  conditions. Surface vegetation and soil function to absorb moisture,  promote evaporation, and prevent water from filtering down to the wastes  beneath the barrier. A diversion ditch carries surface water away from the  waste site. Layers of rock, clay, and synthetic fabrics redirect moisture  away from the buried wastes—and protect the wastes from burrowing  animals.
Olope (-%)
DOE finished constructing the engineered barriers at Oak Ridge in  September 2006 and expects to complete construction at Savannah River  by summer 2007 (see fig. 3). The Oak Ridge barriers are considered an  interim measure under CERCLA, in part because DOE and the state are  still assessing the conditions under which long-lived radioactive wastes,  including transuranic wastes, should be permanently disposed of in-place.  DOE officials at Oak Ridge said they expect a final cleanup decision by  2015, at which time additional remedial actions to address the buried  transuranic wastes could be required.
In addition to the barriers, DOE plans to establish physical and long-term  administrative controls at the two sites aimed at limiting access to areas  where buried wastes were left in place. For example, DOE plans to install  perimeter fencing and gates at both sites and restrict activities to  maintenance of the engineered barriers. DOE also plans to prohibit certain  types of land uses in these areas, such as residential use. It will transfer  land-use restrictions at Savannah River to any future occupants, should  the federal government decide to sell or lease land that includes the burial  grounds. Furthermore, DOE officials from both sites will evaluate and  repair the cap, as needed, and provide physical controls or sampling of the  groundwater or surface waters in these areas for evidence of  contamination. DOE conducts formal reviews of the barriers and related  controls every 5 years. If EPA determines the measures are not fully  effective, DOE may be required to take further actions, including removing  some or all of the buried wastes.
section_title: DOE Is Still Developing Cleanup Plans at the Three Locations Where Most Transuranic Wastes Are Buried, but Some Waste Removal Is Already Under Way
paragraphs: DOE is still evaluating cleanup options for most of the waste at the three  remaining sites––the Hanford Site, the Idaho National Laboratory, and the  Los Alamos National Laboratory––where about 90 percent of DOE’s  transuranic wastes are buried.
subsections: section_title: Hanford Site
paragraphs: The Hanford Site contains about 66,700 cubic meters of buried transuranic  wastes, or about 53 percent of DOE’s total inventory of such wastes. These  wastes were primarily disposed of in trenches in a 272-acre area located in  the central portion of the site and near the Columbia River. DOE is in the  early stages of site investigations to determine the extent and type of  contamination for most of its burial sites, and according to DOE, the  department is scheduled to evaluate cleanup options and determine its  preferred cleanup approach by 2013. However, DOE officials said that  about 1,100 of the estimated 66,700 cubic meters of buried transuranic  wastes are located in another area of the Hanford site closer to the  Columbia River than other sites. In 2001, DOE agreed to remove the  transuranic wastes buried in this area, as part of an interim effort to  mitigate a plume of tritium, a radioactive (but not transuranic)  contaminant that is migrating and could contaminate the Columbia River.  Cleanup is scheduled for completion by 2012. Overall, although a cleanup  decision for most of Hanford’s buried transuranic wastes is years away,  EPA and Washington state environmental officials have expressed  concern that leaving much of the buried transuranic and other hazardous  wastes in place under engineered barriers––even with additional controls  to limit intrusion––may not provide adequate long-term protection for  human health and the environment, and some removal of these wastes  may be necessary. Citizen groups, such as the Hanford Advisory Council  expressed similar concerns regarding the risks of leaving long-lived  radioactive wastes, such as transuranic wastes, in place.
section_title: Idaho National Laboratory
paragraphs: The Idaho National Laboratory contains about 36,800 cubic meters of  buried transuranic wastes, or about 29 percent of DOE’s inventory of such  wastes. DOE officials at the Idaho site have prepared a draft feasibility  study identifying possible alternatives for cleaning up the subsurface  disposal area—a 97-acre area where transuranic, as well as other  radioactive and hazardous wastes, are buried—which the department  submitted to EPA and state environmental officials for review in March  2007. The alternatives described in the draft study ranged from containing  most of the buried wastes in place under an engineered barrier to  retrieving some or all of the wastes and permanently disposing of the  transuranic portion at WIPP. DOE, EPA, and the state environmental  agency are scheduled to document the selected cleanup approach in a  record of decision by 2008. In 2005, DOE began removing some  transuranic and other wastes buried in a 3-acre section of the 97-acre  disposal area. DOE agreed to remove the wastes to prevent the  contaminants from migrating to the Snake River aquifer, a drinking water  source located about 580 feet below the disposal area.
Although a cleanup approach has not yet been determined for most of the  97-acre disposal area, DOE may be required to remove a significant  portion of the buried transuranic wastes that remain. DOE and Idaho state  officials have a long-standing disagreement regarding the amount of  transuranic wastes that DOE had agreed to remove from the Idaho site  under a 1995 settlement agreement with the state, in a case concerning  shipments of spent nuclear fuel into Idaho. The state of Idaho  subsequently sought to enforce terms of the agreement in court, and in  2006, a federal district court ruled that DOE is obligated under the  agreement to remove all the transuranic wastes at the Idaho National  Laboratory site. DOE has appealed the district court’s decision, but, in  accordance with CERCLA requirements and the cleanup agreement for the  site, the department is continuing to work with EPA and the state  environmental agency to decide on a cleanup approach for most of the  wastes buried at the site.
section_title: Los Alamos National Laboratory
paragraphs: Los Alamos National Laboratory has about 12,000 cubic meters of buried  transuranic wastes, or almost 10 percent of DOE’s inventory of such  wastes. These wastes, which also include hazardous wastes, such as  volatile organic compounds, according to DOE, are in four disposal areas  that comprise about 85 acres of the Los Alamos site. DOE is currently  conducting site investigations to determine the extent and nature of  contamination at the disposal areas and plans to evaluate cleanup options  for those areas.
Unlike the other four DOE sites containing buried transuranic wastes, Los  Alamos was not included on the National Priorities List and, therefore,  transuranic wastes buried there are not being addressed through the  CERCLA process. Instead, cleanup of the buried waste sites is being  carried out under a combination of other federal and state environmental  laws and internal DOE orders.
Hazardous wastes buried at Los Alamos are being addressed through  RCRA. RCRA requires owners and operators of facilities that treat, store,  or dispose of hazardous wastes to obtain a permit from EPA, or an  authorized state, specifying how the facilities will safely manage that  waste. RCRA further authorizes EPA (or an authorized state) to require  facilities holding or seeking permits to clean up contamination at those  facilities. As provided under RCRA, EPA has authorized New Mexico to  carry out a RCRA hazardous waste program under state law in lieu of the  federal program. The cleanup process under the RCRA program is  generally similar to CERCLA, including an investigation of contaminated  areas and evaluation of cleanup options to select a cleanup approach.
DOE will address radioactive wastes, which have been commingled with  hazardous wastes at Los Alamos, under provisions of the Atomic Energy  Act of 1954, as amended, which allows DOE to direct the process of  investigating and cleaning up radioactive contamination according to its  own regulations and internal directives. DOE has an agreement with the  state environmental agency that it would investigate its buried waste sites  containing transuranic wastes by 2006 and complete any cleanup actions  by 2015.
section_title: Estimated Costs to Address Waste Disposal Areas in Which Transuranic Wastes Are Buried Will Likely Increase
paragraphs: DOE’s preliminary cost estimates for addressing the five waste sites where  transuranic and other hazardous wastes have been buried total about $1.6  billion (in fiscal year 2006 dollars). Because these wastes are commingled,  the cost of addressing just the buried transuranic wastes cannot be  separately determined. DOE’s estimates are based on the costs of  managing most of these wastes in place rather than removing them for off- site disposal. However, DOE cautions these estimates are preliminary and  not entirely reliable because some wastes may need to be retrieved and  disposed of off-site, which would increase costs substantially. In addition,  some costs are not included because they are not yet known. As DOE  moves these projects forward to further evaluate its various cleanup  options, DOE’s policies require it to revise cost estimates, accordingly.
subsections: section_title: DOE Has Developed Cost Estimates to Address Geographic Areas Containing Transuranic and Other Waste
paragraphs: DOE has not separately estimated the costs to address only buried  transuranic wastes, but estimates that the costs to address the burial  grounds in which transuranic and other hazardous wastes have been  disposed are about $1.6 billion through 2035. The specific costs associated  with addressing only transuranic wastes cannot be determined because  DOE’s Office of Environmental Management, which is charged with  cleaning up the disposal areas that include transuranic wastes, defines  cleanup projects by geographic waste disposal areas, rather than by  contaminant types. This is because many types of wastes and  contaminants were disposed together in a specific geographic area; and in  general, the Office of Environmental Management intends to address  various wastes buried in each geographic disposal area as a group. The  estimates to address the burial grounds reflect the “lifecycle” of each  project—that is the total estimated expenditures for all aspects of  managing a cleanup project from start to finish. These cost estimates are  reported in DOE’s annual budget request to the Congress and comprise a  portion of DOE’s environmental liabilities estimate included in its annual  financial statement.
As shown in table 2, DOE’s estimated lifecycle baseline costs to address  the burial grounds containing transuranic wastes range from $36 million at  the Savannah River Site—where officials are in the final stages of  completing construction of a cap to contain the wastes—to $1 billion at  the Idaho National Laboratory, where DOE has begun to remove selected  wastes for disposal off-site, but is still evaluating options to address most  of the remaining buried waste.
section_title: Cost Estimates Are Preliminary and Likely Understate the Actual Cost of Addressing Buried Wastes
paragraphs: DOE’s lifecycle cost estimates for addressing buried waste sites are  preliminary because DOE is still evaluating and choosing cleanup options  for the majority of its buried waste, and some of the probable costs  associated with cleanup efforts are currently unknown. DOE has stated  that it is only 50 percent confident that its lifecycle estimates accurately  reflect the costs of addressing buried waste sites. DOE’s estimates will  likely increase, perhaps substantially, for several reasons.
First, the estimates are based upon treatment and remedy assumptions  that may be different from the final cleanup decision. The estimates are  based on DOE’s assumption that it will manage most of the buried wastes  in place under engineered barriers and will monitor these barriers’  effectiveness for as long as necessary to ensure protection of human  health and the environment. This is typically the lowest-cost approach for  addressing buried waste. DOE cost estimates are preliminary until an  actual cleanup decision has been reached, at which time the cost estimates  are revised to reflect that decision. If DOE is required to retrieve  substantial portions of the buried transuranic wastes and dispose of it off- site at WIPP or elsewhere, costs could increase dramatically. For example  if DOE must retrieve all the buried transuranic from the Idaho National  Laboratory site, the department estimates that costs would increase from  about $1 billion to about $8.2 billion. According to DOE, the substantially  higher costs are the result of activities to excavate wastes and the  associated construction and operation of new facilities to treat and  dispose of formerly buried wastes and new wastes created by the retrieval  process.
Second, the authorized capacity of the WIPP is currently insufficient to  allow emplacement of large volumes of buried transuranic wastes beyond  those being exhumed at the Idaho site. Specifically, WIPP is statutorily  authorized to receive a maximum of 175,600 cubic meters of transuranic  wastes. The majority of that capacity has been reserved for about 108,000  cubic meters of transuranic wastes that were generated and placed in  storage at various DOE sites after 1970 and had not yet been emplaced at  WIPP as of 2002, the most recent year for which data are available. About  8,000 cubic meters of waste had already been emplaced at WIPP by 2002.  Wastes DOE has agreed to exhume from the Idaho National Laboratory  are expected to consume another 17,000 cubic meters of WIPP capacity. In  addition, DOE expects to generate about 17,000 cubic meters of additional  transuranic wastes from future nuclear research and waste cleanup  activities, and these wastes also are intended for disposal at WIPP. In total,  DOE estimates that stored wastes, newly generated wastes and the wastes  being exhumed currently at Idaho together will consume about 150,000  cubic meters of WIPP’s authorized capacity, leaving only about 25,600  cubic meters for disposal of other transuranic wastes. DOE has estimated  that if current plans to manage most wastes in place change and buried  transuranic wastes across the weapons complex must be exhumed and  disposed of off-site, up to 85,000 additional cubic meters could potentially  require disposal at the WIPP. Developing alternative disposal paths for the  estimated 60,000 cubic meters of transuranic wastes exceeding current  WIPP capacity could further increase costs.
Third, other assumptions DOE has incorporated into its cost estimates  may also be incorrect, causing DOE’s cost estimates to increase. For  example, DOE’s preliminary cost estimates assume that installing a barrier  over one of the Los Alamos burial grounds will safely contain buried  wastes. However, DOE reports that if further analysis shows this  assumption is incorrect and a more complex solution, such as grouting or  vitrification is required, then cost estimates would increase significantly.  Grouting is a process that uses concrete to bind wastes together and  impede their migration through soil. Vitrification immobilizes the wastes in  glass. At two other locations, DOE has assumed that federal and state  regulators will not require further characterization or excavation.  However, if additional characterization is required, DOE reports that costs  could increase.
Finally, DOE has not included in its estimate some probable cost amounts  that are currently unknown. For example, at DOE’s Hanford site, highly  radioactive and hazardous wastes were buried under 10 to15 feet of earth  in vertical pipes and other containers at a site that is near the Columbia  River. DOE has reported that the lifecycle cost to remove these wastes is  about $113 million. However, according to DOE’s Inspector General, this  estimate does not include all potential costs to store, monitor, and dispose  of this waste once it has been removed, which could increase the cost to  more than $300 million. According to DOE officials, DOE had not yet  evaluated methods for retrieving and disposing of the waste and, as a  result, the costs for these actions were unknown. In addition, both  Hanford and the Idaho National Laboratory lifecycle cost estimates  exclude administrative costs and management fees that will eventually be  negotiated with the private firms contracted to manage the cleanup effort.
Since contracts have not yet been awarded for much of the buried waste  cleanup, those costs have yet to be determined.
As DOE moves forward to further evaluate the risks, benefits, and costs of  various buried waste cleanup options, DOE’s cost estimating and project  management policies expect staff to refine the estimates.According to  DOE guidance, the cost uncertainty is greatest during the period that site  investigations and evaluations of cleanup options are being conducted.  Typically, DOE includes what it calls an “unfunded contingency” in its  lifecycle estimates to account for unanticipated future events, but officials  said they do not include the contingency at a project level that includes  buried waste cleanup estimates. DOE expects cost estimates to become  somewhat more accurate during the design phase of a project and to  become substantially more accurate once a cleanup remedy has been  chosen and construction has been authorized.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the DOE for its review and comment.  In its comments, the department generally agreed with our report. The  department agreed that uncertainties surround the disposition of buried  transuranic wastes and that the volume of such wastes intended for WIPP  could increase. However, the department stated that EPA’s recertification  process for WIPP, which occurs every 5 years, includes a forecast of waste  disposal volumes and that current projections do not indicate insufficient  WIPP capacity. The department further stated that it is prepared to  manage the uncertainties regarding the future disposition of these wastes.  While we agree that current projections do not indicate WIPP capacity will  fall short of future requirements, at the time of our review, cleanup  decisions were still pending at the Hanford Site and the Idaho National  Laboratory. These two sites comprise over 80 percent of DOE’s total  estimated inventory of buried transuranic wastes and it is unclear how  much of these buried wastes ultimately must be exhumed. As we stated in  our report, if substantial volumes of the transuranic wastes at these sites  must be exhumed and disposed of off-site, WIPP’s authorized capacity  could be inadequate.
DOE provided additional technical comments, including clarifications on  terminology and ongoing litigation at the Idaho National Laboratory. We  incorporated these clarifications as appropriate. DOE’s comments are  presented in appendix II.
We will send copies of this report to the Secretary of Energy, and we also  will make copies available to others on request. In addition, the report will  be available at no charge on the GAO Web site at http://www.gao.gov.
If you, or your staff, have any questions about this report or need  additional information, please contact me at (202) 512-3841 or  cosgrovej@gao.gov. Contact points for our Office of Congressional  Relations and Public Affairs can be found on the last page of this report.  Other staff contributing to this report can be found in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To conduct our work, we visited buried waste landfills and stored waste  facilities, and we met with local Department of Energy (DOE) officials at  each of DOE’s five largest transuranic waste burial sites––the Hanford  Site, the Idaho National Laboratory, the Los Alamos National Laboratory,  the Savannah River Site, and the Oak Ridge National Laboratory. We also  reviewed studies and scientific reports by DOE and other federal agencies  and the National Academy of Sciences on the storage and disposition of  transuranic wastes, and interviewed experts in the field.
To determine the extent to which legal requirements and policies govern  DOE’s efforts to address buried transuranic wastes, we reviewed the  Comprehensive Environmental Response, Compensation, and Liability Act  of 1980, as amended (CERCLA), the Resource Conservation and Recovery  Act of 1976, as amended (RCRA), the Atomic Energy Act of 1954, as  amended, and Environmental Protection Agency (EPA) and DOE  regulations and guidance concerning radioactive and hazardous wastes.  We also reviewed the Federal Facility Agreements and Orders between  DOE, EPA, and each state with a site where DOE has buried transuranic  wastes, as well as a May 2006 federal district court decision interpreting an  agreement between DOE and the state of Idaho concerning DOE’s  obligation to remove buried transuranic wastes from the Idaho National  Laboratory site. To better understand the implementation of these laws,  regulations, policies, and agreements at DOE sites, we interviewed state  environmental regulatory officials and EPA officials that oversee each of  the buried waste locations. We did not interview EPA officials in New  Mexico because EPA has authorized the state of New Mexico to carry out  a state RCRA program under state law in lieu of the federal program.
To determine how DOE plans to address buried waste at each of its sites,  we reviewed the planning documents DOE has prepared to comply with  CERCLA or RCRA requirements, feasibility studies describing remediation  alternatives, records of decision for sites that have selected a remedy for  buried waste, and internal DOE reports regarding buried transuranic  wastes, and interviewed the project managers and engineers responsible  for overseeing the remediation of each buried waste site.
To determine DOE’s estimated costs for addressing disposal sites  containing buried transuranic wastes and to evaluate the accuracy of  those estimates, we analyzed each field location’s fiscal year 2006 lifecycle  baseline estimates for specific projects that included cleaning up  previously disposed transuranic wastes. Because DOE has generally  defined cleanup projects by geographic waste disposal areas rather than  by waste types, we were unable to determine the specific costs associated  with addressing only transuranic wastes. To better understand the  lifecycle cost estimates, we reviewed DOE cost estimating and project  management guidance and interviewed officials responsible for preparing  and reporting cost estimates to DOE. All cost estimates in this report are  in constant 2006 dollars.
In reporting the volumes of transuranic wastes buried at DOE sites, we  relied on estimates made by DOE in 1999 and reported in 2000, the most  recent available comprehensive inventory of such wastes. In reporting the  inventory of buried transuranic wastes, we included wastes buried at both  shallow depths (less than 100 feet) and intermediate depths (between 100  and 1,000 feet). In addition, we adjusted the buried waste inventory  reported for Los Alamos and Hanford because officials there had  subsequently developed more accurate inventory data that showed a  somewhat lower volume than had been reported in 2000. At other  locations, DOE officials said they believed the 2000 report reflected the  most accurate data available. With regard to the inventory of stored  transuranic wastes reported in 2000, we used data from a 2001 DOE  report. Some of that waste has now been disposed of permanently at the  Waste Isolation Pilot Plant (WIPP) in New Mexico. The inventory of the  remaining volume of transuranic wastes currently in storage at DOE sites  continues to change because of ongoing shipments to WIPP for permanent  disposal and was not available from DOE.
We performed our work between May 2006 and May 2007 in accordance  with generally accepted government auditing standards.
section_title: Appendix II: Comments from the Department of Energy
section_title: Appendix III: Contact Information and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to the individuals named above, Bill Swick, Assistant Director;  Doreen Feldman; Michael Meleady; Mehrzad Nadji; James Noel; Alison  O’Neill; Jeff Rueckhaus; and Ginny Vanderlinde made key contributions to  this report.