Nuclear Health and Safety: DOE Has Not Demonstrated That Restarting PUREX Is a Sound Decision

Published by the Government Accountability Office on 1990-06-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

 DOE Has Not
 Demonstrated That
 Restarting PUREX Is a
 Sound Decision


RESTRICTI3D --Not     to be released outside the
General Accounting Of&e unless apeciflcally
approved by the Office of Congressional
                       United States
GAO                    General Accounting Office
                       Washington, D.C. 20648

                       Resources, Community, and
                       Economic Development Division


                       June 29,199O

                       The Honorable Mike Synar
                       Chairman, Environment,
                         Energy and Natural
                         Resources Subcommittee
                       Committee on Government Operations
                       House of Representatives

                       Dear Mr. Chairman:

                       This report responds to your August 8, 1989, request that we examine
                       the shutdown and planned restart of the Plutonium-Uranium Extraction
                       (PUREX) plant at the Department of Energy’s (DOE) Hanford Site in Wash-
                       ington State. PUREX, whose main function has been to produce plutonium
                       and other special nuclear materials for nuclear defense, research, and
                       development programs by reprocessing used (or “spent”) nuclear
                       reactor fuel, was shut down in December 1988 for safety-related rea-
                       sons. DOE’s current plans are to (1) restart PUREX in March 1991 to con-
                       tinue its role of extracting weapons-grade plutonium from spent fuel
                       and (2) convert PUREX to a waste management role by processing, for
                       disposal, the spent fuel that cannot yield weapons-grade plutonium. DOE
                       officials indicate permanent shutdown will probably occur around the
                       year 2OOO.l

                       As agreed with your office, we assessed the adequacy of                   DOE’S   plans for
                       restarting PuREx,

                       DOE’S plans for restarting               are not adequate. More specifically,
Results in Brief       has not
                                                        PUREX                                                   DOE

                   l   demonstrated that restarting PUREX, either as a producer of plutonium
                       or as a processor of radioactive waste, is a sound decision. More specifi-
                       cally, DOE has not demonstrated that a need exists for weapons-grade
                       plutonium from PUREX, and it has not fully compared PUREX with other
                       waste disposal alternatives to ‘determine whether PUREX is the best

                       ‘By permanent shutdown of PUREX, we mean what DOE has formally called “deactivation”: removal
                       of special nuclear materials from the plant to reduce the level of radioactivity.

                       Page 1                                                  GAO/RCED-90-207    Restarting   PUWC

             l determined whether a supplemental environmental impact statement?
               for PLJREX is needed. Preparing such a statement would address, among
               other things, (1) any new circumstances or information relevant to envi-
               ronmental concerns that have occurred since the initial environmental
               impact statement was prepared in 1983 and (2) the need for and alterna-
               tives to DOE'S planned/proposed action to convert PUREX to a waste man-
               agement role.
             l required that all identified deficiencies in the final safety analysis
               report’ for PUREX be corrected before the planned restart date. By not
               requiring full compliance with current DOE requirements prior to restart,
               DOE has no assurance that the plant can be operated within safety con-
               trol limits.
             . adequately addressed staff turnover and training problems at the plant.
               From December 1988 to May 1990, over one-third of the plant’s opera-
               tors have left, and DOETS restart plans do not provide assurance that
               staff will be fully trained to operate PUREX safely.

                 In view of the importance of the above concerns and their associated
                 costs, a more important issue is whether PUREX should be restarted at

                        is a DOE-owned, contractor-operated facility at the Hanford Site in
Background       PUREX
                 Washington State. The plant began operations in 1956, was idled in
                 1972, and was restarted in 1983. Its main function has been to reprocess
                 spent uranium fuel rods from Hanford’s now-closed nuclear materials
                 production reactor, the N-reactor. Reprocessing involves dissolving the
                 rods in acid and extracting plutonium. If the plutonium is of adequate
                 quality it can then be used in making nuclear weapons.

                 DOE  initially planned to complete reprocessing of the N-reactor fuel rods
                 by fiscal year 1994. By 1986, however, problems were causing frequent

                 “An environmental impact statement is a detailed written statement prepared by an agency pursuant
                 to the National Environmental Policy Act of 1969,as amended (42 USC. 4321 et),        that identifies
                 significant environmental effects of a proposed major federal action. A supplemental environmental
                 impact statement is required if, subsequent to the environmental impact statement, an agency makes
                 substantial changes in the proposed action that are relevant to environmental concerns or there are
                 significant new circumstances or information relevant to environmental concerns and bearing on the
                 proposed action or its impact.

                 %afety analysis reports are used by DOE to show that facilities are safely designed and constructed.
                 They identify problem areas so that corrective actions can be taken. For contractor-operated facilities
                 such as PUREX, the contractor is responsible for making the safety analysis review, which is subject
                 to DOE review and approval.

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    *                     E240130

                          shutdowns at the plant, and in December 1988, because the plant oper-
                          ated outside established safety requirements, it was again shut down
                          and has not been able to resume operations. DOE estimates that costs to
                          keep PUREX in its current status in fiscal year 1990 will be $87 million
                          because of the need to maintain operating systems and to train staff. For
                          fiscal year 199 1, DOEestimates operational costs to be about $10 1

                          DOE has not demonstrated that restarting PUREX in either of its intended
DOE Has Not               roles-producing    plutonium or processing waste for disposal-is a
Demonstrated That         sound decision. More specifically, DOE has not demonstrated that a need
Restarting PUREX Is a     exists for the remaining weapons-grade plutonium that could be
                          extracted, and it has not fully compared PUREX with other waste
Sound Decision            processing alternatives to determine whether PUREX is the best
                          approach. A comparison of waste processing alternatives would be made
                          if DOE updated PUREX'S environmental impact statement by issuing a sup-
                          plemental environmental impact statement, but DOE has not yet deter-
                          mined whether such an update is needed.

The Need for Weapons-     Under the National Environmental Policy Act, DOE is required to assess
Grade Plutonium Has Not   the impact of any proposed major federal action it takes that signifi-
                          cantly affects the quality of the human environment by preparing an
Been Established          environmental impact statement. The act’s implementing regulations
                          also provide for a supplemental environmental impact statement when-
                          ever there are substantial changes in the proposed action that are rele-
                          vant to environmental concerns or there are significant new
                          circumstances or information relevant to environmental concerns and
                          bearing on the proposed action or its impacts.

                          The initial environmental impact statement for PUREX was prepared in
                           1983. In it, DOE stated that operation of PUREX was needed “to meet pro-
                          jected needs for plutonium . . . in the nation’s nuclear defense . . . pro-
                          grams” and that the number of years of operation “will depend on the
                           future needs for plutonium.” After PUREX was shut down in 1988, DOE
                           planned to restart PUREX in its role of producing plutonium for the
                           nation’s defense mission.

                          A number of circumstances have developed since the initial PUREX envi-
                          ronmental impact statement was prepared that affect the purpose and
                          need for operating PUREX in its traditional role. Specifically, according to
                          DOE’Sfiscal year 1989 Hanford chemical processing plan, the plutonium

                          Page 3                                        GAO/RCEB90-207   Restarting   PUREX
B240130                                                                                        *

needed for new nuclear weapons is to come, not from PUREX, but from
retired warheads and from the stockpile of plutonium “scrap” generated
during the warhead production process. Furthermore, the specific role
PUREX plays in plutonium production has changed. For example, after
shutdown in 1988 DOE planned to restart PUREX to recover plutonium
from all of the N-reactor spent fuel that was to be reprocessed.

Although the majority of the N-reactor spent fuel was fuel-grade pluto-
nium, DOE planned to upgrade it to weapons-grade plutonium at the pro-
posed Special Isotope Separation Plant to be built at DOE'S site at Idaho
Falls, Idaho.4 These plans were significantly affected in January 1990
when funding to build the plant was not included in DOE’s budget.
Without the plant, DOE does not have the capability nationwide to
upgrade the fuel-grade plutonium at PUREX into weapons-grade material.
As a result, the national defense mission for PUREX appears to have been
largely eliminated. Only about 360 metric tons of N-reactor spent fuel
can be processed at PUREX for weapons-grade plutonium, not the approx-
imately 2100 metric tons originally anticipated.”

In light of these events, the need for the weapons-grade plutonium that
would result from the estimated 9 months of plutonium production
(March-December 1991) may be questionable. Although DOE'S Deputy
Assistant Secretary for Nuclear Materials told us in April 1990 that the
plutonium from PUREX was needed, this conflicts with Hanford’s fiscal
year 1989 chemical processing plan. The Hanford chemical processing
plan, as noted, states that plutonium for nuclear weapons is to come
from retired warheads and from the stockpile of plutonium “scrap” gen-
erated during the warhead process. In addition, the fiscal year 1989
budget request says that most plutonium for new nuclear weapons sys-
tems is to come from retired weapons, but it does not clearly indicate the
role of PUREX, if any, in satisfying plutonium requirements. A significant
factor in deciding whether to restart is that if the plutonium from PUREX
is not needed, there would be no reason to operate PUREX for this

4DOE also planned to process on-site reactor fuel from two other DOE facilities-the Shippingport
Pressurized Water Reactor Core II and the Fast Flux Test Facility at Hanford-before deactivating
PUREX. As with the N-reactor fuel, plans called for off-site upgrading to weapons-grade plutonium at
the proposed Special Isotope Separation Plant.

“About 1400 additional metric tons from two other DCE facilities is also planned. By metric tons of
spent fuel, we mean metric tens of uranium.

Page 4                                                       GAO/RCED-90-207      Restarting   PUREX
    .                     R-240120

The Need to Restart       Equally important is the fact that DOE has not established whether
                          PUREX is the best alternative for processing the spent fuel as waste. As
PUREX as a Waste          indicated, plans call for converting PUREX to a waste processing role-a
Processor Has Not Been    fundamental change in its mission. DOE has assumed that processing the
Established               spent fuel as waste at PUREX is the best approach, but it has not fully
                          compared PUREX with other waste processing alternatives.

                          In November 1989 the PUREX contractor advised DOE that PUREX was the
                          best alternative for disposal of N-reactor spent fuel. Of the three alter-
                          natives to PUREX that were evaluated, one involved shipping the fuel to
                          DOE’S Savannah River Site in South Carolina where it would be
                          processed to recover the plutonium and another involved building a new
                          plutonium processing facility at the Hanford Site. Only the third alterna-
                          tive involved disposal of the fuel as waste to a geologic repository.

                          Although DOE officials told us that a decision has not been made on what
                          the best choice is for disposal of N-reactor fuel, DOE has continued to
                          plan for a restart of PUREX for this purpose. More importantly, its plan
                          to restart is not supported by any detailed technical, engineering, or cost
                          analyses that fully demonstrate that PUREX is the best option for dis-
                          posal of spent fuel as waste. Without a thorough analysis of the alterna-
                          tives evaluated by the PUREX contractor, as well as other potential
                          alternatives, DOE has not clearly established whether PUREX represents
                          the safest, most economical, or most environmentally sound approach to

DOE Has Not Determinerd   MOEhas not made a final determination on whether a supplemental envi-
the Need for a            ronmental impact statement for PUREX is needed. The preparation of
                          such a statement would address, among other things, any new circum-
Supplemental              stances or information relevant to environmental concerns that have
Environmental Impact      occurred since 1983 and the need for and alternatives to DOE’S planned/
Statement                 proposed action to convert PUREX to a waste management role.

                          The regulations implementing the National Environmental Policy Act
                          emphasize that the “heart of the environmental impact statement” is a
                          discussion of alternatives (40 C.F.R. section 1502.14). Although WE indi-
                          cated in a preliminary draft environmental analysisi prepared in May
                          1990 that continued operations of PUREX will not affect the environment

                          “An environmental analysis is the first stage of the National Environmental Policy Act process. At
                          this stage an agency review determines whether any further assessment, such as an environmental
                          impact statement, is required.

                          Page S                                                       GAO/RCED-SO-207      Restarting   PUREX

    in any manner significantly different than projected in the initial envi-
    ronmental impact statement, this draft analysis does not address plans
    to change the mission of PLJREX.It only addresses PUREX'S plutonium pro-
    duction role.

    One of the drawbacks of preparing a supplemental environmental
    impact statement is that it could take over one year to complete and
    could be costly. (DOE told us that the cost to prepare such a statement
    for other DOE facilities has ranged from about $2 to $5 million.) How-
    ever, in light of the changes that have occurred since the initial environ-
    mental impact statement was prepared, which affect the purpose and
    need for operating PUREX in its traditional role, we believe that pre-
    paring a supplemental environmental impact statement would address a
    number of important issues. Specifically,

. The preparation of such a statement would address any new circum-
  stances or information relevant to environmental concerns that have
  occurred since 1983.
l DOE’Sapproach faces likely legal challenges. In January 1990, three
  environmental groups announced that they intended to sue to require a
  supplemental environmental impact statement prior to any restart of
  PIJHEX. These groups assert that operating PUREX, even in its traditional
  role as a plutonium producer, will affect the environment in a manner
  that differs significantly from that projected in the initial environmental
  impact statement. While the outcome of such a suit is unknown, a deci-
  sion in favor of these groups could substantially delay any restart of
  PIJHEX. These delays would add additional unplanned expense while
  waiting for a restart.
. Updating the environmental impact statement would help demonstrate
  DOE'S commitment to operating its nuclear facilities safely and in an
  environmentally sound manner. One of the Secretary’s major initiatives
  is to ensure that environmental, safety, and health issues take prece-
  dence over production. The Secretary has also committed to full disclo-
  sure and complete assessment of the environmental impacts of DOE’S
. Most importantly, such a statement would address the apparent
  changed need for PUREX to continue processing spent fuel and whether
  PUREX represents the best alternative for disposing of spent fuel as

    Page 6                                       GAO/RCED-90-207   Restarting   PUREX


                    PUREX'S final safety analysis report7 is not in compliance with DOE
PUREX’s Safety      requirements. Furthermore, DOE has not required correction of all the
Analysis Does Not   identified deficiencies in the report to ensure that PUREX is in full compli-
Meet DOE            ante before the planned restart date. Therefore, DOE cannot ensure that
                    the plant can be operated within safety control limits.
Requirements to
Ensure Safe Plant   DOE'S Safety Analysis and Review System Order, DOE Order 5841. lB,
Operations          requires each facility to have a final safety analysis report. Such reports
                    are significant in that they systematically identify hazards, evaluate
                    measures taken to eliminate, control, or mitigate them, and document
                    the overall risks associated with operation of the plant. The safety con-
                    trol limits (safety boundaries) for a facility are required to be included
                    as part of this report and such operational safety limits must be
                    reviewed and approved by DOE. Safety controls can include limits on
                    steam pressure, temperature, and volume of nuclear material. The pri-
                    mary objective of the safety control limits is to provide the controls nec-
                    essary to help prevent the occurrence of accidents. For example, when
                    PUHEX was shut down in December 1988, inadequate steam pressure for
                    a backup system violated an operational safety requirement.

                    The PUREX final safety analysis report does not meet DOE’S requirements.
                    At PUREX, the operational safety requirements containing safety control
                    limits are in the contractor’s plant manual, not in the final safety anal-
                    ysis report. The plant manual is not subject to DOE'S review or approval.
                    As a result, changes made in safety control limits following the
                    December 1988 shutdown have not been fully reviewed by DOE nor
                    approved as required under DOEorders governing the final safety anal-
                    ysis report. Without the required review and approval, DOE cannot
                    ensure that the plant can be operated within safety control limits at

                    Moreover, DOE has not required that other identified weaknesses in the
                    ITJREX  safety analysis report, such as insufficient information about
                    replaced or modified equipment or insufficient analysis of potential acci-
                    dents involving toxic chemicals, be corrected before restart in March
                    1991, nor has DOE provided the necessary funding to ensure that such
                    weaknesses can be corrected in accordance with regulations prior to
                    restart. PUREX officials originally planned for a complete revision of the

                    7Wediscussedthe issue of safety analysis reports in an earlier report entitled, Nuclear Safety: Safety
                    Analysis Reviews for DOE’s Defense Facilities Can Be Improved (GAOIRCED-86-175, June 16,

                    Page7                                                         GAO/RCED-90-207RestartingPUREX
                        B-240130                                                                                       i

                        final safety analysis report for PUREX by fiscal year 1992 at an esti-
                        mated cost of $6 million. Subsequently, however, due to the lengthy time
                        and costs involved, a modified plan was developed. This modified plan
                        provides for the revision of only a portion of the report before the
                        planned March 1991 restart date. However, DOE has not made these revi-
                        sions a requirement for restart. Under this modified plan, not all identi-
                        fied weaknesses would be corrected before the planned restart. And, as
                        for funding, as of May 1990 only about $1.25 million in fiscal year 1990
                        funds had been made available for making revisions; an additional $2.5
                        million for revisions was planned for the year but not funded. DOE'S
                        restart plans do not address when all identified weaknesses would be

                        DOE has acknowledged that it is heavily dependent on skilled, experi-
Training Problems and   enced personnel to operate the PUREX plant safely. Since the plant’s
Plant Turnover Will     shutdown there has been a considerable loss of experienced personnel
Not Be Resolved Prior   and serious training deficiencies identified as early as 1988 persist. DOE'S
                        plans are insufficient to resolve identified training needs and turnover
to Restart              problems prior to restart. As a result, there is no assurance that plant
                        staff will be adequately trained to operate the plant safely.

                        Serious training deficiencies were reported in DOE'S 1988 technical
                        safety appraisal8 , including the lack of quality technical support for
                        operations training and the lack of a proficiency program to ensure that
                        operators maintained a minimum level of qualification on certified posi-
                        tions. Again, in 1989, PUREX officials reported that plant personnel
                        lacked familiarity with procedures required to ensure that operations
                        are within safety requirements. Since that time, according to DOE and
                        contractor officials, a number of steps have been taken to correct the
                        identified deficiencies including the development of training manuals
                        and increased operator training on safety requirements.

                        Training problems at PUREX have been compounded by the high turnover
                        of personnel. The Advisory Committee on Nuclear Facility Safety
                        reported in July 1988 a turnover of one-third to one-half of the PUREX
                        staff. Our review showed that 48 of 104 plant operators at PUREX in
                        December 1988 were no longer at PUREX and that even more turnover in
                        plant operations staff is expected by the planned March 1991 restart

                        “A technical safety appraisal is a documented multi-discipline appraisal of a nuclear facility con-
                        ducted by DOE to ensure, among other things, the proper department-wide application of particular
                        safety elements.

                        Page 8                                                       GAO/RCED-90-207      Restarting       PUREX
    *           5240120

                date, DOE told us that PUREX will likely continue to lose staff due to the
                uncertainties surrounding the future of PUREX. The plant manager esti-
                mated that by March 1991 as many as two-thirds of the operations staff
                may not have had any actual operational experience in processing spent
                fuel in the plant. PUREX officials believe that possibly the greatest factor
                affecting restart will be the loss of experienced technical and operations
                staff. In addition, they expect a decrease in the performance of existing
                staff because of the inability to practice skills under plant operating
                conditions before the planned restart.

                In the past there have been plant shutdowns due to errors made by
                plant staff. With numerous changes in plant procedures since the
                December 1988 shutdown, PUREX officials believe there will be addi-
                tional errors due to the time needed to learn new procedures. As long as
                there is a high turnover this problem will persist.

                DOE'S current plans are insufficient to resolve these problems. DOE has
                not required that PUREX officials identify how they plan to maintain
                technical and operation staff skills intact until March 199 1. Further-
                more, sufficient time and money are needed for training and retraining
                on a continuing basis when PUREX is operating. The solution proposed by
                PUREX officials is to add enough staff to create an additional shift,
                leaving more time during normal operations for training. The cost for
                doing this is estimated to be about $2.1 million annually. Although
                PUREX officials have told DOE that their plans include implementation of
                another shift after resumption of normal operations, DOE'S current plans
                do not require that such a shift be implemented. Unless DOE makes the
                additional shift a requirement, it has no assurance that the PUREX con-
                tractor will carry through with its plans.

                The Secretary of Energy has committed to ensuring that all DOE nuclear
Conclusions     facilities are operated safely and in an environmentally sound manner;
                one of his major initiatives is to ensure that environmental, safety, and
                health issues take precedence over production. The Secretary has also
                committed to full disclosure and complete assessment of the environ-
                mental impacts of WE’s actions. DOE'S plans for restarting PuREx appear
                to be inconsistent with the Secretary’s stated position.

                Preparing a supplemental environmental impact statement for PuREx
                would help to demonstrate DOE'S commitment to environmental, safety,
                and health issues. Although DOE'S plans call for restarting PUREX as soon
                as March 1991, WE has not yet decided whether the changes that have

                Page 9                                        GAO/RCED-90407   Restarting   PURFX

                      occurred since the initial 1983 environmental impact statement require
                      the department to prepare a supplemental environmental impact state-
                      ment for PUREX prior to restart.

                      A more important question is whether PUREX should be restarted at all
                      given the costs to operate PUREX, in combination with the costs to pre-
                      pare a supplemental environmental impact statement, the time and costs
                      associated with correcting identified safety and training deficiencies,
                      the relatively small amount of remaining weapons-grade plutonium, and
                      the possibility that a better alternative exists to dispose of the fuel-
                      grade plutonium. The Secretary of Energy is in a position to make this
                      determination. If a decision is made to continue with plans to restart
                      PUREX, we believe that a supplemental environmental impact statement
                      should be prepared prior to restart of the plant. Also, if PUREX is to be
                      restarted, DOE needs to ensure that all identified safety and operational
                      deficiencies are corrected.

                    In light of the various issues that have an impact on the future of PUREX,
Recommendations   , we recommend that the Secretary, DOE, determine at this time whether
                    PUREX should be restarted at alljlf the Secretary decides to continue
                    with plans to restart PUREX, we’recommend that a supplemental environ-
                    mental impact statement be prepared before restart. As part of this pro-
                    cess, DOE should demonstrate that PUREX is the best alternative for
                    disposition of spent fuel as waste. Detailed technical, engineering, and
                    cost analyses should accompany DOE'S final decisions.

                      Also, the Secretary should prohibit restart of PUREX until all of the iden-
                      tified safety- and training-related concerns have been corrected or ade-
                      quately addressed. This would include

                  . making corrections to PUREX'S final safety analysis report so that it is in
                    full compliance with DOE orders,
                  . requiring the PUREX contractor to demonstrate how it plans to maintain
                    technical and operation staff skills intact until the plant is restarted,
                  l making implementation of an additional shift a requirement so that ade-
                    quate time for needed training can be better ensured.

                      Page 10                                       GAO/RCED-90-207   Restarting   PUREX

              To complete our work, we interviewed officials at DOE headquarters and
Scopeand      the Richland Operations Office. We also interviewed DOE contractor per-
Methodology   sonnel, including PUREX plant staff. In addition, we interviewed environ-
              mental groups, Environmental Protection Agency Region X officials
              (encompasses the states of Washington, Oregon, Idaho, and Alaska), and
              Washington State regulatory agency officials. We reviewed pertinent
              documents, including congressional testimony, DOE regulations and Sec-
              retary of Energy notices, and applicable Richland Operations Office
              memoranda and PUREX procedures. To develop an overall perspective on
              the potential implications of restarting PUREX, we also relied on indepen-
              dent studies and correspondence associated with PUREX shutdowns. We
              conducted our work from October 1989 through June 1990, in accor-
              dance with generally accepted government auditing standards.

              We discussed the results of our work with DOE officials and incorporated
              their comments where appropriate. In general, they agreed with the
              information presented. As requested, we did not obtain official agency
              comments on this report. Unless you publicly announce its contents ear-
              lier, we plan no further distribution of this report for 30 days from the
              date of this letter. At that time, we will send copies to the appropriate
              congressional committees; the Secretary of Energy; and the Director,
              Office of Management and Budget. We will also make copies available to
              others upon request.

              This work was performed under the direction of Victor S. Rezendes,
              Director, Energy Issues. If you have any questions, please contact him at
              (202) 275-1441. Major contributors to this report are listed in appendix

              Sincerely yours,

              J. Dexter Peach
              Assistant Comptroller General

              Page 11                                     GAO/RCED-90-207   Restarting   PUREX
Appendix I

Major Contributors to This Letter Report                                                       ’ ‘-

                          Judy A. England-Joseph, Associate Director, Energy Issues
Resources,                Carl J. Bannerman, Assistant Director
Community, and            Doris E. L. Cannon, Assignment Manager
Economic                  Duane G. Fitzgerald, Technical Advisor
                          Shirley M. Christensen, Writer-Editor
Development Division,
Washington, D.C.

                          Leonard L. Dowd, Regional Manager Representative
Seattle Regional Office   Keith C. Martensen, Evaluator-in-Charge
                          Stan G. Stenersen, Evaluator
                          Shari K. Eubank, Evaluator

(801998)                  Page 12                                    GAO/RCED-90-207   Restarting   PUREX

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