Nuclear Waste
DOE's Efforts to Protect the Columbia River from Contamination Could Be Further Strengthened Gao ID: GAO-06-1018 August 28, 2006The Department of Energy's (DOE) Hanford site in Washington State is one of the most contaminated nuclear waste sites in North America. The Columbia River flows through about 50 miles of the site. Radioactive and hazardous contamination from decades of producing nuclear materials for the nation's defense have migrated through the soil into the groundwater, which generally flows toward the river. In November 2005, GAO reported on the potential for the Hanford site to contaminate the Columbia River. To address continuing concerns, GAO reviewed the status of DOE's efforts to (1) understand the risk to the Columbia River from Hanford site contamination and to deploy effective technologies to address contamination near the river and (2) strengthen the management of its river protection program. To assess DOE's efforts, GAO reviewed numerous reports by DOE and others, and discussed the problem with federal and state regulators and DOE officials.
DOE is actively assessing the risk to the Columbia River from Hanford site contamination and is addressing problems with deployed river protection technologies. While DOE has extensive knowledge of contaminants that are currently in the groundwater and river, DOE knows less about contamination in the soil below the surface, known as the "vadose zone." Before proposing a cleanup approach, DOE has agreed with its regulators to take vadose zone samples in many of the contaminated areas of the site. DOE is also improving its computer simulation model that will predict future risk from the contamination, and deploying alternative technologies it believes will more effectively contain the contamination that may threaten the river. DOE has also begun to address concerns about its management of Columbia River protection efforts, particularly the lack of integration between groundwater and vadose zone activities. In March 2006, in response to congressional committee direction, DOE proposed a new initiative to better integrate its river protection activities. The initiative included consolidating most groundwater and vadose zone characterization work under a single project; better integrating vadose zone, groundwater, and surface cleanup decisions; and improving the coordination and control over computer models used to predict movement of contamination in future years. Initiating these management improvements is important, but it is equally important that they be implemented effectively, and past history gives some cause for concern. For example, one attempt by DOE to better integrate these activities was unsuccessful when key elements, such as putting all activities under a single project manager, failed to continue after project and other changes occurred at the site. In past GAO work, we reported that high-performing organizations sustained improvement initiatives when key elements were in place, such as clear goals, results-oriented performance measures, and evaluation strategies. Although DOE is beginning to develop a management plan for its new initiative, DOE has yet to implement some key elements, such as results-oriented performance measures and evaluations to gauge the effectiveness of its improvements, which could also help sustain the benefits of the improvements over time.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-06-1018, Nuclear Waste: DOE's Efforts to Protect the Columbia River from Contamination Could Be Further Strengthened
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Report to the Chairman and Ranking Minority Member, Subcommittee on
Energy and Water Development and Related Agencies, Committee on
Appropriations, House of Representatives:
United States Government Accountability Office:
GAO:
August 2006:
Nuclear Waste:
DOE's Efforts to Protect the Columbia River from Contamination Could Be
Further Strengthened:
Columbia River Protection:
GAO-06-1018:
GAO Highlights:
Highlights of GAO-06-1018, a report to Chairman and Ranking Minority
Member, Subcommittee on Energy and Water Development and Related
Agencies, Committee on Appropriations, House of Representatives
Why GAO Did This Study:
DOE‘s Hanford site in Washington State is one of the most contaminated
nuclear waste sites in North America. The Columbia River flows through
about 50 miles of the site. Radioactive and hazardous contamination
from decades of producing nuclear materials for the nation‘s defense
have migrated through the soil into the groundwater, which generally
flows toward the river.
In November 2005, GAO reported on the potential for the Hanford site to
contaminate the Columbia River. To address continuing concerns, GAO
reviewed the status of DOE‘s efforts to (1) understand the risk to the
Columbia River from Hanford site contamination and to deploy effective
technologies to address contamination near the river and (2) strengthen
the management of its river protection program. To assess DOE‘s
efforts, GAO reviewed numerous reports by DOE and others, and discussed
the problem with federal and state regulators and DOE officials.
What GAO Found:
The Department of Energy (DOE) is actively assessing the risk to the
Columbia River from Hanford site contamination and is addressing
problems with deployed river protection technologies. While DOE has
extensive knowledge of contaminants that are currently in the
groundwater and river, DOE knows less about contamination in the soil
below the surface, known as the ’vadose zone.“ Before proposing a
cleanup approach, DOE has agreed with its regulators to take vadose
zone samples in many of the contaminated areas of the site. DOE is also
improving its computer simulation model that will predict future risk
from the contamination, and deploying alternative technologies it
believes will more effectively contain the contamination that may
threaten the river.
DOE has also begun to address concerns about its management of Columbia
River protection efforts, particularly the lack of integration between
groundwater and vadose zone activities. In March 2006, in response to
congressional committee direction, DOE proposed a new initiative to
better integrate its river protection activities. The initiative
included consolidating most groundwater and vadose zone
characterization work under a single project; better integrating vadose
zone, groundwater, and surface cleanup decisions; and improving the
coordination and control over computer models used to predict movement
of contamination in future years.
Initiating these management improvements is important, but it is
equally important that they be implemented effectively, and past
history gives some cause for concern. For example, one attempt by DOE
to better integrate these activities was unsuccessful when key
elements, such as putting all activities under a single project
manager, failed to continue after project and other changes occurred at
the site. In past GAO work, we reported that high-performing
organizations sustained improvement initiatives when key elements were
in place, such as clear goals, results-oriented performance measures,
and evaluation strategies. Although DOE is beginning to develop a
management plan for its new initiative, DOE has yet to implement some
key elements, such as results-oriented performance measures and
evaluations to gauge the effectiveness of its improvements, which could
also help sustain the benefits of the improvements over time.
Figure: Contamination of the Columbia River from DOE's Hanford Site:
[See PDF for Image]
Source: DOE.
[End of Figure]
What GAO Recommends:
To increase the likelihood that DOE will effectively implement and
sustain improvements in its program to protect the Columbia River from
contamination, GAO recommends that the Secretary of Energy establish
results-oriented performance measures and regular evaluations to gauge
the improvements‘ effectiveness. DOE agreed with our recommendation.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-1018.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Gene Aloise at (202) 512-
3841 or aloisee@gao.gov.
[End of Section]
Contents:
Letter:
Results in Brief:
Background:
DOE is Taking Steps to Better Understand Risks to the Columbia River
from Hanford and Is Replacing Ineffective Technologies near the River:
DOE Has Begun To Address Management Weaknesses but Can Further
Strengthen Its Management Plan:
Conclusions:
Recommendation for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Energy:
Appendix III: GAO Contact and Staff Acknowledgments:
Figure:
Figure 1: Sources of Contamination of the Columbia River from DOE's
Hanford Site:
Abbreviations:
CERCLA: Comprehensive Environmental Response, Compensation, and
Liability Act:
DOE: Department of Energy:
EPA: Environmental Protection Agency:
PNNL Pacific Northwest National Laboratory:
RCRA: Resource Conservation and Recovery Act:
United States Government Accountability Office:
Washington, DC 20548:
August 28, 2006:
The Honorable David L. Hobson:
Chairman:
The Honorable Peter J. Visclosky:
Ranking Minority Member:
Subcommittee on Energy and Water Development and Related Agencies:
Committee on Appropriations:
House of Representatives:
The Department of Energy's (DOE) Hanford site in southeastern
Washington State is one of the most contaminated nuclear waste sites in
North America. The site occupies 586 square miles upriver from the
cities of Richland, Pasco, and Kennewick, with a combined regional
population of over 200,000. During Hanford's production era, beginning
in 1943, nine nuclear reactors were built at the site to produce
nuclear materials, especially plutonium, for the nation's defense. The
site was selected, in part, because the Columbia River, the nation's
second largest river by volume, flows through almost 50 miles of it;
the river water was used to cool nuclear reactors and support nuclear
materials processing operations. During operations from 1943 to 1989,
activity at the reactors and other facilities also generated large
volumes of hazardous and radioactive waste. Some of this waste was
deposited directly into the ground in trenches, injection wells, or
other facilities designed to allow the waste to disperse into the soil;
some was packaged into drums and other containers and buried; and some
was stored in 177 large underground tanks.
Over time, concern has developed about the impact of Hanford's
radioactive and hazardous waste moving through the groundwater toward
the Columbia River. The river is a source of hydropower production,
irrigation for agriculture, and drinking water for downstream
communities, as well as a major route for migrating salmon. Besides the
waste intentionally discharged directly into the ground during the time
of reactor operations, DOE has assumed, based on monitoring data and
other techniques used to detect contamination, that 67 of the
underground tanks, some burial grounds, and other waste disposal areas
have also leaked contamination into the soil. Contamination could also
result from accidental spills during ongoing cleanup activities. Much
of this hazardous and radioactive waste can be borne by water through
the soil into the groundwater. While Hanford is a near-desert location
with limited rainfall and, in many areas, thick layers of soil and rock
above the groundwater, water from precipitation and other sources moves
through these layers into the groundwater. The groundwater moves in the
general direction of the river. In the center of the site the
groundwater is more than 200 feet below the surface, but at the river
the groundwater is at or near the river level. As figure 1 illustrates,
the movement of this contaminated liquid through the "vadose zone"--the
span of soil and rock between the surface and the groundwater beneath-
-can result in contamination "plumes" extending downward and outward
from their sources. When these contamination plumes reach the
groundwater, the contamination they contain enters the groundwater and
begins flowing toward the river.
Figure 1: Sources of Contamination of the Columbia River from DOE's
Hanford Site:
[See PDF for image]
Source: DOE.
[End of figure]
The extent to which contamination from the Hanford site has threatened,
or will threaten, the Columbia River, is not fully understood. While
some contamination has already reached the river, DOE has found that it
is barely detectable because the high volume of water dilutes it. DOE
routinely monitors the river's water quality, which currently meets
federal drinking water standards at sampling locations immediately down
river from the Hanford site. However, studies also show that
contamination has been found in some river life, including clams found
near the shore. In addition, the rate at which contamination in the
vadose zone and groundwater may migrate to the river in future years is
uncertain, and depends on the effectiveness of site cleanup activities.
However, migrating contamination may continue to enter the river in the
foreseeable future.
Since the early 1990s, DOE has shifted its efforts at the Hanford site
from production of nuclear materials to cleaning up the contamination
and other materials left over from the production era. DOE carries out
its cleanup activities primarily under the requirements of two
environmental laws: (1) the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (CERCLA); and (2)
the Resource Conservation and Recovery Act of 1976, as amended (RCRA).
Milestones for completing each step of the cleanup process are
specified in a legally binding agreement (commonly known as the Tri-
Party Agreement) between DOE and its regulators--the U.S. Environmental
Protection Agency (EPA) and the Washington State Department of
Ecology.[Footnote 1] Under the Tri-Party Agreement, DOE must complete
remediation of most of the site's soil and groundwater by September
2024. DOE's goal is to complete all cleanup work at the Hanford site by
2035.
The Tri-Party Agreement incorporates the requirements of federal
environmental laws and guides the process under which DOE will analyze
the contamination and consider remedies, which DOE's regulators must
approve.[Footnote 2] First, DOE must conduct a remedial investigation,
in which it carries out field sampling and laboratory analyses to
determine the nature and extent of contamination. DOE is then required
to conduct a feasibility study to develop and screen an initial list of
remedial alternatives. After obtaining additional data, as necessary,
DOE must analyze various remedial alternatives and select a preferred
remedy. The determination of the preferred remedy is to be based on,
among other things, whether a remedial alternative protects human
health and the environment, as well as whether it attains cleanup
standards that are legally applicable or otherwise relevant and
appropriate, including state laws. For example, DOE and its regulators
have determined that the Safe Drinking Water Act[Footnote 3] provides
standards for many of the contaminants in the soil and groundwater at
Hanford. In addition, DOE must consider seven other criteria in
selecting a remedial approach, including the cost effectiveness of the
remedy, its long-term protectiveness of human health and the
environment, and community acceptance. Currently, DOE is required by
the Tri-Party Agreement to meet a deadline of December 2008 to select
preferred remedial alternatives for 57 separate waste management areas
of the site--known as operable units.[Footnote 4]
After DOE selects a preferred remedial alternative, the lead regulatory
agency--either EPA or the state of Washington--prepares a Record of
Decision[Footnote 5] that selects the final remedy. A Record of
Decision generally describes, among other things, (1) the key
contaminants present in the specific waste management area, (2) the
contamination limits DOE must achieve for each key contaminant, (3) the
time frame in which the cleanup goals will be achieved, and (4) the
technologies to be used to address the contamination. In general, if
contaminants remain at the site as part of the final remedy, DOE and
its regulators are required to review the remedial action every 5 years
to determine whether the selected treatment technology is effective in
protecting human health and the environment.
DOE's cleanup program at the Hanford site is aimed, in part, at
protecting the Columbia River from contamination, now and in the
future. Many of the river protection activities treat contamination
before it enters the vadose zone or groundwater, and we have reported
on several of these activities.[Footnote 6] Regarding DOE's efforts to
address contamination in the vadose zone and groundwater, DOE has
prioritized the work to first address threats from contaminated sites
located near the river or requiring immediate action, and then address
threats from contaminated sites that are farther away from the river's
edge.
DOE's effort to address contamination near the river include actively
removing waste, old buildings, and contaminated soil to reduce
contaminants that could migrate--known as the river corridor project--
and treating the groundwater to prevent contaminants from further
migrating. DOE has three main approaches to treating the groundwater:
* Pump-and-treat. With this approach, DOE uses wells to extract
contaminated groundwater, treats the groundwater in above-ground
facilities, and reinjects the treated water into the ground. Since
1995, DOE has operated five pump-and-treat systems to remove strontium-
90, chromium, carbon tetrachloride, and uranium from the groundwater.
Four of these are intended to address near-river contamination of
strontium-90 and chromium.
* Chemical treatment. This approach has been used in one instance. DOE
uses a chemical barrier near the Columbia River to block chromium from
entering the river near major salmon breeding areas.[Footnote 7] The
barrier consists of a 750-yard series of wells through which DOE
injected a chemical into the groundwater; the chemical reacts with the
chromium to change it to a less hazardous and less mobile form.
* Natural attenuation. This approach relies on subsurface processes
such as dilution, adsorption, and chemical reactions with subsurface
materials to reduce contaminant concentrations to acceptable levels.
For example, a large uranium plume in the groundwater is entering the
river about 4 miles above city drinking water intakes. In 1996, DOE and
its regulators agreed to allow the plume to dissipate through natural
attenuation.
DOE's efforts to address contamination threats that are farther from
the river have involved four main types of actions:
* Characterizing the vadose zone and groundwater through sampling and
other studies to help understand the risks from movement of
contamination.
* Removing high-risk material from contaminated sites and/or covering
the surface of the disposal area with a barrier to prevent water
intrusion.
* Decommissioning (by removing or sealing) a portion of the 7,000 wells
used to monitor groundwater and the vadose zone, and for other
purposes, that are no longer needed. Monitoring wells are important,
but they can also contribute to pollution by serving as conduits for
rain, snow melt, or other liquids to flush contaminants through the
vadose zone and into the groundwater.
* Reducing water intrusion from leaking pipelines and surface drainage
that can drive contamination from the vadose zone to the groundwater.
DOE also monitors groundwater conditions and uses information about the
nature and extent of contamination in the groundwater--and its
migration toward the river--to assess current and future risks to the
public and the environment. While current levels of contamination can
be determined by sampling the river, soil, and groundwater, DOE uses
computer models to predict how existing and future contamination from
site cleanup and disposal activities will impact the river over the
next 1,000 to 10,000 years.
In November 2005, we reported on the potential for Columbia River
contamination from the Hanford site.[Footnote 8] We discussed DOE's
understanding of the sources and extent of contamination that
potentially threaten the river, and the mixed results that DOE's
efforts to address the contamination have achieved so far. In addition,
we discussed past criticisms of DOE's program management, including a
poorly organized management structure and lack of coordination among
various river protection activities. Because of continuing concerns
about the risks posed by the contamination and DOE's management of its
river protection program, you asked us to review the status of DOE's
efforts. This report addresses DOE efforts (1) to understand the risk
to the Columbia River from Hanford site contamination and to deploy
effective technologies to address contamination near the river, and (2)
to strengthen the management of its efforts to protect the Columbia
River from Hanford site contamination.
To address these objectives, we reviewed key documents, including
Hanford's 2003 Groundwater Management Plan, the 2004 Hanford Site
Groundwater Strategy, and reports from the National Academy of Sciences
and the DOE Inspector General.[Footnote 9] We visited various
groundwater protection projects at the Hanford site and discussed river
contamination issues with DOE and contractor officials at Hanford. We
also discussed these issues with state and federal regulators, and
other stakeholders. In reviewing the data related to the groundwater
and river programs, we determined they were sufficiently reliable for
the purposes of our report. A more detailed description of our scope
and methodology is presented in appendix I. We conducted our work from
December 2005 to August 2006 in accordance with generally accepted
government auditing standards.
Results in Brief:
DOE has begun taking steps to better understand the risk to the
Columbia River from Hanford site contamination, and to replace cleanup
technologies that have proven to be ineffective in keeping the
contamination from seeping into the river. To better understand the
nature and extent of the potential risk of contaminating the Columbia
River, DOE and its regulators agreed to do additional sampling and
analysis of the Hanford site's vadose zone. While DOE and its
contractors have extensive knowledge of the contaminants that are
currently in the groundwater and in the river, DOE knows less about the
extent and location of contaminants in the vadose zone above the
groundwater. Understanding contamination in the vadose zone is
important for making decisions about how best to protect the Columbia
River from the contamination. To accomplish this additional
investigative work, DOE has requested a 3-year delay--until 2011--to
the regulatory milestone by which DOE must propose to regulators its
plans for addressing the groundwater and vadose zone contamination on
the Hanford site. Once DOE understands the nature and extent of
contamination in the vadose zone and groundwater, it must assess the
risk to the public in future years by estimating how, and where, the
contamination will migrate over time. While DOE relies on sampling to
determine current conditions, it uses computer simulation models to
predict future conditions and estimate future risks. DOE abandoned past
modeling efforts in response to criticism that the models used
inconsistent assumptions, were based on data of questionable
reliability and had weak quality control processes. DOE is beginning to
develop a model it believes will be more reliable. DOE has also begun
taking steps to replace ineffective treatment approaches in response to
concerns raised by us and others, and after receiving congressional
direction to make $10 million available in fiscal year 2006 to research
new treatment technologies at Hanford. These steps include replacing
one pump-and-treat system, improving a leaking chemical barrier, and
pursuing alternatives to allowing natural processes to control uranium
migration.
DOE has also begun to address management problems with its Columbia
River protection efforts at the Hanford site. In March 2006, as a
result of congressional direction to improve management of its river
protection efforts, DOE proposed key steps intended to better
coordinate and manage groundwater and vadose zone activities at the
site. These steps included (1) consolidating most groundwater and
vadose zone activities under a single project, (2) better coordinating
decisions about groundwater cleanup with decisions about how to address
vadose zone contamination, and (3) consolidating risk assessment and
modeling efforts under one project. DOE has taken steps in the past to
address similar management problems, but the initiative was not
successfully implemented. For example, in response to our 1998 report
calling for greater integration of river protection activities at the
Hanford site,[Footnote 10] DOE took some initial steps to better
coordinate its groundwater and vadose zone efforts. However, DOE did
not implement key elements, such as developing a sitewide funding
baseline of all river protection efforts; other elements, such as
integrating groundwater and vadose zone activities under a single
project manager, were initially implemented, but DOE did not continue
them after changes in project organization and contract structuring
occurred at the site.
We previously reported[Footnote 11] that high-performing organizations
sustained management improvement initiatives when they followed a
systematic, results-oriented strategy that included defining specific
program objectives, developing performance measures to gauge progress,
and using results-oriented outcomes to evaluate the effectiveness of
the initiative. As of July 2006, DOE had begun to determine the
objectives of its new integration initiative, but had not yet fully
developed other aspects of a sound management plan, including
developing results-oriented performance measures to gauge effectiveness
and evaluating the initiative using those measures. Unless DOE takes
these steps, we are concerned about its ability to sustain any
improvements its new initiative may offer. The DOE Hanford Assistant
Manager in charge of overseeing the new integration initiative said
that the management plan for the initiative is still evolving and that
future steps may include developing performance measures and evaluation
strategies to gauge effectiveness.
We are recommending that the Secretary of Energy strengthen its
management improvement plan by establishing results-oriented
performance measures and regular evaluations to gauge the program's
effectiveness and sustain benefits of the improvements over time. In
commenting on a draft of this report, DOE agreed with our
recommendation.
Background:
Contamination from the Hanford site that may threaten the Columbia
River includes (1) contamination that resulted from disposal activities
during the era in which DOE produced nuclear material; (2)
contamination that could occur during cleanup activities, such as from
an accidental spill; and (3) possible future migration of contamination
from waste that will be permanently disposed of on the Hanford site in
accordance with the cleanup actions DOE and the regulators plan to use.
Contamination from production era. Contamination at Hanford resulting
from plutonium production (which occurred from 1943 to 1989) that is
currently migrating to the river is primarily from:[Footnote 12]
* Intentional disposal of liquid waste and contaminated water into the
ground (about 450 billion gallons).
* Leaks into the soil from waste tanks and the pipelines that connect
them (between 500,000 to 1 million gallons containing about 1,000,000
curies of radioactivity).
* Contamination that has begun to migrate from solid waste (more than
710,000 cubic meters) disposed of on-site in burial grounds, pits, and
other facilities.
Chemical and radioactive contamination currently affects more than 180
of the 586 square miles of the site's groundwater and large areas of
the vadose zone. While there are numerous contaminants now in the
vadose zone and the groundwater below, DOE believes the key
contaminants in the groundwater include hazardous chemicals (such as
carbon tetrachloride, chromium, nitrate, and trichloroethane) and
radioactive materials (such as iodine-129, strontium-90, technetium-
99, tritium, and uranium). These contaminants are of concern because of
their extent, their mobility in the groundwater, and the potential
health risks associated with them--at sufficient levels, some of these
contaminants are toxic to humans or fish, while others are potential
carcinogens.
Potential contamination from current activities. Current cleanup
efforts at the Hanford site could contribute to contamination of the
vadose zone and groundwater that eventually reaches the river. For
example, some of the waste put into underground storage tanks as liquid
has since turned into sludge or saltcake.[Footnote 13] To dissolve it,
more water will have to be introduced into the tanks--including tanks
known to have leaked. This process may cause additional discharges into
the soil.
Possible future contamination. Under DOE's cleanup plans, and with
regulator approval, a large amount of contaminants will remain on-site
long into the future. This contamination may be in buildings, in mostly
empty underground tanks, in covered burial grounds and waste disposal
areas, and in approved disposal facilities. Contaminants may leach out
of these facilities in the future and join existing contamination in
the vadose zone and migrate to the groundwater, where they could
migrate to the river.
Based on groundwater sampling results, DOE reports that plumes of
contamination continue to move through the vadose zone and the
groundwater, and are leaching into the river. DOE estimates that about
80 square miles of groundwater under the site contains contaminants at,
or above, federal drinking water standards.[Footnote 14] Because the
groundwater and the river are at the same relative elevation, these
plumes are leaching directly into about 10 of the nearly 50 miles of
river shore on the site.
DOE's Office of Groundwater and Soil Remediation under the Assistant
Secretary for Environmental Management sets overall policy and
oversight for groundwater and soil remediation. At the Hanford site,
both the Richland Operations Office and the Office of River Protection,
as well as several contractors, are involved in groundwater and vadose
zone activities. The monitoring of river and shoreline conditions, and
groundwater sampling, is managed by the Pacific Northwest National
Laboratory (PNNL). Analysis of the samples is performed by several
approved laboratories. Funding for groundwater and vadose zone
activities at the site is difficult to identify due to the large number
of organizations and activities involved and the structure of DOE's
budget accounts. However, monitoring, characterization, well drilling
and maintenance, remediation, and research activities received nearly
$175 million in fiscal year 2006.
DOE is Taking Steps to Better Understand Risks to the Columbia River
from Hanford and Is Replacing Ineffective Technologies near the River:
DOE is taking steps to better understand the risk to the Columbia River
from Hanford site contamination and to replace ineffective cleanup
technologies. Specifically, DOE is addressing problems with three main
aspects of its Columbia River protection efforts. First, DOE and its
regulators have agreed that additional investigation of contamination
in the vadose zone is needed, although doing so could delay by about 3
years the date by which DOE will propose its cleanup plans to the
regulators. Second, DOE is reworking its approach to modeling the
future effects of contamination on river conditions. DOE abandoned past
modeling efforts in response to criticism that the models used
inconsistent assumptions, were based on data of questionable
reliability, and had weak quality control processes. Third, in response
to concerns about the effectiveness of some of the technologies DOE had
deployed to remove or contain contamination near the river, and with
specific direction from Congress, DOE is evaluating alternative
technologies that may be more effective at addressing the
contamination.
DOE Has Asked to Extend Regulatory Milestones to Better Understand the
Extent and Location of the Contamination in Soil above the Groundwater:
While DOE has extensive knowledge of the contaminants in the river and
groundwater, and the movement of contaminants in the groundwater and on
or near the surface, DOE has only recently developed limited
information about the extent and location of the contamination that has
migrated from the surface areas into the vadose zone above the
groundwater. Understanding the nature of vadose zone contamination is
critical to determining the most appropriate steps to take to protect
the river now, and in future years, because contaminants still in the
soil may continue to migrate until they eventually reach the
groundwater and the river. DOE has studied some portions of the vadose
zone, such as around the underground storage tanks, where extensive
contamination from leaks and spills occurred in the past. In doing so,
DOE found that some contamination, including technetium-99, had
migrated as far as the groundwater. DOE contractors were able to map
the migration of some of these contaminants. However, DOE acknowledges
that its understanding of contaminants in the vadose zone is limited in
many areas of the site. For example, cribs and trenches near the
underground tanks received large volumes of contaminated wastes that
dispersed directly to the ground. DOE has little information on the
extent and location of the contamination in those areas, according to
DOE officials responsible for planning their cleanup. They also said
that characterization of the lower portions of the vadose zone is
difficult and expensive, and few remediation techniques have been
developed or tested for removing or isolating wastes that are located
deep in the vadose zone.
Understanding the extent of vadose zone contamination is critical
because some contaminants still in the soil may continue to migrate
until they eventually reach the groundwater and the river. Thus,
understanding the type and volume of contaminants in the vadose zone
and their rate of migration is essential to determining the most
appropriate steps to take to protect the river now, and in future
years.
After finding unexpected contaminant migration in the vadose zone at
one waste disposal area known as BC cribs--a location where liquids
were discharged directly into the ground--DOE agreed with its
regulators that its understanding of the vadose zone was inadequate to
support the development of a final cleanup remedy for that area and
some others. Although DOE had originally planned to defer some of its
study of the vadose zone until after December 2008, when draft cleanup
plans were due, DOE now agrees that more sampling and analysis of the
vadose zone is needed to guide cleanup decisions. As a result, DOE has
proposed to regulators to extend the date for submitting draft cleanup
plans until 2011. DOE officials said this will allow the time needed to
develop a better understanding of vadose zone conditions and to
investigate potential remedies.
DOE Is Reworking Efforts to Estimate Risks from the Movement of
Contamination toward the River:
In response to the discovery that its previous models to estimate the
future risks of the movement of contamination toward the river were
based on data of questionable reliability, DOE has begun reworking
these efforts. While DOE relies on sampling to determine current
conditions, it uses computer simulation models to predict future
conditions and estimate future risks. In 1998, DOE groundwater program
officials said DOE concluded from its simulation models that the
migration was slow enough that the contaminants included in the study
would not exceed their limits for 1,000 years into the future. However,
DOE was concerned about the completeness of the model and began an
effort, known as the System Assessment Capability, to develop a more
comprehensive model. This $16 million, 8-year effort was cancelled
when, in the course of a lawsuit over Hanford's disposal
plans,[Footnote 15] several quality assurance problems were found,
including discrepancies in the data. DOE abandoned the past modeling
efforts in response to criticisms that the models used inconsistent
assumptions, were based on data of questionable reliability, and had
weak quality control processes. In January 2006, DOE and Washington
State settled the lawsuit. In the settlement agreement, DOE agreed to
re-analyze and update its study of the cleanup's effect on groundwater.
In addition, DOE agreed to consolidate two studies of the cleanup's
effects on groundwater into a single, integrated study.
DOE Is Considering New Treatment Technologies to Replace Those That
Have Not Kept Contamination from Entering the River:
Both DOE and its regulators have determined that the results of all
three of DOE's approaches to treating groundwater--pump-and-treat,
chemical treatment, and natural attenuation--are not fully
satisfactory. Specifically:
* Pump-and-treat. In a 2004 report, the DOE Inspector General concluded
that the pump-and-treat system to remove strontium-90 was ineffective
and that the other four pump-and-treat systems have had mixed results.
However, Hanford's acting groundwater project manager told us that four
of the five pump-and-treat systems at the Hanford site meet the
remedial objectives agreed to with Hanford's regulators. The official
acknowledged that the system to remove strontium-90 was largely
ineffective and that DOE had been trying to obtain permission from the
regulators to turn it off. Both DOE and the regulators told us that the
regulators refused to allow the system to be turned off, however, until
a more effective remedy was found. In March 2006, after spending about
$16 million since 1996 to install and operate the system, DOE turned
the system off with the regulators' permission, and began testing a
chemical barrier to prevent the strontium-90 from entering the river.
* Chemical treatment. In 2004, DOE reported that, based on groundwater
samples, the chemical barrier for chromium was not fully effective, and
that the hazardous form of chromium was detected beyond the barrier and
close to the river. DOE is currently testing alternative approaches to
improve the barrier.
* Natural attenuation. According to monitoring well data, DOE's
reliance on natural attenuation to dissipate a uranium plume near the
city of Richland was ineffective and has not controlled the migration
of uranium to the river. The plume has not dissipated in the 10-year
period since the natural attenuation strategy was adopted. DOE is
currently investigating the plume, testing chemical barriers, and
exploring other ways to mitigate the problem.
In the conference report accompanying the fiscal year 2006 Energy and
Water Development Appropriations Act, the conferees directed DOE to
make $10 million available to analyze and identify new technologies to
address contaminant migration to the Columbia River.[Footnote 16] DOE
convened a study group to identify potential technologies and determine
how best to allocate the funds to support them. According to DOE's
groundwater project manager, if the technologies tested are successful,
DOE will seek funds to expand the systems to fully address these
problems. DOE is testing the following:
* To address problems with pump-and-treat systems, DOE is testing new
approaches to containing strontium-90 and chromium. To contain the
strontium, DOE is testing two techniques: (1) using a chemical to bind
the strontium to the soil until it decays, which would prevent it from
leaching into the river; and (2) planting willow bushes near shore to
capture the strontium in the plants, which can be harvested to dispose
of the strontium. For chromium removal, DOE has adopted a "systems
approach" which includes combining source removal, pump-and-treat
system expansion, and barrier repairs according to DOE's groundwater
project manager. DOE is also planning to test an improvement to the
pump-and-treat system. The test system will use an electric field to
remove the chromium from the groundwater extracted by several of the
existing wells. If it succeeds, DOE's project manager said, they will
expand the pump-and-treat system to include this technology.
* To address problems with the chromium barrier near the river, DOE
plans to inject chemicals through the wells used to create the barrier
to help convert the chromium to a less toxic and less mobile form.
* To address problems with using natural attenuation to dissipate the
uranium plume near the city of Richland, DOE is testing whether
injecting a chemical called polyphosphate can help prevent the uranium
from migrating to the river.
In addition to these activities, DOE plans to research methods to
better understand the existing carbon tetrachloride plume in the center
of the site.
DOE Has Begun To Address Management Weaknesses but Can Further
Strengthen Its Management Plan:
DOE has begun to address management problems with its Columbia River
protection efforts at the Hanford site by proposing management
improvements to better oversee and coordinate its groundwater and
vadose zone activities. Although those steps are important and needed,
we are concerned about DOE's ability to sustain any improvements made.
Similar efforts in the past failed. In our previous work, we reported
that leading organizations use a systematic, results-oriented plan to
sustain management improvement initiatives. Such a plan incorporates
key elements, such as clear goals, performance measures to gauge
progress toward those goals, and an evaluation strategy to help ensure
the initiative is effective. Although DOE is beginning to develop a
plan for its new integration initiative, it has yet to implement key
elements, such as performance measures or an evaluation strategy. These
tools could help measure effectiveness and sustain the benefits of the
initiative over time.
DOE Is Taking Steps to Improve River Protection Management and
Oversight:
DOE is beginning to address longstanding concerns about the management
and oversight of its Columbia River protection efforts at the Hanford
site. In November 2005, we reported that DOE's river protection efforts
continued to be fragmented among two DOE site operations offices and
several site contractors.[Footnote 17] We raised concerns that the
potential existed for duplication, gaps, and inefficiencies.
Subsequently, in the November 2005 conference report accompanying the
Fiscal Year 2006 Energy and Water Development Appropriations
Act,[Footnote 18] the conference committee cited these continuing
management and organization problems and directed DOE to study how to
better integrate its river protection efforts. In response to the
congressional direction, in March 2006, DOE's Assistant Secretary for
Environmental Management developed a new plan to better integrate
Hanford's river protection, vadose zone, and groundwater efforts.
Specifically, DOE's new integration initiative would:
* Consolidate most groundwater and vadose zone characterization and
cleanup activities under a single project. At the time of the
congressional direction, two DOE offices and three main contractors on-
site were collectively responsible for characterizing and cleaning up
vadose zone and groundwater contamination.[Footnote 19] The Office of
River Protection and its contractor, CH2M Hill Hanford Group, were
responsible for characterizing and addressing contamination of the
vadose zone in tank farms--areas where tanks containing radioactive
liquid waste are buried. The Richland Operations Office and its
contractors, Fluor Hanford and Washington Closure Hanford, were
responsible for vadose zone characterization in the central plateau
area of the site and along the river corridor, respectively. In
addition, Fluor Hanford was responsible for groundwater activities in
all areas of the site. Within Fluor Hanford, responsibility for cleanup
of the groundwater and vadose zone was divided between two different
projects with the project handling vadose zone issues also responsible
for addressing removal of old buildings and burial grounds.
To better coordinate vadose zone and groundwater characterization and
cleanup activities, DOE's new integration initiative proposed
consolidating most of this work under a single project managed and
coordinated by Fluor Hanford. To do so, DOE planned to modify existing
contracts with the affected contractors to reflect this reorganization.
In June 2006, the Office of River Protection and the Richland
Operations Office issued a Plan of Action for Hanford Groundwater and
Vadose Zone Integration Improvements. It identified general activities
and areas of responsibility that the Fluor Hanford and CH2M Hill
Hanford Group contractors would be responsible for under the new
initiative. As of the end of July 2006, DOE was negotiating the details
of this reorganization of responsibilities with the contractors and
anticipated having the contracts modified to reflect the changes by
October 1, 2006.
* Better integrate vadose zone, groundwater, and waste disposal site
cleanup decisions. DOE acknowledged that decisions about when and how
to address vadose zone and groundwater contamination were not always
well coordinated, and they generally were not coordinated with
decisions about when and how to address the source contamination in a
waste disposal site located above the vadose zone and groundwater. For
example, initial plans for cleanup decisions of the surface areas in
the Central Plateau were not necessarily linked to the plans for the
underlying groundwater units, according to DOE's groundwater project
manager.
To better integrate vadose zone, groundwater, and waste disposal site
cleanup decisions, DOE proposed to implement a new strategy by the end
of fiscal year 2006 and to work with regulators to better align
regulatory milestone dates for making cleanup decisions about waste
sites, the vadose zone, and the groundwater. DOE's new strategy
includes plans to transfer most vadose zone characterization activities
into the groundwater program.
* Consolidate responsibility for modeling the movement of contaminants
through the vadose zone and groundwater to estimate the potential
current and future health risks. DOE has acknowledged that
inconsistencies and reliability problems existed in the modeling of how
contaminants move through the vadose zone and groundwater, and how the
environmental risks associated with those contaminants were estimated.
A DOE team reviewing the data quality issues and the modeling effort
found that, in addition to issues of the reliability of data used in
the models, various modeling efforts under way were based on different
assumptions, and information about contamination movement was not
always correctly transferred to other models.
To address these problems, DOE proposed to more closely coordinate
modeling and risk assessment activities at the site and strengthen
control over model design so that a common set of databases and
assumptions were being used for decision making. The groundwater
project would have configuration control over any models used so that
any changes to databases and models assumptions would require approval
by the groundwater project before users could implement them.
In addition to these management improvement efforts at the Hanford
site, in May 2006, DOE also established a new Office of Groundwater and
Soil Remediation to improve headquarters' oversight on issues dealing
with soil and groundwater contamination across the DOE complex. The
office is tasked with reviewing all soil and groundwater remedies at
DOE sites, helping to develop technologies to solve groundwater and
soil contamination problems at different DOE sites, and generally
overseeing DOE policy and assessments regarding vadose zone and
groundwater cleanup.
DOE Has Not Fully Implemented a Management Plan to Ensure Improvements
Will Be Sustained:
Given past problems fully implementing and sustaining improvements to
the management of DOE's Columbia River protection efforts at the
Hanford site, it is uncertain whether any improvements that result from
DOE's new integration initiative will be sustained. In 1998, we
reported that DOE lacked a comprehensive and integrated groundwater and
vadose zone program,[Footnote 20] and recommended that DOE implement an
integrated strategy that defined measurable performance goals, clearly
defined leadership roles, and established accountability for meeting
those goals.
In response to our 1998 report, DOE proposed an integrated management
plan to coordinate groundwater and vadose zone work.[Footnote 21] To
accomplish this, DOE assigned a single DOE Assistant Manager in the
Richland Operations Office to coordinate all groundwater and vadose
zone work at the Hanford site. Because DOE's other site office, the
Office of River Protection, and several contractors at the site also
carried out groundwater and vadose zone cleanup, DOE made the Assistant
Manager responsible for ensuring that all groundwater and vadose zone
activities were integrated into a single planning effort. This
"Integration Project" included developing a sitewide approach to
project planning, funding, and information management, and co-locating
contractor staff working on the project to improve coordination. In
addition, the project included improving coordination of efforts to
develop science and technology to address contamination in the vadose
zone and groundwater.
Despite these proposed changes, DOE was unable to effectively implement
the improvements it planned to make. For example, according to a site
official at Hanford who oversaw the initial integration effort, DOE did
not implement key elements of the plan, such as establishing a sitewide
funding profile for all groundwater and vadose zone activities. DOE
implemented other elements of the plan but did not sustain them when
changes, such as how projects were organized and contracts were
structured, occurred at the site. For example, coordinating all
activities through a single federal project manager faltered as site
offices were reorganized and responsibilities were distributed among
three federal project directors. The DOE official from the Hanford
groundwater program attributes the lack of coordination of groundwater
and vadose zone efforts to redefining project activities, which
resulted in groundwater and vadose zone activities being managed as
separate projects and changes in the structure of site contracts, which
resulted in scopes of work being organized and assigned differently. A
2001 National Academy of Sciences review of DOE's groundwater science
and technology activities noted that DOE's integration efforts had been
superimposed over several already existing cleanup projects without
establishing a clear line of responsibility for results. The National
Academy said that this left the program operating in an unstable
environment.[Footnote 22]
To increase the chances of success for DOE's current improvement
initiative, we assessed DOE's management of its new integration
initiative against model practices used by organizations that
successfully sustained improvement initiatives. We previously reported
that in high-performing organizations, management improvement
initiatives are sustained by using a systematic, results-oriented plan
that incorporates a rigorous measurement of progress.[Footnote 23] Such
a plan typically included the following steps: (1) defining clear
program goals for the initiative--important because it focuses an
organization's efforts on achieving specific outcomes and allows as
assessment of future performance against those goals; (2) developing an
implementation strategy that sets milestones and establishes individual
responsibilities--important because it establishes accountability for
achieving the initiative's goals; (3) establishing results-oriented
performance measures--important because it allows organizations to
measure progress toward achieving their goals; and (4) using results-
oriented data to evaluate the effectiveness of the initiative and make
additional changes where warranted--important because periodic
evaluations can reveal systemic problems and promote continuous program
improvement over the long term.
As of July 2006, DOE had implemented two components and not implemented
other management components to help ensure that it could sustain any
improvements resulting from its new integration initiative. For
example, in putting forward its plan to Congress, DOE described a
general goal of its new integration initiative as better coordination
of Hanford's groundwater and vadose zone cleanup activities in order to
achieve greater protection of the Columbia River. DOE also outlined
steps it would take toward its goal, such as (1) consolidating site
modeling and risk assessments; (2) consolidating river protection
efforts under a single project; and (3) integrating soil and
groundwater cleanup decisions. In going forward, DOE could further
refine its goals to include measurable steps to achieving its overall
goal of protecting the river. For example, a more measurable goal would
be the reduction of contamination reaching the river or ensuring
duplication of efforts is reduced in order to better protect the
Columbia River.
DOE had established general milestones and individual responsibilities
for implementing its new integration initiative. For example, DOE's
plan of action sets 16 milestones by September 2006 by which various
initial steps are to be taken. DOE also reported that five of these
actions, including making staff assignments and establishing an
integrated project team, had been completed.
DOE has not established results-oriented measures to gauge the progress
of its integrated management initiative. In outlining the steps it will
take under its plan, DOE has generally concentrated on establishing
relationships and moving work-scope between various DOE offices and
contractors, and not on outcomes, such as reducing redundancies or gaps
in river protection efforts. Without clear results-oriented performance
measures to gauge progress, problems that occur under a fragmented
management structure could be masked and allowed to continue under
DOE's integration plan. Translating the general goal of "better
integration" and "protection of the river" into a more specific goal,
such as reducing duplicative efforts, would help DOE identify ways it
could measure results and, therefore, gauge progress toward the goals
of its integration initiative.
Finally, DOE has not yet identified an evaluation strategy to determine
whether the steps it is taking are effective and are being sustained.
Without an evaluation strategy based on clear goals and results-
oriented measures, DOE will not have the results-oriented data
necessary to objectively evaluate progress and implement corrective
actions as needed.
Although DOE is still working to define and implement its integration
initiative, fully developing and putting in place key elements outlined
above could help ensure that any program improvements are sustained in
the future. DOE's Hanford Assistant Manager in charge of overseeing the
latest management improvements for the river protection program said
that, beyond outlining broad goals and setting the framework for roles
and responsibilities, DOE had not yet fully developed a project
execution plan for the new initiative. He said that the management plan
is still evolving and that future steps may include more clearly
defining performance measures and strategies for evaluating the
initiative's effectiveness.
Conclusions:
DOE is involved in a lengthy process to identify and address potential
threats to the Columbia River from contamination in the soil and
groundwater at the Hanford site. This requires a good understanding of
the risks to the river and an effective management strategy for
addressing those risks. Over the years, we and others have raised
concerns about DOE's efforts to understand the nature and extent of the
contamination and how best to manage the efforts to prevent
contamination from seeping into the river. In recent months, DOE has
taken several steps to gain a better understanding of the risks from
the contamination as well as to improve its management of the program
and integration of activities. While these steps are encouraging, DOE
has not yet decided whether to put in place elements of a management
plan that could help ensure potential benefits of these improvements
will be continued, even when organizational and contract changes occur
at the site. Such a management plan should include developing results-
oriented performance measures, using the measures to determine progress
toward objectives, and making changes as necessary.
Recommendation for Executive Action:
To increase the likelihood that DOE will effectively implement and
sustain improvements in its program to protect the Columbia River from
contamination at the Hanford site, we recommend that the Secretary of
Energy strengthen the management improvement plan by establishing
results-oriented performance measures and regular evaluations to gauge
the program's effectiveness.
Agency Comments and Our Evaluation:
We provided a draft of this report to DOE for its review and comment.
In a letter from DOE's Principal Deputy Assistant Secretary for
Environmental Management, DOE agreed with the report's findings and
fully endorsed the recommendation to adopt results-oriented performance
measures and regular evaluations of the river protection program. DOE
acknowledged that performance measures and regular evaluations are a
fundamental and integral component of sound project management practice
and said that it would incorporate them into the project. The full text
of DOE's comments is presented in appendix II.
As arranged with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this report until
7 days after the date of this report. At that time, we will send copies
of this report to other interested congressional committees and to the
Secretary of Energy. Copies will be made available to others on
request. In addition, this report will be available at no charge on our
Web site at [Hyperlink, http://www.gao.gov].
If you or your staff have any questions on this report, please contact
me at (202) 512-3841 or by e-mail at aloisee@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this report. Other staff contributing to this
report are listed in appendix III.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Scope and Methodology:
To understand the risk to the Columbia River from Hanford site
contamination, we reviewed risk assessments, groundwater, vadose zone,
and river monitoring reports by the Department of Energy (DOE), DOE's
Office of Inspector General, DOE contractors including the Pacific
Northwest National Laboratory, and various outside groups such as the
National Academy of Sciences. We interviewed DOE officials at both
headquarters and the Hanford site, as well as contractor staff at
Hanford, to obtain information on the distribution of contamination at
Hanford and the steps being taken to better understand it. To
understand DOE's approach to the vadose zone, we primarily reviewed our
1998 report, as well as documents prepared by DOE and its staff in
response to that report. We also reviewed documents DOE submitted to
regulators related to changing Tri-Party Agreement milestones; the
documents were to be used for preparing initial drafts of plans for all
remaining contaminated areas. We discussed the proposed change to the
December 2008 Tri-Party Agreement milestone with DOE officials and
regulators. In reviewing DOE's efforts to determine the extent of risk
of future damage to the river from contamination, we reviewed documents
related to DOE's sitewide modeling effort and legal documents related
to this modeling effort. We discussed these modeling efforts with DOE
officials, contractors, and regulators.
In assessing DOE's efforts to deploy effective technologies to address
contamination near the river, we visited the sites of existing and
planned cleanup efforts. We discussed current existing projects with
DOE officials, contractor staff, regulators, and stakeholders, and
reviewed reports prepared for DOE and others. To assess technology
plans developed by DOE to use $10 million of funds earmarked for fiscal
year 2006, we attended DOE screening panels, reviewed reports prepared
by DOE and others, and discussed the efforts with DOE regulators.
To review DOE efforts to strengthen the management of its river
protection efforts, we reviewed DOE's past and current management
plans. We obtained DOE's recent integration initiative proposals,
including its proposal to Congress in March 2006 and its subsequent
Memorandum of Agreement and Plan of Action. We discussed DOE's approach
with headquarters and site officials. We reviewed previous work in
which we documented strategies used by high-performing organizations to
implement improvement initiatives. We reviewed DOE's proposed
integration initiative and compared it to key elements of these
strategies. We also discussed DOE's plans to implement its strategy
with knowledgeable site officials.
In reviewing the management of DOE programs related to groundwater and
river protection, we reviewed DOE efforts to assure that contamination
levels were accurately reported; we also interviewed regulators, DOE
officials, and contractors regarding data reliability. While we did not
independently test the contaminant data, we reviewed controls over how
the data were obtained and tested, visited sampling locations and
discussed sampling methods with key staff, and reviewed other relevant
information to determine that the data were sufficiently reliable for
the purposes of our report. We conducted our work from December 2005 to
August 2006 in accordance with generally accepted government auditing
standards.
[End of section]
Appendix II: Comments from the Department of Energy:
Department of Energy:
Washington, DC 20585:
August 18, 2006:
Mr. Gene Aloise:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Aloise:
The Department of Energy (DOE) has reviewed, the draft report entitled
"Nuclear Waste - DOE's Efforts to Protect the Columbia River from
Contamination Could Be Further Strengthened." We find the report to be
generally accurate, and we fully endorse the single recommendation
offered by the U.S. Government Accountability Office (GAO). The GAO
recommendation states:
"To increase the likelihood that DOE will effectively implement and
sustain improvements in its program to protect the Columbia River from
contamination, GAO recommends that the Secretary of Energy establish
results-oriented performance measures and regular evaluations to gauge
the program's effectiveness."
We appreciate the thoroughness and professionalism that the GAO team
exhibited throughout the conduct of this audit. The team has made every
effort to be accurate in their report and has interacted with DOE staff
throughout the process to ensure the report has value.
In response to Conference Report (109-275) that accompanied the Fiscal
Year 2006 Energy and Water Development Appropriations Act (P.L. 109-
103), I submitted a March 29, 2006, Report to Congress that outlines
DOE's proposal to:
1. Consolidate modeling and risk assessment work for the Hanford site;
2. Consolidate all groundwater and vadose zone activities under the
Groundwater Remediation Project; and:
3. Integrate groundwater, vadose zone, and source area cleanup
decisions.
The report identified specific actions and schedules for
implementation. The GAO correctly identified that this report did not
include specific results-oriented performance measures and regular
evaluations to gauge the improvements' effectiveness. We agree that
such measures and evaluations are a fundamental and integral component
of sound project management practice and the development and
implementation of such measures and evaluations will strengthen and
ensure DOE's plans to protect the Columbia River. Therefore,
DOE will incorporate the actions identified in the aforementioned March
29, 2006, Report to Congress into our project baseline, including
appropriate specific results-oriented performance measures. We will
also be performing periodic evaluations to gauge the improvements'
effectiveness.
If you have any questions, please call me at (202) 586-7709 or Mr. Mark
A. Gilbertson, Deputy Assistant Secretary for Engineering and
Technology, at (202) 586-0755.
Sincerely,
Signed by:
Charles E. Anderson (Acting for) Assistant Secretary for Environmental
Management:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise, (202) 512-3841:
Staff Acknowledgments:
In addition to the contact named above, Bill Swick, Assistant Director;
Chris Abraham; Doreen Feldman; Nancy Kintner-Meyer; Jeffrey Larson;
Omari Norman; Alison O'Neill; Thomas Perry; and Stan Stenersen made
significant contributions to this report. Others who made important
contributions included Mark Braza, Doreen Eng, and Mehrzad Nadji.
FOOTNOTES
[1] Formally titled the Hanford Federal Facility Agreement and Consent
Order, it was signed in May 1989 and has been amended numerous times
since then.
[2] Some Hanford cleanup activities are conducted under the
requirements of CERCLA, while others are conducted under RCRA. Though
the terminology used to describe cleanup requirements under the two
laws differs, the processes generally are functionally equivalent. In
this report we use the terminology of the CERCLA program.
[3] 42 U.S.C. §§ 300f --300j-26.
[4] The Hanford site is divided into 57 different operable units. These
operable units are divided into source operable units--covering areas
such as contamination in buildings, soils, and burial grounds--and
groundwater operable units. Forty-seven source operable units address
contamination in the soils and vadose zone, and ten groundwater
operable units address contamination in the groundwater. As of July
2006, field investigations for one groundwater operable unit had been
completed.
[5] Under CERCLA, DOE must prepare a Record of Decision. Under RCRA,
DOE prepares a Corrective Measures Study. For either, DOE generally
provides the same information about extent and nature of contaminants,
and proposed remedies.
[6] See, for example, GAO, Hanford Waste Treatment Plant: Contractor
and DOE Management Problems Have Led to Higher Costs, Construction
Delays, and Safety Concerns, GAO-06-602T (Washington, D.C.: Apr. 6,
2006); GAO, Nuclear Waste: Absence of Key Management Reforms on
Hanford's Cleanup Project Adds to Challenges of Achieving Cost and
Schedule Goals, GAO-04-611 (Washington, D.C.: June 9, 2004); GAO,
Nuclear Waste: Challenges to Achieving Potential Savings in DOE's High-
Level Waste Cleanup Program, GAO-03-593 (Washington, D.C.: June 17,
2003).
[7] Chromium is toxic to fish.
[8] GAO, Department of Energy: Preliminary Information on the Potential
for Columbia River Contamination from the Hanford Site, GAO-06-77R
(Washington, D.C.: Nov. 4, 2005).
[9] National Academy of Sciences, Science and Technology for
Environmental Cleanup at Hanford (Washington, D.C.: 2001); Office of
Inspector General, Groundwater Remediation Activities at Hanford, DOE/
IG-0655, (Washington, D.C.: July 22, 2004); and Office of Inspector
General, Well Decommissioning Activities at the Hanford Site, DOE/IG-
0670, (Washington, D.C.: Jan. 3, 2005).
[10] GAO, Nuclear Waste: Understanding of Waste Migration at Hanford is
Inadequate for Key Decisions, GAO/RCED-98-80 (Washington, D.C.: March
13, 1998).
[11] See GAO, Contract Reform: DOE Has Made Progress, but Actions
Needed to Ensure Initiatives Have Improved Results, GAO-02-798
(Washington, D.C.: Sept. 13, 2002); also, GAO, DOE Contracting:
Improved Program Management Could Help Achieve Small Business Goal, GAO-
06-501 (Washington, D.C.: April 7, 2006).
[12] In addition, during Hanford's past operations, DOE and its
predecessor agencies directly discharged to the river cooling water
from the reactors which was contaminated with about 110 million curies
of mostly short-lived radionuclides. (Radioactivity is measured in
curies. One curie equals 37 billion atomic disintegrations per second.)
Operations also resulted in air emissions of about 20 million curies
from 1944 to 1972. The portion that went to the river is unknown. These
discharges are no longer occurring.
[13] Saltcake is a moist sand-like material, such as sodium salts, that
have crystallized from the waste.
[14] While the groundwater at Hanford is generally not used as a source
for drinking water, drinking water standards are still a common measure
of the extent of contamination. EPA sets the maximum contaminant level
for each contaminant allowed in water delivered to a user of any public
water system. This is the federal standard for the contaminant.
[15] Washington v. Bodman, Civ.A. No. 2:03-cv-05018-AAM (E.D. Wash.
filed Mar. 4, 2003).
[16] H.R. Rep. No. 109-275, at 172 (2005).
[17] GAO, Department of Energy: Preliminary Information on the
Potential for Columbia River Contamination from the Hanford Site, GAO-
06-77R (Washington, D.C.: Nov. 4, 2005).
[18] H.R. Rep. No. 109-275, at 172 (2005).
[19] In addition, DOE's PNNL was responsible for support activities,
such as science and technology development and groundwater monitoring
activities.
[20] GAO, Nuclear Waste: Understanding of Waste Migration at Hanford is
Inadequate for Key Decisions, GAO/RCED-98-80 (Washington, D.C.: March
13, 1998).
[21] We have also previously reported about lack of integration among
DOE river protection efforts. For example, in 1992, we reported that
DOE lacked coordination in its efforts to monitor and characterize
contamination in the vadose zone. See GAO, Nuclear Waste: Improvements
Needed in Monitoring Contaminants in Hanford Soils, GAO/RCED-92-149
(Washington, D.C.: July 6, 1992).
[22] National Academy of Sciences, Science and Technology for
Environmental Cleanup at Hanford (Washington, D.C.: 2001).
[23] See GAO, Contract Reform: DOE Has Made Progress, but Actions
Needed to Ensure Initiatives Have Improved Results, GAO-02-798
(Washington, D.C.: Sept. 13, 2002); also, GAO, DOE Contracting:
Improved Program Management Could Help Achieve Small Business Goal, GAO-
06-501 (Washington, D.C.: Apr. 7, 2006).
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