Nuclear and Worker Safety
Limited Information Exists on Costs and Reasons for Work Stoppages at DOE's Hanford Site Gao ID: GAO-09-451 May 7, 2009The Department of Energy's (DOE) Hanford Site in Washington State stores 56 million gallons of untreated radioactive and hazardous wastes resulting from decades of nuclear weapons production. DOE is constructing facilities at the site to treat these wastes before permanent disposal. As part of meeting health, safety, and other standards, work at the site has sometimes been suspended to address safety or construction quality issues. This report discusses (1) work stoppages from January 2000 through December 2008 and what is known about them, (2) the types of costs associated with work stoppages and who paid for them, and (3) whether more effective regulation or oversight could have prevented the work stoppages. GAO interviewed knowledgeable DOE and contractor officials about these events. When documentation was available, GAO obtained DOE and contractor accident and safety incident reports, internal DOE and independent external evaluations, and costs.
DOE officials reported that from January 2000 through December 2008, activities to manage hazardous wastes stored in underground tanks and to construct a waste treatment facility have been suspended at least 31 times to address safety concerns or construction quality issues. Federal regulations governing contracts do not require contractors to formally report work stoppages and the reasons for them, and DOE does not routinely collect information on them. As a result, supporting documentation on work stoppages was limited. DOE reported that work stoppages varied widely in duration, with some incidents lasting a few hours, and others lasting 2 years or more. Officials reported that about half the work stoppages resulted from concerns about worker or nuclear safety and included proactive safety "pauses," which typically were brief and taken to address an unsafe condition that could potentially harm workers. The remainder of the work stoppages occurred to address concerns about construction quality at the waste treatment plant. Under the terms of the cost-reimbursement contracts for managing the tanks and constructing the waste treatment plant, DOE generally pays all costs associated with temporary work stoppages and does not require the contractor to separately track these costs, although DOE and the contractors do track some costs under certain circumstances. For example, the costs for cleaning up, investigating, and implementing corrective actions were collected for a July 2007 hazardous waste spill at one of the tank farms; these costs totaled over $8 million. The contractors, too, can face financial consequences, such as reduction in earned fee or fines and penalties assessed by DOE or outside regulators. For example, DOE may withhold payment of a performance award, called a fee, from contractors for failure to meet specified performance objectives or to comply with applicable environmental, safety, and health requirements. For the majority of DOE's reported work stoppages, supporting documentation was not available to evaluate whether better oversight or regulation could have prevented them. For 2 of 31 work stoppages where some information was available--specifically, accident investigations or prior GAO work--inadequate oversight contributed to the work stoppages. For example, the accident investigation report for the tank farm spill found that oversight and design reviews by DOE's Office of River Protection failed to identify deficiencies in the tanks' pump system design, which did not meet nuclear technical safety requirements. Similarly, in 2006, GAO found that DOE's failure to effectively implement nuclear safety requirements contributed substantially to schedule delays and cost growth at Hanford's waste treatment plant. With regard to regulations, however, officials from DOE, the Defense Nuclear Facilities Safety Board, and DOE's Office of Inspector General said they did not believe that insufficient regulation was a factor in these events.
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-09-451, Nuclear and Worker Safety: Limited Information Exists on Costs and Reasons for Work Stoppages at DOE's Hanford Site
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
May 2009:
Nuclear and Worker Safety:
Limited Information Exists on Costs and Reasons for Work Stoppages at
DOE's Hanford Site:
GAO-09-451:
GAO Highlights:
Highlights of GAO-09-451, a report to congressional requesters.
Why GAO Did This Study:
The Department of Energy‘s (DOE) Hanford Site in Washington State
stores 56 million gallons of untreated radioactive and hazardous wastes
resulting from decades of nuclear weapons production. DOE is
constructing facilities at the site to treat these wastes before
permanent disposal. As part of meeting health, safety, and other
standards, work at the site has sometimes been suspended to address
safety or construction quality issues. This report discusses (1) work
stoppages from January 2000 through December 2008 and what is known
about them, (2) the types of costs associated with work stoppages and
who paid for them, and (3) whether more effective regulation or
oversight could have prevented the work stoppages. GAO interviewed
knowledgeable DOE and contractor officials about these events. When
documentation was available, GAO obtained DOE and contractor accident
and safety incident reports, internal DOE and independent external
evaluations, and costs.
What GAO Found:
DOE officials reported that from January 2000 through December 2008,
activities to manage hazardous wastes stored in underground tanks and
to construct a waste treatment facility have been suspended at least 31
times to address safety concerns or construction quality issues.
Federal regulations governing contracts do not require contractors to
formally report work stoppages and the reasons for them, and DOE does
not routinely collect information on them. As a result, supporting
documentation on work stoppages was limited. DOE reported that work
stoppages varied widely in duration, with some incidents lasting a few
hours, and others lasting 2 years or more. Officials reported that
about half the work stoppages resulted from concerns about worker or
nuclear safety and included proactive safety ’pauses,“ which typically
were brief and taken to address an unsafe condition that could
potentially harm workers. The remainder of the work stoppages occurred
to address concerns about construction quality at the waste treatment
plant.
Under the terms of the cost-reimbursement contracts for managing the
tanks and constructing the waste treatment plant, DOE generally pays
all costs associated with temporary work stoppages and does not require
the contractor to separately track these costs, although DOE and the
contractors do track some costs under certain circumstances. For
example, the costs for cleaning up, investigating, and implementing
corrective actions were collected for a July 2007 hazardous waste spill
at one of the tank farms; these costs totaled over $8 million. The
contractors, too, can face financial consequences, such as reduction in
earned fee or fines and penalties assessed by DOE or outside
regulators. For example, DOE may withhold payment of a performance
award, called a fee, from contractors for failure to meet specified
performance objectives or to comply with applicable environmental,
safety, and health requirements.
For the majority of DOE‘s reported work stoppages, supporting
documentation was not available to evaluate whether better oversight or
regulation could have prevented them. For 2 of 31 work stoppages where
some information was available”specifically, accident investigations or
prior GAO work”inadequate oversight contributed to the work stoppages.
For example, the accident investigation report for the tank farm spill
found that oversight and design reviews by DOE‘s Office of River
Protection failed to identify deficiencies in the tanks‘ pump system
design, which did not meet nuclear technical safety requirements.
Similarly, in 2006, GAO found that DOE‘s failure to effectively
implement nuclear safety requirements contributed substantially to
schedule delays and cost growth at Hanford‘s waste treatment plant.
With regard to regulations, however, officials from DOE, the Defense
Nuclear Facilities Safety Board, and DOE‘s Office of Inspector General
said they did not believe that insufficient regulation was a factor in
these events.
What GAO Recommends:
GAO is recommending that the Secretary of Energy (1) establish criteria
for when DOE should direct contractors to track and report reasons for
and costs of work stoppages and (2) specify the types of costs to be
tracked. In commenting on a draft of the report, DOE generally agreed
with GAO‘s recommendations but plans to implement them only within
Environmental Management.
View [hyperlink, http://www.gao.gov/products/GAO-09-451] or key
components. For more information, contact Gene Aloise at (202) 512-3841
or aloisee@gao.gov.
[End of section]
Contents:
Letter:
Background:
DOE Officials Reported Varied Reasons for Work Stoppages at Tank Farms
and the Waste Treatment Plant, but Supporting Documentation Is Limited:
DOE Generally Pays Costs Associated with Work Stoppages:
Inadequate Oversight Cited as Contributing to Some Work Stoppages:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Work Stoppages Identified by the Office of River
Protection:
Appendix III: Comments from the Department of Energy:
Appendix IV: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Summary of Work Stoppages at the Hanford Site, January 2000 to
December 2008 (in order of duration):
Figures:
Figure 1: Double-Shell Waste Tanks under Construction and Completed
Tank Farm at DOE's Hanford Site:
Figure 2: Waste Treatment Plant Primary Facilities under Construction
as of November 2008:
Abbreviations:
CH2M Hill: CH2M Hill Hanford Group
DOE: Department of Energy:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
May 7, 2009:
The Honorable Henry A. Waxman:
Chairman:
The Honorable John D. Dingell:
Chairman Emeritus:
The Honorable Joe Barton:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Bart Stupak:
Chairman:
The Honorable Greg Walden:
Ranking Member:
Subcommittee on Oversight and Investigations:
Committee on Energy and Commerce
House of Representatives:
The Honorable Jay Inslee:
House of Representatives:
The Department of Energy (DOE) is responsible for one of the world's
largest environmental cleanup programs--the treatment and permanent
disposal of wastes created by the production of materials for the
nation's nuclear weapons program. At the production sites, more than 5
decades of nuclear weapons production left a legacy of chemical,
hazardous, and radioactive waste. DOE's Hanford Site in southeastern
Washington State stores the majority of the untreated nuclear waste--
about 56 million gallons held in 177 large underground storage tanks
clustered in areas known as tank farms.[Footnote 1] DOE has estimated
that it will take tens of billions of dollars and decades to treat and
permanently dispose of this waste.
DOE's Office of River Protection oversees activities at the tank farms
but relies on contractors to carry out the work. At the Hanford Site,
one contractor, CH2M Hill Hanford Group (CH2M Hill) is responsible for
managing and operating the tank farms, which includes maintaining safe
storage of the waste and preparing it for eventual retrieval.[Footnote
2] A second contractor, Bechtel National Inc. (Bechtel), is responsible
for carrying out a multibillion dollar construction project for new
facilities, known as the waste treatment plant, to treat the tank waste
and prepare it for permanent disposal.[Footnote 3] DOE spends about $1
billion annually on these two contracts alone. In carrying out these
activities, DOE and its contractors must comply with health and safety
standards to protect workers, the public, and the environment.
As part of meeting health and safety standards, work activities have,
at times, been suspended[Footnote 4] over the past several years to
address concerns with worker safety or nuclear safety at the tank farms
and during the design and construction of waste treatment facilities.
Such suspensions vary in duration and allow for additional worker
training or corrective actions. In this report, we refer to these
suspensions as work stoppages. To provide a better understanding of
these occurrences and potential financial consequences, this report
discusses (1) work stoppages from January 2000 through December 2008 at
DOE's Hanford Site tank farms and waste treatment plant and what is
known about their nature, duration, and scope; (2) the types of costs
associated with work stoppages and what portions were paid by the
government and by the contractor; and (3) whether more effective
regulation or oversight might have prevented the work stoppages.
In conducting our work, we obtained a listing of work stoppages at the
tank farms and waste treatment plant from officials at DOE's Office of
River Protection. We attempted to independently verify any work
stoppages that occurred at the tank farms or waste treatment plant by
reviewing accident investigation reports and existing DOE reporting
systems for events that could have resulted in a temporary work
stoppage. Of the 31 work stoppages reported, only 3 had any supporting
documentation. For those 3 work stoppages, we reviewed and analyzed the
documents provided to obtain a more thorough understanding of the
events, causes, and corrective actions and whether DOE regulation or
oversight was a contributing factor. We also interviewed DOE officials
with the Office of River Protection, as well as DOE headquarters
officials with the Offices of Environmental Management; Health, Safety,
and Security; and General Counsel. We interviewed officials with
regulatory and oversight entities, including the Defense Nuclear
Facilities Safety Board, the Occupational Safety and Health
Administration, and the Nuclear Regulatory Commission. Further, we met
with union representatives at the Hanford Site to obtain union
perspectives on work stoppages and safety. A more detailed description
of our scope and methodology appears in appendix I. We conducted this
performance audit from June 2008 to April 2009, in accordance with
generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
Background:
Since plutonium production ended at the Hanford Site in the late 1980s,
DOE has focused on cleaning up the radioactive and hazardous waste
accumulated at the site. It has established an approach for
stabilizing, treating, and disposing of the site's tank wastes. Its
planned cleanup process involves removing, or retrieving, waste from
the tanks; treating the waste on site; and ultimately disposing of the
lower-activity radioactive waste on site and sending the highly
radioactive waste to a geologic repository for permanent disposal. As
cleanup has unfolded, however, the schedule has slipped, and the costs
have mounted. According to DOE's latest estimate in June 2008,
treatment of the waste is not expected to begin until late 2019 and
could continue until 2050 or longer. The following two figures show a
tank farm and construction of waste treatment plant facilities at the
Hanford Site.
Figure 1: Double-Shell Waste Tanks under Construction and Completed
Tank Farm at DOE's Hanford Site:
[Refer to PDF for image: two photographs]
Source: DOE.
[End of figure]
Figure 2: Waste Treatment Plant Primary Facilities under Construction
as of November 2008:
[Refer to PDF for image: photograph]
Source: DOE.
[End of figure]
Most of the cleanup activities at Hanford, including the emptying of
the underground tanks, are carried out under the Hanford Federal
Facility Agreement and Consent Order among DOE, Washington State's
Department of Ecology, and the federal Environmental Protection Agency.
Commonly called the Tri-Party Agreement, this accord lays out legally
binding milestones for completing the major steps of Hanford's waste
treatment and cleanup processes. The agreement was signed in May 1989
and has been amended a number of times since then. A variety of local
and regional stakeholders, including county and local governmental
agencies, citizen and advisory groups, and Native American tribes, also
have long-standing interests in Hanford cleanup issues.
Two primary contractors are carrying out these cleanup activities; one
is responsible for managing and operating the tank farms, and the other
for constructing the facilities to treat the tank waste and prepare it
for permanent disposal. During our review, these contractors were CH2M
Hill and Bechtel, respectively. Both contracts are cost-reimbursement
contracts, which means that DOE pays all allowable costs.[Footnote 5]
In addition, the contractors can also earn a fee, or profit, by meeting
specified performance objectives or measures. Applicable DOE orders and
regulations are incorporated into these contracts, either as distinct
contract clauses or by reference. For example, contractors are required
to use an accounting system that provides consistency in how costs are
accumulated and reported so that comparable financial transactions are
treated alike. Such a system is to include consistent practices for
determining how various administrative costs are assessed or how
indirect costs for labor are calculated. Contractors also are required
to implement an integrated safety management system, a set of
standardized practices that allow the contractor to identify hazards
associated with a specific scope of work, to establish controls to
ensure that work is performed safely, and to provide feedback that
supports continuous improvement. The system, which allows contractors
to stop work when conditions are unsafe, is intended to instill in
everyone working at the site a sense of responsibility for safety. This
policy is reinforced by labor agreements between the contractor and its
workforce that explicitly allow work stoppages as needed for safety and
security reasons.
With few exceptions, DOE's sites and facilities are not regulated by
the Nuclear Regulatory Commission or by the Occupational Safety and
Health Administration. Instead, DOE provides internal oversight at
several different levels. DOE's Office of River Protection oversees the
contractors directly. In addition, the Office of Environmental
Management provides funding and program direction. DOE's Office of
Enforcement[Footnote 6] and other oversight groups within the Office of
Health, Safety, and Security oversee contractors' activities to ensure
nuclear and worker safety. Finally, the Defense Nuclear Facilities
Safety Board, an independent oversight organization created by Congress
in 1988, provides advice and recommendations to the Secretary of Energy
to help ensure adequate protection of public health and safety.
DOE Officials Reported Varied Reasons for Work Stoppages at Tank Farms
and the Waste Treatment Plant, but Supporting Documentation Is Limited:
DOE officials reported that from January 2000 through December 2008,
work on the Hanford tank farms and the waste treatment plant
temporarily stopped at least 31 times to address various safety or
construction concerns. These work stoppages ranged in duration from a
few hours to more than 2 years, yet little supporting documentation of
these occurrences exists.
Work Was Stopped to Address Safety or Construction Concerns:
DOE reported that of the 31 work stoppages, 12 occurred at the tank
farms and 19 at the waste treatment plant. Sixteen of the work
stoppages reportedly resulted from concerns about safety. A complete
listing of these work stoppages is included in appendix II. These work
stoppages were initiated to respond directly to an event in which
property was damaged or a person injured, or they addressed an unsafe
condition with the potential to harm workers in the future. Four of
these work stoppages were relatively brief, lasting less than 2 days,
and were characterized by DOE and officials as proactive safety
"pauses." For example, in October 2007, after a series of slips, trips,
or falls during routine activities, contractor managers stopped work at
the waste treatment plant site for 1 hour to refresh workers'
understanding of workplace hazards.
The following two examples, for which supporting documentation was
available, illustrate the types of work stoppages occurring at the
Hanford Site because of safety concerns:
* Controlling worker exposure to tank farm vapors. Beginning in 2002,
as activities to transfer waste from leak-prone, single-shell tanks to
more secure double-shell tanks disturbed tank contents, the number of
incidents increased in which workers complained of illnesses, coughing,
and skin irritation after exposure to the tank vapors. The Hanford
underground storage tanks contain a complex variety of radioactive
elements and chemicals that have been extensively mixed and commingled
over the years, and DOE is uncertain of the specific proportions of
chemicals contained in any one tank. These constituents generate
numerous gases, such as ammonia, hydrogen, and volatile organic
compounds, which are purposely vented to release pressure on the tanks,
although some gases also escape through leaks. During the 1990s, the
tank farm contractor evaluated potential hazards and determined that if
workers around the tanks used respirators, they would be sufficiently
protected from harmful gases. DOE reported in 2004, however, that
disturbing the tank waste during transfers had changed the
concentration of gases released in the tanks and that no standards for
human exposure to some of these chemicals existed. To protect workers'
health, in 2004 the tank farm contractor equipped workers with tanks of
air like those used by firefighters. Work at the tank farms stopped
intermittently for about 2 weeks as a result, in part because the
contractor had to locate and procure sufficient self-contained air and
equipment for all workers.
* Accidental spill of radioactive and chemical wastes at tank S-102. In
July 2007, as waste was being pumped out of a single-shell to a double-
shell tank, about 85 gallons of waste was spilled. DOE has been
gradually emptying waste from Hanford's single-shell tanks into double-
shell tanks in preparation for treatment and permanent disposal, but
because the tank waste contains sludge and solids, waste removal has
been challenging. Because the tanks were not designed with specific
waste retrieval features, waste must be retrieved through openings,
called risers, in the tops of the tanks; technicians must insert
specially designed pumps into the tanks to pump the waste up about 45
to 60 feet to ground level. DOE has used a variety of technologies to
loosen the solids, including sprays of acid or water to help break up
the waste and a vacuum-like system to suck up and remove waste through
the risers at the top. On July 27, 2007, during retrieval of
radioactive mixed waste from a 758,000-gallon single-shell tank, a pump
failed, spilling 85 gallons of highly radioactive waste to the ground.
At least two workers were exposed to chemical vapors, and later several
workers reported health effects they believed to be related to the
spill. Retrieval operations for all single-shell tanks were suspended
after the accident, and DOE did not resume operations until June 2008,
a delay of 1 year, while the contractor cleaned up the spill and DOE
and the contractor investigated the accident to evaluate the cause, the
contractor's response, and appropriate corrective action.
DOE officials reported that the remaining 15 work stoppages resulted
from concerns about construction quality and involved rework to address
nuclear safety or technical requirements that had not been fully met,
such as defective design, parts fabrication and installation, or faulty
construction. For example:
* Outdated ground-motion studies supporting seismic design of the waste
treatment plant. In 2002, the Defense Nuclear Facilities Safety Board
began expressing concerns that the seismic standards used to design the
waste treatment facilities were not based on the most current ground-
motion studies and computer models or on the geologic conditions
present directly beneath the construction site. After more than 2 years
of analysis and discussion, DOE contracted for an initial seismic
analysis, which confirmed the Defense Nuclear Facilities Safety Board's
concerns that the seismic criteria were not sufficiently conservative
for the largest treatment facilities--the pretreatment facility and the
high-level waste facility. Revising the seismic criteria caused Bechtel
to recalculate thousands of engineering estimates and to rework
thousands of design drawings to ensure that tanks, piping, cables, and
other equipment in these facilities were adequately anchored. Bechtel
determined that the portions of the building structures already
constructed were sufficiently robust to meet the new seismic
requirements. By December 2005, however, Bechtel estimated that
engineering rework and other changes to tanks and other equipment
resulting from the more conservative seismic requirement would increase
project costs substantially and add as much as 26 months to the
schedule. Ultimately, work on the two facilities was suspended for 2
years, from August 2005 until August 2007. About 900 workers were laid
off as a result.
Information on Work Stoppages Is Not Consistently Collected:
DOE does not routinely collect or formally report information about
work stoppages, in part because federal regulations governing contracts
do not require contractors to track work stoppages and the reasons for
them.[Footnote 7] While federal acquisition regulations do require that
contractors implement a reliable cost-accounting system, the
regulations do not require contractors to centrally collect information
on the specific circumstances surrounding a work stoppage. Without a
centralized system for collecting explanatory data on work stoppages,
the majority of information DOE reported to us is based on contractors'
and DOE officials' recollections of those events or on officials'
review of detailed logs maintained at each of the facilities.
Officials expressed concern that systematically monitoring all work
stoppages could send the message that work stoppages should be avoided,
possibly hampering effective implementation of DOE's integrated safety
management policy. This policy explicitly encourages any employee to
"stop work" to address conditions that raise safety concerns. Officials
said they believe that work stoppages help bolster workplace safety and
construction quality because work can be halted and corrective action
taken before someone is seriously injured, property is seriously
damaged, or poor workmanship has compromised the quality and
functionality of a facility. Officials said that systematically
monitoring all types of work stoppages could ultimately discourage
workers from halting activities when unsafe conditions or construction
problems emerge in the workplace.
DOE Generally Pays Costs Associated with Work Stoppages:
Under the terms of the cost-reimbursement contracts for the tank farms
and the waste treatment plant, DOE generally pays the costs for
corrective action or construction rework associated with temporary work
stoppages and does not require the contractor to separately track these
costs.
Costs Associated with Work Stoppages Can Include Corrective Action and
Lost Productivity:
Various categories of costs can be associated with work stoppages, with
some easier to measure or separately identify than others. The category
of costs related to correcting a problem that precipitates a work
stoppage, such as the cost of investigating and cleaning up a hazardous
waste spill or the cost of rework to address improper construction, is
usually more easily measured. In contrast, lost productivity--
expenditures for labor during periods workers were not fully engaged in
productive work or the difference between the value of work that should
have been accomplished against the value of work that was accomplished--
is more difficult to quantify.
Most of the work stoppages reported by DOE officials involved some
corrective action or construction rework to address the problem
precipitating the work stoppage. These are costs that tend to be easier
to separately identify and track, and DOE has directed contractors to
do so in certain instances, as it did for the July 2007 tank waste
spill. For the work stoppages at the tank farms, corrective actions
encompassed such activities as investigating and cleaning up the July
2007 spill, monitoring and testing vapors escaping from the tanks to
determine the constituents, and training contractor employees on
required new procedures or processes. For the work stoppages at the
waste treatment plant, corrective actions at times involved retraining
workers or developing new procedures to prevent future problems,
although many of the work stoppages at the waste treatment plant
involved construction rework. Construction rework can include obtaining
new parts to replace substandard parts or labor and materials to undo
installations or construction, followed by proper installation or
construction--pouring new concrete, for example, or engineering and
design work to address nuclear safety issues.
The cost of lost productivity associated with a work stoppage can be
more difficult to measure or separately identify, although under a cost-
reimbursement contract, the government would generally absorb the cost.
While no generally accepted means of measuring lost productivity
exists, two methods have been commonly used. The first, a measure of
the cost of idleness, or doing nothing, calculates the expense incurred
for labor and overhead during periods that no productive work is taking
place. These were the types of costs associated with a July 2004
suspension, or "stand-down," of operations at the Los Alamos National
Laboratory, where a pattern of mishaps led the contractor to stop most
work at the facility for many months to address safety and security
concerns. Laboratory activities resumed in stages, returning to full
operations in May 2005. Although officials with both the National
Nuclear Security Administration, which oversees the laboratory, and the
Los Alamos contractor, tried to measure lost productivity at the
laboratory, each developed widely differing estimates--of $370 million
and $121 million, respectively--partly because of difficulties
measuring labor costs.[Footnote 8] According to DOE officials, when
work stopped at the Hanford Site tank farms, CH2M Hill reassigned
workers to other productive activities. Therefore, according to DOE
officials, no costs of idleness were incurred as a result of those work
stoppages. We were unable to verify, however, that tank farm workers
had been reassigned to other productive work after the S-102 tank waste
spill or during other tank farm work stoppages. During the period that
work stopped on the pretreatment and high-level waste facilities of the
waste treatment plant, in contrast, the contractor substantially
reduced its workforce. According to Bechtel officials and documents,
about 900 of 1,200 construction workers were laid off during the work
stoppage, and the remaining workers were employed on the other
facilities under construction.
An alternative means of measuring lost productivity associated with
suspension of work activities is to measure the value of work planned
that should have been accomplished but was not. This method
concentrates on the work that was not done, as opposed to the cost of
paying workers to do little or nothing. This method of measuring lost
productivity is typically undertaken as part of a formal earned value
management system, a project management approach that combines the
technical scope of work with schedule and cost elements to establish an
"earned value" for a specific set of tasks. If the earned value of work
accomplished during a given period is less than the earned value of
work planned for that period, then a loss in productivity has occurred,
and the cost is equal to the difference in value between planned and
finished work.[Footnote 9] DOE officials were unable to provide this
measure for the three work stoppages that had supporting documentation,
partly because the analyses of productivity under earned value
management techniques did not disaggregate activities in a manner that
could capture the three work stoppages. For example, with regard to the
tank farms, DOE measures the overall progress made on waste
stabilization and retrieval for all 177 storage tanks in aggregate but
does not measure the direct impact of setbacks at any one storage tank,
such as the spill at tank S-102.
Contractors Are Not Ordinarily Required to Track Work Stoppage Costs
Separately:
The contracts for the tank farms and the waste treatment plant do not
generally require the contractors to separately track costs associated
with work stoppages. Contractors must use an accounting system adequate
to allow DOE to track costs incurred against the budget in accordance
with federal cost-accounting standards. These standards permit a
contractor to establish and use its own cost-accounting system, as long
as the system provides an accurate breakdown of work performed and the
accumulated costs and allows comparisons against the budget for that
work. For the tank farm and waste treatment plant contracts, the
contractors must completely define a project by identifying discrete
physical work activities, essentially the steps necessary to carry out
the project. This "work breakdown structure" is the basis for tracking
costs and schedule progress. Corrective action and rework associated
with work stoppages are generally not explicitly identified as part of
a project's work breakdown structure, although these costs are
generally allowable and contractors do not have to account for them
separately.
Despite the lack of a requirement to track costs associated with work
stoppages, DOE and contractors sometimes do track these costs
separately, as in the following three circumstances:
* DOE can request the contractor to separately track costs associated
with corrective action when DOE officials believe it is warranted. DOE
specifically asked CH2M Hill to separately track costs associated with
addressing the July 2007 tank spill because of the potential impacts on
tank farm operations, workers, and the environment and because of
heightened public and media attention to the event.
* Contractors may voluntarily track selected costs associated with a
work stoppage if they believe that a prolonged suspension of work will
alter a project's cost and schedule. Contractors may want to collect
this information for internal management purposes or to request an
adjustment of contract terms in the future. For example, Bechtel
estimated costs for both redesign work and lost productivity resulting
from a change in seismic standards for the waste treatment plant.
* DOE may require a contractor to track particular costs associated
with investigating an incident that it believes may violate DOE nuclear
safety requirements or the Atomic Energy Act of 1954, as amended (these
violations are referred to as Price-Anderson Amendment Act violations).
DOE's Office of Enforcement notifies the contractor in a "segregation
letter" that an investigation of the potential violation will be
initiated and that the contractor must segregate, or separately
identify, any costs incurred in connection with the investigation.
These are not costs of corrective action or rework. The costs incurred
in connection with the investigation are generally not allowable. Not
all such investigations involve a work stoppage, however.
Of the 31 work stoppages reported to us by DOE officials, costs are
available only for the July 2007 spill at the tank farm, since DOE
specifically required the contractor to separately identify and report
those costs. The costs of that incident totaled $8.1 million and
included expenditures for cleaning up contamination resulting from the
spill, investigating the causes of the accident, investigating health
effects of the accident on workers, administrative support, and
oversight of remediation activities. These were all considered
allowable costs, and DOE has reimbursed the contractor for them.
Although a subsequent investigation took place to determine whether
nuclear safety rules had been violated, the costs to participate in
that investigation ($52,913) were segregated as directed by DOE's
Office of Enforcement and were not billed to the government.
Although DOE officials said that none of the reported work stoppages
involved lost-productivity costs, the work stoppage to address the tank
spill could well contribute to delays and rising costs for tank waste
retrieval activities over the long run. Given that DOE was emptying
only about one tank per year when we reported on Hanford tanks in June
2008,[Footnote 10] the 1-year suspension of waste retrieval activities,
without additional steps to recover lost time, may contribute to
delayed project completion. Many factors already contribute to delays
in emptying the tanks. DOE has acknowledged that it will not meet the
milestones agreed to with Washington State and the Environmental
Protection Agency in the Tri-Party Agreement. We found that DOE's own
internal schedule for tank waste retrieval, approved in mid-2007,
reflects time frames almost 2 decades later than those in the
agreement. Ultimately, delays contribute to higher costs because of
ongoing costs to monitor the waste until it is retrieved, treated, and
permanently disposed of, and estimated costs for tank waste retrieval
and closure have been growing. DOE estimated in 2003 that waste
retrieval and closure costs from 2007 onward--in addition to the $236
million already spent to empty the first seven tanks--would be about
$4.3 billion. By 2006, this estimate had grown to $7.6 billion. Because
of limitations in DOE's reporting systems, however, we were unable to
determine the specific effect of the tank spill on overall tank
retrieval costs beyond the $8.1 million in corrective action costs.
In addition, although specific costs were not available for the 2-year
suspension of construction activities at two of the facilities in the
waste treatment plant, we have previously reported on some of the
potential impacts. In an April 2006 testimony,[Footnote 11] we reported
on the many technical challenges Bechtel had encountered during design
and construction of the waste treatment plant. These ongoing technical
challenges included changing seismic standards that resulted in
substantial reengineering of the design for the pretreatment and high-
level waste facilities, problems at the pretreatment plant with "pulse
jet mixers" needed to keep waste constituents uniformly mixed while in
various tanks, and the potential buildup of flammable hydrogen gas in
the waste treatment plant tanks and pipes. In December 2005, Bechtel
estimated that these technical problems could collectively add nearly
$1.4 billion to the project's estimated cost.
DOE Generally Pays All Costs, but Contractors Can Face Some Financial
Consequences:
Under the cost-reimbursement contracts for the tank farms and the waste
treatment plant, costs associated with work stoppages, such as the
costs of corrective action or construction rework, generally are
allowable costs. As such, DOE generally pays these costs, regardless of
whether they are separately identified or whether they are included in
the overall costs of work performed.
Even though the contractors are being reimbursed for the costs
associated with work stoppages, they can experience financial
consequences, either through loss of performance fee or fines and
penalties assessed by DOE or its regulators. For example, DOE may
withhold payment of a performance award, called a fee, from contractors
for failure to meet specified performance objectives or measures or to
comply with applicable environmental, safety, and health requirements.
The tank farm and waste treatment plant contractors both lost
performance fee because of work stoppages as follows:
* For the July 2007 spill at the tank farms, under CH2M Hill's
"conditional payment of fee" provision, DOE reduced by $500,000 the
performance fee the contractor could have earned for the year. In its
memo to the contractor, DOE stated that the event and the contractor's
associated response were not consistent with the minimum requirement
for protecting the safety and health of workers, public health, and the
environment. Nevertheless, DOE did allow CH2M Hill to earn up to
$250,000, or half the reduction amount, provided the contractor fully
implement the corrective action plan developed after the accident
investigation, with verification of these actions by DOE personnel.
* Bechtel also lost performance fee because of design and construction
deficiencies at the waste treatment plant facilities and the 2-year
delay on construction of the pretreatment and high-level waste
facilities. Overall, DOE withheld $500,000 in Bechtel's potential
performance fee for failure to meet construction milestones. In
addition, DOE withheld $300,000 under the "conditional payment of fee"
provision in the contract after a number of serious safety events and
near misses on the project.
Furthermore, in addition to having potential fee reduced for safety
violations and work stoppages, DOE and other federal and state
regulators may also assess fines or civil penalties against contractors
for violating nuclear safety rules and other legal or regulatory
requirements. These fines and penalties are one of the categories of
costs that are specifically not allowed under cost-reimbursement
contracts, and these costs are borne solely by the contractor. For
example, DOE's Office of Enforcement can assess civil penalties for
violations of nuclear safety and worker safety and health rules. Both
contractors were assessed fines or civil penalties for the events
associated with their work stoppages.
* Fines and penalties assessed against CH2M Hill for the July 2007 tank
spill totaled over $800,000 and included (1) civil penalties of
$302,500 assessed by DOE's Office of Enforcement for violation of
nuclear safety rules, such as long-standing problems in ensuring
engineering quality and deficiencies in recognizing and responding to
the spill; (2) a Washington State Department of Ecology fine of
$500,000 for inadequacies in design of the waste retrieval system and
inadequate engineering reviews; and (3) a fine of $30,800 from the
Environmental Protection Agency for delays in notification of the
event. The contractor was required to notify the agency within 15
minutes of the spill but instead took almost 12 hours.
* From March 2006 through December 2008, DOE's Office of Enforcement
issued three separate notices of violation to Bechtel, with civil
penalties totaling $748,000. These violations of nuclear safety rules
were associated with procurement and design deficiencies of specific
components at the waste treatment plant. In its December 2008 letter to
the contractor, DOE stated that significant deficiencies in Bechtel's
quality-assurance system represented weaknesses that had also been
found in the two earlier enforcement actions.
Inadequate Oversight Cited as Contributing to Some Work Stoppages:
For the majority of DOE's reported work stoppages, no supporting
documentation was available to evaluate whether better oversight or
regulation could have prevented them. For two incidents for which
documentation was available--internal investigations and prior GAO
work--a lack of oversight contributed to both. These two work stoppages
occurred at the tank farms and the waste treatment plant, and both
resulted from engineering-design problems. In a third case--efforts to
address potentially hazardous vapors venting from underground waste
storage tanks--DOE's efforts to enforce worker protections were found
to have been inadequate, although this lack of oversight does not
appear to have directly caused the work stoppage associated with the
vapors problem.
Insufficient oversight was a factor in these three events as follows:
* Accidental spill of radioactive and chemical wastes at tank S-102.
Specifically, the accident investigation report for the tank farm spill
found that oversight and design reviews by DOE's Office of River
Protection failed to identify deficiencies in CH2M Hill's tank pump
system, which did not meet nuclear safety technical requirements. The
Office of River Protection failed to determine that this pump system
did not have a needed backflow device to prevent excessive pressure in
one of the hoses serving a tank, ultimately causing it to fail and
release waste, which then overflowed from the top of this tank and
spilled to the ground. In addition, the investigation found that CH2M
Hill failed to respond to the accident in a timely manner and failed to
ensure that nuclear safety requirements had been met.
* Outdated ground-motion studies supporting seismic design of the waste
treatment plant. Lax oversight was also a factor in a second event at
the waste treatment plant. GAO in 2006 found that DOE's failure to
effectively implement nuclear safety requirements, including
requirements that all waste treatment plant facilities would survive a
potential earthquake, contributed substantially to delays and growing
costs at the plant. The Defense Nuclear Facilities Safety Board first
expressed concerns with the seismic design in 2002, believing that the
seismic standards followed had not been based on then-current ground-
motion studies and computer models or on geologic conditions directly
below the waste treatment plant site. It took DOE 2 years to confirm
that the designs for two of the facilities at the site--the
pretreatment and the high-level waste facilities--were not sufficiently
conservative. Revising the seismic criteria required Bechtel to
recalculate thousands of design drawings and engineering estimates to
ensure that key components of these facilities would be adequately
anchored. Work was halted at the two facilities for 2 years as a
result.
* Controlling worker exposure to tank farm vapors. In 2004, DOE's then
Office of Independent Oversight and Performance Assurance (today
reorganized as DOE's Office of Health, Safety, and Security)
investigated vapor exposures at the Hanford tank farms and the adequacy
of worker safety and health programs at the site, including the
adequacy of DOE oversight. Investigators were unable to determine
whether any workers had been exposed to hazardous vapors in excess of
regulatory limits but found several weaknesses in the industrial
hygiene (worker safety) program at the site, in particular, hazard
controls and DOE oversight. According to the investigation, the Office
of River Protection had not effectively overseen the contractor's
worker safety program; had failed to provide the necessary expertise,
time, and resources to adequately perform its management oversight
responsibilities at the tank farms; and had failed to ensure corrective
action for identified problems. After the investigation, DOE stepped up
its monitoring efforts at the tank farms, and the contractor provided
tank farm workers with supplied air, an action that slowed or halted
work at the tank farms for about 2 weeks while supplied air equipment
was secured and workers were trained to use it.
With regard to regulations, however, officials we interviewed from DOE,
the Defense Nuclear Facilities Safety Board, and the Office of
Inspector General said they did not believe that insufficient
regulation was a factor in these two events. Officials from the Nuclear
Regulatory Commission declined to comment on the sufficiency of
regulations.
Conclusions:
The final cost to the American public of cleaning up the Hanford Site
is expected to reach tens of billions of dollars. Consequently, factors
that can potentially escalate costs--including work stoppages--matter
to taxpayers, DOE, and Congress. Depending on what causes a work
stoppage and how long it lasts, some stoppages could increase already
substantial cleanup costs. Although prudent oversight would seem to
call for DOE to understand the reasons for work stoppages and the
effects of these work stoppages on costs, neither law nor regulation
requires that this information be systematically recorded and reported.
DOE and other stakeholders have expressed reservations that collecting
information on work stoppages could send a message that work stoppages
should be minimized, thus discouraging managers or workers from
reporting potential safety or construction quality issues. We recognize
that the opportunity for any manager or worker to call a work stoppage
when worker safety or construction quality is at stake is an integral
part of DOE's safety and construction management strategies and should
not be stifled. Yet DOE has also recognized the importance of cost
information and in one recent case--the 2007 tank waste spill--required
the contractor to separately track detailed cost information. In
addition, we previously recommended that DOE require contractors to
track the costs associated with future work stoppages, similar to the
one at Los Alamos National Laboratory in 2004, and DOE agreed with this
recommendation. While acknowledging these competing pressures, we
believe that systematically collecting cost information on selected
work stoppages can increase transparency and yet balance worker and
public safety.
Recommendations for Executive Action:
To provide a more thorough and consistent understanding of the
potential effect of work stoppages on project costs, we recommend that
the Secretary of Energy take the following two actions: (1) establish
criteria for when DOE should direct contractors to track and report to
DOE the reasons for and costs associated with work stoppages, ensuring
that these criteria fully recognize the importance of worker and
nuclear safety, and (2) specify the types of costs to be tracked.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Secretary of Energy for
review and comment. In written comments, the Chief Operations Officer
for Environmental Management generally agreed with our recommendations,
stating that they will be accepted for implementation within the
Environmental Management program. The comments (which are reproduced in
app. III) were silent on whether the recommendations will be
implemented in other DOE programs.
In its comments, DOE expressed concern that readers of appendix II
could misconstrue the information in the column labeled "Duration" as
representing a delay in the entire listed project, not simply the time
required to resolve the specific issue in question; DOE maintains that
during this time, workers were shifted to other work activities. We
found, however, that some of the short work stoppages, which DOE termed
"safety pauses," were specifically called to allow the contractor to
refresh workers' understanding of workplace hazards; in these cases,
which were essentially training exercises, workers were not reassigned
to other work activities. Other work stoppages may have led to workers'
assignment to other activities, but we were unable to verify to what
extent reassignment occurred because the documentation available on
work stoppages was limited. Finally, during the 2-year delay due to
seismic concerns in waste treatment plant construction, work on two
facilities--the pretreatment plant and high-level waste facility--was
ultimately suspended from August 2005 until August 2007, and about 900
workers were laid off, not reassigned. We added a footnote to table 1
to clarify the "Duration" column.
Regarding our discussion of the role of oversight in several work
stoppages, DOE acknowledged that inadequate oversight was a factor in
the cited work stoppages and stated that the Office of Environmental
Management has implemented corrective actions to address these
contributing factors. Evaluating these actions and the resulting
outcomes, if any, however, was beyond the scope of our report. We
incorporated other technical comments in our report as appropriate.
As agreed with our offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
Secretary of Energy and interested congressional committees. The report
also will be available at no charge on the GAO Web site at [hyperlink,
http://www.gao.gov].
If you or your staffs have any questions about this report, please
contact me at (202) 512-3841 or aloisee@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix IV.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Scope and Methodology:
To determine the number of times work was suspended at the Hanford
site, we obtained from the Department of Energy's (DOE) Office of River
Protection officials a listing of work stoppages occurring from January
2000 through December 2008 at either the waste treatment plant or the
tank farms. We did not review other work stoppages that may have
occurred elsewhere at the Hanford Site during this period.
We sought to independently verify the 31 work stoppages identified by
DOE and to uncover additional information about them, including the
nature of the event and the duration and the scope of each, by
reviewing the following:
* DOE's Occurrence Reporting and Processing System, a database of
reportable accidents and other incidents affecting worker, public, and
environmental safety;
* DOE's database of investigation reports on accidents causing serious
injury to workers or serious damage to the facility or the environment;
* DOE citations issued against contractors for violating nuclear safety
regulations;[Footnote 12]
* Defense Nuclear Facilities Safety Board reports addressing Hanford
Site safety problems; and:
* Bechtel National Inc. and CH2M Hill Hanford Group Problem Evaluation
Requests, internal reports of incidents or accidents involving safety
issues.
We were unable to independently verify DOE's list of work stoppages
from these sources, however, because in most cases, the reporting
systems did not indicate whether safety incidents had halted work or,
if so, for how long. In addition, these reporting systems focus on
safety incidents and do not specifically address construction rework
and design problems, which represent about half the work stoppages
reported by DOE.
Of the 31 work stoppages reported, however, we were able to obtain
additional information from other sources for three specific events.
These were (1) ongoing problems protecting workers from potentially
harmful vapors venting from the tank farms, (2) a radioactive waste
spill from tank S-102 in July 2007, and (3) the seismic redesign from
August 2005 to August 2007 of the waste treatment plant pretreatment
and high-level waste facilities. To obtain a more thorough
understanding of these three work stoppages, what caused them, and how
problems were corrected, we reviewed DOE, contractor, and Office of the
Inspector General evaluations of these events, including official
accident reports, external independent investigations, and our 2006
testimony on cost and schedule problems at the Hanford waste treatment
plant.[Footnote 13]
To determine the types of costs associated with work stoppages, we
reviewed Federal Acquisition Regulation reporting requirements for cost-
reimbursement contracts and Defense Contract Audit Agency guidance on
auditing incurred costs. To gain a better understanding of the costs
associated with lost productivity resulting from a work stoppage, we
reviewed cost-estimating guidance from the Association for the
Advancement of Cost Engineering International and earned value
management guidance by GAO and by the National Research Council. To
develop an understanding of the costs paid by the government, compared
with those absorbed by the contractor, we reviewed Bechtel National
Inc. and CH2M Hill Hanford Group requests to DOE for equitable
adjustments to their respective contracts to recover lost productivity
and other costs linked to work stoppages. We reviewed the Atomic Energy
Act of 1954, as amended, and the letters sent from DOE to contractors
requesting that they segregate costs incurred in connection with
investigations of potential violations of the law and DOE nuclear
safety requirements. We reviewed assessments by Washington State, DOE,
and federal regulators fining Bechtel and CH2M Hill Hanford Group for
safety violations and other problems at the Hanford Site since 2000.
Finally, we interviewed contractor and Office of River Protection
finance officials to determine cost-accounting requirements and
practices.
To determine whether more-effective regulation or oversight might have
prevented the work stoppages, we relied primarily on Office of River
Protection and Bechtel officials' assessments of these events because
supporting documentation was generally unavailable. For 3 of the 31
work stoppages, we reviewed numerous internal DOE, external
independent, and contractor evaluations to assess whether lack of
oversight was a contributing factor. To gain further perspective on how
lack of oversight or regulations might have played a role in these work
stoppages, we interviewed DOE headquarters officials with the Offices
of Environmental Management; Health, Safety, and Security; and General
Counsel. We interviewed officials with regulatory and oversight
entities, including the Defense Nuclear Facilities Safety Board, the
Occupational Safety and Health Administration, and the Nuclear
Regulatory Commission. We also interviewed union representatives at the
Hanford Site to obtain the union's and workers' perspectives on work
stoppages and safety.
We conducted this performance audit from June 2008 to April 2009, in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
[End of section]
Appendix II: Work Stoppages Identified by the Office of River
Protection:
We obtained and reviewed information on 31 work stoppages that occurred
at the Hanford Site from January 2000 to December 2008; these are
summarized in table 1.
Table 1: Summary of Work Stoppages at the Hanford Site, January 2000 to
December 2008 (in order of duration):
1.
Date of occurrence: Oct. 2007;
Duration[A]: 1 hour;
Reason for work stoppage: Sitewide safety pause;
Type of event[B]: A;
Location: Waste treatment plant.
2.
Date of occurrence: Oct. 2007;
Duration[A]: ½ day;
Reason for work stoppage: Safety pause;
Type of event[B]: A;
Location: Tank farms.
3.
Date of occurrence: Mar. 2007;
Duration[A]: ½ day;
Reason for work stoppage: Safety pause to address newly implemented
improvements to safety statistics and management program;
Type of event[B]: A;
Location: Tank farms.
4.
Date of occurrence: Oct. 2004;
Duration[A]: 6 hours;
Reason for work stoppage: Injury to worker exiting heavy equipment at
the integrated disposal facility;
Type of event[B]: C;
Location: Tank farms.
5.
Date of occurrence: Oct. 2006;
Duration[A]: 1 day;
Reason for work stoppage: Forklift collision with a vehicle;
Type of event[B]: C;
Location: Tank farms.
6.
Date of occurrence: Sept. 2005;
Duration[A]: 1 ½ days;
Reason for work stoppage: Sitewide pause to address hazardous energy
use;
Type of event[B]: A;
Location: Waste treatment plant.
7.
Date of occurrence: June 2003;
Duration[A]: 2 days;
Reason for work stoppage: Personnel contaminated by radiation exposure
during removal of a waste transfer line jumper assembly;
Type of event[B]: C;
Location: Tank farms.
8.
Date of occurrence: June 2008;
Duration[A]: 2 days;
Reason for work stoppage: Changed workers' protective equipment from
self-contained tank air to respirators with contaminant-filtering
cartridges;
Type of event[B]: A;
Location: Tank farms.
9.
Date of occurrence: June 2008;
Duration[A]: 2 days;
Reason for work stoppage: Radiation contamination spread to the back
area of a facility that evaporates water contained in tank waste, to
reduce the volume of that waste. As a result, the Office of River
Protection issued a new order outlining additional work controls for
the area;
Type of event[B]: A;
Location: Tank farms.
10.
Date of occurrence: July 2004;
Duration[A]: 1 week;
Reason for work stoppage: A nuclear chemical operator exceeded the
maximum extremity and skin radiation exposure level during removal of
an instrument used to measure temperature in the tanks;
Type of event[B]: C;
Location: Tank farms.
11.
Date of occurrence: June 2002;
Duration[A]: 1 month;
Reason for work stoppage: Damage to a crane due to operator error
requiring repair; delayed use of site cranes; required alternate crane
configuration, causing inefficiencies;
Type of event[B]: C;
Location: Waste treatment plant.
12.
Date of occurrence: Jan. 2007;
Duration[A]: 1 month;
Reason for work stoppage: Hazardous air sample identified during
welding operations;
Type of event[B]: A;
Location: Waste treatment plant.
13.
Date of occurrence: Not available;
Duration[A]: 1 ½ months;
Reason for work stoppage: Repeated violations of a safety procedure,
called a lock-out, tag-out, to ensure that dangerous machines are
properly shut off and not started up again before completion of
maintenance or servicing. Procedure requires that a tag be affixed to
the locked device, indicating that it should not be turned on;
Type of event[B]: A;
Location: Tank farms.
14.
Date of occurrence: Oct. 2002;
Duration[A]: 3 months;
Reason for work stoppage: Reinspection and reinforcement of undersized
structural steel welds at the low-activity waste facility;
Type of event[B]: B; Location:
Waste treatment plant.
15.
Date of occurrence: Feb. 2005;
Duration[A]: 4 months;
Reason for work stoppage: Welding manual rewritten to comply with
requirements of the authorization basis for waste treatment plant;
Type of event[B]: B;
Location: Waste treatment plant.
16.
Date of occurrence: May 2005;
Duration[A]: 6 months;
Reason for work stoppage: Redesign of structural steel fabrication
drawings;
Type of event[B]: B;
Location: Waste treatment plant.
17.
Date of occurrence: Oct. 2005;
Duration[A]: 6 months;
Reason for work stoppage: Laboratory testing showed that recently
poured concrete was not meeting the necessary strength requirements of
either 4,000 or 5,000 pounds of pressure per square inch. The
contractor found that the concrete plant supplying the aggregate had
changed the grind of its constituents during the winter months,
weakening the concrete;
Type of event[B]: B;
Location: Waste treatment plant.
18;
Date of occurrence: Apr. 2005;
Duration[A]: 6 months;
Reason for work stoppage: Faulty fabrication of leak detection box;
Type of event[B]: B;
Location: Waste treatment plant.
19.
Date of occurrence: Oct. 2007;
Duration[A]: 6 months;
Reason for work stoppage: Contractor procured from suppliers piping
that had not received the required 100 percent radiographic testing to
identify hidden flaws in welds. These pipes were to be installed in
heavily shielded concrete cells (called black cells) that would not be
physically accessible following the completion of construction because
of high radiation exposure;
Type of event[B]: B;
Location: Waste treatment plant.
20.
Date of occurrence: July 2002;
Duration[A]: 7 months;
Reason for work stoppage: "Cold joint" formed in concrete at the low-
activity waste facility because pouring was interrupted, creating a
weak area that could allow water to enter;
Type of event[B]: B;
Location: Waste treatment plant.
21.
Date of occurrence: Sept. 2004;
Duration[A]: 9 months;
Reason for work stoppage: Process tanks intended for installation in
black cells did not receive the required 100 percent radiographic
testing to identify hidden flaws. Three tanks had already been
installed and had to be examined and repaired in place at the
pretreatment and high-level waste facilities as a result;
Type of event[B]: B;
Location: Waste treatment plant.
22.
Date of occurrence: Mar. 2007;
Duration[A]: 10 months;
Reason for work stoppage: Repairs to degraded air compressors and
equipment;
Type of event[B]: B;
Location: Waste treatment plant.
23.
Date of occurrence: June 2005;
Duration[A]: 1 year; Reason for work stoppage: Delay covering coaxial
transfer pipe with soil because it did not meet sloping requirements
and had to be reconfigured;
Type of event[B]: B;
Location: Waste treatment plant.
24.
Date of occurrence: July 2007;
Duration[A]: 1 year;
Reason for work stoppage: Suspension of work in S-102 and C-108 tanks
to address radioactive waste spill; C-104 activities also suspended;
Type of event[B]: C;
Location: Tank farms.
25.
Date of occurrence: Jan. 2006;
Duration[A]: 1 ½ years;
Reason for work stoppage: Rework to reapply appropriate fire protection
coating onto structural steel;
Type of event[B]: B;
Location: Waste treatment plant.
26.
Date of occurrence: Feb. 2006;
Duration[A]: 2 years;
Reason for work stoppage: Requirements were not met to ensure that
commercially procured components for the facility were suitable for
nuclear use. As a result, the contractor halted activities until fully
developing and implementing a new procurement program to ensure those
requirements could be met;
Type of event[B]: B;
Location: Waste treatment plant.
27.
Date of occurrence: Aug. 2005;
Duration[A]: 2 years;
Reason for work stoppage: Seismic ground-motion review including soil
sampling, data analysis, and development of appropriate design criteria
and implementation of changes;
Type of event[B]: B;
Location: Waste treatment plant.
28.
Date of occurrence: Oct. 2005;
Duration[A]: 2 ¼ years;
Reason for work stoppage: Revised requirements to ensure that design of
joggle boxes had adequate shielding from radiation hazards. Joggle
boxes are used to ensure that structural penetrations at 90-degree
angles (such as walls or floors) are designed in such a way that
radiation is blocked from leaving one room and entering another;
Type of event[B]: B;
Location: Waste treatment plant.
29.
Date of occurrence: July 2003;
Duration[A]: Unknown;
Reason for work stoppage: Rework to address construction equipment and
temporary power installations that did not comply with electrical
codes;
Type of event[B]: B;
Location: Waste treatment plant.
30.
Date of occurrence: Feb. 2008;
Duration[A]: Unknown;
Reason for work stoppage: Failed battery in a respirator halted work
inside high-contamination area;
Type of event[B]: A;
Location: Tank farms.
31.
Date of occurrence: 2004;
Duration[A]: Intermittent during 2-week period;
Reason for work stoppage: Protection of workers exposed to potentially
hazardous vapors escaping from underground tanks;
Type of event[B]: C;
Location: Tank farms.
Source: GAO summary of DOE Office of River Protection information.
[A] Time spans in this column represent the time needed to resolve the
issue described. Workers may have been reassigned to other activities
during these times, but we were unable to verify the extent to which
reassignment occurred.
[B] Letters in this column denote the following:
A, pause in work activity to address unsafe situation or prevent
recurrence of unsafe incident;
B, delay of activity to perform rework or to address faulty
workmanship, poor installation, or quality assurance issues, including
compliance with nuclear safety management requirements identified in 10
C.F.R. part 830;
C, suspension of activity to address workplace accident, physical
damage, or injury.
[End of table]
[End of section]
Appendix III: Comments from the Department of Energy:
Department of Energy:
Washington, DC 20585:
April 24, 2009:
Mr. Gene Aloise:
Director:
Natural Resources and Environment:
Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
The Environmental Management (EM) Program has reviewed the Government
Accountability Office (GAO) draft report entitled Nuclear and Worker
Safety. Limited Information Exists on Costs and Reasons for Work
Stoppages at DOE's Hanford Site, GAO-09-451, which was provided to the
Secretary of Energy on March 27, 2009. The recommendations included: 1)
establish criteria for when Department of Energy (DOE) should direct
contractors to track and report the reasons for and costs associated
with work stoppages, and 2) specify the types of costs to be tracked.
EM accepts these recommendations for implementation within the EM
program.
However, there is a significant likelihood for misrepresentation in
Appendix II. The table lists the "Duration" it took to resolve the
"Reason for the work stoppage" issue. As stated throughout the body of
the report, when there was a work stoppage, whether due to a safety
concern or a quality concern, the workers were shifted to other work
activities until the issue was resolved. Thus, it is imperative to
ensure that the reader of Table 1 understands that when an issue
resulted in work stoppage, it did not affect the work on the entire
project and workers affected by the work stoppage in the specific area
were shifted to other work activities. Therefore, it is essential that
the following clarification be made to Table 1, Appendix II: 1) revise
the column which reads "Duration" to "Issue Resolution Duration", and
2) add to the title - "The "Issue Resolution Duration" is the time to
resolve the issue for the "Reason for the work stoppage" and during
this period workers were assigned to other work activities".
Page 17 of the report identifies inadequate oversight as factors in
several work stoppages. EM acknowledges that inadequate oversight was a
factor in the cited work stoppages; however EM has implemented
corrective actions to address these contributing factors. Additionally,
EM has established a number of processes that promote enhanced DOE
engagement in oversight of design and engineering activities. These
include use of technology readiness assessments, external technical
reviews, and establishment of a Technical Authority Board.
Further, on page 6, the 3rd paragraph indicates the work stoppages
result from safety or construction concerns. Thus, in the 3rd sentence,
"accident" should be replaced with "event or issue".
Thank you for the opportunity to provide comments on the draft report.
If you have any further questions, please contact Mr. Dae Chung, Deputy
Assistant Secretary for Safety Management and Operations, at (202) 586-
5151.
Sincerely,
Signed by:
James M. Owendoff:
Chief Operations Officer for Environmental Management:
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise, (202) 512-3841, or aloisee@gao.gov.
Staff Acknowledgments:
In addition to the individual named above, Janet Frisch, Assistant
Director; Carole Blackwell; Ellen W. Chu; Brenna McKay; Mehrzad Nadji;
Timothy M. Persons, Chief Scientist; Jeanette Soares; Ginny
Vanderlinde; and William T. Woods made key contributions to this
report.
[End of section]
Footnotes:
[1] Of the 177 underground storage tanks at Hanford, 149 have only a
single carbon-steel shell. At more than 40 years old, 67, or almost
half, of these single-shell tanks have leaked or are presumed to have
leaked waste into the soil below. Newer double-shell tanks were built
starting in the late 1960s. For more information on the underground
tanks and stabilization activities, see GAO, Nuclear Waste: DOE Lacks
Critical Information Needed to Assess Its Tank Management Strategy at
Hanford, [hyperlink, http://www.gao.gov/products/GAO-08-793]
(Washington, D.C.: June 30, 2008).
[2] CH2M Hill managed and operated the tank farms from October 1, 1999,
through September 30, 2008. As part of its overall strategy for cleanup
at the Hanford site, DOE awarded a new contract for the management and
operation of the tank farms. Since October 1, 2008, Washington River
Protection Solutions LLC has managed and operated the tank farms. For
the purposes of this report, we refer to CH2M Hill as the tank farms'
contractor, since it was the contractor when all of the reported work
stoppages occurred.
[3] The waste treatment plant under construction consists of a
pretreatment facility that separates waste into high-level waste
(containing highly radioactive elements, such as strontium-90, cesium-
137, technetium-99, and iodine-129) and low-activity waste. The plant
will also include two other facilities to treat the separated portions
of the waste, one analytical laboratory, and a variety of supporting
facilities. In April 2006, we reported that since the construction
contract was awarded in 2000, the project's estimated cost had
increased more than 150 percent, to about $11 billion, and the
completion date had been extended from 2011 to 2017 or later. See GAO,
Hanford Waste Treatment Plant: Contractor and DOE Management Problems
Have Led to Higher Costs, Construction Delays, and Safety Concerns,
[hyperlink, http://www.gao.gov/products/GAO-06-602T] (Washington, D.C.:
Apr. 6, 2006).
[4] Under the contracts for the tank farms and the waste treatment
plant, either DOE or the contractor can suspend work for various
reasons, including responding to concerns about worker and nuclear
safety.
[5] A cost is only allowable when it meets the following requirements:
reasonableness, allocability, generally accepted accounting principles
or other appropriate practices, the terms of the contract, and Federal
Acquisition Regulation, part 31.2. For the purposes of this report, we
will refer to costs that meet all these requirements as "allowable
costs."
[6] DOE's Office of Enforcement is responsible for identifying
violations of the nuclear safety rules and assessing civil penalties
against contractors. This enforcement program, originally established
in 1995, now also includes enforcement of rules that have been issued
for security and safeguarding of classified information and for worker
or industrial health and safety.
[7] DOE officials said that while DOE does not formally collect or
report information on work stoppages, officials are aware of these
events, which are identified in daily and weekly reports submitted by
DOE staff monitoring the worksite.
[8] In a 2005 report on this stand-down of operations, we recommended
that DOE require contractors to improve their ability to track such
costs. See GAO, Stand-Down of Los Alamos National Laboratory: Total
Costs Uncertain; Almost All Mission-Critical Programs Were Affected but
Have Recovered, GAO-06-83 (Washington, D.C.: Nov. 18, 2005).
[9] For further information on earned value management systems, see
GAO, GAO Cost Estimating and Assessment Guide: Best Practices for
Developing and Managing Capital Program Costs, [hyperlink,
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: Mar. 2,
2009).
[10] [hyperlink, http://www.gao.gov/products/GAO-08-793].
[11] [hyperlink, http://www.gao.gov/products/GAO-06-602T].
[12] DOE is authorized under 42 U.S.C. § 2282a to impose civil monetary
penalties for violations of DOE nuclear safety regulations.
[13] [hyperlink, http://www.gao.gov/products/GAO-06-602T].
[End of section]
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