Nuclear Waste
Uncertainties and Questions about Costs and Risks Persist with DOE's Tank Waste Cleanup Strategy at Hanford Gao ID: GAO-09-913 September 30, 2009At its Hanford Site in Washington State, the Department of Energy (DOE) is responsible for one of the world's biggest cleanup projects: the treatment and disposal of about 56 million gallons of radioactive and hazardous waste, stored in 177 underground tanks. Two decades and several halted efforts later, none of this waste has yet been treated, cleanup costs have grown steadily, and prospective cleanup time frames have lengthened. GAO was asked to assess (1) DOE's current tank waste cleanup strategy and key technical, legal, and other uncertainties; (2) the extent to which DOE has analyzed whether this strategy is commensurate with risks from the wastes; and (3) opportunities to reduce tank waste cleanup costs. GAO reviewed pertinent documents, visited the site, and interviewed officials and independent experts.
DOE's tank waste cleanup strategy consists of five key phases--waste characterization, retrieval, pretreatment, treatment, and permanent disposal--but critical uncertainties call into question whether the strategy can succeed as planned. Technical uncertainties include whether DOE can retrieve waste from tanks at the rate needed to support continuous operation of the waste treatment complex now under construction and whether key treatment technologies will work. Legal uncertainties include whether DOE can treat and dispose of some tank waste as other than high-level (highly radioactive) waste and how much residual waste can be left in the tanks when they are eventually closed. Such uncertainties could lead to significant cost increases and further delays in completing Hanford's tank waste cleanup activities. DOE has not systematically evaluated whether its tank waste cleanup strategy is commensurate with risks posed by the wastes. DOE lacks credible or complete estimates of how much the strategy will cost or how long it will take. The total project cost of constructing the waste treatment plant alone grew from $4.3 billion in 2000 to $12.3 billion in 2006. In addition, DOE did not include, or has been unable to quantify, a number of significant costs in its current estimate of the overall cost of its cleanup strategy. For example, DOE has not included some actual expenditures to date or storage costs for high-level waste canisters. Further, DOE's schedule targets have slipped, with end of treatment extending from 2028 to 2047, which increases overall operations costs. Overall the total estimated cost could significantly exceed DOE's current estimate of $77 billion, with estimates ranging from about $86 billion to over $100 billion, depending upon the date cleanup is completed. DOE has also fallen short in terms of risk-informed decision making. While DOE has analyzed risks in environmental impact statements required for its tank waste treatment activities at Hanford, it has not followed a systematic risk assessment framework, like one outlined in a 1983 report, updated in 2008, by the National Academy of Sciences. As a result, DOE cannot be assured that its present strategy is proportional to the reduction in risk that cleanup is to achieve. Some opportunities may still exist to reduce the costs of DOE's tank waste cleanup strategy, but the likelihood of success is unknown. For example, DOE is trying to increase the concentration of high-level waste in each disposal canister, thereby reducing the number of canisters and possibly shortening treatment time frames. DOE could also work with regulators to demonstrate, on a tank-farm basis, the feasibility of leaving varying amounts of residual waste in tanks at closing without threatening human or ecological health. In removing waste from tanks, DOE has found that the last portion can be disproportionately difficult and costly to remove. Specifically, the cost of removing the last 15 percent of waste can equal or exceed the cost of removing the first 85 percent.
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-09-913, Nuclear Waste: Uncertainties and Questions about Costs and Risks Persist with DOE's Tank Waste Cleanup Strategy at Hanford
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Report to the Subcommittee on Energy and Water Development, Committee
on Appropriations, House of Representatives:
United States Government Accountability Office:
GAO:
September 2009:
Nuclear Waste:
Uncertainties and Questions about Costs and Risks Persist with DOE's
Tank Waste Cleanup Strategy at Hanford:
GAO-09-913:
GAO Highlights:
Highlights of GAO-09-913, a report to the Subcommittee on Energy and
Water Development, Committee on Appropriations, House of
Representatives.
Why GAO Did This Study:
At its Hanford Site in Washington State, the Department of Energy (DOE)
is responsible for one of the world‘s biggest cleanup projects: the
treatment and disposal of about 56 million gallons of radioactive and
hazardous waste, stored in 177 underground tanks. Two decades and
several halted efforts later, none of this waste has yet been treated,
cleanup costs have grown steadily, and prospective cleanup time frames
have lengthened.
GAO was asked to assess (1) DOE‘s current tank waste cleanup strategy
and key technical, legal, and other uncertainties; (2) the extent to
which DOE has analyzed whether this strategy is commensurate with risks
from the wastes; and (3) opportunities to reduce tank waste cleanup
costs. GAO reviewed pertinent documents, visited the site, and
interviewed officials and independent experts.
What GAO Found:
DOE‘s tank waste cleanup strategy consists of five key phases”waste
characterization, retrieval, pretreatment, treatment, and permanent
disposal”but critical uncertainties call into question whether the
strategy can succeed as planned. Technical uncertainties include
whether DOE can retrieve waste from tanks at the rate needed to support
continuous operation of the waste treatment complex now under
construction and whether key treatment technologies will work. Legal
uncertainties include whether DOE can treat and dispose of some tank
waste as other than high-level (highly radioactive) waste and how much
residual waste can be left in the tanks when they are eventually
closed. Such uncertainties could lead to significant cost increases and
further delays in completing Hanford‘s tank waste cleanup activities.
DOE has not systematically evaluated whether its tank waste cleanup
strategy is commensurate with risks posed by the wastes. DOE lacks
credible or complete estimates of how much the strategy will cost or
how long it will take. The total project cost of constructing the waste
treatment plant alone grew from $4.3 billion in 2000 to $12.3 billion
in 2006. In addition, DOE did not include, or has been unable to
quantify, a number of significant costs in its current estimate of the
overall cost of its cleanup strategy. For example, DOE has not included
some actual expenditures to date or storage costs for high-level waste
canisters. Further, DOE‘s schedule targets have slipped, with end of
treatment extending from 2028 to 2047, which increases overall
operations costs. Overall the total estimated cost could significantly
exceed DOE‘s current estimate of $77 billion, with estimates ranging
from about $86 billion to over $100 billion, depending upon the date
cleanup is completed. DOE has also fallen short in terms of risk-
informed decision making. While DOE has analyzed risks in environmental
impact statements required for its tank waste treatment activities at
Hanford, it has not followed a systematic risk assessment framework,
like one outlined in a 1983 report, updated in 2008, by the National
Academy of Sciences. As a result, DOE cannot be assured that its
present strategy is proportional to the reduction in risk that cleanup
is to achieve.
Some opportunities may still exist to reduce the costs of DOE‘s tank
waste cleanup strategy, but the likelihood of success is unknown. For
example, DOE is trying to increase the concentration of high-level
waste in each disposal canister, thereby reducing the number of
canisters and possibly shortening treatment time frames. DOE could also
work with regulators to demonstrate, on a tank-farm basis, the
feasibility of leaving varying amounts of residual waste in tanks at
closing without threatening human or ecological health. In removing
waste from tanks, DOE has found that the last portion can be
disproportionately difficult and costly to remove. Specifically, the
cost of removing the last 15 percent of waste can equal or exceed the
cost of removing the first 85 percent.
What GAO Recommends:
GAO is recommending that, for Hanford, DOE (1) improve its life-cycle
cost and schedule estimates, (2) adopt a risk assessment framework that
considers available guidance, (3) consider seeking congressional
clarification about reclassifying its high-level tank waste, and (4)
work with regulators on tank closure options. DOE agreed with three of
these; it disagreed with seeking further clarification about
reclassifying high-level waste. GAO believes this recommendation
remains valid, given the importance of waste reclassification to DOE‘s
strategy.
View [hyperlink, http://www.gao.gov/products/GAO-09-913] or key
components. For more information, contact Gene Aloise at (202) 512-3841
or aloisee@gao.gov.
[End of section]
Contents:
Letter:
Background:
Critical Uncertainties Persist in DOE's Hanford Tank Waste Cleanup
Strategy:
DOE Has Not Systematically Evaluated Whether Its Tank Waste Cleanup
Strategy, Including Costs, Is Commensurate with Risks from the Waste:
Some Opportunities May Exist to Reduce Costs of DOE's Hanford Tank
Waste Cleanup Strategy:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Overview of DOE's Efforts to Select an Approach to
Supplement Its Low-Activity Tank Waste Treatment Capacity:
Appendix III: Comments from the Department of Energy:
Appendix IV: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Table:
Table 1: Estimated Costs Associated with DOE's Tank Waste Cleanup
Strategy:
Figures:
Figure 1: Changes in Hanford's Tank Waste Cleanup Strategy, 1989 to
Present:
Figure 2: Key Phases in DOE's Tank Waste Cleanup Strategy:
Figure 3: Cost Estimates for Constructing Hanford's Waste Treatment
Plant:
Figure 4: Shifting Estimates of the Duration of Hanford Tank Waste
Treatment:
Abbreviations:
CERCLA: Comprehensive Environmental Response, Compensation, and
Liability Act:
DOE: Department of Energy:
EPA: Environmental Protection Agency:
RCRA: Resource Conservation and Recovery Act:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 30, 2009:
The Honorable Peter J. Visclosky:
Chairman:
The Honorable Rodney P. Frelinghuysen:
Ranking Member:
Subcommittee on Energy and Water Development:
Committee on Appropriations:
House of Representatives:
The Department of Energy (DOE) is responsible for one of the world's
largest environmental cleanup programs: the treatment and disposal of
nuclear waste created as a by-product of producing nuclear weapons.
Decades of nuclear weapons production have left a legacy of radioactive
and hazardous wastes to be cleaned up at DOE sites across the country.
One of DOE's most contaminated locations is its Hanford Site, which
lies along the Columbia River in southeastern Washington State. The
site occupies 586 square miles upriver from the Tri-Cities area of
Richland, Pasco, and Kennewick, with a combined regional population of
over 200,000. DOE and its predecessor agencies[Footnote 1] produced
nuclear materials at the Hanford Site from 1944 through 1988,
generating millions of gallons of radioactive and hazardous waste
during those years. Some of this waste was deposited directly into the
soil; some was encased in drums or other containers and buried; and
some was stored in 177 large, underground tanks. In total, these tanks,
clustered together in 18 locations called tank farms, contain about 56
million gallons of waste--enough to cover an entire football field to a
depth of over 150 feet, or the height of a 15-story building.
Since plutonium production ended at Hanford in the late 1980s, DOE has
spent more than $12 billion[Footnote 2] to manage the tank waste and
explore ways to treat and dispose of it. After beginning and
discontinuing several different tank waste cleanup strategies, DOE has
now embarked on a strategy that involves building a complex of
treatment facilities, collectively called the Hanford Waste Treatment
and Immobilization Plant. Currently under construction and estimated to
cost $12.3 billion to design, build, and commission, this waste
treatment plant consists of a laboratory for analyzing the waste's
composition; a pretreatment plant to separate the waste into two
streams (a highly radioactive fraction called high-level waste and a
lower-radioactivity fraction called low-activity waste); two waste
treatment facilities, one for high-level waste and one for low-activity
waste; and more than 20 support facilities. DOE estimates that it will
cost tens of billions of dollars and take until 2047 to complete tank
waste cleanup and permanently close the underground storage tanks. To
date, however, no tank waste at Hanford has been treated for final
disposal, and none of the tanks has been permanently closed.
DOE's cleanup, treatment, and disposal of radioactive and hazardous
wastes are governed by a number of federal and state laws and
implemented under the leadership of DOE's Assistant Secretary for
Environmental Management. Key laws include the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended, and the Resource Conservation and Recovery Act of
1976 (RCRA), as amended.[Footnote 3] In addition, most of the cleanup
activities at Hanford, including emptying the underground tanks, are
carried out under the Hanford Federal Facility Agreement and Consent
Order among DOE, the Washington State Department of Ecology, and the
federal Environmental Protection Agency (EPA).[Footnote 4] Commonly
called the Tri-Party Agreement, this accord was signed in May 1989 and
has been amended a number of times since then. The agreement lays out a
series of legally enforceable milestones for completing major
activities in Hanford's waste treatment and cleanup process. A variety
of local and regional stakeholders, including county and local
government agencies, citizen and advisory groups, and Native American
tribes, also have long-standing interests in Hanford cleanup issues.
Like nearly all of DOE's missions, the majority of the work at the
Hanford Site is performed by private firms under contract to DOE.
Cleanup activities employ thousands of people in the private and public
sectors, thus contributing significantly to the economy of the Tri-
Cities area.
As requested, this report discusses (1) Hanford's current tank waste
cleanup strategy and key associated technical, legal, and other
uncertainties; (2) the extent to which DOE has determined whether its
cleanup strategy at Hanford is commensurate with risks posed by the
wastes; and (3) opportunities for DOE to reduce the costs of cleaning
up Hanford's tank waste while still protecting human health and the
environment.
To address these objectives, we gathered and reviewed information on
the Hanford waste cleanup strategy, including technical reports and
internal and external reviews. We reviewed legal and regulatory
requirements governing cleanup of hazardous and radioactive wastes,
including requirements for determining whether some tank wastes can be
classified as other than high-level waste. We also reviewed the Tri-
Party Agreement to gain an understanding of its requirements and time
frames. Several key documents were released by DOE just before, or were
scheduled to be released shortly after, the date of this report. These
included a tentative legal settlement with the state of Washington, an
amended Tri-Party Agreement, a draft environmental impact statement for
tank closure, and a new cost and schedule baseline for the Hanford tank
waste cleanup effort. We reviewed an August 10, 2009, version of the
tentative legal settlement and were provided access to a version of the
draft environmental impact statement, but the remaining documents were
not available at the time of our review. These documents are discussed
in our report and factored into its conclusions and recommendations as
available and appropriate. As agreed with DOE, we included only
publicly available information about the draft environmental impact
statement in our report. In addition, we interviewed officials at the
Hanford Site's Office of River Protection and at DOE headquarters,
including in the Office of Engineering and Construction Management and
the Office of Environmental Management. We interviewed contractor
officials at the Hanford Site responsible for building the waste
treatment plant. We also visited the Hanford Site, including the waste
treatment plant construction site. We interviewed officials with
regulatory and other agencies, specifically, the Washington State
Department of Ecology, EPA, the Nuclear Regulatory Commission, and the
Defense Nuclear Facilities Safety Board. To assist in understanding
concerns with various aspects of Hanford's tank waste cleanup strategy,
we interviewed staff at the National Academy of Sciences. In addition,
we identified and interviewed 18 independent experts for their input on
various aspects of DOE's Hanford tank waste cleanup strategy. We
provided an interim briefing in May 2009 to the subcommittee on the
status of our work. Appendix I describes our scope and methodology in
more detail. We conducted this performance audit from July 2008 to
September 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:
Established in 1943, the Hanford Site produced plutonium for the
world's first nuclear device. At the time, little attention was given
to the resulting by-products--massive amounts of radioactive and
chemically hazardous waste. From 1944 through 1988, about 525 million
gallons of radioactive tank waste was generated by Hanford's plutonium-
processing plants. The federal government initially managed this waste
by intentionally discharging it into the ground; reducing its volume
through various waste concentration methods, such as evaporating off
the liquids; and building underground tanks to store the waste until it
could be treated and permanently disposed of.
From the 1940s through the mid-1960s, 149 underground "single-shell"
storage tanks were built at Hanford. Originally expected to last 10 to
20 years until a permanent disposal solution could be found, each of
these tanks consisted of an outer concrete wall lined with one layer of
carbon steel. Grouped into 12 tank farms and buried some 6 to 11 feet
beneath the surface, most of these single-shell tanks measure roughly
75 feet in diameter, range from 30 to 49 feet high, and have a capacity
ranging from 530,000 to 1 million gallons of waste.[Footnote 5]
Together, the single-shell tanks contain almost 30 million gallons of
waste; about 27 million gallons are in solid or semisolid form, and
about 3 million gallons are liquid. By the mid-1990s, 67 of the single-
shell tanks had leaked or were presumed to have leaked about 1 million
gallons of waste into the surrounding soil. To address concerns with
the design of the single-shell tanks, a new tank design with two carbon-
steel shells was adopted in the late 1960s. From 1968 through 1986, 28
of these double-shell tanks, with storage capacities ranging from 1
million to 1.2 million gallons, were built and sited in 6 more tank
farms at Hanford. Together, these double-shell tanks contain about 26
million gallons of waste.[Footnote 6] To help minimize further leaking,
DOE had, by 2005, transferred most of the liquid in the single-shell
tanks to the double-shell tanks, a process called interim
stabilization. DOE is currently retrieving the remaining waste from
single-shell tanks and moving it to the double-shell tanks in
preparation for treatment.[Footnote 7]
The contents of these tanks have settled and today exist in four main
forms or layers:
* Vapor: Gases produced from chemical reactions and radioactive decay
occupy tank space above the waste.
* Liquid: Fluids may float above a layer of settled solids or under a
floating layer of crust; fluids may also seep into pore spaces or
cavities of settled solids, crust, or sludge.
* Saltcake: Water-soluble compounds, such as sodium salts, can
crystallize or solidify out of wastes to form a moist salt-like
hardened or crusty material.
* Sludge: Denser, water-insoluble or solid components generally settle
to the bottom of a tank to form a thick layer having the consistency of
peanut butter.
About 46 different radioactive elements--by-products of chemically
separating plutonium from uranium for use in nuclear weapons--represent
the majority of the radioactivity currently residing in the tanks. Some
of these elements lose most of their radioactivity in a relatively
short time, while others remain radioactive for millions of years. The
rate of radioactive decay is measured in half-lives, that is, the time
required for half the unstable atoms in a radioactive substance to
disintegrate, or decay, and release their radiation. The half-lives of
major radioactive tank constituents differ widely. The vast majority
(98 percent) of the tank waste's radioactivity comes from two elements,
strontium-90 and cesium-137, which have half-lives of about 29 and 30
years, respectively. The remaining radioactive elements, which account
for about 2 percent of the waste's total radioactivity, have much
longer half-lives. For example, the half-life of technetium-99 is
213,000 years, and that of iodine-129 is 15.7 million years. As we
reported in 2003 on the basis of radioactivity levels measured as of
August 2002, within 100 years, more than 90 percent of the
radioactivity in the tanks will have dissipated, and within 300 years,
99.8 percent will disappear.[Footnote 8] After the waste is separated,
the high-level waste stream will contain over 95 percent of the
radioactivity but total less than 10 percent of the volume to be
treated. In comparison, the low-activity waste stream will contain less
than 5 percent of the radioactivity but constitute over 90 percent of
the volume.
The tanks also contain large volumes of hazardous chemical waste,
including various metal hydroxides, oxides, and carbonates. Like
radioactive by-products of plutonium production, some of these
chemicals--including acids, caustic sodas, solvents, and toxic heavy
metals such as chromium--came from chemically reprocessing spent
nuclear fuel to extract weapons-grade plutonium. Altogether, DOE added
about 240,000 tons of chemicals to the tanks from the 1940s to the mid-
1980s. A majority of the chemicals (caustics, such as sodium hydroxide)
were added to neutralize acids in the waste. Other chemicals, such as
solvents, ferrocyanide, and several organic compounds, were added
during various waste extraction operations to help recover selected
radioactive elements (uranium, cesium, and strontium) for reuse. These
hazardous chemicals are dangerous to human health, and they can remain
dangerous for thousands of years.
Over the past 20 years, DOE has tried developing various approaches for
treating and disposing of these wastes, at varying costs and with
little success (see figure 1). In 1989, DOE's original strategy called
for treating waste only from the double-shell tanks. Part of this
effort involved renovating a World War II-era facility, called B Plant,
[Footnote 9] in which it planned to start waste treatment. DOE spent
about $23 million on this project but discontinued it because of
technical and environmental issues and stakeholder concerns that not
all the waste would be treated. In 1991, DOE decided to treat waste
from all 177 tanks. Under this strategy, DOE would have completed the
treatment facility before other aspects of the waste treatment program
were fully developed, and the planned treatment facility would have had
insufficient capacity to treat all the waste in a time frame acceptable
to regulators. DOE spent about $418 million on this approach. Beginning
in 1995, DOE attempted to "privatize" tank waste cleanup, shift risk to
its contractor,[Footnote 10] build a demonstration facility to treat 10
percent of the waste and 25 percent of the radioactivity by 2018, and
end cleanup in 2028. But because of dramatically escalating costs and
concerns about contractor performance, DOE terminated the contract
after spending about $300 million, mostly on plant design. According to
available information, since 1997 DOE has spent an average of more than
$300 million each year on tank management and risk reduction
activities, such as retrievals and facility upgrades.
Figure 1: Changes in Hanford's Tank Waste Cleanup Strategy, 1989 to
Present:
[Refer to PDF for image: timeline]
Renovate existing facility: treat double-shell tank waste:
Estimated cost: $2.8 billion (constant 1988 dollars);
Planned start of treatment: 1999.
Build new facility: treat all tank waste:
Estimated cost: $25 billion–$45 billion (current dollars);
Planned start of treatment: 1999.
Build demonstration facility: treat 10 percent of waste first:
Estimated cost: more than $50 billion (current dollars);
Planned start of treatment: 2002;
Revised start of treatment: 2007.
Current tank waste cleanup strategy:
Estimated cost: about $80 billion (current dollars):
Planned start of treatment: 2011;
Revised start of treatment: 2019.
Source: GAO analysis of DOE data.
Note: When estimating costs for its cleanup strategies, DOE has not
always included adequate contingency funding for unforeseen
circumstances. The $80 billion estimate for DOE's current strategy
includes such contingency funding of about $19 billion.
[End of figure]
Critical Uncertainties Persist in DOE's Hanford Tank Waste Cleanup
Strategy:
Critical uncertainties, such as technical and legal issues, call into
question whether DOE's strategy to treat and dispose of millions of
gallons of radioactive and hazardous tank wastes at its Hanford Site
can succeed as planned.
DOE's Waste Treatment Strategy Consists of Five Key Phases:
DOE's current strategy generally consists of removing, or retrieving,
waste from the underground tanks; separating the wastes into high-level
and low-activity waste streams through a process called pretreatment;
treating the waste on site; and ultimately disposing of the low-
activity waste on site and sending the high-level waste to a geologic
repository for permanent disposal (see figure 2). Specifically, the
five key phases are:
* Characterization: Sampling and analysis to determine the specific
physical, radiological, and chemical components of the wastes in each
tank. Waste is sampled and analyzed starting before it is retrieved
from the tanks and continuing until it is ready for final treatment.
* Retrieval: Removing waste from the tanks by pumping or other means
and transferring it to the treatment facilities. DOE uses a variety of
technologies, including high-pressure sprays to break up hardened waste
on the tank bottom and vacuum systems to suck the waste out of the
tanks. Because a large amount of liquid may be introduced during
retrieval to break up hardened waste, waste removed from a tank is
transferred to a facility to evaporate some of the liquid and reduce
its volume before being sent to the waste treatment plant.[Footnote 11]
* Pretreatment: Mixing and separating waste constituents into high-
level and low-activity waste streams by filtering, dissolving, and
extracting radioactive from nonradioactive constituents such as
aluminum, chromium, and salts. DOE uses a variety of technologies to
extract specific radioactive and hazardous materials during this
pretreatment phase.
* Treatment: Immobilizing the radioactive and hazardous constituents in
glass through a process called vitrification. The entire high-level
waste stream, and about half the low-activity waste, is to be
immobilized in the waste treatment plant by mixing it with a glass-
forming material, melting the mixture into glass in two vitrification
facilities--one for high-level waste and a second for low-activity
waste--and pouring the vitrified waste into stainless-steel canisters
(high-level waste) or containers (low-activity waste) to cool and
harden.
* Final disposal: Storing high-level waste canisters temporarily on
site until a permanent geologic repository opens and then permanently
disposing of it in a designated geologic repository and disposing of
the low-activity waste on site in a designated disposal landfill. Tanks
will be closed permanently after as much waste as technically possible
has been removed.
Figure 2: Key Phases in DOE's Tank Waste Cleanup Strategy:
[Refer to PDF for image: illustration]
Characterization:
Sampling and analyzing the waste throughout preparation for treatment.
Retrieval:
Retrieving waste from tanks and preparing for treatment;
Single-shell tanks; Double-shell tanks.
Pretreatment:
Mixing and separating waste constituents into high-level and low-
activity waste streams.
Treatment:
Vitrifying high-level waste and placing it into stainless-steel
canisters;
Vitrifying low-activity waste and placing it into stainless-steel
containers.
Final disposal:
Storing high-level waste canisters temporarily on site until permanent
repository opens;
Storing low-activity waste containers permanently on site in landfill.
Sources: GAO and DOE.
[End of figure]
Technical Uncertainties at Each Phase Could Threaten Cleanup Success:
DOE faces critical technical uncertainties, including whether the pace
of retrieving waste from the tanks will be sufficient to keep the waste
treatment plant operating as planned and whether key treatment
technologies will work. Unless DOE successfully resolves these
uncertainties, it could face problems, such as facility shutdowns,
facility modifications and retrofitting, or significant cost increases
and delays in completing Hanford's tank waste cleanup activities.
It Is Unclear Whether Systems Designed to Characterize the Waste Will
Operate at the Rate Planned:
DOE plans to rely on new systems to collect and analyze waste samples,
but the performance of these new systems has not yet been fully
demonstrated, although DOE continues to test them. It is unclear, for
example, whether these systems will be able to complete the more than
10,000 samples needed each year to ensure that the waste's composition
is understood and meets the criteria for treatment and disposal. A
sampling and analysis rate of 10,000 samples per year for the new
analytical laboratory is several times the rate that samples have been
taken and analyzed in existing Hanford laboratories. Given that waste
sampling and analysis are to occur throughout preparation of the waste
for treatment, a backlog in this system could substantially slow the
overall waste treatment process. DOE officials told us that they
recognize this uncertainty and that they are working to reduce the
number of samples that will need to be analyzed.
DOE May Have Difficulty Retrieving Waste from the Tanks at Planned
Rates:
DOE's strategy assumes that transferring waste from the single-shell
tanks into the double-shell tanks (for mixing and blending before
treatment) will progress faster than experience to date suggests. It is
unclear, however, whether DOE can increase its retrieval rate to
adequately supply waste to the waste treatment plant on a continuous,
long-term basis when the plant begins operating in 2019, as currently
planned. Since 2003, DOE has emptied 7 tanks--about 1 tank per year.
[Footnote 12] According to an August 2009 tentative legal settlement,
DOE has agreed to retrieve 10 tanks over the next 5 years--or an
increase to 2 tanks per year. Even if DOE is successful in retrieving
this number of tanks, it is uncertain whether sufficient space is
available in the double-shell tanks to hold this waste. Further,
according to DOE officials, to provide adequate waste feed to the
pretreatment facility, waste retrieval will need to increase to an
average of 5 to 7 tanks per year when operation of the waste treatment
plant begins. Even if DOE is successful in retrieving waste at this
rate from the single-shell tanks, the waste must again be retrieved
from the double-shell tanks to feed into the pretreatment facility.
Retrieving the waste in an uninterrupted manner over several decades
requires enough trained personnel; equipment and infrastructure such as
pumps, transfer lines, monitoring equipment, and scaffolding around the
tanks; and a place to transfer and store waste removed from the tanks.
A 2008 DOE report noted that tank waste retrieval rates could become
the limiting process in maintaining the overall treatment schedule.
[Footnote 13] Nevertheless, DOE officials told us they believe they
will gain enough experience in retrieving waste over the next 10 years
that increasing the retrieval rates will not be a problem.
Failure of Pretreatment Technologies Could Shut Down the Entire Waste
Treatment Operation:
In 2006, an external team of experts reported that several problems and
uncertainties with technologies designed to remove particular
radioactive and hazardous constituents from the waste streams could
make the pretreatment facility difficult to operate and maintain.
Specifically, the experts noted the potential for plugging of piping
that transports the waste through the facility; inadequate filtering to
remove certain constituents, such as aluminum and chromium; and
insufficient mixing of the waste before and during pretreatment. To
address these problems, DOE built a test facility called the
pretreatment engineering platform to test and demonstrate selected
pretreatment technologies using simulated tank wastes.[Footnote 14] On
the basis of preliminary results, DOE has adjusted the pretreatment
technologies and believes that several potential problems have been
mitigated. Although final test results have not been disclosed, DOE
officials report that the first testing phase appears to be successful.
Still, DOE has tested the systems in the pretreatment engineering
platform using only simulated waste, and according to some independent
experts we spoke with, using simulated waste to test a new system may
not uncover all potential problems. Thus, until the pretreatment
facility is operating with real waste, it will remain unclear how well
the pretreatment technologies will perform. DOE's 2008 report noted
that any single-point failure in pretreatment capabilities could halt
operation of the entire waste treatment plant.
Uncertainties over Waste Treatment Plant Capacity Complicate Treatment
Time Frames:
In addition to other rate-limiting uncertainties, questions persist
over how to treat all the low-activity waste--about 90 percent of the
total volume of waste that must be treated. At present, the low-
activity waste vitrification facility is to process only about half the
anticipated amount of low-activity waste by midcentury, when DOE hopes
to complete treatment of high-level waste. Without supplemental
capacity, DOE has estimated that tank waste cleanup could last as long
as the 2090s. Over the years, DOE has taken steps to evaluate various
supplemental options for treating low-activity waste, and the
department has an environmental impact statement under way that
includes further evaluation of supplemental treatment options (see
appendix II). Nevertheless, the department has indicated that it is
planning on a second vitrification facility specifically for low-
activity waste. The amount of low-activity waste that will ultimately
need treatment depends in large part on the amount of sodium in this
waste stream. Sodium hydroxide, which was added to the tanks to control
corrosion, is also added during pretreatment to help dissolve and
remove aluminum from the waste. Adding sodium helps reduce the volume
of the high-level waste stream but increases the volume of the low-
activity waste stream. DOE is still studying how much sodium is likely
to be needed, and if this amount is large, treatment time frames could
be lengthened by several years. Building another vitrification
facility--which, like the existing high-level and low-activity
vitrification facilities, would depend on the same series of
characterization, retrieval, and pretreatment processes--could worsen
such potential bottlenecks. That is, because DOE has no alternative to
the pretreatment facility, if this facility fails, the entire treatment
operation, including all three vitrification facilities, could come to
a halt.
The Permanent Storage Location for High-Level Waste Has Become
Uncertain:
While DOE's plan to permanently dispose of Hanford's vitrified low-
activity tank waste in an on-site landfill has been approved by state
regulators, final disposition of the vitrified high-level wastes has
become less certain. DOE had planned to store this waste temporarily at
Hanford until it could be shipped to Yucca Mountain, Nevada, the
designated repository for the nation's spent fuel and high-level waste.
[Footnote 15] DOE has been developing a license application for
constructing the repository and in June 2008 submitted this application
to the Nuclear Regulatory Commission for review. In March 2009,
however, the Secretary of Energy announced that Yucca Mountain would no
longer be the final repository for the nation's nuclear waste and in
its fiscal year 2010 budget justification, DOE proposed to eliminate
all project funding, except $197 million, primarily for licensing
activities. If no other high-level waste repository is established, DOE
sites, including Hanford,[Footnote 16] could end up storing their high-
level waste canisters on site indefinitely. Hanford's existing
temporary storage facility can accommodate only 880 high-level waste
canisters; at DOE's currently expected production rates of more than
500 canisters of vitrified high-level waste per year, Hanford will run
out of storage space less than 2 years after treatment operations
begin, or as early as 2021. Consequently, Hanford officials told us
they are exploring ways to provide additional temporary high-level
waste storage space on site. DOE plans to look at a range of options,
one of which could entail building additional modular storage
facilities that could initially store about 2,000 to 4,000 high-level
waste canisters, with future expansion for an additional 12,000 to
14,000 canisters if necessary. Until a final decision is made about
permanent disposal of high-level waste, neither the extent of
additional storage capacity needed on site nor associated costs will be
known.
Legal and Regulatory Uncertainties May Limit DOE's Ability to Carry Out
Certain Aspects of Its Tank Waste Cleanup Strategy as Planned:
DOE's tank waste cleanup strategy faces two key legal and regulatory
challenges. First, DOE's plans assume that the department will obtain
regulatory approval to reclassify some tank waste as transuranic waste,
thereby reducing the overall amount of high-level waste to be treated.
[Footnote 17] Second, because the tank waste is managed as high-level
waste and the technology to remove all of it from the tanks either does
not exist or is extremely costly to use, DOE could face potential legal
hurdles in leaving any radioactive waste in the bottom of the tanks at
closing since the tanks are not considered permanent storage facilities
for high-level waste.
Regulatory Approval Uncertain for DOE to Treat Some Waste as
Transuranic Waste:
DOE believes that waste in 11 single-shell tanks, nearly 1.5 million
gallons (of about 56 million gallons of waste at Hanford), can be
treated and disposed of as transuranic, rather than high-level, waste.
[Footnote 18] According to a DOE official, the waste in these tanks
comes largely from chemical additives and other processes, not directly
from the reprocessing of spent nuclear fuel that generates high-level
waste. In addition, DOE believes that the tanks' contents are not
radioactive enough to warrant the heavy shielding needed to protect
workers when they handle high-level waste. DOE's present tank waste
treatment strategy assumes that the department will be able to
reclassify and treat this waste as transuranic waste, at a cost of $233
million. Before DOE can go ahead with this plan, however, it will have
to gain a series of regulatory approvals from EPA, the Washington State
Department of Ecology, and the state of New Mexico, each of which has
previously expressed reservations. In 2007, EPA raised doubts as to
whether the waste qualified as transuranic waste and asked DOE for
further substantiating documentation. Ecology must approve DOE's plans
to retrieve and treat the transuranic tank waste and package it for
final disposal, but Ecology officials told us they are reluctant to
approve any treatment plans until DOE receives assurance that New
Mexico will accept the waste in its geologic repository. And New
Mexico, which has been reluctant to accept any waste once regarded as
high-level waste, may decide not to allow disposal of Hanford's tank
waste at its repository. If regulators do not approve DOE's plans for
this waste, the schedule--and associated costs--of operating Hanford's
waste treatment plant could increase by 1 year and about $1 billion.
DOE Could Face Legal Challenges over Leaving Residual Waste in the
Tanks at Closure:
Under the Tri-Party Agreement, DOE must retrieve as much waste as
technically possible from Hanford's single-shell tanks. Any waste left
in the tanks, along with the tanks themselves, could be considered high-
level waste, which would not be permitted to stay in the ground but
would have to be disposed of in a geologic repository. DOE has a
process (spelled out in its order 435.1 and associated guidance manual)
for determining whether high-level waste can be reclassified as another
waste type, and it plans to use this process to allow residual waste to
remain in Hanford's tanks when they are permanently closed. DOE's
authority to apply this order to certain high-level waste, however, was
challenged in a 2002 lawsuit, which eventually failed on procedural
grounds.[Footnote 19] Meanwhile, in 2004 DOE sought legislation
clarifying its authority to reclassify high-level waste, but although
Congress enacted legislation allowing waste reclassification at two
other sites, the relevant provision of the law specifically excluded
Hanford.[Footnote 20] This conclusion could leave DOE open to further
legal challenges if the department followed its reclassification
process to close Hanford's tanks. And if DOE lost such a challenge, it
could be forced to exhume Hanford's tanks, and any residual waste, and
dispose of it all in a geologic repository (called clean closure). In
2004, DOE estimated that this scenario could add delays and more than
$19 billion to Hanford's cleanup costs.
DOE Has Not Systematically Evaluated Whether Its Tank Waste Cleanup
Strategy, Including Costs, Is Commensurate with Risks from the Waste:
As the National Academy of Sciences and others have pointed out, a
number of factors warrant consideration when undertaking a project of
the magnitude of DOE's cleanup mission. Among these are costs, risks to
human and ecological health, and cultural and societal impacts. Yet DOE
lacks much of the information it would need to weigh these factors
fully.
DOE Lacks Credible Life-Cycle Cost Estimates for Cleaning Up Hanford's
Tank Waste:
DOE's estimates of how much it will cost to clean up Hanford's tank
waste are not credible or complete. DOE has estimated the cost of a
number of components that would go into a life-cycle cost estimate,
including the cost to design and construct the waste treatment plant,
the cost to manage and treat the tank waste, and contingency funds to
cover unanticipated costs involved with this effort.[Footnote 21] But
these estimates are not credible or complete, and each new estimate has
increased over previous estimates.[Footnote 22]
Specifically, in 2007 we reported that from 2000 to 2006, the estimated
costs to construct the waste treatment plant almost tripled, increasing
from $4.3 billion to about $12.3 billion (see figure 3),[Footnote 23]
because of contractor and management performance problems, changes in
contract scope, and technical issues.[Footnote 24] Likewise, DOE's
estimates of costs for managing and treating the tank waste have
increased significantly, raising doubts about the estimates'
reliability. In 2006, for example, DOE estimated that cleanup
activities would be finished by 2032, at an estimated cost of about $23
billion.[Footnote 25] Two years later, the completion date was pushed
out by 13 years, to 2045, with a corresponding rise in costs of about
$23 billion, to $46 billion overall,[Footnote 26] and indications are
that these costs could increase still further. DOE also normally
develops an estimate for contingency costs when carrying out large
projects like Hanford's tank waste cleanup--in this case, an estimate
of the costs to cover unknown or unforeseen events during the design
and construction of facilities and during tank waste management and
treatment activities. While DOE has included a contingency-cost
estimate of about $1 billion in the waste treatment plant's total
project cost, DOE project officials estimate that an additional
contingency of $700 million may be needed. DOE has also estimated that
a contingency amount of about $18 billion may be needed for tank waste
management and treatment.[Footnote 27] The magnitude of such
contingency funding is still another indication of the overall
uncertainty surrounding DOE's cost estimates for its tank waste cleanup
strategy. In all, the estimated cost of these three key components--
waste treatment plant construction and initial operations, tank farm
maintenance and treatment operations, and contingency costs--totals
nearly $77 billion.
Figure 3: Cost Estimates for Constructing Hanford's Waste Treatment
Plant:
[Refer to PDF for image: vertical bar graph]
Original contract price as awarded in December 2000: $4.3 billion.
Revised contract price as renegotiated in March 2003: $5.7 billion.
Contractor‘s revised cost estimate in March 2005: $8.3 billion.
Contractor‘s revised cost estimate in December 2005: $10.5 billion.
Contractor‘s latest cost estimate in December 2006: $12.3 billion.
Source: GAO analysis of DOE data.
Notes: Neither the $8.3 billion figure nor the $10.5 billion figure was
approved by DOE. The $12.3 billion figure represents the current total
project cost. The $10.5 billion figure does not include a contractor
performance fee, which is a fee that a contractor can earn above a
project's costs and that offers an added incentive to complete a
project on time and on budget.
[End of figure]
DOE did not include, or was unable to quantify, a number of significant
costs when estimating the overall cost of its cleanup strategy. DOE's
own guidance states that life-cycle cost estimates should include
actual expenditures and estimated costs from the time an activity
begins until it is completed. For the cleanup strategy, however, DOE's
estimates excluded:
* Actual expenditures before 1997. DOE incurred more than $3 billion
from 1989 through 1996 to manage Hanford's tank waste and explore ways
to treat and permanently dispose of it, bringing life-cycle costs to
about $80 billion.
* Costs associated with any increase in waste volume. Uncertainties
over the amount of sodium to be added during pretreatment could
increase the volume of low-activity waste needing treatment and
ultimately increase waste treatment costs by approximately $3 billion,
according to a January 2009 DOE study.[Footnote 28]
* Costs to build a second low-activity waste vitrification facility.
DOE has yet to size or design this facility, but given costs for a
supplemental technology that DOE already included in its estimate for
managing and treating the tank waste, additional estimated costs for a
second low-activity waste facility could increase total life-cycle
costs by nearly $1 billion, according to DOE project officials.
* Upgrading additional facilities. DOE is considering the need for as
many as four interim holding facilities for temporarily storing waste
retrieved from underground tanks before pretreatment. DOE will also
need to upgrade Hanford's facility for processing secondary waste
generated from the waste treatment operations. The costs of upgrading
or building these facilities are not fully known but, according to DOE
project officials, could be on the order of several hundred million
dollars.
* Adding temporary storage capacity for high-level waste canisters. DOE
recently estimated that its present plans to expand existing space for
storing high-level waste canisters would cost about $200 million.
According to DOE project officials, uncertainties over the fate of
Yucca Mountain could demand still more storage space on site--perhaps
nearly 14 times as much as what DOE has planned--at a cost of hundreds
of millions of additional dollars to build, maintain, and secure.
* Transporting high-level waste canisters to, and permanently disposing
of them in, a geologic repository. DOE expects to ship these canisters
to a geologic repository eventually, but the transportation and long-
term disposal costs are not included in a life-cycle cost estimate for
Hanford. Although DOE project officials could not precisely estimate
how much these activities would cost, they stated that the costs could
amount to billions of dollars.
Developing a credible, complete cost estimate including the foregoing
components is especially important now that, under the terms of the
August 2009 tentative legal settlement with Washington State, DOE is
required to have a comprehensive life-cycle cost estimate and to update
it annually. Since DOE has not included these cost components in its
estimates to date, it is unclear whether the department will do so in
future life-cycle cost estimates.
Uncertainty surrounding DOE's overall tank waste cleanup schedule adds
further doubt to the reliability of life-cycle cost estimates. Cleanup
costs stem directly from cleanup duration, and any lengthening of
cleanup time leads to cost increases of comparable magnitude. According
to present Tri-Party Agreement milestones, DOE is required to complete
treatment by 2028. In recent years, however, DOE's estimate of when it
expects to complete tank waste treatment has shifted repeatedly. In its
negotiations of new cleanup milestones with its regulators, it has
agreed that tank waste treatment may not be completed until 2047. In
addition, DOE's proposed fiscal year 2010 budget shows a range of
treatment completion dates from 2042 to 2054. Other documents consider
treatment time frames extending even further (see figure 4).
Figure 4: Shifting Estimates of the Duration of Hanford Tank Waste
Treatment:
[Refer to PDF for image: illustration]
Current Tri-Party Agreement milestones:
Start of treatment: 2011;
End of treatment: 2028.
DOE‘s approved project baseline schedule, fiscal year 2006:
Start of treatment: 2016;
Planned end of treatment: 2032;
Revised end of treatment: 2042.
DOE‘s annual updated schedule, fiscal year 2008[A]:
Start of treatment: 2019;
End of treatment: 2045.
DOE‘s System Plan, 2008[B]:
Start of treatment: 2018;
Range of end of treatment: 2049-2060.
DOE‘s fiscal year 2010 budget submittal[C]:
Start of treatment: 2019;
Range of end of treatment: 2042-2054.
Proposed change to Tri-Party Agreement milestones, 2009:
Start of treatment: 2019;
End of treatment: 2047.
DOE‘s System Plan, 2009[D]:
Start of treatment: 2019;
Range of end of treatment: 2047-2054.
Source: GAO analysis of DOE data.
[A] Department of Energy, Office of River Protection, Fiscal Year (FY)
2008 Project Baseline Summary Sheets: GEN-02 Reports (Richland, Wash.,
September 2008). This document, submitted annually to Congress,
represents DOE's best estimate of project costs and schedules.
[B] CH2M Hill Hanford Group, River Protection Project System Plan, ORP-
11242, rev. 3A, prepared for DOE (Richland, Wash., July 2008). This
planning document explains how DOE believes it can carry out its tank
waste cleanup strategy.
[C] Department of Energy, FY 2010 Congressional Budget Request:
Environmental Management, Defense Nuclear Waste Disposal, Nuclear Waste
Disposal, DOE/CF-039, vol. 5 (Washington, D.C., May 2009).
[D] Washington River Protection Solutions and AEM Consulting, River
Protection Project System Plan, ORP-11242, rev. 4, prepared for DOE
(Richland, Wash., September 2009).
[End of figure]
In the absence of a clear and reliable schedule, DOE cannot develop a
reliable cost estimate for its tank waste cleanup strategy. Moreover,
the former project manager for waste treatment plant construction
suggested that a reliable completion schedule may not be known until
2022--some years after treatment operations are to begin. Given that
estimated average annual expenditures amount to about $1.2
billion,[Footnote 29] if treatment activities actually last until 2054,
as some DOE planning documents suggest, tank waste management and
treatment could increase about $8.4 billion dollars more than
anticipated (see table 1).
Table 1: Estimated Costs Associated with DOE's Tank Waste Cleanup
Strategy:
Cost components: Waste treatment plant total project cost;
Costs included in DOE's estimate: $12.3 billion.
Cost components: Tank waste management and waste treatment operations,
fiscal years 1997 to 2045[B];
Costs included in DOE's estimate: $46.0 billion.
Cost components: Contingency: Waste treatment plant Tank waste
management and waste treatment operations;
Costs included in DOE's estimate: $0.7 billion and $18.0 billion.
Cost components: Total of DOE's current estimate for cleanup;
Costs included in DOE's estimate: $77.0 billion.
Cost components: Actual costs, fiscal years 1989 to 1996;
Costs not included in DOE's estimate[A]: $3.0 billion.
Cost components: Increases in waste volume;
Costs not included in DOE's estimate[A]: $3.0 billion.
Cost components: Second low-activity vitrification facility;
Costs not included in DOE's estimate[A]: $1.0 billion.
Cost components: Cleanup schedule extension from 2045 to 2047[C];
Costs not included in DOE's estimate[A]: $2.4 billion.
Cost components: Total potential costs if treatment extends to 2047;
Costs not included in DOE's estimate[A]: $86.4 billion.
Cost components: Cleanup schedule extension to 2054[D];
Costs not included in DOE's estimate[A]: $8.4 billion.
Cost components: Total potential costs if treatment extends to 2054;
Costs not included in DOE's estimate[A]: $94.8 billion.
Cost components: Additional facilities;
Costs not included in DOE's estimate[A]: Hundreds of millions of
dollars.
Cost components: Temporary storage capacity for high-level waste
canisters;
Costs not included in DOE's estimate[A]: Hundreds of millions of
dollars.
Cost components: Transporting and disposing for high-level waste
canisters;
Costs not included in DOE's estimate[A]: Billions of dollars.
Cost components: Potential cost of DOE's cleanup strategy;
Costs not included in DOE's estimate[A]: $86 billion to more than $100
billion.
Source: GAO analysis of DOE data.
[A] Unless otherwise indicated, these estimates, provided by DOE,
represent only rough orders of magnitude.
[B] DOE's most recent estimate, dated September 2008, reflects a
cleanup completion date of 2045.
[C] DOE's most recent estimate, dated September 2008, reflects a
cleanup completion date of 2045. In an August 2009 proposed legal
settlement, however, DOE agreed to complete cleanup by 2047. The cost
estimate is based on data provided by DOE.
[D] DOE's latest internal planning document shows a range of cleanup
completion dates from 2047 to 2054. The cost estimate is based on data
provided by DOE.
[End of table]
Overall the total estimated cost could significantly exceed DOE's
current estimate of $77 billion, with estimates ranging from about $86
billion to over $100 billion, depending upon the date cleanup is
completed.
DOE Has Not Applied Risk-Informed Decision Making in Its Tank Waste
Cleanup Strategy:
Although the importance of risk assessment for decision making had been
recognized for more than 2 decades before cleanup of DOE's weapons
complex began, to date DOE has analyzed risks to human and ecological
health mainly in the context of complying with environmental analysis
requirements under the National Environmental Policy Act of 1969.
[Footnote 30] Under this act, agencies evaluate the likely
environmental effects of projects they are proposing by using an
environmental assessment or, if the projects are likely to
significantly affect the environment, a more detailed environmental
impact statement. Under regulations implementing the act, an
environmental impact statement must assess the environmental effects of
the proposed agency action and all reasonable alternatives. A 1983
National Academy of Sciences report, on the other hand, explicitly
assessed the feasibility of, and offered guidelines for, federal
agencies' use of risk assessment--separate from regulatory functions--
in their decision making.[Footnote 31] Since DOE's cleanup efforts
started, some three dozen studies by academics, the National Academy,
and DOE itself have examined aspects of risk assessment in relation to
DOE's cleanup work. Many of these studies have identified shortcomings
in the department's efforts to address risk in its decision making and
urged it both to adopt a more disciplined process for analyzing risks
and to use the results of such risk analyses when making key decisions.
DOE's principal risk assessment to date with regard to tank waste is
found in its 1996 environmental impact statement. This statement
discussed the potential environmental effects related to several
strategies for managing and treating Hanford's tank wastes.[Footnote
32] Most of these alternatives involved vitrification technologies, to
the near exclusion of other potential alternative treatment pathways.
This environmental impact statement was not required to be--and was
not--a systematic risk assessment of all options to treat Hanford's
tank wastes. As we previously reported, for example, it did not purport
to analyze the condition or long-term viability of Hanford's aging
tanks or the risks of leaving waste in the tanks for several decades
during cleanup operations.[Footnote 33] The environmental impact
statement did examine 10 tank waste treatment strategies--including "no
action" and a "preferred alternative"--and the potential effects of
these strategies on different groups of people, such as site workers,
recreational river shoreline users, farmers, and Native American users,
under different long-term land-use scenarios. The "no action"
alternative was predicted to result in 600 "latent cancer fatalities"
among future farmers on the site over 10,000 years. DOE's preferred
alternative--on which DOE's present strategy is based--was predicted to
reduce to 10 the number of farmers' deaths over 10,000 years. This
alternative would also result in disturbing the widest area of the
region's native shrub-steppe ecosystem of all the alternatives
presented. In comparison with no action, however, this alternative
would add thousands of regional jobs during treatment plant
construction. Significant costs were associated with all 10 treatment
alternatives; in 1996 dollars, no action was estimated to cost $13
billion to $16 billion, while the preferred alternative was projected
at the time to reach $30 billion to $38 billion.
Internal as well as external reports since that time have noted
problems with DOE's risk assessment and decision making. One of the
major findings of DOE's 2002 "top-to-bottom" review of its
Environmental Management program, for example, states that
"[Environmental Management's] complex-wide cleanup strategy is not
based on a comprehensive, coherent, technically supported risk
prioritization....This approach has resulted in costly waste management
and disposition strategies that are not proportional to risks posed to
human health and the environment."[Footnote 34] More recently, a 2005
National Academy of Sciences report observed that "DOE risk assessments
and decision processes...do not exhibit all of the characteristics of
an effective and credible risk-informed decision-making process."
[Footnote 35]
DOE is planning to issue another environmental impact statement,
[Footnote 36] expected in October 2009, but it is unclear to what
extent its consideration of risks will follow available risk assessment
guidelines. According to the National Academy's 2005 report, a risk
assessment framework would weigh a number of factors--including costs,
worker and public safety, effect on ecosystems, technical feasibility,
cultural impact, and other trade-offs. A 2008 report by the academy
goes further, outlining a three-phase framework for risk-based decision
making that "maximizes the utility of risk assessment" in evaluating
options to reduce hazards.[Footnote 37] DOE's forthcoming environmental
impact statement will evaluate a number of alternative strategies for
carrying out tank waste cleanup and other cleanup-related activities--
in particular, options for supplementing the capacity for treating low-
activity waste and options for closing the tanks.[Footnote 38]
Regarding tank waste cleanup, for example, the document will discuss
the short-and long-term effects of several options for treating both
high-level and low-activity tank waste, coupled with various tank
closure alternatives. These options include retrieving an amount of
waste (90 percent) that is less than the goal set by the Tri-Party
Agreement (99 percent) and retrieving nearly all the waste (99.9
percent), an amount that would have to be achieved if the tanks are to
be removed from the ground. In addition, the environmental impact
statement will consider long-term cumulative effects from past
practices (including waste already discharged into the soil), present
activities, and future actions. The document's release has been delayed
more than 2 years, and it is not yet clear when it will be
issued.[Footnote 39]
Given that environmental impact statements are DOE's primary risk
assessment vehicle, the current effort provides an opportunity to use
available risk assessment guidelines to consider scenarios the
department has not considered to date--in particular, the possibility
of removing varied quantities of waste from the tanks. The National
Academy's 2005 report stated, for example, that removing every gram of
high-level waste is technologically unfeasible without also removing
the tanks themselves and that the effort is likely to be out of
proportion with the concomitant risk reduction. Indeed, more than half
the experts we spoke with said that the 99 percent figure has no
scientific basis, and several recommended that DOE conduct a
comprehensive risk assessment of residual tank waste.
Some Opportunities May Exist to Reduce Costs of DOE's Hanford Tank
Waste Cleanup Strategy:
Given the current status of DOE's cleanup strategy and associated
costs, three primary options appear available for reducing life-cycle
costs of tank waste cleanup. The likelihood of their success--and
potential effects on cleanup costs--has not yet been determined.
Increasing the Amount of High-Level Waste Captured in Each Canister
Could Reduce the Number of Canisters and Treatment Duration, Thereby
Reducing Costs:
DOE officials at Hanford are researching methods for increasing the
amount of high-level waste ultimately immobilized in each canister in
an attempt to reduce the total number of canisters produced and,
perhaps, treatment duration. The total concentration of high-level
waste per canister depends on, among other factors, the specific mix of
radioactive and other constituents going into the canister. Certain
chemical mixes lend themselves less well to vitrification than others.
Chemicals such as aluminum can be added to glass only up to specific
limits without altering glass quality. If aluminum concentration
exceeds these limits, the resulting glass product may not be able to
keep the radioactive constituents from leaching out over time. DOE is
therefore studying techniques for fine-tuning the mix of constituents
so as to maximize the concentration and retention of high-level waste
in each canister. DOE estimates that its waste canisters may, on
average, contain about 28-31 percent high-level waste.[Footnote 40] At
this concentration, DOE would generate more than 500 high-level waste
canisters per year, or a total of 9,000 to 15,000 high-level waste
canisters. DOE is hoping to increase high-level waste concentrations in
each canister, but it is too early to tell what levels can be
consistently achieved during full-scale treatment. If successful,
according to some DOE officials, such increases in waste concentrations
could reduce the number of high-level waste canisters, potentially
shaving years--and associated costs--off treatment operations. While it
is unclear what savings could be achieved, DOE believes the savings
could be substantial.
Performing Additional Testing on Pretreatment Technologies Could Help
Minimize Problems during Waste Treatment Operations:
In 2008, DOE built a test facility, the pretreatment engineering
platform, to help resolve uncertainties in selected pretreatment
technologies, particularly the engineering designs for ultrafiltration,
or filtering the waste to remove solids; efficiently dissolving
components such as aluminum and chromium to facilitate separating high-
level from low-activity waste streams; and ensuring that piping
throughout the facility will not clog with waste sludge moving through
the system. A number of the experts we spoke with had concerns about
the reliability of these and other pretreatment technologies.[Footnote
41] In May 2009, DOE officials stated that the department has completed
most of the testing on these technologies (with a report to be released
later this year), and project officials stated that they had improved
the facility's design as a result of the testing. It appears, however,
that the pretreatment platform provides DOE with an opportunity to use
the platform to test additional pretreatment technologies and also to
refine or enhance the efficiency and effectiveness of future
pretreatment operations. Given the delays--and costs--that could arise
if the pretreatment facility becomes a significant bottleneck for waste
treatment plant operations overall, some of the experts we spoke with
commented that using the pretreatment engineering platform for testing
before full operations begin could help reduce uncertainties. As we
reported in 2003, if pretreatment processes at Hanford do not work as
planned, facilities would likely have to be retrofitted, resulting in
potential cost increases and schedule delays much greater than those
associated with process testing in a pilot facility.[Footnote 42] DOE
has recognized this opportunity and is considering options for further
testing and for obtaining needed funding.
Allowing More Residual Waste to Remain in Selected Tanks at Closing
Could Help Reduce Costs without Adding Risks to Human or Ecological
Health:
With regard to amounts of residual waste permitted in the tanks at
closure, DOE's present strategy is driven in large measure by
milestones agreed to in the Tri-Party Agreement. This agreement calls
for retrieving as much waste as technically possible, with tank waste
residues not to exceed specified volumes.[Footnote 43] Federal
regulations under RCRA define a waste container as "empty" if, among
other criteria, it contains no more than 1 inch of waste residues,
which is the equivalent of the volume limits stipulated in the Tri-
Party Agreement.[Footnote 44] According to one DOE official, the volume
limits in the agreement were set to ensure that at least 99 percent of
the waste would be removed from the single-shell tanks. Several of the
experts we interviewed, however, suggested that DOE could leave more
waste in selected tanks at closing and still protect human health and
the environment.
As DOE has emptied the single-shell tanks, it has found that estimates
for retrieving the waste have significantly understated actual costs.
For example, in 2003, DOE estimated that retrieving waste from all the
single-shell tanks would cost approximately $1.1 billion, or an average
of about $7.6 million per tank. Actual costs of removing waste from the
first seven tanks, however, have amounted to $236 million, or about $34
million per tank.[Footnote 45] Because four of the emptied tanks were
Hanford's smallest, actual costs for the more-numerous larger tanks
could be much higher.
In retrieving waste from Hanford's single-shell tanks, DOE has also
found that retrieving the last portion of waste from a tank can be
disproportionately costly. In at least five out of the seven tanks
emptied to date, DOE has found it technically challenging to retrieve
99 percent of the waste and meet the Tri-Party Agreement goal. For some
of these tanks, DOE has estimated that the cost of retrieving the last
15 percent of the waste can equal or exceed the cost of removing the
first 85 percent (the cost per gallon can be as much as three times
higher). For example, as we previously reported, DOE found that in
retrieving the waste from one large tank (C-106), the cost of removing
each additional cubic foot, or about 8 gallons, of waste ranged from
$35,000 to $84,000--in other words, from 7 to 16 times the average cost
per cubic foot to retrieve the first nearly 99 percent of the
waste.[Footnote 46] Moreover, in its analysis, DOE concluded that the
risk to workers from removing this waste, combined with the high cost,
outweighed a relatively minimal reduction in risk to the public and
future users of the site. Similarly, a DOE official told us that for
another tank (C-103), the cost to date of retrieving about 85 percent
of its residual waste was about $4 million and for retrieving an
additional 12 percent of the residual waste, $2 million.[Footnote 47]
Currently, DOE has not analyzed how to close the tanks in a manner that
would balance risk with cost. The Washington State Department of
Ecology and DOE developed a plan for a tank closure demonstration
project to be carried out in collaboration with DOE, its contractors,
EPA, and the state itself. The project's purpose was to bring the
agencies together to, among other objectives, gather engineering and
cost data on technologies that might be used to close single-shell tank
systems; identify and begin to gather information needed for specific
regulatory decisions associated with tank closure; and develop a common
understanding of the relevant regulatory processes in order to
facilitate permitting. In the August 2009 tentative legal settlement,
DOE agreed to complete certain activities in this tank closure
demonstration project by 2011. These activities include determining the
process DOE will follow to reclassify residual tank waste, studying
technical aspects of exhuming tanks, and evaluating alternatives for
removing residual waste from a selected tank. Such a demonstration
project could be expanded to include analyzing varying amounts of waste
that could be left in a group of tanks at closing, with the goal of
reducing costs while adequately protecting human and ecological health.
This demonstration could allow DOE and the state to determine how to
close the tanks in a cost-effective manner, as well as to streamline
the tank closure process by determining closure goals and methodologies
on a group of tanks, instead of one tank at a time.
Conclusions:
In 1989, when DOE began its cleanup mission at the Hanford Site, the
total estimated cost was $2.8 billion, with treatment to begin in 1999.
Despite the passage of two decades, investment of $12 billion, attempts
at several ultimately discontinued strategies, and numerous
recommendations from us and others, no waste has yet been treated for
final disposal. DOE has, however, learned lessons along the way. It has
improved its strategy, developed and refined its retrieval and
treatment technologies, and made progress constructing the treatment
facilities. DOE has also learned that cleaning up the legacy of
radioactive and hazardous waste is more complex, more time-consuming,
and significantly more expensive than envisioned. Yet DOE still faces
many critical unknowns, including whether the treatment plant will
actually work as planned, whether DOE can reclassify waste as planned
without explicit statutory authority, and where treated high-level
waste will be permanently disposed of. And although it is clear that
the total costs--now estimated at $77 billion--will be much higher than
originally anticipated, ranging from $86 billion to more than $100
billion, it is unclear at this point what the final costs will be.
Moreover, as we have previously reported, certain risks--such as
radioactivity--are declining with time, even as costs continue to climb
and cleanup completion dates recede into the future. Given that the
intersection is constantly shifting between actual cleanup costs and
changing risks posed by the wastes, it is imperative that Congress have
access to reliable life-cycle cost and risk information as it decides
how to best allocate limited financial resources among many competing
needs. And given escalating expenditures, it is also imperative that
DOE diligently seek ways to reduce the costs of this massive
undertaking without unduly compromising ecological, worker, or public
health. Otherwise, the effort, worker exposure, and expense associated
with retrieval, immobilization, and final disposal of tank waste in a
geologic repository might be out of proportion with the risk reduction
achieved.
Recommendations for Executive Action:
In light of growing costs and lengthening schedules as DOE proceeds
with its strategy to treat and permanently dispose of Hanford's tank
waste, we recommend that the Secretary of Energy direct the Assistant
Secretary for Environmental Management to take the following four
actions:
* Develop credible and complete life-cycle cost and schedule estimates,
which include actual costs expended to date and projected future
expenditures for all key elements; obtain independent expert evaluation
of these estimates; and report these estimated costs to Congress.
* Adopt a risk assessment framework for Hanford cleanup that considers
available guidance, such as that provided by the National Academy of
Sciences.
* Consider seeking clarification from Congress about the department's
authority at Hanford to determine whether some waste now managed by DOE
as high-level waste can be treated and disposed of as a waste type
other than high-level waste.
* Work with state and federal regulators to develop a risk-based
approach for closing waste storage tanks in an efficient and effective
manner--such as through a tank closure demonstration project--and to
analyze varying amounts of waste that could be safely left in the tanks
or a group of tanks at closing, with the goal of reducing costs while
adequately protecting human and ecological health.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Department of Energy for its
review and comment. On behalf of the department, DOE's Assistant
Secretary for Environmental Management wrote that DOE generally agreed
with three of the four recommendations we made. DOE did not agree with
our recommendation to consider seeking clarification from Congress
about the department's authority at Hanford to determine whether some
waste now managed as high-level waste can be treated and disposed of as
other than high-level waste. In addition, DOE expressed concerns about
how we characterized the Office of Environmental Management's progress
at cleaning up Hanford tank waste with respect to three primary issues:
addressing technical and other challenges, developing credible and
complete life-cycle cost and schedule estimates, and assessing risks.
On September 18, 2009, we met with the Assistant Secretary for
Environmental Management to discuss selected DOE comments on our draft
report, as well as the Assistant Secretary's concerns that readers may
be confused about the scope of our report and assume that we also
reviewed and based our conclusions on an assessment of legal and
technical documents that are scheduled to be released shortly after our
report is issued. We added a clarification in the scope and methodology
section of this report to note that our conclusions and recommendations
are based only on information available to us during our review. DOE's
written comments on our draft report are reproduced in appendix III.
DOE also provided general and specific technical comments, which we
discuss below or incorporated in the body of the report as appropriate.
The first major issue for DOE regards progress in addressing technical
and other challenges. DOE stated that we did not adequately describe
the department's substantial experience in and processes in place for
addressing technical and other challenges of treating and disposing of
Hanford's tank waste. In its letter, DOE cited a number of examples of
cleanup activities across the DOE complex of sites that it said are
applicable to the challenges at Hanford and inform its technical and
project management approach. Without doubt, DOE has gained knowledge
about treating tank waste and closing tanks through its work at the
Savannah River Site, South Carolina; the Idaho National Laboratory; and
other locations. At none of these sites, however, does the waste
approach the amount and complexity of Hanford tank waste. About 56
million gallons of tank waste must be treated at Hanford, more than at
any other DOE site. In addition, this tank waste is uniquely complex
because of the specific radioactive and chemical elements that have
been mixed in it over the years, so that work done at other sites,
though helpful, may not always be directly relevant to treating
Hanford's tank waste. The examples of success DOE cited in its written
comments are informative but, relative to the final output expected at
the Hanford Site, of much smaller scope. For example, DOE cited West
Valley, New York, where about 275 high-level waste canisters were
produced. Some estimates for Hanford, in contrast, put the number of
high-level waste canisters alone between 9,000 and 15,000. Moreover,
the scope of our study, as requested by Congress, was to look at
Hanford's tank waste cleanup project, not cleanup across the rest of
the DOE complex.
DOE also commented that we did not cite all the initiatives it has
under way to help address technical uncertainties specifically at the
Hanford Site. We did discuss several initiatives, including the
pretreatment engineering platform and external review teams, which have
been very useful in identifying and helping address technical
challenges that DOE faces at Hanford. Even with these and other efforts
mentioned by DOE in its letter, however, DOE's own assessments of the
waste treatment plant point out that a number of uncertainties still
exist and that solving these may be critical to operating the plant as
planned. Also, some experts we spoke with said that it is to be
expected that some technical issues may remain unresolved until the
plant is operating and actual waste is being treated. As discussed in
our report, many of the technical uncertainties at Hanford surround
whether treatment operations will be able to achieve the throughput
assumed in DOE's planning documents. The former project manager at the
Hanford Site told us that it may take a few years of plant operation
before DOE will be able to accurately determine how many years it will
take to treat all of the site's tank waste. Finally, technical concerns
discussed in this report have been documented in DOE's own assessments
and studies, as well as echoed by the experts we spoke with.
Further, DOE stated that our report should provide better context for
our analysis of the challenges at Hanford and, as evidence, cited a
2001 report we issued on the Rocky Flats closure project.[Footnote 48]
In that report, we stated that DOE could have difficulty meeting the
target closure date because of significant challenges that DOE and its
Rocky Flats contractor faced. Nevertheless, despite these challenges,
DOE and its contractor did meet their target closure date of 2006. Our
conclusions in that report were based on the contractor's own
assessment that it had only about a 15 percent probability of
completing the project by 2006. In our view, by highlighting the
challenges DOE and its contractor faced, our report helped focus
attention needed to successfully complete the project in a timely
manner.
The second issue DOE raised in its written comments relates to whether
DOE is developing credible and complete life-cycle cost and schedule
estimates. In agreeing with our recommendation on this topic, DOE
stated that it has a process for developing credible and complete life-
cycle cost estimates for Hanford. We maintain, however, that past cost
estimates for Hanford tank waste cleanup were neither credible nor
complete. As discussed in this report, costs for constructing the waste
treatment plant and managing the tank waste, for example, have grown
significantly over the life of the project. Although DOE stated that we
used a point estimate of our own construct, we in fact discussed with
DOE officials at the Office of River Protection the cost estimates
making up the $77 billion figure in table 1. These officials provided
updated figures to reflect a 2045 completion date, rather than a 2042
date for the figures quoted by DOE in its written comments. DOE's
current estimate for cleanup could range from $58.3 billion if no
contingency is included to $77.0 billion if the full $18.7 billion
contingency is included, in contrast to the range of $56 billion to $74
billion that DOE provided in its letter.
Further, many potentially significant costs were not included in any
estimates DOE provided us. If these are added in, the total cost for
this undertaking could range from $86 billion to more than $100
billion. We recognize that DOE has been taking steps to try to improve
its cost-estimating process, including using GAO's cost-estimating
guide,[Footnote 49] when developing cost and schedule estimates. DOE is
also developing a new cost and schedule baseline for the Hanford tank
waste cleanup effort, but since this baseline has not yet been
validated or approved by DOE, it was not available for our review.
Further, as noted in its comments, under the August 2009 tentative
legal settlement for Hanford (which is still subject to public review
and comment), DOE has agreed to prepare a life-cycle analysis of all
Hanford cleanup costs to meet the legally mandated cleanup timelines.
We look forward to development of this analysis because we believe that
until DOE develops a complete life-cycle cost analysis at Hanford--one
that takes into account all potentially significant costs stemming from
the effort to clean up tank wastes, including those for interim and
permanent storage of waste canisters--information presented to Congress
could understate the true costs of this challenging cleanup effort.
DOE's third issue relates to consideration of risk. DOE agreed with our
related recommendation to adopt a risk assessment framework that
considers available guidance, such as that provided by the National
Academy of Sciences, but added that it believes it already has a risk
assessment framework for Hanford and that our report does not recognize
existing DOE risk management efforts (our emphasis). We acknowledge
that DOE has taken steps to assess risks, such as in its forthcoming
draft environmental impact statement, which is expected to be released
for public comment in October 2009. DOE also has a process for managing
risks, and its letter says the Tri-Party Agreement contains provisions
for mitigation of programmatic risk. Risk assessment, however, is not
the same as risk management. Specifically, in the view of the National
Academy of Sciences, the assessment of risks and related scientific
findings and policy judgments should be distinguished from risk
management alternatives. In essence, the science of risk analysis and
assessment to inform policy are related to but distinct from actions
taken to manage identified risks. In its technical comments on our
report, DOE addressed risk management activities at some length. For
example, it stated that we failed to mention DOE guidance on risk
management, the River Protection Project Federal Risk Management Plan,
and other key documents that include risk mitigation actions. DOE
described these documents, for example noting that the river protection
plan lays out the critical technical, programmatic, and operational
risks facing Hanford's cleanup projects. But in our view, DOE's
description focuses on mitigation steps for addressing risks to meeting
the project's cost and schedule estimates. Therefore, although we
considered these documents, we did not include them in our analysis
because they focused on project risks rather than addressing risks to
human and ecological health.
Moreover, we are not the first to suggest that DOE's risk assessment
framework falls short. As stated in our report, some three dozen
studies by academics, the National Academy of Sciences--including
studies done at the behest of DOE--and DOE itself have examined aspects
of risk assessment in relation to DOE's cleanup efforts and found
shortcomings. As early as 1983, a National Academy of Sciences report
offered guidelines for federal agencies' use of risk assessment,
distinct from regulatory functions, in their decision making. Yet we
found, and DOE's comments also stated, that the draft environmental
impact statement on tank waste treatment and closure, required under
the National Environmental Policy Act, is a primary risk assessment
vehicle. In light of DOE's comments on this topic, confusion seems to
persist about the differences between risk assessment and risk
management.
With regard to the issue of the risks of leaving more waste in tanks,
DOE stated that it is important to recognize that the department has
limited discretion when it comes to decisions on how to proceed with
cleanup. It noted that the Tri-Party Agreement generally requires
removal of 99 percent of waste from the tanks using available
technologies. We recognize that DOE must operate within the legal
constraints placed on it. That said, the Tri-Party Agreement does allow
DOE to seek an exemption from the 99 percent target on a tank-by-tank
basis, and DOE is currently using this exemption process for one tank
it has been emptying. Our point is that, given the enormous task DOE
faces and the enormous associated costs, if and when situations arise
where the efforts and costs to meet the 99 percent waste removal
standard are significantly out of proportion with the actual risk
reduction achieved, DOE and its regulators should perhaps reconsider
the reasonable and appropriate path forward. We, like DOE, believe the
tank closure demonstration project DOE plans to carry out in
collaboration with Washington State and EPA will be useful in informing
this discussion.
DOE disagreed with our recommendation suggesting that the department
consider seeking clarification from Congress about its authority to
reclassify high-level waste, stating that it does not believe it needs
clarification about the department's authority at this time. DOE stated
that its attention for the next 10 years will be on removing waste from
tanks, finishing construction of the waste treatment plant, and
starting waste treatment operations. The department was silent,
however, on the merits of the recommendation itself. We recognize that
DOE requested this clarification once before and that in 2004
legislation (section 3116 of Public Law No. 108-375), Congress provided
this authority to DOE sites in Idaho and South Carolina while
specifically excluding DOE sites in Washington State. Given the
importance of waste classification to the overall Hanford cleanup
strategy, however, we believe that it may be prudent to consider
revisiting the topic with Congress. By indefinitely postponing
potential resolution of this question, DOE may be leaving itself
vulnerable to future litigation on a topic that could pose more severe
problems later. By pursuing the question now, DOE could have time on
its side and can work with regulators and stakeholders to tailor its
strategy appropriately.
Finally, in its technical comments, DOE stated that many comparisons
made in the report do not have consistent or equitable bases. DOE
commented that while the costs and schedules for its Hanford tank waste
cleanup strategy have varied over time, the associated scope has
greatly changed, and earlier cost estimates did not include over $2
billion in funded contingency. In describing the previous and current
treatment strategies, our report does note that the scope, as well as
associated costs, has changed over time. This information is given as
background for readers, not an exhaustive discussion of previous
strategies that did not reach fruition. DOE also commented that we
compared information, such as treatment completion dates, from
documents having different purposes, such as a baseline schedule and a
strategic planning document. We recognize that the documents were
developed for varied reasons. Nevertheless, we believe that the wide
range of completion dates from these different documents, in
particular, contributes to a better understanding of the potential
uncertainties surrounding an effort of this magnitude and complexity.
We are sending copies of this report to other interested congressional
committees and to the Secretary of Energy. The report also is available
at no charge on the GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions regarding 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. Key contributors 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 Department of Energy's (DOE) current Hanford Site
cleanup strategy and the key technical, legal, and other uncertainties
it faces, we gathered and reviewed numerous reports and studies
addressing DOE's overall plan to retrieve, treat, and dispose of
Hanford's tank waste. We reviewed historical documents to understand
how DOE's tank waste cleanup strategy has evolved. We reviewed reports
by DOE and its contractors, which discussed technical problems with the
waste treatment plant and other phases of DOE's strategy. We also
reviewed documents analyzing DOE's need for supplemental capacity, and
the department's analysis of potential options, for treating low-
activity waste. To identify legal, regulatory, and other uncertainties,
we reviewed applicable laws, regulations, policy, and guidance
documents, as well as information on past and pending lawsuits. In
addition, we interviewed DOE Hanford Site officials in the Office of
River Protection and visited the Hanford Site. We also interviewed
officials at DOE headquarters in the Office of Engineering and
Construction Management and in the Office of Environmental Management's
Office of Project Recovery and Office of Engineering and Technology. We
interviewed contractor officials at the Hanford Site responsible for
building the waste treatment plant. We interviewed officials with
regulatory and other agencies--specifically, the Washington State
Department of Ecology, the Environmental Protection Agency (EPA), the
Nuclear Regulatory Commission, and the Defense Nuclear Facilities
Safety Board--as well as the National Academy of Sciences.
To determine the extent to which DOE has assessed whether Hanford's
tank waste cleanup strategy, including costs, is commensurate with the
risks from its tank wastes, we examined budget and financial documents,
environmental impact studies, and other relevant DOE documents. Budget
information we reviewed included DOE's proposed budget for 2010, DOE's
estimated costs for tank waste cleanup, and project cost and schedule
baselines. We spoke with DOE officials and took other steps to ensure
that all cost data were sufficiently useful for purposes of this
report. We reported all cost data as provided by DOE--rather than
normalize them for comparison by using constant dollars, for example--
because not all cost information was available annually. We also
reviewed GAO's recent cost-estimating guide for further information on
life-cycle costs and risks in developing credible cost estimates.
[Footnote 50] Further, we reviewed milestones DOE agreed to under the
Tri-Party Agreement, as well as alternative schedules, such as DOE's
suggested milestone changes proposed during negotiations with the state
of Washington and EPA, and other documents showing schedule plans. We
reviewed DOE's guidance on risk assessments, as well as National
Academy of Sciences reports and published articles by risk assessment
professionals. We also reviewed DOE's past environmental impact
statement and information on DOE's most recent environmental impact
statement, as well as performance assessments; both assessment types
discuss risks.
To evaluate options that DOE could follow to reduce costs of its tank
waste cleanup strategy, we reviewed DOE documents discussing various
options. To gain additional insights, we interviewed 18 experts, all of
whom are independent of DOE and its contractors and have extensive
knowledge of DOE's tank waste cleanup strategy. We identified these
experts in consultation with various sources, including the National
Academy of Sciences and Defense Nuclear Facilities Safety Board; prior
independent reviews of DOE's Hanford tank waste cleanup strategy; and
our technical consultant, George W. Hinman, Professor Emeritus of
Applied Energy Studies at Washington State University, who has
extensive nuclear energy experience in industry, government, and
academia. We developed a structured interview guide, containing open-
ended questions about various aspects of Hanford's waste cleanup
strategy. These questions addressed uncertainties with DOE's current
waste treatment strategy, treatment technologies for low-activity
waste, and developing risk assessment information for DOE's tank waste
cleanup strategy. We pretested our interview guide to ensure the
questions were clear and relevant. Using the guide, we interviewed each
expert either by telephone or in person. Because the questions were
open-ended, and experts were knowledgeable about varied but not all
aspects of the issues covered, we did not attempt to quantify their
responses for reporting purposes.
Several key documents were just released or were scheduled to be
released by DOE shortly after our report was to be issued. These
included a tentative legal settlement with the state of Washington, an
amended Tri-Party Agreement, a draft environmental impact statement for
tank closure, and a new cost and schedule baseline for the Hanford tank
waste cleanup effort. We reviewed an August 10, 2009, version of the
tentative legal settlement and were provided access to a version of the
draft environmental impact statement, but the remaining documents were
not available at the time of our review. These documents are discussed
in our report and factored into its conclusions and recommendations as
available and appropriate. As agreed with DOE, we included only
publicly available information about the draft environmental impact
statement in our report.
We conducted this performance audit from July 2008 to September 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: Overview of DOE's Efforts to Select an Approach to
Supplement Its Low-Activity Tank Waste Treatment Capacity:
As DOE's strategy for cleaning up tank waste at the Hanford Site has
evolved over the past 20 years, the department has evaluated a number
of technologies to supplement its capacity to treat the low-activity
fraction of the waste.[Footnote 51] As of July 2009, however, DOE
officials told us they had postponed further testing of one potential
supplemental technology at Hanford and were proceeding with planning
for another low-activity waste vitrification facility to provide more
treatment capacity.
Over the years, DOE's approach to treating low-activity waste at
Hanford has moved away from grout, a method used at other DOE sites, to
vitrification. DOE's original plan in 1989 called for mixing low-
activity waste with materials to form the hardened, cementlike
substance called grout, which would be permanently disposed of on site
in more than 200 large, underground vaults with elaborate environmental
controls. This disposal method is similar to those widely used in the
commercial nuclear industry and by DOE at sites besides Hanford, such
as Savannah River and West Valley, for immobilizing and disposing of
low-activity and hazardous wastes. In the early 1990s, however, state
regulators and other stakeholders raised concerns about using grout at
Hanford. These concerns included doubts about grout's ability to
prevent long-lived radionuclides, such as technetium-99, from migrating
into groundwater over a long period; reliance on engineered barriers to
further limit water infiltration into the vaults; the irretrievability
of grout from the vaults once disposed of; and the large land area
(over 200 acres) that would be needed for the underground vaults. Given
these concerns, DOE suspended efforts to develop a grout-based disposal
form while it studied the feasibility of other options, including
various vitrification alternatives.
In 1994, DOE officially decided against grout and chose to pursue
vitrifying Hanford's low-activity tank waste. DOE studies concluded
that a vitrified disposal form offered superior performance over grout.
These studies showed that glass was capable of retaining long-lived
radionuclides over a much longer period, required a much smaller
permanent disposal facility, and had life-cycle costs generally
comparable to those for grout. In 1994, the Tri-Party Agreement was
amended to include immobilization of low-activity waste by
vitrification.[Footnote 52] DOE's 1996 tank waste remediation system
environmental impact statement--which evaluated treatment options and
short-and long-term effects for Hanford's tank waste cleanup--largely
considered vitrification as the technological option for treating low-
activity waste. DOE ultimately decided on a phased approach to treating
the waste, that is, building demonstration-sized facilities to test
treatment technologies on a small portion of the waste--eventually
determined to be 10 percent of the waste volume--with construction of a
full-scale facility after testing was complete.[Footnote 53] After the
contract was awarded in 2000 to build the waste treatment plant,
however, DOE opted to have its contractor build a full-scale treatment
plant, which included a low-activity vitrification facility that was
not large enough to treat all of Hanford's low-activity tank waste by
the time high-level waste treatment was completed.
In 2002, DOE shifted its treatment strategy to an accelerated approach
to meet regulatory and other commitments calling for completing
treatment of Hanford's tank waste by 2028. DOE recognized, however,
that the low-activity vitrification facility planned for Hanford would
not be able to treat more than 50 percent of the low-activity waste by
this deadline. DOE, along with the Washington State Department of
Ecology; EPA; and experts from national laboratories, industry, and
academia, then met to evaluate a number of technologies that could be
used to supplement Hanford's treatment capacity to meet the accelerated
schedule.[Footnote 54]
Together, the agencies identified three technologies--bulk
vitrification, fluidized bed steam reforming, and cast stone--along
with a second low-activity vitrification facility, as the most viable
options for supplementing DOE's treatment capability. Bulk
vitrification is a vitrification process similar to the technology
planned for the first low-activity waste vitrification facility--
whereby waste is mixed with other materials, heated in a melter to form
a glass substance, then poured into stainless-steel containers for
disposal--except that in bulk vitrification, the melter also serves as
the final disposal container. Steam reforming is a thermal process that
uses steam and chemical additives mixed with the waste to form a
granular, mineral-like waste form. Cast stone is a nonthermal, cement-
based approach that mixes the waste with Portland cement to create a
monolithic disposal form. While the Washington State Department of
Ecology participated in selecting technologies for further testing, the
state has maintained that any supplemental treatment technology must be
shown to be "as good as glass," which means that it must meet or exceed
all the same performance standards and disposal criteria to protect
human and ecological health that apply to the approved glass form.
Further evaluations concluded that steam reforming and bulk
vitrification showed the most promise for performing comparably to
glass in immobilizing Hanford's low-activity tank waste.
Then, in 2003, DOE decided to proceed with development of bulk
vitrification at the Hanford Site because it believed the technology
would be less costly, able to be more rapidly demonstrated and
deployed, and more acceptable to state regulators than the other
options. After spending more than $100 million on the bulk
vitrification demonstration project, however, DOE officials have
suspended construction activities and elected not to pursue additional
funding for the project in fiscal year 2009. Throughout testing, bulk
vitrification had proved to be more costly and technically difficult to
develop than initially envisioned. Because DOE opted to proceed only
with testing and developing bulk vitrification for Hanford wastes,
other technologies--such as steam reforming or cast stone--have not
been extensively tested using actual Hanford waste. With the suspension
of bulk vitrification, DOE officials told us they currently have no
other supplemental technology development under way or planned for
treating a majority of Hanford's low-activity waste.
Since suspending bulk vitrification, DOE officials have said that the
department is planning for a second low-activity vitrification facility
to provide the additional capacity needed to complete treatment of
Hanford's low-activity waste within a realistic time frame.[Footnote
55] While DOE maintains the decision is not final, a second
vitrification facility will be the path forward for planning purposes.
For example, in 2008, DOE released an external review of its systems
planning for low-activity waste treatment at Hanford, which concluded
that a second low-activity waste vitrification facility was the most
viable option from a cost perspective for supplementing DOE's low-
activity waste treatment capability.[Footnote 56] In addition, the
report suggested that further demonstration of bulk vitrification
should be given a low priority while the department focuses its
attention on resolving other uncertainties with its strategy, such as
the total amount of waste to be processed.
On the basis of its 2008 report, DOE project officials told us in March
2009 that they are moving forward in their planning as if a second
vitrification facility were the selected technology and that the new
project baseline, due out by the end of the year, will include a second
low-activity vitrification plant as the supplemental treatment
approach. Despite these planning decisions, DOE maintains that a final
determination on its supplemental treatment approach will be made in
accordance with its project management orders and after issuance of the
environmental impact statement. In a December 2008 letter to Congress,
DOE indicated that a final decision on its supplemental treatment
approach will not likely be made until 2015 at the earliest.
[End of section]
Appendix III: Comments from the Department of Energy:
Department of Energy:
Washington, DC 20585:
September 18, 2009:
Mr. Gene Aloise:
Director of Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Aloise:
Thank you for the opportunity to review the draft report "Nuclear
Waste: Uncertainties and Questions about Costs and Risks Persist with
DOE's Tank Waste Cleanup Strategy at Hanford." Although we generally
agree with three of the four recommendations, we would like to provide
clarifications regarding key technical and legal uncertainties facing
the Tank Waste project at Hanford. In addition, we are concerned with
how the U.S. Government Accountability Office (GAO) has characterized
the Office of Environmental Management's (EM) progress at Hanford.
Specifically, we believe the report's findings should provide a better
supported, balanced and more accurate portrayal of EM's Tank Waste
Strategy at Hanford, in part by including descriptions of ongoing
initiatives and actions, a number of which EM launched in recognition
of the need for improvement. We are providing our concerns on the draft
report below and through technical comments, which include factual
corrections to certain information in GAO's draft report. We are
looking forward to reporting in the future on the progress being made
as we continue to focus on removing waste from tanks, finishing
construction of the Waste Treatment Plant (WTP), and initiating waste
treatment operations.
We believe that we have gained substantial experience over the past
decade in the cleanup of tank waste within the EM complex with the
vitrification of waste at Savannah River Site's (SRS) Defense Waste
Processing Facility, with the cleanup in New York State's West Valley
Demonstration Project and Oak Ridge, and from waste processing and tank
closures completed at Idaho National Laboratory (INL). This experience
is applicable to our challenges at Hanford and informs our technical
and project management approach. In 2009, one of our key initiatives is
an Integrated Project Team specifically to evaluate current and
emerging tank waste strategies for Hanford and SRS, to take advantage
of best practices and lessons learned, and to provide recommendations
on which strategies to pursue to reduce technical risks and
uncertainties. This is one example of information we believe is
critically important to the concerns raised and the characterization of
this program by the GAO, but absent from the draft report.
We agree that some technical uncertainties remain; however, we believe
that we have developed a systematic approach to evaluate alternative
strategies and transformational solutions that will continue to improve
and optimize the tank waste operations and help us realize life-cycle
cost reductions. We believe that the processes we have put in place
Printed with soy ink on recycled paper to reduce technical
uncertainties will result in the resolution of the issues in a timely
manner. We have gained a great deal of experience in tank waste
characterization, retrieval, treatment, and immobilization from the
cleanup efforts at other sites and believe that this experience will
also help to reduce uncertainties at Hanford. Tank closure and waste
processing successes have been realized at Department of Energy (DOE)
facilities at West Valley, SRS, Oak Ridge, and INL. At West Valley, for
instance, 628 tons of glass in 275 canisters were produced,
immobilizing 8,640 cubic feet of high-level waste. Since 1996, SRS has
vitrified over 2.6 million gallons of sludge waste, and since 2008 has
vitrified about 2.9 million gallons of high-level waste producing over
2,700 canisters of high-level waste that arc in two onsite storage
facilities. At Oak Ridge 8 tanks with a capacity of 90,000 gallons were
cleaned and grouted, and at INL 11 high-level waste tanks with a
capacity of 2.2 million gallons were grouted and closed. The River
Protection Project (RPP) takes advantage of that experience in many
ways; e.g., through lessons learned, technical exchanges, contracting
and through interaction of contractor and Federal staff that have been
involved in operations at these sites. Highlights of these exchanges
included updated approaches to high-level waste tank integrity, new
approaches to tank chemistry, and aluminum and chromium mitigation.
The report should be revised to reflect that the Secretary of Energy is
planning on convening a Blue Ribbon Panel to evaluate the options for
high-level waste disposal, and the Panel will provide DOE
recommendations to resolve this issue. In the meantime, EM has already
built two interim storage facilities at SRS and one at Hanford
(Canister Storage Building). Therefore, we are confident that we are
fully able to build interim storage facilities at Hanford if necessary
and will be able to calculate life-cycle costs for this operation at
Hanford, if it is needed. We believe it is premature to anticipate
these costs until after the Blue Ribbon Panel completes its work.
DOE agrees that it is important to assess the impacts on human health
and the environment for the range of possible cleanup strategies with
regard to the Hanford tanks. To that end, the Department is nearing
completion of a draft Environmental Impact Statement (EIS) which
rigorously evaluates 11 alternatives for accomplishing cleanup of the
tanks ranging from no action to complete removal of the tanks. The
Office of River Protection provided the GAO access to review the draft
EIS.
While DOE has assessed the costs and risks of its actions at Hanford,
it is important to recognize that the Department has limited discretion
when it comes to decisions on how to proceed with cleanup. Pursuant to
Federal law, DOE must comply with state requirements for control of
hazardous waste (such as the chemical constituents of the tanks at
Hanford) "in the same manner and to the same extent as any person is
subject to such requirements" (42. U.S.C. section 6961). The pertinent
Washington State regulatory framework requires the use of best
available technology. Hanford's Tri-Party Agreement thus requires
removal of 99 percent of waste from the tanks using available
technologies.
Likewise, the regulatory framework established by Congress in Section
31 16 of Public Law 108-375 (if it were applicable to Hanford) would
require a technology-based approach where highly radioactive
radionuclides are removed from the tanks to the maximum extent
practical.
DOE agrees that it is important to develop credible and complete life-
cycle cost and schedule estimates, and we have done this. We believe
that our estimates represent our most current and best understanding of
the actions necessary to meet regulatory commitments and to complete
tank waste cleanup at Hanford. The Tank Farms Project (TFP) life-cycle
cost estimate range is between $44 and $62 Billion (B). The Office of
Engineering and Construction Management (OECM) verified the
reasonableness of that range. An External Independent Review of the TFP
was performed as required in DOE Order 413.3A prior to validation of
the near-term baseline. The WTP total estimated contract price is
$11.07B, including incentives and award fee; $12.26B when DOE
contingency and other DOE project costs are included. This cost was
reviewed by the U.S. Army Corps of Engineers, validated by OECM, and
approved by the Deputy Secretary of Energy in late 2006. The RPP, which
includes TFP and WTP, total cost range is $56B to $74B as provided
during the factual accuracy review with your staff. GAO, instead, chose
to use a point estimate of their own construct.
EM utilizes strategic planning in developing its overall approach to
high-level waste treatment at Hanford, and other sites where such waste
was created, to reduce life-cycle costs. This effort includes ongoing
evaluations to identify opportunities for cost and schedule improvement
and risk reduction, and the use of External Technical Reviews and
Technology Readiness Assessments to focus attention on resolving
technical uncertainties and ensuring that technology risks are properly
managed. EM focuses its Technology Development and Demonstration (TDD)
efforts to identify and develop promising technologies for use in
further reducing baseline costs and schedule durations, and has
requested more than a three-fold increase in TDD funding in fiscal year
(FY) 2010.
The draft GAO report should provide a better context for its analysis
of the challenges at Hanford. The GAO's conclusion in 2001 (GAO-01-284,
Nuclear Cleanup: Progress Made at Rocky Flats, but Closure by 2006 Is
Unlikely, and Costs May Increase) stated that "Kaiser-Hill and DOE are
unlikely to meet the December 2006 target closure date" for Rocky
Flats, and yet this closure date was indeed met by DOE and the Rocky
Flats cleanup contractor Kaiser-Hill. The Rocky Flats cleanup was
completed nearly 50 years earlier and for $20.513 less than original
estimates. As recommended by the GAO in 2006 (GAO-06-352, Nuclear
Cleanup of Rocky Flats: DOE Can Use Lessons Learned to Improve
Oversight of Other Sites' Cleanup Activities), EM used the lessons
learned from Rocky Flats for other cleanup efforts across the complex
to accomplish extremely successful cleanups. We won the Project
Management Institute award for our prowess in project management in
2006 and 2007 for the Rocky Flats and Fernald cleanup projects,
respectively.
The draft GAO report does not recognize existing DOE risk management
efforts. The report states that DOE has not applied risk-informed
decision making to its tank waste cleanup strategy. While there is a
limited discussion of the Tri-Party Agreement and draft ETS, there are
gaps in addressing the overall RPP risk management. Uncertainties noted
in the report are in the RPP risk management plan and risk mitigation
actions, and contingencies are included in the life-cycle baseline, yet
GAO fails to mention this.
In addition, the Tri-Party Agreement does include provisions for
mitigation of programmatic risk; Appendix H is in place to provide a
means to set, evaluate, and revise criteria for determining the
allowable residual waste following waste retrieval operations on the
Hanford single shell tanks (SST). The process allows reassessment of
the retrieval goals based upon the tank farm retrieval experience. A
Performance Assessment for each SST waste management area will be
performed. This process includes a risk-based analysis. Finally, the
draft EIS provides a cumulative risk analysis of the overall process.
As new technological improvements are developed, we are committed to
continuously assess the strategies and operations of the WTP to ensure
that it is protective of human and ecological health and that it is
operated cost effectively and efficiently.
Although we agree with the finding that "Some Opportunities May Exist
to Reduce Costs of DOE's Hanford Tank Waste Cleanup Strategy," it may
be premature to state that "Allowing More Residual Waste to Remain in
Selected Tanks at Closing Could Help Reduce Costs without Adding Risks
to Human and Ecological Health." We need to complete the analysis for
the tank closure demonstration project in collaboration with Washington
State and the U.S. Environmental Protection Agency and to work with the
regulators to determine what will be acceptable.
With the August 11, 2009, announcement by Secretary of Energy Chu,
Washington State Governor Gregoire, Oregon State Governor Kulongoski,
U.S. Senators Murray and Cantwell, and Acting Assistant Attorney
General Cruden, we have a proposed legal settlement for Hanford (still
subject to a public comment period). Under the agreement, DOE will
prepare a life-cycle analysis of all Hanford cleanup costs to meet the
legally mandated timelines for cleanup. We are also committed to an
"End Date Review Process" that will ensure that the Hanford tank waste
cleanup remains as aggressive as possible. In addition, DOE is
committed to publishing an upcoming draft EIS that fully examines the
costs and consequences of a wide range of cleanup options.
The draft GAO report does not acknowledge the work that DOE has been
doing on the RPP. It does not reflect the successful tank waste
treatments that DOE has completed nationwide, which have advanced the
RPP tank waste cleanup efforts. Furthermore, the report does not
adequately acknowledge the environmental risk reduction activities that
DOE has performed. Removal of the pumpable liquids from SSTs to achieve
Interim Stabilization was conducted from late 1970 until 2005. In
addition, DOE has removed 140 million curies from Hanford's tanks in
the form of cesium and strontium capsules.
We generally agree with GAO's recommendation one, two and four. We
believe that we have a process for developing credible and complete
life-cycle cost and will continue to update the costs on an annual
basis. We already have a risk assessment framework for Hanford and will
be publishing the draft EIS in FY 2010. We continue to work closely
with the States of Washington and Oregon, the Tribal nations, the
Environmental Protection Agency, the Defense Nuclear Facility Safety
Board, the Hanford Advisory Board, and other stakeholders to complete
Hanford's cleanup.
DOE does not agree with GAO's third recommendation. At this time, we do
not believe that we need to seek clarification from Congress about the
Department's authority at Hanford to determine whether some waste now
managed by DOE as high-level waste can be treated and disposed of as a
waste type other than high-level waste. Our focus for the next ten
years is to remove waste from tanks, finish construction of the WTP,
and initiate waste treatment operations.
Again, thank you for your assistance as we seek to strengthen our tank
waste cleanup strategy at Hanford. We welcome direct dialogue with you
on these issues prior to finalizing your report. We would also
appreciate you including the enclosed comments in the final report. if
you have any questions with regard to these comments, please contact me
at (202) 586-7709 or Mr. Mark Gilbertson at (202) 586-0755.
Sincerely,
Ines R. Triay:
Assistant Secretary for Environmental Management:
Enclosure:
cc:
D. Chung, EM-2:
J. Owendoff, EM-3:
F. Marcinowski, EM-l0:
M. Sykes, EM-30:
S. Olinger, ORP:
[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 E. Frisch, Assistant
Director; Ellen W. Chu; Doreen Eng; George W. Hinman; Richard P.
Johnson; Karen Keegan; Nancy Kintner-Meyer; Mike Meleady; Mehrzad
Nadji; Joshua Ormond; Thomas C. Perry; Timothy M. Persons; Jena
Sinkfield; and John Smale made key contributions to this report.
[End of section]
Related GAO Products:
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.
Hanford Waste Treatment Plant: Department of Energy Needs to Strengthen
Controls over Contractor Payments and Project Assets. [hyperlink,
http://www.gao.gov/products/GAO-07-888]. Washington, D.C.: July 20,
2007.
Nuclear Waste: DOE Should Reassess Whether the Bulk Vitrification
Demonstration Project at Its Hanford Site Is Still Needed to Treat
Radioactive Waste. [hyperlink, http://www.gao.gov/products/GAO-07-762].
Washington, D.C.: June 12, 2007.
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.:
April 6, 2006.
Nuclear Waste: Absence of Key Management Reforms on Hanford's Cleanup
Project Adds to Challenges of Achieving Cost and Schedule Goals.
[hyperlink, http://www.gao.gov/products/GAO-04-611]. Washington, D.C.:
June 9, 2004.
Nuclear Waste: Challenges to Achieving Potential Savings in DOE's High-
Level Waste Cleanup Program. [hyperlink,
http://www.gao.gov/products/GAO-03-593]. Washington, D.C.: June 17,
2003.
Nuclear Waste: Department of Energy's Hanford Tank Waste Project--
Schedule, Cost, and Management Issues. [hyperlink,
http://www.gao.gov/products/GAO-RCED-99-13]. Washington, D.C.: October
8, 1998.
Nuclear Waste: Management and Technical Problems Continue to Delay
Characterizing Hanford's Tank Waste. [hyperlink,
http://www.gao.gov/products/GAO-RCED-96-56]. Washington, D.C.: January
26, 1996.
Nuclear Waste: Further Improvement Needed in the Hanford Tank Farm
Maintenance Program. [hyperlink,
http://www.gao.gov/products/GAO/RCED-95-29]. Washington, D.C.: November
8, 1994.
Nuclear Waste: Hanford Tank Waste Program Needs Cost, Schedule, and
Management Changes. vGAO/RCED-93-99. Washington, D.C.: March 8, 1993.
Nuclear Waste: Hanford Single-Shell Tank Leaks Greater Than Estimated.
[hyperlink, http://www.gao.gov/products/GAO/RCED-91-177]. Washington,
D.C.: August 5, 1991.
Nuclear Waste: Problems and Delays with Characterizing Hanford's Single-
Shell Tank Waste. [hyperlink,
http://www.gao.gov/products/GAO/RCED-91-118]. Washington, D.C.: April
23, 1991.
Nuclear Energy: Consequences of Explosion of Hanford's Single-Shell
Tanks Are Understated. [hyperlink,
http://www.gao.gov/products/GAO/RCED-91-34]. Washington, D.C.: October
10, 1990.
Nuclear Waste: Program to Prepare High-Level Radioactive Waste for
Final Disposal. [hyperlink,
http://www.gao.gov/products/GAO/RCED-90-46FS]. Washington, D.C.:
November 9, 1989.
Nuclear Waste: DOE's Management of Single-Shell Tanks at Hanford,
Washington. [hyperlink, http://www.gao.gov/products/GAO/RCED-89-157].
Washington, D.C.: July 18, 1989.
[End of section]
Footnotes:
[1] DOE has managed the Hanford Site since 1977. Before then, the site
was managed by the U.S. Army Corps of Engineers (1943-47), the Atomic
Energy Commission (1947-75), and the Energy Research and Development
Administration (1975-77).
[2] Unless otherwise specified, all cost numbers come from DOE and are
reported in current dollars.
[3] 42 U.S.C. 9601 et seq. (CERCLA); 42 U.S.C. 6901 et seq. (RCRA).
[4] Since 2007, DOE has been renegotiating Tri-Party Agreement
milestones that it has missed or believes it will miss, such as the
starting date of waste treatment operations. In 2008, the state of
Washington filed suit against DOE, claiming DOE violated the Tri-Party
Agreement by missing enforceable milestones, including tank retrieval
and treatment milestones. On August 10, 2009, DOE and the state
announced they had reached a tentative settlement, including agreement
on new cleanup milestones. A 2047 completion date was agreed to by DOE
and its regulators in the tentative settlement.
[5] Sixteen of Hanford's 149 single-shell tanks are much smaller, with
a storage capacity of 55,000 gallons.
[6] The total volume of waste in all of Hanford's underground tanks
fluctuates over time as DOE carries out its tank waste cleanup process.
[7] Hanford's underground storage tanks were not designed with specific
waste retrieval features. Waste must be retrieved through openings,
called risers, in the top of the tanks. Technicians must therefore
insert specially designed pumps into the tanks to pump the waste up
about 45 to 60 feet to ground level. Removing waste from the tanks that
have already leaked without releasing still more material into the soil
also poses a challenge, which DOE is trying to address with new
retrieval technologies.
[8] GAO, Nuclear Waste: Challenges to Achieving Potential Savings in
DOE's High-Level Waste Cleanup Program, [hyperlink,
http://www.gao.gov/products/GAO-03-593] (Washington, D.C.: June 17,
2003).
[9] B Plant was originally used to recover plutonium for nuclear
weapons. In the early 1960s, it was refurbished and used to remove
certain high-level radioactive materials from the tank wastes.
[10] Under its privatization approach, DOE planned to set a fixed price
and pay the contractor for canisters and containers of immobilized tank
waste that complied with contract specifications. If costs grew as a
result of contractor performance problems, the contractor, not DOE, was
to bear these cost increases. Any cost growth occurring as a result of
changes directed by DOE was to result in an adjustment to the contract
price and was to be borne by DOE.
[11] DOE estimates that additional liquid introduced into the tanks may
amount to three or four times the volume of waste in the tanks, or 176
million gallons for single-shell tanks. DOE does not have an estimate
of the additional liquid that will be added to the double-shell tanks
during retrieval.
[12] DOE is limited in the amount of waste it can retrieve from single-
shell tanks, in part because of limited storage capacity in the double-
shell tanks. Although the double-shell tanks have an estimated capacity
of slightly over 32 million gallons, as of June 2009 (the latest data
available), they already contained nearly 26 million gallons of waste.
[13] Department of Energy, External Technical Review of System Planning
for Low-Activity Waste Treatment at Hanford (Washington, D.C., November
2008).
[14] The pretreatment engineering platform also partially addresses a
recommendation we made in 2003 to pilot-test pretreatment technologies
before full-scale operation. See [hyperlink,
http://www.gao.gov/products/GAO-03-593].
[15] Congress approved the Yucca Mountain site in 2002. Pub. L. No. 107-
200, 116 Stat. 735 (2002).
[16] DOE's budget justification noted that the administration intends
to convene a panel of experts to evaluate alternative approaches for
meeting the federal responsibility to manage and ultimately dispose of
spent nuclear fuel and high-level radioactive waste from both
commercial and defense activities. The panel is to provide
recommendations that will form the basis for working with Congress to
revise the statutory framework for managing and disposing of spent
nuclear fuel and high-level radioactive waste.
[17] The term transuranic generally applies to wastes containing
radionuclides (radioactive elements) with atomic numbers higher than 92
(uranium's atomic number) and half-lives longer than 20 years in
concentrations exceeding 100 nanocuries (a measure of radioactivity)
per gram.
[18] DOE's transuranic wastes are destined for transfer to and final
disposal at the Waste Isolation Pilot Plant, a geologic repository in
Carlsbad, New Mexico.
[19] Natural Resources Defense Council v. Abraham, 271 F.Supp.2d 1260
(D.Idaho 2003), vacated as unripe 388 F.3d 701 (9th Cir. 2004).
[20] Pub. L. No. 108-375, Div. C, Title XXXI, § 3116, 118 Stat. 2162
(2004).
[21] Unless otherwise specified, all cost numbers come from DOE and are
reported in current dollars.
[22] Our report on best practices for estimating project costs
highlights the need for credible cost estimates as a critical function
in managing agency projects. 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.: March 2009).
[23] The original $4.3 billion was to construct and operate a
demonstration waste treatment plant with initial capacity to vitrify 10
percent by mass of the waste and 25 percent of the radioactivity by
2018. The $12.3 billion is to construct a plant with increased capacity
to vitrify all the high-level waste and about half the low-activity
waste.
[24] GAO, Department of Energy: Major Construction Projects Need a
Consistent Approach for Assessing Technology Readiness to Help Avoid
Cost Increases and Delays, [hyperlink,
http://www.gao.gov/products/GAO-07-336] (Washington, D.C.: Mar. 27,
2007).
[25] This figure reflects estimated costs from fiscal year 2007 to
2032. If DOE had included available actual costs from fiscal year 1997
through fiscal year 2006, this estimate would come to about $26
billion.
[26] These dollar amounts reflect actual costs from 1997 through 2007
and future costs from 2008 through 2045. Complete cost information
before 1997 was not available from DOE.
[27] Both the $700 million and $18 billion figures are "unfunded
contingency" estimates, which represent additional funds that may be
needed for potential future problems.
[28] Department of Energy, Technical Studies Plan for Assessing
Alternative Sodium Management Strategies for the River Protection
Project, DOE/ORP-2009-01 (Richland, Wash., January 2009).
[29] This $1.2 billion estimate includes costs of both tank farm and
waste treatment plant activities beginning in 2019.
[30] 42 U.S.C. § 4332(2)(C).
[31] National Research Council, Risk Assessment in the Federal
Government: Managing the Process (Washington, D.C.: National Academy
Press, 1983).
[32] Department of Energy and Washington State Department of Ecology,
Final Environmental Impact Statement for the Tank Waste Remediation
System, Hanford Site, Richland, Washington, DOE/EIS-0189 (Richland,
Wash., August 1996).
[33] 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).
[34] Department of Energy, A Review of the Environmental Management
Program (Washington, D.C., Feb. 4, 2002).
[35] National Research Council, Risk and Decisions about Disposition of
Transuranic and High-Level Radioactive Wastes (Washington, D.C.:
National Academies Press, 2005), and list of references therein.
[36] Department of Energy, Tank Closure and Waste Management
Environmental Impact Statement for the Hanford Site, Richland,
Washington, forthcoming.
[37] National Research Council, Science and Decisions: Advancing Risk
Assessment (Washington, D.C.: National Academies Press, 2008).
[38] This document considers tank waste cleanup and closure in
combination with two other major cleanup-related activities:
decommissioning of the Fast Flux Test Facility (a nuclear research
reactor that operated at Hanford from 1982 to 1992) and waste
management and disposal on the Hanford Site.
[39] DOE had originally intended to issue a public draft of the
environmental impact statement in spring 2007. After delays, DOE
officials told us in May 2009 that the document would be issued by the
end of June 2009. As of July 2009, DOE had again delayed the
statement's release until revisions could be made analyzing the effects
of the uncertainty regarding the ultimate repository site for DOE's
high-level waste. DOE officials said they plan to issue the statement
for public review before the end of October 2009.
[40] The remaining canister contents consist of glass-forming material.
[41] Some of the experts we interviewed also had concerns about the
reliability of the ion exchange system that extracts the waste from the
highly radioactive element cesium-137. The ion exchange process was not
tested as part of the pretreatment engineering platform.
[42] [hyperlink, http://www.gao.gov/products/GAO-03-593].
[43] Under the Tri-Party Agreement, DOE is required to retrieve as much
tank waste as technically possible, with tank waste residues not to
exceed 360 cubic feet in the so-called "100" series of tanks, 30 cubic
feet in the "200" series tanks, or the limit of waste retrieval
technology capability, whichever is less. (Tri-Party Agreement Action
Plan, appendix D, milestone M-045-00.) These quantities represent 99
percent waste retrieval for each single-shell tank. If DOE believes
that waste retrieval to these levels is not possible for individual
tanks, DOE may request an exception.
[44] 40 C.F.R. 261.7(b)(1)(ii). A container is also considered empty if
no more than 0.3 percent by weight of the total capacity of the
container remains in the container or inner liner, if the container is
greater than 119 gallons in size. 40 C.F.R. 261.7(b)(1)(iii)(B).
[45] Retrieval costs per tank for each of the seven tanks retrieved
thus far have varied significantly, ranging from $143 million for a
large tank (530,000 to 1 million gallons) to less than $10 million per
tank for four of the smallest tanks (55,000 gallons).
[46] [hyperlink, http://www.gao.gov/products/GAO-08-793].
[47] These costs do not include costs to design and construct tank
waste retrieval structures and equipment.
[48] GAO, Nuclear Cleanup: Progress Made at Rocky Flats, but Closure by
2006 Is Unlikely, and Costs May Increase, GAO-01-284 (Washington, D.C.:
Feb. 28, 2001).
[49] [hyperlink, http://www.gao.gov/products/GAO-09-3SP].
[50] [hyperlink, http://www.gao.gov/products/GAO-09-3SP].
[51] Under Tri-Party Agreement milestone M-62-08, DOE was to submit by
June 30, 2006, a report comparing the performance of potential
supplemental technologies with that of a second low-activity waste
vitrification facility. In an August 2009 proposed legal settlement
with its regulators, DOE agreed to submit a report on potential
supplemental treatment technologies by 2014 only if the department
proposed to pursue a technology other than a second vitrification plant
for low-activity waste.
[52] Tri-Party Agreement, appendix D, milestones M-61 and M-62.
[53] "Record of Decision for the Tank Waste Remediation System, Hanford
Site, Richland, Washington," 62 Fed. Reg. 8693 (February 1997).
[54] In all, DOE compared about 10 available technical options for
treating Hanford's low-activity waste. Criteria used to rank them were
(a) waste treatment acceleration, (b) technology maturity, (c)
implementation flexibility, (d) ease of regulatory compliance, (e)
human health and safety risk reduction, (f) operational safety (worker
protection), (g) compatibility with the Tri-Party Agreement (milestone
schedules), and (h) waste retrieval acceleration.
[55] While the Tri-Party Agreement still includes a milestone for
completing treatment by 2028, both DOE and Washington State acknowledge
that DOE will not be able to achieve this goal, and the August 2009
tentative legal settlement sets a revised cleanup date of 2047. Even
with this extended treatment schedule, DOE believes that the low-
activity waste vitrification facility currently under construction will
lack the capacity to treat all the low-activity waste within this time
frame.
[56] Although the report acknowledged cast stone and steam reforming as
other potentially viable options, and noted that these options were
being evaluated within the environmental impact statement process, it
did not assess these options, focusing only on alternatives to increase
Hanford's vitrification capacity.
[End of section]
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