United States Government Accountability Office

GAO Report to the Chairman and Ranking 

Minority Member, Subcommittee on Energy 

and Water Development and Related 

Agencies, Committee on Appropriations, 

House of Representatives 

NUCLEAR WASTE

DOE’s Efforts to 

Protect the Columbia 

River from 

Contamination Could 

Be Further 

Strengthened 

August 2006 

 

GAO-06-1018 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

August 2006

NUCLEAR WASTE

DOE’s Efforts to Protect the Columbia 

River from Contamination Could Be 

Further Strengthened 

Highlights of GAO-06-1018, a report to 

Chairman and Ranking Minority Member, 

Subcommittee on Energy and Water 

Development and Related Agencies, 

Committee on Appropriations, House of 

Representatives 

DOE’s Hanford site in Washington 

State is one of the most

contaminated nuclear waste sites 

in North America. The Columbia

River flows through about 50 miles

of the site. Radioactive and 

hazardous contamination from 

decades of producing nuclear 

materials for the nation’s defense 

have migrated through the soil into 

the groundwater, which generally 

flows toward the river.

In November 2005, GAO reported

on the potential for the Hanford 

site to contaminate the Columbia

River. To address continuing 

concerns, GAO reviewed the status 

of DOE’s efforts to (1) understand

the risk to the Columbia River from 

Hanford site contamination and to

deploy effective technologies to

address contamination near the 

river and (2) strengthen the 

management of its river protection 

program. To assess DOE’s efforts, 

GAO reviewed numerous reports 

by DOE and others, and discussed 

the problem with federal and state 

regulators and DOE officials. 

What GAO Recommends

To increase the likelihood that 

DOE will effectively implement and 

sustain improvements in its 

program to protect the Columbia 

River from contamination, GAO

recommends that the Secretary of

Energy establish results-oriented 

performance measures and regular 

evaluations to gauge the 

improvements’ effectiveness. DOE

agreed with our recommendation. 

The Department of Energy (DOE) is actively assessing the risk to the 

Columbia River from Hanford site contamination and is addressing problems 

with deployed river protection technologies. While DOE has extensive 

knowledge of contaminants that are currently in the groundwater and river, 

DOE knows less about contamination in the soil below the surface, known 

as the “vadose zone.” Before proposing a cleanup approach, DOE has agreed 

with its regulators to take vadose zone samples in many of the contaminated 

areas of the site. DOE is also improving its computer simulation model that 

will predict future risk from the contamination, and deploying alternative 

technologies it believes will more effectively contain the contamination that 

may threaten the river. 

DOE has also begun to address concerns about its management of Columbia 

River protection efforts, particularly the lack of integration between 

groundwater and vadose zone activities. In March 2006, in response to 

congressional committee direction, DOE proposed a new initiative to better 

integrate its river protection activities. The initiative included consolidating 

most groundwater and vadose zone characterization work under a single 

project; better integrating vadose zone, groundwater, and surface cleanup 

decisions; and improving the coordination and control over computer 

models used to predict movement of contamination in future years. 

Initiating these management improvements is important, but it is equally 

important that they be implemented effectively, and past history gives some 

cause for concern. For example, one attempt by DOE to better integrate 

these activities was unsuccessful when key elements, such as putting all

activities under a single project manager, failed to continue after project and 

other changes occurred at the site. In past GAO work, we reported that highperforming organizations sustained improvement initiatives when key 

elements were in place, such as clear goals, results-oriented performance 

measures, and evaluation strategies. Although DOE is beginning to develop a 

management plan for its new initiative, DOE has yet to implement some key 

elements, such as results-oriented performance measures and evaluations to 

gauge the effectiveness of its improvements, which could also help sustain 

the benefits of the improvements over time.

Contamination of the Columbia River from DOE’s Hanford Site

Source: DOE.

www.gao.gov/cgi-bin/getrpt?GAO-06-1018.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Gene Aloise at 

(202) 512-3841 or aloisee@gao.gov. 
Contents 

Letter 1

Results in Brief 7

Background 9

DOE is Taking Steps to Better Understand Risks to the Columbia 

River from Hanford and Is Replacing Ineffective Technologies 

near the River 11 

DOE Has Begun To Address Management Weaknesses but Can 

Further Strengthen Its Management Plan 15 

Conclusions 21

Recommendation for Executive Action 22 

Agency Comments and Our Evaluation 22 

Appendix I Scope and Methodology 24 

Appendix II Comments from the Department of Energy 26 

Appendix III GAO Contact and Staff Acknowledgments 28

Figure 

Figure 1: Sources of Contamination of the Columbia River from

DOE’s Hanford Site 2 

Page i GAO-06-1018 Columbia River Protection
Abbreviations 

CERCLA Comprehensive Environmental Response, 

Compensation, and Liability Act 

DOE Department of Energy 

EPA Environmental Protection Agency 

PNNL Pacific Northwest National Laboratory 

RCRA Resource Conservation and Recovery Act 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page ii GAO-06-1018 Columbia River Protection
United States Government Accountability Office

Washington, DC 20548 

August 28, 2006 

The Honorable David L. Hobson 

Chairman 

The Honorable Peter J. Visclosky 

Ranking Minority Member 

Subcommittee on Energy and Water Development 

 and Related Agencies 

Committee on Appropriations 

House of Representatives 

The Department of Energy’s (DOE) Hanford site in southeastern 

Washington State is one of the most contaminated nuclear waste sites in 

North America. The site occupies 586 square miles upriver from the cities 

of Richland, Pasco, and Kennewick, with a combined regional population 

of over 200,000. During Hanford’s production era, beginning in 1943, nine 

nuclear reactors were built at the site to produce nuclear materials, 

especially plutonium, for the nation’s defense. The site was selected, in

part, because the Columbia River, the nation’s second largest river by 

volume, flows through almost 50 miles of it; the river water was used to 

cool nuclear reactors and support nuclear materials processing 

operations. During operations from 1943 to 1989, activity at the reactors 

and other facilities also generated large volumes of hazardous and 

radioactive waste. Some of this waste was deposited directly into the 

ground in trenches, injection wells, or other facilities designed to allow the 

waste to disperse into the soil; some was packaged into drums and other 

containers and buried; and some was stored in 177 large underground 

tanks. 

Over time, concern has developed about the impact of Hanford’s 

radioactive and hazardous waste moving through the groundwater toward 

the Columbia River. The river is a source of hydropower production, 

irrigation for agriculture, and drinking water for downstream 

communities, as well as a major route for migrating salmon. Besides the 

waste intentionally discharged directly into the ground during the time of 

reactor operations, DOE has assumed, based on monitoring data and other 

techniques used to detect contamination, that 67 of the underground 

tanks, some burial grounds, and other waste disposal areas have also 

leaked contamination into the soil. Contamination could also result from 

accidental spills during ongoing cleanup activities. Much of this hazardous 

and radioactive waste can be borne by water through the soil into the 

Page 1 GAO-06-1018 Columbia River Protection
groundwater. While Hanford is a near-desert location with limited rainfall 

and, in many areas, thick layers of soil and rock above the groundwater, 

water from precipitation and other sources moves through these layers 

into the groundwater. The groundwater moves in the general direction of

the river. In the center of the site the groundwater is more than 200 feet 

below the surface, but at the river the groundwater is at or near the river 

level. As figure 1 illustrates, the movement of this contaminated liquid 

through the “vadose zone”—the span of soil and rock between the surface 

and the groundwater beneath—can result in contamination “plumes” 

extending downward and outward from their sources. When these 

contamination plumes reach the groundwater, the contamination they 

contain enters the groundwater and begins flowing toward the river. 

Figure 1: Sources of Contamination of the Columbia River from DOE’s Hanford Site 

Source: DOE.

The extent to which contamination from the Hanford site has threatened,

or will threaten, the Columbia River, is not fully understood. While some 

contamination has already reached the river, DOE has found that it is 

barely detectable because the high volume of water dilutes it. DOE 

routinely monitors the river’s water quality, which currently meets federal 

drinking water standards at sampling locations immediately down river 

from the Hanford site. However, studies also show that contamination has 

been found in some river life, including clams found near the shore. In 

addition, the rate at which contamination in the vadose zone and 

Page 2 GAO-06-1018 Columbia River Protection
groundwater may migrate to the river in future years is uncertain, and 

depends on the effectiveness of site cleanup activities. However, migrating 

contamination may continue to enter the river in the foreseeable future. 

Since the early 1990s, DOE has shifted its efforts at the Hanford site from 

production of nuclear materials to cleaning up the contamination and 

other materials left over from the production era. DOE carries out its 

cleanup activities primarily under the requirements of two environmental 

laws: (1) the Comprehensive Environmental Response, Compensation, and 

Liability Act of 1980, as amended (CERCLA); and (2) the Resource 

Conservation and Recovery Act of 1976, as amended (RCRA). Milestones 

for completing each step of the cleanup process are specified in a legally 

binding agreement (commonly known as the Tri-Party Agreement) 

between DOE and its regulators—the U.S. Environmental Protection 

Agency (EPA) and the Washington State Department of Ecology.1

 Under 

the Tri-Party Agreement, DOE must complete remediation of most of the 

site’s soil and groundwater by September 2024. DOE’s goal is to complete 

all cleanup work at the Hanford site by 2035. 

The Tri-Party Agreement incorporates the requirements of federal 

environmental laws and guides the process under which DOE will analyze 

the contamination and consider remedies, which DOE’s regulators must 

approve.2

 First, DOE must conduct a remedial investigation, in which it 

carries out field sampling and laboratory analyses to determine the nature

and extent of contamination. DOE is then required to conduct a feasibility 

study to develop and screen an initial list of remedial alternatives. After 

obtaining additional data, as necessary, DOE must analyze various 

remedial alternatives and select a preferred remedy. The determination of 

the preferred remedy is to be based on, among other things, whether a 

remedial alternative protects human health and the environment, as well 

as whether it attains cleanup standards that are legally applicable or 

otherwise relevant and appropriate, including state laws. For example, 

DOE and its regulators have determined that the Safe Drinking Water Act3

 1

Formally titled the Hanford Federal Facility Agreement and Consent Order, it was signed 

in May 1989 and has been amended numerous times since then. 

2

Some Hanford cleanup activities are conducted under the requirements of CERCLA, while 

others are conducted under RCRA. Though the terminology used to describe cleanup 

requirements under the two laws differs, the processes generally are functionally 

equivalent. In this report we use the terminology of the CERCLA program.

3

42 U.S.C. §§ 300f — 300j-26. 

Page 3 GAO-06-1018 Columbia River Protection
provides standards for many of the contaminants in the soil and 

groundwater at Hanford. In addition, DOE must consider seven other 

criteria in selecting a remedial approach, including the cost effectiveness 

of the remedy, its long-term protectiveness of human health and the 

environment, and community acceptance. Currently, DOE is required by 

the Tri-Party Agreement to meet a deadline of December 2008 to select 

preferred remedial alternatives for 57 separate waste management areas of 

the site—known as operable units.4

After DOE selects a preferred remedial alternative, the lead regulatory 

agency—either EPA or the state of Washington—prepares a Record of 

Decision5

 that selects the final remedy. A Record of Decision generally 

describes, among other things, (1) the key contaminants present in the 

specific waste management area, (2) the contamination limits DOE must 

achieve for each key contaminant, (3) the time frame in which the cleanup 

goals will be achieved, and (4) the technologies to be used to address the 

contamination. In general, if contaminants remain at the site as part of the 

final remedy, DOE and its regulators are required to review the remedial 

action every 5 years to determine whether the selected treatment 

technology is effective in protecting human health and the environment. 

DOE’s cleanup program at the Hanford site is aimed, in part, at protecting 

the Columbia River from contamination, now and in the future. Many of 

the river protection activities treat contamination before it enters the 

vadose zone or groundwater, and we have reported on several of these 

activities.6

 Regarding DOE’s efforts to address contamination in the vadose 

 4

The Hanford site is divided into 57 different operable units. These operable units are 

divided into source operable units—covering areas such as contamination in buildings,

soils, and burial grounds—and groundwater operable units. Forty-seven source operable 

units address contamination in the soils and vadose zone, and ten groundwater operable

units address contamination in the groundwater. As of July 2006, field investigations for 

one groundwater operable unit had been completed. 

5

Under CERCLA, DOE must prepare a Record of Decision. Under RCRA, DOE prepares a 

Corrective Measures Study. For either, DOE generally provides the same information about

extent and nature of contaminants, and proposed remedies. 

6

See, for example, GAO, Hanford Waste Treatment Plant: Contractor and DOE 

Management Problems Have Led to Higher Costs, Construction Delays, and Safety

Concerns, GAO-06-602T (Washington, D.C.: Apr. 6, 2006); GAO, Nuclear Waste: Absence of

Key Management Reforms on Hanford’s Cleanup Project Adds to Challenges of Achieving

Cost and Schedule Goals, GAO-04-611 (Washington, D.C.: June 9, 2004); GAO, Nuclear 

Waste: Challenges to Achieving Potential Savings in DOE’s High-Level Waste Cleanup

Program, GAO-03-593 (Washington, D.C.: June 17, 2003).

Page 4 GAO-06-1018 Columbia River Protection
zone and groundwater, DOE has prioritized the work to first address 

threats from contaminated sites located near the river or requiring 

immediate action, and then address threats from contaminated sites that 

are farther away from the river’s edge. 

DOE’s effort to address contamination near the river include actively 

removing waste, old buildings, and contaminated soil to reduce 

contaminants that could migrate—known as the river corridor project—

and treating the groundwater to prevent contaminants from further 

migrating. DOE has three main approaches to treating the groundwater: 

• Pump-and-treat. With this approach, DOE uses wells to extract 

contaminated groundwater, treats the groundwater in above-ground 

facilities, and reinjects the treated water into the ground. Since 1995, DOE 

has operated five pump-and-treat systems to remove strontium-90, 

chromium, carbon tetrachloride, and uranium from the groundwater. Four 

of these are intended to address near-river contamination of strontium-90

and chromium. 

• Chemical treatment. This approach has been used in one instance. DOE 

uses a chemical barrier near the Columbia River to block chromium from

entering the river near major salmon breeding areas.7

 The barrier consists 

of a 750-yard series of wells through which DOE injected a chemical into 

the groundwater; the chemical reacts with the chromium to change it to a 

less hazardous and less mobile form. 

• Natural attenuation. This approach relies on subsurface processes such 

as dilution, adsorption, and chemical reactions with subsurface materials 

to reduce contaminant concentrations to acceptable levels. For example, a 

large uranium plume in the groundwater is entering the river about 4 miles 

above city drinking water intakes. In 1996, DOE and its regulators agreed 

to allow the plume to dissipate through natural attenuation. 

DOE’s efforts to address contamination threats that are farther from the 

river have involved four main types of actions: 

• Characterizing the vadose zone and groundwater through sampling and 

other studies to help understand the risks from movement of 

contamination. 

 7

Chromium is toxic to fish. 

Page 5 GAO-06-1018 Columbia River Protection
• Removing high-risk material from contaminated sites and/or covering the

surface of the disposal area with a barrier to prevent water intrusion. 

• Decommissioning (by removing or sealing) a portion of the 7,000 wells 

used to monitor groundwater and the vadose zone, and for other purposes, 

that are no longer needed. Monitoring wells are important, but they can 

also contribute to pollution by serving as conduits for rain, snow melt, or 

other liquids to flush contaminants through the vadose zone and into the 

groundwater. 

• Reducing water intrusion from leaking pipelines and surface drainage that

can drive contamination from the vadose zone to the groundwater. 

DOE also monitors groundwater conditions and uses information about 

the nature and extent of contamination in the groundwater—and its 

migration toward the river—to assess current and future risks to the 

public and the environment. While current levels of contamination can be

determined by sampling the river, soil, and groundwater, DOE uses 

computer models to predict how existing and future contamination from 

site cleanup and disposal activities will impact the river over the next 

1,000 to 10,000 years. 

In November 2005, we reported on the potential for Columbia River 

contamination from the Hanford site.8

 We discussed DOE’s understanding 

of the sources and extent of contamination that potentially threaten the 

river, and the mixed results that DOE’s efforts to address the 

contamination have achieved so far. In addition, we discussed past 

criticisms of DOE’s program management, including a poorly organized 

management structure and lack of coordination among various river 

protection activities. Because of continuing concerns about the risks 

posed by the contamination and DOE’s management of its river protection 

program, you asked us to review the status of DOE’s efforts. This report 

addresses DOE efforts (1) to understand the risk to the Columbia River 

from Hanford site contamination and to deploy effective technologies to

address contamination near the river, and (2) to strengthen the 

management of its efforts to protect the Columbia River from Hanford site 

contamination. 

 8

GAO, Department of Energy: Preliminary Information on the Potential for Columbia

River Contamination from the Hanford Site, GAO-06-77R (Washington, D.C.: Nov. 4,

2005). 

Page 6 GAO-06-1018 Columbia River Protection
To address these objectives, we reviewed key documents, including 

Hanford’s 2003 Groundwater Management Plan, the 2004 Hanford Site 

Groundwater Strategy, and reports from the National Academy of Sciences 

and the DOE Inspector General.9

 We visited various groundwater 

protection projects at the Hanford site and discussed river contamination 

issues with DOE and contractor officials at Hanford. We also discussed 

these issues with state and federal regulators, and other stakeholders. In 

reviewing the data related to the groundwater and river programs, we 

determined they were sufficiently reliable for the purposes of our report. A 

more detailed description of our scope and methodology is presented in 

appendix I. We conducted our work from December 2005 to August 2006 

in accordance with generally accepted government auditing standards. 

DOE has begun taking steps to better understand the risk to the Columbia 

River from Hanford site contamination, and to replace cleanup

technologies that have proven to be ineffective in keeping the 

contamination from seeping into the river. To better understand the nature 

and extent of the potential risk of contaminating the Columbia River, DOE 

and its regulators agreed to do additional sampling and analysis of the 

Hanford site’s vadose zone. While DOE and its contractors have extensive 

knowledge of the contaminants that are currently in the groundwater and 

in the river, DOE knows less about the extent and location of 

contaminants in the vadose zone above the groundwater. Understanding 

contamination in the vadose zone is important for making decisions about 

how best to protect the Columbia River from the contamination. To 

accomplish this additional investigative work, DOE has requested a 3-year 

delay—until 2011—to the regulatory milestone by which DOE must 

propose to regulators its plans for addressing the groundwater and vadose 

zone contamination on the Hanford site. Once DOE understands the 

nature and extent of contamination in the vadose zone and groundwater, it 

must assess the risk to the public in future years by estimating how, and 

where, the contamination will migrate over time. While DOE relies on 

sampling to determine current conditions, it uses computer simulation 

models to predict future conditions and estimate future risks. DOE 

abandoned past modeling efforts in response to criticism that the models 

Results in Brief 

 9

National Academy of Sciences, Science and Technology for Environmental Cleanup at

Hanford (Washington, D.C.: 2001); Office of Inspector General, Groundwater Remediation

Activities at Hanford, DOE/IG-0655, (Washington, D.C.: July 22, 2004); and Office of

Inspector General, Well Decommissioning Activities at the Hanford Site, DOE/IG-0670, 

(Washington, D.C.: Jan. 3, 2005). 

Page 7 GAO-06-1018 Columbia River Protection
used inconsistent assumptions, were based on data of questionable 

reliability and had weak quality control processes. DOE is beginning to 

develop a model it believes will be more reliable. DOE has also begun 

taking steps to replace ineffective treatment approaches in response to 

concerns raised by us and others, and after receiving congressional 

direction to make $10 million available in fiscal year 2006 to research new

treatment technologies at Hanford. These steps include replacing one 

pump-and-treat system, improving a leaking chemical barrier, and 

pursuing alternatives to allowing natural processes to control uranium 

migration. 

DOE has also begun to address management problems with its Columbia 

River protection efforts at the Hanford site. In March 2006, as a result of 

congressional direction to improve management of its river protection 

efforts, DOE proposed key steps intended to better coordinate and 

manage groundwater and vadose zone activities at the site. These steps 

included (1) consolidating most groundwater and vadose zone activities 

under a single project, (2) better coordinating decisions about 

groundwater cleanup with decisions about how to address vadose zone 

contamination, and (3) consolidating risk assessment and modeling efforts 

under one project. DOE has taken steps in the past to address similar 

management problems, but the initiative was not successfully 

implemented. For example, in response to our 1998 report calling for 

greater integration of river protection activities at the Hanford site,10 DOE 

took some initial steps to better coordinate its groundwater and vadose 

zone efforts. However, DOE did not implement key elements, such as 

developing a sitewide funding baseline of all river protection efforts; other 

elements, such as integrating groundwater and vadose zone activities 

under a single project manager, were initially implemented, but DOE did 

not continue them after changes in project organization and contract 

structuring occurred at the site. 

We previously reported11 that high-performing organizations sustained 

management improvement initiatives when they followed a systematic, 

 10GAO, Nuclear Waste: Understanding of Waste Migration at Hanford is Inadequate for

Key Decisions, GAO/RCED-98-80 (Washington, D.C.: March 13, 1998).

11See GAO, Contract Reform: DOE Has Made Progress, but Actions Needed to Ensure 

Initiatives Have Improved Results, GAO-02-798 (Washington, D.C.: Sept. 13, 2002); also, 

GAO, DOE Contracting: Improved Program Management Could Help Achieve Small 

Business Goal, GAO-06-501 (Washington, D.C.: April 7, 2006). 

Page 8 GAO-06-1018 Columbia River Protection
results-oriented strategy that included defining specific program 

objectives, developing performance measures to gauge progress, and using 

results-oriented outcomes to evaluate the effectiveness of the initiative. As

of July 2006, DOE had begun to determine the objectives of its new 

integration initiative, but had not yet fully developed other aspects of a 

sound management plan, including developing results-oriented 

performance measures to gauge effectiveness and evaluating the initiative

using those measures. Unless DOE takes these steps, we are concerned 

about its ability to sustain any improvements its new initiative may offer. 

The DOE Hanford Assistant Manager in charge of overseeing the new 

integration initiative said that the management plan for the initiative is still 

evolving and that future steps may include developing performance 

measures and evaluation strategies to gauge effectiveness. 

We are recommending that the Secretary of Energy strengthen its 

management improvement plan by establishing results-oriented 

performance measures and regular evaluations to gauge the program’s 

effectiveness and sustain benefits of the improvements over time. In 

commenting on a draft of this report, DOE agreed with our 

recommendation. 

Contamination from the Hanford site that may threaten the Columbia 

River includes (1) contamination that resulted from disposal activities 

during the era in which DOE produced nuclear material; (2) contamination 

that could occur during cleanup activities, such as from an accidental spill; 

and (3) possible future migration of contamination from waste that will be 

permanently disposed of on the Hanford site in accordance with the 

cleanup actions DOE and the regulators plan to use. 

Contamination from production era. Contamination at Hanford resulting 

from plutonium production (which occurred from 1943 to 1989) that is 

currently migrating to the river is primarily from:12 

Background 

 12In addition, during Hanford’s past operations, DOE and its predecessor agencies directly 

discharged to the river cooling water from the reactors which was contaminated with 

about 110 million curies of mostly short-lived radionuclides. (Radioactivity is measured in 

curies. One curie equals 37 billion atomic disintegrations per second.) Operations also 

resulted in air emissions of about 20 million curies from 1944 to 1972. The portion that 

went to the river is unknown. These discharges are no longer occurring. 

Page 9 GAO-06-1018 Columbia River Protection
• Intentional disposal of liquid waste and contaminated water into the 

ground (about 450 billion gallons). 

• Leaks into the soil from waste tanks and the pipelines that connect them 

(between 500,000 to 1 million gallons containing about 1,000,000 curies of 

radioactivity). 

• Contamination that has begun to migrate from solid waste (more than 

710,000 cubic meters) disposed of on-site in burial grounds, pits, and other

facilities. 

Chemical and radioactive contamination currently affects more than 180 

of the 586 square miles of the site’s groundwater and large areas of the 

vadose zone. While there are numerous contaminants now in the vadose 

zone and the groundwater below, DOE believes the key contaminants in 

the groundwater include hazardous chemicals (such as carbon

tetrachloride, chromium, nitrate, and trichloroethane) and radioactive

materials (such as iodine-129, strontium-90, technetium-99, tritium, and 

uranium). These contaminants are of concern because of their extent, 

their mobility in the groundwater, and the potential health risks associated 

with them—at sufficient levels, some of these contaminants are toxic to 

humans or fish, while others are potential carcinogens. 

Potential contamination from current activities. Current cleanup efforts 

at the Hanford site could contribute to contamination of the vadose zone 

and groundwater that eventually reaches the river. For example, some of 

the waste put into underground storage tanks as liquid has since turned 

into sludge or saltcake.13 To dissolve it, more water will have to be 

introduced into the tanks—including tanks known to have leaked. This 

process may cause additional discharges into the soil. 

Possible future contamination. Under DOE’s cleanup plans, and with 

regulator approval, a large amount of contaminants will remain on-site 

long into the future. This contamination may be in buildings, in mostly 

empty underground tanks, in covered burial grounds and waste disposal 

areas, and in approved disposal facilities. Contaminants may leach out of 

these facilities in the future and join existing contamination in the vadose 

zone and migrate to the groundwater, where they could migrate to the 

river. 

 13Saltcake is a moist sand-like material, such as sodium salts, that have crystallized from 

the waste. 

Page 10 GAO-06-1018 Columbia River Protection
Based on groundwater sampling results, DOE reports that plumes of 

contamination continue to move through the vadose zone and the 

groundwater, and are leaching into the river. DOE estimates that about 80 

square miles of groundwater under the site contains contaminants at, or 

above, federal drinking water standards.14 Because the groundwater and 

the river are at the same relative elevation, these plumes are leaching 

directly into about 10 of the nearly 50 miles of river shore on the site. 

DOE’s Office of Groundwater and Soil Remediation under the Assistant 

Secretary for Environmental Management sets overall policy and oversight 

for groundwater and soil remediation. At the Hanford site, both the 

Richland Operations Office and the Office of River Protection, as well as 

several contractors, are involved in groundwater and vadose zone 

activities. The monitoring of river and shoreline conditions, and 

groundwater sampling, is managed by the Pacific Northwest National 

Laboratory (PNNL). Analysis of the samples is performed by several 

approved laboratories. Funding for groundwater and vadose zone 

activities at the site is difficult to identify due to the large number of 

organizations and activities involved and the structure of DOE’s budget 

accounts. However, monitoring, characterization, well drilling and 

maintenance, remediation, and research activities received nearly $175 

million in fiscal year 2006. 

DOE is taking steps to better understand the risk to the Columbia River 

from Hanford site contamination and to replace ineffective cleanup 

technologies. Specifically, DOE is addressing problems with three main 

aspects of its Columbia River protection efforts. First, DOE and its 

regulators have agreed that additional investigation of contamination in 

the vadose zone is needed, although doing so could delay by about 3 years 

the date by which DOE will propose its cleanup plans to the regulators. 

Second, DOE is reworking its approach to modeling the future effects of 

contamination on river conditions. DOE abandoned past modeling efforts 

in response to criticism that the models used inconsistent assumptions, 

were based on data of questionable reliability, and had weak quality 

control processes. Third, in response to concerns about the effectiveness 

of some of the technologies DOE had deployed to remove or contain 

DOE is Taking Steps 

to Better Understand 

Risks to the Columbia 

River from Hanford 

and Is Replacing 

Ineffective 

Technologies near the 

River 

 14While the groundwater at Hanford is generally not used as a source for drinking water,

drinking water standards are still a common measure of the extent of contamination. EPA 

sets the maximum contaminant level for each contaminant allowed in water delivered to a 

user of any public water system. This is the federal standard for the contaminant. 

Page 11 GAO-06-1018 Columbia River Protection
contamination near the river, and with specific direction from Congress, 

DOE is evaluating alternative technologies that may be more effective at

addressing the contamination. 

While DOE has extensive knowledge of the contaminants in the river and 

groundwater, and the movement of contaminants in the groundwater and 

on or near the surface, DOE has only recently developed limited 

information about the extent and location of the contamination that has 

migrated from the surface areas into the vadose zone above the 

groundwater. Understanding the nature of vadose zone contamination is 

critical to determining the most appropriate steps to take to protect the 

river now, and in future years, because contaminants still in the soil may 

continue to migrate until they eventually reach the groundwater and the 

river. DOE has studied some portions of the vadose zone, such as around 

the underground storage tanks, where extensive contamination from leaks 

and spills occurred in the past. In doing so, DOE found that some 

contamination, including technetium-99, had migrated as far as the 

groundwater. DOE contractors were able to map the migration of some of 

these contaminants. However, DOE acknowledges that its understanding 

of contaminants in the vadose zone is limited in many areas of the site. For 

example, cribs and trenches near the underground tanks received large 

volumes of contaminated wastes that dispersed directly to the ground. 

DOE has little information on the extent and location of the contamination 

in those areas, according to DOE officials responsible for planning their 

cleanup. They also said that characterization of the lower portions of the 

vadose zone is difficult and expensive, and few remediation techniques 

have been developed or tested for removing or isolating wastes that are 

located deep in the vadose zone. 

Understanding the extent of vadose zone contamination is critical because

some contaminants still in the soil may continue to migrate until they 

eventually reach the groundwater and the river. Thus, understanding the 

type and volume of contaminants in the vadose zone and their rate of 

migration is essential to determining the most appropriate steps to take to

protect the river now, and in future years. 

After finding unexpected contaminant migration in the vadose zone at one 

waste disposal area known as BC cribs—a location where liquids were 

discharged directly into the ground—DOE agreed with its regulators that 

its understanding of the vadose zone was inadequate to support the 

development of a final cleanup remedy for that area and some others. 

Although DOE had originally planned to defer some of its study of the 

DOE Has Asked to Extend 

Regulatory Milestones to 

Better Understand the 

Extent and Location of the 

Contamination in Soil 

above the Groundwater 

Page 12 GAO-06-1018 Columbia River Protection
vadose zone until after December 2008, when draft cleanup plans were 

due, DOE now agrees that more sampling and analysis of the vadose zone

is needed to guide cleanup decisions. As a result, DOE has proposed to 

regulators to extend the date for submitting draft cleanup plans until 2011. 

DOE officials said this will allow the time needed to develop a better 

understanding of vadose zone conditions and to investigate potential 

remedies. 

In response to the discovery that its previous models to estimate the future

risks of the movement of contamination toward the river were based on 

data of questionable reliability, DOE has begun reworking these efforts. 

While DOE relies on sampling to determine current conditions, it uses 

computer simulation models to predict future conditions and estimate 

future risks. In 1998, DOE groundwater program officials said DOE 

concluded from its simulation models that the migration was slow enough 

that the contaminants included in the study would not exceed their limits 

for 1,000 years into the future. However, DOE was concerned about the 

completeness of the model and began an effort, known as the System 

Assessment Capability, to develop a more comprehensive model. This $16 

million, 8-year effort was cancelled when, in the course of a lawsuit over 

Hanford’s disposal plans,15 several quality assurance problems were found, 

including discrepancies in the data. DOE abandoned the past modeling 

efforts in response to criticisms that the models used inconsistent 

assumptions, were based on data of questionable reliability, and had weak 

quality control processes. In January 2006, DOE and Washington State 

settled the lawsuit. In the settlement agreement, DOE agreed to re-analyze

and update its study of the cleanup’s effect on groundwater. In addition, 

DOE agreed to consolidate two studies of the cleanup’s effects on 

groundwater into a single, integrated study. 

Both DOE and its regulators have determined that the results of all three

of DOE’s approaches to treating groundwater—pump-and-treat, chemical 

treatment, and natural attenuation—are not fully satisfactory. Specifically:

• Pump-and-treat. In a 2004 report, the DOE Inspector General concluded 

that the pump-and-treat system to remove strontium-90 was ineffective 

and that the other four pump-and-treat systems have had mixed results. 

DOE Is Reworking Efforts 

to Estimate Risks from the 

Movement of 

Contamination toward the 

River 

DOE Is Considering New 

Treatment Technologies to 

Replace Those That Have 

Not Kept Contamination 

from Entering the River 

 15Washington v. Bodman, Civ.A. No. 2:03-cv-05018-AAM (E.D. Wash. filed Mar. 4, 2003). 

Page 13 GAO-06-1018 Columbia River Protection
However, Hanford’s acting groundwater project manager told us that four

of the five pump-and-treat systems at the Hanford site meet the remedial 

objectives agreed to with Hanford’s regulators. The official acknowledged 

that the system to remove strontium-90 was largely ineffective and that 

DOE had been trying to obtain permission from the regulators to turn it 

off. Both DOE and the regulators told us that the regulators refused to 

allow the system to be turned off, however, until a more effective remedy

was found. In March 2006, after spending about $16 million since 1996 to

install and operate the system, DOE turned the system off with the 

regulators’ permission, and began testing a chemical barrier to prevent the 

strontium-90 from entering the river. 

• Chemical treatment. In 2004, DOE reported that, based on groundwater 

samples, the chemical barrier for chromium was not fully effective, and 

that the hazardous form of chromium was detected beyond the barrier and 

close to the river. DOE is currently testing alternative approaches to 

improve the barrier. 

• Natural attenuation. According to monitoring well data, DOE’s reliance 

on natural attenuation to dissipate a uranium plume near the city of 

Richland was ineffective and has not controlled the migration of uranium 

to the river. The plume has not dissipated in the 10-year period since the 

natural attenuation strategy was adopted. DOE is currently investigating

the plume, testing chemical barriers, and exploring other ways to mitigate 

the problem. 

In the conference report accompanying the fiscal year 2006 Energy and

Water Development Appropriations Act, the conferees directed DOE to 

make $10 million available to analyze and identify new technologies to 

address contaminant migration to the Columbia River.16 DOE convened a 

study group to identify potential technologies and determine how best to 

allocate the funds to support them. According to DOE’s groundwater 

project manager, if the technologies tested are successful, DOE will seek 

funds to expand the systems to fully address these problems. DOE is 

testing the following: 

• To address problems with pump-and-treat systems, DOE is testing new 

approaches to containing strontium-90 and chromium. To contain the 

strontium, DOE is testing two techniques: (1) using a chemical to bind the 

strontium to the soil until it decays, which would prevent it from leaching 

 16H.R. Rep. No. 109-275, at 172 (2005). 

Page 14 GAO-06-1018 Columbia River Protection
into the river; and (2) planting willow bushes near shore to capture the 

strontium in the plants, which can be harvested to dispose of the 

strontium. For chromium removal, DOE has adopted a “systems approach” 

which includes combining source removal, pump-and-treat system 

expansion, and barrier repairs according to DOE’s groundwater project 

manager. DOE is also planning to test an improvement to the pump-andtreat system. The test system will use an electric field to remove the 

chromium from the groundwater extracted by several of the existing wells. 

If it succeeds, DOE’s project manager said, they will expand the pumpand-treat system to include this technology. 

• To address problems with the chromium barrier near the river, DOE plans 

to inject chemicals through the wells used to create the barrier to help 

convert the chromium to a less toxic and less mobile form. 

• To address problems with using natural attenuation to dissipate the 

uranium plume near the city of Richland, DOE is testing whether injecting

a chemical called polyphosphate can help prevent the uranium from 

migrating to the river. 

In addition to these activities, DOE plans to research methods to better 

understand the existing carbon tetrachloride plume in the center of the 

site. 

DOE has begun to address management problems with its Columbia River 

protection efforts at the Hanford site by proposing management 

improvements to better oversee and coordinate its groundwater and 

vadose zone activities. Although those steps are important and needed, we 

are concerned about DOE’s ability to sustain any improvements made. 

Similar efforts in the past failed. In our previous work, we reported that 

leading organizations use a systematic, results-oriented plan to sustain 

management improvement initiatives. Such a plan incorporates key 

elements, such as clear goals, performance measures to gauge progress 

toward those goals, and an evaluation strategy to help ensure the initiative

is effective. Although DOE is beginning to develop a plan for its new 

integration initiative, it has yet to implement key elements, such as 

performance measures or an evaluation strategy. These tools could help

measure effectiveness and sustain the benefits of the initiative over time. 

DOE Has Begun To

Address Management 

Weaknesses but Can 

Further Strengthen Its 

Management Plan 

Page 15 GAO-06-1018 Columbia River Protection
DOE is beginning to address longstanding concerns about the 

management and oversight of its Columbia River protection efforts at the 

Hanford site. In November 2005, we reported that DOE’s river protection 

efforts continued to be fragmented among two DOE site operations offices 

and several site contractors.17 We raised concerns that the potential 

existed for duplication, gaps, and inefficiencies. Subsequently, in the 

November 2005 conference report accompanying the Fiscal Year 2006 

Energy and Water Development Appropriations Act,18 the conference 

committee cited these continuing management and organization problems 

and directed DOE to study how to better integrate its river protection 

efforts. In response to the congressional direction, in March 2006, DOE’s 

Assistant Secretary for Environmental Management developed a new plan

to better integrate Hanford’s river protection, vadose zone, and 

groundwater efforts. Specifically, DOE’s new integration initiative would:

DOE Is Taking Steps to 

Improve River Protection 

Management and 

Oversight 

• Consolidate most groundwater and vadose zone characterization

and cleanup activities under a single project. At the time of the 

congressional direction, two DOE offices and three main contractors onsite were collectively responsible for characterizing and cleaning up 

vadose zone and groundwater contamination.19 The Office of River 

Protection and its contractor, CH2M Hill Hanford Group, were responsible 

for characterizing and addressing contamination of the vadose zone in 

tank farms—areas where tanks containing radioactive liquid waste are 

buried. The Richland Operations Office and its contractors, Fluor Hanford 

and Washington Closure Hanford, were responsible for vadose zone 

characterization in the central plateau area of the site and along the river 

corridor, respectively. In addition, Fluor Hanford was responsible for 

groundwater activities in all areas of the site. Within Fluor Hanford, 

responsibility for cleanup of the groundwater and vadose zone was 

divided between two different projects with the project handling vadose 

zone issues also responsible for addressing removal of old buildings and 

burial grounds. 

 17GAO, Department of Energy: Preliminary Information on the Potential for Columbia

River Contamination from the Hanford Site, GAO-06-77R (Washington, D.C.: Nov. 4,

2005). 

18H.R. Rep. No. 109-275, at 172 (2005). 

19In addition, DOE’s PNNL was responsible for support activities, such as science and 

technology development and groundwater monitoring activities. 

Page 16 GAO-06-1018 Columbia River Protection
To better coordinate vadose zone and groundwater characterization and 

cleanup activities, DOE’s new integration initiative proposed consolidating 

most of this work under a single project managed and coordinated by 

Fluor Hanford. To do so, DOE planned to modify existing contracts with 

the affected contractors to reflect this reorganization. In June 2006, the 

Office of River Protection and the Richland Operations Office issued a 

Plan of Action for Hanford Groundwater and Vadose Zone Integration 

Improvements. It identified general activities and areas of responsibility 

that the Fluor Hanford and CH2M Hill Hanford Group contractors would 

be responsible for under the new initiative. As of the end of July 2006, 

DOE was negotiating the details of this reorganization of responsibilities 

with the contractors and anticipated having the contracts modified to 

reflect the changes by October 1, 2006. 

• Better integrate vadose zone, groundwater, and waste disposal site

cleanup decisions. DOE acknowledged that decisions about when and 

how to address vadose zone and groundwater contamination were not 

always well coordinated, and they generally were not coordinated with 

decisions about when and how to address the source contamination in a 

waste disposal site located above the vadose zone and groundwater. For 

example, initial plans for cleanup decisions of the surface areas in the 

Central Plateau were not necessarily linked to the plans for the underlying

groundwater units, according to DOE’s groundwater project manager. 

To better integrate vadose zone, groundwater, and waste disposal site 

cleanup decisions, DOE proposed to implement a new strategy by the end 

of fiscal year 2006 and to work with regulators to better align regulatory 

milestone dates for making cleanup decisions about waste sites, the 

vadose zone, and the groundwater. DOE’s new strategy includes plans to 

transfer most vadose zone characterization activities into the groundwater 

program. 

• Consolidate responsibility for modeling the movement of 

contaminants through the vadose zone and groundwater to 

estimate the potential current and future health risks. DOE has 

acknowledged that inconsistencies and reliability problems existed in the 

modeling of how contaminants move through the vadose zone and 

groundwater, and how the environmental risks associated with those 

contaminants were estimated. A DOE team reviewing the data quality 

issues and the modeling effort found that, in addition to issues of the 

reliability of data used in the models, various modeling efforts under way 

were based on different assumptions, and information about 

Page 17 GAO-06-1018 Columbia River Protection
contamination movement was not always correctly transferred to other 

models. 

To address these problems, DOE proposed to more closely coordinate 

modeling and risk assessment activities at the site and strengthen control 

over model design so that a common set of databases and assumptions 

were being used for decision making. The groundwater project would have 

configuration control over any models used so that any changes to 

databases and models assumptions would require approval by the 

groundwater project before users could implement them. 

In addition to these management improvement efforts at the Hanford site, 

in May 2006, DOE also established a new Office of Groundwater and Soil 

Remediation to improve headquarters’ oversight on issues dealing with 

soil and groundwater contamination across the DOE complex. The office 

is tasked with reviewing all soil and groundwater remedies at DOE sites, 

helping to develop technologies to solve groundwater and soil 

contamination problems at different DOE sites, and generally overseeing 

DOE policy and assessments regarding vadose zone and groundwater 

cleanup. 

Given past problems fully implementing and sustaining improvements to 

the management of DOE’s Columbia River protection efforts at the 

Hanford site, it is uncertain whether any improvements that result from 

DOE’s new integration initiative will be sustained. In 1998, we reported 

that DOE lacked a comprehensive and integrated groundwater and vadose 

zone program,20 and recommended that DOE implement an integrated 

strategy that defined measurable performance goals, clearly defined 

leadership roles, and established accountability for meeting those goals. 

In response to our 1998 report, DOE proposed an integrated management 

plan to coordinate groundwater and vadose zone work.21 To accomplish 

this, DOE assigned a single DOE Assistant Manager in the Richland 

DOE Has Not Fully 

Implemented a 

Management Plan to 

Ensure Improvements Will 

Be Sustained 

 20GAO, Nuclear Waste: Understanding of Waste Migration at Hanford is Inadequate for

Key Decisions, GAO/RCED-98-80 (Washington, D.C.: March 13, 1998).

21We have also previously reported about lack of integration among DOE river protection 

efforts. For example, in 1992, we reported that DOE lacked coordination in its efforts to

monitor and characterize contamination in the vadose zone. See GAO, Nuclear Waste:

Improvements Needed in Monitoring Contaminants in Hanford Soils, GAO/RCED-92-149 

(Washington, D.C.: July 6, 1992). 

Page 18 GAO-06-1018 Columbia River Protection
Operations Office to coordinate all groundwater and vadose zone work at 

the Hanford site. Because DOE’s other site office, the Office of River 

Protection, and several contractors at the site also carried out 

groundwater and vadose zone cleanup, DOE made the Assistant Manager 

responsible for ensuring that all groundwater and vadose zone activities 

were integrated into a single planning effort. This “Integration Project” 

included developing a sitewide approach to project planning, funding, and 

information management, and co-locating contractor staff working on the 

project to improve coordination. In addition, the project included 

improving coordination of efforts to develop science and technology to 

address contamination in the vadose zone and groundwater. 

Despite these proposed changes, DOE was unable to effectively implement 

the improvements it planned to make. For example, according to a site 

official at Hanford who oversaw the initial integration effort, DOE did not 

implement key elements of the plan, such as establishing a sitewide 

funding profile for all groundwater and vadose zone activities. DOE 

implemented other elements of the plan but did not sustain them when 

changes, such as how projects were organized and contracts were 

structured, occurred at the site. For example, coordinating all activities 

through a single federal project manager faltered as site offices were 

reorganized and responsibilities were distributed among three federal 

project directors. The DOE official from the Hanford groundwater 

program attributes the lack of coordination of groundwater and vadose 

zone efforts to redefining project activities, which resulted in groundwater 

and vadose zone activities being managed as separate projects and 

changes in the structure of site contracts, which resulted in scopes of 

work being organized and assigned differently. A 2001 National Academy 

of Sciences review of DOE’s groundwater science and technology 

activities noted that DOE’s integration efforts had been superimposed over 

several already existing cleanup projects without establishing a clear line 

of responsibility for results. The National Academy said that this left the 

program operating in an unstable environment.22

To increase the chances of success for DOE’s current improvement 

initiative, we assessed DOE’s management of its new integration initiative

against model practices used by organizations that successfully sustained

improvement initiatives. We previously reported that in high-performing 

 22National Academy of Sciences, Science and Technology for Environmental Cleanup at

Hanford (Washington, D.C.: 2001). 

Page 19 GAO-06-1018 Columbia River Protection
organizations, management improvement initiatives are sustained by using 

a systematic, results-oriented plan that incorporates a rigorous

measurement of progress.23 Such a plan typically included the following 

steps: (1) defining clear program goals for the initiative—important 

because it focuses an organization’s efforts on achieving specific 

outcomes and allows as assessment of future performance against those 

goals; (2) developing an implementation strategy that sets milestones and 

establishes individual responsibilities—important because it establishes 

accountability for achieving the initiative’s goals; (3) establishing resultsoriented performance measures—important because it allows 

organizations to measure progress toward achieving their goals; and (4) 

using results-oriented data to evaluate the effectiveness of the initiative

and make additional changes where warranted—important because 

periodic evaluations can reveal systemic problems and promote 

continuous program improvement over the long term. 

As of July 2006, DOE had implemented two components and not 

implemented other management components to help ensure that it could

sustain any improvements resulting from its new integration initiative. For 

example, in putting forward its plan to Congress, DOE described a general 

goal of its new integration initiative as better coordination of Hanford’s 

groundwater and vadose zone cleanup activities in order to achieve 

greater protection of the Columbia River. DOE also outlined steps it would 

take toward its goal, such as (1) consolidating site modeling and risk 

assessments; (2) consolidating river protection efforts under a single 

project; and (3) integrating soil and groundwater cleanup decisions. In 

going forward, DOE could further refine its goals to include measurable 

steps to achieving its overall goal of protecting the river. For example, a 

more measurable goal would be the reduction of contamination reaching 

the river or ensuring duplication of efforts is reduced in order to better 

protect the Columbia River. 

DOE had established general milestones and individual responsibilities for 

implementing its new integration initiative. For example, DOE’s plan of 

action sets 16 milestones by September 2006 by which various initial steps 

are to be taken. DOE also reported that five of these actions, including 

 23See GAO, Contract Reform: DOE Has Made Progress, but Actions Needed to Ensure 

Initiatives Have Improved Results, GAO-02-798 (Washington, D.C.: Sept. 13, 2002); also, 

GAO, DOE Contracting: Improved Program Management Could Help Achieve Small 

Business Goal, GAO-06-501 (Washington, D.C.: Apr. 7, 2006). 

Page 20 GAO-06-1018 Columbia River Protection
making staff assignments and establishing an integrated project team, had

been completed. 

DOE has not established results-oriented measures to gauge the progress 

of its integrated management initiative. In outlining the steps it will take 

under its plan, DOE has generally concentrated on establishing 

relationships and moving work-scope between various DOE offices and 

contractors, and not on outcomes, such as reducing redundancies or gaps 

in river protection efforts. Without clear results-oriented performance 

measures to gauge progress, problems that occur under a fragmented 

management structure could be masked and allowed to continue under 

DOE’s integration plan. Translating the general goal of “better integration” 

and “protection of the river” into a more specific goal, such as reducing 

duplicative efforts, would help DOE identify ways it could measure results 

and, therefore, gauge progress toward the goals of its integration initiative. 

Finally, DOE has not yet identified an evaluation strategy to determine 

whether the steps it is taking are effective and are being sustained. 

Without an evaluation strategy based on clear goals and results-oriented 

measures, DOE will not have the results-oriented data necessary to 

objectively evaluate progress and implement corrective actions as needed. 

Although DOE is still working to define and implement its integration 

initiative, fully developing and putting in place key elements outlined 

above could help ensure that any program improvements are sustained in 

the future. DOE’s Hanford Assistant Manager in charge of overseeing the 

latest management improvements for the river protection program said 

that, beyond outlining broad goals and setting the framework for roles and 

responsibilities, DOE had not yet fully developed a project execution plan 

for the new initiative. He said that the management plan is still evolving 

and that future steps may include more clearly defining performance 

measures and strategies for evaluating the initiative’s effectiveness. 

DOE is involved in a lengthy process to identify and address potential 

threats to the Columbia River from contamination in the soil and 

groundwater at the Hanford site. This requires a good understanding of the 

risks to the river and an effective management strategy for addressing 

those risks. Over the years, we and others have raised concerns about 

DOE’s efforts to understand the nature and extent of the contamination 

and how best to manage the efforts to prevent contamination from seeping 

into the river. In recent months, DOE has taken several steps to gain a 

better understanding of the risks from the contamination as well as to 

Conclusions 

Page 21 GAO-06-1018 Columbia River Protection
improve its management of the program and integration of activities. 

While these steps are encouraging, DOE has not yet decided whether to 

put in place elements of a management plan that could help ensure 

potential benefits of these improvements will be continued, even when 

organizational and contract changes occur at the site. Such a management 

plan should include developing results-oriented performance measures, 

using the measures to determine progress toward objectives, and making 

changes as necessary. 

To increase the likelihood that DOE will effectively implement and sustain 

improvements in its program to protect the Columbia River from 

contamination at the Hanford site, we recommend that the Secretary of 

Energy strengthen the management improvement plan by establishing 

results-oriented performance measures and regular evaluations to gauge

the program’s effectiveness. 

We provided a draft of this report to DOE for its review and comment. In a 

letter from DOE’s Principal Deputy Assistant Secretary for Environmental 

Management, DOE agreed with the report’s findings and fully endorsed the 

recommendation to adopt results-oriented performance measures and 

regular evaluations of the river protection program. DOE acknowledged 

that performance measures and regular evaluations are a fundamental and 

integral component of sound project management practice and said that it

would incorporate them into the project. The full text of DOE’s comments 

is presented in appendix II. 

As arranged with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 7 days after the 

date of this report. At that time, we will send copies of this report to other 

interested congressional committees and to the Secretary of Energy. 

Copies will be made available to others on request. In addition, this report 

will be available at no charge on our Web site at http://www.gao.gov. 

Recommendation for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 22 GAO-06-1018 Columbia River Protection
If you or your staff have any questions on this report, please contact me at 

(202) 512-3841 or by e-mail at aloisee@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. Other staff contributing to this report are listed in 

appendix III. 

Gene Aloise 

Director, Natural Resources and Environment 

Page 23 GAO-06-1018 Columbia River Protection
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To understand the risk to the Columbia River from Hanford site 

contamination, we reviewed risk assessments, groundwater, vadose zone, 

and river monitoring reports by the Department of Energy (DOE), DOE’s 

Office of Inspector General, DOE contractors including the Pacific 

Northwest National Laboratory, and various outside groups such as the 

National Academy of Sciences. We interviewed DOE officials at both 

headquarters and the Hanford site, as well as contractor staff at Hanford,

to obtain information on the distribution of contamination at Hanford and 

the steps being taken to better understand it. To understand DOE’s 

approach to the vadose zone, we primarily reviewed our 1998 report, as 

well as documents prepared by DOE and its staff in response to that 

report. We also reviewed documents DOE submitted to regulators related 

to changing Tri-Party Agreement milestones; the documents were to be 

used for preparing initial drafts of plans for all remaining contaminated 

areas. We discussed the proposed change to the December 2008 Tri-Party

Agreement milestone with DOE officials and regulators. In reviewing 

DOE’s efforts to determine the extent of risk of future damage to the river 

from contamination, we reviewed documents related to DOE’s sitewide 

modeling effort and legal documents related to this modeling effort. We 

discussed these modeling efforts with DOE officials, contractors, and 

regulators. 

In assessing DOE’s efforts to deploy effective technologies to address 

contamination near the river, we visited the sites of existing and planned

cleanup efforts. We discussed current existing projects with DOE officials, 

contractor staff, regulators, and stakeholders, and reviewed reports 

prepared for DOE and others. To assess technology plans developed by

DOE to use $10 million of funds earmarked for fiscal year 2006, we 

attended DOE screening panels, reviewed reports prepared by DOE and 

others, and discussed the efforts with DOE regulators. 

To review DOE efforts to strengthen the management of its river 

protection efforts, we reviewed DOE’s past and current management 

plans. We obtained DOE’s recent integration initiative proposals, including 

its proposal to Congress in March 2006 and its subsequent Memorandum 

of Agreement and Plan of Action. We discussed DOE’s approach with 

headquarters and site officials. We reviewed previous work in which we 

documented strategies used by high-performing organizations to 

implement improvement initiatives. We reviewed DOE’s proposed 

integration initiative and compared it to key elements of these strategies. 

We also discussed DOE’s plans to implement its strategy with 

knowledgeable site officials. 

Page 24 GAO-06-1018 Columbia River Protection
Appendix I: Scope and Methodology 

In reviewing the management of DOE programs related to groundwater 

and river protection, we reviewed DOE efforts to assure that 

contamination levels were accurately reported; we also interviewed 

regulators, DOE officials, and contractors regarding data reliability. While 

we did not independently test the contaminant data, we reviewed controls 

over how the data were obtained and tested, visited sampling locations 

and discussed sampling methods with key staff, and reviewed other 

relevant information to determine that the data were sufficiently reliable

for the purposes of our report. We conducted our work from December 

2005 to August 2006 in accordance with generally accepted government 

auditing standards. 

Page 25 GAO-06-1018 Columbia River Protection
Appendix II: Comments from the Department Appendix II: Comments from the Department of Energy 

of Energy 

Page 26 GAO-06-1018 Columbia River Protection
Appendix II: Comments from the Department 

of Energy 

Page 27 GAO-06-1018 Columbia River Protection
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 28 GAO-06-1018

Appendix III: GAO Contact and Staff 

Acknowledgments 

Gene Aloise, (202) 512-3841 

In addition to the contact named above, Bill Swick, Assistant Director; 

Chris Abraham; Doreen Feldman; Nancy Kintner-Meyer; Jeffrey Larson; 

Omari Norman; Alison O’Neill; Thomas Perry; and Stan Stenersen made 

significant contributions to this report. Others who made important 

contributions included Mark Braza, Doreen Eng, and Mehrzad Nadji. 

Columbia River Protection

GAO Contact 

Staff 

Acknowledgments 

(360638) 
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