HANFORD WASTE 

TREATMENT PLANT

DOE Needs to Take 

Action to Resolve 

Technical and 

Management 

Challenges

Report to Congressional Requesters

December 2012

GAO-13-38

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-38, a report to 

congressional requesters

December 2012 

HANFORD WASTE TREATMENT PLANT

DOE Needs to Take Action to Resolve Technical and 

Management Challenges

Why GAO Did This Study

In December 2000, DOE awarded 

Bechtel a contract to design and 

construct the WTP project at DOE’s 

Hanford Site in Washington State. This 

project—one of the largest nuclear 

waste cleanup facilities in the world—

was originally scheduled for completion 

in 2011 at an estimated cost of $4.3 

billion. Technical challenges and other 

issues, however, have contributed to 

cost increases and schedule delays.

GAO was asked to examine (1) 

remaining technical challenges, if any, 

the WTP faces; (2) the cost and 

schedule estimates for the WTP; and 

(3) steps DOE is taking, if any, to 

improve the management and 

oversight of the WTP project. GAO 

reviewed DOE and contractor data and 

documents, external review reports, 

and spoke with officials from DOE and 

the Defense Nuclear Facilities Safety 

Board and with contractors at the WTP 

site and test facilities.

What GAO Recommends

GAO recommends that DOE (1) not 

resume construction on WTP’s 

pretreatment and high-level waste 

facilities until, among other things, the 

facilities’ design has been completed to 

the level established by nuclear 

industry guidelines; (2) ensure the 

department’s contractor performance 

evaluation process does not 

prematurely reward contractors for 

resolving technical issues later found 

to be unresolved; and (3) take 

appropriate steps to determine whether 

any incentive payments were made 

erroneously and, if so, take actions to 

recover them. DOE generally agreed 

with the report and its 

recommendations.

What GAO Found

The Department of Energy (DOE) faces significant technical challenges in 

successfully constructing and operating the Waste Treatment and Immobilization 

Plant (WTP) project that is to treat millions of gallons of highly radioactive liquid 

waste resulting from the production of nuclear weapons. DOE and Bechtel 

National, Inc. identified hundreds of technical challenges that vary in significance 

and potential negative impact and have resolved many of them. Remaining 

challenges include (1) developing a viable technology to keep the waste mixed 

uniformly in WTP mix tanks to both avoid explosions and so that it can be 

properly prepared for further processing; (2) ensuring that the erosion and 

corrosion of components, such as tanks and piping systems, is effectively 

mitigated; (3) preventing the buildup of flammable hydrogen gas in tanks, 

vessels, and piping systems; and (4) understanding better the waste that will be 

processed at the WTP. Until these and other technical challenges are resolved, 

DOE will continue to be uncertain whether the WTP can be completed on 

schedule and whether it will operate safely and effectively.

Since its inception in 2000, DOE’s estimated cost to construct the WTP has 

tripled and the scheduled completion date has slipped by nearly a decade to 

2019. GAO’s analysis shows that, as of May 2012, the project’s total estimated 

cost had increased to $13.4 billion, and significant additional cost increases and 

schedule delays are likely to occur because DOE has not fully resolved the 

technical challenges faced by the project. DOE has directed Bechtel to develop a 

new cost and schedule baseline for the project and to begin a study of 

alternatives that include potential changes to the WTP’s design and operational 

plans. These alternatives could add billions of dollars to the cost of treating the 

waste and prolong the overall waste treatment mission. 

DOE is taking steps to improve its management and oversight of Bechtel’s 

activities but continues to face challenges to completing the WTP project within 

budget and on schedule. DOE’s Office of Health, Safety, and Security has 

conducted investigations of Bechtel’s activities that have resulted in penalties for 

design deficiencies and for multiple violations of DOE safety requirements. In 

January 2012, the office reported that some aspects of the WTP design may not 

comply with DOE safety standards. As a result, DOE ordered Bechtel to suspend 

work on several major WTP systems, including the pretreatment facility and parts 

of the high-level waste facility, until Bechtel can demonstrate that activities align 

with DOE nuclear safety requirements. While DOE has taken actions to improve 

performance, the ongoing use of an accelerated approach to design and 

construction—an approach best suited for well-defined and less-complex 

projects—continues to result in cost and schedule problems, allowing 

construction and fabrication of components that may not work and may not meet 

nuclear safety standards. While guidelines used in the civilian nuclear industry 

call for designs to be at least 90 percent complete before construction of nuclear 

facilities, DOE estimates that WTP is more than 55 percent complete though the 

design is only 80 percent complete. In addition, DOE has experienced continuing 

problems overseeing its contractor’s activities. For example, DOE’s incentives 

and management controls are inadequate for ensuring effective project 

management, and GAO found instances where DOE prematurely rewarded the 

contractor for resolving technical issues and completing work. 

View GAO-13-38. For more information, 

contact David C. Trimble at (202) 512-3841 or 

trimbled@gao.gov. 
Page i GAO-13-38 DOE’s Waste Treatment Plant 

Letter 1 

Background 6

Significant Technical Challenges Remain Unresolved 11

Substantial Additional Cost Increases and Schedule Delays

 Are Likely 14

DOE Is Taking Steps to Address Some Management and Oversight 

Problems but Continues to Face Challenges to Completing the 

WTP 17

Conclusions 23

Recommendations for Executive Action 25

Agency Comments and Our Evaluation 25

Appendix I Comments from the Department of Energy 27

Appendix II GAO Contact and Staff Acknowledgments 31

Figures

Figure 1: WTP Waste Treatment Process 3

Figure 2: WTP Construction Site as of March 2012 10

Abbreviations

DOE Department of Energy

EPA Environmental Protection Agency 

ORP DOE’s Office of River Protection

PNNL Pacific Northwest National Laboratory 

WTP Waste Treatment and Immobilization Plant

Contents 

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Page 1 GAO-13-38 DOE’s Waste Treatment Plant 

United States Government Accountability Office 

Washington, DC 20548

December 19, 2012

The Honorable Fred Upton

Chairman

The Honorable Henry A. Waxman

Ranking Member

Committee on Energy and Commerce

House of Representatives

The Honorable Cliff Stearns

Chairman

The Honorable Diana DeGette 

Ranking Member

Subcommittee on Oversight and Investigations

Committee on Energy and Commerce

House of Representatives

The Honorable Edward J. Markey

House of Representatives

The Department of Energy (DOE) is responsible for one of the world’s 

largest environmental cleanup projects: the treatment and disposal of 

millions of gallons of radioactive and hazardous waste at its 586-squaremile Hanford Site in southeastern Washington State. A total of nine 

nuclear reactors––including the world’s first operating large-scale reactor, 

developed as part of the Manhattan Project during World War II––were 

built at Hanford and operated until the late 1980s. The primary mission of 

these reactors was to produce plutonium and other special nuclear 

materials for DOE’s nuclear weapons program. Some of the large 

volumes of hazardous and radioactive waste that resulted from nuclear 

materials production was deposited directly into the ground in trenches, 

injection wells, or other facilities designed to allow the waste to disperse 

into the soil, and some was packaged into drums and other containers 

and buried. The most dangerous waste was stored in 177 large 

underground storage tanks. The underground tanks currently hold more 

than 56 million gallons of this waste—enough to fill an area the size of a 

football field to a depth of over 150 feet.

The oldest 149 tanks, some of which date back to the 1940s, have singlelayer walls, or shells; were built with a 20-year design life; and will be 

almost 100 years old by the estimated end of waste treatment. DOE has 

reported that 67 of these tanks are assumed or are known to have leaked 

 
 

Page 2 GAO-13-38 DOE’s Waste Treatment Plant 

waste into the soil. Because some of this contamination has reached the 

groundwater under the tanks, DOE officials are concerned that the 

contamination is now making its way to the Columbia River, which 

borders the Hanford Site for almost 50 miles. The Columbia River is the 

second largest river in the United States and a source for hydropower 

production, agricultural irrigation, drinking water, and salmon 

reproduction. The site is also near the cities of Richland, Pasco, and 

Kennewick, with a combined regional population of over 200,000. DOE, 

the Environmental Protection Agency (EPA), and the Washington State

Department of Ecology have determined that containing, stabilizing, and 

preparing this highly radioactive liquid waste for final disposal is one of 

the highest priority cleanup activities at the Hanford site. It is also one of 

the most complex cleanup activities and, as of August 2012, none of the 

waste in the tanks had been treated for disposal because no treatment 

facility was yet available.

In 2000, DOE awarded a contract to Bechtel National, Inc. to design, 

construct, and commission a Waste Treatment and Immobilization Plant 

(WTP) to stabilize large quantities of this waste and prepare it for disposal 

at a permanent national geologic repository that is yet to be identified. 

The WTP is to consist of a pretreatment facility that separates waste into 

high-level and low-activity radioactivity waste streams; two facilities to 

treat these separated streams using a process called vitrification, where 

waste is mixed with melted glass and poured into steel canisters where it 

cools and hardens, to prepare it for final disposal; an analytical laboratory; 

and a variety of supporting facilities.1

 

1

As designed, the WTP Low Activity Waste Facility will only be capable of treating less 

than half of the expected quantity of Hanford’s low-activity waste. DOE has indicated that 

a second plant or alternative approach that is not part of the current project will be 

necessary to treat the rest of the low-activity waste and is still exploring a supplemental 

technology outside the scope of the WTP to treat this waste. See GAO, Nuclear Waste: 

DOE Should Reassess Whether the Bulk Vitrification Demonstration Project at Its Hanford 

Site Is Still Needed to Treat Radioactive Waste,

See figure 1 for a description of the 

process that is to be used to treat and stabilize waste at the WTP and 

prepare it for disposal.

GAO-07-762 (Washington, D.C.: 

June 12, 2007).
 

Page 3 GAO-13-38 DOE’s Waste Treatment Plant 

Figure 1: WTP Waste Treatment Process

To construct the facility, DOE and Bechtel adopted a fast-track, designbuild approach. Using the unconventional design-build approach, 

technology development activities, plant design, and construction occur 

simultaneously. In a conventional construction approach, these activities 

occur sequentially. As required by DOE’s project management directives, 

approval to begin construction is granted when technology development 

and design of the facility is essentially complete and after the 

establishment and approval of a project’s performance baseline, which 

represents DOE’s commitment to complete a project with a specific scope 

at a certain cost and by a specific date. We and others have raised 

concerns about DOE’s use of the design-build approach for the WTP 

because some sections of this facility are constructed before designs are 

complete and before technology issues are fully resolved, which has
 

Page 4 GAO-13-38 DOE’s Waste Treatment Plant 

led to significant cost increases and schedule delays.2

In this context, you asked us to evaluate DOE’s management of the WTP 

project. Our objectives were to examine: (1) remaining technical 

challenges, if any, the WTP faces; (2) cost and schedule estimates for the 

WTP; and (3) steps DOE is taking, if any, to improve the management 

and oversight of the WTP project.

Specifically, when 

the contract was awarded in 2000 for the WTP, the contract for 

constructing the WTP specified that the project would cost $4.3 billion and 

would be completed in 2011. As a result of numerous problems with the 

design and construction of WTP facilities, in 2006, DOE significantly 

modified the project’s baseline. Despite the problems throughout the 

construction process, however, DOE has continued with the design-build 

approach. In the last 2 years, several WTP project engineers and 

managers and the Defense Nuclear Facility Safety Board (Safety 

Board)—an independent oversight agency created by Congress to 

assess safety conditions and operations at defense nuclear facilities at 

DOE’s sites—publicly criticized DOE and Bechtel for ignoring technical 

and safety concerns that threaten the plant’s ability to operate safely once 

constructed. In 2011, DOE reported that unresolved technical risks would 

cause the cost and schedule estimates to slip further unless additional 

funding was provided.

To accomplish our objectives, we conducted our work at the Hanford Site, 

including the WTP construction site; DOE’s Office of River Protection 

(ORP)—which is responsible for DOE management of the construction of 

the WTP; Bechtel’s WTP project office in Richland, Washington; and test 

facilities at Mid Columbia Engineering. We interviewed, among others, 

current and past DOE WTP project directors and officials from WTP 

project support divisions, including the WTP Engineering Division, ORP 

Engineering and Nuclear Safety Division, and ORP Environmental Safety 

and Quality Division.

 

2

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, Department of Energy: Major Construction 

Projects Need a Consistent Approach for Assessing Technology Readiness to Help Avoid 

Cost Increases and Delays, GAO-07-336 (Washington, D.C.: Mar. 27, 2007); 

GAO-07-762. 
 

Page 5 GAO-13-38 DOE’s Waste Treatment Plant 

To identify any remaining technical challenges that the WTP is facing, we 

reviewed DOE and Bechtel documents that provide a summary and 

current status of technical issues, including criteria for addressing these 

issues and a timeline for their resolution. We also examined independent 

reviews on technical and safety issues and interviewed officials from 

DOE’s Office of Engineering and Construction Management and Office of 

Health, Safety, and Security; the Pacific Northwest National Laboratory 

(PNNL); the Safety Board; and the Consortium for Risk Evaluation with 

Stakeholder Participation—a group of engineering, scientific, and policy 

experts from seven universities that advises DOE in its environmental 

management activities.3

To examine the current cost and schedule estimates for the WTP, we 

reviewed the most current estimates for the project that DOE prepared in 

2006, DOE and Bechtel progress reports on the project’s adherence to 

these cost and schedule estimates, and project risk management plans. 

We also interviewed DOE officials to obtain information on recent efforts 

to revise the project’s cost and schedule estimates.

We also interviewed officials from the 

Washington State Department of Ecology and EPA.

To determine any steps DOE is taking to improve the management and 

oversight of the WTP project, we reviewed DOE policies on project 

management, examined regulatory requirements, and reviewed 

agreements between DOE, EPA, and the state of Washington. We also 

reviewed DOE WTP management documents, risk analysis reports, and 

contractor project plans.

We conducted this performance audit from September 2011 to December 

2012 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.

 

3

DOE’s Office of Engineering and Construction Management is now called the Office of 

Project Management and is within DOE’s Office of Acquisition and Project Management. 
 

Page 6 GAO-13-38 DOE’s Waste Treatment Plant 

Established in 1943, Hanford produced plutonium for the world’s first 

nuclear device. At the time, little attention was given to the resulting byproducts—massive amounts of radioactive and chemically hazardous 

waste—or how these by-products were to be permanently disposed of. 

About 46 different radioactive elements represent the majority of the 

radioactivity currently residing in Hanford’s tanks. Once Hanford tank 

waste is separated by the WTP waste treatment process, the high-level 

waste stream will contain more than 95 percent of the radioactivity but 

constitute less than 10 percent of the volume to be treated. The lowactivity 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. These hazardous chemicals are 

dangerous to human health and can cause medical disorders including 

cancer, and they can remain dangerous for thousands of years. Over the 

years, the waste contained in these tanks has settled; today it exists in 

the following four main forms or layers:

• Vapor: Gases produced from chemical reactions and radioactive 

decay occupies tank space above the waste.

• Liquid: Fluids (supernatant liquid) 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 salt-like 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 

similar to peanut butter.

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, as 

Background
 

Page 7 GAO-13-38 DOE’s Waste Treatment Plant 

amended,4 and the Resource Conservation and Recovery Act of 1976, as 

amended.5

DOE has attempted and abandoned several different strategies to treat 

and dispose of Hanford’s tank wastes. In 1989, DOE’s initial strategy 

called for treating only part of the waste. Part of this effort involved 

renovating a World War II-era facility 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; however, the planned treatment facility would not 

have had sufficient capacity to treat all the waste in a time frame 

acceptable to EPA and the Washington State Department of Ecology. 

In addition, most of the cleanup activities at Hanford are 

carried out under the Hanford Federal Facility Agreement and Consent 

Order among DOE, the Washington State Department of Ecology, and 

EPA. Commonly called the Tri-Party Agreement, this accord was signed 

in May 1989 and has been amended a number of times since then to, 

among other things, establish additional enforceable milestones for 

certain WTP construction and tank waste retrieval activities. 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. These stakeholders make their views known through various 

public involvement processes, including site-specific advisory boards. 

DOE’s ORP administers Hanford’s radioactive liquid tank waste 

stabilization and disposition project including the construction of the WTP. 

The office has an annual budget of about $1 billion and a staff of 151 

federal employees, of which 54 support the WTP project. Other cleanup 

projects at Hanford are administered by DOE’s Richland Operations 

Office.

 

4

42 U.S.C. § 9601 et seq. The act, among other things, provided the federal government 

with authority to respond to releases or threatened releases of hazardous substances. 

5

42 U.S.C. § 6901 et seq. Under the act, the owners or operators of facilities located on 

sites where hazardous waste was or is treated, stored, or disposed of must, among other 

things, clean up present and past contamination within the boundaries of their sites, as 

well as contamination that may have spread beyond those boundaries.
 

Page 8 GAO-13-38 DOE’s Waste Treatment Plant 

DOE spent about $418 million on this strategy. Beginning in 1995, DOE 

attempted to privatize tank waste cleanup. Under its privatization strategy, 

DOE planned to set a fixed price and pay the contractor for canisters and 

containers of stabilized 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. 

Under the privatization strategy, DOE’s contractor would build a 

demonstration facility to treat 10 percent of the waste volume and 25 

percent of the radioactivity by 2018 and complete cleanup in 2028. 

However, because of dramatically escalating costs and concerns about 

contractor performance, DOE terminated the contract after spending 

about $300 million, mostly on plant design. Following our criticisms of 

DOE’s earlier privatization approach,6

DOE’s current strategy for dealing with tank waste consists of the 

construction of a large plant—the WTP—to treat and prepare the waste 

for permanent disposal. Begun in 2000, the WTP project is over half 

completed and covers 65 acres and is described by DOE as the world’s 

largest radioactive waste treatment plant. As designed, the WTP project 

is to consist of three waste processing facilities, an analytical laboratory, 

and over 20 smaller supporting facilities to treat the waste and prepare it 

for permanent disposal. The three waste processing facilities are as 

follows (see fig. 2):

DOE decided that a costreimbursement contract with incentive fees would be more appropriate 

than a fixed-price contract using a privatization approach for the Hanford 

project and would better motivate the contractor to control costs through 

incentive fees. In total, since 1989 when cleanup of the Hanford site 

began, DOE has spent over $16 billion to manage the waste and explore 

possible ways to treat and dispose of it.

• Pretreatment Facility – This facility is to receive the waste from the 

tanks and separate it into high-level and low-activity components. This 

is the largest of the WTP facilities––expected to be 12-stories tall with 

a foundation the size of four football fields.

 

6

See GAO, Nuclear Waste: Observations on DOE’s Privatization Initiative for Complex 

Cleanup Projects, GAO/T-RCED-00-215 (Washington, D.C.: June 22, 2000).
 

Page 9 GAO-13-38 DOE’s Waste Treatment Plant 

• High-Level Waste Facility – This facility is to receive the high-level 

waste from the pretreatment facility and immobilize it by mixing it with 

a glass-forming material, melting the mixture into glass, and pouring 

the vitrified waste into stainless-steel canisters to cool and harden. 

The canisters filled with high-level waste were initially intended to be 

permanently disposed of at a geological repository that was to be 

constructed at Yucca Mountain in Nevada. However, in 2010, DOE 

began taking steps to terminate the Yucca Mountain project and is 

now considering other final disposal options.7

• Low-Activity Waste Facility – This facility is to receive the low-activity 

waste from the pretreatment facility and vitrify it. The containers of 

vitrified waste will then be permanently disposed of at another facility 

at Hanford known as the Integrated Disposal Facility.

In the meantime, highlevel waste canisters will be stored at Hanford.

 

7

GAO, Commercial Nuclear Waste: Effects of a Termination of the Yucca Mountain 

Repository Program and Lessons Learned, GAO-11-229 (Washington, D.C.: 

May 10, 2011).
 

Page 10 GAO-13-38 DOE’s Waste Treatment Plant 

Figure 2: WTP Construction Site as of March 2012

Constructing the WTP is a massive, highly complex, and technically 

challenging project. For example, according to Bechtel documents, the 

completed project will contain almost 270,000 cubic yards of concrete and 

nearly a million linear feet of piping. The project also involves developing 

first-of-a-kind nuclear waste mixing technologies that will need to operate 

for decades with perfect reliability because, as currently designed, once 

WTP begins operating, it will not be possible to access parts of the plant 

to conduct maintenance and repair of these technologies due to high 

radiation levels.
 

Page 11 GAO-13-38 DOE’s Waste Treatment Plant 

Since the start of the project, DOE and Bechtel have identified hundreds 

of technical challenges that vary in their significance and potential 

negative impact, and significant technical challenges remain. Technical 

challenges are to be expected on a one-of-a-kind project of this size, and 

DOE and Bechtel have resolved many of them. However, because such 

challenges remain, DOE cannot be certain whether the WTP can be 

completed on schedule and, once completed, whether it will successfully 

operate as intended.

Among others, the significant technical challenges DOE and Bechtel are 

trying to resolve include the following:

• Waste mixing—One function of the WTP will be to keep the waste 

uniformly mixed in tanks so it can be transported through the plant 

and to prevent the buildup of flammable hydrogen and fissile material 

that could inadvertently result in a nuclear criticality accident. The 

WTP project has been developing a technology known as “pulse jet 

mixers” that uses compressed air to mix the waste. Such devices 

have previously been used successfully in other materials mixing 

applications but have never been used for mixing wastes with high 

solid content like those to be treated at the WTP. In 2004 and again in 

2006, we reported that Bechtel’s inability to successfully demonstrate 

waste mixing technologies was already leading to cost and schedule 

delays.8

 

8

GAO, Nuclear Waste: Absence of Key Management Reforms on Hanford’s Cleanup 

Project Adds to Challenges of Achieving Cost and Schedule Goals,

Our 2004 report recommended that DOE and Bechtel resolve 

this issue before continuing with construction. DOE agreed with our 

recommendation, slowed construction on the pretreatment and highlevel waste facilities and established a path forward that included 

larger-scale testing to address the mixing issue. In 2010, following 

further testing by Bechtel, DOE announced that mixing issues had 

been resolved and moved forward with construction. However, 

concerns about the pulse jet mixers’ ability to successfully ensure 

uniform mixing continued to be raised by the Safety Board, PNNL, 

and DOE engineering officials on site. As a result, in late 2011, DOE 

directed Bechtel to demonstrate that the mixers will work properly and 

meet the safety standards for the facility. According to DOE officials, 

no timeline for the completion of this testing has been set.

GAO-04-611 

(Washington, D.C.: June 9, 2004) and GAO-06-602T. 

Significant Technical 

Challenges Remain 

Unresolved
 

Page 12 GAO-13-38 DOE’s Waste Treatment Plant 

• Preventing erosion and corrosion of WTP components—Excessive 

erosion or corrosion of components such as mixing tanks and piping 

systems in the WTP is possible. Such excessive erosion and 

corrosion could be caused by potentially corrosive chemicals and 

large dense particles present in the waste that is to be treated. This 

excessive erosion and corrosion could result in the components’ 

failure and lead to disruptions of waste processing. Bechtel officials 

first raised concerns about erosion and corrosion of WTP components 

in 2001, and these concerns were echoed in 2006 by an independent 

expert review of the project. Following further testing, DOE project 

officials declared the issue closed in 2008. However, DOE and 

Bechtel engineers recently voiced concerns that erosion and 

corrosion of components is still a significant risk that has not been 

sufficiently addressed. Furthermore, in January 2012, the Safety 

Board reported that concerns about erosion in the facility had still not 

been addressed, and that further testing is required to resolve 

remaining uncertainties. Bechtel has agreed to do further work to 

resolve technical challenges surrounding erosion and corrosion of the 

facilities internal components; however, DOE and Bechtel have not 

yet agreed upon an overall plan and schedule to resolve this 

challenge.

• Preventing buildup of flammable hydrogen gas—Waste treatment 

activities in the WTP’s pretreatment and high-level waste facilities can 

result in the generation of hydrogen gas in the plant’s tanks and piping 

systems. The buildup of flammable gas in excess of safety limits could 

cause significant safety and operational problems. DOE and Bechtel 

have been aware of this challenge since 2002, and Bechtel formed an 

independent review team consisting of engineers and other experts in 

April 2010 to track and resolve the challenge. This team identified 35 

technical issues that must be addressed before the hydrogen buildup 

challenge can be resolved. Bechtel has been working to address 

these issues. However, a 2011 DOE construction project review noted 

that, while Bechtel continues to make progress resolving these issues, 

the estimated schedule to resolve this challenge has slipped.9

 

9 DOE, Department of Energy Review Committee Report on the Construction Project 

Review of the Waste Treatment and Immobilization Plant Project at the Office of River 

Protection at Hanford (Washington, D.C.: August 2011).

According to DOE and Bechtel officials, Bechtel is still conducting 

analysis and is planning to complete the work to resolve this 

challenge by 2013.
 

Page 13 GAO-13-38 DOE’s Waste Treatment Plant 

• Incomplete understanding of waste—DOE does not have 

comprehensive data on the specific physical, radiological, and 

chemical properties of the waste in each underground waste tank at 

Hanford. In the absence of such data, DOE has established some 

parameters for the waste that are meant to estimate the range of 

waste that may go through the WTP in an effort to help the contractor 

design a facility that will be able to treat whatever waste––or 

combination of wastes—is ultimately brought into the WTP. In 2006, 

an independent review team stated that properly understanding the 

waste would be an essential key factor in designing an effective 

facility. In 2010, the Consortium for Risk Evaluation with Stakeholder 

Participation, PNNL, and the Safety Board reviewed the status of 

DOE’s plans to obtain comprehensive data on the characteristics of 

the waste, and each concluded that DOE and Bechtel did not have 

enough information about the waste and would therefore need to 

increase the range of possible wastes that the WTP is designed to 

treat in order to account for the uncertainty. Officials at PNNL reported 

that not having a large enough range is “a vulnerability that could lead 

to inadequate mixing and line plugging.” The Safety Board reported 

that obtaining representative samples of the waste is necessary to 

demonstrate that the WTP can be operated safely, but that DOE and 

its contractors have not been able to explain how those samples will 

be obtained. In its 2011 review of the WTP project, a DOE 

headquarters construction project review report notes that progress 

has been made on including additional information and uncertainties 

in the efforts to estimate and model the waste that will be fed to the 

WTP. However, DOE officials stated that more sampling of the waste 

is needed. An expert study is under way that will analyze the gap 

between what is known and what is needed to be known to design an 

effective facility. This study is expected to be completed in August 

2014.

The risks posed by these technical challenges are exacerbated because 

once the facility begins operating, certain areas within the WTP 

(particularly in the pretreatment and high-level waste facilities) will be 

permanently closed off to any human intervention in order to protect 

workers and the public from radioactive contamination. To shield plant 

workers from intense radiation that will occur during WTP operations, 

some processing tanks will be located in sealed compartments called 

“black cells.” These black cells are enclosed rooms where inspection, 

maintenance, repair, or replacement of equipment or components is 

extremely difficult because high radiation levels prevent access into them. 

As a result, plant equipment in black cells must last for WTP’s 40-year 
 

Page 14 GAO-13-38 DOE’s Waste Treatment Plant 

expected design life without maintenance. According to a recent review 

conducted by the DOE Inspector General, premature failure of these 

components could result in radiation exposure to workers, contaminate 

large portions of the WTP and/or interrupt waste processing for an 

unknown period.10 Significant failures of components installed in the WTP 

once operations begin could render the WTP unusable and unrepairable, 

wasting the billions of dollars invested in the WTP. In August 2012, DOE 

announced that it was asking a team of experts to examine the WTP’s 

capability to detect problems in the black cells and the plant’s ability to 

repair equipment in the black cells, if necessary. According to DOE 

officials, the team will, if needed, recommend design changes to improve 

the operational reliability of the black cells and the WTP. In addition, the 

Secretary of Energy has been actively engaged in the development of a 

new approach to managing WTP technical challenges and has 

assembled subject matter experts to assist in addressing the technical 

challenges confronting the WTP.

The estimated cost to construct the WTP has almost tripled since the 

project’s inception in 2000, its scheduled completion date has slipped by 

nearly a decade, and additional significant cost increases and schedule 

delays are likely to occur because DOE has not fully resolved the 

technical challenges faced by the project. In addition, DOE recently 

reported that Bechtel’s actions to take advantage of potential cost savings 

opportunities are frequently delayed and, as a result, rising costs are 

outpacing opportunities for savings.

DOE’s original contract price for constructing the WTP, approved in 2000, 

stated that the project would cost $4.3 billion and be completed in 2011. 

In 2006, however, DOE revised the cost baseline to $12.3 billion, nearly 

triple the initial estimate, with a completion date of 2019. As we reported 

in 2006, contractor performance problems, weak DOE management, and 

technical challenges resulted in these cost increases and schedule 

delays.11

 

10 U.S.DOE Office of Inspector General, Audit Report: The Department of Energy’s $12.2 

Billion Waste Treatment and Immobilization Plant—Quality Assurance Issues—Black Cell 

Vessels, DOE/IG-0863 (Washington D.C.: April 2012). 

A 2011 DOE headquarters review report on the WTP projected 

11GAO-06-602T. 

Substantial Additional 

Cost Increases and 

Schedule Delays 

Are Likely

DOE Has Not Yet Fully 

Estimated the Cost and 

Schedule Impact of 

Resolving Technical 

Challenges
 

Page 15 GAO-13-38 DOE’s Waste Treatment Plant 

additional cost increases of $800 million to $900 million over the revised 

2006 cost estimate of $12.3 billion and additional delays to the project 

schedule.12 Furthermore, in November 2011, the Department of Justice 

notified the state of Washington that there is a serious risk that DOE may 

be unable to meet the legally enforceable milestones required by legal 

agreement, for completing certain activities in Hanford’s WTP 

construction and startup activities, as well as tank waste retrieval 

activities.13

DOE ORP officials warn that cost increases and schedule delays will 

occur as a result of funding shortfalls and will prevent the department 

from successfully resolving technical challenges the WTP project faces. 

However, from fiscal years 2007 to 2010, the project was appropriated 

the $690 million that DOE requested in its annual congressional budget 

request.

The Department of Justice did not identify the cause of the 

delay or specify the milestones that could be affected. As of May 2012, 

according to our analysis, the project’s total estimated cost had increased 

to $13.4 billion, and additional cost increases and schedule delays are 

likely, although a new performance baseline has not yet been developed 

and approved.

14

DOE and Bechtel have not yet fully estimated the effect of resolving these 

technical challenges on the project’s baseline. In February 2012, DOE 

directed Bechtel to develop a new, proposed cost and schedule baseline 

In fiscal years 2011 and 2012, DOE received approximately 

$740 million each year––a $50 million increase over fiscal year 2010 

funding. DOE project management officials and Bechtel representatives 

told us that $740 million for fiscal year 2012 was not enough to support 

planned work and, as a result, project work would slow down and project 

staffing levels would be reduced. However, according to senior DOE 

officials, including the acting Chief Financial Officer, the primary cause of 

the increasing costs and delayed completion has been the difficulty in 

resolving complex technical challenges rather than funding issues.

 

12DOE, Department of Energy Review Committee Report on the Construction Project 

Review of the Waste Treatment and Immobilization Plant Project at the Office of River 

Protection at Hanford (Washington, D.C.: August 2011).

13Consent Decree at 4 and Appx A in Washington v. DOE, Case No. 08-5085-FVS (E.D. 

WA. October 25, 2010).

14DOE’s 2008 enacted appropriation of $690 million was later reduced by a rescission of 

.91 percent to $683.721 million.
 

Page 16 GAO-13-38 DOE’s Waste Treatment Plant 

for the project and, at the same time, to begin a study of alternatives that 

includes potential changes to the WTP’s design and operational plans to 

resolve technical challenges faced by the project. The study is to also 

identify the cost and schedule impact of these alternatives on the project. 

For example, according to a DOE official, one alternative Bechtel is 

studying is to construct an additional facility that would process the tank 

waste by removing the largest solid particles from the waste before it 

enters WTP’s pretreatment facility. This advance processing would 

reduce the risks posed by insufficient mixing of the waste in the 

pretreatment facility by the pulse jet mixers. A DOE official told us that 

this alternative could add $2 to $3 billion to the overall cost of the project 

and further delay its completion by several years.

According to DOE officials, other alternatives being studied involve 

reducing the total amount of waste the WTP treats or operating the WTP 

at a slower pace for a longer period of time to accomplish its waste 

processing mission. However, these alternatives could delay the total 

time needed to process Hanford’s waste and add billions of dollars to the 

total cost to treat all of Hanford’s tank waste. Further delays constructing 

the WTP could also result in significant cost increases to treat all of 

Hanford’s waste. For example, DOE has estimated that a 4-year delay in 

the WTP start-up date could add an additional $6 to $8 billion to the total 

cost of the Hanford Site tank waste treatment mission.

In June 2012, DOE announced that the new cost and schedule baseline 

Bechtel is developing would not include the pretreatment and high-level 

waste facilities. According to DOE officials, additional testing and analysis 

is needed to resolve the facilities’ technical challenges before a 

comprehensive new cost and schedule baseline can be completed. DOE 

officials responsible for overseeing the WTP project are uncertain when 

the new baseline for these facilities will be completed. As a result, our 

May 2012 cost estimate of $13.4 is highly uncertain and could grow 

substantially if the technical challenges that the project faces are not 

easily and quickly resolved.

DOE and Bechtel have identified some opportunities for cost savings, but 

these opportunities are not always pursued in a timely fashion. For 

example, Bechtel has identified an estimated $48 million in savings that 

could be achieved over the life of the project by accelerating specific 

areas of the project scope. Specifically, some of these savings could be 

achieved by acquiring material and equipment in bulk to maintain the 

pace of construction activities and avoid delays. In addition, another $24 

Project Cost and Schedule 

Increases Could Be 

Partially Offset by 

Opportunities for Savings
 

Page 17 GAO-13-38 DOE’s Waste Treatment Plant 

million in savings could be achieved by reducing the amount of steel, 

pipe, wire, and other materials needed in remaining design work. DOE 

reported in March 2012, however, that Bechtel’s actions to take 

advantage of potential cost savings opportunities are frequently delayed 

and, as a result, rising costs have outpaced opportunities for savings. For 

example, DOE reported that Bechtel continues to perform poorly in 

meeting planned dates for material delivery due to delayed identification 

and resolution of internal issues impacting procurement of plant 

equipment. Specifically, DOE noted that, of 95 needed project equipment 

deliveries scheduled for July 2011 through October 2011, 42 were 

delivered on time and that this poor performance trend is expected to 

continue.

DOE is taking steps to improve its management and oversight of 

Bechtel’s activities, including levying penalties on the contractor for 

quality and safety problems but continues to face challenges to 

completing the WTP project within budget and on schedule. For example, 

DOE’s continued use of a fast-track, design-build management approach 

where construction on the project has moved forward before design 

activities are complete has resulted in costly reworking and schedule 

delays.

DOE is taking steps to improve its management and oversight of 

Bechtel’s activities. For example, in November 2011, DOE’s Office of 

Enforcement and Oversight started an investigation into Bechtel’s 

potential noncompliance with DOE’s nuclear safety requirements. 

Specifically, this DOE office is investigating Bechtel’s processes for 

designing, procuring, and installing structures, systems, and components 

and their potential noncompliance with DOE nuclear safety requirements. 

If the contractor is found to not be complying with DOE requirements, 

DOE’s Office of Enforcement and Oversight is authorized to take 

appropriate action, including the issuance of notices of violations and 

proposed civil penalties against Bechtel. Since 2006, DOE’s Office of 

Enforcement and Oversight has conducted six investigations into 

Bechtel’s activities at WTP that resulted in civil penalty against Bechtel. 

Five of the six investigations involved issues related to the design and 

safe operation of the WTP. For example, in 2008, DOE’s Office of 

Enforcement and Oversight investigated Bechtel for circumstances 

DOE Is Taking Steps 

to Address Some 

Management and 

Oversight Problems 

but Continues to Face 

Challenges to 

Completing the WTP

DOE Is Taking Steps to 

Improve the Management 

and Oversight of the WTP 

Project
 

Page 18 GAO-13-38 DOE’s Waste Treatment Plant 

associated with procurement and design deficiencies of equipment for the 

WTP and identified multiple violations of DOE nuclear safety 

requirements. This investigation resulted in Bechtel receiving a $385,000 

fine.

In addition, in January 2012, DOE’s Office of Health, Safety, and Security 

reported that some aspects of the WTP design may not comply with DOE 

safety requirements.15

DOE has also taken steps to address concerns about the project’s safety 

culture. According to DOE’s Integrated Safety Management System 

Guide, safety culture is an organization’s values and behaviors modeled 

by its leaders and internalized by its members, which serves to make safe 

performance of work the overriding priority to protect workers, the public, 

and the environment. In 2011, the Safety Board issued the results of an 

investigation into health and safety concerns at WTP. The investigation’s 

principal conclusion was that the prevailing safety culture of the WTP 

project effectively defeats DOE’s policy to establish and maintain a strong 

safety culture at its nuclear facilities. The Safety Board found that both the 

DOE and Bechtel project management behaviors reinforce a subculture 

at WTP that deters the timely reporting, acknowledgement, and ultimate 

resolution of technical safety concerns. In addition, the Safety Board 

found a flawed safety culture embedded in the project at the time had a 

substantial probability of jeopardizing the WTP mission. As a result of 

Specifically, under DOE safety regulations, Bechtel 

must complete a preliminary documented safety analysis—an analysis 

that demonstrates the extent to which a nuclear facility can be operated 

safely with respect to workers, the public, and the environment. However, 

Bechtel’s preliminary documented safety analyses have not always kept 

pace with the frequently changing designs and specifications for the 

various WTP facilities and DOE oversight reviews have highlighted 

significant deficiencies in the project’s safety analyses. In November 

2011, according to DOE officials, DOE ordered Bechtel to suspend work 

on design, procurement, and installation activities for several major WTP 

systems including parts of the pretreatment facility and high-level waste 

facility until the contractor demonstrates that these activities are aligned 

with DOE nuclear safety requirements. This suspension remains in effect.

 

15DOE, Office of Health, Safety, and Security, Office of Enforcement and Oversight, 

Independent Assessment of the Nuclear Safety Culture and Management of Nuclear 

Safety Concerns at the Hanford Site Waste Treatment and Immobilization Plant

(Washington, D.C.: January 2012).
 

Page 19 GAO-13-38 DOE’s Waste Treatment Plant 

these findings, the Safety Board made a series of recommendations to 

DOE to address WTP project safety problems. DOE has developed 

implementation plans to address the Safety Board’s recommendations. In 

addition, DOE itself has raised significant concerns about WTP safety 

culture. In 2011 DOE’s Office of Health, Safety, and Security conducted 

an independent assessment of the nuclear safety culture and 

management of nuclear safety concerns at the WTP. As a result of this 

assessment, DOE determined that most DOE and Bechtel WTP staff at 

the WTP believed that safety is a high priority. However, DOE also 

determined that a significant number of DOE and Bechtel staff expressed 

reluctance to raise concerns about safety or quality of WTP facilities 

design because WTP project management does not create an 

atmosphere conducive to hearing concerns or for fear of retaliation. 

Employees’ willingness to raise safety concerns without fear of retaliation 

is an essential element of a healthy safety culture and creating an 

atmosphere where problems can be identified. DOE’s assessment also 

determined that DOE has mechanisms in place to address safety culture 

concerns. For example, according to a January 2012 issued DOE Office 

of Health, Safety, and Security report on the safety culture and safety 

management of the project, the project has an employee’s concerns 

program and a differing professional opinion program that assist staff to 

raise safety concerns. In addition, the January 2012 issued report stated 

that several DOE reviews of the WTP project have been effective in 

identifying deficiencies in WTP designs and vulnerabilities that could 

impact the future operation of waste treatment facilities.

DOE has taken some steps to improve its management and oversight of 

Bechtel’s activities, but some problems remain. For example, DOE’s 

ongoing use of a fast-track, design-build approach continues to result in 

cost and schedule problems. As we reported in 2006, DOE’s 

management of the project has been flawed, as evidenced by DOE’s 

decision to adopt a fast-track, design-build approach to design and 

construction activities, and its failure to exercise adequate and effective 

oversight of contractor activities, both of which contributed to cost and 

schedule delays.16

 

16

According to DOE officials, DOE’s current project 

management orders will not allow the use of the fast-track, design-build 

GAO-06-602T. 

DOE’s Fast-Track, DesignBuild Management 

Approach and Other 

Management and 

Oversight Problems Have 

Led to Cost Increases and 

Schedule Delays
 

Page 20 GAO-13-38 DOE’s Waste Treatment Plant 

approach for first-of-its-kind complex facilities such as the WTP.17

According to DOE officials, construction of the WTP is currently more 

than 55 percent complete, though the design is only about 80 percent 

complete. Nuclear industry guidelines suggest that design should be 

complete to at least 90 percent before starting construction of nuclear 

facilities. Furthermore, according to current DOE orders, construction 

should not begin until engineering and design work on critical 

technologies is essentially complete, and these technologies have been 

tested and proven to work. According to DOE’s analysis in 2007, several 

years after the beginning of WTP construction, several critical 

technologies designed for the WTP had not yet reached this level of 

readiness.

However, DOE was able to start the project using the fast-track, designbuild approach before this order was in place. In a February 2012 written 

statement, DOE defended the fast-track, design-build management 

approach for the WTP project by stating that: (1) it allows for a single 

contract that gives the contractor responsibility for designing, building, 

and commissioning the facility, thus helping ensure that the design works 

as expected; (2) it allows the contractor to begin construction on parts of 

the facility for which design was complete; and (3) doing so would 

encourage construction to be completed faster.

18

Using the fast-track, design-build approach, DOE has moved the project 

forward constructing and fabricating WTP components that may not work 

and may not meet nuclear safety standards. For example, as discussed 

above, pulse jet mixer technology continues to be tested to evaluate its 

effectiveness. Moreover, some already procured and installed equipment 

may need to be removed, refabricated, and reinstalled. For example, to 

In addition, current DOE guidance states that the designbuild approach can be used most successfully with projects that have 

well-defined requirements, are not complex, and have limited risks.

 

17DOE, Program and Project Management for the Acquisition of Capital Assets, DOE 

Order 413.3B (Washington, D.C.: Nov. 29, 2010). The order also states that “aggressive 

risk mitigation strategies are required” for fast-tracked, design-build projects.

18DOE measures technology readiness using Technology Readiness Levels, which range 

from 1 to 9; where 9 represents a fully tested and proven technology. DOE guidance 

indicates that critical technologies should be at Technology Readiness Level 6 or higher 

before construction begins. However, in 2007, the last time DOE assessed Technical 

Readiness Levels for the entire project, DOE found that 14 out of 21 critical technologies 

assessed were at a Technology Readiness Level lower than 6.
 

Page 21 GAO-13-38 DOE’s Waste Treatment Plant 

keep pace with the construction schedule, Bechtel fabricated 38 vessels 

containing pulse jet mixers and installed 27 of them into the WTP 

pretreatment and high-level waste facilities. However, according to DOE 

officials, Bechtel has been forced to halt construction on the pretreatment 

facility and parts of the high-level waste facility because it was unable to 

verify that several vessels would work as designed and meet safety 

requirements. Bechtel is currently analyzing potential alternatives that 

include, among other things, scrapping 5 to 10 already completed vessels 

and replacing them with vessels with more easily verifiable designs, 

according to DOE officials. The cost and schedule impact of these 

alternatives has not yet been fully estimated.

DOE has also experienced continuing problems overseeing its contractor’s 

activities. For example, DOE’s incentives and management controls are 

inadequate for ensuring effective project management and oversight of the 

WTP project to ensure that the WTP project is completed within budget and 

on schedule. As we reported in 2006, DOE did not ensure adherence to 

normal project reporting requirements and as a result, status reports 

provided an overly optimistic assessment of progress on the project.19

 

19

We 

also questioned the adequacy of project incentives for ensuring effective 

project management. Specifically, because of cost increases and schedule 

delays, we noted that the incentive fees in the original contract—including 

more than $300 million in potential fees for meeting cost and schedule 

goals or construction milestones—were no longer meaningful. Since that 

time, some problems have continued. For example, Bechtel’s current 

contract, which was modified in 2009, allows the contractor to receive 

substantial incentives, such as an award fee for achieving specified project 

objectives, and DOE has paid this fee, although events subsequently 

revealed that the project was likely to exceed future cost and schedule 

estimates. Since 2009, DOE has paid Bechtel approximately $24.2 million 

or 63 percent of its $38.6 million incentive fee based, in part, on Bechtel’s 

adherence to cost and schedule targets and its resolution of technical 

challenges associated with waste mixing. However, the WTP project is now 

at serious risk of missing major future cost and schedule targets, and it was 

subsequently determined by DOE that the waste mixing technical 

challenges were not resolved after all. According to DOE officials, 

substantial further effort is needed that will take at least an additional 3 

years of testing and analysis until project scientists and engineers can fully 

GAO-06-602T. 
 

Page 22 GAO-13-38 DOE’s Waste Treatment Plant 

resolve this challenge. In the current contract, there is no contractual 

mechanism for recovering an incentive fee that was paid to a contractor for 

work that was subsequently determined to be insufficient, according to 

DOE officials.

Furthermore, under its project management order, DOE is to incorporate 

and manage an appropriate level of risk—including critical technical, 

performance, schedule, and cost risks—to ensure the best value for the 

government.20 However, DOE has no assurance that the incentives 

included in the WTP construction contract are assisting in the effective 

management of these risks. The contract provides that “incentives are 

structured to ensure a strong financial motivation for the Contractor to 

achieve the Contract requirements.”21 However, the contract 

requirements have been, and continue to be, revised to provide for a 

longer schedule and higher cost. For example, DOE has already 

announced that the project will not be completed within the 2006 

performance baseline and has directed the contractor to prepare a 

revised performance baseline. Further, since 2009, DOE has awarded 

$15.6 million in incentive fees to Bechtel for meeting periodic schedule 

and cost goals, even though the WTP’s schedule has slipped, and 

construction costs have continued to increase.22

DOE’s Inspector General has also found that DOE may have awarded 

Bechtel fees without the contractor adequately fulfilling work. A 2012 DOE 

Office of Inspector General report notes that DOE may have overpaid $15 

million of potentially $30 million in incentive fees for the delivery and 

installation of vessels into the WTP facility.

Bechtel has estimated, 

as of May 2012, that costs to complete the project are currently more than 

$280 million over the amount specified in the construction contract.

23

 

20DOE, Program and Project Management for the Acquisition of Capital Assets, DOE 

Order 413.3B (Washington, D.C.: Nov. 29, 2010). The order also states that “aggressive 

risk mitigation strategies are required” for fast-tracked, design-build projects. 

When DOE learned that one 

21Contract No. DE-AC27-01RV14136, § B.4 (conformed through modification No. 287).

22The contract specifically links schedule incentives with overall progress under the 

contract: “Each milestone represents and measures progress towards achieving the 

Contract requirements and do not represent payment for the specific named milestone 

itself.” Contract No. DE-AC27-01RV14136, § B.4(c) (conformed through modification No. 

287).

23DOE Office of Inspector General, Audit Report: The Department of Energy’s $12.2 

Billion Waste Treatment and Immobilization Plant —Quality Assurance Issues—Black Cell 

Vessels, DOE/IG-0863 (Washington, D.C.: April 2012). 
 

Page 23 GAO-13-38 DOE’s Waste Treatment Plant 

of the vessels did not have quality assurance records and therefore did 

not conform to contract requirements, it instructed Bechtel to return $15 

million of the performance fee. However, according to the DOE Office of 

Inspector General report, neither DOE nor Bechtel could provide 

evidence that the fee was returned to DOE.

DOE’s oversight of Bechtel’s activities may also be hampered because 

project reviews, such as external independent reviews or independent 

project reviews—which are a key oversight mechanism—are only 

required by DOE’s project management order to occur at major decision 

points in a project. These reviews examine a project’s estimated cost, 

scope, and schedule and are intended to provide reasonable assurance 

that the project can be successfully executed on time and within budget. 

For example, these independent reviews are to occur when a cost and 

schedule baseline is completed for the project or when construction is 

authorized to begin. A 2006 review conducted by the U.S. Army Corps of 

Engineers, for example, identified serious problems with Bechtel’s 

progress on the WTP project and indicated that the project would 

significantly exceed both cost and schedule targets. 24 In 2009, the Office 

of Project Management also conducted an external independent review. 

Such reviews are an important mechanism for overseeing DOE contractor 

activities. In a large, complex, multiyear project such as WTP, however, 

many years can pass between these critical decision points and the 

associated independent reviews. DOE officials noted that other reviews, 

such as Construction Project Reviews, were also completed between 

2009 and 2011 for the WTP project. While officials stated that these 

reviews did examine the project’s cost and schedule, they noted that the 

reviews were not as extensive as the 2006 and 2009 reviews.

DOE is responsible for one of the world’s largest environmental cleanup 

projects in which it must stabilize large quantities of hazardous and 

radioactive waste and prepare it for disposal at a permanent national 

geologic repository that has yet to be identified. By just about any 

definition, DOE’s WTP project at Hanford has not been a well-planned, 

well-managed, or well-executed major capital construction project. 

Daunting technical challenges that will take significant effort and years to 

 

24U.S. Army Corps of Engineers, Independent Validation Review of the May 2006 

Estimate at Completion for the Hanford Waste Treatment and Immobilization Plant Project 

(U.S. Army Corps of Engineers Walla Walla District: Aug. 28, 2006). 

Conclusions
 

Page 24 GAO-13-38 DOE’s Waste Treatment Plant 

resolve combined with a near tripling of project costs and a decade of 

schedule delays raise troubling questions as to whether this project can 

be constructed and operated successfully. Additional cost increases 

amounting to billions of dollars and schedule delays of years are almost 

certain to occur. DOE and Bechtel officials have stated that the most 

recent cost increases and schedule delays are the result of, among other 

things, Congress not providing the required funding to resolve technical 

issues. In our view, however, the more credible explanation continues to 

be DOE’s decision to build what the department itself describes as the 

world’s largest and most complex nuclear waste treatment plant using a 

fast-track, design-build strategy that is more appropriate for much simpler, 

smaller scale construction projects. Where nuclear industry guidelines 

suggest completing 90 percent of design prior to beginning construction, 

DOE instead began construction when design of the facility was in the 

early stages and insisted on developing new technologies and completing 

design efforts while construction was ongoing. The result has been 

significant design rework, and some already procured and installed 

equipment to possibly be removed, refabricated, and reinstalled.

The technical challenges are especially acute in the WTP’s pretreatment 

and high-level waste facilities. Technologies for these facilities require 

perfect reliability over the plant’s 40-year lifetime because no maintenance 

or repair will be possible once waste treatment begins. According to DOE’s 

analysis, several critical technologies designed for the WTP have not been 

tested and verified as effective. Additional expensive rework in the 

pretreatment and high-level waste facilities, particularly in the area of waste 

mixing, is likely to occur. Further, an additional facility to treat tank waste 

before the waste arrives at the WTP’s pretreatment facility may be 

required. This additional facility could add billions to the cost of treating 

Hanford’s waste. All the while, DOE and outside experts continue to raise 

safety concerns, and Bechtel continues to earn incentive fees for meeting 

specific project objectives even as the project’s costs and timelines balloon 

far beyond the initially planned goals. DOE’s recent actions to identify cost 

savings opportunities and to hold Bechtel accountable for the significant 

deficiencies in its preliminary documented safety analyses and requiring 

the contractor to comply with DOE’s nuclear safety regulations are steps in 

the right direction. However, we continue to have serious concerns not only 

about the ultimate cost and final completion date for this complex project, 

but whether this project can successfully accomplish its waste treatment 

mission given that several critical technologies have not been tested and 

verified.
 

Page 25 GAO-13-38 DOE’s Waste Treatment Plant 

To improve DOE’s management and oversight of the WTP project, we 

recommend that the Secretary of Energy take the following three actions:

• Do not resume construction on the WTP’s pretreatment and high-level 

waste facilities until critical technologies are tested and verified as 

effective, the facilities’ design has been completed to the level 

established by nuclear industry guidelines, and Bechtel’s preliminary 

documented safety analyses complies with DOE nuclear safety 

regulations.

• Ensure the department’s contractor performance evaluation process 

does not prematurely reward contractors for resolving technical issues 

later found to be unresolved. For example, DOE could seek to modify 

its contracts to withhold payment of incentive fees until the technical 

challenges are independently verified as resolved.

• Take appropriate steps to determine whether any incentive payments 

made to the contractor for meeting project milestones were made 

erroneously and, if so, take appropriate actions to recover those 

payments.

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

DOE generally agreed with the report and its recommendations. In its 

written comments, DOE described actions under way to address the first 

recommendation, as well as additional steps it plans to take to address 

each of the report’s recommendations. 

DOE stated that it has recently taken action that is, in part, aligned with 

the first recommendation. Specifically, it issued guidance to the 

contractor, which directed the contractor to address remaining WTP 

technical and management issues sufficient to produce a high confidence 

design and baseline for the pretreatment and high-level waste facilities of 

the WTP. DOE also established a limited construction activity list for the 

high-level waste facility, as well as a much more limited set of 

construction activities in the pretreatment facility, which DOE stated will 

allow it to complete construction of some portions of the facilities while 

taking into account the unresolved technical issues. DOE stated that it 

believes this approach balances the intent of the recommendation and 

the need to continue moving forward with the project and preparations to 

remove waste from Hanford waste storage tanks. While this approach 

appears reasonable, we would caution that DOE should sufficiently 

monitor the construction activities to ensure that additional construction 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 26 GAO-13-38 DOE’s Waste Treatment Plant 

beyond the activities specifically named on the approved list not be 

undertaken until the technical and management issues are satisfactorily 

resolved. DOE also noted that the Secretary of Energy has been actively 

engaged in the development of a new approach to managing the WTP 

and, together with a group of independent subject matter experts, is 

working to resolve long-standing technical issues. As requested by DOE, 

we did incorporate information into the report to indicate the Secretary’s 

personal involvement in addressing the WTP issues and the technical 

teams assembled to help resolve these persistent technical issues. In 

addition, DOE stated that the department and the contractor have 

implemented a plan to assure that the WTP documented safety analysis 

will meet the department’s nuclear safety requirements and DOE 

established a Safety Basis Review Team that will provide a mechanism 

for reviewing the documented safety analyses for each facility to ensure it

meets nuclear safety requirements. DOE’s planned actions to address the 

recommendations in this report are discussed more fully in DOE’s letter, 

which is reproduced in appendix I. DOE also provided technical 

clarifications, which we incorporated into the report as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

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

Secretary of Energy; the appropriate congressional committees; the 

Director, Office of Management and Budget; and other interested parties. 

In addition, the report will be available at no charge on the GAO website 

at http://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or trimbled@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix II.

David C. Trimble

Director

Natural Resources and Environment
Appendix I: Comments from the Department of 

Energy

Page 27 GAO-13-38 DOE’s Waste Treatment Plant 

Appendix I: Comments from the Department 

of Energy
Appendix I: Comments from the Department of 

Energy

Page 28 GAO-13-38 DOE’s Waste Treatment Plant 
Appendix I: Comments from the Department of 

Energy

Page 29 GAO-13-38 DOE’s Waste Treatment Plant 
Appendix I: Comments from the Department of 

Energy

Page 30 GAO-13-38 DOE’s Waste Treatment Plant 
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 31 GAO-13-38 DOE’s Waste Treatment Plant 

David C. Trimble, (202) 512-3841, or trimbled@gao.gov

In addition to the individual named above, Ryan T. Coles and Janet 

Frisch, Assistant Directors; Gene Aloise; Scott Fletcher; Mark Gaffigan; 

Richard Johnson; Jeff Larson; Mehrzad Nadji; Alison O’Neill; Kathy 

Pedalino; Tim Persons; Peter Ruedel; and Ron Schwenn made key 

contributions to this report.

Appendix II: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(361327)
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