GAO 

United States Government Accountability Office

Report to the Subcommittee on Energy 

and Water Development, Committee on 

Appropriations, House of 

Representatives 

NUCLEAR WASTE

Uncertainties and 

Questions about Costs 

and Risks Persist with 

DOE’s Tank Waste 

Cleanup Strategy at 

Hanford 

September 2009 

GAO-09-913 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2009

NUCLEAR WASTE

Uncertainties and Questions about Costs and Risks

Persist with DOE’s Tank Waste Cleanup Strategy at 

Highlights of GAO-09-913, a report to the Hanford 

Subcommittee on Energy and Water 

Development, Committee on 

Appropriations, House of Representatives 

At its Hanford Site in Washington 

State, the Department of Energy 

(DOE) is responsible for one of the 

world’s biggest cleanup projects: 

the treatment and disposal of about 

56 million gallons of radioactive 

and hazardous waste, stored in 177 

underground tanks. Two decades 

and several halted efforts later, 

none of this waste has yet been 

treated, cleanup costs have grown 

steadily, and prospective cleanup 

time frames have lengthened. 

GAO was asked to assess (1) DOE’s 

current tank waste cleanup 

strategy and key technical, legal, 

and other uncertainties; (2) the 

extent to which DOE has analyzed 

whether this strategy is 

commensurate with risks from the 

wastes; and (3) opportunities to 

reduce tank waste cleanup costs. 

GAO reviewed pertinent 

documents, visited the site, and 

interviewed officials and 

independent experts. 

What GAO Recommends

GAO is recommending that, for 

Hanford, DOE (1) improve its lifecycle cost and schedule estimates, 

(2) adopt a risk assessment 

framework that considers available 

guidance, (3) consider seeking 

congressional clarification about 

reclassifying its high-level tank 

waste, and (4) work with regulators 

on tank closure options. DOE 

agreed with three of these; it 

disagreed with seeking further 

clarification about reclassifying 

high-level waste. GAO believes this 

recommendation remains valid, 

given the importance of waste 

reclassification to DOE’s strategy. 

DOE’s tank waste cleanup strategy consists of five key phases—waste 

characterization, retrieval, pretreatment, treatment, and permanent disposal—

but critical uncertainties call into question whether the strategy can succeed 

as planned. Technical uncertainties include whether DOE can retrieve waste 

from tanks at the rate needed to support continuous operation of the waste 

treatment complex now under construction and whether key treatment 

technologies will work. Legal uncertainties include whether DOE can treat 

and dispose of some tank waste as other than high-level (highly radioactive) 

waste and how much residual waste can be left in the tanks when they are 

eventually closed. Such uncertainties could lead to significant cost increases 

and further delays in completing Hanford’s tank waste cleanup activities. 

DOE has not systematically evaluated whether its tank waste cleanup strategy 

is commensurate with risks posed by the wastes. DOE lacks credible or 

complete estimates of how much the strategy will cost or how long it will 

take. The total project cost of constructing the waste treatment plant alone 

grew from $4.3 billion in 2000 to $12.3 billion in 2006. In addition, DOE did not 

include, or has been unable to quantify, a number of significant costs in its 

current estimate of the overall cost of its cleanup strategy. For example, DOE 

has not included some actual expenditures to date or storage costs for highlevel waste canisters. Further, DOE’s schedule targets have slipped, with end 

of treatment extending from 2028 to 2047, which increases overall operations 

costs. Overall the total estimated cost could significantly exceed DOE’s 

current estimate of $77 billion, with estimates ranging from about $86 

billion to over $100 billion, depending upon the date cleanup is completed. 

DOE has also fallen short in terms of risk-informed decision making. While 

DOE has analyzed risks in environmental impact statements required for its 

tank waste treatment activities at Hanford, it has not followed a systematic 

risk assessment framework, like one outlined in a 1983 report, updated in 

2008, by the National Academy of Sciences. As a result, DOE cannot be 

assured that its present strategy is proportional to the reduction in risk that 

cleanup is to achieve. 

Some opportunities may still exist to reduce the costs of DOE’s tank waste 

cleanup strategy, but the likelihood of success is unknown. For example, DOE 

is trying to increase the concentration of high-level waste in each disposal 

canister, thereby reducing the number of canisters and possibly shortening 

treatment time frames. DOE could also work with regulators to demonstrate, 

on a tank-farm basis, the feasibility of leaving varying amounts of residual 

waste in tanks at closing without threatening human or ecological health. In 

removing waste from tanks, DOE has found that the last portion can be 

disproportionately difficult and costly to remove. Specifically, the cost of 

removing the last 15 percent of waste can equal or exceed the cost of 

removing the first 85 percent. View GAO-09-913 or key components. 

For more information, contact Gene Aloise at 

(202) 512-3841 or aloisee@gao.gov. 
Page i GAO-09-913 

Contents 

Letter 1

Background 4 

Critical Uncertainties Persist in DOE’s Hanford Tank Waste 

Cleanup Strategy 8 

DOE Has Not Systematically Evaluated Whether Its Tank Waste 

Cleanup Strategy, Including Costs, Is Commensurate with Risks 

from the Waste 16 

Some Opportunities May Exist to Reduce Costs of DOE’s Hanford 

Tank Waste Cleanup Strategy 26 

Conclusions 30 

Recommendations for Executive Action 31 

Agency Comments and Our Evaluation 31 

Appendix I Scope and Methodology 38 

Appendix II Overview of DOE’s Efforts to Select an Approach to 

Supplement Its Low-Activity Tank Waste Treatment 

Capacity 41 

Appendix III Comments from the Department of Energy 45 

Appendix IV GAO Contact and Staff Acknowledgments 50 

Related GAO Products 51 

Table 

Table 1: Estimated Costs Associated with DOE’s Tank Waste 

Cleanup Strategy 22 

Hanford Tank Waste Cleanup Strategy 
Figures 

Figure 1: Changes in Hanford’s Tank Waste Cleanup Strategy, 1989 

to Present 8 

Figure 2: Key Phases in DOE’s Tank Waste Cleanup Strategy 10 

Figure 3: Cost Estimates for Constructing Hanford’s Waste 

Treatment Plant 18 

Figure 4: Shifting Estimates of the Duration of Hanford Tank Waste 

Treatment 21 

Abbreviations 

CERCLA Comprehensive Environmental Response, Compensation, 

and Liability Act 

DOE Department of Energy 

EPA Environmental Protection Agency 

RCRA Resource Conservation and Recovery Act 

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Page ii GAO-09-913 Hanford Tank Waste Cleanup Strategy
Page 1 GAO-09-913 

 

United States Government Accountability Office

Washington, DC 20548 

 

September 30, 2009 

The Honorable Peter J. Visclosky 

Chairman 

The Honorable Rodney P. Frelinghuysen 

Ranking Member 

Subcommittee on Energy and Water Development 

Committee on Appropriations 

House of Representatives 

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

largest environmental cleanup programs: the treatment and disposal of 

nuclear waste created as a by-product of producing nuclear weapons. 

Decades of nuclear weapons production have left a legacy of radioactive 

and hazardous wastes to be cleaned up at DOE sites across the country. 

One of DOE’s most contaminated locations is its Hanford Site, which lies 

along the Columbia River in southeastern Washington State. The site 

occupies 586 square miles upriver from the Tri-Cities area of Richland, 

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

200,000. DOE and its predecessor agencies1

 produced nuclear materials at 

the Hanford Site from 1944 through 1988, generating millions of gallons of 

radioactive and hazardous waste during those years. Some of this waste 

was deposited directly into the soil; some was encased in drums or other 

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

tanks. In total, these tanks, clustered together in 18 locations called tank 

farms, contain about 56 million gallons of waste—enough to cover an 

entire football field to a depth of over 150 feet, or the height of a 15-story 

building. 

Since plutonium production ended at Hanford in the late 1980s, DOE has 

spent more than $12 billion2

 to manage the tank waste and explore ways to 

treat and dispose of it. After beginning and discontinuing several different 

tank waste cleanup strategies, DOE has now embarked on a strategy that 

involves building a complex of treatment facilities, collectively called the 

1

DOE has managed the Hanford Site since 1977. Before then, the site was managed by the 

U.S. Army Corps of Engineers (1943-47), the Atomic Energy Commission (1947-75), and the 

Energy Research and Development Administration (1975-77). 

2

Unless otherwise specified, all cost numbers come from DOE and are reported in current 

dollars. 

Hanford Tank Waste Cleanup Strategy 
 

Hanford Waste Treatment and Immobilization Plant. Currently under 

construction and estimated to cost $12.3 billion to design, build, and 

commission, this waste treatment plant consists of a laboratory for 

analyzing the waste’s composition; a pretreatment plant to separate the 

waste into two streams (a highly radioactive fraction called high-level 

waste and a lower-radioactivity fraction called low-activity waste); two 

waste treatment facilities, one for high-level waste and one for low-activity 

waste; and more than 20 support facilities. DOE estimates that it will cost 

tens of billions of dollars and take until 2047 to complete tank waste 

cleanup and permanently close the underground storage tanks. To date, 

however, no tank waste at Hanford has been treated for final disposal, and 

none of the tanks has been permanently closed. 

DOE’s cleanup, treatment, and disposal of radioactive and hazardous 

wastes are governed by a number of federal and state laws and 

implemented under the leadership of DOE’s Assistant Secretary for 

Environmental Management. Key laws include the Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980 

(CERCLA), as amended, and the Resource Conservation and Recovery Act 

of 1976 (RCRA), as amended.3

 In addition, most of the cleanup activities at 

Hanford, including emptying the underground tanks, are carried out under 

the Hanford Federal Facility Agreement and Consent Order among DOE, 

the Washington State Department of Ecology, and the federal 

Environmental Protection Agency (EPA).4

 Commonly called the Tri-Party 

Agreement, this accord was signed in May 1989 and has been amended a 

number of times since then. The agreement lays out a series of legally 

enforceable milestones for completing major activities in Hanford’s waste 

treatment and cleanup process. A variety of local and regional 

stakeholders, including county and local government agencies, citizen and 

advisory groups, and Native American tribes, also have long-standing 

interests in Hanford cleanup issues. Like nearly all of DOE’s missions, the 

majority of the work at the Hanford Site is performed by private firms 

under contract to DOE. Cleanup activities employ thousands of people in 

 

3

42 U.S.C. 9601 et seq. (CERCLA); 42 U.S.C. 6901 et seq. (RCRA). 

4

Since 2007, DOE has been renegotiating Tri-Party Agreement milestones that it has missed 

or believes it will miss, such as the starting date of waste treatment operations. In 2008, the 

state of Washington filed suit against DOE, claiming DOE violated the Tri-Party Agreement 

by missing enforceable milestones, including tank retrieval and treatment milestones. On 

August 10, 2009, DOE and the state announced they had reached a tentative settlement, 

including agreement on new cleanup milestones. A 2047 completion date was agreed to by 

DOE and its regulators in the tentative settlement. 

Page 2 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

the private and public sectors, thus contributing significantly to the 

economy of the Tri-Cities area. 

As requested, this report discusses (1) Hanford’s current tank waste 

cleanup strategy and key associated technical, legal, and other 

uncertainties; (2) the extent to which DOE has determined whether its 

cleanup strategy at Hanford is commensurate with risks posed by the 

wastes; and (3) opportunities for DOE to reduce the costs of cleaning up 

Hanford’s tank waste while still protecting human health and the 

environment. 

To address these objectives, we gathered and reviewed information on the 

Hanford waste cleanup strategy, including technical reports and internal 

and external reviews. We reviewed legal and regulatory requirements 

governing cleanup of hazardous and radioactive wastes, including 

requirements for determining whether some tank wastes can be classified 

as other than high-level waste. We also reviewed the Tri-Party Agreement 

to gain an understanding of its requirements and time frames. Several key 

documents were released by DOE just before, or were scheduled to be 

released shortly after, the date of this report. These included a tentative 

legal settlement with the state of Washington, an amended Tri-Party 

Agreement, a draft environmental impact statement for tank closure, and a 

new cost and schedule baseline for the Hanford tank waste cleanup effort. 

We reviewed an August 10, 2009, version of the tentative legal settlement 

and were provided access to a version of the draft environmental impact 

statement, but the remaining documents were not available at the time of 

our review. These documents are discussed in our report and factored into 

its conclusions and recommendations as available and appropriate. As 

agreed with DOE, we included only publicly available information about 

the draft environmental impact statement in our report. In addition, we 

interviewed officials at the Hanford Site’s Office of River Protection and at 

DOE headquarters, including in the Office of Engineering and 

Construction Management and the Office of Environmental Management. 

We interviewed contractor officials at the Hanford Site responsible for 

building the waste treatment plant. We also visited the Hanford Site, 

including the waste treatment plant construction site. We interviewed 

officials with regulatory and other agencies, specifically, the Washington 

State Department of Ecology, EPA, the Nuclear Regulatory Commission, 

and the Defense Nuclear Facilities Safety Board. To assist in 

understanding concerns with various aspects of Hanford’s tank waste 

cleanup strategy, we interviewed staff at the National Academy of 

Sciences. In addition, we identified and interviewed 18 independent 

experts for their input on various aspects of DOE’s Hanford tank waste 

Page 3 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

cleanup strategy. We provided an interim briefing in May 2009 to the 

subcommittee on the status of our work. Appendix I describes our scope 

and methodology in more detail. We conducted this performance audit 

from July 2008 to September 2009, in accordance with generally accepted 

government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives. 

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

first nuclear device. At the time, little attention was given to the resulting 

by-products—massive amounts of radioactive and chemically hazardous 

waste. From 1944 through 1988, about 525 million gallons of radioactive 

tank waste was generated by Hanford’s plutonium-processing plants. The 

federal government initially managed this waste by intentionally 

discharging it into the ground; reducing its volume through various waste 

concentration methods, such as evaporating off the liquids; and building 

underground tanks to store the waste until it could be treated and 

permanently disposed of. 

Background 

From the 1940s through the mid-1960s, 149 underground “single-shell” 

storage tanks were built at Hanford. Originally expected to last 10 to 20 

years until a permanent disposal solution could be found, each of these 

tanks consisted of an outer concrete wall lined with one layer of carbon 

steel. Grouped into 12 tank farms and buried some 6 to 11 feet beneath the 

surface, most of these single-shell tanks measure roughly 75 feet in 

diameter, range from 30 to 49 feet high, and have a capacity ranging from 

530,000 to 1 million gallons of waste.5

 Together, the single-shell tanks 

contain almost 30 million gallons of waste; about 27 million gallons are in 

solid or semisolid form, and about 3 million gallons are liquid. By the mid1990s, 67 of the single-shell tanks had leaked or were presumed to have 

leaked about 1 million gallons of waste into the surrounding soil. To 

address concerns with the design of the single-shell tanks, a new tank 

design with two carbon-steel shells was adopted in the late 1960s. From 

1968 through 1986, 28 of these double-shell tanks, with storage capacities 

ranging from 1 million to 1.2 million gallons, were built and sited in 6 more 

 

5

Sixteen of Hanford’s 149 single-shell tanks are much smaller, with a storage capacity of 

55,000 gallons. 

Page 4 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

tank farms at Hanford. Together, these double-shell tanks contain about 

26 million gallons of waste.6

 To help minimize further leaking, DOE had, 

by 2005, transferred most of the liquid in the single-shell tanks to the 

double-shell tanks, a process called interim stabilization. DOE is cur

retrieving the remaining waste from single-shell tanks and moving it to the 

double-shell tanks in preparation for treatment.

rently 

 

7

The contents of these tanks have settled and today exist in four main 

forms or layers: 

• Vapor: Gases produced from chemical reactions and radioactive decay 

occupy tank space above the waste. 

• Liquid: Fluids may float above a layer of settled solids or under a floating 

layer of crust; fluids may also seep into pore spaces or cavities of settled 

solids, crust, or sludge. 

• Saltcake: Water-soluble compounds, such as sodium salts, can crystallize 

or solidify out of wastes to form a moist saltlike hardened or crusty 

material. 

• Sludge: Denser, water-insoluble or solid components generally settle to 

the bottom of a tank to form a thick layer having the consistency of peanut 

butter. 

About 46 different radioactive elements—by-products of chemically 

separating plutonium from uranium for use in nuclear weapons—

represent the majority of the radioactivity currently residing in the tanks. 

Some of these elements lose most of their radioactivity in a relatively short 

time, while others remain radioactive for millions of years. The rate of 

radioactive decay is measured in half-lives, that is, the time required for 

half the unstable atoms in a radioactive substance to disintegrate, or 

decay, and release their radiation. The half-lives of major radioactive tank 

constituents differ widely. The vast majority (98 percent) of the tank 

6

The total volume of waste in all of Hanford’s underground tanks fluctuates over time as 

DOE carries out its tank waste cleanup process. 

7

Hanford’s underground storage tanks were not designed with specific waste retrieval 

features. Waste must be retrieved through openings, called risers, in the top of the tanks. 

Technicians must therefore insert specially designed pumps into the tanks to pump the 

waste up about 45 to 60 feet to ground level. Removing waste from the tanks that have 

already leaked without releasing still more material into the soil also poses a challenge, 

which DOE is trying to address with new retrieval technologies. 

Page 5 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

waste’s radioactivity comes from two elements, strontium-90 and cesium137, which have half-lives of about 29 and 30 years, respectively. The 

remaining radioactive elements, which account for about 2 percent of the 

waste’s total radioactivity, have much longer half-lives. For example, the 

half-life of technetium-99 is 213,000 years, and that of iodine-129 is 

15.7 million years. As we reported in 2003 on the basis of radioactivity 

levels measured as of August 2002, within 100 years, more than 90 percent 

of the radioactivity in the tanks will have dissipated, and within 300 years, 

99.8 percent will disappear.8

 After the waste is separated, the high-level 

waste stream will contain over 95 percent of the radioactivity but total less 

than 10 percent of the volume to be treated. In comparison, the 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. Like 

radioactive by-products of plutonium production, some of these 

chemicals—including acids, caustic sodas, solvents, and toxic heavy 

metals such as chromium—came from chemically reprocessing spent 

nuclear fuel to extract weapons-grade plutonium. Altogether, DOE added 

about 240,000 tons of chemicals to the tanks from the 1940s to the mid1980s. A majority of the chemicals (caustics, such as sodium hydroxide) 

were added to neutralize acids in the waste. Other chemicals, such as 

solvents, ferrocyanide, and several organic compounds, were added during 

various waste extraction operations to help recover selected radioactive 

elements (uranium, cesium, and strontium) for reuse. These hazardous 

chemicals are dangerous to human health, and they can remain dangerous 

for thousands of years. 

Over the past 20 years, DOE has tried developing various approaches for 

treating and disposing of these wastes, at varying costs and with little 

success (see fig. 1). In 1989, DOE’s original strategy called for treating 

waste only from the double-shell tanks. Part of this effort involved 

renovating a World War II-era facility, called B Plant,9

 in which it planned 

to start waste treatment. DOE spent about $23 million on this project but 

 

8

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). 

9

B Plant was originally used to recover plutonium for nuclear weapons. In the early 1960s, 

it was refurbished and used to remove certain high-level radioactive materials from the 

tank wastes. 

Page 6 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

discontinued it because of technical and environmental issues and 

stakeholder concerns that not all the waste would be treated. In 1991, DOE 

decided to treat waste from all 177 tanks. Under this strategy, DOE would 

have completed the treatment facility before other aspects of the waste 

treatment program were fully developed, and the planned treatment 

facility would have had insufficient capacity to treat all the waste in a time 

frame acceptable to regulators. DOE spent about $418 million on this 

approach. Beginning in 1995, DOE attempted to “privatize” tank waste 

cleanup, shift risk to its contractor,10 build a demonstration facility to treat 

10 percent of the waste and 25 percent of the radioactivity by 2018, and 

end cleanup in 2028. But because of dramatically escalating costs and 

concerns about contractor performance, DOE terminated the contract 

after spending about $300 million, mostly on plant design. According to 

available information, since 1997 DOE has spent an average of more than 

$300 million each year on tank management and risk reduction activities, 

such as retrievals and facility upgrades. 

 

10Under its privatization approach, DOE planned to set a fixed price and pay the contractor 

for canisters and containers of immobilized tank waste that complied with contract 

specifications. If costs grew as a result of contractor performance problems, the 

contractor, not DOE, was to bear these cost increases. Any cost growth occurring as a 

result of changes directed by DOE was to result in an adjustment to the contract price and 

was to be borne by DOE. 

Page 7 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

Figure 1: Changes in Hanford’s Tank Waste Cleanup Strategy, 1989 to Present 

1989

1991 1999

1999

1995 2002 2007

2000 2011 2019

Source: GAO analysis of DOE data.

1990 1995 2000 2005 2010 2015 2020

Renovate existing facility: treat double-shell tank waste

Estimated cost: $2.8 billion (constant 1988 dollars)

Planned start 

of treatment

Build new facility: treat all tank waste

Estimated cost: $25 billion–$45 billion (current dollars)

Planned start 

of treatment

Build demonstration facility: treat 10 percent of waste first

Estimated cost: more than $50 billion (current dollars)

Planned start 

of treatment

Revised start 

of treatment

Current tank waste cleanup strategy

Estimated cost: about $80 billion (current dollars)

Planned start 

of treatment

Revised start 

of treatment

Note: When estimating costs for its cleanup strategies, DOE has not always included adequate 

contingency funding for unforeseen circumstances. The $80 billion estimate for DOE’s current 

strategy includes such contingency funding of about $19 billion. 

Critical uncertainties, such as technical and legal issues, call into question 

whether DOE’s strategy to treat and dispose of millions of gallons of 

radioactive and hazardous tank wastes at its Hanford Site can succeed as 

planned. 

Critical Uncertainties 

Persist in DOE’s 

Hanford Tank Waste 

Cleanup Strategy 

Page 8 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

DOE’s current strategy generally consists of removing, or retrieving, waste 

from the underground tanks; separating the wastes into high-level and lowactivity waste streams through a process called pretreatment; treating the 

waste on site; and ultimately disposing of the low-activity waste on site 

and sending the high-level waste to a geologic repository for permanent 

disposal (see fig. 2). Specifically, the five key phases are: 

DOE’s Waste Treatment 

Strategy Consists of Five 

Key Phases 

• Characterization: Sampling and analysis to determine the specific 

physical, radiological, and chemical components of the wastes in each 

tank. Waste is sampled and analyzed starting before it is retrieved from the 

tanks and continuing until it is ready for final treatment. 

• Retrieval: Removing waste from the tanks by pumping or other means and 

transferring it to the treatment facilities. DOE uses a variety of 

technologies, including high-pressure sprays to break up hardened waste 

on the tank bottom and vacuum systems to suck the waste out of the 

tanks. Because a large amount of liquid may be introduced during retrieval 

to break up hardened waste, waste removed from a tank is transferred to a 

facility to evaporate some of the liquid and reduce its volume before being 

sent to the waste treatment plant.11

• Pretreatment: Mixing and separating waste constituents into high-level 

and low-activity waste streams by filtering, dissolving, and extracting 

radioactive from nonradioactive constituents such as aluminum, 

chromium, and salts. DOE uses a variety of technologies to extract 

specific radioactive and hazardous materials during this pretreatment 

phase. 

• Treatment: Immobilizing the radioactive and hazardous constituents in 

glass through a process called vitrification. The entire high-level waste 

stream, and about half the low-activity waste, is to be immobilized in the 

waste treatment plant by mixing it with a glass-forming material, melting 

the mixture into glass in two vitrification facilities—one for high-level 

waste and a second for low-activity waste—and pouring the vitrified waste 

into stainless-steel canisters (high-level waste) or containers (low-activity 

waste) to cool and harden. 

 

11DOE estimates that additional liquid introduced into the tanks may amount to three or 

four times the volume of waste in the tanks, or 176 million gallons for single-shell tanks. 

DOE does not have an estimate of the additional liquid that will be added to the doubleshell tanks during retrieval. 

Page 9 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

• Final disposal: Storing high-level waste canisters temporarily on site until 

a permanent geologic repository opens and then permanently disposing of 

it in a designated geologic repository and disposing of the low-activity 

waste on site in a designated disposal landfill. Tanks will be closed 

permanently after as much waste as technically possible has been 

removed. 

Figure 2: Key Phases in DOE’s Tank Waste Cleanup Strategy 

Retrieving waste from 

tanks and preparing 

for treatment

Single-shell

tanks

Double-shell

tanks

Characterization Retrieval Pretreatment Treatment Final disposal

Sampling and analyzing

the waste throughout 

preparation for treatment

Vitrifying high-level 

waste and placing it 

into stainless-steel 

canisters

Vitrifying low-activity 

waste and placing it 

into stainless-steel 

containers

Storing high-level waste 

canisters temporarily on 

site until permanent 

repository opens

Storing low-activity 

waste containers

permanently on site 

in landfill

Sources: GAO and DOE.

Mixing and separating

waste constituents

into high-level and

low-activity waste streams

Technical Uncertainties at 

Each Phase Could 

Threaten Cleanup Success 

DOE faces critical technical uncertainties, including whether the pace of 

retrieving waste from the tanks will be sufficient to keep the waste 

treatment plant operating as planned and whether key treatment 

technologies will work. Unless DOE successfully resolves these 

uncertainties, it could face problems, such as facility shutdowns, facility 

modifications and retrofitting, or significant cost increases and delays in 

completing Hanford’s tank waste cleanup activities. 

Page 10 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

DOE plans to rely on new systems to collect and analyze waste samples, 

but the performance of these new systems has not yet been fully 

demonstrated, although DOE continues to test them. It is unclear, for 

example, whether these systems will be able to complete the more than 

10,000 samples needed each year to ensure that the waste’s composition is 

understood and meets the criteria for treatment and disposal. A sampling 

and analysis rate of 10,000 samples per year for the new analytical 

laboratory is several times the rate that samples have been taken and 

analyzed in existing Hanford laboratories. Given that waste sampling and 

analysis are to occur throughout preparation of the waste for treatment, a 

backlog in this system could substantially slow the overall waste treatment 

process. DOE officials told us that they recognize this uncertainty and that 

they are working to reduce the number of samples that will need to be 

analyzed. 

It Is Unclear Whether Systems 

Designed to Characterize the 

Waste Will Operate at the Rate 

Planned 

DOE’s strategy assumes that transferring waste from the single-shell tanks 

into the double-shell tanks (for mixing and blending before treatment) will 

progress faster than experience to date suggests. It is unclear, however, 

whether DOE can increase its retrieval rate to adequately supply waste to 

the waste treatment plant on a continuous, long-term basis when the plant 

begins operating in 2019, as currently planned. Since 2003, DOE has 

emptied 7 tanks—about 1 tank per year.12 According to an August 2009 

tentative legal settlement, DOE has agreed to retrieve 10 tanks over the 

next 5 years—or an increase to 2 tanks per year. Even if DOE is successful 

in retrieving this number of tanks, it is uncertain whether sufficient space 

is available in the double-shell tanks to hold this waste. Further, according 

to DOE officials, to provide adequate waste feed to the pretreatment 

facility, waste retrieval will need to increase to an average of 5 to 7 tanks 

per year when operation of the waste treatment plant begins. Even if DOE 

is successful in retrieving waste at this rate from the single-shell tanks, the 

waste must again be retrieved from the double-shell tanks to feed into the 

pretreatment facility. Retrieving the waste in an uninterrupted manner 

over several decades requires enough trained personnel; equipment and 

infrastructure such as pumps, transfer lines, monitoring equipment, and 

scaffolding around the tanks; and a place to transfer and store waste 

removed from the tanks. A 2008 DOE report noted that tank waste 

retrieval rates could become the limiting process in maintaining the 

DOE May Have Difficulty 

Retrieving Waste from the 

Tanks at Planned Rates 

 

12DOE is limited in the amount of waste it can retrieve from single-shell tanks, in part 

because of limited storage capacity in the double-shell tanks. Although the double-shell 

tanks have an estimated capacity of slightly over 32 million gallons, as of June 2009 (the 

latest data available), they already contained nearly 26 million gallons of waste. 

Page 11 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

overall treatment schedule.13 Nevertheless, DOE officials told us they 

believe they will gain enough experience in retrieving waste over the next 

10 years that increasing the retrieval rates will not be a problem. 

In 2006, an external team of experts reported that several problems and 

uncertainties with technologies designed to remove particular radioactive 

and hazardous constituents from the waste streams could make the 

pretreatment facility difficult to operate and maintain. Specifically, the 

experts noted the potential for plugging of piping that transports the waste 

through the facility; inadequate filtering to remove certain constituents, 

such as aluminum and chromium; and insufficient mixing of the waste 

before and during pretreatment. To address these problems, DOE built a 

test facility called the pretreatment engineering platform to test and 

demonstrate selected pretreatment technologies using simulated tank 

wastes.14 On the basis of preliminary results, DOE has adjusted the 

pretreatment technologies and believes that several potential problems 

have been mitigated. Although final test results have not been disclosed, 

DOE officials report that the first testing phase appears to be successful. 

Still, DOE has tested the systems in the pretreatment engineering platform 

using only simulated waste, and according to some independent experts 

we spoke with, using simulated waste to test a new system may not 

uncover all potential problems. Thus, until the pretreatment facility is 

operating with real waste, it will remain unclear how well the 

pretreatment technologies will perform. DOE’s 2008 report noted that any 

single-point failure in pretreatment capabilities could halt operation of the 

entire waste treatment plant. 

Failure of Pretreatment 

Technologies Could Shut Down 

the Entire Waste Treatment 

Operation 

In addition to other rate-limiting uncertainties, questions persist over how 

to treat all the low-activity waste—about 90 percent of the total volume of 

waste that must be treated. At present, the low-activity waste vitrification 

facility is to process only about half the anticipated amount of low-activity 

waste by midcentury, when DOE hopes to complete treatment of highlevel waste. Without supplemental capacity, DOE has estimated that tank 

waste cleanup could last as long as the 2090s. Over the years, DOE has 

taken steps to evaluate various supplemental options for treating lowUncertainties over Waste 

Treatment Plant Capacity 

Complicate Treatment Time 

Frames 

 

13Department of Energy, External Technical Review of System Planning for Low-Activity 

Waste Treatment at Hanford (Washington, D.C., November 2008). 

14The pretreatment engineering platform also partially addresses a recommendation we 

made in 2003 to pilot-test pretreatment technologies before full-scale operation. See 

GAO-03-593. 

Page 12 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

activity waste, and the department has an environmental impact statement 

under way that includes further evaluation of supplemental treatment 

options (see app. II). Nevertheless, the department has indicated that it is 

planning on a second vitrification facility specifically for low-activity 

waste. The amount of low-activity waste that will ultimately need 

treatment depends in large part on the amount of sodium in this waste 

stream. Sodium hydroxide, which was added to the tanks to control 

corrosion, is also added during pretreatment to help dissolve and remove 

aluminum from the waste. Adding sodium helps reduce the volume of the 

high-level waste stream but increases the volume of the low-activity waste 

stream. DOE is still studying how much sodium is likely to be needed, and 

if this amount is large, treatment time frames could be lengthened by 

several years. Building another vitrification facility—which, like the 

existing high-level and low-activity vitrification facilities, would depend on 

the same series of characterization, retrieval, and pretreatment 

processes—could worsen such potential bottlenecks. That is, because 

DOE has no alternative to the pretreatment facility, if this facility fails, the 

entire treatment operation, including all three vitrification facilities, could 

come to a halt. 

While DOE’s plan to permanently dispose of Hanford’s vitrified lowactivity tank waste in an on-site landfill has been approved by state 

regulators, final disposition of the vitrified high-level wastes has become 

less certain. DOE had planned to store this waste temporarily at Hanford 

until it could be shipped to Yucca Mountain, Nevada, the designated 

repository for the nation’s spent fuel and high-level waste.15 DOE has been 

developing a license application for constructing the repository and in 

June 2008 submitted this application to the Nuclear Regulatory 

Commission for review. In March 2009, however, the Secretary of Energy 

announced that Yucca Mountain would no longer be the final repository 

for the nation’s nuclear waste and in its fiscal year 2010 budget 

justification, DOE proposed to eliminate all project funding, except 

$197 million, primarily for licensing activities. If no other high-level waste 

repository is established, DOE sites, including Hanford,16 could end up 

The Permanent Storage 

Location for High-Level Waste 

Has Become Uncertain 

 

15Congress approved the Yucca Mountain site in 2002. Pub. L. No. 107-200, 116 Stat. 735 

(2002). 

16DOE’s budget justification noted that the administration intends to convene a panel of 

experts to evaluate alternative approaches for meeting the federal responsibility to manage 

and ultimately dispose of spent nuclear fuel and high-level radioactive waste from both 

commercial and defense activities. The panel is to provide recommendations that will form 

the basis for working with Congress to revise the statutory framework for managing and 

disposing of spent nuclear fuel and high-level radioactive waste. 

Page 13 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

storing their high-level waste canisters on site indefinitely. Hanford’s 

existing temporary storage facility can accommodate only 880 high-level 

waste canisters; at DOE’s currently expected production rates of more 

than 500 canisters of vitrified high-level waste per year, Hanford will run 

out of storage space less than 2 years after treatment operations begin, or 

as early as 2021. Consequently, Hanford officials told us they are exploring 

ways to provide additional temporary high-level waste storage space on 

site. DOE plans to look at a range of options, one of which could entail 

building additional modular storage facilities that could initially store 

about 2,000 to 4,000 high-level waste canisters, with future expansion for 

an additional 12,000 to 14,000 canisters if necessary. Until a final decision 

is made about permanent disposal of high-level waste, neither the extent 

of additional storage capacity needed on site nor associated costs will be 

known. 

Legal and Regulatory 

Uncertainties May Limit 

DOE’s Ability to Carry Out 

Certain Aspects of Its Tank 

Waste Cleanup Strategy as 

Planned 

DOE’s tank waste cleanup strategy faces two key legal and regulatory 

challenges. First, DOE’s plans assume that the department will obtain 

regulatory approval to reclassify some tank waste as transuranic waste, 

thereby reducing the overall amount of high-level waste to be treated.17

Second, because the tank waste is managed as high-level waste and the 

technology to remove all of it from the tanks either does not exist or is 

extremely costly to use, DOE could face potential legal hurdles in leaving 

any radioactive waste in the bottom of the tanks at closing since the tanks 

are not considered permanent storage facilities for high-level waste. 

DOE believes that waste in 11 single-shell tanks, nearly 1.5 million gallons 

(of about 56 million gallons of waste at Hanford), can be treated and 

disposed of as transuranic, rather than high-level, waste.18 According to a 

DOE official, the waste in these tanks comes largely from chemical 

additives and other processes, not directly from the reprocessing of spent 

nuclear fuel that generates high-level waste. In addition, DOE believes that 

the tanks’ contents are not radioactive enough to warrant the heavy 

Regulatory Approval Uncertain 

for DOE to Treat Some Waste 

as Transuranic Waste 

 

17The term transuranic generally applies to wastes containing radionuclides (radioactive 

elements) with atomic numbers higher than 92 (uranium’s atomic number) and half-lives 

longer than 20 years in concentrations exceeding 100 nanocuries (a measure of 

radioactivity) per gram. 

18DOE’s transuranic wastes are destined for transfer to and final disposal at the Waste 

Isolation Pilot Plant, a geologic repository in Carlsbad, New Mexico. 

Page 14 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

shielding needed to protect workers when they handle high-level waste. 

DOE’s present tank waste treatment strategy assumes that the department 

will be able to reclassify and treat this waste as transuranic waste, at a 

cost of $233 million. Before DOE can go ahead with this plan, however, it 

will have to gain a series of regulatory approvals from EPA, the 

Washington State Department of Ecology, and the state of New Mexico, 

each of which has previously expressed reservations. In 2007, EPA raised 

doubts as to whether the waste qualified as transuranic waste and asked 

DOE for further substantiating documentation. Ecology must approve 

DOE’s plans to retrieve and treat the transuranic tank waste and package 

it for final disposal, but Ecology officials told us they are reluctant to 

approve any treatment plans until DOE receives assurance that New 

Mexico will accept the waste in its geologic repository. And New Mexico, 

which has been reluctant to accept any waste once regarded as high-level 

waste, may decide not to allow disposal of Hanford’s tank waste at its 

repository. If regulators do not approve DOE’s plans for this waste, the 

schedule—and associated costs—of operating Hanford’s waste treatment 

plant could increase by 1 year and about $1 billion. 

Under the Tri-Party Agreement, DOE must retrieve as much waste as 

technically possible from Hanford’s single-shell tanks. Any waste left in 

the tanks, along with the tanks themselves, could be considered high-level 

waste, which would not be permitted to stay in the ground but would have 

to be disposed of in a geologic repository. DOE has a process (spelled out 

in its order 435.1 and associated guidance manual) for determining 

whether high-level waste can be reclassified as another waste type, and it 

plans to use this process to allow residual waste to remain in Hanford’s 

tanks when they are permanently closed. DOE’s authority to apply this 

order to certain high-level waste, however, was challenged in a 2002 

lawsuit, which eventually failed on procedural grounds.19 Meanwhile, in 

2004 DOE sought legislation clarifying its authority to reclassify high-level 

waste, but although Congress enacted legislation allowing waste 

reclassification at two other sites, the relevant provision of the law 

specifically excluded Hanford.20 This conclusion could leave DOE open to 

further legal challenges if the department followed its reclassification 

process to close Hanford’s tanks. And if DOE lost such a challenge, it 

could be forced to exhume Hanford’s tanks, and any residual waste, and 

DOE Could Face Legal 

Challenges over Leaving 

Residual Waste in the Tanks at 

Closure 

 

19Natural Resources Defense Council v. Abraham, 271 F.Supp.2d 1260 (D.Idaho 2003), 

vacated as unripe 388 F.3d 701 (9th Cir. 2004). 

20Pub. L. No. 108-375, Div. C, Title XXXI, § 3116, 118 Stat. 2162 (2004). 

Page 15 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

dispose of it all in a geologic repository (called clean closure). In 2004, 

DOE estimated that this scenario could add delays and more than 

$19 billion to Hanford’s cleanup costs. 

As the National Academy of Sciences and others have pointed out, a 

number of factors warrant consideration when undertaking a project of 

the magnitude of DOE’s cleanup mission. Among these are costs, risks to 

human and ecological health, and cultural and societal impacts. Yet DOE 

lacks much of the information it would need to weigh these factors fully. 

DOE Has Not 

Systematically 

Evaluated Whether Its 

Tank Waste Cleanup 

Strategy, Including 

Costs, Is 

Commensurate with 

Risks from the Waste 

DOE Lacks Credible LifeCycle Cost Estimates for 

Cleaning Up Hanford’s 

Tank Waste 

DOE’s estimates of how much it will cost to clean up Hanford’s tank waste 

are not credible or complete. DOE has estimated the cost of a number of 

components that would go into a life-cycle cost estimate, including the 

cost to design and construct the waste treatment plant, the cost to manage 

and treat the tank waste, and contingency funds to cover unanticipated 

costs involved with this effort.21 But these estimates are not credible or 

complete, and each new estimate has increased over previous estimates.22

Specifically, in 2007 we reported that from 2000 to 2006, the estimated 

costs to construct the waste treatment plant almost tripled, increasing 

from $4.3 billion to about $12.3 billion (see fig. 3),23 because of contractor 

and management performance problems, changes in contract scope, and 

 

21Unless otherwise specified, all cost numbers come from DOE and are reported in current 

dollars. 

22Our report on best practices for estimating project costs highlights the need for credible 

cost estimates as a critical function in managing agency projects. See GAO, GAO Cost 

Estimating and Assessment Guide: Best Practices for Developing and Managing Capital 

Program Costs, GAO-09-3SP (Washington, D.C.: March 2009). 

23The original $4.3 billion was to construct and operate a demonstration waste treatment 

plant with initial capacity to vitrify 10 percent by mass of the waste and 25 percent of the 

radioactivity by 2018. The $12.3 billion is to construct a plant with increased capacity to 

vitrify all the high-level waste and about half the low-activity waste. 

Page 16 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

technical issues.24 Likewise, DOE’s estimates of costs for managing and 

treating the tank waste have increased significantly, raising doubts about 

the estimates’ reliability. In 2006, for example, DOE estimated that cleanup 

activities would be finished by 2032, at an estimated cost of about 

$23 billion.25 Two years later, the completion date was pushed out by 13 

years, to 2045, with a corresponding rise in costs of about $23 billion, to 

$46 billion overall,26 and indications are that these costs could increase 

still further. DOE also normally develops an estimate for contingency 

costs when carrying out large projects like Hanford’s tank waste 

cleanup—in this case, an estimate of the costs to cover unknown or 

unforeseen events during the design and construction of facilities and 

during tank waste management and treatment activities. While DO

included a contingency-cost estimate of about $1 billion in the waste 

treatment plant’s total project cost, DOE project officials estimate that an 

additional contingency of $700 million may be needed. DOE has also 

estimated that a contingency amount of about $18 billion may be needed

for tank waste management and treatment.

E has 

totals nearly $77 billion. 

 

27 The magnitude of such 

contingency funding is still another indication of the overall uncertainty

surrounding DOE’s cost estimates for its tank waste cleanup strategy. In 

all, the estimated cost of these three key components—waste treatment 

plant construction and initial operations, tank farm maintenance and 

treatment operations, and contingency costs—

24GAO, 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). 

25This figure reflects estimated costs from fiscal year 2007 to 2032. If DOE had included 

available actual costs from fiscal year 1997 through fiscal year 2006, this estimate would 

come to about $26 billion. 

26These dollar amounts reflect actual costs from 1997 through 2007 and future costs from 

2008 through 2045. Complete cost information before 1997 was not available from DOE. 

27Both the $700 million and $18 billion figures are “unfunded contingency” estimates, which 

represent additional funds that may be needed for potential future problems. 

Page 17 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

Figure 3: Cost Estimates for Constructing Hanford’s Waste Treatment Plant 

Dollars (in billions)

Source: GAO analysis of DOE data.

0

2

4

6

8

10

12

14

$4.3

$5.7

$8.3

$10.5

$12.3

Original contract

price as

awarded in December 2000

Revised contract price

as renegotiated in March 2003

Contractor’s revised

cost estimate in March 2005

Contractor’s revised

cost estimate in December 2005

Contractor’s latest cost estimate in December 2006

Notes: Neither the $8.3 billion figure nor the $10.5 billion figure was approved by DOE. The $12.3 

billion figure represents the current total project cost. The $10.5 billion figure does not include a 

contractor performance fee, which is a fee that a contractor can earn above a project’s costs and that 

offers an added incentive to complete a project on time and on budget. 

DOE did not include, or was unable to quantify, a number of significant 

costs when estimating the overall cost of its cleanup strategy. DOE’s own 

guidance states that life-cycle cost estimates should include actual 

expenditures and estimated costs from the time an activity begins until it 

is completed. For the cleanup strategy, however, DOE’s estimates 

excluded 

• Actual expenditures before 1997. DOE incurred more than $3 billion from 

1989 through 1996 to manage Hanford’s tank waste and explore ways to 

treat and permanently dispose of it, bringing life-cycle costs to about $80 

billion. 

• Costs associated with any increase in waste volume. Uncertainties over 

the amount of sodium to be added during pretreatment could increase the 

volume of low-activity waste needing treatment and ultimately increase 

Page 18 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

waste treatment costs by approximately $3 billion, according to a January 

2009 DOE study.28

• Costs to build a second low-activity waste vitrification facility. DOE has 

yet to size or design this facility, but given costs for a supplemental 

technology that DOE already included in its estimate for managing and 

treating the tank waste, additional estimated costs for a second lowactivity waste facility could increase total life-cycle costs by nearly $1 

billion, according to DOE project officials. 

• Upgrading additional facilities. DOE is considering the need for as many 

as four interim holding facilities for temporarily storing waste retrieved 

from underground tanks before pretreatment. DOE will also need to 

upgrade Hanford’s facility for processing secondary waste generated from 

the waste treatment operations. The costs of upgrading or building these 

facilities are not fully known but, according to DOE project officials, could 

be on the order of several hundred million dollars. 

• Adding temporary storage capacity for high-level waste canisters. DOE 

recently estimated that its present plans to expand existing space for 

storing high-level waste canisters would cost about $200 million. 

According to DOE project officials, uncertainties over the fate of Yucca 

Mountain could demand still more storage space on site—perhaps nearly 

14 times as much as what DOE has planned—at a cost of hundreds of 

millions of additional dollars to build, maintain, and secure. 

• Transporting high-level waste canisters to, and permanently disposing 

of them in, a geologic repository. DOE expects to ship these canisters to a 

geologic repository eventually, but the transportation and long-term 

disposal costs are not included in a life-cycle cost estimate for Hanford. 

Although DOE project officials could not precisely estimate how much 

these activities would cost, they stated that the costs could amount to 

billions of dollars. 

Developing a credible, complete cost estimate including the foregoing 

components is especially important now that, under the terms of the 

August 2009 tentative legal settlement with Washington State, DOE is 

required to have a comprehensive life-cycle cost estimate and to update it 

annually. Since DOE has not included these cost components in its 

 

28Department of Energy, Technical Studies Plan for Assessing Alternative Sodium 

Management Strategies for the River Protection Project, DOE/ORP-2009-01 (Richland, 

Wash., January 2009). 

Page 19 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

estimates to date, it is unclear whether the department will do so in future 

life-cycle cost estimates. 

Uncertainty surrounding DOE’s overall tank waste cleanup schedule adds 

further doubt to the reliability of life-cycle cost estimates. Cleanup costs 

stem directly from cleanup duration, and any lengthening of cleanup time 

leads to cost increases of comparable magnitude. According to present 

Tri-Party Agreement milestones, DOE is required to complete treatment by 

2028. In recent years, however, DOE’s estimate of when it expects to 

complete tank waste treatment has shifted repeatedly. In its negotiations 

of new cleanup milestones with its regulators, it has agreed that tank 

waste treatment may not be completed until 2047. In addition, DOE’s 

proposed fiscal year 2010 budget shows a range of treatment completion 

dates from 2042 to 2054. Other documents consider treatment time frames 

extending even further (see fig. 4). 

Page 20 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

Figure 4: Shifting Estimates of the Duration of Hanford Tank Waste Treatment 

2011 2028

2016 2032 2042

2019 2042 2054

Source: GAO analysis of DOE data.

Current Tri-Party Agreement milestones

DOE’s fiscal year 2010 budget submittalc

DOE’s System Plan, 2009d

Start of treatment End of treatment

2010 2020 2030 2040 2050 2060

2019 2047

Proposed change to Tri-Party Agreement milestones, 2009

2019 2045

DOE’s annual updated schedule, fiscal year 2008a

DOE’s approved project baseline schedule, fiscal year 2006

Planned Revised

Range

2019 2047 2054

Range

2018 2049 2060

DOE’s System Plan, 2008b

Range

a

Department of Energy, Office of River Protection, Fiscal Year (FY) 2008 Project Baseline Summary 

Sheets: GEN-02 Reports (Richland, Wash., September 2008). This document, submitted annually to 

Congress, represents DOE’s best estimate of project costs and schedules. 

b

CH2M Hill Hanford Group, River Protection Project System Plan, ORP-11242, rev. 3A, prepared for 

DOE (Richland, Wash., July 2008). This planning document explains how DOE believes it can carry 

out its tank waste cleanup strategy. 

c

Department of Energy, FY 2010 Congressional Budget Request: Environmental Management, 

Defense Nuclear Waste Disposal, Nuclear Waste Disposal, DOE/CF-039, vol. 5 (Washington, D.C., 

May 2009). 

d

Washington River Protection Solutions and AEM Consulting, River Protection Project System Plan, 

ORP-11242, rev. 4, prepared for DOE (Richland, Wash., September 2009). 

Page 21 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

In the absence of a clear and reliable schedule, DOE cannot develop a 

reliable cost estimate for its tank waste cleanup strategy. Moreover, the 

former project manager for waste treatment plant construction suggested 

that a reliable completion schedule may not be known until 2022—some 

years after treatment operations are to begin. Given that estimated average 

annual expenditures amount to about $1.2 billion,29 if treatment activities 

actually last until 2054, as some DOE planning documents suggest, tank 

waste management and treatment could increase about $8.4 billion dollars 

more than anticipated (see table 1). 

Table 1: Estimated Costs Associated with DOE’s Tank Waste Cleanup Strategy 

Cost components 

Costs included in DOE’s 

estimate 

Costs not included in DOE’s 

estimatea

Waste treatment plant total project cost $12.3 billion 

Tank waste management and waste treatment operations, fiscal 

years 1997 to 2045b

 46.0 billion 

Contingency 

Waste treatment plant 

Tank waste management and 

waste treatment operations 

 0.7 billion 

 18.0 billion 

Total of DOE’s current estimate for cleanup $77.0 billion 

Actual costs, fiscal years 1989 to 1996 $ 3.0 billion 

Increases in waste volume 3.0 billion 

Second low-activity vitrification facility 1.0 billion 

Cleanup schedule extension from 2045 to 2047c 2.4 billion 

Total potential costs if treatment extends to 2047 $86.4 billion 

Cleanup schedule extension to 2054d 8.4 billion 

Total potential costs if treatment extends to 2054 $94.8 billion 

Additional facilities Hundreds of millions 

of dollars 

Temporary storage capacity for high-level waste canisters Hundreds of millions 

of dollars 

Transporting and disposing for high-level waste canisters Billions of dollars 

Potential cost of DOE’s cleanup strategy $86 billion to more than $100 

billion 

Source: GAO analysis of DOE data. 

 

29This $1.2 billion estimate includes costs of both tank farm and waste treatment plant 

activities beginning in 2019. 

Page 22 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

a

Unless otherwise indicated, these estimates, provided by DOE, represent only rough orders of 

magnitude. 

b

DOE’s most recent estimate, dated September 2008, reflects a cleanup completion date of 2045. 

c

DOE’s most recent estimate, dated September 2008, reflects a cleanup completion date of 2045. In 

an August 2009 proposed legal settlement, however, DOE agreed to complete cleanup by 2047. The 

cost estimate is based on data provided by DOE. 

d

DOE’s latest internal planning document shows a range of cleanup completion dates from 2047 to 

2054. The cost estimate is based on data provided by DOE. 

Overall the total estimated cost could significantly exceed DOE’s current 

estimate of $77 billion, with estimates ranging from about $86 billion to 

over $100 billion, depending upon the date cleanup is completed. 

DOE Has Not Applied 

Risk-Informed Decision 

Making in Its Tank Waste 

Cleanup Strategy 

Although the importance of risk assessment for decision making had been 

recognized for more than 2 decades before cleanup of DOE’s weapons 

complex began, to date DOE has analyzed risks to human and ecological 

health mainly in the context of complying with environmental analysis 

requirements under the National Environmental Policy Act of 1969.30

Under this act, agencies evaluate the likely environmental effects of 

projects they are proposing by using an environmental assessment or, if 

the projects are likely to significantly affect the environment, a more 

detailed environmental impact statement. Under regulations implementing 

the act, an environmental impact statement must assess the environmental 

effects of the proposed agency action and all reasonable alternatives. A 

1983 National Academy of Sciences report, on the other hand, explicitly 

assessed the feasibility of, and offered guidelines for, federal agencies’ use 

of risk assessment—separate from regulatory functions—in their decision 

making.31 Since DOE’s cleanup efforts started, some three dozen studies 

by academics, the National Academy, and DOE itself have examined 

aspects of risk assessment in relation to DOE’s cleanup work. Many o

these studies have identified shortcomings in the department’s efforts to 

address risk in its decision making and urged it both to adopt a more 

disciplined process for analyzing risks and to use the results of such ris

analyses when making key de

f 

k 

cisions. 

 

3042 U.S.C. § 4332(2)(C). 

31National Research Council, Risk Assessment in the Federal Government: Managing the 

Process (Washington, D.C.: National Academy Press, 1983). 

Page 23 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

DOE’s principal risk assessment to date with regard to tank waste is found 

in its 1996 environmental impact statement. This statement discussed the 

potential environmental effects related to several strategies for managing 

and treating Hanford’s tank wastes.32 Most of these alternatives involved 

vitrification technologies, to the near exclusion of other potential 

alternative treatment pathways. This environmental impact statement was 

not required to be—and was not—a systematic risk assessment of all 

options to treat Hanford’s tank wastes. As we previously reported, for 

example, it did not purport to analyze the condition or long-term viability 

of Hanford’s aging tanks or the risks of leaving waste in the tanks for 

several decades during cleanup operations.33 The environmental impact 

statement did examine 10 tank waste treatment strategies—including “no 

action” and a “preferred alternative”—and the potential effects of these 

strategies on different groups of people, such as site workers, recreational 

river shoreline users, farmers, and Native American users, under different 

long-term land-use scenarios. The “no action” alternative was predicted to 

result in 600 “latent cancer fatalities” among future farmers on the site 

over 10,000 years. DOE’s preferred alternative—on which DOE’s present 

strategy is based—was predicted to reduce to 10 the number of farmers’ 

deaths over 10,000 years. This alternative would also result in disturbing 

the widest area of the region’s native shrub-steppe ecosystem of all the 

alternatives presented. In comparison with no action, however, this 

alternative would add thousands of regional jobs during treatment plant 

construction. Significant costs were associated with all 10 treatment 

alternatives; in 1996 dollars, no action was estimated to cost $13 billion to 

$16 billion, while the preferred alternative was projected at the time to 

reach $30 billion to $38 billion. 

Internal as well as external reports since that time have noted problems 

with DOE’s risk assessment and decision making. One of the major 

findings of DOE’s 2002 “top-to-bottom” review of its Environmental 

Management program, for example, states that “[Environmental 

Management’s] complex-wide cleanup strategy is not based on a 

comprehensive, coherent, technically supported risk prioritization. . . . 

This approach has resulted in costly waste management and disposition 

 

32Department of Energy and Washington State Department of Ecology, Final 

Environmental Impact Statement for the Tank Waste Remediation System, Hanford Site, 

Richland, Washington, DOE/EIS-0189 (Richland, Wash., August 1996). 

33GAO, Nuclear Waste: DOE Lacks Critical Information Needed to Assess Its Tank 

Management Strategy at Hanford, GAO-08-793 (Washington, D.C.: June 30, 2008). 

Page 24 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

strategies that are not proportional to risks posed to human health and the 

environment.”34 More recently, a 2005 National Academy of Sciences 

report observed that “DOE risk assessments and decision processes . . . do 

not exhibit all of the characteristics of an effective and credible riskinformed decision-making process.”35

DOE is planning to issue another environmental impact statement,36

expected in October 2009, but it is unclear to what extent its consideration 

of risks will follow available risk assessment guidelines. According to the 

National Academy’s 2005 report, a risk assessment framework would 

weigh a number of factors—including costs, worker and public safety, 

effect on ecosystems, technical feasibility, cultural impact, and other 

trade-offs. A 2008 report by the academy goes further, outlining a threephase framework for risk-based decision making that “maximizes the 

utility of risk assessment” in evaluating options to reduce hazards.37 DOE’s 

forthcoming environmental impact statement will evaluate a number of 

alternative strategies for carrying out tank waste cleanup and other 

cleanup-related activities—in particular, options for supplementing the 

capacity for treating low-activity waste and options for closing the tanks.38

Regarding tank waste cleanup, for example, the document will discuss the 

short- and long-term effects of several options for treating both high-level 

and low-activity tank waste, coupled with various tank closure 

alternatives. These options include retrieving an amount of waste 

(90 percent) that is less than the goal set by the Tri-Party Agreement 

(99 percent) and retrieving nearly all the waste (99.9 percent), an amount 

that would have to be achieved if the tanks are to be removed from the 

ground. In addition, the environmental impact statement will consider 

long-term cumulative effects from past practices (including waste already 

 

34Department of Energy, A Review of the Environmental Management Program 

(Washington, D.C., Feb. 4, 2002). 

35National Research Council, Risk and Decisions about Disposition of Transuranic and 

High-Level Radioactive Wastes (Washington, D.C.: National Academies Press, 2005), and 

list of references therein. 

36Department of Energy, Tank Closure and Waste Management Environmental Impact 

Statement for the Hanford Site, Richland, Washington, forthcoming. 

37National Research Council, Science and Decisions: Advancing Risk Assessment 

(Washington, D.C.: National Academies Press, 2008). 

38This document considers tank waste cleanup and closure in combination with two other 

major cleanup-related activities: decommissioning of the Fast Flux Test Facility (a nuclear 

research reactor that operated at Hanford from 1982 to 1992) and waste management and 

disposal on the Hanford Site. 

Page 25 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

discharged into the soil), present activities, and future actions. The 

document’s release has been delayed more than 2 years, and it is not yet 

clear when it will be issued.39

Given that environmental impact statements are DOE’s primary risk 

assessment vehicle, the current effort provides an opportunity to use 

available risk assessment guidelines to consider scenarios the department 

has not considered to date—in particular, the possibility of removing 

varied quantities of waste from the tanks. The National Academy’s 2005 

report stated, for example, that removing every gram of high-level waste is 

technologically unfeasible without also removing the tanks themselves 

and that the effort is likely to be out of proportion with the concomitant 

risk reduction. Indeed, more than half the experts we spoke with said that 

the 99 percent figure has no scientific basis, and several recommended 

that DOE conduct a comprehensive risk assessment of residual tank 

waste. 

Given the current status of DOE’s cleanup strategy and associated costs, 

three primary options appear available for reducing life-cycle costs of tank 

waste cleanup. The likelihood of their success—and potential effects on 

cleanup costs—has not yet been determined. 

Some Opportunities 

May Exist to Reduce 

Costs of DOE’s 

Hanford Tank Waste 

Cleanup Strategy 

 

39DOE had originally intended to issue a public draft of the environmental impact statement 

in spring 2007. After delays, DOE officials told us in May 2009 that the document would be 

issued by the end of June 2009. As of July 2009, DOE had again delayed the statement’s 

release until revisions could be made analyzing the effects of the uncertainty regarding the 

ultimate repository site for DOE’s high-level waste. DOE officials said they plan to issue the 

statement for public review before the end of October 2009. 

Page 26 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

DOE officials at Hanford are researching methods for increasing the 

amount of high-level waste ultimately immobilized in each canister in an 

attempt to reduce the total number of canisters produced and, perhaps, 

treatment duration. The total concentration of high-level waste per 

canister depends on, among other factors, the specific mix of radioactive 

and other constituents going into the canister. Certain chemical mixes 

lend themselves less well to vitrification than others. Chemicals such as 

aluminum can be added to glass only up to specific limits without altering 

glass quality. If aluminum concentration exceeds these limits, the resulting 

glass product may not be able to keep the radioactive constituents from 

leaching out over time. DOE is therefore studying techniques for finetuning the mix of constituents so as to maximize the concentration and 

retention of high-level waste in each canister. DOE estimates that its waste 

canisters may, on average, contain about 28-31 percent high-level waste.40

At this concentration, DOE would generate more than 500 high-level waste 

canisters per year, or a total of 9,000 to 15,000 high-level waste canisters. 

DOE is hoping to increase high-level waste concentrations in each 

canister, but it is too early to tell what levels can be consistently achieved 

during full-scale treatment. If successful, according to some DOE officials, 

such increases in waste concentrations could reduce the number of highlevel waste canisters, potentially shaving years—and associated costs—off 

treatment operations. While it is unclear what savings could be achieved, 

DOE believes the savings could be substantial. 

Increasing the Amount of 

High-Level Waste Captured 

in Each Canister Could 

Reduce the Number of 

Canisters and Treatment 

Duration, Thereby 

Reducing Costs 

Performing Additional 

Testing on Pretreatment 

Technologies Could Help 

Minimize Problems during 

Waste Treatment 

Operations 

In 2008, DOE built a test facility, the pretreatment engineering platform, to 

help resolve uncertainties in selected pretreatment technologies, 

particularly the engineering designs for ultrafiltration, or filtering the 

waste to remove solids; efficiently dissolving components such as 

aluminum and chromium to facilitate separating high-level from lowactivity waste streams; and ensuring that piping throughout the facility will 

not clog with waste sludge moving through the system. A number of the 

experts we spoke with had concerns about the reliability of these and 

other pretreatment technologies.41 In May 2009, DOE officials stated that 

the department has completed most of the testing on these technologies 

(with a report to be released later this year), and project officials stated 

 

40The remaining canister contents consist of glass-forming material. 

41Some of the experts we interviewed also had concerns about the reliability of the ion 

exchange system that extracts the waste from the highly radioactive element cesium-137. 

The ion exchange process was not tested as part of the pretreatment engineering platform. 

Page 27 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

that they had improved the facility’s design as a result of the testing. It 

appears, however, that the pretreatment platform provides DOE with an 

opportunity to use the platform to test additional pretreatment 

technologies and also to refine or enhance the efficiency and effectiveness 

of future pretreatment operations. Given the delays—and costs—that 

could arise if the pretreatment facility becomes a significant bottleneck for 

waste treatment plant operations overall, some of the experts we spoke 

with commented that using the pretreatment engineering platform for 

testing before full operations begin could help reduce uncertainties. As we 

reported in 2003, if pretreatment processes at Hanford do not work as 

planned, facilities would likely have to be retrofitted, resulting in potential 

cost increases and schedule delays much greater than those associated 

with process testing in a pilot facility.42 DOE has recognized this 

opportunity and is considering options for further testing and for obtaining 

needed funding. 

Allowing More Residual 

Waste to Remain in 

Selected Tanks at Closing 

Could Help Reduce Costs 

without Adding Risks to 

Human or Ecological 

Health 

With regard to amounts of residual waste permitted in the tanks at closure, 

DOE’s present strategy is driven in large measure by milestones agreed to 

in the Tri-Party Agreement. This agreement calls for retrieving as much 

waste as technically possible, with tank waste residues not to exceed 

specified volumes.43 Federal regulations under RCRA define a waste 

container as “empty” if, among other criteria, it contains no more than 

1 inch of waste residues, which is the equivalent of the volume limits 

stipulated in the Tri-Party Agreement.44 According to one DOE official, the 

volume limits in the agreement were set to ensure that at least 99 percent 

of the waste would be removed from the single-shell tanks. Several of the 

experts we interviewed, however, suggested that DOE could leave more 

waste in selected tanks at closing and still protect human health and the 

environment. 

 

42GAO-03-593. 

43Under the Tri-Party Agreement, DOE is required to retrieve as much tank waste as 

technically possible, with tank waste residues not to exceed 360 cubic feet in the so-called 

“100” series of tanks, 30 cubic feet in the “200” series tanks, or the limit of waste retrieval 

technology capability, whichever is less. (Tri-Party Agreement Action Plan, appendix D, 

milestone M-045-00.) These quantities represent 99 percent waste retrieval for each singleshell tank. If DOE believes that waste retrieval to these levels is not possible for individual 

tanks, DOE may request an exception. 

4440 C.F.R. 261.7(b)(1)(ii). A container is also considered empty if no more than 0.3 percent 

by weight of the total capacity of the container remains in the container or inner liner, if 

the container is greater than 119 gallons in size. 40 C.F.R. 261.7(b)(1)(iii)(B). 

Page 28 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

As DOE has emptied the single-shell tanks, it has found that estimates for 

retrieving the waste have significantly understated actual costs. For 

example, in 2003, DOE estimated that retrieving waste from all the singleshell tanks would cost approximately $1.1 billion, or an average of about 

$7.6 million per tank. Actual costs of removing waste from the first seven 

tanks, however, have amounted to $236 million, or about $34 million per 

tank.45 Because four of the emptied tanks were Hanford’s smallest, actual 

costs for the more-numerous larger tanks could be much higher. 

In retrieving waste from Hanford’s single-shell tanks, DOE has also found 

that retrieving the last portion of waste from a tank can be 

disproportionately costly. In at least five out of the seven tanks emptied to 

date, DOE has found it technically challenging to retrieve 99 percent of the 

waste and meet the Tri-Party Agreement goal. For some of these tanks, 

DOE has estimated that the cost of retrieving the last 15 percent of the 

waste can equal or exceed the cost of removing the first 85 percent (the 

cost per gallon can be as much as three times higher). For example, as we 

previously reported, DOE found that in retrieving the waste from one large 

tank (C-106), the cost of removing each additional cubic foot, or about 

8 gallons, of waste ranged from $35,000 to $84,000—in other words, from 7 

to 16 times the average cost per cubic foot to retrieve the first nearly 

99 percent of the waste.46 Moreover, in its analysis, DOE concluded that 

the risk to workers from removing this waste, combined with the high 

cost, outweighed a relatively minimal reduction in risk to the public and 

future users of the site. Similarly, a DOE official told us that for another 

tank (C-103), the cost to date of retrieving about 85 percent of its residual 

waste was about $4 million and for retrieving an additional 12 percent of 

the residual waste, $2 million.47

Currently, DOE has not analyzed how to close the tanks in a manner that 

would balance risk with cost. The Washington State Department of 

Ecology and DOE developed a plan for a tank closure demonstration 

project to be carried out in collaboration with DOE, its contractors, EPA, 

and the state itself. The project’s purpose was to bring the agencies 

 

45Retrieval costs per tank for each of the seven tanks retrieved thus far have varied 

significantly, ranging from $143 million for a large tank (530,000 to 1 million gallons) to less 

than $10 million per tank for four of the smallest tanks (55,000 gallons). 

46GAO-08-793. 

47These costs do not include costs to design and construct tank waste retrieval structures 

and equipment. 

Page 29 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

together to, among other objectives, gather engineering and cost data on 

technologies that might be used to close single-shell tank systems; identify 

and begin to gather information needed for specific regulatory decisions 

associated with tank closure; and develop a common understanding of the 

relevant regulatory processes in order to facilitate permitting. In the 

August 2009 tentative legal settlement, DOE agreed to complete certain 

activities in this tank closure demonstration project by 2011. These 

activities include determining the process DOE will follow to reclassify 

residual tank waste, studying technical aspects of exhuming tanks, and 

evaluating alternatives for removing residual waste from a selected tank. 

Such a demonstration project could be expanded to include analyzing 

varying amounts of waste that could be left in a group of tanks at closing, 

with the goal of reducing costs while adequately protecting human and 

ecological health. This demonstration could allow DOE and the state to 

determine how to close the tanks in a cost-effective manner, as well as to 

streamline the tank closure process by determining closure goals and 

methodologies on a group of tanks, instead of one tank at a time. 

In 1989, when DOE began its cleanup mission at the Hanford Site, the total 

estimated cost was $2.8 billion, with treatment to begin in 1999. Despite 

the passage of two decades, investment of $12 billion, attempts at several 

ultimately discontinued strategies, and numerous recommendations from 

us and others, no waste has yet been treated for final disposal. DOE has, 

however, learned lessons along the way. It has improved its strategy, 

developed and refined its retrieval and treatment technologies, and made 

progress constructing the treatment facilities. DOE has also learned that 

cleaning up the legacy of radioactive and hazardous waste is more 

complex, more time-consuming, and significantly more expensive than 

envisioned. Yet DOE still faces many critical unknowns, including whether 

the treatment plant will actually work as planned, whether DOE can 

reclassify waste as planned without explicit statutory authority, and where 

treated high-level waste will be permanently disposed of. And although it 

is clear that the total costs—now estimated at $77 billion—will be much 

higher than originally anticipated, ranging from $86 billion to more than 

$100 billion, it is unclear at this point what the final costs will be. 

Moreover, as we have previously reported, certain risks—such as 

radioactivity—are declining with time, even as costs continue to climb and 

cleanup completion dates recede into the future. Given that the 

intersection is constantly shifting between actual cleanup costs and 

changing risks posed by the wastes, it is imperative that Congress have 

access to reliable life-cycle cost and risk information as it decides how to 

best allocate limited financial resources among many competing needs. 

Conclusions 

Page 30 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

And given escalating expenditures, it is also imperative that DOE diligently 

seek ways to reduce the costs of this massive undertaking without unduly 

compromising ecological, worker, or public health. Otherwise, the effort, 

worker exposure, and expense associated with retrieval, immobilization, 

and final disposal of tank waste in a geologic repository might be out of 

proportion with the risk reduction achieved. 

In light of growing costs and lengthening schedules as DOE proceeds with 

its strategy to treat and permanently dispose of Hanford’s tank waste, we 

recommend that the Secretary of Energy direct the Assistant Secretary for 

Environmental Management to take the following four actions: 

• Develop credible and complete life-cycle cost and schedule estimates, 

which include actual costs expended to date and projected future 

expenditures for all key elements; obtain independent expert evaluation of 

these estimates; and report these estimated costs to Congress. 

• Adopt a risk assessment framework for Hanford cleanup that considers 

available guidance, such as that provided by the National Academy of 

Sciences. 

• Consider seeking clarification from Congress about the department’s 

authority at Hanford to determine whether some waste now managed by 

DOE as high-level waste can be treated and disposed of as a waste type 

other than high-level waste. 

• Work with state and federal regulators to develop a risk-based approach 

for closing waste storage tanks in an efficient and effective manner—such 

as through a tank closure demonstration project—and to analyze varying 

amounts of waste that could be safely left in the tanks or a group of tanks 

at closing, with the goal of reducing costs while adequately protecting 

human and ecological health. 

We provided a draft of this report to the Department of Energy for its 

review and comment. On behalf of the department, DOE’s Assistant 

Secretary for Environmental Management wrote that DOE generally 

agreed with three of the four recommendations we made. DOE did not 

agree with our recommendation to consider seeking clarification from 

Congress about the department’s authority at Hanford to determine 

whether some waste now managed as high-level waste can be treated and 

disposed of as other than high-level waste. In addition, DOE expressed 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 31 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

concerns about how we characterized the Office of Environmental 

Management’s progress at cleaning up Hanford tank waste with respect to 

three primary issues: addressing technical and other challenges, 

developing credible and complete life-cycle cost and schedule estimates, 

and assessing risks. On September 18, 2009, we met with the Assistant 

Secretary for Environmental Management to discuss selected DOE 

comments on our draft report, as well as the Assistant Secretary’s 

concerns that readers may be confused about the scope of our report and 

assume that we also reviewed and based our conclusions on an 

assessment of legal and technical documents that are scheduled to be 

released shortly after our report is issued. We added a clarification in the 

scope and methodology section of this report to note that our conclusions 

and recommendations are based only on information available to us 

during our review. DOE’s written comments on our draft report are 

reproduced in appendix III. DOE also provided general and specific 

technical comments, which we discuss below or incorporated in the body 

of the report as appropriate. 

The first major issue for DOE regards progress in addressing technical and 

other challenges. DOE stated that we did not adequately describe the 

department’s substantial experience in and processes in place for 

addressing technical and other challenges of treating and disposing of 

Hanford’s tank waste. In its letter, DOE cited a number of examples of 

cleanup activities across the DOE complex of sites that it said are 

applicable to the challenges at Hanford and inform its technical and 

project management approach. Without doubt, DOE has gained knowledge 

about treating tank waste and closing tanks through its work at the 

Savannah River Site, South Carolina; the Idaho National Laboratory; and 

other locations. At none of these sites, however, does the waste approach 

the amount and complexity of Hanford tank waste. About 56 million 

gallons of tank waste must be treated at Hanford, more than at any other 

DOE site. In addition, this tank waste is uniquely complex because of the 

specific radioactive and chemical elements that have been mixed in it over 

the years, so that work done at other sites, though helpful, may not always 

be directly relevant to treating Hanford’s tank waste. The examples of 

success DOE cited in its written comments are informative but, relative to 

the final output expected at the Hanford Site, of much smaller scope. For 

example, DOE cited West Valley, New York, where about 275 high-level 

waste canisters were produced. Some estimates for Hanford, in contrast, 

put the number of high-level waste canisters alone between 9,000 and 

15,000. Moreover, the scope of our study, as requested by Congress, was to 

look at Hanford’s tank waste cleanup project, not cleanup across the rest 

of the DOE complex. 

Page 32 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

DOE also commented that we did not cite all the initiatives it has under 

way to help address technical uncertainties specifically at the Hanford 

Site. We did discuss several initiatives, including the pretreatment 

engineering platform and external review teams, which have been very 

useful in identifying and helping address technical challenges that DOE 

faces at Hanford. Even with these and other efforts mentioned by DOE in 

its letter, however, DOE’s own assessments of the waste treatment plant 

point out that a number of uncertainties still exist and that solving these 

may be critical to operating the plant as planned. Also, some experts we 

spoke with said that it is to be expected that some technical issues may 

remain unresolved until the plant is operating and actual waste is being 

treated. As discussed in our report, many of the technical uncertainties at 

Hanford surround whether treatment operations will be able to achieve 

the throughput assumed in DOE’s planning documents. The former project 

manager at the Hanford Site told us that it may take a few years of plant 

operation before DOE will be able to accurately determine how many 

years it will take to treat all of the site’s tank waste. Finally, technical 

concerns discussed in this report have been documented in DOE’s own 

assessments and studies, as well as echoed by the experts we spoke with. 

Further, DOE stated that our report should provide better context for our 

analysis of the challenges at Hanford and, as evidence, cited a 2001 report 

we issued on the Rocky Flats closure project.48 In that report, we stated 

that DOE could have difficulty meeting the target closure date because of 

significant challenges that DOE and its Rocky Flats contractor faced. 

Nevertheless, despite these challenges, DOE and its contractor did meet 

their target closure date of 2006. Our conclusions in that report were 

based on the contractor’s own assessment that it had only about a 

15 percent probability of completing the project by 2006. In our view, by 

highlighting the challenges DOE and its contractor faced, our report 

helped focus attention needed to successfully complete the project in a 

timely manner. 

The second issue DOE raised in its written comments relates to whether 

DOE is developing credible and complete life-cycle cost and schedule 

estimates. In agreeing with our recommendation on this topic, DOE stated 

that it has a process for developing credible and complete life-cycle cost 

estimates for Hanford. We maintain, however, that past cost estimates for 

 

48GAO, Nuclear Cleanup: Progress Made at Rocky Flats, but Closure by 2006 Is Unlikely, 

and Costs May Increase, GAO-01-284 (Washington, D.C.: Feb. 28, 2001). 

Page 33 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

Hanford tank waste cleanup were neither credible nor complete. As 

discussed in this report, costs for constructing the waste treatment plant 

and managing the tank waste, for example, have grown significantly over 

the life of the project. Although DOE stated that we used a point estimate 

of our own construct, we in fact discussed with DOE officials at the Office 

of River Protection the cost estimates making up the $77 billion figure in 

table 1. These officials provided updated figures to reflect a 2045 

completion date, rather than a 2042 date for the figures quoted by DOE in 

its written comments. DOE’s current estimate for cleanup could range 

from $58.3 billion if no contingency is included to $77.0 billion if the full 

$18.7 billion contingency is included, in contrast to the range of $56 billion 

to $74 billion that DOE provided in its letter. 

Further, many potentially significant costs were not included in any 

estimates DOE provided us. If these are added in, the total cost for this 

undertaking could range from $86 billion to more than $100 billion. We 

recognize that DOE has been taking steps to try to improve its costestimating process, including using GAO’s cost-estimating guide,49 when 

developing cost and schedule estimates. DOE is also developing a new 

cost and schedule baseline for the Hanford tank waste cleanup effort, but 

since this baseline has not yet been validated or approved by DOE, it was 

not available for our review. Further, as noted in its comments, under the 

August 2009 tentative legal settlement for Hanford (which is still subject to 

public review and comment), DOE has agreed to prepare a life-cycle 

analysis of all Hanford cleanup costs to meet the legally mandated cleanup 

timelines. We look forward to development of this analysis because we 

believe that until DOE develops a complete life-cycle cost analysis at 

Hanford—one that takes into account all potentially significant costs 

stemming from the effort to clean up tank wastes, including those for 

interim and permanent storage of waste canisters—information presented 

to Congress could understate the true costs of this challenging cleanup 

effort. 

DOE’s third issue relates to consideration of risk. DOE agreed with our 

related recommendation to adopt a risk assessment framework that 

considers available guidance, such as that provided by the National 

Academy of Sciences, but added that it believes it already has a risk 

assessment framework for Hanford and that our report does not recognize 

existing DOE risk management efforts (our emphasis). We acknowledge 

 

49GAO-09-3SP. 

Page 34 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

that DOE has taken steps to assess risks, such as in its forthcoming draft 

environmental impact statement, which is expected to be released for 

public comment in October 2009. DOE also has a process for managing 

risks, and its letter says the Tri-Party Agreement contains provisions for 

mitigation of programmatic risk. Risk assessment, however, is not the 

same as risk management. Specifically, in the view of the National 

Academy of Sciences, the assessment of risks and related scientific 

findings and policy judgments should be distinguished from risk 

management alternatives. In essence, the science of risk analysis and 

assessment to inform policy are related to but distinct from actions taken 

to manage identified risks. In its technical comments on our report, DOE 

addressed risk management activities at some length. For example, it 

stated that we failed to mention DOE guidance on risk management, the 

River Protection Project Federal Risk Management Plan, and other key 

documents that include risk mitigation actions. DOE described these 

documents, for example noting that the river protection plan lays out the 

critical technical, programmatic, and operational risks facing Hanford’s 

cleanup projects. But in our view, DOE’s description focuses on mitigation 

steps for addressing risks to meeting the project’s cost and schedule 

estimates. Therefore, although we considered these documents, we did not 

include them in our analysis because they focused on project risks rather 

than addressing risks to human and ecological health. 

Moreover, we are not the first to suggest that DOE’s risk assessment 

framework falls short. As stated in our report, some three dozen studies by 

academics, the National Academy of Sciences—including studies done at 

the behest of DOE—and DOE itself have examined aspects of risk 

assessment in relation to DOE’s cleanup efforts and found shortcomings. 

As early as 1983, a National Academy of Sciences report offered guidelines 

for federal agencies’ use of risk assessment, distinct from regulatory 

functions, in their decision making. Yet we found, and DOE’s comments 

also stated, that the draft environmental impact statement on tank waste 

treatment and closure, required under the National Environmental Policy 

Act, is a primary risk assessment vehicle. In light of DOE’s comments on 

this topic, confusion seems to persist about the differences between risk 

assessment and risk management. 

With regard to the issue of the risks of leaving more waste in tanks, DOE 

stated that it is important to recognize that the department has limited 

discretion when it comes to decisions on how to proceed with cleanup. It 

noted that the Tri-Party Agreement generally requires removal of 

99 percent of waste from the tanks using available technologies. We 

recognize that DOE must operate within the legal constraints placed on it. 

Page 35 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

That said, the Tri-Party Agreement does allow DOE to seek an exemption 

from the 99 percent target on a tank-by-tank basis, and DOE is currently 

using this exemption process for one tank it has been emptying. Our point 

is that, given the enormous task DOE faces and the enormous associated 

costs, if and when situations arise where the efforts and costs to meet the 

99 percent waste removal standard are significantly out of proportion with 

the actual risk reduction achieved, DOE and its regulators should perhaps 

reconsider the reasonable and appropriate path forward. We, like DOE, 

believe the tank closure demonstration project DOE plans to carry out in 

collaboration with Washington State and EPA will be useful in informing 

this discussion. 

DOE disagreed with our recommendation suggesting that the department 

consider seeking clarification from Congress about its authority to 

reclassify high-level waste, stating that it does not believe it needs 

clarification about the department’s authority at this time. DOE stated that 

its attention for the next 10 years will be on removing waste from tanks, 

finishing construction of the waste treatment plant, and starting waste 

treatment operations. The department was silent, however, on the merits 

of the recommendation itself. We recognize that DOE requested this 

clarification once before and that in 2004 legislation (section 3116 of 

Public Law No. 108-375), Congress provided this authority to DOE sites in 

Idaho and South Carolina while specifically excluding DOE sites in 

Washington State. Given the importance of waste classification to the 

overall Hanford cleanup strategy, however, we believe that it may be 

prudent to consider revisiting the topic with Congress. By indefinitely 

postponing potential resolution of this question, DOE may be leaving itself 

vulnerable to future litigation on a topic that could pose more severe 

problems later. By pursuing the question now, DOE could have time on its 

side and can work with regulators and stakeholders to tailor its strategy 

appropriately. 

Finally, in its technical comments, DOE stated that many comparisons 

made in the report do not have consistent or equitable bases. DOE 

commented that while the costs and schedules for its Hanford tank waste 

cleanup strategy have varied over time, the associated scope has greatly 

changed, and earlier cost estimates did not include over $2 billion in 

funded contingency. In describing the previous and current treatment 

strategies, our report does note that the scope, as well as associated costs, 

has changed over time. This information is given as background for 

readers, not an exhaustive discussion of previous strategies that did not 

reach fruition. DOE also commented that we compared information, such 

as treatment completion dates, from documents having different purposes, 

Page 36 GAO-09-913 Hanford Tank Waste Cleanup Strategy
 

such as a baseline schedule and a strategic planning document. We 

recognize that the documents were developed for varied reasons. 

Nevertheless, we believe that the wide range of completion dates from 

these different documents, in particular, contributes to a better 

understanding of the potential uncertainties surrounding an effort of this 

magnitude and complexity. 

We are sending copies of this report to other interested congressional 

committees and to the Secretary of Energy. The report also is available at 

no charge on the GAO Web site at http://www.gao.gov. 

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

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

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

last page of this report. Key contributors are listed in appendix IV. 

ene Aloise 

Director, Natural Resources and Environment 

G

Page 37 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To determine the Department of Energy’s (DOE) current Hanford Site 

cleanup strategy and the key technical, legal, and other uncertainties it 

faces, we gathered and reviewed numerous reports and studies addressing 

DOE’s overall plan to retrieve, treat, and dispose of Hanford’s tank waste. 

We reviewed historical documents to understand how DOE’s tank waste 

cleanup strategy has evolved. We reviewed reports by DOE and its 

contractors, which discussed technical problems with the waste treatment 

plant and other phases of DOE’s strategy. We also reviewed documents 

analyzing DOE’s need for supplemental capacity, and the department’s 

analysis of potential options, for treating low-activity waste. To identify 

legal, regulatory, and other uncertainties, we reviewed applicable laws, 

regulations, policy, and guidance documents, as well as information on 

past and pending lawsuits. In addition, we interviewed DOE Hanford Site 

officials in the Office of River Protection and visited the Hanford Site. We 

also interviewed officials at DOE headquarters in the Office of Engineering 

and Construction Management and in the Office of Environmental 

Management’s Office of Project Recovery and Office of Engineering and 

Technology. We interviewed contractor officials at the Hanford Site 

responsible for building the waste treatment plant. We interviewed 

officials with regulatory and other agencies—specifically, the Washington 

State Department of Ecology, the Environmental Protection Agency 

(EPA), the Nuclear Regulatory Commission, and the Defense Nuclear 

Facilities Safety Board—as well as the National Academy of Sciences. 

To determine the extent to which DOE has assessed whether Hanford’s 

tank waste cleanup strategy, including costs, is commensurate with the 

risks from its tank wastes, we examined budget and financial documents, 

environmental impact studies, and other relevant DOE documents. Budget 

information we reviewed included DOE’s proposed budget for 2010, DOE’s 

estimated costs for tank waste cleanup, and project cost and schedule 

baselines. We spoke with DOE officials and took other steps to ensure that 

all cost data were sufficiently useful for purposes of this report. We 

reported all cost data as provided by DOE—rather than normalize them 

for comparison by using constant dollars, for example—because not all 

cost information was available annually. We also reviewed GAO’s recent 

cost-estimating guide for further information on life-cycle costs and risks 

in developing credible cost estimates.1

 Further, we reviewed milestones 

DOE agreed to under the Tri-Party Agreement, as well as alternative 

schedules, such as DOE’s suggested milestone changes proposed during 

 

1

GAO-09-3SP. 

Page 38 GAO-09-913 Hanford Tank Waste Cleanup Strategy 
Appendix I: Scope and Methodology 

negotiations with the state of Washington and EPA, and other documents 

showing schedule plans. We reviewed DOE’s guidance on risk 

assessments, as well as National Academy of Sciences reports and 

published articles by risk assessment professionals. We also reviewed 

DOE’s past environmental impact statement and information on DOE’s 

most recent environmental impact statement, as well as performance 

assessments; both assessment types discuss risks. 

To evaluate options that DOE could follow to reduce costs of its tank 

waste cleanup strategy, we reviewed DOE documents discussing various 

options. To gain additional insights, we interviewed 18 experts, all of 

whom are independent of DOE and its contractors and have extensive 

knowledge of DOE’s tank waste cleanup strategy. We identified these 

experts in consultation with various sources, including the National 

Academy of Sciences and Defense Nuclear Facilities Safety Board; prior 

independent reviews of DOE’s Hanford tank waste cleanup strategy; and 

our technical consultant, George W. Hinman, Professor Emeritus of 

Applied Energy Studies at Washington State University, who has extensive 

nuclear energy experience in industry, government, and academia. We 

developed a structured interview guide, containing open-ended questions 

about various aspects of Hanford’s waste cleanup strategy. These 

questions addressed uncertainties with DOE’s current waste treatment 

strategy, treatment technologies for low-activity waste, and developing 

risk assessment information for DOE’s tank waste cleanup strategy. We 

pretested our interview guide to ensure the questions were clear and 

relevant. Using the guide, we interviewed each expert either by telephone 

or in person. Because the questions were open-ended, and experts were 

knowledgeable about varied but not all aspects of the issues covered, we 

did not attempt to quantify their responses for reporting purposes. 

Several key documents were just released or were scheduled to be 

released by DOE shortly after our report was to be issued. These included 

a tentative legal settlement with the state of Washington, an amended TriParty Agreement, a draft environmental impact statement for tank closure, 

and a new cost and schedule baseline for the Hanford tank waste cleanup 

effort. We reviewed an August 10, 2009, version of the tentative legal 

settlement and were provided access to a version of the draft 

environmental impact statement, but the remaining documents were not 

available at the time of our review. These documents are discussed in our 

report and factored into its conclusions and recommendations as available 

and appropriate. As agreed with DOE, we included only publicly available 

information about the draft environmental impact statement in our report. 

Page 39 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix I: Scope and Methodology 

We conducted this performance audit from July 2008 to September 2009, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

Page 40 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix II: Overview of DOE’s Efforts to 

Select an Approach to Supplement Its Low- Appendix II: Overview of DOE’s Efforts to Activity Tank Waste Treatment Capacity 

Select an Approach to Supplement Its LowActivity Tank Waste Treatment Capacity 

As DOE’s strategy for cleaning up tank waste at the Hanford Site has 

evolved over the past 20 years, the department has evaluated a number of 

technologies to supplement its capacity to treat the low-activity fraction of 

the waste.1

 As of July 2009, however, DOE officials told us they had 

postponed further testing of one potential supplemental technology at 

Hanford and were proceeding with planning for another low-activity waste 

vitrification facility to provide more treatment capacity. 

Over the years, DOE’s approach to treating low-activity waste at Hanford 

has moved away from grout, a method used at other DOE sites, to 

vitrification. DOE’s original plan in 1989 called for mixing low-activity 

waste with materials to form the hardened, cementlike substance called 

grout, which would be permanently disposed of on site in more than 200 

large, underground vaults with elaborate environmental controls. This 

disposal method is similar to those widely used in the commercial nuclear 

industry and by DOE at sites besides Hanford, such as Savannah River and 

West Valley, for immobilizing and disposing of low-activity and hazardous 

wastes. In the early 1990s, however, state regulators and other 

stakeholders raised concerns about using grout at Hanford. These 

concerns included doubts about grout’s ability to prevent long-lived 

radionuclides, such as technetium-99, from migrating into groundwater 

over a long period; reliance on engineered barriers to further limit water 

infiltration into the vaults; the irretrievability of grout from the vaults once 

disposed of; and the large land area (over 200 acres) that would be needed 

for the underground vaults. Given these concerns, DOE suspended efforts 

to develop a grout-based disposal form while it studied the feasibility of 

other options, including various vitrification alternatives. 

In 1994, DOE officially decided against grout and chose to pursue 

vitrifying Hanford’s low-activity tank waste. DOE studies concluded that a 

vitrified disposal form offered superior performance over grout. These 

studies showed that glass was capable of retaining long-lived 

radionuclides over a much longer period, required a much smaller 

permanent disposal facility, and had life-cycle costs generally comparable 

to those for grout. In 1994, the Tri-Party Agreement was amended to 

 

1

Under Tri-Party Agreement milestone M-62-08, DOE was to submit by June 30, 2006, a 

report comparing the performance of potential supplemental technologies with that of a 

second low-activity waste vitrification facility. In an August 2009 proposed legal settlement 

with its regulators, DOE agreed to submit a report on potential supplemental treatment 

technologies by 2014 only if the department proposed to pursue a technology other than a 

second vitrification plant for low-activity waste. 

Page 41 GAO-09-913 Hanford Tank Waste Cleanup Strategy 
Appendix II: Overview of DOE’s Efforts to 

Select an Approach to Supplement Its LowActivity Tank Waste Treatment Capacity 

include immobilization of low-activity waste by vitrification.2 DOE’s 1996 

tank waste remediation system environmental impact statement—which 

evaluated treatment options and short- and long-term effects for Hanford’s 

tank waste cleanup—largely considered vitrification as the technological 

option for treating low-activity waste. DOE ultimately decided on a phased 

approach to treating the waste, that is, building demonstration-sized 

facilities to test treatment technologies on a small portion of the waste—

eventually determined to be 10 percent of the waste volume—with 

construction of a full-scale facility after testing was complete.3

 After the 

contract was awarded in 2000 to build the waste treatment plant, however, 

DOE opted to have its contractor build a full-scale treatment plant, which 

included a low-activity vitrification facility that was not large enough to 

treat all of Hanford’s low-activity tank waste by the time high-level waste 

treatment was completed. 

In 2002, DOE shifted its treatment strategy to an accelerated approach to 

meet regulatory and other commitments calling for completing treatment 

of Hanford’s tank waste by 2028. DOE recognized, however, that the lowactivity vitrification facility planned for Hanford would not be able to treat 

more than 50 percent of the low-activity waste by this deadline. DOE, 

along with the Washington State Department of Ecology; EPA; and experts 

from national laboratories, industry, and academia, then met to evaluate a 

number of technologies that could be used to supplement Hanford’s 

treatment capacity to meet the accelerated schedule.4

Together, the agencies identified three technologies—bulk vitrification, 

fluidized bed steam reforming, and cast stone—along with a second lowactivity vitrification facility, as the most viable options for supplementing 

DOE’s treatment capability. Bulk vitrification is a vitrification process 

similar to the technology planned for the first low-activity waste 

vitrification facility—whereby waste is mixed with other materials, heated 

in a melter to form a glass substance, then poured into stainless-steel 

 

2

Tri-Party Agreement, appendix D, milestones M-61 and M-62. 

3

“Record of Decision for the Tank Waste Remediation System, Hanford Site, Richland, 

Washington,” 62 Fed. Reg. 8693 (February 1997). 

4

In all, DOE compared about 10 available technical options for treating Hanford’s lowactivity waste. Criteria used to rank them were (a) waste treatment acceleration, 

(b) technology maturity, (c) implementation flexibility, (d) ease of regulatory compliance, 

(e) human health and safety risk reduction, (f) operational safety (worker protection), 

(g) compatibility with the Tri-Party Agreement (milestone schedules), and (h) waste 

retrieval acceleration. 

Page 42 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix II: Overview of DOE’s Efforts to 

Select an Approach to Supplement Its LowActivity Tank Waste Treatment Capacity 

containers for disposal—except that in bulk vitrification, the melter also 

serves as the final disposal container. Steam reforming is a thermal 

process that uses steam and chemical additives mixed with the waste to 

form a granular, mineral-like waste form. Cast stone is a nonthermal, 

cement-based approach that mixes the waste with Portland cement to 

create a monolithic disposal form. While the Washington State Department 

of Ecology participated in selecting technologies for further testing, the 

state has maintained that any supplemental treatment technology must be 

shown to be “as good as glass,” which means that it must meet or exceed 

all the same performance standards and disposal criteria to protect human 

and ecological health that apply to the approved glass form. Further 

evaluations concluded that steam reforming and bulk vitrification showed 

the most promise for performing comparably to glass in immobilizing 

Hanford’s low-activity tank waste. 

Then, in 2003, DOE decided to proceed with development of bulk 

vitrification at the Hanford Site because it believed the technology would 

be less costly, able to be more rapidly demonstrated and deployed, and 

more acceptable to state regulators than the other options. After spending 

more than $100 million on the bulk vitrification demonstration project, 

however, DOE officials have suspended construction activities and elected 

not to pursue additional funding for the project in fiscal year 2009. 

Throughout testing, bulk vitrification had proved to be more costly and 

technically difficult to develop than initially envisioned. Because DOE 

opted to proceed only with testing and developing bulk vitrification for 

Hanford wastes, other technologies—such as steam reforming or cast 

stone—have not been extensively tested using actual Hanford waste. With 

the suspension of bulk vitrification, DOE officials told us they currently 

have no other supplemental technology development under way or 

planned for treating a majority of Hanford’s low-activity waste. 

Since suspending bulk vitrification, DOE officials have said that the 

department is planning for a second low-activity vitrification facility to 

provide the additional capacity needed to complete treatment of Hanford’s 

low-activity waste within a realistic time frame.5

 While DOE maintains the 

 

5

While the Tri-Party Agreement still includes a milestone for completing treatment by 2028, 

both DOE and Washington State acknowledge that DOE will not be able to achieve this 

goal, and the August 2009 tentative legal settlement sets a revised cleanup date of 2047. 

Even with this extended treatment schedule, DOE believes that the low-activity waste 

vitrification facility currently under construction will lack the capacity to treat all the lowactivity waste within this time frame. 

Page 43 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix II: Overview of DOE’s Efforts to 

Select an Approach to Supplement Its LowActivity Tank Waste Treatment Capacity 

decision is not final, a second vitrification facility will be the path forward 

for planning purposes. For example, in 2008, DOE released an external 

review of its systems planning for low-activity waste treatment at Hanford, 

which concluded that a second low-activity waste vitrification facility was 

the most viable option from a cost perspective for supplementing DOE’s 

low-activity waste treatment capability.6

 In addition, the report suggested 

that further demonstration of bulk vitrification should be given a low 

priority while the department focuses its attention on resolving other 

uncertainties with its strategy, such as the total amount of waste to be 

processed. 

On the basis of its 2008 report, DOE project officials told us in March 2009 

that they are moving forward in their planning as if a second vitrification 

facility were the selected technology and that the new project baseline, 

due out by the end of the year, will include a second low-activity 

vitrification plant as the supplemental treatment approach. Despite these 

planning decisions, DOE maintains that a final determination on its 

supplemental treatment approach will be made in accordance with its 

project management orders and after issuance of the environmental 

impact statement. In a December 2008 letter to Congress, DOE indicated 

that a final decision on its supplemental treatment approach will not likely 

be made until 2015 at the earliest. 

 

6

Although the report acknowledged cast stone and steam reforming as other potentially 

viable options, and noted that these options were being evaluated within the environmental 

impact statement process, it did not assess these options, focusing only on alternatives to 

increase Hanford’s vitrification capacity. 

Page 44 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix III: Comments from the Department Appendix III: Comments from the of Energy 

Department of Energy 

Page 45 GAO-09-913 Hanford Tank Waste Cleanup Strategy 
Appendix III: Comments from the Department 

of Energy 

Page 46 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix III: Comments from the Department 

of Energy 

Page 47 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix III: Comments from the Department 

of Energy 

Page 48 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix III: Comments from the Department 

of Energy 

Page 49 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 50 GAO-09-913 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

Gene Aloise, (202) 512-3841 or aloisee@gao.gov

In addition to the individual named above, Janet E. Frisch, Assistant 

Director; Ellen W. Chu; Doreen Eng; George W. Hinman; Richard P. 

Johnson; Karen Keegan; Nancy Kintner-Meyer; Mike Meleady; Mehrzad 

Nadji; Joshua Ormond; Thomas C. Perry; Timothy M. Persons; Jena 

Sinkfield; and John Smale made key contributions to this report. 

GAO Contact 

Staff 

Acknowledgments 

Hanford Tank Waste Cleanup Strategy 
Related GAO Products Related GAO Products 

Nuclear Waste: DOE Lacks Critical Information Needed to Assess Its 

Tank Management Strategy at Hanford. GAO-08-793. Washington, D.C.: 

June 30, 2008. 

Hanford Waste Treatment Plant: Department of Energy Needs to 

Strengthen Controls over Contractor Payments and Project Assets.

GAO-07-888. Washington, D.C.: July 20, 2007. 

Nuclear Waste: DOE Should Reassess Whether the Bulk Vitrification 

Demonstration Project at Its Hanford Site Is Still Needed to Treat 

Radioactive Waste. GAO-07-762. Washington, D.C.: June 12, 2007. 

Hanford Waste Treatment Plant: Contractor and DOE Management 

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

Concerns. GAO-06-602T. Washington, D.C.: April 6, 2006. 

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

Cleanup Project Adds to Challenges of Achieving Cost and Schedule 

Goals. GAO-04-611. Washington, D.C.: June 9, 2004. 

Nuclear Waste: Challenges to Achieving Potential Savings in DOE’s 

High-Level Waste Cleanup Program. GAO-03-593. Washington, D.C.: June 

17, 2003. 

Nuclear Waste: Department of Energy’s Hanford Tank Waste Project—

Schedule, Cost, and Management Issues. GAO-RCED-99-13. Washington, 

D.C.: October 8, 1998. 

Nuclear Waste: Management and Technical Problems Continue to Delay 

Characterizing Hanford’s Tank Waste. GAO-RCED-96-56. Washington, 

D.C.: January 26, 1996. 

Nuclear Waste: Further Improvement Needed in the Hanford Tank Farm 

Maintenance Program. GAO/RCED-95-29. Washington, D.C.: November 8, 

1994. 

Nuclear Waste: Hanford Tank Waste Program Needs Cost, Schedule, and 

Management Changes. GAO/RCED-93-99. Washington, D.C.: March 8, 

1993. 

Nuclear Waste: Hanford Single-Shell Tank Leaks Greater Than 

Estimated. GAO/RCED-91-177. Washington, D.C.: August 5, 1991. 

Page 51 GAO-09-913 Hanford Tank Waste Cleanup Strategy
Related GAO Products 

Nuclear Waste: Problems and Delays with Characterizing Hanford’s 

Single-Shell Tank Waste. GAO/RCED-91-118. Washington, D.C.: April 23, 

1991. 

Nuclear Energy: Consequences of Explosion of Hanford’s Single-Shell 

Tanks Are Understated. GAO/RCED-91-34. Washington, D.C.: October 10, 

1990. 

Nuclear Waste: Program to Prepare High-Level Radioactive Waste for 

Final Disposal. GAO/RCED-90-46FS. Washington, D.C.: November 9, 1989. 

Nuclear Waste: DOE’s Management of Single-Shell Tanks at Hanford,

Washington. GAO/RCED-89-157. Washington, D.C.: July 18, 1989. 

(360987) Page 52 GAO-09-913 Hanford Tank Waste Cleanup Strategy
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