HANFORD WASTE 

TREATMENT PLANT

DOE Needs to Take 

Further Actions to 

Address Weaknesses 

in Its Quality 

Assurance Program

Report to the Committee on Armed 

Services, U.S. Senate

April 2018

GAO-18-241

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-241, a report to the

Committee on Armed Services, U.S. Senate

April 2018

HANFORD WASTE TREATMENT PLANT

DOE Needs to Take Further Actions to Address 

Weaknesses in Its Quality Assurance Program

What GAO Found

The Department of Energy (DOE) has taken several actions to identify and 

address quality assurance problems at the Waste Treatment and Immobilization 

Plant (WTP) at its Hanford site in Washington. Among the actions taken is the 

implementation of the Managed Improvement Plan by DOE’s Office of River 

Protection (ORP) and the WTP contactor. The plan is intended to ensure that the 

WTP can operate in compliance with DOE-approved safety and quality 

requirements. The contractor has stated that the plan is fully implemented, but 

GAO found that a number of key activities may be incomplete and ORP officials 

will not be able to verify the extent of implementation until December 2018. 

According to DOE documents that GAO reviewed and ORP quality assurance 

experts GAO spoke with, ORP has not ensured that all WTP quality assurance 

problems have been identified and some previously identified problems are 

recurring. For example, a 2016 DOE report found quality assurance problems, 

such as engineering errors and construction deficiencies, that neither ORP nor 

the contractor had identified when the work was conducted. ORP quality 

assurance experts GAO spoke with reiterated the issues identified in reports. In 

addition, DOE audits have found that previously identified quality assurance 

problems have recurred in key areas, such as the procurement of items that do 

not meet requirements or perform as specified. These problems were also raised 

by several of the ORP quality assurance experts GAO interviewed. According to 

these experts, such recurring problems may lead to significant rework at WTP 

facilities in the future if work is not stopped and the issues addressed. ORP’s 

quality assurance framework requires the contractor to determine the extent to 

which quality assurance problems exist in all WTP structures, systems, and 

components when such problems are identified, and allows ORP to stop work at 

a facility if recurring issues arise. However, ORP has neither directed the 

contractor to make this determination nor stopped work when problems recur 

because it has confidence in the Managed Improvement Plan.

ORP’s organizational structure may not provide its Quality Assurance Division

with sufficient independence from the office’s upper management to oversee the 

contractor’s quality assurance program effectively. GAO has previously found 

that an oversight organization should be structurally distinct and separate from 

program offices responsible for cost and schedule performance to avoid conflict 

between mission objectives and safety. However, a 2017 DOE headquarters 

assessment found that ORP’s Quality Assurance Division’s effectiveness has 

been limited. This is because in some cases ORP upper management had 

mischaracterized its findings, and in other instances, ORP upper management 

had not used this division to evaluate the extent of potential quality assurance 

problems. ORP quality assurance experts GAO spoke to were also concerned 

that ORP’s organizational structure does not always ensure the independence of 

the division. For example, two of these experts described instances when ORP 

upper management had downgraded the division’s findings so that the contractor 

could take less stringent corrective measures. By providing the Quality 

Assurance Division adequate independence, DOE can better ensure that

compliance with nuclear safety requirements will not be subordinated to other 

project management goals, such as meeting cost and schedule targets.

View GAO-18-241. For more information, 

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

trimbled@gao.gov.

Why GAO Did This Study

DOE and its contractor are building the 

WTP—which consists of multiple

facilities—to treat a large portion of 

nuclear waste at Hanford. The project

has faced persistent challenges, 

including quality assurance problems 

that have delayed it by decades and 

more than tripled its costs, to nearly 

$17 billion. DOE’s quality assurance 

framework aims to ensure that all 

problems are identified and do not 

recur.

Senate Report 114-49 accompanying 

the National Defense Authorization Act 

for Fiscal Year 2016 included a 

provision for GAO to carry out an 

ongoing evaluation of the WTP. This 

first report examines (1) the actions 

DOE has taken to identify and address 

WTP quality assurance problems, 

(2) the extent to which DOE has 

ensured that quality assurance 

problems have been identified and do

not recur, and (3) the extent to which 

DOE’s organizational structure at ORP 

provides the Quality Assurance 

Division with independence to 

effectively oversee the contractor’s 

quality assurance program. GAO

reviewed DOE documents and 

obtained the insights of ORP’s internal 

experts on WTP quality assurance

efforts and outcomes. 

What GAO Recommends

GAO recommends that DOE direct the 

WTP contractor to determine the 

extent of problems in WTP structures, 

systems, and components and order 

work stops when problems recur, and

DOE should direct ORP to revise its

organizational structure to ensure the 

independence of the Quality 

Assurance Division. DOE generally

agreed with GAO’s recommendations.
Page i GAO-18-241 Hanford Waste Treatment Plant

Letter 1

Background 6

ORP Has Taken Several Actions to Identify and Address Quality 

Assurance Problems at the WTP, but All Planned Actions Have 

Not Been Completed 11

ORP Has Not Ensured That All Quality Assurance Problems Have 

Been Identified, and Some Previously Identified Problems Are 

Recurring 16

ORP’s Organizational Structure May Not Provide Sufficient 

Independence for Effective Oversight of the WTP Contractor’s 

Quality Assurance Program 22

Conclusions 25

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 27

Appendix I Comments from the Department of Energy 28

Appendix II GAO Contact and Staff Acknowledgments 31

Figure

Figure 1: Waste Treatment and Immobilization Plant (WTP) and 

Other Facilities Planned for Hanford Tank Waste 

Treatment 9

Abbreviations

DFLAW Direct Feed Low-Activity Waste

DOE Department of Energy

MIP Managed Improvement Plan 

ORP Office of River Protection 

WTP Waste Treatment and Immobilization Plant

Contents

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Page 1 GAO-18-241 Hanford Waste Treatment Plant

441 G St. N.W.

Washington, DC 20548

April 24, 2018

The Honorable John McCain

Chairman

The Honorable Jack Reed

Ranking Member

Committee on Armed Services

United States Senate

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

largest environmental cleanup programs: the treatment and disposal of 

millions of gallons of radioactive and hazardous waste at its 586-squaremile Hanford Site in southeastern Washington State. This waste was 

created as a by-product of producing plutonium and other special nuclear 

materials for nuclear weapons, starting during World War II and 

continuing until the late 1980s. The most hazardous and radioactive 

waste is stored in 177 large underground tanks.1 However, as of January 

2017, none of the tank waste had been treated for disposal because the 

facilities intended to treat a significant portion of this waste—known 

collectively as the Waste Treatment and Immobilization Plant (WTP)—

have faced persistent technical and management challenges that have 

increased the project’s cost by billions of dollars and added decades to 

the waste treatment schedule. Among these challenges, DOE has had 

difficulty ensuring that WTP engineering, procurement, and construction 

work meets nuclear safety and quality requirements.

In 2000, DOE awarded a contract to Bechtel National, Incorporated, to 

design, construct, and commission the WTP. The WTP is a complex, firstof-a-kind project and is being constructed under a design-build contract. 

In the design-build approach, technology development activities, plant 

design, and construction occur simultaneously rather than sequentially. 

 1

The oldest 149 tanks, some of which date back to the 1940s, have single-layer walls, or 

shells; were built to last about 20 years; and will be almost 100 years old by the estimated 

end of waste treatment. DOE has reported that 67 of these tanks are assumed or are 

known to have leaked waste into the soil.

Letter
Page 2 GAO-18-241 Hanford Waste Treatment Plant

DOE no longer allows the use of the design-build approach for complex, 

first-of-a-kind facilities but has continued to use it for the WTP.2

In December 2012, the WTP Engineering Division of DOE’s Office of 

River Protection (ORP) issued a memorandum that recommended that all 

activities affecting engineering design, construction, and installation of 

structures, systems, and components be stopped because the division 

had found that it could not verify that completed work met nuclear safety 

and quality requirements. According to the memorandum, stopping work 

would help the department avoid future nuclear safety and quality 

compromises and substantial rework.3 Instead of stopping all work at the 

WTP, ORP management stopped work only on those facilities that faced 

the most significant technical challenges.4 Around this time, ORP issued 

nine “Priority Level One” findings—findings reflecting problems that if 

uncorrected could have serious effects on safety, quality, and operability 

of a nuclear facility, as well as on the environment, according to ORP’s 

quality assurance guidance.5 Seven of the nine findings were issued by 

ORP’s WTP Engineering Division in 2012 and focused on engineering 

and nuclear safety. The other two were issued by ORP’s Quality 

 2

In 2004, we recommended that DOE avoid using the design-build approach for the 

Hanford tank waste treatment mission. See GAO, Nuclear Waste: Absence of Key 

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

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

concurred with the recommendation, and although it continues to use the design-build 

approach for the WTP, DOE has prohibited this contract structure for other large capital 

asset projects.

3

Department of Energy, Office of River Protection, WTP Engineering Division 

Memorandum: Stop Work Recommendation and Basis (Dec. 19, 2012).

4

Technical challenges vary widely, from the challenge of preventing hydrogen from 

building up in WTP facilities’ piping and vessels and causing an explosion, to the 

challenge of preventing corrosive waste from eroding treatment equipment and causing a 

leak of radioactive materials.

5

Department of Energy, Office of River Protection, Quality Assurance Program 

Description, MGT-PM-PL-04, rev. 4 (Aug. 20, 2014). In ORP’s quality assurance program, 

project issues are identified using condition reports, which ORP quality assurance officials 

submit. Project issues are rated as Priority Level One, Two, or Three. A Priority Level One 

issue is the most serious and is defined as (1) a performance issue that directly or 

indirectly resulted in, or could result in, a major event or systemic breakdown in safety or 

quality or (2) an issue that could have a serious effect or impact on quality, worker health 

or safety, operability, the public, the environment, and facility operations. A Priority Level 

Two project issue is a serious issue that indicates an adverse condition, such as a 

noncompliance or breakdown of a management system.
Page 3 GAO-18-241 Hanford Waste Treatment Plant

Assurance Division in 2013 and focused on the contractor’s quality 

assurance program.

Federal regulations require DOE contractors to establish DOE-approved 

quality assurance programs.6 Under an approved quality assurance 

program, the contractor must establish and implement processes to 

detect and prevent quality problems; identify, control, and correct items, 

services, and processes that do not meet established requirements; 

identify the causes of problems and work to prevent recurrence as a part 

of correcting the problems; and plan and conduct independent 

assessments to measure the adequacy of work performance and to 

promote improvement. ORP’s two Priority Level One findings related to 

quality assurance deficiencies found that the contractor’s quality 

assurance program did not effectively ensure that work was being 

completed to meet these requirements. Significantly, one of the two 

findings concluded that the contractor’s overall quality assurance program 

was not fully effective. The other finding concluded that the contractor’s 

Corrective Action Program to address quality assurance problems was 

not fully effective. Overall, ORP determined that the deficiencies in the 

contractor’s quality assurance program were the most serious type—

those that could result in a systemic breakdown in safety or quality or that 

could have a serious effect on worker health and safety, the public and 

environment, and facility operations. In addition, the report stated that the 

deficiencies warranted immediate attention by the contractor and required 

corrective measures and a high degree of ORP oversight.7

We have reported on the need for effective oversight of nuclear safety—

including quality assurance programs—across the DOE complex, finding 

in 2008 that a strong management and oversight program is needed to 

ensure that DOE’s nuclear operations are carried out in a safe and 

environmentally acceptable manner.8 Also in 2008, we identified key 

elements that any nuclear safety oversight organization should have in 

order for it to provide effective independent oversight. For example, we 

 6

10 C.F.R. part 830, subpart A, Quality Assurance Requirements.

7

Systemic quality assurance problems described in the two Priority Level One findings 

included deficiencies in software quality assurance, document control, and control of 

purchased items and services. 

8

GAO, Nuclear Safety: Department of Energy Needs to Strengthen Its Independent 

Oversight of Nuclear Facilities and Operations, GAO-09-61 (Washington, D.C.: Oct. 23, 

2008). 
Page 4 GAO-18-241 Hanford Waste Treatment Plant

found that the organization should be structurally distinct and separate 

from DOE program offices to avoid management interference or conflict 

between program office mission objectives, such as cost and schedule 

performance, and safety.

Senate Report 114-49 accompanying the Senate version of the National 

Defense Authorization Act for Fiscal Year 2016 includes a provision for 

GAO to carry out an ongoing evaluation of issues related to the WTP. 

This first report (1) describes the actions DOE has taken to identify and 

address quality assurance problems at the WTP, (2) examines the extent 

to which DOE has ensured that all quality assurance problems have been 

identified and will not recur, and (3) examines the extent to which DOE’s 

organizational structure at ORP provides the independence to effectively 

oversee the WTP contractor’s quality assurance program.

To describe the actions DOE has taken to identify and address quality 

assurance problems at the WTP, we obtained and reviewed DOE 

documents and reports that describe ORP and contractor actions, 

including the contractor’s root cause analyses of quality assurance 

problems at the WTP. In addition, we reviewed DOE orders, ORP 

procedures, and documents that describe the requirements DOE is to 

follow to ensure that work meets quality assurance requirements and that 

the contractor has implemented corrective measures for identified quality 

assurance problems.

To examine the extent to which DOE has ensured that all quality 

assurance problems have been identified and will not recur, we reviewed 

internal and external assessments, audits, and reviews of ORP’s and the 

contractor’s quality assurance programs. In addition, we reviewed 

technical and management issues that were reported to the contractor’s 

Corrective Action Management Program database from January 1, 2014, 

when the contractor started to implement corrective measures, to 

September 31, 2017, to identify significant quality assurance problems 

and issues.

To examine the extent to which DOE’s organizational structure at ORP 

provides the independence to effectively oversee the WTP contractor’s 

quality assurance program, we obtained and reviewed internal and 

external reports and assessments conducted by ORP, DOE’s Office of 

Environmental Management’s Office of Standards and Quality Assurance, 

DOE’s Office of Enterprise Assessment, DOE’s Office of Inspector 

General, and the Defense Nuclear Facilities Safety Board, on the portions 

of WTP engineering, procurement, and construction that have been 
Page 5 GAO-18-241 Hanford Waste Treatment Plant

subject to review and examination for adherence to quality assurance 

requirements. In addition, we examined ORP’s record of implementing 

DOE headquarters office’s audit and assessment recommendations 

designed to improve the WTP quality assurance program dating back to 

January 2012.9

To address all of our objectives, we also conducted semi-structured 

interviews, which we used to obtain information from staff with ORP’s 

Quality Assurance, WTP Construction Oversight and Assurance, and 

WTP Engineering Divisions who are involved in the oversight of the 

contractor’s quality assurance program. The group consisted of all nine 

subject matter experts that ORP management identified as employees 

primarily responsible for WTP quality assurance oversight. In this report, 

we refer to this group as ORP quality assurance experts. During the semistructured interviews, we asked a series of questions on DOE’s and the 

contractor’s compliance with quality assurance requirements, as well as 

questions on the resolution of problems with the contractor’s quality 

assurance program and DOE’s oversight of the program. In several 

cases, all nine ORP quality assurance experts were not able to answer 

our questions for various reasons, such as not having recent experience 

working in a particular quality assurance area. In addition to conducting 

semi-structured interviews, for all objectives we interviewed DOE officials 

with ORP; the Inspector General’s Office at Hanford; and DOE 

headquarters offices, including the Office of Environmental 

Management’s Office of Standards and Quality Assurance and the Office 

of Enterprise Assessments. We also interviewed WTP contractors, 

officials from the Washington State Department of Ecology, and officials 

from the Defense Nuclear Facilities Safety Board.

We conducted this performance audit from February 2016 to April 2018 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.

 9

We examined ORP’s implementation of audit and assessment recommendations issued 

by the DOE Inspector General, the Office of Enterprise Assessments, and Environmental 

Management’s Office of Standards and Quality Assurance.
Page 6 GAO-18-241 Hanford Waste Treatment Plant

This section describes DOE’s tank waste treatment approach at Hanford 

and DOE’s quality assurance framework and requirements.

Cleanup of the Hanford Site is governed by two main compliance 

agreements: (1) the 1989 Hanford Federal Facility Agreement and 

Consent Order, or Tri-Party Agreement, an agreement between DOE, the 

Washington State Department of Ecology, and the Environmental 

Protection Agency,10 and (2) a 2010 consent decree.11 The Tri-Party 

Agreement was signed in May 1989 and lays out a series of legally 

enforceable milestones for completing major activities in Hanford’s waste 

treatment and cleanup process.12 The Tri-Party Agreement has been 

amended a number of times to establish additional enforceable 

milestones for certain WTP construction and tank waste retrieval 

activities, among other things. Under the Tri-Party Agreement, DOE must 

complete waste treatment at the Hanford Site by 2047.

The overall mission of the WTP is to treat and immobilize a large part of 

54 million gallons of radioactive and chemical waste stored in 177 

underground storage tanks. The WTP is the most technically complex 

and largest construction project within DOE’s Office of Environmental 

Management, occupying 65 acres of the Hanford Site. Some of DOE’s 

tank waste is highly radioactive material—known as high-level waste—

mixed with hazardous waste. Under current law, this waste must be 

vitrified—a process in which the waste is immobilized in glass—prior to 

disposal. Low-activity waste is DOE’s term for the portion of the tank 

waste at Hanford with low levels of radioactivity. Low-activity waste is 

primarily the liquid portion of the tank waste that remains after as much 

 10Hanford Federal Facility Agreement and Consent Order, Environmental Protection 

Agency Docket No. 1089-03-04-120, Ecology Docket No. 89-54, as amended through 

April 17, 2017. The agreement is available at 

http://www.hanford.gov/page.cfm/TriParty/TheAgreement.

11Washington v. Chu, Civ. No. 08-05085 (E.D. Wash), entered October 25, 2010, as 

amended through April 12, 2016.

12The purpose of the Tri-Party Agreement is to ensure that Hanford cleanup activities 

comply with the Comprehensive Environmental Response, Compensation, and Liability 

Act, Resource Conservation and Recovery Act, and Washington’s Hazardous Waste 

Management Act. DOE entered into the Tri-Party Agreement pursuant to the 

Comprehensive Environmental Response, Compensation, and Liability Act; the Resource 

Conservation and Recovery Act, Executive Order 12580; and the Atomic Energy Act of 

1954. 

Background

DOE’s Tank Waste 

Treatment Approach
Page 7 GAO-18-241 Hanford Waste Treatment Plant

radioactive material as technically and economically practical has been 

removed.13

The WTP consists of the following set of facilities that are designed to 

separate waste into low-activity and high-level waste streams and, once 

completed, treat these waste streams in separate facilities using 

vitrification.

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

tanks and separate it into high-level and low-activity waste streams.

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

waste from the Pretreatment facility and immobilize it by vitrification. 

The canisters of vitrified waste will be permanently disposed of at 

another facility at Hanford.

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

waste from the Pretreatment Facility and immobilize it by vitrification. 

The canisters of vitrified waste will be stored on-site until a final 

repository is established.

• Effluent Management Facility. The Effluent Management Facility is 

being built to evaporate much of the secondary waste produced 

during low-activity waste processing and vitrification at the LowActivity Waste Facility.

• Analytical Laboratory. This facility will conduct analyses as needed, 

such as testing samples of the vitrified waste to ensure that it meets 

certain criteria and regulatory requirements for disposal.14

• Balance of Facilities. These facilities consist of the 22 support facilities 

that make up the plant infrastructure, such as cooling water systems 

and silos that hold vitrifying materials.

 13As designed, the WTP will only be capable of treating less than half of the expected 

quantity of Hanford’s low-activity waste. DOE has indicated that a second plant, or 

alternative approach that is not part of the current project, will be necessary to treat the 

rest of the low-activity waste. See GAO, Nuclear Waste: Opportunities Exist to Reduce 

Risks and Costs by Evaluating Different Waste Treatment Approaches at Hanford, 

GAO-17-306 (Washington, D.C.: May 3, 2017).

14Tank waste to be sent to the Pretreatment Facility for processing must meet specific 

physical and chemical characteristics, known as waste acceptance criteria, and the waste 

must be certified as having met these criteria before transfer from the tank farms to the 

Pretreatment Facility. The criteria may stipulate that waste meet certain requirements for 

chemical composition, particle size, and density.
Page 8 GAO-18-241 Hanford Waste Treatment Plant

In part because of the 2012 work stoppage at the WTP’s Pretreatment 

and High-Level Waste Facilities, in 2012 DOE adopted a phased waste 

treatment strategy through which the department aims to begin treating 

some of the low-activity waste before resolving all WTP technical 

issues.15 During the first phase of this strategy, DOE plans to implement a 

Direct Feed Low-Activity Waste (DFLAW) approach to transfer some lowactivity waste from the tanks to the WTP’s Low-Activity Waste Facility for 

vitrification before the Pretreatment Facility is completed. The approach 

relies on construction of a new facility—the Low-Activity Waste 

Pretreatment System—designed to remove highly radioactive particles 

from liquid tank waste before sending the waste stream to the LowActivity Waste Facility. During later phases, DOE intends to complete the 

WTP Pretreatment Facility and High-Level Waste Facilities. DOE also 

plans to construct a Tank Waste Characterization and Staging Facility 

under a different contract to stage, mix, sample, and characterize highlevel waste from the tanks prior to delivery to the Pretreatment Facility. 

Figure 1 illustrates WTP and other facilities planned for Hanford tank 

waste treatment.

 15In December 2016, DOE and the contractor modified the WTP contract to account for 

the new phased strategy. According to DOE, under the revised contract it will cost 

approximately $16.8 billion to complete the first phase. Through fiscal year 2017, DOE 

has spent $11 billion on the construction of the WTP. The WTP facilities are in various 

stages of design and construction, and DOE and the contractor have not yet negotiated a 

cost for the remaining phases needed to complete the WTP.
Page 9 GAO-18-241 Hanford Waste Treatment Plant

Figure 1: Waste Treatment and Immobilization Plant (WTP) and Other Facilities Planned for Hanford Tank Waste Treatment

Note: The Low Activity Waste Pretreatment System and the Tank Waste Characterization and 

Staging Facility are not part of the WTP, but these facilities may be needed to transport waste from 

the tanks to the WTP.

A set of federal regulations, DOE orders, and ORP procedures 

collectively make up DOE’s quality assurance framework that aims to 

ensure that all WTP quality assurance problems can be identified and that 

identified problems do not recur. DOE’s quality assurance regulations 

require DOE contractors to establish DOE-approved quality assurance 

programs. The regulations specify that under an approved program, the 

contractor’s quality assurance program must, among other things, (1) 

establish and implement processes to detect and prevent quality 

problems; (2) identify, control, and correct items, services, and processes 

that do not meet established requirements; (3) procure items and services 

that meet established requirements and perform as specified; (4) plan 

DOE’s Quality Assurance 

Framework and 

Requirements
Page 10 GAO-18-241 Hanford Waste Treatment Plant

and conduct independent assessments to measure item and service 

quality, to measure the adequacy of work performance, and to promote 

improvement; and (5) maintain items to prevent damage, loss, or 

deterioration.16 In addition, DOE Order 226.1B requires that DOE’s 

organizations and contractors implement oversight processes that ensure 

that relevant quality assurance problems are evaluated and corrected on 

a timely basis to prevent recurrence.17

The WTP contract requires compliance with these regulations and 

requirements. The WTP contract specifies that as the owner of the WTP 

project, DOE is responsible for providing quality assurance oversight of 

the WTP.18 ORP’s Quality Assurance Division provides such oversight, 

for example, by doing the following:

• Reviewing a sampling of the contractor’s documentation on the WTP’s 

engineering, procurement, and construction.

• Conducting audits and assessments to ensure that the contractor’s 

work complies with applicable quality assurance requirements.

• Assessing the effectiveness of the contractor’s Corrective Action 

Management Program, which involves identifying, documenting, 

planning, addressing, and tracking actions required to resolve or 

correct problems.19

Both the contractor’s and ORP’s quality assurance programs require that 

corrective actions to address significant problems with the quality of the 

work must include a determination of the extent to which the problematic 

conditions exist (known as an extent-of-condition review) as well as the 

underlying causes of those conditions. If corrective actions do not 

address the conditions, ORP’s quality assurance policy allows the office 

 1610 C.F.R. § 830.122.

17Department of Energy, Implementation of Department of Energy Oversight Policy, DOE 

Order 226.1B (Washington, D.C.: Apr. 4, 2011). 

18Waste Treatment and Immobilization Plant Contract Number: DE-AC27-01RV14136, 

Section C.3 (b), conformed through Modification No. 406. 

19The Corrective Action Management Program provides a structured issues management 

system. Department of Energy, Implementation of Department of Energy Oversight Policy 

Order 226.1B, stipulates that contractors must implement oversight processes that ensure 

that relevant quality assurance problems are evaluated and corrected to prevent 

recurrence.
Page 11 GAO-18-241 Hanford Waste Treatment Plant

to call for a suspension of work.20 ORP’s stop work procedure includes 

the process ORP is to follow when the Quality Assurance Division 

Director, in consultation with ORP management, determines that work 

needs to be suspended as a result of the occurrence or reoccurrence of 

significant quality assurance problems.21 ORP updated this procedure in 

February 2016 to describe the type of quality assurance deficiencies that 

should trigger consideration of work stoppage. According to the updated 

procedure, characteristics of a deficiency that can trigger an order to stop 

work include, but are not limited to, problems that will result in $25 million 

or more in loss of productivity, construction rework, or environmental 

damage or a significant quality problem that if left uncorrected can result 

in construction delays or create adverse safety conditions. Until February 

2016, ORP did not have precise criteria describing the conditions under 

which it should evaluate work for possible stoppage, according to a DOE 

headquarters report.22

ORP has taken several actions to identify and address quality assurance 

problems at the WTP, but all planned actions have not been completed. 

In 2013 ORP conducted a comprehensive audit, which resulted in several 

actions, including when the office had the contractor begin implementing 

a Managed Improvement Plan (MIP) in 2014. The MIP is intended to 

ensure that the WTP could operate in compliance with DOE-approved 

safety and quality requirements. Implementation of the MIP was to be 

completed by April 2016. Although the contractor reported that the 

implementation was complete, some of the plan’s corrective measures 

have not been fully implemented, according to contractor documents we 

reviewed and quality assurance experts we spoke to. In addition, ORP’s 

effort to verify the extent to which the contractor has implemented MIP 

corrective measures is not scheduled to be complete until at least 

December 2018.

 20Specifically, the policy states that “Work suspension is appropriate when continued work 

would be unsafe, would be likely to create rework, and when safety or quality is 

indeterminate.” Department of Energy, Office of River Protection, Quality Assurance 

Program Description, MGT-PM-PL-04 Revision 4, August 20, 2014.

21Department of Energy, Office of River Protection, ORP Stop Work Procedure, TRSQSH-IP-03, rev. 2 (Feb. 29, 2016).

22Department of Energy, Office of Environmental Management, Quality Assurance Audit 

Report, EM-PA-15-02, ORP, Technical and Regulatory Support, (Washington, D.C.: May 

2015).

ORP Has Taken 

Several Actions to 

Identify and Address 

Quality Assurance 

Problems at the WTP, 

but All Planned 

Actions Have Not 

Been Completed
Page 12 GAO-18-241 Hanford Waste Treatment Plant

ORP has taken several actions to identify and address quality assurance 

problems at the WTP. After the partial work stoppage in 2012, ORP 

conducted an audit in 2013 to evaluate the adequacy, implementation, 

and effectiveness of the contractor’s quality assurance program. The 

audit found that the contractor’s quality assurance program was generally 

adequate. However, it also found that the contractor’s quality assurance 

program was not fully effective in several areas.23 In response to the 

audit, ORP and the WTP contractor took the following actions:

• Developed compensatory measures. At ORP’s request, in 2013, the 

contractor started implementing “compensatory measures” to ensure 

that ongoing WTP work during a 2-year performance improvement 

period would meet DOE quality and safety requirements. For 

example, in September 2013, the contractor implemented a measure 

requiring senior management review of all condition reports and their 

associated levels of significance. According to ORP officials, the 

compensatory measures were intended to be additional, temporary 

internal controls to ensure that work at the WTP did not result in new 

or recurring quality assurance problems.

• Initiated the MIP. To systematically integrate compensatory 

measures, the contractor developed the MIP to address all quality 

assurance problems identified in the two Priority Level One findings 

and the seven Priority Level One findings associated with engineering 

and nuclear safety. In August 2014, the contractor started 

implementing the MIP.24 The MIP is a set of 52 corrective measures 

intended to establish processes, procedures, and metrics to produce 

an overall quality program that ensures that the WTP can safely 

operate in compliance with DOE-approved nuclear safety 

requirements, according to the contractor.25 The measures include the 

following:

 23In particular, the audit found unsatisfactory performance in the program’s ability to 

ensure quality in design control, software design, procurement documentation, control of 

purchased items and services, and corrective actions.

24Department of Energy and Bechtel National, Incorporated, Waste Treatment Plant 

Project Managed Improvement Plan, 24590-WTP-PL-MGT-14-0006, Rev 1, August 2014.

25In August 2014, the contractor estimated that it would cost more than $1 billion to 

implement MIP corrective measures. ORP and contractor officials described the MIP 

implementation cost estimate as a rough order of magnitude cost estimate. According to 

these officials, a more accurate cost estimate was not developed for implementing the 

MIP and actual costs to implement MIP initiatives have not been tracked.

Actions Taken to Identify 

and Address Quality

Assurance Problems at 

the WTP
Page 13 GAO-18-241 Hanford Waste Treatment Plant

• Actions to enhance external independent oversight. This measure 

calls for the contractor to conduct assessments using external 

subject matter experts to evaluate the ability of the contractor’s 

quality assurance program to identify precursors to potential 

problems and their causes. This measure responds to the 2013 

audit in which DOE concluded that the contractor’s quality 

assurance program could not ensure compliance with 

requirements. Specifically, the audit found that the contractor’s 

quality assurance program was not fully effective in several areas, 

including, but not limited to, design, software quality, procurement, 

and ensuring that identified problems are corrected.

• Actions to ensure that procured items and services meet 

requirements and perform as specified. This measure is intended 

to ensure that the contractor’s processes and procedures to 

identify and ensure the quality of technical products meet 

requirements. The nuclear industry uses “commercial grade 

dedication” to refer to the process by which the contractor or 

subcontractor verifies that an item (e.g., an electric switch) or 

service (e.g., design of an electrical system) can meet commercial 

quality and safety requirements and be approved for use in a 

nuclear facility. It requires the contractor to perform source 

verification, perform inspections and tests, and assess the 

processes that control the quality of purchased items and services 

to help ensure that critical components of procured items and 

services are designed, fabricated, assembled, installed, and 

tested with appropriate documentation to support their compliance 

with WTP safety requirements. This measure also responds to 

DOE’s 2013 audit, which found that the contractor had inadequate 

control over the quality of purchased items and services.

• Actions to control and correct items and processes that do not 

meet requirements. This measure is intended to allow the 

contractor to identify and ensure that materials and equipment that 

have been received, and that will be received in the future, meet 

requirements. The contractor is to conduct comprehensive 

reviews of previously received material and equipment, as well as 

all future deliveries, to help ensure the verification, accuracy, and 

completeness of documentation for materials and equipment 

received from suppliers. This measure also responds to DOE’s 

2013 audit, which found that the contractor had received 

components that did not comply with safety requirements.

• Performed targeted audits to test compensatory measures and the 

implementation of the MIP. To assess the effectiveness of the 
Page 14 GAO-18-241 Hanford Waste Treatment Plant

compensatory measures and the MIP, ORP performed targeted 

audits. For example, to assess the extent to which the contractor has 

addressed quality assurance program deficiencies, in early 2017 

ORP’s Quality Assurance Division conducted a “vertical slice audit.”

This audit reviewed engineering, procurement, and construction of a 

key system that will be needed for initial WTP operations.

Because of the long-standing quality assurance problems at the WTP, 

DOE required ORP to closely monitor the contractor’s implementation of 

the MIP. Specifically, as a result of a DOE Office of Enforcement 

investigation into the contractor’s quality assurance and corrective action 

management programs, DOE entered into a Consent Order with the 

contractor in 2015.26 The Consent Order required the contractor to 

complete the actions identified in the MIP to the extent necessary to 

restore quality assurance program to full effectiveness by April 30, 

2016.27 The Consent Order does not preclude DOE from reopening the 

investigation or issuing an enforcement action if there is a recurrence of 

nuclear safety deficiencies similar to those identified in the Consent Order 

or the if contractor fails to complete actions required by the Consent 

Order in a timely and effective manner to prevent recurrence of the 

identified issues.

The contractor has not fully implemented corrective measures for all 

identified quality assurance problems, according to contractor documents 

we reviewed. In August 2017, the contractor reported that it had finished 

its actions to implement the MIP.28 However, according to the contractor’s 

MIP status update accompanying the contractor’s report, 13 of the 52 

corrective measures specified in the MIP had not been fully implemented. 

Our review of these 13 MIP corrective measures we found that 9 were 

intended to exclusively or partially address weaknesses in the 

 26DOE has established procedures for (1) investigating the nature and extent of violations 

of DOE nuclear safety requirements, (2) determining whether a violation of these 

requirements has occurred, (3) imposing an appropriate remedy, and (4) adjudicating the 

assessment of a civil penalty at 10 C.F.R. part 820.

27Consent Order Incorporating Agreement Between U.S. Department of Energy and 

Bechtel National Incorporated, NCO-2015-02, June 8, 2015.

28Bechtel National, Incorporated, Letter to ORP Manager, Closure of the MIP (Aug. 24, 

2017).

Corrective Measures to 

Address Quality 

Assurance Problems at 

the WTP Have Not Been 

Fully Implemented
Page 15 GAO-18-241 Hanford Waste Treatment Plant

contractor’s quality assurance program.29 For example, the two corrective 

measures to ensure that WTP facilities’ computer software meets 

requirements were not complete, according to the MIP status update. 

These corrective measures included improving the software procurement 

process and revising the quality assurance manual.

In addition, of the 39 measures that the contractor considers complete, 

some do not appear to be fully implemented, according to one ORP 

quality assurance expert that we spoke to. For example, one ORP quality 

assurance expert disagreed with the contractor’s assessment that a

corrective measure for documentation pertaining to radiographic film—

which is needed for conducting quality assurance reviews of certain 

equipment—was fully implemented. This corrective measure calls for the 

contractor to review purchase orders for radiographic film and then store 

the radiographic film as documentation of compliance with nuclear quality 

standards. According to the expert, radiographic film reviews are still not 

consistently conducted, and radiographic film documentation is still not 

consistently stored. In cases where such documentation is incomplete or 

missing, the contractor is at times forced to re-create the documentation 

at considerable cost to DOE. According to ORP’s MIP oversight plan, it 

will take the office until at least December 2018 to verify the extent to 

which the contractor has implemented each of the 52 MIP corrective 

measures.

 29Among the incomplete measures, one is related to the quality of procuring commercial 

items for use in a nuclear facility. ORP has previously identified weaknesses in quality 

assurance in this area on several occasions. For example, in 2008 ORP reported that the 

contractor had not met its due date to complete corrective actions to address weaknesses 

in its procedures for procuring commercial items for use in a nuclear facility. Later, in 2015 

ORP found that the contractor’s internal controls for this process were not consistently 

performed; did not consistently comply with procedural requirements; and, in many cases, 

did not establish reasonable assurance that procured systems, services, and components 

would perform their intended safety functions . 
Page 16 GAO-18-241 Hanford Waste Treatment Plant

According to DOE documents we reviewed and ORP quality assurance 

experts we spoke with, ORP’s actions have not ensured that all quality 

assurance problems have been identified at the WTP, and some 

previously identified problems are recurring. Specifically, according to 

DOE documents and the experts we spoke with, ORP’s oversight has not 

ensured that the contractor has identified all quality assurance problems 

in structures, systems, and components that were completed and 

installed before the 2012 work stoppage or identified all such problems in 

newer structures, systems, and components needed for initial WTP 

operations. In addition, according to the documents we reviewed and 

experts we interviewed, previously identified quality assurance problems 

are recurring.

Recent DOE reviews have found that ORP has not ensured that all 

quality assurance problems have been identified at the WTP. First, a 

2016 DOE Office of Enterprise Assessment report found quality 

assurance deficiencies that neither ORP nor the contractor had identified 

at the time the work was conducted. 30 The report identified numerous 

construction deficiencies, procurement and supplier deficiencies, 

engineering errors, maintenance issues, and materials with expired shelf 

lives. For example, the report identified welding deficiencies on tanks 

designed to hold nuclear waste that were identified in a WTP facility 

several years after the tanks were installed. The report concluded that the 

contractor is aware that significant quality assurance problems likely exist 

in older structures, systems, and components. This report noted that 

much of the equipment in older structures, systems, and components was 

manufactured and delivered to the project from 5 to 10 years ago—and 

some of this equipment was supplied by vendors or manufacturers that 

are no longer in business—which could lead to costly rework.

Second, a 2015 DOE Inspector General report found that the contractor 

had procured $4 billion in parts and materials through fiscal year 2014, 

but ORP and the contractor had not always identified problems with the 

quality of procured items in a timely manner. For example, the report 

found that in about 45 percent of the nearly 1,400 procurement problems 

reviewed, the contractor did not identify the problems until at least 2 years 

after the items arrived on site. The report also found that in many cases 

 30Department of Energy, Office of Enterprise Assessments Assessment of Construction 

Quality at the Hanford Site Waste Treatment and Immobilization Plant (June 2016).

ORP Has Not 

Ensured That All 

Quality Assurance 

Problems Have Been 

Identified, and Some 

Previously Identified 

Problems Are 

Recurring

ORP Oversight Has Not 

Ensured That the 

Contractor Has Identified 

All Quality Assurance 

Problems
Page 17 GAO-18-241 Hanford Waste Treatment Plant

the contractor canceled its efforts to recover the costs to resolve the 

problems because of the length of time that had passed. The report 

concluded that these problems were caused by weaknesses in the 

contractor’s quality assurance program and that the contractor’s 

procedures to prevent or identify problems with procured items were not 

always followed effectively.

The findings of these reports are consistent with the views of ORP quality 

assurance experts we spoke with who stated that ORP oversight has not 

ensured that the contractor has identified all quality assurance problems 

in structures, systems, and components—particularly those that were 

completed and installed before the 2012 work stoppage. These quality 

assurance experts said that because quality assurance problems have 

not been identified, they expect significant rework will be needed for work 

that was completed before 2012. Specifically, most of the ORP quality 

assurance experts (seven of the nine) told us that they expect rework will 

be needed for existing WTP facilities, such as the Pretreatment and HighLevel Waste Facilities. One of these seven quality assurance experts 

noted that the contractor does not have a complete record of the 

documentation for key systems and equipment, which is required for 

demonstrating compliance with nuclear safety standards and eventual 

permitting of WTP facilities for operation. According to this expert, the 

extent of this shortcoming is not known, but fixing it—that is, creating a 

complete record of required documentation—may lead to years of delays.

ORP Quality Assurance Division officials told us that because ORP’s 

focus is on ensuring that facilities needed for initial operations will be 

ready to operate by December 2023, they have not been directed by ORP 

management to focus on identifying all quality assurance problems for 

work completed before 2012 for facilities needed for later phases of WTP 

operations, such as structures, systems, and components of the 

Pretreatment and High-Level Waste Facilities. In addition, they stated that 

there may be significant changes to these facilities needed for the WTP’s 

later phases, making it unnecessary for them to review the extent of 

quality assurance problems until it is known what parts of the facilities will 

remain and which parts will not.

However, similar problems appear to exist in WTP facilities needed for 

initial operations. ORP quality assurance experts that we interviewed also 

stated that ORP oversight has not always ensured that all quality 

assurance problems in facilities needed for the initial WTP operations, or 

DFLAW, have been identified. Five experts told us that issues such as 

identifying problematic items, services, and processes had not been fully 
Page 18 GAO-18-241 Hanford Waste Treatment Plant

resolved. Specifically, these ORP quality assurance experts told us that 

when quality assurance problems are identified in structures, systems, or 

components needed for DFLAW, ORP does not always ensure that the 

contractor identifies the extent to which such problems may exist in other 

areas affected by the same structures, systems, or components. For 

example, an ORP quality assurance expert cited an instance in which an 

ORP quality assurance team reviewed a sample of 25 procurement 

“packages” (out of thousands) for a DFLAW facility and identified 143 

problems—significantly more problems than the team expected for such a 

small sample. Consistent with ORP quality assurance requirements, this 

ORP quality assurance expert recommended to ORP upper management 

that the contractor determine the extent to which such problems could 

affect other structures, systems, and components needed for DFLAW. 

However, according to an ORP memo, ORP upper management did not 

require the contractor to implement this recommendation, instead citing 

“extenuating circumstances” and requiring a lesser corrective action than 

what was recommended. Three ORP quality assurance experts told us 

that they believe that because problems have not been comprehensively 

assessed, there may be equipment and systems within DFLAW that will 

fail to meet their intended functions.

We also found that although ORP conducted its vertical slice audit in 

2017 to test its compensatory measures and the MIP to improve quality 

assurance, the audit report notes that it was focused on only one system 

within the Low-Activity Waste Facility.31 According to ORP officials, there 

are numerous structures, systems, and components in facilities needed 

for DFLAW that have not been audited or reviewed in a manner similar to 

the vertical slice audit. Both the contractor’s and ORP’s quality assurance 

programs require that corrective actions to address significant problems

with the quality of the work include a determination of the extent to which 

the problematic conditions exist as well as the underlying causes of those 

conditions. Until ORP requires the WTP contractor to determine the full 

extent to which problems exist in all WTP structures, systems, and 

components, DOE lacks a comprehensive understanding of all potential 

quality assurance problems at all WTP facilities.

 31ORP Quality Assurance Division officials told us that they selected this system for audit 

because it was the only major system in which all engineering, procurement, and 

construction occurred after the contractor had started new internal controls.
Page 19 GAO-18-241 Hanford Waste Treatment Plant

DOE requires its program offices, such as ORP, and contractors to have 

oversight processes to ensure that quality assurance problems are 

evaluated and corrected in a timely basis to prevent recurrence. However, 

several DOE documents we reviewed show that previously identified 

quality assurance problems have recurred in recent years, including the 

following:

• In 2015, an ORP audit report identified recurring weaknesses in 

quality assurance for the contractor’s process for procuring 

commercial items for use in a nuclear facility.32 For example, ORP 

found that the contractor’s internal controls for this process were not 

consistently performed; did not consistently comply with procedural 

requirements; and, in many cases, did not establish reasonable 

assurance that procured systems, services, and components acquired 

from 2010 to 2014 would perform their intended safety functions.

• In a 2015 report on the design and operability of key systems and 

components for the Low-Activity Waste Facility, ORP found that the 

quality of computer systems software was not in full compliance with 

DOE requirements, leading to conditions where personnel and the 

environment may not be adequately protected.33 ORP had identified a 

similar problem in 2008, when it found that the contractor’s computer 

programs used in engineering calculations were not always verified to 

show that they produced correct solutions within defined limits for all 

parameters, as required by the contractor’s quality assurance manual. 

ORP had also previously identified WTP computer software quality 

problems in 2010 when it issued a Priority Level Two finding on 

software procedures and another Priority Level Two finding on 

software testing.

• In 2017, ORP’s Quality Assurance Division issued a report that 

examined the contractor’s quality assurance program and found 

problems in quality assurance areas that had been previously 

 32Department of Energy, ORP of Bechtel National, Inc. Commercial Grade Dedication 

Program, Audit Report U-14-QAD-RPPWTP-003 (Aug. 6, 2015).

33Department of Energy, Office of River Protection, Waste Treatment and Immobilization 

Plant Low-Activity Waste Facility Design and Operability Review and Recommendations

(Sept. 4, 2015).

Previously Identified 

Quality Assurance 

Problems Are Recurring
Page 20 GAO-18-241 Hanford Waste Treatment Plant

identified.34 The report noted that in 6 of 19 quality assurance 

program areas, the contractor’s performance was marginal—and in 

need of improvement—or indeterminate. These 6 areas included 

identifying, controlling, and correcting items, services, and processes 

that do not meet established requirements; maintaining items to 

prevent damage, loss, or deterioration; and procuring items and 

services that meet established requirements and perform as specified.

ORP quality assurance experts that we spoke with also stated that 

previously identified quality assurance problems are recurring, including 

some in areas where the contractor had implemented corrective 

measures. These quality assurance experts told us that quality assurance 

problems are recurring in several key areas, including those areas 

identified in the documents described above: (1) procurement of items 

and services that do not meet established requirements or perform as 

specified; (2) software that does not meet established requirements; and 

(3) a maintenance program that does not prevent damage, loss, or 

deterioration of WTP structures, systems, and components. For example, 

see the following.

• Procurement of items and services that do not meet requirements or 

perform as specified. Four out of the five ORP quality assurance 

experts we interviewed who had recent experience with the 

procurement of items and services told us that problems with 

procured items and services that do not meet established 

requirements or perform as specified are not fully resolved. One of 

these ORP quality assurance experts stated that an ORP team 

recently reviewed a random sample of 45 of the roughly 30,000 

procurements the contractor had made for the WTP and identified a 

number of instances where materials did not meet requirements, 

which resulted in one Priority Level Two finding—which represents a 

serious issue that indicates an adverse condition, such as a 

noncompliance or breakdown of a management system—and five 

 34Department of Energy, ORP Effectiveness Determination of Bechtel National, Inc. 

Project Office Corrective Actions Related to Audit Findings U-13-QAT-RPPWTP-001-F01 

and U-13-QAT-RPPWTP-001-F02, and Overall Adequacy, Implementation, and 

Effectiveness of Bechtel National, Incorporated Quality Assurance Program (February 

2017).
Page 21 GAO-18-241 Hanford Waste Treatment Plant

Priority Level Three findings. The expert noted that this was many 

more deficiencies than the team expected for such a small sample.35

• Software that does not meet requirements. ORP quality assurance 

experts told us that problems are recurring in certain areas where 

items and processes do not meet requirements, such as computer 

software quality assurance, despite the contractor developing two MIP 

corrective measures in this area. Two ORP quality assurance experts 

reported that problems with software quality are recurring. One ORP 

quality assurance expert added that the contractor often fails to 

develop software quality documentation that is needed to demonstrate 

compliance with quality requirements when permitting facilities for 

operation. As a result, the contractor will have to re-create this 

documentation at some cost.

• A maintenance program that does not prevent damage, loss, or 

deterioration. Each of the three ORP quality assurance experts with 

knowledge in this area told us that the contractor had not established 

a fully effective WTP maintenance program, particularly for the 

Pretreatment and High-Level Waste Facilities, and as a result, 

structures, systems, and components at these facilities have 

deteriorated and been damaged.36 Such statements are consistent 

with findings of the Defense Nuclear Facilities Safety Board, which 

reported in April 2016 that systems and components stored in an 

outdoor storage yard were not properly covered and showed signs of 

being affected by water, sand, or animals. In March 2016, ORP 

reported significant water intrusion into several areas of the HighLevel Waste Facility. As a result, some of the facility’s structures, 

systems, and components had deteriorated and will require costly 

rework. The contractor notified DOE in April 2017 that because DOE’s 

focus is on completing facilities needed for initial WTP operations, it 

would submit a proposal to change the WTP contract to account for 

the increased scope, cost, and schedule of long-term maintenance, 

storage, and management of procured and partially installed 

 35According to one ORP quality assurance expert, the contractor’s delay in inspecting 

items—and its interest in maintaining relationships with vendors—have prevented it from 

seeking reimbursement for items that do not meet requirements. In some cases, vendors 

are no longer in business when the contractor has discovered that a part does not meet 

requirements, and in other cases, the contractor has not sought reimbursement because it 

wants to maintain its ability to procure parts from the vendor in the future. 

36The three ORP quality assurance experts who could discuss this area told us that this it 

is not yet fully resolved.

Settlement of Allegations of Contractors 

Knowingly Mischarging Costs at the Waste 

Treatment and Immobilization Plant (WTP)

In November 2016, the WTP contractor and 

certain subcontractors agreed to pay $125 

million to resolve allegations under the False 

Claims Act that they made false statements 

and claims to the Department of Energy (DOE) 

by charging DOE for deficient nuclear quality 

materials, services, and testing that were 

provided to the WTP at DOE’s Hanford Site. 

The contract required materials, testing, and 

services to meet certain nuclear quality 

standards. The Department of Justice alleged 

that the defendants violated the False Claims 

Act by charging the government the cost of 

complying with these standards when they 

failed to do so. In particular, the Department of 

Justice alleged that the defendants improperly 

billed the government for materials and 

services from vendors that did not meet quality 

control requirements, for piping and waste 

vessels that did not meet quality standards, 

and for testing from vendors that did not have 

compliant quality programs. As part of the 

settlement, the contractors admitted no 

wrongdoing, and the United States did not 

concede that its claims were not well founded.

Source: Department of Justice. | GAO-18-241
Page 22 GAO-18-241 Hanford Waste Treatment Plant

structures, systems, and components at those facilities not needed for 

initial WTP operations.

Consistent with its quality assurance procedures, ORP can use its 

authorities—such as those under the Consent Order and its quality 

assurance policy—to stop work if corrective measures do not prevent 

quality assurance problems from recurring. However, ORP has not used 

such authorities. ORP senior officials told us that they did not consider it 

necessary to stop work because of the recurrence of problems in certain 

areas because they plan to evaluate the extent of the contractor’s 

implementation of MIP corrective measures over the next year and have 

allowed work to continue because they believe that the contractor’s 

quality assurance program is generally adequate. Without directing ORP 

to use its authorities to stop work in areas where quality assurance 

problems are recurring until it can verify that the problems are corrected 

and will not recur, DOE may face future rework that could increase costs 

and schedule delays for the WTP.

A 2017 assessment from DOE headquarters and our interviews with nine 

ORP quality assurance experts suggest that ORP’s organizational 

structure does not provide the quality assurance function with sufficient 

independence from upper management—which includes the ORP 

Manager and the WTP Federal Project Director—to effectively oversee 

the contractor’s quality assurance program. Our prior work has found that 

to be independent, an oversight organization should be structurally 

distinct and separate from program offices responsible for achieving the 

program’s mission to avoid management interference or conflict between 

program office mission objectives and safety.37 At ORP, however, the 

Quality Assurance Division is not fully separate and independent from the 

upper management of the WTP project, which manages cost and 

schedule performance. We believe that such a structure has the potential 

to create a conflict of interest.

Specifically, we found that ORP’s Quality Assurance Division performs 

assessments of the contractor’s quality assurance program, among other 

things, and reports its findings to ORP upper management, including the 

ORP Manager, who has the discretion to determine whether and to what 

extent to require the contractor to take action in response to findings. 

When quality assurance issues are identified, ORP upper management 

 37GAO-09-61. 

ORP’s Organizational 

Structure May Not 

Provide Sufficient 

Independence for 

Effective Oversight of 

the WTP Contractor’s 

Quality Assurance 

Program
Page 23 GAO-18-241 Hanford Waste Treatment Plant

must balance its mission of meeting cost and schedule targets with its 

responsibility to ensure that nuclear safety and quality standards are met. 

However, these are two potentially conflicting responsibilities because 

meeting WTP cost and schedule targets may be threatened if serious 

quality assurance problems are identified.

A February 2017 external assessment from DOE headquarters noted that 

ORP’s Quality Assurance Division’s effectiveness has been limited 

because, in some instances, its findings have been mischaracterized by 

ORP upper management, and in others, ORP upper management has not 

used this division effectively to evaluate the extent of potential quality 

assurance problems.38 This assessment found that ORP had not 

performed adequate oversight of the contractor’s MIP and that some 

critical quality assurance areas were not receiving the necessary scrutiny 

from ORP. Further, the assessment found that ORP management 

sometimes mischaracterized the seriousness of the Quality Assurance 

Division’s findings and, as a result, did not require the contractor to 

conduct extent-of-condition review for significant quality assurance 

problems. While this assessment stated that ORP had an effective quality 

assurance program, it concluded that three of the eight quality assurance 

areas the assessment team reviewed were not fully effective, including 

ORP’s ability to conduct assessments of the contractor’s quality 

assurance program.

The views of ORP quality assurance experts with whom we spoke are 

consistent with the findings of the 2017 DOE assessment. For example, 

see the following:

• Two ORP quality assurance experts told us that quality assurance 

findings are reviewed and approved by ORP upper management 

before being transmitted to the contractor, and in some instances 

ORP upper managements downgraded the Quality Assurance 

Division’s findings. For example, a 2015 ORP quality assurance 

assessment found that many items procured from 2010 to July 2014 

did not appear to meet nuclear safety requirements. One of these 

experts told us that the ORP Quality Assurance Division 

recommended that ORP management issue a Priority Level One 

finding, the most significant of three levels, based on this 2015 

assessment. However, according to this expert, ORP upper 

 38Department of Energy, Quality Assurance Analysis Report on the Office of River 

Protection Quality Assurance Program (February 2017).
Page 24 GAO-18-241 Hanford Waste Treatment Plant

management chose to issue it as a Priority Level Two finding, 

meaning that ORP considered the problem less severe and required 

the contractor to implement less stringent corrective measures to 

address the issue. The ORP quality assurance expert and an ORP 

upper manager told us that it was the WTP federal project director 

and the former ORP Manager who downgraded this Quality 

Assurance Division finding.

• Two other ORP quality assurance experts told us that ORP upper 

management and the contractor place cost and schedule performance 

above identifying and resolving quality assurance issues. One quality 

assurance expert specified that ORP’s culture does not encourage 

staff to identify quality assurance problems or ineffective corrective 

measures. This expert said that people who discover problems are 

not rewarded; rather, their findings are met with resistance, which has 

created a culture where quality assurance staff are hesitant to identify 

quality assurance problems or problems with corrective measures. 

This expert added that quality assurance is subordinate to cost and 

schedule—that is, senior managers responsible for approving quality 

assurance findings are more concerned with whether WTP 

construction meets schedule milestones than identifying and resolving 

quality assurance issues. This expert compared the WTP to the 

Zimmer Power Plant—a power plant in Ohio that was designed to be 

a nuclear power plant but that was never licensed because of 

unresolved quality assurance problems and a focus on schedule over 

construction quality. 

As stated earlier, in October 2008, we identified key elements that any 

nuclear safety oversight organization should have in order for it to provide 

effective independent oversight.39 For example, we found that an 

organization should be structurally distinct and separate from DOE 

program offices to avoid management interference or conflict between 

program office mission objectives, such as cost and schedule 

performance and safety. We also found that the organization should have 

sufficient authority to require program offices to effectively address its 

findings and recommendations.

ORP’s Assistant Manager for Technical and Regulatory Support and ORP 

senior quality assurance staff told us that ORP’s organizational structure 

ensures that the quality assurance function is sufficiently independent of 

ORP management. These officials and the ORP Quality Assurance 

 39GAO-09-61. 

A Cautionary Tale: Quality Assurance 

Problems Doom Commercial Nuclear 

Power Plant

In the commercial nuclear industry, there is a 

notable example of a construction project that 

faced significant quality assurance challenges. 

In the 1970s and early 1980s, Cincinnati Gas 

& Electric attempted to construct a commercial 

nuclear power plant, known as the Zimmer 

Plant, near Moscow, Ohio. After 10 years of 

construction and more than $2 billion spent, 

the company abandoned its effort to construct 

the plant. An independent review mandated by 

the Nuclear Regulatory Commission in 1982 

concluded that several issues impeded 

successful construction of the Zimmer Plant as 

a commercial nuclear power plant. These 

issues included (1) the company’s failure to 

elevate its commitment to quality and quality 

assurance to an equal status with cost and 

schedule, (2) the regulator’s failure to hold the 

company accountable for quality in design and 

construction, and (3) the company’s 

inadequate quality assurance procedures. To 

recoup some of the $2 billion spent in 

attempting to construct this commercial 

nuclear power plant, Cincinnati Gas & Electric 

later converted facilities built at the site for use 

in a coal-fired power plant.

Source: Nuclear Regulatory Commission. | GAO-18-241
Page 25 GAO-18-241 Hanford Waste Treatment Plant

Program Description state that the Quality Assurance Division is 

structured to report directly to the ORP Assistant Manager for Technical 

and Regulatory Support and the ORP Manager. They also cited the ORP 

Quality Assurance Program policy, which states that the Quality 

Assurance Division has the authority and overall responsibility to 

independently audit the contractor’s quality assurance program to verify 

the achievement of quality. According to these officials, this organizational 

structure ensures independence from cost and schedule considerations 

and ensures objectivity in quality assurance evaluations, and they added 

that the ORP Manager evaluates differing opinions without any 

hindrances or organizational bias.

Given that some previously identified problems are recurring at the WTP, 

including some in areas where the contractor had implemented corrective 

measures, and given the findings of the 2017 headquarters assessment 

and the statements of ORP’s quality assurance experts outlined above, 

we are concerned that ORP’s organizational structure may not entirely 

ensure that the Quality Assurance Division meets key elements for a 

nuclear safety oversight organization to provide effective independent 

oversight. According to ORP reports and officials, in ORP’s current 

organizational structure, upper level management retains discretion in 

how to resolve quality assurance problems. As a result, the Quality 

Assurance Division does not have sufficient authority to ensure that its 

findings are addressed and its recommendations are implemented. By 

revising ORP’s organizational structure so that the quality assurance 

function is independent of ORP upper-level management, DOE can have 

better assurance that compliance with nuclear safety requirements will 

not be subordinated to meeting cost and schedule targets.

For years DOE has faced quality assurance problems at the WTP. Upon 

learning in 2012 that it could not verify that engineering, procurement, and 

construction at the WTP met nuclear safety and quality requirements, 

ORP directed the contractor to implement quality assurance corrective 

measures to ensure that problems would be identified and prevented from 

recurring. However, 5 years later, the contractor has not fully 

implemented all planned corrective measures. Moreover, in some areas 

where the contractor has stated that corrective measures are now in 

place, ORP continues to encounter quality assurance problems similar to 

those it encountered in the past. When and where problems have 

recurred, ORP has not always required the contractor to determine the 

extent to which the problems may affect all parts of the WTP. By directing 

ORP to require the WTP contractor, where quality assurance problems 

Conclusions
Page 26 GAO-18-241 Hanford Waste Treatment Plant

have been identified, to determine the full extent to which problems exist 

in all WTP structures, systems, and components, DOE will gain a 

comprehensive understanding of all quality assurance problems at all 

WTP facilities. In addition, ORP has not always used its authorities to 

stop work when problems are detected before they are fully corrected. 

Without directing ORP to use its authorities to stop work in areas where 

quality assurance problems are recurring until it can verify that the 

problems are corrected and will not recur, DOE may face future rework 

that could increase costs and schedule delays for the WTP.

Also of concern is the potential lack of sufficient independence of ORP’s 

Quality Assurance Division from ORP’s upper management. This has 

resulted in ORP upper management not always allowing its own experts 

to fully examine the contractor’s work even when problems have recurred. 

At other times, this has resulted in the significance of identified 

problems—and strength of associated corrective measures—being 

reduced. DOE’s ability to effectively self-regulate a high-hazard nuclear 

facility not only depends on vigorous oversight of the contractor by the 

program office but also on active oversight by an independent group. The 

WTP is the largest and most technically complex cleanup project 

managed by DOE, and we recognize that meeting its cost and schedule 

targets places immense pressure on ORP upper management. However, 

meeting those targets is further threatened when quality assurance 

problems are downgraded. By revising ORP’s organizational structure so 

that the quality assurance function is independent of ORP upper 

management, DOE can have better assurance that compliance with 

nuclear safety requirements will not be subordinated to meeting cost and 

schedule targets.

We are making the following three recommendations to DOE:

The Secretary of Energy should direct ORP to require the WTP contractor 

to determine the full extent to which problems exist in all WTP structures, 

systems, and components.

The Secretary of Energy should direct ORP to use its authorities to stop 

work in areas where quality assurance problems are recurring until ORP’s 

Quality Assurance Division can verify that the problems are corrected and 

will not recur.

Recommendations for 

Executive Action
Page 27 GAO-18-241 Hanford Waste Treatment Plant

The Secretary of Energy should revise ORP’s organizational structure so 

that the quality assurance function is independent of ORP upper 

management.

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

its written comments, reproduced in appendix I, DOE generally agreed 

with the findings in the report and its recommendations. DOE agreed with 

our first two recommendations and described actions it has under way 

and planned to address them. In addition, DOE agreed with our third 

recommendation—to revise ORP’s organizational structure so that the 

quality assurance function is independent of ORP upper management—in 

principle. While DOE states that it believes that the current ORP quality 

assurance reporting relationship meets all established requirements, it 

also states that the report identifies instances that indicate that ORP 

could be strengthened to improve the effectiveness and independence of 

its quality assurance functions. In response to our recommendation, DOE 

plans to direct ORP to assess the quality assurance functional reporting 

lines, responsibilities, and processes to enhance the independence of the 

quality function from cost and schedule influences and to strengthen and 

clarify quality assurance reporting to the ORP Manager. This planned 

action is a positive first step toward implementing our recommendation.

We are sending copies of this report to the appropriate congressional 

committees; the Secretary of Energy; and other interested parties. In 

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov.

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

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

our Offices of Congressional Relations and Public Affairs may be found 

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

contributions to this report are listed in appendix II.

David C. Trimble

Director, Natural Resources and Environment

Agency Comments 

and Our Evaluation
Appendix I: Comments from the Department of 

Energy

Page 28 GAO-18-241 Hanford Waste Treatment Plant

Appendix I: Comments from the Department 

of Energy
Appendix I: Comments from the Department of 

Energy

Page 29 GAO-18-241 Hanford Waste Treatment Plant
Appendix I: Comments from the Department of 

Energy

Page 30 GAO-18-241 Hanford Waste Treatment Plant
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 31 GAO-18-241 Hanford Waste Treatment Plant

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

In addition to the contact named above, Nathan Anderson (Assistant 

Director), Mark Braza, Scott Fletcher, Ellen Fried, Richard Johnson, Paul 

Kazemersky, and Peter Ruedel made key contributions to this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100625)
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