Nuclear Waste: DOE's Efforts to Protect the Columbia River from Contamination Could Be Further Strengthened
Published: 2006-08-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Department of Energy's (DOE) Hanford site in Washington State is one of the most contaminated nuclear waste sites in North America. The Columbia River flows through about 50 miles of the site. Radioactive and hazardous contamination from decades of producing nuclear materials for the nation's defense have migrated through the soil into the groundwater, which generally flows toward the river. In November 2005, GAO reported on the potential for the Hanford site to contaminate the Columbia River. To address continuing concerns, GAO reviewed the status of DOE's efforts to (1) understand the risk to the Columbia River from Hanford site contamination and to deploy effective technologies to address contamination near the river and (2) strengthen the management of its river protection program. To assess DOE's efforts, GAO reviewed numerous reports by DOE and others, and discussed the problem with federal and state regulators and DOE officials.
section_title: What GAO Found
paragraphs: DOE is actively assessing the risk to the Columbia River from Hanford site contamination and is addressing problems with deployed river protection technologies. While DOE has extensive knowledge of contaminants that are currently in the groundwater and river, DOE knows less about contamination in the soil below the surface, known as the "vadose zone." Before proposing a cleanup approach, DOE has agreed with its regulators to take vadose zone samples in many of the contaminated areas of the site. DOE is also improving its computer simulation model that will predict future risk from the contamination, and deploying alternative technologies it believes will more effectively contain the contamination that may threaten the river. DOE has also begun to address concerns about its management of Columbia River protection efforts, particularly the lack of integration between groundwater and vadose zone activities. In March 2006, in response to congressional committee direction, DOE proposed a new initiative to better integrate its river protection activities. The initiative included consolidating most groundwater and vadose zone characterization work under a single project; better integrating vadose zone, groundwater, and surface cleanup decisions; and improving the coordination and control over computer models used to predict movement of contamination in future years. Initiating these management improvements is important, but it is equally important that they be implemented effectively, and past history gives some cause for concern. For example, one attempt by DOE to better integrate these activities was unsuccessful when key elements, such as putting all activities under a single project manager, failed to continue after project and other changes occurred at the site. In past GAO work, we reported that high-performing organizations sustained improvement initiatives when key elements were in place, such as clear goals, results-oriented performance measures, and evaluation strategies. Although DOE is beginning to develop a management plan for its new initiative, DOE has yet to implement some key elements, such as results-oriented performance measures and evaluations to gauge the effectiveness of its improvements, which could also help sustain the benefits of the improvements over time.

section_title: Letter
paragraphs: The Department of Energy’s (DOE) Hanford site in southeastern  Washington State is one of the most contaminated nuclear waste sites in  North America. The site occupies 586 square miles upriver from the cities  of Richland, Pasco, and Kennewick, with a combined regional population  of over 200,000. During Hanford’s production era, beginning in 1943, nine  nuclear reactors were built at the site to produce nuclear materials,  especially plutonium, for the nation’s defense. The site was selected, in  part, because the Columbia River, the nation’s second largest river by  volume, flows through almost 50 miles of it; the river water was used to  cool nuclear reactors and support nuclear materials processing  operations. During operations from 1943 to 1989, activity at the reactors  and other facilities also generated large volumes of hazardous and  radioactive waste. Some of this waste was deposited directly into the  ground in trenches, injection wells, or other facilities designed to allow the  waste to disperse into the soil; some was packaged into drums and other  containers and buried; and some was stored in 177 large underground  tanks.
Over time, concern has developed about the impact of Hanford’s  radioactive and hazardous waste moving through the groundwater toward  the Columbia River. The river is a source of hydropower production,  irrigation for agriculture, and drinking water for downstream  communities, as well as a major route for migrating salmon. Besides the  waste intentionally discharged directly into the ground during the time of  reactor operations, DOE has assumed, based on monitoring data and other  techniques used to detect contamination, that 67 of the underground  tanks, some burial grounds, and other waste disposal areas have also  leaked contamination into the soil. Contamination could also result from  accidental spills during ongoing cleanup activities. Much of this hazardous  and radioactive waste can be borne by water through the soil into the  groundwater. While Hanford is a near-desert location with limited rainfall  and, in many areas, thick layers of soil and rock above the groundwater,  water from precipitation and other sources moves through these layers  into the groundwater. The groundwater moves in the general direction of  the river. In the center of the site the groundwater is more than 200 feet  below the surface, but at the river the groundwater is at or near the river  level. As figure 1 illustrates, the movement of this contaminated liquid  through the “vadose zone”—the span of soil and rock between the surface  and the groundwater beneath—can result in contamination “plumes”  extending downward and outward from their sources. When these  contamination plumes reach the groundwater, the contamination they  contain enters the groundwater and begins flowing toward the river.
The extent to which contamination from the Hanford site has threatened,  or will threaten, the Columbia River, is not fully understood. While some  contamination has already reached the river, DOE has found that it is  barely detectable because the high volume of water dilutes it. DOE  routinely monitors the river’s water quality, which currently meets federal  drinking water standards at sampling locations immediately down river  from the Hanford site. However, studies also show that contamination has  been found in some river life, including clams found near the shore. In  addition, the rate at which contamination in the vadose zone and  groundwater may migrate to the river in future years is uncertain, and  depends on the effectiveness of site cleanup activities. However, migrating  contamination may continue to enter the river in the foreseeable future.
Since the early 1990s, DOE has shifted its efforts at the Hanford site from  production of nuclear materials to cleaning up the contamination and  other materials left over from the production era. DOE carries out its  cleanup activities primarily under the requirements of two environmental  laws: (1) the Comprehensive Environmental Response, Compensation, and  Liability Act of 1980, as amended (CERCLA); and (2) the Resource  Conservation and Recovery Act of 1976, as amended (RCRA). Milestones  for completing each step of the cleanup process are specified in a legally  binding agreement (commonly known as the Tri-Party Agreement)  between DOE and its regulators—the U.S. Environmental Protection  Agency (EPA) and the Washington State Department of Ecology. Under  the Tri-Party Agreement, DOE must complete remediation of most of the  site’s soil and groundwater by September 2024. DOE’s goal is to complete  all cleanup work at the Hanford site by 2035.
The Tri-Party Agreement incorporates the requirements of federal  environmental laws and guides the process under which DOE will analyze  the contamination and consider remedies, which DOE’s regulators must  approve. First, DOE must conduct a remedial investigation, in which it  carries out field sampling and laboratory analyses to determine the nature  and extent of contamination. DOE is then required to conduct a feasibility  study to develop and screen an initial list of remedial alternatives. After  obtaining additional data, as necessary, DOE must analyze various  remedial alternatives and select a preferred remedy. The determination of  the preferred remedy is to be based on, among other things, whether a  remedial alternative protects human health and the environment, as well  as whether it attains cleanup standards that are legally applicable or  otherwise relevant and appropriate, including state laws. For example,  DOE and its regulators have determined that the Safe Drinking Water Act  provides standards for many of the contaminants in the soil and  groundwater at Hanford. In addition, DOE must consider seven other  criteria in selecting a remedial approach, including the cost effectiveness  of the remedy, its long-term protectiveness of human health and the  environment, and community acceptance. Currently, DOE is required by  the Tri-Party Agreement to meet a deadline of December 2008 to select  preferred remedial alternatives for 57 separate waste management areas of  the site—known as operable units.
After DOE selects a preferred remedial alternative, the lead regulatory  agency—either EPA or the state of Washington—prepares a Record of  Decision that selects the final remedy. A Record of Decision generally  describes, among other things, (1) the key contaminants present in the  specific waste management area, (2) the contamination limits DOE must  achieve for each key contaminant, (3) the time frame in which the cleanup  goals will be achieved, and (4) the technologies to be used to address the  contamination. In general, if contaminants remain at the site as part of the  final remedy, DOE and its regulators are required to review the remedial  action every 5 years to determine whether the selected treatment  technology is effective in protecting human health and the environment.
DOE’s cleanup program at the Hanford site is aimed, in part, at protecting  the Columbia River from contamination, now and in the future. Many of  the river protection activities treat contamination before it enters the  vadose zone or groundwater, and we have reported on several of these  activities. Regarding DOE’s efforts to address contamination in the vadose  zone and groundwater, DOE has prioritized the work to first address  threats from contaminated sites located near the river or requiring  immediate action, and then address threats from contaminated sites that  are farther away from the river’s edge.
DOE’s effort to address contamination near the river include actively  removing waste, old buildings, and contaminated soil to reduce  contaminants that could migrate—known as the river corridor project— and treating the groundwater to prevent contaminants from further  migrating. DOE has three main approaches to treating the groundwater:    Pump-and-treat. With this approach, DOE uses wells to extract  contaminated groundwater, treats the groundwater in above-ground  facilities, and reinjects the treated water into the ground. Since 1995, DOE  has operated five pump-and-treat systems to remove strontium-90,  chromium, carbon tetrachloride, and uranium from the groundwater. Four  of these are intended to address near-river contamination of strontium-90  and chromium.
Chemical treatment. This approach has been used in one instance. DOE  uses a chemical barrier near the Columbia River to block chromium from  entering the river near major salmon breeding areas. The barrier consists  of a 750-yard series of wells through which DOE injected a chemical into  the groundwater; the chemical reacts with the chromium to change it to a  less hazardous and less mobile form.
Natural attenuation. This approach relies on subsurface processes such  as dilution, adsorption, and chemical reactions with subsurface materials  to reduce contaminant concentrations to acceptable levels. For example, a  large uranium plume in the groundwater is entering the river about 4 miles  above city drinking water intakes. In 1996, DOE and its regulators agreed  to allow the plume to dissipate through natural attenuation.
DOE’s efforts to address contamination threats that are farther from the  river have involved four main types of actions:    Characterizing the vadose zone and groundwater through sampling and  other studies to help understand the risks from movement of  contamination.
Removing high-risk material from contaminated sites and/or covering the  surface of the disposal area with a barrier to prevent water intrusion.
Decommissioning (by removing or sealing) a portion of the 7,000 wells  used to monitor groundwater and the vadose zone, and for other purposes,  that are no longer needed. Monitoring wells are important, but they can  also contribute to pollution by serving as conduits for rain, snow melt, or  other liquids to flush contaminants through the vadose zone and into the  groundwater.
Reducing water intrusion from leaking pipelines and surface drainage that  can drive contamination from the vadose zone to the groundwater.
DOE also monitors groundwater conditions and uses information about  the nature and extent of contamination in the groundwater—and its  migration toward the river—to assess current and future risks to the  public and the environment. While current levels of contamination can be  determined by sampling the river, soil, and groundwater, DOE uses  computer models to predict how existing and future contamination from  site cleanup and disposal activities will impact the river over the next  1,000 to 10,000 years.
In November 2005, we reported on the potential for Columbia River  contamination from the Hanford site. We discussed DOE’s understanding  of the sources and extent of contamination that potentially threaten the  river, and the mixed results that DOE’s efforts to address the  contamination have achieved so far. In addition, we discussed past  criticisms of DOE’s program management, including a poorly organized  management structure and lack of coordination among various river  protection activities. Because of continuing concerns about the risks  posed by the contamination and DOE’s management of its river protection  program, you asked us to review the status of DOE’s efforts. This report  addresses DOE efforts (1) to understand the risk to the Columbia River  from Hanford site contamination and to deploy effective technologies to  address contamination near the river, and (2) to strengthen the  management of its efforts to protect the Columbia River from Hanford site  contamination.
To address these objectives, we reviewed key documents, including  Hanford’s 2003 Groundwater Management Plan, the 2004 Hanford Site  Groundwater Strategy, and reports from the National Academy of Sciences  and the DOE Inspector General. We visited various groundwater  protection projects at the Hanford site and discussed river contamination  issues with DOE and contractor officials at Hanford. We also discussed  these issues with state and federal regulators, and other stakeholders. In  reviewing the data related to the groundwater and river programs, we  determined they were sufficiently reliable for the purposes of our report. A  more detailed description of our scope and methodology is presented in  appendix I. We conducted our work from December 2005 to August 2006  in accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: Contamination from the Hanford site that may threaten the Columbia  River includes (1) contamination that resulted from disposal activities  during the era in which DOE produced nuclear material; (2) contamination  that could occur during cleanup activities, such as from an accidental spill;  and (3) possible future migration of contamination from waste that will be  permanently disposed of on the Hanford site in accordance with the  cleanup actions DOE and the regulators plan to use.
Contamination from production era. Contamination at Hanford resulting  from plutonium production (which occurred from 1943 to 1989) that is  currently migrating to the river is primarily from:   Intentional disposal of liquid waste and contaminated water into the  ground (about 450 billion gallons).
Leaks into the soil from waste tanks and the pipelines that connect them  (between 500,000 to 1 million gallons containing about 1,000,000 curies of  radioactivity).
Contamination that has begun to migrate from solid waste (more than  710,000 cubic meters) disposed of on-site in burial grounds, pits, and other  facilities.
Chemical and radioactive contamination currently affects more than 180  of the 586 square miles of the site’s groundwater and large areas of the  vadose zone. While there are numerous contaminants now in the vadose  zone and the groundwater below, DOE believes the key contaminants in  the groundwater include hazardous chemicals (such as carbon  tetrachloride, chromium, nitrate, and trichloroethane) and radioactive  materials (such as iodine-129, strontium-90, technetium-99, tritium, and  uranium). These contaminants are of concern because of their extent,  their mobility in the groundwater, and the potential health risks associated  with them—at sufficient levels, some of these contaminants are toxic to  humans or fish, while others are potential carcinogens.
Potential contamination from current activities. Current cleanup efforts  at the Hanford site could contribute to contamination of the vadose zone  and groundwater that eventually reaches the river. For example, some of  the waste put into underground storage tanks as liquid has since turned  into sludge or saltcake. To dissolve it, more water will have to be  introduced into the tanks—including tanks known to have leaked. This  process may cause additional discharges into the soil.
Possible future contamination. Under DOE’s cleanup plans, and with  regulator approval, a large amount of contaminants will remain on-site  long into the future. This contamination may be in buildings, in mostly  empty underground tanks, in covered burial grounds and waste disposal  areas, and in approved disposal facilities. Contaminants may leach out of  these facilities in the future and join existing contamination in the vadose  zone and migrate to the groundwater, where they could migrate to the  river.
Based on groundwater sampling results, DOE reports that plumes of  contamination continue to move through the vadose zone and the  groundwater, and are leaching into the river. DOE estimates that about 80  square miles of groundwater under the site contains contaminants at, or  above, federal drinking water standards. Because the groundwater and  the river are at the same relative elevation, these plumes are leaching  directly into about 10 of the nearly 50 miles of river shore on the site.
DOE’s Office of Groundwater and Soil Remediation under the Assistant  Secretary for Environmental Management sets overall policy and oversight  for groundwater and soil remediation. At the Hanford site, both the  Richland Operations Office and the Office of River Protection, as well as  several contractors, are involved in groundwater and vadose zone  activities. The monitoring of river and shoreline conditions, and  groundwater sampling, is managed by the Pacific Northwest National  Laboratory (PNNL). Analysis of the samples is performed by several  approved laboratories. Funding for groundwater and vadose zone  activities at the site is difficult to identify due to the large number of  organizations and activities involved and the structure of DOE’s budget  accounts. However, monitoring, characterization, well drilling and  maintenance, remediation, and research activities received nearly $175  million in fiscal year 2006.
section_title: DOE is Taking Steps to Better Understand Risks to the Columbia River from Hanford and Is Replacing Ineffective Technologies near the River
paragraphs: DOE is taking steps to better understand the risk to the Columbia River  from Hanford site contamination and to replace ineffective cleanup  technologies. Specifically, DOE is addressing problems with three main  aspects of its Columbia River protection efforts. First, DOE and its  regulators have agreed that additional investigation of contamination in  the vadose zone is needed, although doing so could delay by about 3 years  the date by which DOE will propose its cleanup plans to the regulators.  Second, DOE is reworking its approach to modeling the future effects of  contamination on river conditions. DOE abandoned past modeling efforts  in response to criticism that the models used inconsistent assumptions,  were based on data of questionable reliability, and had weak quality  control processes. Third, in response to concerns about the effectiveness  of some of the technologies DOE had deployed to remove or contain  contamination near the river, and with specific direction from Congress,  DOE is evaluating alternative technologies that may be more effective at  addressing the contamination.
subsections: section_title: DOE Has Asked to Extend Regulatory Milestones to Better Understand the Extent and Location of the Contamination in Soil above the Groundwater
paragraphs: While DOE has extensive knowledge of the contaminants in the river and  groundwater, and the movement of contaminants in the groundwater and  on or near the surface, DOE has only recently developed limited  information about the extent and location of the contamination that has  migrated from the surface areas into the vadose zone above the  groundwater. Understanding the nature of vadose zone contamination is  critical to determining the most appropriate steps to take to protect the  river now, and in future years, because contaminants still in the soil may  continue to migrate until they eventually reach the groundwater and the  river. DOE has studied some portions of the vadose zone, such as around  the underground storage tanks, where extensive contamination from leaks  and spills occurred in the past. In doing so, DOE found that some  contamination, including technetium-99, had migrated as far as the  groundwater. DOE contractors were able to map the migration of some of  these contaminants. However, DOE acknowledges that its understanding  of contaminants in the vadose zone is limited in many areas of the site. For  example, cribs and trenches near the underground tanks received large  volumes of contaminated wastes that dispersed directly to the ground.  DOE has little information on the extent and location of the contamination  in those areas, according to DOE officials responsible for planning their  cleanup. They also said that characterization of the lower portions of the  vadose zone is difficult and expensive, and few remediation techniques  have been developed or tested for removing or isolating wastes that are  located deep in the vadose zone.
Understanding the extent of vadose zone contamination is critical because  some contaminants still in the soil may continue to migrate until they  eventually reach the groundwater and the river. Thus, understanding the  type and volume of contaminants in the vadose zone and their rate of  migration is essential to determining the most appropriate steps to take to  protect the river now, and in future years.
After finding unexpected contaminant migration in the vadose zone at one  waste disposal area known as BC cribs—a location where liquids were  discharged directly into the ground—DOE agreed with its regulators that  its understanding of the vadose zone was inadequate to support the  development of a final cleanup remedy for that area and some others.  Although DOE had originally planned to defer some of its study of the  vadose zone until after December 2008, when draft cleanup plans were  due, DOE now agrees that more sampling and analysis of the vadose zone  is needed to guide cleanup decisions. As a result, DOE has proposed to  regulators to extend the date for submitting draft cleanup plans until 2011.  DOE officials said this will allow the time needed to develop a better  understanding of vadose zone conditions and to investigate potential  remedies.
section_title: DOE Is Reworking Efforts to Estimate Risks from the Movement of Contamination toward the River
paragraphs: In response to the discovery that its previous models to estimate the future  risks of the movement of contamination toward the river were based on  data of questionable reliability, DOE has begun reworking these efforts.  While DOE relies on sampling to determine current conditions, it uses  computer simulation models to predict future conditions and estimate  future risks. In 1998, DOE groundwater program officials said DOE  concluded from its simulation models that the migration was slow enough  that the contaminants included in the study would not exceed their limits  for 1,000 years into the future. However, DOE was concerned about the  completeness of the model and began an effort, known as the System  Assessment Capability, to develop a more comprehensive model. This $16  million, 8-year effort was cancelled when, in the course of a lawsuit over  Hanford’s disposal plans, several quality assurance problems were found,  including discrepancies in the data. DOE abandoned the past modeling  efforts in response to criticisms that the models used inconsistent  assumptions, were based on data of questionable reliability, and had weak  quality control processes. In January 2006, DOE and Washington State  settled the lawsuit. In the settlement agreement, DOE agreed to re-analyze  and update its study of the cleanup’s effect on groundwater. In addition,  DOE agreed to consolidate two studies of the cleanup’s effects on  groundwater into a single, integrated study.
section_title: DOE Is Considering New Treatment Technologies to Replace Those That Have Not Kept Contamination from Entering the River
paragraphs: Both DOE and its regulators have determined that the results of all three  of DOE’s approaches to treating groundwater—pump-and-treat, chemical  treatment, and natural attenuation—are not fully satisfactory. Specifically:    Pump-and-treat. In a 2004 report, the DOE Inspector General concluded  that the pump-and-treat system to remove strontium-90 was ineffective  and that the other four pump-and-treat systems have had mixed results.
However, Hanford’s acting groundwater project manager told us that four  of the five pump-and-treat systems at the Hanford site meet the remedial  objectives agreed to with Hanford’s regulators. The official acknowledged  that the system to remove strontium-90 was largely ineffective and that  DOE had been trying to obtain permission from the regulators to turn it  off. Both DOE and the regulators told us that the regulators refused to  allow the system to be turned off, however, until a more effective remedy  was found. In March 2006, after spending about $16 million since 1996 to  install and operate the system, DOE turned the system off with the  regulators’ permission, and began testing a chemical barrier to prevent the  strontium-90 from entering the river.
Chemical treatment. In 2004, DOE reported that, based on groundwater  samples, the chemical barrier for chromium was not fully effective, and  that the hazardous form of chromium was detected beyond the barrier and  close to the river. DOE is currently testing alternative approaches to  improve the barrier.
Natural attenuation. According to monitoring well data, DOE’s reliance  on natural attenuation to dissipate a uranium plume near the city of  Richland was ineffective and has not controlled the migration of uranium  to the river. The plume has not dissipated in the 10-year period since the  natural attenuation strategy was adopted. DOE is currently investigating  the plume, testing chemical barriers, and exploring other ways to mitigate  the problem.
In the conference report accompanying the fiscal year 2006 Energy and  Water Development Appropriations Act, the conferees directed DOE to  make $10 million available to analyze and identify new technologies to  address contaminant migration to the Columbia River. DOE convened a  study group to identify potential technologies and determine how best to  allocate the funds to support them. According to DOE’s groundwater  project manager, if the technologies tested are successful, DOE will seek  funds to expand the systems to fully address these problems. DOE is  testing the following:    To address problems with pump-and-treat systems, DOE is testing new  approaches to containing strontium-90 and chromium. To contain the  strontium, DOE is testing two techniques: (1) using a chemical to bind the  strontium to the soil until it decays, which would prevent it from leaching  into the river; and (2) planting willow bushes near shore to capture the  strontium in the plants, which can be harvested to dispose of the  strontium. For chromium removal, DOE has adopted a “systems approach”  which includes combining source removal, pump-and-treat system  expansion, and barrier repairs according to DOE’s groundwater project  manager. DOE is also planning to test an improvement to the pump-and- treat system. The test system will use an electric field to remove the  chromium from the groundwater extracted by several of the existing wells.  If it succeeds, DOE’s project manager said, they will expand the pump- and-treat system to include this technology.
To address problems with the chromium barrier near the river, DOE plans  to inject chemicals through the wells used to create the barrier to help  convert the chromium to a less toxic and less mobile form.
To address problems with using natural attenuation to dissipate the  uranium plume near the city of Richland, DOE is testing whether injecting  a chemical called polyphosphate can help prevent the uranium from  migrating to the river.
In addition to these activities, DOE plans to research methods to better  understand the existing carbon tetrachloride plume in the center of the  site.
section_title: DOE Has Begun To Address Management Weaknesses but Can Further Strengthen Its Management Plan
paragraphs: DOE has begun to address management problems with its Columbia River  protection efforts at the Hanford site by proposing management  improvements to better oversee and coordinate its groundwater and  vadose zone activities. Although those steps are important and needed, we  are concerned about DOE’s ability to sustain any improvements made.  Similar efforts in the past failed. In our previous work, we reported that  leading organizations use a systematic, results-oriented plan to sustain  management improvement initiatives. Such a plan incorporates key  elements, such as clear goals, performance measures to gauge progress  toward those goals, and an evaluation strategy to help ensure the initiative  is effective. Although DOE is beginning to develop a plan for its new  integration initiative, it has yet to implement key elements, such as  performance measures or an evaluation strategy. These tools could help  measure effectiveness and sustain the benefits of the initiative over time.
subsections: section_title: DOE Is Taking Steps to Improve River Protection Management and Oversight
paragraphs: DOE is beginning to address longstanding concerns about the  management and oversight of its Columbia River protection efforts at the  Hanford site. In November 2005, we reported that DOE’s river protection  efforts continued to be fragmented among two DOE site operations offices  and several site contractors. We raised concerns that the potential  existed for duplication, gaps, and inefficiencies. Subsequently, in the  November 2005 conference report accompanying the Fiscal Year 2006  Energy and Water Development Appropriations Act, the conference  committee cited these continuing management and organization problems  and directed DOE to study how to better integrate its river protection  efforts. In response to the congressional direction, in March 2006, DOE’s  Assistant Secretary for Environmental Management developed a new plan  to better integrate Hanford’s river protection, vadose zone, and  groundwater efforts. Specifically, DOE’s new integration initiative would:    Consolidate most groundwater and vadose zone characterization  and cleanup activities under a single project. At the time of the  congressional direction, two DOE offices and three main contractors on- site were collectively responsible for characterizing and cleaning up  vadose zone and groundwater contamination. The Office of River  Protection and its contractor, CH2M Hill Hanford Group, were responsible  for characterizing and addressing contamination of the vadose zone in  tank farms—areas where tanks containing radioactive liquid waste are  buried. The Richland Operations Office and its contractors, Fluor Hanford  and Washington Closure Hanford, were responsible for vadose zone  characterization in the central plateau area of the site and along the river  corridor, respectively. In addition, Fluor Hanford was responsible for  groundwater activities in all areas of the site. Within Fluor Hanford,  responsibility for cleanup of the groundwater and vadose zone was  divided between two different projects with the project handling vadose  zone issues also responsible for addressing removal of old buildings and  burial grounds.
To better coordinate vadose zone and groundwater characterization and  cleanup activities, DOE’s new integration initiative proposed consolidating  most of this work under a single project managed and coordinated by  Fluor Hanford. To do so, DOE planned to modify existing contracts with  the affected contractors to reflect this reorganization. In June 2006, the  Office of River Protection and the Richland Operations Office issued a  Plan of Action for Hanford Groundwater and Vadose Zone Integration  Improvements. It identified general activities and areas of responsibility  that the Fluor Hanford and CH2M Hill Hanford Group contractors would  be responsible for under the new initiative. As of the end of July 2006,  DOE was negotiating the details of this reorganization of responsibilities  with the contractors and anticipated having the contracts modified to  reflect the changes by October 1, 2006.
Better integrate vadose zone, groundwater, and waste disposal site  cleanup decisions. DOE acknowledged that decisions about when and  how to address vadose zone and groundwater contamination were not  always well coordinated, and they generally were not coordinated with  decisions about when and how to address the source contamination in a  waste disposal site located above the vadose zone and groundwater. For  example, initial plans for cleanup decisions of the surface areas in the  Central Plateau were not necessarily linked to the plans for the underlying  groundwater units, according to DOE’s groundwater project manager.
To better integrate vadose zone, groundwater, and waste disposal site  cleanup decisions, DOE proposed to implement a new strategy by the end  of fiscal year 2006 and to work with regulators to better align regulatory  milestone dates for making cleanup decisions about waste sites, the  vadose zone, and the groundwater. DOE’s new strategy includes plans to  transfer most vadose zone characterization activities into the groundwater  program.
Consolidate responsibility for modeling the movement of  contaminants through the vadose zone and groundwater to  estimate the potential current and future health risks. DOE has  acknowledged that inconsistencies and reliability problems existed in the  modeling of how contaminants move through the vadose zone and  groundwater, and how the environmental risks associated with those  contaminants were estimated. A DOE team reviewing the data quality  issues and the modeling effort found that, in addition to issues of the  reliability of data used in the models, various modeling efforts under way  were based on different assumptions, and information about  contamination movement was not always correctly transferred to other  models.
To address these problems, DOE proposed to more closely coordinate  modeling and risk assessment activities at the site and strengthen control  over model design so that a common set of databases and assumptions  were being used for decision making. The groundwater project would have  configuration control over any models used so that any changes to  databases and models assumptions would require approval by the  groundwater project before users could implement them.
In addition to these management improvement efforts at the Hanford site,  in May 2006, DOE also established a new Office of Groundwater and Soil  Remediation to improve headquarters’ oversight on issues dealing with  soil and groundwater contamination across the DOE complex. The office  is tasked with reviewing all soil and groundwater remedies at DOE sites,  helping to develop technologies to solve groundwater and soil  contamination problems at different DOE sites, and generally overseeing  DOE policy and assessments regarding vadose zone and groundwater  cleanup.
section_title: DOE Has Not Fully Implemented a Management Plan to Ensure Improvements Will Be Sustained
paragraphs: Given past problems fully implementing and sustaining improvements to  the management of DOE’s Columbia River protection efforts at the  Hanford site, it is uncertain whether any improvements that result from  DOE’s new integration initiative will be sustained. In 1998, we reported  that DOE lacked a comprehensive and integrated groundwater and vadose  zone program, and recommended that DOE implement an integrated  strategy that defined measurable performance goals, clearly defined  leadership roles, and established accountability for meeting those goals.
In response to our 1998 report, DOE proposed an integrated management  plan to coordinate groundwater and vadose zone work. To accomplish  this, DOE assigned a single DOE Assistant Manager in the Richland  Operations Office to coordinate all groundwater and vadose zone work at  the Hanford site. Because DOE’s other site office, the Office of River  Protection, and several contractors at the site also carried out  groundwater and vadose zone cleanup, DOE made the Assistant Manager  responsible for ensuring that all groundwater and vadose zone activities  were integrated into a single planning effort. This “Integration Project”  included developing a sitewide approach to project planning, funding, and  information management, and co-locating contractor staff working on the  project to improve coordination. In addition, the project included  improving coordination of efforts to develop science and technology to  address contamination in the vadose zone and groundwater.
Despite these proposed changes, DOE was unable to effectively implement  the improvements it planned to make. For example, according to a site  official at Hanford who oversaw the initial integration effort, DOE did not  implement key elements of the plan, such as establishing a sitewide  funding profile for all groundwater and vadose zone activities. DOE  implemented other elements of the plan but did not sustain them when  changes, such as how projects were organized and contracts were  structured, occurred at the site. For example, coordinating all activities  through a single federal project manager faltered as site offices were  reorganized and responsibilities were distributed among three federal  project directors. The DOE official from the Hanford groundwater  program attributes the lack of coordination of groundwater and vadose  zone efforts to redefining project activities, which resulted in groundwater  and vadose zone activities being managed as separate projects and  changes in the structure of site contracts, which resulted in scopes of  work being organized and assigned differently. A 2001 National Academy  of Sciences review of DOE’s groundwater science and technology  activities noted that DOE’s integration efforts had been superimposed over  several already existing cleanup projects without establishing a clear line  of responsibility for results. The National Academy said that this left the  program operating in an unstable environment.
To increase the chances of success for DOE’s current improvement  initiative, we assessed DOE’s management of its new integration initiative  against model practices used by organizations that successfully sustained  improvement initiatives. We previously reported that in high-performing  organizations, management improvement initiatives are sustained by using  a systematic, results-oriented plan that incorporates a rigorous  measurement of progress. Such a plan typically included the following  steps: (1) defining clear program goals for the initiative—important  because it focuses an organization’s efforts on achieving specific  outcomes and allows as assessment of future performance against those  goals; (2) developing an implementation strategy that sets milestones and  establishes individual responsibilities—important because it establishes  accountability for achieving the initiative’s goals; (3) establishing results- oriented performance measures—important because it allows  organizations to measure progress toward achieving their goals; and (4)  using results-oriented data to evaluate the effectiveness of the initiative  and make additional changes where warranted—important because  periodic evaluations can reveal systemic problems and promote  continuous program improvement over the long term.
As of July 2006, DOE had implemented two components and not  implemented other management components to help ensure that it could  sustain any improvements resulting from its new integration initiative. For  example, in putting forward its plan to Congress, DOE described a general  goal of its new integration initiative as better coordination of Hanford’s  groundwater and vadose zone cleanup activities in order to achieve  greater protection of the Columbia River. DOE also outlined steps it would  take toward its goal, such as (1) consolidating site modeling and risk  assessments; (2) consolidating river protection efforts under a single  project; and (3) integrating soil and groundwater cleanup decisions. In  going forward, DOE could further refine its goals to include measurable  steps to achieving its overall goal of protecting the river. For example, a  more measurable goal would be the reduction of contamination reaching  the river or ensuring duplication of efforts is reduced in order to better  protect the Columbia River.
DOE had established general milestones and individual responsibilities for  implementing its new integration initiative. For example, DOE’s plan of  action sets 16 milestones by September 2006 by which various initial steps  are to be taken. DOE also reported that five of these actions, including  making staff assignments and establishing an integrated project team, had  been completed.
DOE has not established results-oriented measures to gauge the progress  of its integrated management initiative. In outlining the steps it will take  under its plan, DOE has generally concentrated on establishing  relationships and moving work-scope between various DOE offices and  contractors, and not on outcomes, such as reducing redundancies or gaps  in river protection efforts. Without clear results-oriented performance  measures to gauge progress, problems that occur under a fragmented  management structure could be masked and allowed to continue under  DOE’s integration plan. Translating the general goal of “better integration”  and “protection of the river” into a more specific goal, such as reducing  duplicative efforts, would help DOE identify ways it could measure results  and, therefore, gauge progress toward the goals of its integration initiative.
Finally, DOE has not yet identified an evaluation strategy to determine  whether the steps it is taking are effective and are being sustained.  Without an evaluation strategy based on clear goals and results-oriented  measures, DOE will not have the results-oriented data necessary to  objectively evaluate progress and implement corrective actions as needed.
Although DOE is still working to define and implement its integration  initiative, fully developing and putting in place key elements outlined  above could help ensure that any program improvements are sustained in  the future. DOE’s Hanford Assistant Manager in charge of overseeing the  latest management improvements for the river protection program said  that, beyond outlining broad goals and setting the framework for roles and  responsibilities, DOE had not yet fully developed a project execution plan  for the new initiative. He said that the management plan is still evolving  and that future steps may include more clearly defining performance  measures and strategies for evaluating the initiative’s effectiveness.
section_title: Conclusions
paragraphs: DOE is involved in a lengthy process to identify and address potential  threats to the Columbia River from contamination in the soil and  groundwater at the Hanford site. This requires a good understanding of the  risks to the river and an effective management strategy for addressing  those risks. Over the years, we and others have raised concerns about  DOE’s efforts to understand the nature and extent of the contamination  and how best to manage the efforts to prevent contamination from seeping  into the river. In recent months, DOE has taken several steps to gain a  better understanding of the risks from the contamination as well as to  improve its management of the program and integration of activities.  While these steps are encouraging, DOE has not yet decided whether to  put in place elements of a management plan that could help ensure  potential benefits of these improvements will be continued, even when  organizational and contract changes occur at the site. Such a management  plan should include developing results-oriented performance measures,  using the measures to determine progress toward objectives, and making  changes as necessary.
section_title: Recommendation for Executive Action
paragraphs: To increase the likelihood that DOE will effectively implement and sustain  improvements in its program to protect the Columbia River from  contamination at the Hanford site, we recommend that the Secretary of  Energy strengthen the management improvement plan by establishing  results-oriented performance measures and regular evaluations to gauge  the program’s effectiveness.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOE for its review and comment. In a  letter from DOE’s Principal Deputy Assistant Secretary for Environmental  Management, DOE agreed with the report’s findings and fully endorsed the  recommendation to adopt results-oriented performance measures and  regular evaluations of the river protection program. DOE acknowledged  that performance measures and regular evaluations are a fundamental and  integral component of sound project management practice and said that it  would incorporate them into the project. The full text of DOE’s comments  is presented in appendix II.
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If you or your staff have any questions on this report, please contact me at  (202) 512-3841 or by e-mail at aloisee@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. Other staff contributing to this report are listed in  appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To understand the risk to the Columbia River from Hanford site  contamination, we reviewed risk assessments, groundwater, vadose zone,  and river monitoring reports by the Department of Energy (DOE), DOE’s  Office of Inspector General, DOE contractors including the Pacific  Northwest National Laboratory, and various outside groups such as the  National Academy of Sciences. We interviewed DOE officials at both  headquarters and the Hanford site, as well as contractor staff at Hanford,  to obtain information on the distribution of contamination at Hanford and  the steps being taken to better understand it. To understand DOE’s  approach to the vadose zone, we primarily reviewed our 1998 report, as  well as documents prepared by DOE and its staff in response to that  report. We also reviewed documents DOE submitted to regulators related  to changing Tri-Party Agreement milestones; the documents were to be  used for preparing initial drafts of plans for all remaining contaminated  areas. We discussed the proposed change to the December 2008 Tri-Party  Agreement milestone with DOE officials and regulators. In reviewing  DOE’s efforts to determine the extent of risk of future damage to the river  from contamination, we reviewed documents related to DOE’s sitewide  modeling effort and legal documents related to this modeling effort. We  discussed these modeling efforts with DOE officials, contractors, and  regulators.
In assessing DOE’s efforts to deploy effective technologies to address  contamination near the river, we visited the sites of existing and planned  cleanup efforts. We discussed current existing projects with DOE officials,  contractor staff, regulators, and stakeholders, and reviewed reports  prepared for DOE and others. To assess technology plans developed by  DOE to use $10 million of funds earmarked for fiscal year 2006, we  attended DOE screening panels, reviewed reports prepared by DOE and  others, and discussed the efforts with DOE regulators.
To review DOE efforts to strengthen the management of its river  protection efforts, we reviewed DOE’s past and current management  plans. We obtained DOE’s recent integration initiative proposals, including  its proposal to Congress in March 2006 and its subsequent Memorandum  of Agreement and Plan of Action. We discussed DOE’s approach with  headquarters and site officials. We reviewed previous work in which we  documented strategies used by high-performing organizations to  implement improvement initiatives. We reviewed DOE’s proposed  integration initiative and compared it to key elements of these strategies.  We also discussed DOE’s plans to implement its strategy with  knowledgeable site officials.
In reviewing the management of DOE programs related to groundwater  and river protection, we reviewed DOE efforts to assure that  contamination levels were accurately reported; we also interviewed  regulators, DOE officials, and contractors regarding data reliability. While  we did not independently test the contaminant data, we reviewed controls  over how the data were obtained and tested, visited sampling locations  and discussed sampling methods with key staff, and reviewed other  relevant information to determine that the data were sufficiently reliable  for the purposes of our report. We conducted our work from December  2005 to August 2006 in accordance with generally accepted government  auditing standards.
section_title: Appendix II: Comments from the Department of Energy
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Bill Swick, Assistant Director;  Chris Abraham; Doreen Feldman; Nancy Kintner-Meyer; Jeffrey Larson;  Omari Norman; Alison O’Neill; Thomas Perry; and Stan Stenersen made  significant contributions to this report. Others who made important  contributions included Mark Braza, Doreen Eng, and Mehrzad Nadji.