Nuclear Waste: Challenges and Savings Opportunities in DOE's High-Level Waste Cleanup Program
Published: 2003-07-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Department of Energy (DOE) oversees the treatment and disposal of 94 million gallons of highly radioactive nuclear waste from the nation's nuclear weapons program, currently at DOE sites in Washington, Idaho, and South Carolina. In 2002, DOE began an initiative to reduce the estimated $105-billion cost and 70-year time frame of this cleanup. GAO was asked to testify on the status of this initiative, the legal and technical challenges DOE faces in implementation, and any further opportunities to reduce costs or improve program management. GAO's testimony is based on a report (GAO-03-593) released at the hearing.
section_title: What GAO Found
paragraphs: DOE's initiative for reducing the costs and time required for cleanup of high-level wastes is still evolving. DOE's main strategy for treating high-level waste continues to include separating and concentrating much of the radioactivity into a smaller volume for disposal in a geologic repository. Under the initiative, DOE sites are evaluating other approaches, such as disposing of more waste on site. DOE's current savings estimate for these approaches is $29 billion, but the estimate may not be reliable or complete. For example, the savings estimate does not adequately reflect uncertainties or take into account the timing of when savings will be realized. DOE faces significant legal and technical challenges to realize these savings. A key legal challenge involves DOE's process for deciding that some waste with relatively low concentrations of radioactivity can be treated and disposed of on-site. A recent court ruling invalidated this process, putting the accelerated schedule and potential savings in jeopardy. A key technical challenge is that DOE's approach relies on laboratory testing to confirm separation of the waste into high-level and low-activity portions. At the Hanford Site in Washington State, DOE plans to build a facility before conducting integrated testing of the waste separation technology--an approach that failed on a prior major project. DOE is exploring proposals, such as increasing the amount of high-level waste in each disposal canister, that if successful could save billions of dollars more than the current $29 billion estimate. However, considerable evaluation remains to be done. DOE also has opportunities to improve program management by fully addressing recurring weaknesses GAO has identified in DOE's management of cleanup projects, including the practice of incorporating technology into projects before it is sufficiently tested.

section_title: Letter
paragraphs: We are pleased to be here today to discuss the Department of Energy’s  (DOE) high-level waste cleanup program. DOE has about 94 million  gallons of highly radioactive nuclear waste from the nation’s nuclear  weapons program. This waste is currently in temporary storage at DOE  sites in Washington, South Carolina, and Idaho. After investing more than  20 years and about $18 billion, DOE acknowledged in February 2002 that  the program to clean up its high-level waste was far behind schedule, far  over budget, and in need of major change. In 2002, DOE began an initiative  to reduce the program’s nearly $105-billion estimated cost and 70-year  time frame to finish permanent disposal of this waste. Our testimony,  based on work included in the report being released by the Subcommittee  today, discusses (1) the components of DOE’s high-level waste and the  process involved in preparing the waste for disposal, (2) the status of  DOE’s accelerated cleanup initiative for high-level waste, (3) legal and  technical challenges DOE faces in implementing the initiative, and (4)  further opportunities to reduce costs beyond those identified in DOE’s  current cost-savings proposal or to improve program management.
In summary, we found the following:    DOE’s high-level waste has many components, ranging from  radioactive isotopes and corrosive chemicals to the water in which  much of this material was initially discharged. The radioactive  components vary greatly; a small portion will remain dangerously  radioactive for millions of years, while the vast majority will lose much  of their radioactivity more quickly, so that more than 90 percent of the  current radioactivity will be gone within 100 years. To prepare the  waste for permanent disposal, DOE plans to separate the waste into  two waste streams: one with high levels of radioactivity and the other  with lower concentrations of radioactivity. DOE expects that this  process will concentrate at least 90 percent of the radioactivity into a  volume that is significantly smaller than the current total volume of  waste. DOE plans to immobilize and bury the highly radioactive portion  in a permanent underground repository. The remaining waste will be  immobilized and disposed of at the location where it is currently stored  or at some other location.
DOE’s initiative to accelerate the cleanup is evolving, and while its  savings estimates are changing accordingly, we have ongoing concerns  about the reliability of those estimates. As of April 2003, DOE  estimated it could shorten the waste cleanup schedule by 20-35 years  and save up to $29 billion. To help achieve these schedule and cost  reductions, DOE has identified alternative treatment and disposal  strategies, such as developing ways to permanently dispose of more of  the radioactive waste at current sites rather than moving it to the  planned underground repository. However, our assessment of DOE’s  savings estimate indicates that it may not be reliable. For example, the  savings analysis does not take into account all costs associated with  alternative treatment strategies. Also, the estimate of savings does not  compare costs on the basis of “present value,” where dollars to be  saved in future years are discounted to a common year to reflect the  time value of money. At DOE’s Savannah River Site in South Carolina,  such an adjustment would lower the savings estimate for accelerated  waste processing by $2.6 billion—from $5.4 billion to $2.8 billion (in  2003 dollars).
DOE faces significant legal and technical challenges to realize the  estimated savings. A key legal challenge involves DOE’s authority to  apply a designation other than high-level waste to some waste with  relatively low concentrations of radioactivity, so that this portion can  be treated less expensively than highly radioactive waste. A recent  court ruling invalidated this redesignation process, thus precluding  DOE from proceeding with this element of its accelerated initiative. If  DOE cannot meet its accelerated schedules, then potential savings are  in jeopardy. A key technical challenge is that DOE’s approach relies  primarily on laboratory testing to confirm that separating waste into  high-level and low-activity portions will be successful. At the Hanford  Site in Washington State, DOE is planning to construct full-scale  facilities before fully testing the technologies on an integrated basis— an approach that has failed on another project in the past, resulting in  significant cost increases and schedule delays.
DOE is exploring additional cost savings beyond those identified in its  current cost-saving proposals. The proposals that offer significant  potential are being developed by the Hanford and Savannah River sites.  These proposals call for increasing the amount of waste that can be  concentrated into the canisters destined for the permanent  underground repository. DOE’s data indicates that these proposals, if  successful, could save several billion dollars. Considerable evaluation  of these proposals remains to be done and cost-saving estimates have  not yet been fully developed, according to DOE officials. DOE also has  opportunities to improve its management of the cleanup program by  addressing management weaknesses that we and others have identified  in the past. Although DOE has taken steps to improve program  management, we have continuing concerns about management  weaknesses in several areas. These include making key decisions  without rigorous supporting analysis, incorporating technology into  projects before it is sufficiently tested, and pursuing a “fast-track”  approach of launching into facility construction before completing  sufficient design work. It does not appear that DOE’s current  management efforts will fully address these weaknesses.
Our report makes several recommendations to DOE that, if implemented,  will help to manage or reduce legal and technical risks to the program,  avoid costly delays, and strengthen overall program management. DOE  agreed to consider our recommendation to seek clarification from the  Congress regarding its authority to determine that some waste can be  treated and disposed of as other than high-level waste. However, regarding  our recommendations that the department conduct integrated pilot testing  of its waste separation processes at Hanford, and take steps to improve  the management of high-level waste projects, such as by conducting more  rigorous analyses to support key project decisions, DOE believes that its  current approach is adequate. We do not agree with DOE’s views and  continue to believe that all of our recommendations are warranted.
subsections: section_title: Background
paragraphs: DOE has a vast complex of sites across the nation dedicated to the nuclear  weapons program. DOE largely ceased production of plutonium and  enriched uranium by 1992, but the waste remains at the sites. Most of the  tanks in which the waste is stored have already exceeded their design life.  For example, many of Hanford’s and Savannah River’s tanks were built in  the 1940s to 1960s and were designed to last 10-40 years. Leaks from some  of these tanks were first detected at Hanford in 1956 and at Savannah  River in 1959. Given the age and deteriorating condition of some of the  tanks, there is concern that some of them will leak additional waste into  the soil, where it may migrate to the water table and, in the case of the  Hanford Site, to the Columbia River.
Responsibility for the high-level waste produced at DOE facilities is  governed primarily by federal laws, including the Atomic Energy Act of  1954. These laws established responsibility for the regulatory control of  radioactive materials including DOE’s high-level waste and assigned the  Nuclear Regulatory Commission (NRC) the function of licensing facilities  that are expressly authorized for long-term storage of high-level  radioactive waste generated by DOE. In addition, the Nuclear Waste Policy  Act of 1982 defined high-level radioactive waste. Various other federal  laws, including the Resource Conservation and Recovery Act of 1976,  guide how DOE must carry out its cleanup program. The high-level waste  cleanup program is under the leadership of the Assistant Secretary for  Environmental Management. It involves consultation with a variety of  stakeholders, including the Environmental Protection Agency, state  environmental agencies where DOE sites are located, county and local  governmental agencies, citizen groups, advisory groups, and Native  American tribes.
section_title: DOE’s High-Level Waste Is a Complex Mixture That Requires a Multi-Step Process to Prepare for Disposal
paragraphs: The waste in the tanks at the Hanford and Savannah River sites and the  Idaho National Laboratory near Idaho Falls is a complex mixture of  radioactive and hazardous components. DOE’s process for preparing it for  disposal is designed to separate much of the radioactive material from  other waste components.
subsections: section_title: Much of the Radioactivity Declines Relatively Quickly
paragraphs: Nearly all the radioactivity in the waste originates from radionuclides with  half-lives of about 30 years or less. The relatively short half-lives of most  of the radionuclides in the waste means that within 30 years, about  50 percent of the current radioactivity will have decayed away, and within  100 years this figure will rise to more than 90 percent. Figure 1 shows the  pattern of decay, using 2002 to 2102 as the 100-year period. Extending the  analysis beyond the 100-year period shown in the figure, in 300 years,  99.8 percent of the radioactivity will have decayed, leaving 0.2 percent of  the current radioactivity remaining.
Despite the relatively rapid decay of most of the current radioactivity,  some radionuclides have half-lives in the hundreds of thousands of years  and will remain dangerously radioactive for millions of years. Some of  these long-lived radionuclides are potentially very mobile in the  environment and therefore must remain permanently isolated. If these  highly mobile radionuclides leak out or are released into the environment,  they can contaminate the soil and water.
section_title: Processing Can Concentrate the Radioactivity into a Much Smaller Volume of Waste
paragraphs: DOE plans to isolate the radioactive components and prepare the waste  for disposal through a multi-step treatment process. DOE expects this  process to concentrate at least 90 percent of the radioactivity into a much  smaller volume that can be permanently isolated for at least 10,000 years  in a geologic repository. The portion of the waste not sent to the geologic  repository will have relatively small amounts of radioactivity and  long-lived radionuclides. Based on current disposal standards used by the  NRC, if the radioactivity of this remaining waste is sufficiently low, it  can be disposed of on site near the surface of the ground, using less  complex and expensive techniques than those required for the highly  radioactive portion. DOE plans to dispose of this waste on site in vaults  or canisters, or at other designated disposal facilities.
DOE has successfully applied this process in a demonstration project at  the West Valley site in New York State. At West Valley, separation of the  low-activity portion from the high-level portion of the waste reduced by  90 percent the quantity of waste requiring permanent isolation and  disposal at a geologic repository. The high-level portion was stabilized in a  glass material (vitrified) and remains stored at the site pending completion  of the high-level waste geologic repository and resolution of other issues  associated with disposal costs. The remaining low-activity portion was  mixed with cement-forming materials, poured into drums where it  solidified into grout (a cement-like material), and remains stored on site,  awaiting shipment to an off-site disposal facility.
section_title: DOE’s Initiative for Accelerating Cleanup Is Still Evolving, with the Extent of Savings Uncertain
paragraphs: DOE’s new initiative, implemented in 2002, attempts to address the  schedule delays and increasing costs DOE has encountered in its efforts to  treat and dispose of high-level waste. This initiative is still evolving. As of  April 2003, DOE had identified several strategies to help reduce the time  needed to treat and dispose of the waste. Based on these strategies, DOE  estimated that it could reduce the waste cleanup schedule by about 20 to  35 years at its high-level waste sites and save about $29 billion compared  to the existing program baseline. While some degree of savings is likely if  the strategies are successfully implemented, the extent of the savings is  still uncertain.
subsections: section_title: Initiative Centers on Ways to Speed Disposal and Save Money
paragraphs: Many of DOE’s proposals to speed cleanup and reduce environmental risk  involve ways to do one or more of the following:    Deal with some tank waste as low-level or transuranic waste, rather  than as high-level waste. Doing so would eliminate the need to vitrify  the waste for off-site disposal in the geologic repository for high-level  waste.
Complete the waste treatment more quickly by using additional or  supplemental technologies. For example, DOE’s Hanford Site is  considering using up to four supplemental technologies, in addition to  vitrification, to process its low-activity waste. DOE believes these  technologies are needed to help it meet a schedule milestone date of  2028 agreed to with regulators to complete waste processing. Without  these technologies, DOE believes waste treatment would not be  completed before 2048.
Segregate the waste more fully than initially planned and tailor waste  treatment to each of the waste types. By doing so, DOE plans to apply  less costly treatment methods to waste with lower concentrations of  radioactivity.
Close waste storage tanks earlier than expected, thereby avoiding the  operating costs involved in maintaining the tanks and monitoring the  wastes.
Table 1 summarizes the estimated cost savings for each DOE site if  accelerated proposals for cleaning up high-level waste are successfully  implemented.
section_title: Savings Estimate May Not Be Reliable
paragraphs: Our review indicates that DOE’s current estimate of $29 billion may not  yet be reliable and that the actual amount to be saved if DOE successfully  implements the alternative waste treatment and disposal strategies may be  substantially different from what DOE is projecting. We have several  concerns about the reliability and completeness of the estimate. These  concerns include the accuracy of baseline cost estimates from which  savings are calculated, whether all appropriate costs are included in the  analysis, and whether the savings estimates properly reflect the timing of  the savings or uncertainties.
subsections: section_title: Baseline Costs Are Not Fully Reliable
paragraphs: DOE’s current lifecycle cost baseline is used as the base cost from  which potential savings associated with any improvements are measured.  However, in recent years, we and others have raised concerns about the  reliability of DOE’s baseline cost estimates. In a 1999 report, we noted that  DOE lacked a standard methodology for sites to use in developing their  lifecycle cost baseline, raising a concern about the reliability of data used  to develop these cost estimates. DOE’s Office of Inspector General also  raised a concern in a 1999 review of DOE project estimates, noting that  several project cost estimates examined were not supported or complete.  DOE acknowledged in its February 2002 review of the cleanup program  that baseline cost estimates do not provide a reliable picture of  project costs.
section_title: Estimates of Project Costs May Be Incomplete
paragraphs: Some of DOE’s savings may be based on incomplete estimates of the costs  for the accelerated proposals. According to Office of Management and  Budget (OMB) guidance on developing cost estimates, agencies should  ensure that all appropriate costs are addressed in the estimate. However,  DOE has not always done so. For example, the Idaho National  Laboratory’s estimated savings of up to $7 billion is based, in large part, on  eliminating the need to build a vitrification facility to treat its waste.  However, the waste may have to undergo an alternative treatment method  before it can be accepted at a geological repository, and the Idaho  National Laboratory is considering four different technologies for doing  so. Nevertheless, DOE’s current savings estimate reflects the potential  cost of only one of those technologies. DOE has not yet developed the  costs of using any of the other waste treatment approaches. DOE noted  that the accelerated lifecycle estimate could likely change depending on  which one of the technologies is selected and the associated costs of  treating the waste are developed.
section_title: Savings Estimates Do Not Reflect Timing, Uncertainty, or Nonbudgetary Impacts
paragraphs: According to OMB guidance, agencies should ensure that the timing of  when the savings will occur is accounted for, that uncertainties are  recognized and quantified where possible, and that nonbudgetary impacts,  such as a change in the level of risk to workers, are quantified, or at least  described. We found problems in all three areas.
Regarding the time value of money, applying OMB guidance would  mean that estimates of savings in DOE’s accelerated plans should  reflect a comparison of its baseline cost estimate with the alternative,  expressed in a “present value,” where the dollars are discounted to a  common year to reflect the time value of money. Instead, DOE’s  savings estimates generally measure savings by comparing dollars in  different years. For example, the Savannah River Site estimates a  savings of nearly $5.4 billion by reducing by 8 years (from 2027 to 2019)  the time required to process its high-level waste. Adjusting the savings  estimate to present value in 2003 results in a savings of $2.8 billion in  2003 dollars.
Regarding uncertainties, in contrast to OMB guidance, the DOE savings  estimates generally do not consider uncertainties. For example, the  savings projected in the Idaho National Laboratory’s accelerated plan  reflect the proposal to no longer build the vitrification facility and an  associated reduction in operations costs. However, the savings do not  account for uncertainties such as whether alternatives to vitrification  will succeed and at what cost. Rather than reflecting uncertainties by  providing a range of savings, DOE’s savings estimate is a single point  estimate of $7 billion.
Regarding nonbudgetary impacts, DOE’s savings estimates generally  do not fully assess the value of potential nonbudgetary impacts, such  as a change in the level of risk to workers or potential effects on the  environment. OMB guidelines recommend identification and, where  possible, quantification of other expected benefits and costs to society  when evaluating alternative plans. For example, the Idaho National  Laboratory’s accelerated plan does not assess potential increases in  environmental risk, if any, from disposing of the waste without  stabilizing it into a vitrified form. By not assessing these benefits and  risks to workers and the environment, DOE leaves unclear how  important these risks and trade-offs are to choosing an alternative  treatment approach.
section_title: Key Legal and Technical Challenges Could Limit Potential Savings from DOE’s Accelerated Cleanup Initiative
paragraphs: DOE faces significant legal and technical challenges in achieving the  cost and schedule reductions proposed in its new initiative. On the legal  side, DOE’s proposals depend heavily on the agency’s authority to apply  a designation other than “high-level waste” to the low-activity portion  of the waste stream, so that this low-activity portion does not have to  be disposed of more expensively as high-level waste. The portion of DOE’s  order setting out criteria for making such determinations has been  invalidated in a recent court ruling. On the technical side, DOE’s proposals  rest heavily on the successful application of waste separation methods  that are still under development and will not be fully tested before being  put in place. DOE’s track record in this regard has not been strong; it has  had to abandon past projects that were also based on promising—but not  fully tested—technologies. Either or both of these challenges could limit  the potential savings from DOE’s accelerated cleanup initiative.
subsections: section_title: DOE’s Accelerated Initiative Relies on a Process for Reclassifying Waste That the Court Has Ruled Invalid
paragraphs: DOE has traditionally managed all of the wastes in its tanks as high-level  waste because the waste resulted primarily from the reprocessing of spent  nuclear fuel and contains significant amounts of radioactivity. However,  by separating the waste into high-level and low-activity portions and  managing the low-activity portion as something other than high-level  waste, DOE could use less costly and less complicated treatment  approaches. DOE has developed guidelines for deciding when waste in the  tanks should not be considered high-level waste. In 1999, under Order  435.1, DOE formalized its process for determining which waste is  incidental to reprocessing (“incidental waste”), not high level waste,  and therefore will not be sent to a geological repository for high-level  waste disposal. This process provides a basis for DOE to treat and  dispose of some portion of its wastes less expensively as low-level or  transuranic wastes.
DOE’s ability to define some waste as incidental to reprocessing, and to  then follow a different set of treatment and disposal requirements for that  waste, is central to its overall strategy for addressing its tank waste. For  example, DOE planned to use its incidental waste process to manage  about 90 percent of its 54 million gallons of tank waste at the Hanford Site  as low-level waste, rather than process it through a high-level waste  vitrification facility. Using that approach, most of the waste would be  eligible for treatment and disposal on site. Such an approach would save  billions compared to treating all of the waste as high-level waste and  sending it for disposal in a high-level waste geologic repository.
A recent court ruling precludes DOE from reclassifying some of its waste  as other than high-level waste. In March 2002, the Natural Resources  Defense Council and others filed a lawsuit challenging DOE’s authority to  manage its wastes through its incidental waste process. The plaintiffs  alleged that DOE arbitrarily established the incidental waste determination  process without proper regard for the law or properly establishing a  justification for this process. A primary concern of the plaintiffs was that  DOE would use its incidental waste process to permanently leave  intensely radioactive waste sediments in the tanks with only minimal  treatment. The lawsuit alleged that DOE’s incidental waste process  improperly allows DOE to reclassify high-level waste as incidental waste  that does not need to be treated in the same way as high-level waste.  According to the plaintiffs, the Nuclear Waste Policy Act defines all waste  originating from a given source—that is, from reprocessing of spent  nuclear fuel—as high-level waste and requires that such waste be managed  as high-level waste, yet DOE has chosen to differentiate its wastes  according to the level of radioactivity and manage them accordingly. In a  July 3, 2003 ruling on the lawsuit, the court agreed with the plaintiffs,  stating that the portion of DOE’s Order 435.1 setting out its incidental  waste determination process violates the Nuclear Waste Policy Act and  thus is invalid.
The court’s ruling could seriously hinder DOE’s efforts to implement its  accelerated treatment and disposal strategies. Under the ruling, DOE’s  incidental waste determinations cannot be implemented. Since the start of  the lawsuit, DOE had not implemented any of its approved incidental  waste determinations and had not yet decided whether to defer or proceed  with its pending incidental waste determinations—such as those for  closing tanks at the Savannah River Site and Idaho National Laboratory.
If DOE appeals the court ruling, a lengthy legal process could follow. A  lengthy legal process will also likely delay treatment plans for this waste  and delay closing tanks on an accelerated schedule. For example, the  Idaho National Laboratory planned to begin closing tanks in the spring of  2003, pending approval of an incidental waste determination that would  allow DOE to close the tanks by managing tank waste residuals as low- level waste. A DOE official at the Idaho National Laboratory told us that  while a delay of several months would not immediately threaten schedule  dates, a delay beyond 24 months would seriously affect the site’s ability to  meet its accelerated 2012 date to close all of the tanks.
If the court’s ruling invalidating DOE’s incidental waste determination  process is upheld, DOE may need to find an alternative that would allow it  to treat waste with lower concentrations of radioactivity less expensively.  Searching for such an alternative could delay progress at all three of  DOE’s high-level waste sites that rely on incidental waste determinations.  If DOE cannot meet its accelerated schedules, then potential savings are  in jeopardy. At this point, the department does not appear to have a  strategy to avoid the potential effects of challenges to its incidental waste  determination authority, either from the current court ruling or future  challenges. At the time of our report, DOE officials told us that they  believed the department would prevail in the legal challenge. DOE  believed it would be premature to explore alternative strategies to  overcome potentially significant delays to the program that could result  from a protracted legal conflict or from an adverse decision. Such  strategies could range from exploring alternative approaches for  establishing an incidental waste regulation to asking that the Congress  provide legislative authority for DOE to implement an incidental  waste policy.
section_title: Accelerated Initiative Also Relies on Waste Separation Approaches That Will Not Be Fully Tested
paragraphs: Like the ability to determine that some waste is incidental to reprocessing,  the ability to separate the waste components is important to meet waste  cleanup schedule and cost goals. If the waste is not separated, all of it— about 94 million gallons—may have to be treated as high-level waste and  disposed of in the geological repository. Doing so would require a much  larger repository than currently planned, and drive up disposal costs  by billions of dollars. Successful separation will substantially reduce the  volume of waste needing disposal at the planned repository, as well as the  time and cost required to prepare it for disposal, and allow less expensive  methods to be used in treating and disposing of the remaining low- activity waste. The waste separation process is complicated, difficult, and  unique in scope at each site. The waste differs among sites not only in  volume but also in the way it has been generated, managed, and stored  over the years.
The challenge to successfully separate the waste is significant at the  Hanford Site, where DOE intends to build a facility for separating the  waste before fully testing the separation processes that will be used. The  planned laboratory testing includes a combination of pilot-scale testing of  major individual processes and use of operational data for certain of those  processes for which DOE officials said they had extensive experience.  However, integrated testing will not be performed until full-scale facilities  are constructed. DOE plans to fully test the processes for the first time  during the operational tests of the newly constructed facilities.
This approach does not fully reflect DOE guidance, which calls for  ensuring that new or complex technology is mature before integrating it  into a project. Specifically, DOE’s Project Management Order 413.3  requires DOE to assess the risks associated with technology at various  phases of a project’s development. For projects with significant technical  uncertainties that could affect cost and schedule, corrective action plans  to address these uncertainties are required before the projects can  proceed. In addition, DOE’s supplementary project management guidance  suggests that technologies be developed to a reasonable level of maturity  before a project progresses to full implementation to reduce risks and  avoid cost increases and schedule delays. The guidance suggests that DOE  avoid the risk of designing facilities concurrently with  technology development.
The laboratories working to develop Hanford’s waste separation process  have identified several technical uncertainties, which they are working to  address. These uncertainties or critical technology risks include problems  with separating waste solids through an elaborate filtration system,  problems associated with mixing the waste during separation processes,  and various problems associated with the low-activity waste evaporator.
Given these and other uncertainties, Hanford’s construction  contractor and outside experts have seen Hanford’s approach as  having high technical risk and have proposed integrated testing during  project development. However, DOE and the construction contractor  eventually decided not to construct an integrated pilot facility and instead  to accept a higher-risk approach. DOE officials said they wanted to avoid  increasing project costs and schedule delays, which they believe will result  from building a testing facility. Instead, Hanford officials said that they will  continue to conduct pilot-scale tests of major separation processes. DOE  officials said they believe this testing will provide assurance that the  separation processes will function in an integrated manner. After the full- scale treatment facilities are constructed, DOE plans to fully test and  demonstrate the separation process during facility startup operations.
The consequences of not adhering to sound technology development  guidelines can be severe. At the Savannah River Site, for example,  DOE invested nearly $500 million over nearly 15 years to develop a waste  separation process, called in-tank precipitation, to treat Savannah River’s  high-level waste. While laboratory tests of this process were viewed as  successful, DOE did not adequately test the components until it started  full-scale operations. DOE followed this approach, in part, because the  technology was commercially available and considered “mature.”  However, when DOE started full-scale operations, major problems  occurred. Benzene, a dangerously flammable byproduct, was produced in  large quantities. Operations were stopped after DOE spent about  $500 million because experts could not explain how or why benzene was  being produced and could not determine how to economically reconfigure  the facility to minimize it. Consequences of this technology failure  included significant cost increases, schedule delays, a full-scale waste  separation process that did not work, and a less-than-optimum waste  treatment operation. Savannah River is now developing and implementing  a new separation technology at an additional cost of about $1.8 billion and  a delay of about 7 years.
Subsequent assessments of the problems that developed at Savannah  River found that DOE (1) relied on laboratory-scale tests to demonstrate  separation processes, (2) believed that technical problems could be  resolved later during facility construction and startup, and (3) decided to  scale up the technology from lab tests to full-scale without the benefit of  using additional testing facilities to confirm that processes would work at  a larger scale. Officials at Hanford are following a similar approach.  Several experts with whom we talked cautioned that if separation  processes at Hanford do not work as planned, facilities will have to be  retrofitted, and potential cost increases and schedule delays would be  much greater than any associated with integrated process testing in a  pilot facility.
section_title: Opportunities Exist to Explore Additional Cost Savings and to Strengthen Program Management
paragraphs: In addition to the potential cost savings identified in the accelerated  site cleanup plans, DOE continues to develop and evaluate other proposals  to reduce costs but is still assessing them. Although the potential cost  savings have not been fully developed, they could be in the range of  several billion dollars, if the proposals are successfully implemented. At  the Savannah River and Hanford sites, for example, DOE is identifying  ways to increase the amount of waste that can be placed in its high-level  waste canisters to reduce treatment and disposal costs. DOE also has a  number of initiatives under way to improve overall program management.  However, we are concerned that the initiatives may not be adequate. In  our examinations of problems that have plagued DOE’s project  management over the years, three contributing factors often emerged— making key project decisions without rigorous analysis, incorporating new  technology before it has received sufficient testing, and using a “fast-track”  approach (concurrent design and construction) on complex projects.
Ensuring that these weaknesses are addressed as part of its program  management initiatives would further improve the management of the  program and increase the chances for success.
subsections: section_title: DOE Is Considering Additional Potential Opportunities to Reduce Costs
paragraphs: DOE is continuing to identify other proposals for reducing costs under  its accelerated cleanup initiative. Among the proposals that DOE is  considering, the ones that appear to offer significant cost savings  opportunities would increase the amount of waste placed in each disposal  canister. The amount of waste that can be placed into a canister depends  on a complex set of factors, including the specific mix of radioactive  material combined with other chemicals in the waste, such as chromium  and sulfate, that affect the processing and quality of the immobilized  product. These factors affect the percentage of waste than can be placed  in each canister because they indicate the likelihood that radioactive  constituents could move out of the immobilizing glass medium and into  the environment. The greater the potential for the waste to become  mobile, the lower the allowable percentage of waste and the higher  the percentage of glass material that must be used.
Savannah River officials believe they can increase the amount of waste  loaded in each canister from 28 percent to about 35 percent, and for at  least one waste batch, to nearly 50 percent. In June 2003, Savannah River  began to implement this new process to increase the amount of waste in  each canister. If successful, Savannah River’s improved approach could  reduce the number of canisters needed by about 1,000 canisters and save  about $2.7 billion, based on preliminary estimates. Other efforts to  increase waste loading of the canisters are also under way that, if  successful, may permit further cost savings of about $1.7 billion. The  Hanford Site is also exploring ways to decrease the numbers of waste  canisters that will be needed by using waste forms other than the standard  borosilicate glass. This effort is in a very early stage of development and  cost-savings estimates have not been fully developed.
section_title: DOE Has Opportunities to Improve Management of the Program by Addressing Previously Identified Weaknesses
paragraphs: In addition to site-specific proposals for saving time and money, DOE is  also undertaking management improvements using teams to study  individual issues. Nine teams are currently in place, while other teams to  address issues such as improving the environmental review process to  better support decision making have not yet been formed. Each team has a  disciplined management process to follow, and even after the teams’  work is completed, any implementation will take time. These efforts are in  the early stages, and therefore it is unclear if they will correct the  performance problems DOE and others have identified.
We are concerned that these management reforms may not go far enough  in addressing performance problems with the high-level waste program.  Our concerns stem from our review of initiatives under way in the  management teams, our discussions with DOE officials, and our past and  current work, as well as work by others inside and outside DOE. We have  identified three recurring weaknesses in DOE’s management of cleanup  projects that we believe need to be addressed as part of DOE’s overall  review. These weaknesses cut across the various issues that the teams are  working on and are often at the center of problems that have been  identified. Two of these weaknesses have been raised earlier in this  testimony—lack of rigor in the analysis supporting key decisions, and  incorporating technology into projects before it is sufficiently mature. The  final area of weakness involves using “fast-track” methods to begin  construction of complex facilities before sufficient planning and design  have taken place.
subsections: section_title: Key Decisions Not Always Supported by Rigorous Current Analysis
paragraphs: DOE’s project management guidance emphasizes the importance of  rigorous and current analysis to support decision making during the  development of DOE projects. Similarly, OMB guidance states that  agencies should validate earlier planning decisions with updated  information before finalizing decisions to construct facilities. This  validation is particularly important where early cost comparisons are  susceptible to uncertainties and change.
DOE does not always follow this guidance, yet no DOE management team  appears to be addressing this weakness. Proceeding without rigorous  review has been a recurring cause of many of the problems we have  identified in past DOE projects. For example, the decision at Hanford to  construct a vitrification plant to treat Hanford’s low-activity waste has not  been validated with updated information. Hanford’s primary analysis  justifying the cost of this approach was prepared in 1999 and was based on  technical performance data, disposal assumptions, and cost data  developed in the early to mid-1990s—conditions that are no longer  applicable. Subsequent analyses have continued to rely on this data.  However, since that time conditions have changed, including the  performance capabilities of alternative technologies such as grout, the  relative cost of different technologies, and the amount of waste DOE  intends to process through a vitrification facility.
DOE officials disagree with our assessment of their analysis, stating that a  comprehensive analysis was conducted in the spring of 2003. However,  DOE’s high-level waste project team agreed that the DOE officials at  Hanford had not performed a current, rigorous analysis of low-activity  waste treatment options including the use of grout as an alternative to  vitrification, and the team encouraged the Hanford site to update its  analysis based on current waste treatment and disposal assumptions. DOE  officials at Hanford told us they do not plan to reassess the decision to  construct a low-activity vitrification facility because their compliance  agreement with the state of Washington calls for vitrification of this waste.  They also stated that vitrification is a technology needed for destroying  hazardous constituents in a portion of the waste.
section_title: New Technology Is Incorporated before It Is Sufficiently Mature
paragraphs: Our work on Department of Defense acquisitions has documented a set of  “best practices” used by industry for integrating new technology into  major projects. We reported in July 1999 that the maturity of a technology  at the start of a project is an important determinant of success. As  technology develops from preconceptual design through preliminary  design and testing, the maturity of the technology increases and the risks  associated with incorporating that technology into a project decrease.  Waiting until technology is well-developed and tested before integrating it  into a project will greatly increase the chances of meeting cost, schedule,  and technical baselines. On the other hand, integrating technology that is  not fully mature into a project greatly increases the risk of cost increases  and schedule delays. According to industry experts, correcting problems  after a project has begun can cost 10 times as much as resolving  technology problems beforehand.
DOE’s project management guidance issued in October 2000 is consistent  with these best practices. The guidance discusses technology development  and sets out suggested steps to ensure that new technology is brought to a  sufficient level of maturity at each decision point in a project. For  example, during the conceptual design phase of a project, “proof of  concept” testing should be performed before approval to proceed to the  preliminary design phase. Furthermore, the guidance states that  attempting to concurrently develop the technology and design the facility  for a project poses ill-defined risks to the project.
Nevertheless, as we discussed earlier, DOE sites continue to integrate  immature technologies into their projects. For example, as discussed  earlier, DOE is constructing a facility at the Hanford Site to separate  high-level waste components, although integrated testing of the many  steps in the separations process has not occurred and will not occur until  after the facility is completed. DOE, trying to keep the project on schedule  and within budget, has decided the risks associated with this approach are  acceptable. However, there are many projects for which this approach  created schedule delays and unexpected costs. The continued reliance on  this approach in the face of so many past problems is a signal of an area  that needs careful attention as DOE proceeds with its management reform  efforts. At present, no DOE management team is addressing this issue.
section_title: Facility Construction Starts before Design Is Sufficiently Developed
paragraphs: Finally, we have concerns about DOE’s practice of launching into  construction of complex, one-of-a-kind facilities well before their final  design is sufficiently developed, again in an effort to save time and money.  Both DOE guidance and external reviews stress the importance of  adequate upfront planning before beginning project construction. DOE’s  project management guidance identifies a series of well-defined steps  before construction begins and suggests that complex projects with  treatment processes that have never before been combined into a facility  do not lend themselves to being expedited. However, DOE guidance does  not explicitly prohibit a fast-track—or concurrent design and  construction—approach to complex, one-of-a-kind projects, and DOE  often follows this approach. For example, at the Hanford Site, DOE is  concurrently designing and constructing facilities for the largest, most  complex environmental cleanup job in the United States. Problems are  already surfacing. Only 24 months after the contract was awarded, the  project was 10 months behind schedule dates, construction activities have  outpaced design work causing inefficient work sequencing, and DOE has  withheld performance fee from the design/construction contractor  because of these problems.
DOE experienced similar problems in concurrent design and construction  activities on other waste treatment facilities. Both the spent nuclear fuel  project at Hanford and the waste separations facility at the Savannah River  Site encountered schedule delays and cost increases in part because the  concurrent approach led to mistakes and rework, and required extra time  and money to address the problems. In its 2001 follow-up report on DOE  project management, the National Research Council noted that inadequate  pre-construction planning and definition of project scope led to cost and  schedule overruns on DOE’s cleanup projects. The Council reported that  research studies suggest that inadequate project definition accounts for  50 percent of the cost increases for environmental remediation projects.  Again, no DOE team is specifically examining the “fast-track” approach,  yet it frequently contributed to past problems and DOE continues to use  this approach.
section_title: Conclusions
paragraphs: DOE’s efforts to improve its high-level waste cleanup program and to rein  in the uncontrolled growth in project costs and schedules are important  and necessary. The accelerated cleanup initiative represents at least the  hope of treating and disposing of the waste in a more economical and  timely way, although the actual savings are unknown at this time.  Furthermore, specific components of this initiative face key legal and  technical challenges. Much of the potential for success rested on DOE’s  ability to dispose of large quantities of waste with relatively low  concentrations of radioactivity on site by applying its incidental waste  process. Recently, a court ruled that the portion of DOE’s order setting out  its incidental waste determination process violates the Nuclear Waste  Policy Act and is invalid. Thus, DOE is precluded from implementing this  element of its accelerated initiative. Success in accelerating cleanup also  rests on DOE’s ability to obtain successful technical performance from its  as-yet unproven waste separation processes. Any technical problems with  these processes will likely result in costly delays. At DOE’s Hanford Site,  we believe the potential for such problems warrants reconsidering the  need for more thorough testing of the processes, before completing  construction of the full-scale waste separation facility.
DOE’s accelerated cleanup initiative should mark the beginning, not  the end, of DOE’s efforts to identify other opportunities to improve the  program by accomplishing the work more quickly, more effectively, or at  less cost. As DOE continues to pursue other management improvements,  it should reassess certain aspects of its current management approach,  including the quality of the analysis underlying key decisions, the  adequacy of its approach to incorporating new technologies into projects,  and the merits of a fast-track approach to designing and building complex  nuclear facilities. Although the challenges are great, the opportunities for  program improvements are even greater. Therefore, DOE must continue  its efforts to clean up its high-level waste while demonstrating tangible,  measurable program improvements.
In the report being released today, we made several recommendations to  help DOE manage or reduce the legal and technical risks faced by the  program as well as to strengthen DOE’s overall program management.  DOE agreed to consider seeking clarification from Congress regarding its  authority to define some waste as incidental to reprocessing, if the legal  challenge to its authority significantly affected DOE’s ability to achieve  savings under the accelerated initiative. Regarding our recommendations  to conduct integrated pilot-scale testing of the separations facility at  Hanford before construction is completed, and to make other management  improvements to address the weaknesses I just discussed, DOE’s position  is that it has already taken appropriate steps to manage the technology  risks and strengthen its management practices. We disagree and believe  that implementing all of our recommendations would help reduce the risk  of costly delays and improve overall management of DOE’s entire high- level waste program.  -     -     -     -     -  Thank you, Mr. Chairman and Members of the Subcommittee. That  concludes my testimony. I would be pleased to respond to any questions  that you may have.
For further information on this testimony, please contact Ms. Robin  Nazzaro at (202) 512-3841. Individuals making key contributions to this  testimony included Carole Blackwell, Robert Crystal, Doreen Feldman,  Chris Hatscher, George Hinman, Gary Jones, Nancy Kintner-Meyer, Avani  Locke, Mehrzad Nadji, Cynthia Norris, Tom Perry, Stan Stenersen, and Bill  Swick.
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