Nuclear Waste: Challenges to Achieving Potential Savings in DOE's High-Level Waste Cleanup Program
Published: 2003-06-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Department of Energy (DOE) oversees one of the largest cleanup programs in history--the treatment and disposal of 94 million gallons of highly radioactive nuclear waste from the nation's nuclear weapons program. This waste is 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 determine the status of this initiative, the legal and technical challenges DOE faces in implementing it, and any further opportunities to reduce costs or improve program management.
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 authority to decide that some waste with relatively low concentrations of radioactivity can be disposed of on site. This authority is being challenged in court, and a prolonged challenge or an adverse decision could seriously hamper DOE's ability to meet its accelerated schedules. 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 integrated testing of the separation technology--an approach that has failed on other projects in the past, resulting in significant cost increases and schedule delays. DOE is exploring proposals, such as increasing the amount of high-level waste in each disposal canister, which if successful could result in billions of dollars in additional savings. 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.

section_title: Letter
paragraphs: The Department of Energy (DOE) oversees one of the largest cleanup  programs in history: the treatment and disposal of nuclear waste created  as a result of the nation’s nuclear weapons program. As of 2003, one  major aspect of this effort, DOE’s high-level waste cleanup program,  was estimated to cost nearly $105 billion and take decades to complete.  High-level waste contains radioactive elements, such as plutonium and  uranium, in concentrations sufficient to require long-term isolation from  the environment. DOE’s high-level waste results from the process of  dissolving used (or “spent”) nuclear fuel to remove plutonium, uranium,  and other useful materials. During some of the processing, solvents and  other materials can be introduced, creating waste that is both radioactive  and chemically hazardous. About 94 million gallons of untreated high-level  waste is stored at DOE facilities at Hanford, Washington; Savannah River,  South Carolina; and near Idaho Falls, Idaho—primarily in underground  tanks. This waste would fill an area the size of a football field to a depth of  about 260 feet. Since the 1980s, DOE has been actively working on ways  to prepare this waste for permanent disposal. These plans center on  eventually placing high-level waste in an underground repository where  it can be safely stored for thousands of years.
After investing more than 20 years and about $18 billion, DOE  acknowledged that the program to clean up its high-level waste was  far behind schedule, far over budget, and in need of major change. In  February 2002, DOE began an initiative to accelerate the schedule and  reduce the costs of cleaning up high-level and other radioactive and  hazardous waste, while focusing its resources on reducing risks to  human health and the environment at its sites. Although this initiative  covers DOE’s entire cleanup program, it may have the most significant  impact on DOE’s plans for high-level waste, which is the highest  cost component of DOE’s cleanup program. In this context, you asked  us to (1) describe the components of DOE’s high-level waste and the  process involved in preparing the waste for permanent disposal,  (2) discuss DOE’s initiative for accelerating its high-level waste  cleanup and assess the reliability of the associated potential cost  savings, (3) identify the legal and technical challenges DOE faces  regarding this initiative, and (4) determine any additional opportunities  to reduce the costs, as well as opportunities to improve the management  of its high-level waste program.
This report is based largely on our detailed work at DOE sites where  high-level waste is currently stored and our analysis of cost information  and legal documents pertaining to the high-level waste program. We  obtained the assistance of a physicist with extensive experience in the  nuclear field to evaluate the technical aspects of DOE’s high-level waste  program. A detailed discussion of our scope and methodology is included  in appendix I.
subsections: section_title: Background
paragraphs: High-level waste contains radioactive components that emit dangerously  intense radiation. Radiation is generated through a decay process in which  the atoms of a radioactive component (also known as a radionuclide)  lose their radioactivity by spontaneously releasing energy in the form of  subatomic particles or rays similar to X-rays. Even short but extremely  intense exposure to radiation can cause almost immediate health  problems such as radiation sickness, burns, and, in severe cases, death.  Excessive exposure to these particles or rays damages cells in living  tissue and is believed to cause long-term health problems such as genetic  mutations and an increased risk of cancer. Because of the intense  radiation emitted from high-level waste, the waste must be isolated and  handled remotely behind heavy shielding such as a layer of concrete in  order to protect humans and the environment. In addition to the intense  radioactivity, some of the radioactive components can be very mobile in  the environment and may migrate quickly to contaminate the soil and  groundwater if not immobilized. Besides radioactive components, DOE  high-level waste also generally contains hazardous components added  during the process of dissolving used nuclear fuel to remove plutonium  and other nuclear materials. These hazardous components include  solvents, acids, caustic sodas, and toxic heavy metals such as chromium  and lead. Radioactive waste components, when combined with hazardous  components, are referred to as “mixed wastes.”
DOE has a vast complex of sites across the nation dedicated to the nuclear  weapons program, but the high-level waste stemming from reprocessing  spent fuel to produce weapons material such as plutonium and uranium  has been limited mainly to three sites—Hanford, Washington; the Idaho  National Engineering and Environmental Laboratory (“Idaho National  Laboratory”) near Idaho Falls, Idaho; and Savannah River, South Carolina.  DOE largely ceased production of plutonium and enriched uranium by  1992, but the waste remains. Most of the tanks in which it 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. (Figure 1 shows waste storage tanks being constructed  at the Hanford Site.) These tanks, most of which are underground, are  used to store high-level waste. 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.
Treatment and disposal of high-level waste produced at DOE facilities  are governed by a number of federal laws, including laws that define the  roles of DOE and the Nuclear Regulatory Commission (NRC) in waste  management. The Atomic Energy Act of 1954 (AEA) and the Energy  Reorganization Act of 1974 established responsibility for the regulatory  control of radioactive materials including DOE’s high-level wastes. The  Energy Reorganization Act of 1974 assigned the NRC the function of  licensing facilities that are expressly authorized for long-term storage of  high-level radioactive waste generated by DOE and others. The Nuclear  Waste Policy Act of 1982, as amended, defines high-level radioactive waste  as “the highly radioactive material resulting from the reprocessing of spent  nuclear fuel, including liquid waste produced directly in reprocessing and  any solid material derived from such liquid waste that contains fission  products in sufficient concentrations, and…other highly radioactive  material that the …determines…requires permanent isolation.”  The act also established a process for developing and siting a geologic  repository (a permanent deep disposal system) for the disposal of  high-level waste and spent fuel. Regarding DOE’s high-level waste, the act  provided that unless the President determined that a separate repository  was required for such waste, DOE should arrange for the use of  commercial repositories developed under the act for disposal of its  defense waste. In 1985, President Reagan decided that a separate  repository for defense waste was not needed. Under amendments the  Federal Facility Compliance Act of 1992 made to the Resource  Conservation and Recovery Act of 1976 (RCRA), DOE generally must  develop waste treatment plans for its sites that contain mixed wastes.  These plans are approved by states that the Environmental Protection  Agency (EPA) has authorized to administer RCRA or by EPA in states that  have not been so authorized.
DOE carries out its high-level waste cleanup program under the leadership  of the Assistant Secretary for Environmental Management and in  consultation with a variety of stakeholders. In addition to the EPA and  state environmental agencies that have regulatory authority in states  where the sites are located, stakeholders include county and local  governmental agencies, citizen groups, advisory groups, and Native  American tribes. These stakeholders advocate their views through  various public involvement processes including site-specific advisory  boards. Over the years, much of the cleanup activity has been  implemented under compliance agreements between DOE and the  regulatory agencies. These compliance agreements provide for  establishing legally enforceable schedule milestones that govern the  work to be done.
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 Hanford, Savannah River, and the Idaho  National Laboratory is a complex mixture of radioactive and hazardous  components, and DOE’s process for preparing it for disposal is designed to  separate much of the radioactive material from other waste components.  In the tanks, this mixture has transformed into a variety of liquid and  semisolid forms. The radioactive components are of many different types;  some remain dangerous for millions of years, while others lose much of  their radioactivity in relatively short periods of time. Because most of the  radioactive components decay relatively rapidly, over 90 percent of the  current radioactivity will dissipate within 100 years. DOE plans to isolate  the radioactive components and prepare the waste for disposal through  the use of an extensive and sequential multi-step treatment process. To  fulfill its current commitment to federal and state regulators, 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. DOE plans to dispose of the  remaining waste of relatively low radioactivity on-site near the surface  of the ground, such as in vaults or canisters, or at other designated  disposal facilities.
subsections: section_title: Waste Has Turned into a Variety of Forms
paragraphs: High-level waste generally exists in a variety of physical forms and  layers inside the underground tanks, depending on the physical and  chemical properties of the waste components. The waste in the tanks  takes three main forms:    Sludge: The denser, water insoluble components generally settle to the  bottom of the tank to form a thick layer known as sludge, which has the  consistency of peanut butter.
Saltcake: Above the sludge may be water-soluble components such as  sodium salts that crystallize or solidify out of the waste solution to form a  moist sand-like material called saltcake.
Liquid: Above or between the denser layers may be liquids comprised of  water and dissolved salts called supernate.
As figure 2 shows, 44 percent of the total volume of high-level waste is in  saltcake form, followed by liquid and sludges. In addition, a small portion  of the waste volume is also in solid form and is stored in facilities other  than tanks. At the Idaho National Laboratory, some waste is stored in  stainless steel bins, enclosed in concrete vaults, after having undergone a  thermal process that converted the liquid into a solid granular substance  called calcine. At Hanford, some high-level waste was retrieved from the  tanks, dried, and stored as solid material in stainless steel capsules.
The various layers of waste in the tanks are not uniformly distributed and  often differ from tank to tank and even from place to place within a tank.  Depending on how the waste was generated and whether it was mixed or  transferred from one tank to another, the layers of waste within any given  tank may be unevenly distributed and liquid is interspersed between  layers of saltcake. Some tanks contain all three main waste forms—sludge,  saltcake, and liquid—while others contain only one or two forms. Tank  contents also vary among sites. For example, at the Idaho National  Laboratory most tanks contain primarily liquid waste because the waste  was kept in an acidic form, while at Hanford and Savannah River, most  tanks contain waste in two or three physical forms.
section_title: Much of the Radioactivity Declines Relatively Quickly
paragraphs: The radioactive components of the high-level waste vary greatly in terms  of how long they remain radioactive, with the vast majority losing their  radioactivity within years or decades. Each radioactive component, or  radionuclide, in high-level waste loses its radioactivity at a rate that differs  for each component. This rate of decay, which cannot be changed, is  measured in “half-lives”—that is, the time required for half of the  unstable atoms to decay and release their radiation. The half-lives of  major radionuclides in the high-level waste range from 2.6 minutes for  barium-137m to 24,131 years for plutonium-239. To illustrate, for any  given number of radioactive barium-137m atoms, half will lose their  radioactivity within 2.6 minutes. After another 2.6 minutes, half of the  remaining unstable atoms will lose their radioactivity, leaving only one- fourth of the original number of unstable atoms still radioactive. The  process is the same, but the half-life intervals much longer, for long-lived  radionuclides, such as plutonium-239 atoms. For radioactive plutonium- 239 atoms, half will lose their radioactivity within 24,131 years, and half of  the remainder will lose their radioactivity after another 24,131 years.
Currently, nearly all of the radioactivity in DOE’s high-level waste  originates from radionuclides with half-lives of about 30 years or less. As  table 1 shows, about 98 percent of the radioactivity of the high-level waste  comes from four radionuclides: barium-137m, cesium-137, strontium-90,  and yttrium-90. Of these, cesium-137 is the longest lived, with a half-life of  30.17 years.
The relatively short half-lives of most of the radionuclides in the waste  means that much of the total current radioactivity will decay within  100 years. For example, within 30 years, about 50 percent of the current  radioactivity in DOE’s wastes will have decayed away, and within  100 years, this figure will rise to more than 90 percent. Figure 3 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 the current radioactivity in high-level  waste, a variety of long-lived radionuclides will remain radioactive for  a very long time and must be isolated from the environment.  Radionuclides with half-lives greater than cesium-137 (30.17 years),  such as plutonium-239 and americium-241, which have half-lives of  24,131 years and 432.2 years respectively, will continue to pose a threat  to human health and the environment for thousands of years. Once the  radionuclides with relatively short half-lives have decayed away, the  longer-lived radionuclides will be the primary source of radioactivity in the  waste. Some of these long-lived radionuclides, such as technetium-99, 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’s process for dealing with its high-level waste centers on separating  the various components of the waste so that the portion that is most  radioactive can be concentrated into a much smaller volume. While  currently all high-level waste is radioactive and dangerous, significant  portions of the waste, such as contaminated water, will have low levels of  radioactivity if separated from most of the radionuclides that are highly  radioactive. Contaminated water currently represents 54 percent of the  total waste by volume across the DOE complex. In overview, DOE’s  process generally involves separating the waste into two main streams.  One, the high-level portion, will contain at least 90 percent of the  radioactivity and a small portion of the waste volume. The other stream,  the low-activity portion, will contain 10 percent or less of the total  radioactivity but most of the waste volume.
DOE’s plans for treating the waste currently call for a set of steps to be  applied to the waste at each site. The primary steps are shown in table 2.
DOE plans to permanently dispose of the high-level portion of the  separated waste in a geologic repository developed pursuant to the  Nuclear Waste Policy Act. This repository is intended to isolate highly  radioactive waste materials from the public and the environment for  at least 10,000 years. The remaining low-activity portion would be  immobilized in accordance with federal and state environmental laws and  the agreements made with state regulators and disposed of permanently  on-site or at other designated locations.
Although radionuclides with long half-lives are present in both the  high-level and low-activity portions of the waste after the separations  processes are concluded, the portion of the waste not sent to the geologic  repository will have relatively low levels 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 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. DOE  originally identified several strategies to help it reduce the time needed to  treat and dispose of the waste. Based on these strategies, DOE set a goal  of achieving up to $34 billion in savings at its three high-level waste sites  and reducing the waste cleanup schedule by about 20 to 35 years  compared to the existing program baseline. As of April 2003, DOE’s  strategies were still under development, and DOE had revised the  savings estimate to $29 billion. However, even the $29 billion estimate may  not be reliable. While savings are 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: For the most part, DOE’s past efforts to treat and dispose of high-level  waste have been plagued with false starts and failures, resulting in steadily  growing estimates of the program’s total cost. Since the cleanup activities  began about 20 years ago, DOE has spent about $18 billion in its attempts  to prepare high-level waste for disposal. However, less than 5 percent of  the waste has been successfully treated to date. Uncontrolled cost  overruns, numerous schedule delays, and unsuccessful attempts to  develop treatment processes have pushed the overall estimated cost of the  high-level waste program from about $63 billion in 1996 (when the first  comprehensive estimates were developed) to nearly $105 billion in 2003.
In an attempt to gain control over DOE’s waste management program and  to better ensure its affordability, in February 2002 the Assistant Secretary  for Environmental Management undertook a new initiative aimed at  accelerating cleanup at DOE’s sites and focusing on more rapid reduction  of environmental risks. The initiative came as a result of an internal  review of the cleanup program, which identified numerous problems  and recommended a number of corrective actions. Among other  things, the review noted that the cleanup program was not based on a  comprehensive, coherent, technically supported risk prioritization; was  not focused on accelerating risk reduction; and was not addressing the  challenges of uncontrolled cost and schedule growth. A main focus of the  initiative is high-level waste, including both the technical approach to  treating the waste and improving how DOE manages the contracts and  project activities.
DOE developed strategies to speed the cleanup and reduce risk at all  three sites. Many of these proposals involved ways to do one or more of  the following:    Dealing with some tank waste as low-level or transuranic waste, rather  than as high-level waste. Doing so would eliminate the need to prepare the  waste for off-site disposal in the geologic repository for high-level waste.  Disposing of waste in the repository currently is based on immobilizing the  waste in a glass-like substance through a process called vitrification.    Completing the waste treatment more quickly by using additional or  supplemental technologies for treating some of the waste. 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 ensure it can 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.
Segregating the waste more fully than initially planned and tailoring waste  treatment to each of the four segregated waste types. By doing so, DOE  plans to apply less costly treatment methods to waste with lower  concentrations of radioactivity.
Closing waste storage tanks earlier than expected. DOE plans to begin  closing tanks earlier than scheduled, thereby avoiding the operating costs  involved in maintaining the tanks and monitoring the wastes.
Table 3 shows major site-by-site proposals that have been made.
DOE’s initial estimates in August 2002 were that, if the proposals were  successfully implemented, total savings could be about $34 billion  compared to the baseline cost estimate in place when the accelerated  initiative began. As of April 2003, the savings estimate associated with the  new strategies had been revised to about $29 billion (see table 4). DOE  officials told us many of their new strategies are still under development  and that savings estimates are still subject to additional revision.
section_title: Current Savings Estimates May Not Be Reliable
paragraphs: Our review of these savings estimates suggests that they may not yet  be reliable and that the actual amounts to be saved if DOE successfully  implements the strategies may be substantially different from what  DOE is projecting. We have several concerns about the reliability  and completeness of the savings estimates. 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 uncertainties or the timing of  the savings.
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 baselines, 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 itself acknowledged in its February 2002 review of the cleanup  program that baseline cost estimates do not provide a reliable picture of  project costs.
The National Research Council, which has conducted research on DOE’s  project management, has reported on why DOE’s baseline cost estimates  are often unreliable. It noted in 1999 that DOE often sets project baselines  too early and that industry practice calls for completing from 30 percent to  35 percent of a design before establishing a baseline cost estimate. In a  recent example, we found that the estimated contract price of Hanford’s  high-level waste treatment facility is expected to increase to $5.8 billion,  about $1.6 billion above the original $4.2 billion contract price established  in December 2000. The original cost estimate was established when less  than 15 percent of the facility design was complete. The cost increase is  due to such factors as adding contingency funds for unforeseen  occurrences and making some facility modifications not in the  original contract.
section_title: Accelerated Cost Estimates May Be Incomplete
paragraphs: A second reason for concern about the cost-savings estimates is that  some of the savings may be based on incomplete estimates of the costs  for the accelerated proposals. According to the Office of Management and  Budget’s (OMB) guidance on developing cost estimates, agencies should  ensure that all appropriate costs are addressed in the estimate. However,  for example, the Idaho National Laboratory estimates savings of up to  $7 billion, in large part, by eliminating the need to build a vitrification  facility to process waste currently in calcine form and in tanks, as well as  achieving associated reductions in operations and decommissioning costs.  The waste, as is, may have to undergo an alternative treatment method  before it can be accepted at a geological repository. The Idaho National  Laboratory plans to use one of four different technologies currently  being evaluated to treat its tank waste. DOE’s 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 as  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: A third area of concern is that DOE’s savings estimates generally do not  accurately reflect the timing of when savings will occur, the uncertainty  associated with cost estimates or the reliability of a technology, or the  value of potential nonbudgetary impacts of the alternative strategies.  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. 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  did 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. An example where nonbudgetary  impacts were partially, but not fully, considered is the Idaho National  Laboratory. The Idaho National Laboratory’s accelerated plan notes that  its proposal not to vitrify its calcined high-level waste significantly reduces  risk to workers and the environment by eliminating the exposure that  would have been incurred in cleaning up and decommissioning the  vitrification facility once waste treatment had been completed. While site  officials told us such analyses are currently underway, the impact has not  yet been reflected in the savings estimate. However, the proposal 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 to 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 as high-level waste. DOE’s authority to make such  determinations is being challenged in court. 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 Initiative Relies Heavily on Authority That Is Being Challenged in Court
paragraphs: DOE is involved in a lawsuit over whether it has the authority to manage  some tank wastes containing lower concentrations of radioactivity as  other than high-level waste. The outcome could affect DOE’s ability to  move forward with waste treatment on an accelerated schedule. If DOE  retains its ability to manage much of the waste as other than high-level  waste, it can apply less expensive treatment methods to that portion of  the waste, dispose of the waste on-site, and close the tanks more quickly.  If DOE loses the legal challenge, these faster and less expensive treatment  alternatives may not be available. Regardless of the outcome, if an  extended legal process ensues, DOE may be prevented from realizing the  full potential savings associated with its accelerated cleanup initiative.
subsections: section_title: DOE’s Authority and Procedures for Designating Waste as “Incidental”
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,  DOE based its approach to treatment and disposal on the radioactivity  and actual constituents in the waste, as well as the source of the waste.  Focusing on the radioactivity and constituents would allow DOE to use  less costly and less complicated treatment approaches for the majority of  what is now managed as high-level waste.
DOE has developed a process for deciding when waste in the tanks should  not be considered high-level waste. In July1999, DOE issued Order 435.1  setting forth procedures for the management of its radioactive wastes.  Under this order, 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 Order 435.1 establishes the specific criteria for defining the waste  that could be considered incidental to reprocessing and therefore is not  high-level waste and would not require the vitrification treatment that  high-level waste must undergo for disposal purposes. The criteria were  developed in conjunction with the NRC, the governmental entity with  regulatory authority over disposal facilities for high-level waste. The  criteria generally are that the waste (1) has been or will be processed to  remove key radioactive components to the maximum extent technically  and economically practical; (2) will be disposed of in conformance  with the safety requirements for low-activity waste as laid out in NRC  regulations; and (3) will be put in a solid physical form and will not exceed  radioactivity levels set by the NRC for the most radioactive category of  low-level waste, referred to as “Class C standard.” DOE must first satisfy  itself internally that these requirements have been met for waste it wants  to determine is waste incidental to reprocessing and therefore not  high-level waste. DOE then obtains a technical review of its determination  from the NRC, which provides a concurrence that DOE has met its  criteria. DOE then considers the waste not to be high-level waste, but  waste that can be managed as either low-level or transuranic waste.
section_title: Designation as “Incidental” Would Apply to Much of the Waste
paragraphs: 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 plans to use its incidental waste process to manage about  90 percent of its 54 million gallons of tank waste at Hanford 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 be less expensive  than treating all of the waste as high-level waste and sending it for disposal  in a high-level waste geologic repository. DOE has no current estimate  of the cost increase if all 94 million gallons of tank wastes had to be  treated in a high-level waste vitrification facility and stored at a geological  repository. However, a 1996 environmental impact statement at the  Hanford Site estimated such an alternative for the Hanford Site alone  would add about $29 billion to $37 billion (in 1995 dollars), nearly doubling  project costs at that site alone, primarily due to increased disposal costs at  the repository. Furthermore, there would probably not be enough space at  the high-level waste repository to dispose of all of this waste.
Hanford is not the only site affected; as of April 2003, DOE had developed  incidental waste determinations for waste at all four of its high-level waste  sites. In all, DOE had used its authority to designate some of its tank  waste as low-level or transuranic waste in seven separate incidental waste  determinations (see table 5). Although two of these determinations were  approved prior to the issuance of Order 435.1, DOE essentially followed  the same criteria found in the subsequent order. DOE is planning to  initiate further incidental waste determinations as it removes the waste  from additional tanks.
DOE is currently involved in a lawsuit focused on its authority to make  incidental waste determinations. 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. A primary  concern of the plaintiffs is that DOE will use its incidental waste process  to permanently leave intensely radioactive waste sediments in the tanks  with only minimal treatment. The lawsuit alleges 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.
This is not the first legal action that resulted from DOE’s process for  determining which part of its waste can be designated as incidental to  reprocessing and will not be managed as high-level waste. For example,  in 1993, the NRC denied a formal petition from the states of Washington  and Oregon requesting that NRC establish the process and criteria for  determining what part of DOE’s radioactive waste could be managed as  other than high-level waste. The states’ request stemmed from concerns  that the criteria DOE was applying to wastes had not been formally  established by regulation and thus had not been given public scrutiny.  The NRC, in its ruling, concluded that DOE’s process for determining  what waste was incidental to reprocessing was appropriate for making  individual tank-by-tank incidental waste determinations, and that the NRC  had no jurisdiction. Later, in 1998, the Natural Resources Defense Council  petitioned the NRC to assume immediate licensing authority over the  51 tanks at the Savannah River Site, arguing that DOE invented the term  “incidental waste” as a means of circumventing NRC’s authority and  oversight and, furthermore, that waste to be left in the bottom of the tanks  at Savannah River did not meet DOE’s own definition of incidental waste.
The NRC concluded it did not have regulatory authority over high-level or  residual wastes at Savannah River.
section_title: Uncertainty about DOE’s Authority Could Delay Implementing New Initiatives
paragraphs: The current legal challenge, as well as any future challenges, could  affect DOE’s efforts to implement its accelerated treatment and disposal  strategies. For example, the challenge could place on hold indefinitely all  pending incidental waste determinations. Since the start of the lawsuit,  DOE has not implemented any incidental waste determinations and has  not yet decided whether to defer or move forward with its pending  incidental waste determinations—such as for closing tanks. DOE is  concerned that moving forward to implement such determinations could  create a risk that the court could place a general ban on making any  decisions about the waste until the legal challenge is resolved. In addition,  final resolution of the challenge could be further delayed if either party  appeals the decision.
A lengthy legal process could result in delays in moving forward  with treatment plans for this waste and delays in closing tanks on an  accelerated schedule. For example, the Idaho National Laboratory plans  to begin closing tanks in the spring of 2003, but approval for the incidental  waste determination to close the tanks by managing tank waste residuals  as low-level waste is still pending. A DOE official at the Idaho National  Laboratory told us that while a delay of several months in obtaining  incidental waste approval would not present an immediate threat to  schedule dates, a delay beyond 24 months would seriously impact the  site’s ability to meet its accelerated 2012 date to close all of the tanks.  Savannah River also plans to begin closing additional tanks starting in  early 2004. A DOE official at the Savannah River Site said that if the  lawsuit continues, the site may miss a legally binding date agreed to with  regulators to begin closing the tanks.
If the court invalidated DOE’s incidental waste determination process,  DOE may need to find an alternative solution for treating and managing  its wastes that would allow it to treat waste with lower concentrations of  radioactivity less expensively. In that case, DOE could begin experiencing  delays affecting progress at all three of the high-level waste sites that rely  on incidental waste determinations. For example, as one of its savings  strategies, DOE plans to manage about 12.3 million gallons of its waste  at Savannah River as low-level waste and treat this waste through a  grout facility. DOE estimates it could begin treating this waste as  early as August 2003. Although DOE has approved an incidental waste  determination for this waste, the grout treatment facility must receive an  operating permit from state regulators. To date, the state has withheld  approval for the permit, pending resolution of the lawsuit. A site official  said without the permit, DOE cannot go forward with its plans to  accelerate treatment of the waste.
At this point, the department does not appear to have a strategy in  place to avoid the potential effects of challenges to its incidental waste  determination authority, either from the current lawsuit or future  challenges. In a December 2002 internal memorandum, the Assistant  Secretary for Environmental Management issued guidelines for proceeding  with making incidental waste determinations as necessary to meet cleanup  commitments and requirements. However, these guidelines only include  ensuring that such determinations meet the legal requirements of  Order 435.1; the guidelines do not include any alternative strategies  for dealing with the waste. DOE officials told us that they believe the  department will prevail in the legal challenge. Because the outcome of the  lawsuit is so uncertain, DOE believes 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. As of April 2003, DOE had just begun to look at potential  delays that could result from a lengthy legal challenge, but had developed  no formal strategy to deal with those delays. Such strategies could range  from exploring alternative approaches for establishing an incidental waste  regulation to asking that the Congress clarify its intentions regarding  DOE’s authority to implement an incidental waste policy.
section_title: Initiative Also Relies Heavily on Waste Separation Approaches That Will Not Be Fully Tested
paragraphs: DOE’s initiative also faces key technical challenges related to the process  for separating the various components of the waste. Waste separation  involves a sequential process of filtering and extracting each major  high-level waste constituent, such as cesium-137 and strontium-90, from  the waste. DOE guidance recognizes the risks involved in implementing  a technology without first thoroughly testing it. In order to save time,  however, DOE managers at the Hanford Site are planning some of their  strategies around waste separation technologies that will not be fully  tested before being implemented. Past projects that took this approach  have experienced major problems, and outside reviewers have raised  cautions about DOE’s plans to use the same approach in this instance.
subsections: section_title: Separating Waste Is Key to Treating It Economically
paragraphs: Separating high-level waste into its various components is central to  DOE’s treatment and disposal plans. Since the 1980s, federal and state  agreements have reflected DOE’s plan that the waste be processed so that  at least 90 percent of the radioactivity in high-level waste is concentrated  into a much smaller waste stream and prepared for permanent isolation in  a geological repository. The low-activity waste portion, which represents  the majority of the waste volume but significantly less radioactivity, must  also be immobilized according to federal and state agreements.
Separating the waste components is important not only to comply with  federal and state agreements, but also 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 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 and size 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. Although the main steps in the process may vary,  waste separation generally involves a sequential process of filtering and  extracting various high-level waste constituents from the tank waste  (see figure 4). The waste treatment approach at the Hanford Site involves  designing, building, and operating one-of-a-kind separations processes and  facilities. Developing a successful waste separations process has proved  challenging for DOE in the past, especially at Savannah River, and the  current plans for Hanford are no less challenging.
At its Hanford site, DOE intends to build a facility for separating the  waste before fully testing the separation processes that will be used.  The technology for separating waste components at Hanford is being  developed at several laboratories, including the Savannah River  Technology Center. These facilities are performing tests to help validate  underlying assumptions about how the processes will work. The  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 completed 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 for incorporating new  or complex technology into a project, which calls for ensuring that the  technology is mature before integrating it into a project. More 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 are required to determine how the  uncertainties will be resolved before the projects can proceed. In addition  to this order, DOE has drafted supplementary project management  guidance. This guidance suggests that technologies are to be developed  to a reasonable level of maturity before a project can progress to full  implementation to reduce risks and avoid cost increases and schedule  delays. The guidance suggests that DOE avoid the risk of performing  concurrent facility design and 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.  The contractor is also concerned about the availability and performance  of a special resin for separating out cesium-137, a radioactive constituent.  The resin is currently produced by only one supplier, and that supplier  currently does not have the manufacturing capability to produce the  resin in the quantities needed for DOE’s full-scale operations, according  to contractor officials. In an effort to resolve this uncertainty,  DOE’s construction contractor has asked the manufacturer to  expand resin production capability, and in April 2003, DOE signed a  contract modification that allows alternative resins to be used in the  separation process.
Given these and other uncertainties, Hanford’s construction  contractor and outside experts have seen Hanford’s approach as  having high technical risk and have recommended integrated testing  during project development.
In April 2002, concerned about the potential for operational problems  with the waste separation processes, Hanford’s construction contractor  proposed building an integrated testing facility to confirm that Hanford’s  processes will work at a significantly larger scale than has been tested to  date. The contractor proposed conducting fully integrated tests in a pilot  facility using simulated waste before full-scale separation facilities are  completed. The contractor estimated the cost of the pilot facility at  between $6 million and $12 million.  In October 2002, an independent peer review group of industry experts  concluded that an integrated pilot plant for interim testing to confirm the  technical processes was a preferred approach. Several other independent  experts we interviewed also shared this view. These experts are  associated with the National Research Council and various research  organizations, universities, and private institutions. These experts  emphasized that performing integrated testing to verify that separation  processes will work is an essential step, especially for treating Hanford’s  unique waste in the complicated waste treatment facilities that Hanford  is building.
In contrast to these views, DOE’s Office of River Protection and the  construction contractor 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.
Full testing of Hanford’s separation process may be a bigger challenge  than originally envisioned. In April 2003, DOE modified the construction  contract for the waste treatment facilities and adopted a schedule  compressing the facility testing and startup period from 4 years to about  2.5 years. To meet this compressed schedule, Hanford’s construction  contractor decided in late April 2003 to drop its proposal for the pilot  plant. Instead, the contractor plans to continue laboratory testing of  separation processes in an effort to simulate the results of an integrated  pilot plant. While contractor officials stated that their original proposal  for an integrated pilot plant was technically sound, they withdrew the  proposal in order to ensure that they could meet revised contract schedule  and budget commitments.
section_title: Past Experience at Savannah River Shows Consequences of Deviating from Technology Development Guidelines
paragraphs: 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  separations 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 conduct adequate testing of the components  until it started full-scale operations in the newly constructed facility. DOE  followed this approach, in part, because the technology was commercially  available. 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 facility  that did not work, and a less-than-optimum waste treatment operation  without a viable separation process. Savannah River is now taking steps to  develop and implement 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 this same 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 can be much  greater than those 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 additional  proposals to reduce costs, but is still in the process of fully assessing these  proposals. Because DOE is still evaluating these proposals, the potential  cost savings have not been fully developed, but could be in the range of  several billion dollars, if 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 they 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. Senior Environmental Management  officials realize that the proposals to accelerate cleanup identified in  site performance management plans do not represent a complete set of  options for full achievement of DOE’s savings goals. To pursue additional  potential opportunities, the Assistant Secretary for Environmental  Management commissioned several special project teams to evaluate  additional program improvements and cost-savings opportunities. One  of these teams, the high-level waste project team, has completed the  initial phase of its work. According to DOE’s high-level waste project team  leader, it may be some time before their proposals are fully assessed and  decisions are made about how best to proceed. The Assistant Secretary  will consider the proposals from the project teams, but has not stated  when final decisions will occur.
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. We discussed these cost-savings  opportunities with both Savannah River and Hanford officials during our  review. DOE officials at those sites have identified these potential savings  opportunities as deserving further consideration, but have not yet fully  assessed the potential benefits, or overcome technical and operational  barriers.
subsections: section_title: Opportunities at Savannah River Look Promising but Have Not Been Fully Demonstrated
paragraphs: Savannah River officials are working to reduce costs by increasing the  amount of waste immobilized in glass and placed in each disposal canister.  They have proposed increasing the amount of waste in each canister by  developing different blends of glass material, called frit, that they believe  can be tailored to each batch of waste. 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 leach out of the  immobilizing glass medium and into the environment. The greater the  potential for leaching, the lower the allowable percentage of waste and the  higher the percentage of glass frit that must be used. DOE determines that  a consistently acceptable glass is produced by evaluating the leaching  rates of the glass, using a combination of chemical analysis and  predictive modeling.
Based on a recent improvement made to DOE’s predictive model involving  adjustments to the required temperature of the melted waste, and changes  to the type of glass frit 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.  Savannah River plans to implement this new process and begin  increasing the amount of waste in each canister in June 2003. 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.
Beyond the specific improvements Savannah River officials have already  identified, there may be an additional way to increase the loading of waste  into disposal canisters, resulting in additional savings for DOE. During our  review, we determined that DOE’s Offices of Environmental Management  and Civilian Radioactive Waste Management (Radioactive Waste  Management) have been using different acceptance criteria for evaluating  the rate at which waste could leach out of the glass in the disposal  canisters. By conforming to the less restrictive Radioactive Waste  Management criteria, Environmental Management could possibly increase  the amount of waste in the canisters to a higher level. After examining  this possibility, Environmental Management officials at Savannah River  said that, if the higher waste loading could be achieved, this change could  eliminate the need for up to 650 canisters. This may permit further cost  savings of about $1.7 billion. The Savannah River officials stated that they  were continuing to examine this cost-savings possibility.
section_title: Because Opportunities at Hanford Are in Early Development, Savings Are Not Yet Known
paragraphs: The Hanford Site has also proposed strategies to decrease the number of  high-level waste canisters that it will need, but its approach is in a very  early stage of development. In November 2002, Hanford proposed  broadening the high-level waste acceptance criteria to allow waste forms  other than standard borosilicate glass—the type of glass being used at  Savannah River and initially planned for Hanford—to be accepted for  immobilizing high-level waste. Hanford’s proposal is based on recent  changes to NRC’s disposal requirements that will allow for alternative  waste forms to be sent to the repository. These changes may allow  Hanford to package its high-level waste in fewer canisters.
Although it is unclear whether DOE orders will be changed to allow these  other waste forms, DOE has significant incentives to do so. Reducing the  number of canisters at Hanford is especially important because, based  on the expected production capacity of the high-level waste vitrification  plant, only a maximum of 9,600 of the projected 12,800 canisters that DOE  will need can be filled with waste by the 2028 scheduled completion date.
However, by using other types of glass, Hanford estimates that it may be  able to reduce its need for disposal canisters by 2,500 to 3,900 canisters.  If such a significant reduction in the number of canisters produced is  possible, it could shorten Hanford’s high-level waste treatment schedule  by 6 years, save billions of dollars, and help to meet its scheduled  completion date. However, the wide range of Hanford’s estimate reflects  the rough nature of its proposal and that cost savings have not yet been  fully estimated.
section_title: DOE Has Opportunities to Improve Management of the Program by Addressing Previously Identified Weaknesses
paragraphs: In addition to DOE’s efforts to identify 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 using breakthrough business  processes in waste cleanup and 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 be  effective in correcting the causes of the performance problems DOE and  others have identified.
We are concerned, however, 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 underway 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 this  overall review. These weaknesses cut across the various issues that the  teams are working on and are often found at the center of problems that  have been identified. Two of the three weaknesses have been discussed  earlier in this report, as we have identified these as potentially significant  obstacles to achieving savings—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. All DOE projects with costs greater than  $5 million require risk management activities, including a thorough  analysis, to be applied continuously, adjusting these analyses throughout  the process as necessary to ensure DOE is pursuing the best value  alternative at the lowest cost. Similarly, the Office of Management and  Budget 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.
However, DOE does not always follow this guidance. Proceeding without  rigorous review has been a recurring cause of many of the problems we  have identified in past DOE projects. For example, regarding the need to  validate planning decisions with updated information before finalizing  decisions, the decision at Hanford to construct a vitrification plant to  treat Hanford’s low-activity waste has not undergone such a validation.  Hanford’s 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. For example, the 1999 analysis compared DOE’s  low-activity vitrification approach with a disposal approach developed  in the early 1990s that involved large underground grout vaults with  elaborate environmental controls. Although this grout approach was  abandoned in 1994, DOE still used these disposal assumptions for the 1999  comparison and analysis. Since that time other conditions have changed,  including the performance capabilities of alternative technologies such as  grout, the relative costs of different technologies, and the amount of waste  DOE actually intends to process through a vitrification plant. These  changes suggest that earlier planning decisions need to be validated with  updated information to ensure that the current approach is reasonable and  appropriate. DOE’s high-level waste project team also recognized 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 encouraged the Hanford site to update  its analysis based on current waste treatment and disposal assumptions.  Hanford officials responded in April 2003 by developing life-cycle  cost estimates that compared the cost of alternate low-activity waste  approaches. However, they did not fully reassess the decision to vitrify  low-activity waste. 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.
In our previous work, we noted a similar lack of rigor in reevaluating DOE  decisions as conditions change. For example, at three sites—Fernald,  Ohio; Oak Ridge, Tennessee; and the Idaho National Laboratory—DOE  was faced with a decision about whether to dispose of low-level waste  on-site or to use off-site commercial disposal facilities. Between the time  that DOE decided to develop on-site disposal facilities at these three sites  and the time that construction actually began, conditions changed that  affected the usefulness of earlier cost estimates. However, DOE officials  at the sites made little effort to update and reevaluate the original cost  comparisons to validate the on-site disposal decision. In July 2002, DOE’s  Office of Environmental Management issued guidance to implement our  recommendation to validate cost comparisons before constructing or  expanding low-level waste disposal facilities at these three sites.
This weakness cuts across the issues that the DOE teams are working on;  no DOE team appears to be currently addressing it. However, DOE  managers need to ensure that it receives proper consideration as these  management improvement efforts proceed.
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 design 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 having 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 projects  that attempt to concurrently develop the technology and design the facility  proceed with ill-defined risks to all three baselines—cost, schedule,  and technical.
Nevertheless, as we discussed earlier in this report, DOE sites continue  to integrate immature technologies into their projects. For example, at  Hanford, DOE is constructing a facility 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 in 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 project 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 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 rests on DOE’s  continued ability to dispose of large quantities of waste with relatively low  concentrations of radioactivity on-site by applying its incidental waste  process. DOE’s authority in this regard has been challenged in a lawsuit  that is still pending. Much of the success 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.
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.
section_title: Recommendations for Executive Action
paragraphs: To help ensure that DOE’s accelerated cleanup initiative is effective and  that cleanup of high-level waste proceeds in a timely and cost-effective  manner, we recommend that the Secretary of the Department of Energy    seek clarification from the Congress regarding DOE’s authority for  designating waste as incidental to reprocessing if the current challenge  becomes an extended legal process, in order to help DOE determine  what strategy it needs to move its initiative forward and realize  potential savings;  reassess the potential risks, costs, and benefits of constructing an  integrated pilot-scale waste separation facility at the Hanford site to more  fully test separation technologies before completing construction of a  full-scale facility; and    ensure that DOE’s high-level waste projects (1) include a current and  rigorous analysis of the risks, costs, and benefits associated with the  decisions being implemented, in accordance with OMB guidance;  (2) incorporate new technologies consistent with best practices and  DOE guidance so that risks and costs are more effectively managed; and  (3) are carefully evaluated as to the appropriateness of using a fast-track  approach to designing and constructing complex nuclear facilities, and  that the potential risks and costs associated with this approach are  explicitly identified and considered.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the Department of Energy for its  review and comment. DOE’s Assistant Secretary for Environmental  Management responded for DOE. DOE’s written comments acknowledged  the challenges that DOE faces in its high-level waste program, as discussed  in our report. DOE cited its recent initiative to accelerate cleanup and  reduce environmental risks as its response to those challenges. DOE  agreed to consider our recommendation to seek clarification from the  Congress regarding DOE’s authority to determine what waste is incidental  to reprocessing, if legal challenges to DOE’s authority to make such  determinations have a significant effect on implementing proposed  cost-saving and risk-reduction initiatives. However, DOE disagreed with  our recommendation that it conduct integrated pilot testing of its waste  separation processes at Hanford while constructing a full-scale facility. In  addition, regarding opportunities to improve program management, DOE  said that at the Hanford project it was already effectively conducting  rigorous analyses to support decision-making, incorporating new  technologies into the project consistent with best practices and agency  guidelines, and using a fast-track approach of concurrently designing and  building complex nuclear facilities.
Regarding our recommendation that DOE pursue integrated, pilot-scale  testing of the waste separations facility at Hanford, DOE believes that  its current approach is adequate to manage the risks associated with  designing and constructing the facility. DOE said that it does not intend to  pursue an integrated pilot test facility that we believe would increase the  chances of success with the full-scale facility. DOE’s position is based on  two main arguments. DOE believes that (1) the technologies planned for  the separations facility are commercially available and thus are mature  technologies having low technical risk and (2) relying on pilot testing of  individual components of the separation processes in the laboratory  provides adequate mitigation of the risks involved.
We disagree with DOE’s view that the separations approach planned for  the Hanford Site is low risk. DOE has experience with the individual  technologies, but does not have experience in operating an integrated  separations process that incorporates all of the operations required for  Hanford’s unique and complex waste. Furthermore, DOE has experienced  problems with another separation facility where adequate testing was not  done until the facility was fully constructed—the in-tank precipitation  facility at Savannah River. In that case, the separations process failed  after DOE spent about $500 million trying to make it work properly.  And the primary technologies used at Savannah River were also in use  commercially, but had not been fully adapted to the unique Savannah  River wastes.
We also disagree that DOE’s plan to conduct extensive testing in the  laboratory to mitigate the technology risks involved with the separation  processes will provide adequate assurance that the full-scale separations  facility will perform effectively. Numerous experts and DOE’s contractor  have proposed constructing and operating an integrated pilot-scale facility.  They made the proposals while knowing about DOE’s intention to conduct  extensive laboratory testing of separation processes. The contractor as  well as outside experts view the separations facility as having significant  project risk, in contrast to DOE’s statement that the separation processes  pose low project risk. Given the risks associated with fully constructing  the separations facility before conducting integrated testing and the  cost of any delays associated with having significant problems with the  separation processes once the facility is fully constructed, we continue  to believe that conducting integrated pilot-scale testing is an important  risk- and schedule-management tool and that DOE should reconsider its  use for the Hanford project. DOE officials at Hanford acknowledged that  the pilot facility could be included in the project without extending the  project’s schedule.
Regarding management improvement issues, DOE said that we  inadequately portrayed the progress it has made in the three areas in  which we recommended management improvements. However, our report  addresses the three management issues from the broader context of DOE’s  project activities over several years and at a number of sites. Our past  work has clearly linked these weaknesses to problems on cleanup  projects. Because DOE did not take issue with that broader context in  this report, but did assert improved performance on the Hanford project,  the following comments are limited to needed improvements to the  Hanford project.
Regarding DOE’s view that it performed current and rigorous analyses  of risks, cost, and benefits for the Hanford waste treatment project, our  report illustrates our concerns about the analysis DOE performed to  support its decision to vitrify a portion of Hanford’s low-activity waste.  DOE stated that this decision, originally made in 1994, has been revisited  numerous times using rigorous analysis and provided us with three studies  that specifically compared the cost of low-activity waste vitrification with  other approaches, such as grout, to support its decision. None of these  studies included a current and rigorous analysis of risks, costs, and  benefits, as called for in OMB guidance. For example, even the most  recent study, completed in 2003, was primarily based on technical  performance, disposal assumptions, and cost data developed in the early  1990s. The team leader of the high-level waste project team confirmed that  these analyses were not a full and rigorous assessment of the risks, cost,  and benefits of vitrifying low-activity waste. Thus, we continue to believe  that additional efforts are needed in this area.
Regarding our recommendation to follow best practices and DOE  guidance when incorporating new technology into cleanup projects, DOE  commented that it was continuing to consider opportunities to improve  the Hanford project and that the contractor was using a risk-based  management process to address technical and programmatic project  risks. We agree that a risk-based management process is appropriate on  the project. However, we continue to believe that DOE’s approach to  incorporating the separation technologies planned for the Hanford project  is not fully consistent with best practices and DOE guidance because the  approach involves incorporating technologies into the project before  they have been fully tested as an integrated process. This testing of the  integrated process in an operational mode is needed to demonstrate  that the technologies are sufficiently mature to ensure their effective  performance when deployed on the project.
Concerning the appropriateness of using a “fast-track” construction  approach to design and construct complex nuclear facilities for the  Hanford project, DOE said that our report incorrectly portrays the  overall strategy for the Hanford project. We believe our report accurately  describes DOE’s approach, which includes using concurrent design,  construction, and technology development. We have previously reported  on the risks associated with this approach, including the increased  potential for project schedule delays and cost increases.
DOE also provided technical clarifications and corrections to our report,  which we incorporated as appropriate. The full text of DOE’s comments  and our responses are presented in appendix II.
We conducted our review from July 2002 through May 2003, in accordance  with generally accepted government auditing standards. Appendix I  provides details on our scope and methodology.
As arranged with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days after  the date of this letter. At that time, we will send copies to the Secretary  of Energy. We will also make copies available to others on request. In  addition, the report will be available at no charge on the GAO Web site at  http://www.gao.gov. If you or your staff have any questions on this report,  please call me at (202) 512-3841. Other staff contributing to this report are  listed in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To describe the components of DOE’s high-level waste and the process  involved in preparing the waste for permanent disposal, we analyzed  information and documents provided by DOE officials and contractors at  the four sites containing DOE high-level waste: Hanford, Washington;  Idaho National Laboratory, Idaho; Savannah River, South Carolina; and  West Valley, New York. We did not independently verify the accuracy of  the information provided by each DOE site. From these same sites, we  also obtained information on the types, age, and condition of the facilities  used to store the high-level waste. To assist in evaluating technical aspects  of high-level waste, we obtained assistance from our technical consultant,  Dr. George Hinman. Dr. Hinman has a Doctor of Science degree in physics,  is Professor Emeritus at the Washington State University, and has  extensive experience in the nuclear energy field in industry, government,  and academia.
To examine DOE’s initiative for accelerating its high-level waste cleanup  and the associated potential cost savings, we obtained and reviewed the  Performance Management Plans for each of DOE’s four high-level waste  sites (Hanford, Savannah River, Idaho National Laboratory, and West  Valley). We discussed these initiatives thoroughly with officials from  each of the sites and obtained documentation discussing the proposed  initiatives, as well as savings estimates. We reported all dollar estimates  as provided by DOE in current dollars and did not adjust these figures  to constant dollars. We did not verify the accuracy of cost information  provided by DOE. We also reviewed guidance from the Office of  Management and Budget circulars, especially circular A-94, on the type  of analysis that federal agencies should use when developing benefit and  cost estimates, and compared DOE’s proposed savings estimates to that  guidance. We analyzed savings estimate figures provided by DOE’s  Savannah River staff, discounting the dollars to provide an estimate in  constant dollars.
To identify the legal challenges DOE faces, we obtained documentation  relating to the current Natural Resources Defense Council (NRDC)  lawsuit. We discussed the lawsuit separately with attorneys from the  NRDC, as well as from DOE. We also discussed the waste-incidental-to- reprocessing process with staff at the NRC. We documented each site’s  incidental waste determinations, as well as historical information on the  development of DOE Order 435.1. We also reviewed the appropriate  statutes, related regulations and orders. To identify the technical  challenges and issues that must be resolved to realize potential savings,  we obtained documentation on the technical uncertainties and risks  associated with the waste treatment approaches at the Hanford, Idaho  National Laboratory, and Savannah River sites. Because waste separation  is central to successful high-level waste treatment and disposal, we  documented the status of each site’s approach. We identified the major  technical concerns, uncertainties, and risks associated with the waste  separations approaches and discussed them with DOE and contractor  officials at each site. We also visited the Savannah River Technology  Center to review the progress and results of laboratory tests conducted  to develop the Savannah River and Hanford sites’ waste separations  technology. With the assistance of our technical consultant, we contacted  a variety of independent experts in industry and academia to obtain their  views on the risks associated with these technologies.
To determine additional opportunities for reducing high-level waste  program costs, we reviewed DOE waste acceptance policies and  requirements, planning documents, position papers, and internal memos.  We discussed the opportunities with DOE officials, contractors, and  laboratory officials primarily at the Hanford, Idaho National Laboratory,  and Savannah River sites. We compared the cost-savings concepts with  those presented in performance management plans at each site to  document that they represented additional opportunities. We also relied  on the expertise of our technical consultant to help assess the technical  viability of DOE’s proposals. To determine opportunities to improve the  management of the program, we reviewed DOE’s Top-to-Bottom report  and we discussed management reform proposals with officials at DOE  headquarters. We also obtained documentation on DOE’s project review  teams. We reviewed prior reports from GAO, DOE’s IG and the National  Research Council to identify recurring weaknesses in DOE management  of its cleanup program, and we developed current examples of those  weaknesses from our work at the high-level waste sites and meetings  with DOE officials. We also compared management weaknesses we  identified to DOE’s current reform efforts to determine the extent to  which the weaknesses were being addressed and to identify areas needing  continued attention.
We conducted our review from July 2002 through May 2003 in accordance  with generally accepted government auditing standards.
section_title: Appendix II: Comments from the Department of Energy
subsections: section_title: GAO Comments
paragraphs: 1.  We agree and have modified the final report to clarify that the  low-activity portion of the separated tank waste would be immobilized  and disposed of permanently on-site, or at other designated locations.  2.  We agree and have modified the final report to clarify that DOE’s  approach generally involves separating the waste into two main  streams.  3.  We modified the final report to clarify that the intentional discharges  from the tanks were only at the Hanford Site. We do not agree with  DOE’s statement that the tank wastes discharged into the soil  contained relatively low-levels of radioactivity. According to DOE’s  records, the tank waste discharged into the soil at the Hanford Site  contained radioactive components with long half-lives, such as  technetium-99. The available records show that, as of December 1989,  decades after the waste was discharged into the soil, the 121 million  gallons still contained more than 65,000 curies of radioactivity.   4.  We agree and have modified the final report accordingly.  5.  We believe that using the term “contaminated water” when referring to  water from the tanks that may include radioactive and hazardous  components is more accurate. The use of the term “water” by itself  could be misleading for the general reader.  6.  We agree and have modified the final report to clarify that the use of  process knowledge is a central part of the characterization step.  7.  Although DOE may use constant dollars to report the department’s  environmental liabilities under its Government Results and Reporting  Act requirements, it has not done so in its savings estimates or public  disclosures for its accelerated cleanup initiative. In addition, to  correctly compare costs of alternatives with different timing, DOE  should compare “present values” of costs and not merely the constant  dollars. Therefore, we made no change to the final report.  8.  We agree and have modified the final report to include the cost  contingency as a factor in the cost growth for the Hanford high-level  waste treatment facility.  9.  We believe that this comment reinforces the message in the  draft report that some of the proposed savings may be based on  incomplete estimates of the costs for the accelerated proposals. DOE  commented that the range of costs for the alternative technologies for  the sodium-bearing waste in the tanks—from $150-400 million—was  less than the $1 billion estimated cost of vitrifying the waste, and  therefore was not included in the savings estimate. We continue to  believe that the savings estimates in the accelerated plan should have  reflected all associated costs, including the difference between the  costs for the alternative technologies and the costs for vitrification. We  disagree that the $7 billion in estimated savings is solely attributable to  the differences in strategy for treating calcine waste. The July 2002  accelerated plan for the Idaho National Laboratory specifically states  that the $7 billion will be saved by the new cleanup approach for both  calcine and sodium-bearing waste that eliminates the need for a  vitrification facility.   10.  We believe that this comment reinforces the message in the report that  the use of a single point estimate does not reflect uncertainties. We  disagree that including a section in the accelerated plan that catalogs  the government furnished services and items is the same or similar to  accounting for uncertainties by providing a range of savings estimates.  11.  While the accelerated plan for the Idaho National Laboratory  briefly discusses reductions in risk to workers from less intrusive  characterization and sampling techniques and elimination of a  vitrification facility, it does not fully describe the advantages and  disadvantages to workers and the environment. Therefore, we  continue to believe that the savings estimates do not fully discuss the  nonbudgetary impacts such as environmental risks.  12.  We believe this section of the report, including the summary  paragraph, adequately describes DOE’s management of waste  processing activities.  13.  Although section 114 of the Nuclear Waste Policy Act limits the  amount of nuclear waste that can be deposited in the repository, this  limitation is not relevant to the point in this paragraph. Therefore, we  made no change to the final report.  14.  We believe the report adequately conveys this information.  15.  We address these comments in the Agency Comments section of the  report.  16.  We agree and have modified the final report to acknowledge that  DOE had implemented the GAO recommendation to validate cost  comparisons before constructing or expanding disposal facilities for  low-level waste.
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the individual named above, Carole Blackwell, Robert  Crystal, Doreen Feldman, Chris Hatscher, George Hinman, Gary Jones,  Nancy Kintner-Meyer, Avani Locke, Mehrzad Nadji, Cynthia Norris,  Tom Perry, and Stan Stenersen made key contributions to this report.