Hanford Cleanup: DOE Should Take Actions to Improve Inspections and Oversight of Contaminated Excess Facilities
Released: 2020-02-20T00:00:00

Letter

Background

This section provides an overview of the Hanford Site, including DOE’s progress cleaning up the site, and DOE’s requirements and organizational structure for managing and overseeing cleanup and S&M activities at the site.

Overview of Hanford Site and Cleanup Progress

Located in southeastern Washington State, the Hanford Site is one of the most contaminated nuclear waste sites in North America. The site covers 586 square miles upriver from the cities of Richland, Pasco, and Kennewick. The Columbia River flows through about 50 miles of the site. The River Corridor and Central Plateau represent the two main geographic areas for cleanup work. See Figure 1 for a map of the Hanford Site.

DOE’s primary goal for cleaning up Hanford is to protect the Columbia River from contamination now and in the future and to restore groundwater. Since cleanup began in 1989, DOE has made progress towards these goals, including remediating 1,342 of 2,032 waste sites, demolishing 889 of 1,715 excess facilities, removing 18.5 million tons of contaminated soil and debris from areas along the Columbia River, and treating 20 billion gallons of contaminated groundwater. DOE’s most recent schedule estimate for completing cleanup of the Hanford Site is 2078, although final decisions for many cleanup actions have not yet been made. RL’s current overarching set of near-term cleanup goals and priorities—outlined in its 2020 Vision—include initiating the transfer of radioactive sludge from the K basin, cleaning up highly contaminated soils underneath the 324 building, and completing demolition of the Plutonium Finishing Plant, which is among Hanford’s most contaminated nuclear facilities.

Hanford Contaminated Excess Facilities Selected for Our Review

Table 1 includes a list and summary descriptions for each of the contaminated excess facilities we selected for our review. A more detailed discussion of the scope for our review is presented in appendix I.

DOE Requirements for Surveillance and Maintenance of Hanford’s Contaminated Excess Facilities

The objectives for conducting S&M of contaminated excess facilities are to ensure adequate containment of any contaminants left in place; provide physical safety and access controls; and maintain the facility in a manner that will minimize risk to human health and the environment. S&M requirements are derived primarily from nuclear facility safety regulations and DOE orders concerning occupational safety, environmental protection, security, and emergency response planning. DOE orders also require that nuclear facility maintenance plans address aging degradation and obsolescence and that surveillance inspections be conducted to detect malfunction and deterioration and determine whether the structural integrity of contaminated excess facilities is threatened. Under the TPA Action Plan, DOE has established an S&M plan for each of the key excess facilities. The S&M plan identifies the facility and associated structures covered by the plan and the specific inspection activities and frequencies to be conducted. For the other excess facilities, S&M requirements are established through provisions of the cleanup contract which require that the contractor perform the S&M activities necessary to maintain them in a safe and compliant condition.

Due to the wide variation in types of contaminated excess facilities and associated hazards and risks, RL uses a graded approach that allows for differences from facility to facility regarding the frequency and extent of inspections and associated structural integrity engineering evaluations. Structural integrity engineering evaluations are conducted to determine the adequacy, structural integrity, and soundness of structures and their components. Inspections are conducted using a procedural checklist comprising a list of functional areas from the facility’s inspection plans or procedures, which personnel performing inspections are to evaluate. Inspection checklists can include, among other things, structural integrity (an integral part of excess facility inspections), animal and water intrusion, electrical hazards, and ground subsidence. The S&M plans for contaminated excess facilities require interior walk-through inspections generally on an annual basis but that can vary depending on the facility. Typically, these inspections follow a designated path intended to represent conditions that might be present in areas of the facility that are not visually inspected. In addition, a qualified structural engineer conducts an inspection of the roof integrity—recognized as the most likely risk of failure for the contaminated excess facilities—and other associated structures at those facilities. The frequency, extent of future inspections, and recommendations resulting from these periodic inspections are to be documented by the structural engineer.

DOE Framework for Oversight of Hanford Cleanup and S&M of Contaminated Excess Facilities

The program offices at DOE headquarters, RL, and Hanford contractors have overlapping roles and responsibilities for managing and overseeing the cleanup and S&M of Hanford excess facilities. These include:

Office of Environmental Management: DOE established EM in 1989 to address the environmental legacy of 50 years of nuclear weapons production and government-sponsored nuclear energy research across the country. EM is responsible for the cleanup of large amounts of radioactive wastes, spent nuclear fuel and nuclear material, contaminated soil and groundwater, and the decommissioning and demolition of contaminated excess facilities at various sites. EM offices involved with oversight of contaminated excess facilities cleanup and S&M activities include:

Field Operations Oversight/Chief of Nuclear Safety Office.

This office has responsibility for strengthening federal oversight of EM’s cleanup mission, including maintaining operational awareness of field office sites’ operations oversight and implementation of nuclear safety requirements, including requirements for S&M.

The Standards and Quality Assurance Office. This office assists with headquarters review of deactivation and decommissioning project planning documents, configuration management and controls, and S&M programs.

Office of Enterprise Assessments. This independent office, which reports directly to the Office of the Secretary, is responsible for implementing DOE’s Independent Oversight Program for safety and security in accordance with various DOE policies and orders. Through this program, the office conducts appraisals of the adequacy of DOE policy and requirements and the effectiveness of DOE and contractor line management performance in safety and security.

The Office of Environment, Safety, and Health Assessments.

This office is responsible for conducting assessments to provide information on programs and performance in protecting DOE workers, the public, and environment from hazards present at DOE sites and operations. It also conducts special reviews and studies of safety and emergency management topics and activities where warranted based on circumstances or performance or as directed by DOE management.

Hanford Site. RL is responsible for managing and overseeing non- tank waste cleanup activities at Hanford—including S&M of excess facilities—in the Central Plateau area and for completion of some remaining cleanup work in the River Corridor. RL management and oversight includes verification that work is performed in a safe, secure, and quality manner that protects the public, the worker, and the environment and complies with contractual requirements.

Project and Facilities Division. This division is responsible for managing and overseeing the cleanup and S&M of Hanford’s excess facilities.

Operations Oversight Division. This division has primary responsibility for day-to-day oversight to ensure cleanup work is performed in compliance with requirements for safety, quality assurance, and quality control. This includes ensuring that S&M activities follow approved plans and procedures and that the contractor corrects any deficiencies identified during facility inspections.

Site Stewardship Division. This division manages the Long Term Stewardship Program that includes overseeing S&M of the six cocooned reactors.

Cleanup Contractor. Private firms under contract to DOE perform the cleanup and S&M work at Hanford.

Central Plateau Cleanup. Since 2008, cleanup and S&M of most of the contaminated excess facilities discussed in this report have been performed under the Plateau Remediation Contract by C2HM HILL Plateau Remediation Company. The S&M activities for excess facilities, including how often and what parts of the facility are inspected, are determined by the contractor as necessary to meet contract requirements.

Mission Support. Mission Support Alliance is the contractor for the Long Term Stewardship Program and is responsible for ongoing S&M activities for the six cocooned reactors; these activities are expected to last for at least 75 years.

DOE Did Not Assess the Programmatic Causes or Fully Implement Key Recommendations Following the PUREX Tunnel Collapse

DOE has taken some actions to evaluate the causes of the PUREX tunnel 1 collapse, but has not determined the programmatic causes that contributed to the tunnel collapse, such as by completing an accident investigation or a root cause analysis. In addition, DOE headquarters’ recommendations to improve S&M of contaminated excess facilities and the availability of information on the condition of at-risk areas within these facilities have not been fully implemented.

DOE Did Not Conduct a Root Cause Analysis of the Tunnel Collapse

RL has taken some actions to evaluate the physical causes that contributed to the PUREX Tunnel 1 collapse, but has not determined the programmatic causes that led to the collapse, such as by completing an accident investigation or a root cause analysis, among other things.

Specifically, after the collapse, RL took several actions to comply with a 2017 Washington State Department of Ecology Administrative Order. In this order, the Washington State Department of Ecology determined that RL and the Hanford cleanup contractor were not operating and maintaining the PUREX Tunnel 1 to achieve compliance with the site’s hazardous waste permit and failed, among other things, to keep the operation of the tunnel undisturbed until closure of the facility. The Administrative Order required RL to take several corrective actions to address violations outlined in the Administrative Order, including determining the cause of the PUREX Tunnel 1 collapse. To fulfill the 2017 Administrative Order corrective action, the cleanup contractor performed an engineering evaluation to determine the structural conditions that led to the collapse of PUREX Tunnel 1. However, the contractor noted in the evaluation that due to the risks of exposure to high radiation levels and urgency to seal the collapsed area, there was insufficient information available to determine the causes of the collapse. Instead, the evaluation identified three potential causes of the collapse, with the most likely cause being deterioration and decay of the tunnel’s timber structure. The state accepted these findings from the engineering evaluation as satisfying the requirements in the Administrative Order corrective action that RL identify the causes of the collapse.

Notably, the 2017 structural engineering evaluation of Tunnel 1 conducted after the tunnel collapse did not include a root cause analysis to determine the underlying programmatic causes that contributed to DOE not performing previously recommended structural assessments or detecting through regular S&M activity the imminent collapse of PUREX Tunnel 1 collapse. DOE had been aware of concerns with the structural integrity of Tunnel 1 since the 1970s. These concerns lead to the completion of structural assessments in the late 1970s, early 1980’s, and in 1991, when it was recommended that the tunnel be reassessed again in 10 years. Due to elevated risk of contamination and radiation exposure to inspectors, subsequent structural integrity assessments were completed using existing information from prior evaluations, including testing of tunnel structural material, instead of collecting updated information through physical inspections to determine if the PUREX tunnels were structurally sound for continued use, according to RL officials. Figure 2 illustrates the timeline of events related to the tunnels, showing that while the structural integrity of Tunnel 1 was raised several times over the last 40 years and it was recommended in 1991 to assess the tunnel again by 2001, an assessment did not occur until after the May 2017 PUREX Tunnel 1 collapse as part of the corrective actions required by the state.

DOE’s order on accident investigations contains requirements to initiate an investigation into both the individual and organizational (programmatic) root and contributing causes of events resulting in, but not limited to, a fatality of an employee or member of the public or serious injury requiring hospitalization; loss of control of radioactive material or environmental release of hazardous material; or at least $2.5 million in damage to property or in costs for cleaning, decontaminating, renovating, replacing or rehabilitating. According to RL officials, RL did not initiate such an investigation into programmatic causes because management concluded that the PUREX Tunnel 1 collapse did not reach these threshold requirements. However, according to RL officials’ written responses to our questions about incident, the costs of responding to the PUREX Tunnel 1 collapse and stabilizing the tunnel exceeded $10 million.

DOE Order 232.2A, Occurrence Reporting and Processing of Operations Information, also requires the investigation, categorization, and analysis of reportable occurrences by facility representatives and contractors using a graded approach in accordance with locally approved procedures for implementing the requirements of this order. For an occurrence such as the May 2017 PUREX tunnel collapse, which constituted noncompliance with regulatory requirements that created the potential for actual harm, DOE’s order and related guidance indicates that a causal analysis should have been performed to identify the root causes, including the programmatic causal factor or factors that, if corrected, would prevent similar future occurrences.

According to the cleanup contractor’s condition report on the PUREX tunnel collapse, the contractor initially classified the incident as a significant event because it was categorized as an operational emergency and significant by default. According to this report, under the contractor’s reporting procedures, such a classification requires the performance of a root cause analysis to determine the causes and corrective actions with the intent of preventing recurrence. The contractor’s condition report related to the incident notes that RL waived the performance of a root cause analysis in favor of a less rigorous apparent cause analysis to determine the structural factors that led to the collapse of PUREX Tunnel 1. According to a written explanation provided to us by RL management, while the tunnel collapse was due to structural degradation, RL’s first priority was stabilizing the tunnel to mitigate the potential for further collapse, and a programmatic root cause analysis to determine the cause was not warranted. In this written response, RL did not provide any explanation for why a programmatic root cause analysis was not warranted. In an email, RL’s Operations and Oversight Division facility representative granted the cleanup contractor’s request for a waiver from conducting a root cause analysis and concurred with their assertion that an apparent cause analysis was more appropriate. Based on this direction, a root cause analysis was not performed.

A root cause analysis, performed by either DOE headquarters or RL in accordance with the requirements of DOE’s orders on accident investigations and occurrence reporting, would have included an assessment of the underlying programmatic factors that contributed to the collapse of PUREX Tunnel 1. For example, a root cause analysis would determine why PUREX facility inspections that only include visual observations of the surface areas around the tunnels were insufficient in identifying the likelihood of the imminent collapse of PUREX Tunnel 1; why a recommendation made in 1991 for an engineering evaluation to be completed by 2001 to determine if the tunnel was still structurally sound for continued use was not completed; or why RL did not make stabilization or cleanup of the tunnel a higher priority. By conducting a root cause analysis to determine any programmatic weaknesses that contributed to the collapse of PUREX Tunnel 1, and taking action to address any identified weaknesses, DOE would have greater assurance that another, similar event will not take place at Hanford.

DOE Has Not Fully Implemented 2017 Extent of Condition Review Recommendations

In June 2017, shortly after the PUREX Tunnel 1 collapse, EM initiated an Extent of Condition Review to investigate program weaknesses and risks in regard to contaminated excess facilities at three DOE sites, including Hanford. Although EM’s 2017 Extent of Condition Review concluded that, overall, the S&M processes for excess facilities were adequate in mitigating risks, EM’s review identified some weaknesses and made four recommendations to improve the S&M of contaminated excess facilities and availability of information on these facilities’ condition. Specifically, two of these four recommendations addressed weaknesses in inspections of facilities and improving information about the condition of excess facilities:

A comprehensive review should be conducted to identify high-risk areas within excess facilities where inspections have not been conducted for over 5 years. The results of the review should be used to inform the risk management process used to prioritize actions and projects.

For excess facilities for which limited areas may be used for ongoing operations or storage of nuclear materials, the S&M of the unused areas should be reviewed to assure long-term integrity and stability that is comparable to facilities that are excess.

RL has not fully implemented these two recommendations. RL has taken some actions, including commissioning an engineering team to evaluate the structural integrity of some facilities similar to the PUREX tunnels that may pose a future threat of collapse. However, this evaluation of the structural integrity of Hanford’s contaminated excess facilities was not comprehensive and did not include an evaluation of the structural integrity of all excess facilities of concern that may be at risk of structural failure.

For instance, the scope of the evaluation was focused on 27 underground waste storage structures in the Central Plateau, such as cribs, tanks and trenches, which were constructed prior to PUREX Tunnel 1. In addition, this evaluation was largely based on old data and did not include any physical or non-physical inspection and testing to verify if a facility or part of a facility needed to be stabilized or prioritized for cleanup, according to RL officials. In addition, although recommended in EM’s 2017 Extent of Condition Review, to date, RL has not taken action to direct the cleanup contractor to carry out comprehensive inspections at all contaminated excess facilities, and there are areas of some facilities that still have not been entered, either physically or by remote means, to conduct internal inspections. RL officials told us that they generally agree that inspections of aging facilities should include evaluations of their structural integrity. According to these officials, there have been ongoing discussions about such inspections, including how often and in what areas to conduct them. Officials said these decisions would need to be determined on a case-by- case basis depending on the safety consequences of potential incidents. They also stated that RL has prioritized removing hazards to reduce potential threats to human health and the environment to reduce future surveillance and maintenance costs and preparing the canyon areas and other facilities for final cleanup.

According to EM headquarters officials, the 2017 Extent of Condition Review recommendations were intended to be considered as opportunities for improvement which site management could incorporate as deemed appropriate. EM officials explained that there is no requirement for sites to take action to implement the review recommendations or track their progress. However, by not taking actions to implement the Extent of Condition Review recommendations, RL will continue to lack information about the condition of high-risk areas within contaminated excess facilities where inspections have not been conducted for several years and will miss opportunities to identify and address any deteriorating conditions that could lead to the collapse of another contaminated excess facility.

Most Contaminated Excess Facilities Are Inspected as Required, but Some Inspections Are Not Comprehensive

The Hanford contractor is generally conducting surveillance inspections of most contaminated excess facilities as required. However, EM’s 2017 Extent of Condition Review and our review found that the cleanup contractor did not conduct comprehensive inspections at all contaminated excess facilities and that there are areas of some facilities that personnel infrequently or never enter, physically or by remote means, to conduct interior inspections. In addition, although EM’s 2017 Extent of Condition Review team noted that they observed examples where appropriate S&M activities were taking place at contaminated excess facilities, the team also acknowledged that such activities do not assure the EM sites’ S&M programs are adequate to prevent mishaps, as evidenced by the collapse of PUREX tunnel. Further, DOE headquarters offices responsible for the evaluation of DOE site activities have not conducted any specific assessments or audits focusing on management and oversight of Hanford S&M activities since 2013.

DOE Conducts Inspections of Most Contaminated Excess Facilities, but Some Facilities Are Not Comprehensively or Regularly Inspected

According to EM’s 2017 Extent of Condition Review and our review of inspection reports at selected facilities, routine surveillance inspections of Hanford’s contaminated excess facilities are being conducted and the EM review concluded that Hanford’s surveillance inspections were generally adequate. However, this same EM review, as well as our review, identified weaknesses in Hanford’s inspection program.

DOE orders require sites to clearly address aging degradation and obsolescence and to conduct surveillance inspections at contaminated excess facilities to detect malfunction and deterioration and determine whether the structural integrity of contaminated excess facilities is threatened. Once DOE determines that a facility is excess to mission needs, the disposition phase of a contaminated excess facility’s life cycle usually includes deactivation, decommissioning, and S&M activities, followed by decontamination and demolition. According to RL officials, a graded approach—taking into account the risks posed at each contaminated excess facility— can be used to tailor S&M activities, including the frequency of facility inspections. In addition, S&M plans and procedures are prepared by DOE and implemented by the contractor, who determines the frequencies and areas of contaminated excess facilities included in surveillance inspections.

EM’s 2017 Extent of Condition Review found that at three EM sites, including Hanford, contaminated excess facilities surveillance inspections were adequate and overall ensured that the S&M programs were mitigating risks. Additionally, the review found that the sites were giving appropriate attention to roof integrity through the S&M process. Roof structural integrity is a key concern at contaminated excess facilities, as the roof serves as protection against spread of contamination and represents the most likely failure risk and safety risk for workers. Further, in our review of selected contaminated excess facilities, we found that the Hanford cleanup contractor has conducted annual surveillance inspections of most of these facilities and has taken action to ensure the structural integrity of some contaminated excess facilities. For example, RL’s responses to our questionnaire indicated that for 16 of the 18 contaminated excess facilities we selected for our review, the contractor conducts interior inspections of structural integrity on a periodic basis. In addition, we found that between 2008 and 2018, the contractor annually inspected three of the four contaminated excess facilities we selected for our in-depth reviews.

However, RL responses to our questionnaire revealed concerns with completeness of structural integrity evaluations and the structural integrity of some facilities. For five of 18 facilities, RL officials identified structural integrity or degradation which could lead to the potential release of hazardous or nuclear materials, such as the May 2017 partial collapse of PUREX Tunnel 1, as a concern. RL responses also indicated that engineering analyses to evaluate structural integrity had been conducted for 13 of the 18 facilities; however, at 10 of these facilities some areas were not included in the evaluation due to concerns about worker safety from radiological or other hazards. Further, EM’s 2017 Extent of Condition Review, other recent DOE reports, and our review of inspection reports for selected contaminated excess facilities found several instances in which the cleanup contractor did not conduct comprehensive surveillance inspections at all excess contaminated facilities, including infrequently or never entering portions of some facilities, either physically or by remote means, to conduct interior structural integrity evaluations.

REDOX. According to the 2015 Canyon Risk Mitigation Plan, the REDOX canyon is not accessed during routine S&M activities. This report also notes that the canyon deck area is expected to be highly contaminated, is not inspected, has not been entered in more than 50 years, and structural conditions are unknown. The canyon deck is located in the central portion of the canyon building and is isolated from other areas of the facility by thick reinforced concrete walls and floors. It is located above the facility process cells that were used to extract plutonium. According to RL officials, these process cells and other parts of the main canyon building are not accessed during routine walkthrough inspections due to high levels of radioactive contamination. Furthermore, in the contractor’s 2016 annual inspection of the REDOX facility complex, the contractor did not evaluate three annexes of the canyon facility for structural integrity, according to RL’s response to our questionnaire. According to RL officials, the contractor did not carry out these evaluations of the annexes because RL plans to complete their final cleanup in the near term. However, according to a 2016 DOE planning document, the schedule for conducting the cleanup of the annexes is unknown, and RL officials told us it may be several more years before cleanup begins.

Because these annexes are not inspected for structural integrity, RL and the cleanup contractor may not have sufficient information regarding their condition for planning purposes, such as assessing if immediate maintenance is required to stabilize a structure or prioritizing an annex for immediate cleanup. In addition, according to a 2012 DOE report, because the canyon was not deactivated after shutdown in the 1960s, information is very limited and there is a significant level of uncertainty about the conditions inside the building. According to the EM’s 2017 Extent of Condition Review, despite ongoing S&M activities, if facility deterioration continues and is left unaddressed, the condition of the facility could present a threat to human health and the environment, as well as increase the costs of S&M in the near term.

PUREX. According to EM’s 2017 Extent of Condition Review, parts of the main PUREX facility are not physically inspected, including the canyon deck. The canyon deck is in the central portion of the main canyon building and is isolated from the surrounding areas of the facility by thick, reinforced concrete walls and floors and has not been entered in more than 10 years, according to the Hanford cleanup contractor’s 2015 Canyon Risk Mitigation Plan report. According to this report, conditions within this space are unknown, and high contamination levels are expected. Due to lack of information and concerns about this area, the 2015 Canyon Risk Mitigation Plan recommended—for data-gathering and planning purposes— inspecting this area either physically or remotely, if physical entry is not possible due to high levels of radiation. This report also stated that future cleanup work could not be initiated in this area without sufficient information related to the condition of the canyon deck. In addition, a 2019 engineering evaluation of the facility determined that degradation may not be fully addressed by S&M activities and the risk of release of hazardous substances will increase as degradation continues or goes undetected. Figure 3 shows the main PUREX plant and auxiliary facilities.

216-Z-9 Crib. According to the EM’s 2017 Extent of Condition Review, due to the highly contaminated nature of 216-Z-9 Crib, inspections of this facility are limited to external surveillance of the roof and looking down the facility stairwell to the trench area of the crib. However, a 2006 inspection of the interior of the crib utilized a remote controlled device to inspect and determine that the structural integrity of the facility’s roof was suspect. This inspection recommended that the roof be inspected for structural integrity every 5 years; however RL did not direct the contractor to inspect the facility until 2016. Furthermore, according to RL officials, when the facility was inspected in 2016 and then again in 2018, the inspections did not include an engineering evaluation or use of non-physical engineering or robotic tools to inspect the structural integrity of the roof, as was done in 2006, to determine if the facility was safe for continued use. Despite the lack of an engineering evaluation or interior inspection of the roof, the 2016 and 2018 inspection reports gave the facility a passing grade for structural integrity—raising questions about both the basis and reliability of this assessment. RL officials told us they did not instruct the contractor to conduct such an evaluation because recent visual surveillance inspections of the outside of the crib roof did not indicate that structural failure was imminent. However, in its January 2019 structural integrity assessment of contaminated excess facilities at risk of collapse, the contractor reported that this facility was among 11 facilities needing further evaluation.

Plutonium Finishing Plant 241-Z-361 Settling Tank. According to RL’s response to our January 2019 questionnaire, the interior of the Plutonium Finishing Plant 241-Z-361 Settling Tank is not inspected. RL’s response noted that although there are concerns regarding the structural integrity of the facility, the facility is safe for continued use. However, RL’s response is not consistent with prior studies on the condition of the tank. To support the questionnaire response, RL referred to the 2018 Documented Safety Analysis and a 1997 Structural Integrity Assessment for Plutonium Finishing Plant 241-Z- 361 Settling Tank. The 2018 Documented Safety Analysis concludes that the tank is in a structurally degraded condition but is not considered at risk of imminent failure.

However, the 1997 Structural Integrity Assessment that DOE used to support the conclusion in its Documented Safety Analysis determined it was not possible to accurately assess the condition of concrete in the facility and there were uncertainties associated with the strength of its structural steel. The 1997 report also concluded that deteriorating conditions of the facility could lead to the leakage of radioactive waste material, further accelerating the degradation through corrosion and conditions that could result in the collapse of the tank. Notably, a subsequent 1999 video inspection revealed cracking in the interior roof, dissolving of the interior steel liner, and deterioration of the concrete sidewall of the tank.

Despite these documented concerns about the structural integrity of the facility, RL officials that we spoke with could not provide a specific reason for why the interior of this facility has not been inspected. Most recently, a structural integrity initial assessment performed for the contractor in January 2019 identified the Plutonium Finishing Plant 241-Z-361 Settling Tank as the top priority among 11 contaminated excess facilities needing further evaluation to determine if the facility is structurally sound for continued use. This report stated that the facility is currently in a structurally degraded condition, with severe deterioration of the construction materials supporting the structure.

224B Concentration Facility. This facility is contaminated from past operations and parts of the facility are not physically inspected, according to the 2015 Canyon Risk Mitigation report. In addition, according to a 2015 RL briefing report, the facility’s roof is aging and will likely require replacement within 5 years. According to RL officials, the roof of this facility has not been replaced, and according to RL’s response to our questionnaire, no significant maintenance or structural work has been conducted since 2008 and none is needed or planned based upon the current condition of the facility. However, RL’s response to our questionnaire indicates that RL has not conducted a structural integrity engineering evaluation of the facility to support this conclusion. According to RL officials, they are currently in the process of developing a plan to complete decommissioning and decontamination of the facility. Under the TPA, the plan is to be submitted by the end of September 2020. However, RL officials told us that even with regulatory approval of the plan, DOE likely will use additional funding to pursue other near-term cleanup priorities rather than clean up the 224B Concentration Facility.

According to EM’s 2017 Extent of Condition Review, other recent DOE reports, and our review of inspection reports for selected contaminated excess facilities, gaps in S&M activities are, in some cases, due to access challenges at the facilities. According to the EM 2017 Extent of Condition Review, not all facility areas are inspected regularly due to difficulty of access or elevated risk of contamination or exposure, or because those areas are in such a degraded condition they are not safe to enter. However, the contractor has demonstrated the capability to use engineering or robotic evaluations to inspect or determine the structural integrity of the facility, or parts of the facility, and verify whether it needs to be stabilized or prioritized for cleanup. For example, such analyses were done at the PUREX tunnels and at the 216-Z-9 Crib, as noted above. Despite this capability, RL management has not directed the cleanup contractor to perform such inspections for some of Hanford’s contaminated excess facilities or parts of facilities. According to RL officials, decisions on regularity and types of inspections and structural evaluations will depend on the known risks associated with the facility. Without directing the contractor to routinely conduct comprehensive inspections to gather crucial information on the condition of contaminated excess facilities, RL cannot ensure that it is meeting all of DOE’s S&M requirements—such as addressing aging degradation and obsolescence of facilities—and preventing other potential events similar to the PUREX tunnel collapse.

DOE Headquarters Has Conducted Some Assessments of RL Cleanup Work but Has Not Conducted Oversight Reviews of S&M Activities at Hanford

DOE headquarters offices have conducted some assessments of RL cleanup work but have not conducted any assessments or audits focused on RL’s oversight of the cleanup contractor’s S&M activities since 2013. EM’s Field Operations Oversight/Chief of Nuclear Safety Office and DOE’s Office of Enterprise Assessments are required to conduct independent oversight to the extent necessary to evaluate the effectiveness of DOE field office oversight of contractor activities, including activities needed to maintain contaminated excess facilities in a safe and compliant condition pending their final cleanup. We reviewed 21 DOE HQ oversight reports on RL activity from the past 5 years and determined that none of these assessments or audits focused on RL’s management and oversight of the contractor’s S&M activities for contaminated excess facilities.

We spoke with DOE officials from two headquarters offices responsible for independent oversight of DOE field offices—the EM Field Operations Oversight/Chief of Nuclear Safety Office and the Office of Enterprise Assessments. Officials with both headquarters offices confirmed that neither office has conducted a specific assessment or audit focusing on RL’s management and oversight of S&M activities for contaminated excess facilities in the last 5 years. Officials with the Office of Enterprise Assessments told us that, given the limited resources available to conduct oversight, they have to prioritize and be selective about the reviews they plan to conduct in a given year, and conducting an in-depth assessment of RL’s oversight of Hanford S&M activity has not been a priority with that office. In December 2018, the office considered whether to conduct a formal assessment of RL oversight of Hanford S&M activity, but decided that such an assessment was not needed.

However, the projected overall time in S&M mode underscores the importance that S&M be adequate to maintain facility safety during the final stages of cleanup operations through a seamless transition to the final disposition of the facility to protect human health and the environment. We found that S&M requirements for selected contaminated excess facilities will continue for decades. Specifically, our review of 18 contaminated facilities at Hanford found that many of these facilities were determined to be excess between the 1960s and the late 1980s and transitioned into S&M status at that time. Notably, our review of these facilities shows that several of them do not have planned cleanup completion dates and for those with cleanup completion dates, cleanup is scheduled to be completed between 1 and 6 decades in the future. Table 2 shows the dates for when the 18 contaminated excess facilities transitioned into S&M mode and how long RL will need to continue S&M activities until cleanup is completed.

As S&M of Hanford’s contaminated excess facilities is expected to continue for many decades, conducting an effective S&M program is essential to minimize the risks of potential releases of contamination that could harm the environment or human health before cleanup is completed. Notably, RL has not established final cleanup dates for several of the 18 contaminated excess facilities included in our review. DOE, however, has not conducted independent reviews of S&M oversight activity necessary to determine whether weaknesses exist in RL’s management and oversight of the Hanford Site contractor’s S&M activities for these facilities. Without prioritizing and conducting periodic assessments or audits focused on RL’s management and oversight of the Hanford Site contractor’s S&M activities for contaminated excess facilities, DOE does not have assurance that RL is overseeing S&M activity in a way that ensures contaminated excess facilities are being inspected and maintained in a safe and compliant condition pending final cleanup.

DOE Seeks to Balance Risks with Other Factors to Establish Hanford Site Cleanup Priorities

RL seeks to balance risks with other factors, such as legally enforceable milestones, available budget, and stakeholder interests, to prioritize cleanup activities that support achieving its overarching Hanford Site cleanup goals, according to RL officials and planning documents. While EM has overall responsibility for managing DOE’s cleanup program, including deactivation and demolition of excess facilities, it has delegated prioritization of cleanup activities to the sites through the annual budget process. As part of the process, EM requests sites develop and submit a site-specific Integrated Priority List to EM management. The Integrated Priority List is based on a number of site-specific factors, including regulatory commitments, agreements with EPA and states, and risks to worker safety and the environment. According to RL officials, EM does not provide specific written guidance for the sites to follow in developing their priority lists, other than a list of seven general factors. RL officials told us that more specific guidance is not necessary because site management needs the flexibility in setting and adjusting cleanup priorities to reflect changes in site conditions and other evolving circumstances as they arise.

Since 2017, RL and the Hanford cleanup contractor have been using a new site-wide risk-informed tool, known as the Project Evaluation Matrix, to help inform decisions on which cleanup priorities to include in the Integrated Priority List. The matrix is used to produce a prioritized listing of the stabilization, waste removal, and other activities that need to be completed as part of the deactivation and decommissioning of the contaminated excess facilities and their associated buildings, structures, and waste sites. RL and cleanup contractor officials described the matrix as a broad, overarching tool to aid in establishing a qualitative basis by which they can determine and agree on cleanup priorities that are planned to be executed within the next 1 to 5 years. Neither the Washington State Department of Ecology nor the Environmental Protection Agency is directly involved in the development of the rankings in the matrix.

The contractor’s guidance document explains that the risk evaluation process used to develop the matrix rankings involves a number of steps. It starts with the data collection phase, during which RL and the contractor collect information on site conditions from a variety of sources, such as historical records, safety assessments, subject matter experts, and S&M activities. This information is then used to develop relative ranking scores for the various cleanup and S&M activities using weighted scores for three criteria: (1) risk reduction; (2) mortgage reduction/cost avoidance; and (3) TPA milestones/regulatory drivers. The initial scores also take into consideration other factors such as potential consequences of failure and overall project lifecycle costs. After developing an initial risk ranking of cleanup projects and activities, the contractor works with RL management to evaluate the initial results and make adjustments as necessary to reflect comments, changes in conditions, or new work scope. The risk rankings are then updated and used by RL to inform decisions on which projects to prioritize in its Integrated Priority List budget submission to EM. As funding decisions are made and cleanup work proceeds, risks are reassessed and the process starts again.

RL officials explained that planned cleanup priorities established in the Integrated Priority List can be adjusted as necessary to reflect information learned through S&M activities and changes in site conditions. For example, routine annual S&M inspections at one facility identified concerns with the integrity of the roof. Based on these concerns, a structural analysis was performed by the cleanup contractor, and RL adjusted its priorities for fiscal year 2016 to include replacing the facility’s roof. Similarly, RL may also modify its planned cleanup priorities to reflect changes in site conditions, such as completing cleanup of a facility or taking actions to stabilize a facility pending its final disposition. For example, based on structural evaluations completed after the partial collapse of Tunnel 1 in May 2017, RL elevated interim stabilization of both PUREX tunnels as among its top priorities in fiscal years 2018-2019.

The ability of RL management to establish and adjust cleanup priorities depends on the availability of quality information on site conditions that is reliable, complete, and current. One source of information for this process is annual and routine S&M activities for Hanford’s contaminated excess facilities. These activities, such as facility inspections, structural integrity evaluations, and radiological monitoring, help provide management with updated information on potential changes in site conditions that may lead to an adjustment in previously planned priorities. As discussed above, however, both EM’s 2017 Extent of Condition Review and our review found that parts of certain contaminated excess facilities that may be at risk for structural deterioration—such as the REDOX annexes—are not included in the routine surveillance inspections and have not been inspected within the past 5 years, or longer. We also identified instances where structural integrity evaluations for some facilities, such as for the 216-Z-9 crib and the Plutonium Finishing Plant 241-Z-361 Settling Tank, appear to have relied on outdated information and reached determinations seemingly inconsistent with the contractor’s more recent analyses and conclusions. By conducting comprehensive surveillance inspections of Hanford’s contaminated excess facilities, DOE would have greater assurance that RL and the contractor’s process for identifying cleanup priorities reflects the current status of the potential human health and environmental risks present at such facilities.

Conclusions

At Hanford, RL has made progress in cleaning up approximately 800 excess facilities, and six major plutonium production reactors are now cocooned and waiting final dispositioning. Despite efforts to mitigate risks and cleanup excess facilities, significant vulnerabilities remain at Hanford due to, among other things, the degrading state of hundreds of contaminated excess facilities still requiring cleanup. Given the pivotal role of the S&M program in ensuring that aging and degrading contaminated excess facilities do not collapse or fail to contain radioactive or hazardous material, it is important that this program is functioning effectively and that any weaknesses are addressed in a timely manner.

The partial collapse of PUREX Tunnel 1 was a clear signal that there are flaws in the S&M program at Hanford. By conducting a root cause analysis to determine any programmatic weaknesses that contributed to the causes of the PUREX Tunnel 1 collapse, and taking action to address any identified weaknesses, DOE will have greater assurance that another, similar event will not occur at Hanford. Additionally, the PUREX Tunnel 1 event demonstrates that RL and the cleanup contractor need complete and updated information regarding the condition of aging contaminated excess facilities to determine if facilities should be stabilized to prevent structural failure or prioritized for cleanup. This information can only be acquired by routinely completing comprehensive surveillance inspections, to include, if necessary, engineering evaluations including the use of remote controlled probes. Without directing the contractor to conduct routine and comprehensive inspections to gather crucial information on the condition of contaminated excess facilities, RL cannot ensure that it is meeting all of DOE’s S&M requirements—such as addressing aging degradation and obsolescence of facilities—and preventing other potential events similar to the PUREX tunnel collapse. Furthermore, because DOE headquarters offices have not prioritized and conducted any assessments or audits focused on RL’s oversight of the cleanup contractor’s S&M activities within the past 5 years or since the PUREX Tunnel 1 collapse, they are missing an opportunity to identify and address any Hanford S&M program weaknesses that may have led to the collapse.

Recommendations for Executive Action

We are making the following three recommendations to DOE: The Assistant Secretary of DOE’s Office of Environmental Management should direct RL to conduct a root cause analysis to identify any programmatic causes that may have led to the collapse of PUREX Tunnel 1. (Recommendation 1)

The Assistant Secretary of DOE’s Office of Environmental Management, while ensuring the protection of DOE workers, the public, and the environment, should ensure that RL directs the Hanford Site cleanup contractor to explore using robotic or other means to routinely complete comprehensive surveillance inspections of contaminated excess facilities to identify aging degradation and obsolescence of facilities and take timely action as warranted. (Recommendation 2)

The Secretary of Energy should ensure DOE headquarters offices responsible for the oversight of EM sites’ field offices conduct an assessment of RL’s management and oversight of the Hanford Site contractor’s surveillance and maintenance activity for contaminated excess facilities. Based on the results of this assessment, DOE headquarters offices should consider whether such assessments should be conducted on a periodic basis. (Recommendation 3)

Agency Comments

We provided a draft of this report to the Secretary of the Department of Energy. In its written comments, reproduced in appendix III, DOE agreed with the report’s findings and concurred with our recommendations. In addition, DOE described ongoing and planned actions to address our recommendations by December 31, 2020.

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If you or your staff members have any questions about this report, please contact me at (202) 512-3841 or trimbled@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix IV.

Appendix I: Objectives, Scope, and Methodology

This report reviews issues related to the cleanup, inspection and maintenance of Hanford’s contaminated excess facilities, such as the Plutonium Uranium Extraction Plant (PUREX), and how the Department of Energy (DOE) and the Richland Operations Office (RL) prioritizes and schedules cleanup and ensures that the Hanford Site contractor inspects and maintains these facilities. The objectives of our review were to (1) examine actions DOE has taken to evaluate the causes of the PUREX Tunnel Collapse, 2) examine the extent to which DOE ensures that the contractor’s surveillance and maintenance of Hanford’s contaminated excess facilities meet DOE requirements, and (3) describe how DOE determines the priority ranking and schedule for cleanup of Hanford’s excess facilities.

To examine actions DOE has taken to address the PUREX Tunnel Collapse and the extent to which DOE ensures that the contractor’s surveillance and maintenance (S&M) of Hanford’s contaminated excess facilities meets DOE requirements, we reviewed DOE orders, policies, RL procedures, and documents that describe DOE’s S&M requirements. We also obtained and reviewed DOE evaluation reports and assessments of S&M activities and operations at Hanford facilities; these include the Office of Environmental Management’s (EM) 2017 Extent of Condition Review for Excess Facilities and historic S&M assessment reports on PUREX tunnel structural stability.

To describe how DOE determines the priority ranking and schedule for Hanford cleanup work of Hanford’s contaminated excess facilities, we reviewed federal environmental regulations, legal agreements, planning documents from DOE and the Hanford cleanup contractor, DOE directives and guidance, and reports by the Consortium for Risk Evaluation with Stakeholder Participation and others on ways to consider risk in making cleanup decisions. These include, but are not limited to, the Tri-Party Agreement (TPA) and associated Action Plan; EM’s Fiscal Year 2020 budget request; RL’s 2015 Vision and 2020Vision, which include high-level cleanup priorities and goals; the Hanford cleanup contractor’s Project Evaluation Matrix and its associated guideline; and RL’s Integrated Priority List.

For all objectives, we also interviewed DOE officials with RL, the DOE Office of Inspector General at Hanford, and DOE headquarters offices, including the Office of Enterprise Assessments and EM’s Office of Safety, Security, and Quality Assurance. In addition, we interviewed Hanford cleanup contractors, officials from the Washington State Department of Ecology, and officials from the Defense Nuclear Facilities Safety Board.

Due to the large number of Hanford contaminated excess facilities requiring cleanup (approximately 800), we focused our review on 18 contaminated excess facilities. These contaminated excess facilities represent the majority of the excess facilities cleanup effort and include some of the most challenging of the non-tank waste cleanup efforts remaining at Hanford, according to DOE officials. We chose key excess contaminated facilities as identified in the TPA because, among other things, DOE and its regulators identify these facilities in Section 8 of the agreement as presenting sufficient potential environmental concern that coordination of the decommissioning process with cleanup activities under the agreement was deemed necessary. We also selected the five other contaminated excess facilities because DOE identified them as having 1) high risks to the environment, workers, and public safety, 2) high annual S&M costs, and 3) high disposition costs. See Table 1 in the report for summary descriptions of each facility we selected.

To gather information about RL’s planning on S&M activities at Hanford and estimated costs for fiscal year 2019, we administered a questionnaire to RL facility representatives responsible for overseeing the cleanup contractor’s implementation of S&M for contaminated excess facilities. For each facility, the representatives were asked whether there was an S&M plan for the facility, when it was developed, and when it was most recently updated. We also asked about the type and frequencies of facility inspections, whether the facility included areas where structural integrity was a concern, if any structural integrity evaluations had been conducted, and whether any significance corrective or preventative maintenance had been performed. We also asked them to explain the facility representative’s role in overseeing that the contractor was conducting S&M activities in accordance with the applicable plan and DOE requirements. A copy of the complete questionnaire is included in appendix II.

We conducted two pretests of the questionnaire with RL officials in November and December 2018, and we revised it in response to their comments. During this process, we sought to ensure that (1) the questionnaire questions were clear and unambiguous, (2) terminology was used correctly, (3) the questionnaire did not place an undue burden on respondents, and (4) respondents had sufficient information to answer the questions.

For the questionnaire we identified an initial set of 21 contaminated excess facilities based on the following criteria: (1) whether they were a key facility identified by DOE and its regulators in Section 8 of the Tri- Party Agreement Action Plan and (2) whether we considered them to be a contaminated excess facility that poses high risks to the environment, workers, and public safety; (3) whether it has potentially high annual surveillance and maintenance costs; and (4) whether it has high final disposition costs based on information we gathered from DOE. After further correspondence with RL officials, we agreed that three of the contaminated excess facilities on our list could be deleted because they were not in S&M mode, as cleanup was completed for one facility, one was undergoing active cleanup, and the other was in operational status. We sent the questionnaire by email in a password-protected Word document to which respondents could return electronically after marking checkboxes or entering responses into open-answer boxes. We sent the questionnaire with a cover letter to DOE officials on January 10, 2019, with a request to complete and return it by January 31, 2019. By February 25, 2019, we received completed questionnaires for each of the 18 selected contaminated excess facilities.

In addition, to provide further context for all objectives, we conducted in- depth reviews regarding S&M of selected Hanford facilities. For these reviews, we selected four high-risk facilities: PUREX, REDOX, the 224B Concentration Facility, and the 216–Z-9 Crib. We used a judgmental (non-probability) sample to select four contaminated excess facilities for in-depth review. These facilities have been identified by DOE, the DOE Office of Inspector General, or the Consortium for Risk Evaluation with Stakeholder Participation as contaminated excess facilities with concerns regarding high risks to the environment, workers, and public safety and risk of potential release of radioactive material and other hazardous materials due to aging degradation and weakening structural integrity. In addition, these contaminated excess facilities are moderate- to high-risk priority facilities for cleanup, according to the contractor’s June 2018 Project Evaluation Matrix, but not scheduled to start cleanup for at least 5 years. For these reviews, we examined DOE documents, including inspection records dating back to the start of fiscal year 2008 through the end of fiscal year 2018 to determine if inspections were occurring, and interviewed RL officials.

We conducted this performance audit from March 2018 to January 2020 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Questionnaire

Appendix III: Comments from the Department of Energy

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, Ned Woodward, Assistant Director; Tara Congdon; Justin Fisher; Richard Johnson; Michael Meleady; Peter Ruedel; Sara Sullivan; and Roxanne Sun made key contributions to this report.