Nuclear Waste: DOE's Efforts to Protect the Columbia River from Contamination Could Be Further Strengthened
Released: 2006-09-05T00:00:00

Letter

Background

Contamination from the Hanford site that may threaten the Columbia River includes (1) contamination that resulted from disposal activities during the era in which DOE produced nuclear material; (2) contamination that could occur during cleanup activities, such as from an accidental spill; and (3) possible future migration of contamination from waste that will be permanently disposed of on the Hanford site in accordance with the cleanup actions DOE and the regulators plan to use.

Contamination from production era. Contamination at Hanford resulting from plutonium production (which occurred from 1943 to 1989) that is currently migrating to the river is primarily from: Intentional disposal of liquid waste and contaminated water into the ground (about 450 billion gallons).

Leaks into the soil from waste tanks and the pipelines that connect them (between 500,000 to 1 million gallons containing about 1,000,000 curies of radioactivity).

Contamination that has begun to migrate from solid waste (more than 710,000 cubic meters) disposed of on-site in burial grounds, pits, and other facilities.

Chemical and radioactive contamination currently affects more than 180 of the 586 square miles of the site’s groundwater and large areas of the vadose zone. While there are numerous contaminants now in the vadose zone and the groundwater below, DOE believes the key contaminants in the groundwater include hazardous chemicals (such as carbon tetrachloride, chromium, nitrate, and trichloroethane) and radioactive materials (such as iodine-129, strontium-90, technetium-99, tritium, and uranium). These contaminants are of concern because of their extent, their mobility in the groundwater, and the potential health risks associated with them—at sufficient levels, some of these contaminants are toxic to humans or fish, while others are potential carcinogens.

Potential contamination from current activities. Current cleanup efforts at the Hanford site could contribute to contamination of the vadose zone and groundwater that eventually reaches the river. For example, some of the waste put into underground storage tanks as liquid has since turned into sludge or saltcake. To dissolve it, more water will have to be introduced into the tanks—including tanks known to have leaked. This process may cause additional discharges into the soil.

Possible future contamination. Under DOE’s cleanup plans, and with regulator approval, a large amount of contaminants will remain on-site long into the future. This contamination may be in buildings, in mostly empty underground tanks, in covered burial grounds and waste disposal areas, and in approved disposal facilities. Contaminants may leach out of these facilities in the future and join existing contamination in the vadose zone and migrate to the groundwater, where they could migrate to the river.

Based on groundwater sampling results, DOE reports that plumes of contamination continue to move through the vadose zone and the groundwater, and are leaching into the river. DOE estimates that about 80 square miles of groundwater under the site contains contaminants at, or above, federal drinking water standards. Because the groundwater and the river are at the same relative elevation, these plumes are leaching directly into about 10 of the nearly 50 miles of river shore on the site.

DOE’s Office of Groundwater and Soil Remediation under the Assistant Secretary for Environmental Management sets overall policy and oversight for groundwater and soil remediation. At the Hanford site, both the Richland Operations Office and the Office of River Protection, as well as several contractors, are involved in groundwater and vadose zone activities. The monitoring of river and shoreline conditions, and groundwater sampling, is managed by the Pacific Northwest National Laboratory (PNNL). Analysis of the samples is performed by several approved laboratories. Funding for groundwater and vadose zone activities at the site is difficult to identify due to the large number of organizations and activities involved and the structure of DOE’s budget accounts. However, monitoring, characterization, well drilling and maintenance, remediation, and research activities received nearly $175 million in fiscal year 2006.

DOE is Taking Steps to Better Understand Risks to the Columbia River from Hanford and Is Replacing Ineffective Technologies near the River

DOE is taking steps to better understand the risk to the Columbia River from Hanford site contamination and to replace ineffective cleanup technologies. Specifically, DOE is addressing problems with three main aspects of its Columbia River protection efforts. First, DOE and its regulators have agreed that additional investigation of contamination in the vadose zone is needed, although doing so could delay by about 3 years the date by which DOE will propose its cleanup plans to the regulators. Second, DOE is reworking its approach to modeling the future effects of contamination on river conditions. DOE abandoned past modeling efforts in response to criticism that the models used inconsistent assumptions, were based on data of questionable reliability, and had weak quality control processes. Third, in response to concerns about the effectiveness of some of the technologies DOE had deployed to remove or contain contamination near the river, and with specific direction from Congress, DOE is evaluating alternative technologies that may be more effective at addressing the contamination.

DOE Has Asked to Extend Regulatory Milestones to Better Understand the Extent and Location of the Contamination in Soil above the Groundwater

While DOE has extensive knowledge of the contaminants in the river and groundwater, and the movement of contaminants in the groundwater and on or near the surface, DOE has only recently developed limited information about the extent and location of the contamination that has migrated from the surface areas into the vadose zone above the groundwater. Understanding the nature of vadose zone contamination is critical to determining the most appropriate steps to take to protect the river now, and in future years, because contaminants still in the soil may continue to migrate until they eventually reach the groundwater and the river. DOE has studied some portions of the vadose zone, such as around the underground storage tanks, where extensive contamination from leaks and spills occurred in the past. In doing so, DOE found that some contamination, including technetium-99, had migrated as far as the groundwater. DOE contractors were able to map the migration of some of these contaminants. However, DOE acknowledges that its understanding of contaminants in the vadose zone is limited in many areas of the site. For example, cribs and trenches near the underground tanks received large volumes of contaminated wastes that dispersed directly to the ground. DOE has little information on the extent and location of the contamination in those areas, according to DOE officials responsible for planning their cleanup. They also said that characterization of the lower portions of the vadose zone is difficult and expensive, and few remediation techniques have been developed or tested for removing or isolating wastes that are located deep in the vadose zone.

Understanding the extent of vadose zone contamination is critical because some contaminants still in the soil may continue to migrate until they eventually reach the groundwater and the river. Thus, understanding the type and volume of contaminants in the vadose zone and their rate of migration is essential to determining the most appropriate steps to take to protect the river now, and in future years.

After finding unexpected contaminant migration in the vadose zone at one waste disposal area known as BC cribs—a location where liquids were discharged directly into the ground—DOE agreed with its regulators that its understanding of the vadose zone was inadequate to support the development of a final cleanup remedy for that area and some others. Although DOE had originally planned to defer some of its study of the vadose zone until after December 2008, when draft cleanup plans were due, DOE now agrees that more sampling and analysis of the vadose zone is needed to guide cleanup decisions. As a result, DOE has proposed to regulators to extend the date for submitting draft cleanup plans until 2011. DOE officials said this will allow the time needed to develop a better understanding of vadose zone conditions and to investigate potential remedies.

DOE Is Reworking Efforts to Estimate Risks from the Movement of Contamination toward the River

In response to the discovery that its previous models to estimate the future risks of the movement of contamination toward the river were based on data of questionable reliability, DOE has begun reworking these efforts. While DOE relies on sampling to determine current conditions, it uses computer simulation models to predict future conditions and estimate future risks. In 1998, DOE groundwater program officials said DOE concluded from its simulation models that the migration was slow enough that the contaminants included in the study would not exceed their limits for 1,000 years into the future. However, DOE was concerned about the completeness of the model and began an effort, known as the System Assessment Capability, to develop a more comprehensive model. This $16 million, 8-year effort was cancelled when, in the course of a lawsuit over Hanford’s disposal plans, several quality assurance problems were found, including discrepancies in the data. DOE abandoned the past modeling efforts in response to criticisms that the models used inconsistent assumptions, were based on data of questionable reliability, and had weak quality control processes. In January 2006, DOE and Washington State settled the lawsuit. In the settlement agreement, DOE agreed to re-analyze and update its study of the cleanup’s effect on groundwater. In addition, DOE agreed to consolidate two studies of the cleanup’s effects on groundwater into a single, integrated study.

DOE Is Considering New Treatment Technologies to Replace Those That Have Not Kept Contamination from Entering the River

Both DOE and its regulators have determined that the results of all three of DOE’s approaches to treating groundwater—pump-and-treat, chemical treatment, and natural attenuation—are not fully satisfactory. Specifically: Pump-and-treat. In a 2004 report, the DOE Inspector General concluded that the pump-and-treat system to remove strontium-90 was ineffective and that the other four pump-and-treat systems have had mixed results.

However, Hanford’s acting groundwater project manager told us that four of the five pump-and-treat systems at the Hanford site meet the remedial objectives agreed to with Hanford’s regulators. The official acknowledged that the system to remove strontium-90 was largely ineffective and that DOE had been trying to obtain permission from the regulators to turn it off. Both DOE and the regulators told us that the regulators refused to allow the system to be turned off, however, until a more effective remedy was found. In March 2006, after spending about $16 million since 1996 to install and operate the system, DOE turned the system off with the regulators’ permission, and began testing a chemical barrier to prevent the strontium-90 from entering the river.

Chemical treatment. In 2004, DOE reported that, based on groundwater samples, the chemical barrier for chromium was not fully effective, and that the hazardous form of chromium was detected beyond the barrier and close to the river. DOE is currently testing alternative approaches to improve the barrier.

Natural attenuation. According to monitoring well data, DOE’s reliance on natural attenuation to dissipate a uranium plume near the city of Richland was ineffective and has not controlled the migration of uranium to the river. The plume has not dissipated in the 10-year period since the natural attenuation strategy was adopted. DOE is currently investigating the plume, testing chemical barriers, and exploring other ways to mitigate the problem.

In the conference report accompanying the fiscal year 2006 Energy and Water Development Appropriations Act, the conferees directed DOE to make $10 million available to analyze and identify new technologies to address contaminant migration to the Columbia River. DOE convened a study group to identify potential technologies and determine how best to allocate the funds to support them. According to DOE’s groundwater project manager, if the technologies tested are successful, DOE will seek funds to expand the systems to fully address these problems. DOE is testing the following: To address problems with pump-and-treat systems, DOE is testing new approaches to containing strontium-90 and chromium. To contain the strontium, DOE is testing two techniques: (1) using a chemical to bind the strontium to the soil until it decays, which would prevent it from leaching into the river; and (2) planting willow bushes near shore to capture the strontium in the plants, which can be harvested to dispose of the strontium. For chromium removal, DOE has adopted a “systems approach” which includes combining source removal, pump-and-treat system expansion, and barrier repairs according to DOE’s groundwater project manager. DOE is also planning to test an improvement to the pump-and- treat system. The test system will use an electric field to remove the chromium from the groundwater extracted by several of the existing wells. If it succeeds, DOE’s project manager said, they will expand the pump- and-treat system to include this technology.

To address problems with the chromium barrier near the river, DOE plans to inject chemicals through the wells used to create the barrier to help convert the chromium to a less toxic and less mobile form.

To address problems with using natural attenuation to dissipate the uranium plume near the city of Richland, DOE is testing whether injecting a chemical called polyphosphate can help prevent the uranium from migrating to the river.

In addition to these activities, DOE plans to research methods to better understand the existing carbon tetrachloride plume in the center of the site.

DOE Has Begun To Address Management Weaknesses but Can Further Strengthen Its Management Plan

DOE has begun to address management problems with its Columbia River protection efforts at the Hanford site by proposing management improvements to better oversee and coordinate its groundwater and vadose zone activities. Although those steps are important and needed, we are concerned about DOE’s ability to sustain any improvements made. Similar efforts in the past failed. In our previous work, we reported that leading organizations use a systematic, results-oriented plan to sustain management improvement initiatives. Such a plan incorporates key elements, such as clear goals, performance measures to gauge progress toward those goals, and an evaluation strategy to help ensure the initiative is effective. Although DOE is beginning to develop a plan for its new integration initiative, it has yet to implement key elements, such as performance measures or an evaluation strategy. These tools could help measure effectiveness and sustain the benefits of the initiative over time.

DOE Is Taking Steps to Improve River Protection Management and Oversight

DOE is beginning to address longstanding concerns about the management and oversight of its Columbia River protection efforts at the Hanford site. In November 2005, we reported that DOE’s river protection efforts continued to be fragmented among two DOE site operations offices and several site contractors. We raised concerns that the potential existed for duplication, gaps, and inefficiencies. Subsequently, in the November 2005 conference report accompanying the Fiscal Year 2006 Energy and Water Development Appropriations Act, the conference committee cited these continuing management and organization problems and directed DOE to study how to better integrate its river protection efforts. In response to the congressional direction, in March 2006, DOE’s Assistant Secretary for Environmental Management developed a new plan to better integrate Hanford’s river protection, vadose zone, and groundwater efforts. Specifically, DOE’s new integration initiative would: Consolidate most groundwater and vadose zone characterization and cleanup activities under a single project. At the time of the congressional direction, two DOE offices and three main contractors on- site were collectively responsible for characterizing and cleaning up vadose zone and groundwater contamination. The Office of River Protection and its contractor, CH2M Hill Hanford Group, were responsible for characterizing and addressing contamination of the vadose zone in tank farms—areas where tanks containing radioactive liquid waste are buried. The Richland Operations Office and its contractors, Fluor Hanford and Washington Closure Hanford, were responsible for vadose zone characterization in the central plateau area of the site and along the river corridor, respectively. In addition, Fluor Hanford was responsible for groundwater activities in all areas of the site. Within Fluor Hanford, responsibility for cleanup of the groundwater and vadose zone was divided between two different projects with the project handling vadose zone issues also responsible for addressing removal of old buildings and burial grounds.

To better coordinate vadose zone and groundwater characterization and cleanup activities, DOE’s new integration initiative proposed consolidating most of this work under a single project managed and coordinated by Fluor Hanford. To do so, DOE planned to modify existing contracts with the affected contractors to reflect this reorganization. In June 2006, the Office of River Protection and the Richland Operations Office issued a Plan of Action for Hanford Groundwater and Vadose Zone Integration Improvements. It identified general activities and areas of responsibility that the Fluor Hanford and CH2M Hill Hanford Group contractors would be responsible for under the new initiative. As of the end of July 2006, DOE was negotiating the details of this reorganization of responsibilities with the contractors and anticipated having the contracts modified to reflect the changes by October 1, 2006.

Better integrate vadose zone, groundwater, and waste disposal site cleanup decisions. DOE acknowledged that decisions about when and how to address vadose zone and groundwater contamination were not always well coordinated, and they generally were not coordinated with decisions about when and how to address the source contamination in a waste disposal site located above the vadose zone and groundwater. For example, initial plans for cleanup decisions of the surface areas in the Central Plateau were not necessarily linked to the plans for the underlying groundwater units, according to DOE’s groundwater project manager.

To better integrate vadose zone, groundwater, and waste disposal site cleanup decisions, DOE proposed to implement a new strategy by the end of fiscal year 2006 and to work with regulators to better align regulatory milestone dates for making cleanup decisions about waste sites, the vadose zone, and the groundwater. DOE’s new strategy includes plans to transfer most vadose zone characterization activities into the groundwater program.

Consolidate responsibility for modeling the movement of contaminants through the vadose zone and groundwater to estimate the potential current and future health risks. DOE has acknowledged that inconsistencies and reliability problems existed in the modeling of how contaminants move through the vadose zone and groundwater, and how the environmental risks associated with those contaminants were estimated. A DOE team reviewing the data quality issues and the modeling effort found that, in addition to issues of the reliability of data used in the models, various modeling efforts under way were based on different assumptions, and information about contamination movement was not always correctly transferred to other models.

To address these problems, DOE proposed to more closely coordinate modeling and risk assessment activities at the site and strengthen control over model design so that a common set of databases and assumptions were being used for decision making. The groundwater project would have configuration control over any models used so that any changes to databases and models assumptions would require approval by the groundwater project before users could implement them.

In addition to these management improvement efforts at the Hanford site, in May 2006, DOE also established a new Office of Groundwater and Soil Remediation to improve headquarters’ oversight on issues dealing with soil and groundwater contamination across the DOE complex. The office is tasked with reviewing all soil and groundwater remedies at DOE sites, helping to develop technologies to solve groundwater and soil contamination problems at different DOE sites, and generally overseeing DOE policy and assessments regarding vadose zone and groundwater cleanup.

DOE Has Not Fully Implemented a Management Plan to Ensure Improvements Will Be Sustained

Given past problems fully implementing and sustaining improvements to the management of DOE’s Columbia River protection efforts at the Hanford site, it is uncertain whether any improvements that result from DOE’s new integration initiative will be sustained. In 1998, we reported that DOE lacked a comprehensive and integrated groundwater and vadose zone program, and recommended that DOE implement an integrated strategy that defined measurable performance goals, clearly defined leadership roles, and established accountability for meeting those goals.

In response to our 1998 report, DOE proposed an integrated management plan to coordinate groundwater and vadose zone work. To accomplish this, DOE assigned a single DOE Assistant Manager in the Richland Operations Office to coordinate all groundwater and vadose zone work at the Hanford site. Because DOE’s other site office, the Office of River Protection, and several contractors at the site also carried out groundwater and vadose zone cleanup, DOE made the Assistant Manager responsible for ensuring that all groundwater and vadose zone activities were integrated into a single planning effort. This “Integration Project” included developing a sitewide approach to project planning, funding, and information management, and co-locating contractor staff working on the project to improve coordination. In addition, the project included improving coordination of efforts to develop science and technology to address contamination in the vadose zone and groundwater.

Despite these proposed changes, DOE was unable to effectively implement the improvements it planned to make. For example, according to a site official at Hanford who oversaw the initial integration effort, DOE did not implement key elements of the plan, such as establishing a sitewide funding profile for all groundwater and vadose zone activities. DOE implemented other elements of the plan but did not sustain them when changes, such as how projects were organized and contracts were structured, occurred at the site. For example, coordinating all activities through a single federal project manager faltered as site offices were reorganized and responsibilities were distributed among three federal project directors. The DOE official from the Hanford groundwater program attributes the lack of coordination of groundwater and vadose zone efforts to redefining project activities, which resulted in groundwater and vadose zone activities being managed as separate projects and changes in the structure of site contracts, which resulted in scopes of work being organized and assigned differently. A 2001 National Academy of Sciences review of DOE’s groundwater science and technology activities noted that DOE’s integration efforts had been superimposed over several already existing cleanup projects without establishing a clear line of responsibility for results. The National Academy said that this left the program operating in an unstable environment.

To increase the chances of success for DOE’s current improvement initiative, we assessed DOE’s management of its new integration initiative against model practices used by organizations that successfully sustained improvement initiatives. We previously reported that in high-performing organizations, management improvement initiatives are sustained by using a systematic, results-oriented plan that incorporates a rigorous measurement of progress. Such a plan typically included the following steps: (1) defining clear program goals for the initiative—important because it focuses an organization’s efforts on achieving specific outcomes and allows as assessment of future performance against those goals; (2) developing an implementation strategy that sets milestones and establishes individual responsibilities—important because it establishes accountability for achieving the initiative’s goals; (3) establishing results- oriented performance measures—important because it allows organizations to measure progress toward achieving their goals; and (4) using results-oriented data to evaluate the effectiveness of the initiative and make additional changes where warranted—important because periodic evaluations can reveal systemic problems and promote continuous program improvement over the long term.

As of July 2006, DOE had implemented two components and not implemented other management components to help ensure that it could sustain any improvements resulting from its new integration initiative. For example, in putting forward its plan to Congress, DOE described a general goal of its new integration initiative as better coordination of Hanford’s groundwater and vadose zone cleanup activities in order to achieve greater protection of the Columbia River. DOE also outlined steps it would take toward its goal, such as (1) consolidating site modeling and risk assessments; (2) consolidating river protection efforts under a single project; and (3) integrating soil and groundwater cleanup decisions. In going forward, DOE could further refine its goals to include measurable steps to achieving its overall goal of protecting the river. For example, a more measurable goal would be the reduction of contamination reaching the river or ensuring duplication of efforts is reduced in order to better protect the Columbia River.

DOE had established general milestones and individual responsibilities for implementing its new integration initiative. For example, DOE’s plan of action sets 16 milestones by September 2006 by which various initial steps are to be taken. DOE also reported that five of these actions, including making staff assignments and establishing an integrated project team, had been completed.

DOE has not established results-oriented measures to gauge the progress of its integrated management initiative. In outlining the steps it will take under its plan, DOE has generally concentrated on establishing relationships and moving work-scope between various DOE offices and contractors, and not on outcomes, such as reducing redundancies or gaps in river protection efforts. Without clear results-oriented performance measures to gauge progress, problems that occur under a fragmented management structure could be masked and allowed to continue under DOE’s integration plan. Translating the general goal of “better integration” and “protection of the river” into a more specific goal, such as reducing duplicative efforts, would help DOE identify ways it could measure results and, therefore, gauge progress toward the goals of its integration initiative.

Finally, DOE has not yet identified an evaluation strategy to determine whether the steps it is taking are effective and are being sustained. Without an evaluation strategy based on clear goals and results-oriented measures, DOE will not have the results-oriented data necessary to objectively evaluate progress and implement corrective actions as needed.

Although DOE is still working to define and implement its integration initiative, fully developing and putting in place key elements outlined above could help ensure that any program improvements are sustained in the future. DOE’s Hanford Assistant Manager in charge of overseeing the latest management improvements for the river protection program said that, beyond outlining broad goals and setting the framework for roles and responsibilities, DOE had not yet fully developed a project execution plan for the new initiative. He said that the management plan is still evolving and that future steps may include more clearly defining performance measures and strategies for evaluating the initiative’s effectiveness.

Conclusions

DOE is involved in a lengthy process to identify and address potential threats to the Columbia River from contamination in the soil and groundwater at the Hanford site. This requires a good understanding of the risks to the river and an effective management strategy for addressing those risks. Over the years, we and others have raised concerns about DOE’s efforts to understand the nature and extent of the contamination and how best to manage the efforts to prevent contamination from seeping into the river. In recent months, DOE has taken several steps to gain a better understanding of the risks from the contamination as well as to improve its management of the program and integration of activities. While these steps are encouraging, DOE has not yet decided whether to put in place elements of a management plan that could help ensure potential benefits of these improvements will be continued, even when organizational and contract changes occur at the site. Such a management plan should include developing results-oriented performance measures, using the measures to determine progress toward objectives, and making changes as necessary.

Recommendation for Executive Action

To increase the likelihood that DOE will effectively implement and sustain improvements in its program to protect the Columbia River from contamination at the Hanford site, we recommend that the Secretary of Energy strengthen the management improvement plan by establishing results-oriented performance measures and regular evaluations to gauge the program’s effectiveness.

Agency Comments and Our Evaluation

We provided a draft of this report to DOE for its review and comment. In a letter from DOE’s Principal Deputy Assistant Secretary for Environmental Management, DOE agreed with the report’s findings and fully endorsed the recommendation to adopt results-oriented performance measures and regular evaluations of the river protection program. DOE acknowledged that performance measures and regular evaluations are a fundamental and integral component of sound project management practice and said that it would incorporate them into the project. The full text of DOE’s comments is presented in appendix II.

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If you or your staff have any questions on this report, please contact me at (202) 512-3841 or by e-mail at aloisee@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Other staff contributing to this report are listed in appendix III.

Appendix I: Scope and Methodology

To understand the risk to the Columbia River from Hanford site contamination, we reviewed risk assessments, groundwater, vadose zone, and river monitoring reports by the Department of Energy (DOE), DOE’s Office of Inspector General, DOE contractors including the Pacific Northwest National Laboratory, and various outside groups such as the National Academy of Sciences. We interviewed DOE officials at both headquarters and the Hanford site, as well as contractor staff at Hanford, to obtain information on the distribution of contamination at Hanford and the steps being taken to better understand it. To understand DOE’s approach to the vadose zone, we primarily reviewed our 1998 report, as well as documents prepared by DOE and its staff in response to that report. We also reviewed documents DOE submitted to regulators related to changing Tri-Party Agreement milestones; the documents were to be used for preparing initial drafts of plans for all remaining contaminated areas. We discussed the proposed change to the December 2008 Tri-Party Agreement milestone with DOE officials and regulators. In reviewing DOE’s efforts to determine the extent of risk of future damage to the river from contamination, we reviewed documents related to DOE’s sitewide modeling effort and legal documents related to this modeling effort. We discussed these modeling efforts with DOE officials, contractors, and regulators.

In assessing DOE’s efforts to deploy effective technologies to address contamination near the river, we visited the sites of existing and planned cleanup efforts. We discussed current existing projects with DOE officials, contractor staff, regulators, and stakeholders, and reviewed reports prepared for DOE and others. To assess technology plans developed by DOE to use $10 million of funds earmarked for fiscal year 2006, we attended DOE screening panels, reviewed reports prepared by DOE and others, and discussed the efforts with DOE regulators.

To review DOE efforts to strengthen the management of its river protection efforts, we reviewed DOE’s past and current management plans. We obtained DOE’s recent integration initiative proposals, including its proposal to Congress in March 2006 and its subsequent Memorandum of Agreement and Plan of Action. We discussed DOE’s approach with headquarters and site officials. We reviewed previous work in which we documented strategies used by high-performing organizations to implement improvement initiatives. We reviewed DOE’s proposed integration initiative and compared it to key elements of these strategies. We also discussed DOE’s plans to implement its strategy with knowledgeable site officials.

In reviewing the management of DOE programs related to groundwater and river protection, we reviewed DOE efforts to assure that contamination levels were accurately reported; we also interviewed regulators, DOE officials, and contractors regarding data reliability. While we did not independently test the contaminant data, we reviewed controls over how the data were obtained and tested, visited sampling locations and discussed sampling methods with key staff, and reviewed other relevant information to determine that the data were sufficiently reliable for the purposes of our report. We conducted our work from December 2005 to August 2006 in accordance with generally accepted government auditing standards.

Appendix II: Comments from the Department of Energy

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, Bill Swick, Assistant Director; Chris Abraham; Doreen Feldman; Nancy Kintner-Meyer; Jeffrey Larson; Omari Norman; Alison O’Neill; Thomas Perry; and Stan Stenersen made significant contributions to this report. Others who made important contributions included Mark Braza, Doreen Eng, and Mehrzad Nadji.