oversight

Nuclear Waste: Challenges and Savings Opportunities in DOE's High-Level Waste Cleanup Program

Published by the Government Accountability Office on 2003-07-17.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                             United States General Accounting Office

GAO                          Testimony
                             Before the Subcommittee on Oversight
                             and Investigations, Committee on Energy
                             and Commerce, House of Representatives

For Release on Delivery
Expected at 9:30 a.m. EDT,
Thursday, July 17, 2003      NUCLEAR WASTE
                             Challenges and Savings
                             Opportunities in DOE's
                             High-Level Waste Cleanup
                             Program
                             Statement of Robin M. Nazzaro, Director
                             Natural Resources and Environment




GAO-03-930T
                                              July 17, 2003


                                              NUCLEAR WASTE

                                              Challenges and Savings Opportunities in
Highlights of GAO-03-930T, a testimony
before the Subcommittee on Oversight
                                              DOE’s High-Level Waste Cleanup
and Investigations, Committee on Energy
and Commerce, House of Representatives
                                              Program



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

GAO made recommendations in the               DOE is exploring proposals, such as increasing the amount of high-level
report on which this testimony is             waste in each disposal canister, that if successful could save billions
based. In commenting on the                   of dollars more than the current $29 billion estimate. However, considerable
report, DOE agreed to consider
                                              evaluation remains to be done. DOE also has opportunities to improve
seeking clarification from the
Congress about its authority to               program management by fully addressing recurring weaknesses GAO has
decide that waste with low                    identified in DOE’s management of cleanup projects, including the practice
concentrations of radioactivity               of incorporating technology into projects before it is sufficiently tested.
could be treated and disposed of
on-site. DOE disagreed with the               Waste Storage Tanks under Construction at DOE’s Hanford Site, September 1947
need to conduct integrated testing
of the Hanford waste separation
technology and argued that its
existing actions are sufficient to
support decision making with
rigorous analysis, test new
technology before incorporating it
into projects, and pursue
concurrent design/construction of
complex facilities. GAO disagrees
and continues to believe that its
recommendations are warranted.
www.gao.gov/cgi-bin/getrpt?GAO-03-930T

To view the full product, click on the link   Many of the waste storage tanks, such as those above, were built in the 1940s to 1960s. These
above. For more information, contact Robin    tanks, now underground, are used to store high-level waste and have exceeded their design life of
M. Nazzaro at (202) 512-3841 or               10-40 years. Some have leaked waste into the soil.
nazzaror@gao.gov.
Mr. Chairman and Members of the Subcommittee:

We are pleased to be here today to discuss the Department of Energy’s
(DOE) high-level waste cleanup program. DOE has about 94 million
gallons of highly radioactive nuclear waste from the nation’s nuclear
weapons program. This waste is currently in temporary storage at DOE
sites in Washington, South Carolina, and Idaho. After investing more than
20 years and about $18 billion, DOE acknowledged in February 2002 that
the program to clean up its high-level waste was far behind schedule, far
over budget, and in need of major change. In 2002, DOE began an initiative
to reduce the program’s nearly $105-billion estimated cost and 70-year
time frame to finish permanent disposal of this waste. Our testimony,
based on work included in the report being released by the Subcommittee
today,1 discusses (1) the components of DOE’s high-level waste and the
process involved in preparing the waste for disposal, (2) the status of
DOE’s accelerated cleanup initiative for high-level waste, (3) legal and
technical challenges DOE faces in implementing the initiative, and (4)
further opportunities to reduce costs beyond those identified in DOE’s
current cost-savings proposal or to improve program management.

In summary, we found the following:

•   DOE’s high-level waste has many components, ranging from
    radioactive isotopes and corrosive chemicals to the water in which
    much of this material was initially discharged. The radioactive
    components vary greatly; a small portion will remain dangerously
    radioactive for millions of years, while the vast majority will lose much
    of their radioactivity more quickly, so that more than 90 percent of the
    current radioactivity will be gone within 100 years. To prepare the
    waste for permanent disposal, DOE plans to separate the waste into
    two waste streams: one with high levels of radioactivity and the other
    with lower concentrations of radioactivity. DOE expects that this
    process will concentrate at least 90 percent of the radioactivity into a
    volume that is significantly smaller than the current total volume of
    waste. DOE plans to immobilize and bury the highly radioactive portion
    in a permanent underground repository. The remaining waste will be
    immobilized and disposed of at the location where it is currently stored
    or at some other location.


1
 U.S. General Accounting Office, Nuclear Waste: Challenges to Achieving Potential
Savings in DOE’s High-Level Waste Cleanup Program, GAO-03-593 (Washington, D.C.:
June 17, 2003).




Page 1                                        GAO-03-930T High-Level Waste Cleanup
•   DOE’s initiative to accelerate the cleanup is evolving, and while its
    savings estimates are changing accordingly, we have ongoing concerns
    about the reliability of those estimates. As of April 2003, DOE
    estimated it could shorten the waste cleanup schedule by 20-35 years
    and save up to $29 billion. To help achieve these schedule and cost
    reductions, DOE has identified alternative treatment and disposal
    strategies, such as developing ways to permanently dispose of more of
    the radioactive waste at current sites rather than moving it to the
    planned underground repository. However, our assessment of DOE’s
    savings estimate indicates that it may not be reliable. For example, the
    savings analysis does not take into account all costs associated with
    alternative treatment strategies. Also, the estimate of savings does not
    compare costs on the basis of “present value,” where dollars to be
    saved in future years are discounted to a common year to reflect the
    time value of money. At DOE’s Savannah River Site in South Carolina,
    such an adjustment would lower the savings estimate for accelerated
    waste processing by $2.6 billion—from $5.4 billion to $2.8 billion (in
    2003 dollars).

•   DOE faces significant legal and technical challenges to realize the
    estimated savings. A key legal challenge involves DOE’s authority to
    apply a designation other than high-level waste to some waste with
    relatively low concentrations of radioactivity, so that this portion can
    be treated less expensively than highly radioactive waste. A recent
    court ruling invalidated this redesignation process, thus precluding
    DOE from proceeding with this element of its accelerated initiative. If
    DOE cannot meet its accelerated schedules, then potential savings are
    in jeopardy. A key technical challenge is that DOE’s approach relies
    primarily on laboratory testing to confirm that separating waste into
    high-level and low-activity portions will be successful. At the Hanford
    Site in Washington State, DOE is planning to construct full-scale
    facilities before fully testing the technologies on an integrated basis—
    an approach that has failed on another project in the past, resulting in
    significant cost increases and schedule delays.

•   DOE is exploring additional cost savings beyond those identified in its
    current cost-saving proposals. The proposals that offer significant
    potential are being developed by the Hanford and Savannah River sites.
    These proposals call for increasing the amount of waste that can be
    concentrated into the canisters destined for the permanent
    underground repository. DOE’s data indicates that these proposals, if
    successful, could save several billion dollars. Considerable evaluation
    of these proposals remains to be done and cost-saving estimates have



Page 2                                    GAO-03-930T High-Level Waste Cleanup
                not yet been fully developed, according to DOE officials. DOE also has
                opportunities to improve its management of the cleanup program by
                addressing management weaknesses that we and others have identified
                in the past. Although DOE has taken steps to improve program
                management, we have continuing concerns about management
                weaknesses in several areas. These include making key decisions
                without rigorous supporting analysis, incorporating technology into
                projects before it is sufficiently tested, and pursuing a “fast-track”
                approach of launching into facility construction before completing
                sufficient design work. It does not appear that DOE’s current
                management efforts will fully address these weaknesses.

             Our report makes several recommendations to DOE that, if implemented,
             will help to manage or reduce legal and technical risks to the program,
             avoid costly delays, and strengthen overall program management. DOE
             agreed to consider our recommendation to seek clarification from the
             Congress regarding its authority to determine that some waste can be
             treated and disposed of as other than high-level waste. However, regarding
             our recommendations that the department conduct integrated pilot testing
             of its waste separation processes at Hanford, and take steps to improve
             the management of high-level waste projects, such as by conducting more
             rigorous analyses to support key project decisions, DOE believes that its
             current approach is adequate. We do not agree with DOE’s views and
             continue to believe that all of our recommendations are warranted.


             DOE has a vast complex of sites across the nation dedicated to the nuclear
Background   weapons program. DOE largely ceased production of plutonium and
             enriched uranium by 1992, but the waste remains at the sites. Most of the
             tanks in which the waste is stored have already exceeded their design life.
             For example, many of Hanford’s and Savannah River’s tanks were built in
             the 1940s to 1960s and were designed to last 10-40 years. Leaks from some
             of these tanks were first detected at Hanford in 1956 and at Savannah
             River in 1959. Given the age and deteriorating condition of some of the
             tanks, there is concern that some of them will leak additional waste into
             the soil, where it may migrate to the water table and, in the case of the
             Hanford Site, to the Columbia River.

             Responsibility for the high-level waste produced at DOE facilities is
             governed primarily by federal laws, including the Atomic Energy Act of
             1954. These laws established responsibility for the regulatory control of
             radioactive materials including DOE’s high-level waste and assigned the
             Nuclear Regulatory Commission (NRC) the function of licensing facilities



             Page 3                                   GAO-03-930T High-Level Waste Cleanup
                            that are expressly authorized for long-term storage of high-level
                            radioactive waste generated by DOE. In addition, the Nuclear Waste Policy
                            Act of 1982 defined high-level radioactive waste. Various other federal
                            laws, including the Resource Conservation and Recovery Act of 1976,
                            guide how DOE must carry out its cleanup program. The high-level waste
                            cleanup program is under the leadership of the Assistant Secretary for
                            Environmental Management. It involves consultation with a variety of
                            stakeholders, including the Environmental Protection Agency, state
                            environmental agencies where DOE sites are located, county and local
                            governmental agencies, citizen groups, advisory groups, and Native
                            American tribes.

                            The waste in the tanks at the Hanford and Savannah River sites and the
DOE’s High-Level            Idaho National Laboratory near Idaho Falls is a complex mixture of
Waste Is a Complex          radioactive and hazardous components. DOE’s process for preparing it for
                            disposal is designed to separate much of the radioactive material from
Mixture That Requires       other waste components.
a Multi-Step Process
to Prepare for
Disposal

Much of the Radioactivity   Nearly all the radioactivity in the waste originates from radionuclides with
Declines Relatively         half-lives2 of about 30 years or less. The relatively short half-lives of most
Quickly                     of the radionuclides in the waste means that within 30 years, about
                            50 percent of the current radioactivity will have decayed away, and within
                            100 years this figure will rise to more than 90 percent. Figure 1 shows the
                            pattern of decay, using 2002 to 2102 as the 100-year period. Extending the
                            analysis beyond the 100-year period shown in the figure, in 300 years,
                            99.8 percent of the radioactivity will have decayed, leaving 0.2 percent of
                            the current radioactivity remaining.




                            2
                             Each radioactive component, or radionuclide, in high-level waste loses its radioactivity at
                            a rate that differs for each component. This rate of decay, which cannot be changed, is
                            measured in “half-lives”—that is, the length of time required for half of the unstable atoms
                            to decay and release their radiation.




                            Page 4                                             GAO-03-930T High-Level Waste Cleanup
                            Figure 1: Natural Decay of Radionuclides in DOE’s Untreated High-Level Waste
                            from 2002 to 2102




                            Note: Radioactivity is measured in a unit called a curie. One curie equals 37 billion atomic
                            disintegrations per second.


                            Despite the relatively rapid decay of most of the current radioactivity,
                            some radionuclides have half-lives in the hundreds of thousands of years
                            and will remain dangerously radioactive for millions of years. Some of
                            these long-lived radionuclides are potentially very mobile in the
                            environment and therefore must remain permanently isolated. If these
                            highly mobile radionuclides leak out or are released into the environment,
                            they can contaminate the soil and water.


Processing Can              DOE plans to isolate the radioactive components and prepare the waste
Concentrate the             for disposal through a multi-step treatment process. DOE expects this
Radioactivity into a Much   process to concentrate at least 90 percent of the radioactivity into a much
                            smaller volume that can be permanently isolated for at least 10,000 years
Smaller Volume of Waste     in a geologic repository. The portion of the waste not sent to the geologic
                            repository will have relatively small amounts of radioactivity and
                            long-lived radionuclides. Based on current disposal standards used by the
                            NRC, if the radioactivity of this remaining waste is sufficiently low, it
                            can be disposed of on site near the surface of the ground, using less



                            Page 5                                                   GAO-03-930T High-Level Waste Cleanup
                          complex and expensive techniques than those required for the highly
                          radioactive portion. DOE plans to dispose of this waste on site in vaults
                          or canisters, or at other designated disposal facilities.

                          DOE has successfully applied this process in a demonstration project at
                          the West Valley site in New York State. At West Valley, separation of the
                          low-activity portion from the high-level portion of the waste reduced by
                          90 percent the quantity of waste requiring permanent isolation and
                          disposal at a geologic repository. The high-level portion was stabilized in a
                          glass material (vitrified) and remains stored at the site pending completion
                          of the high-level waste geologic repository and resolution of other issues
                          associated with disposal costs.3 The remaining low-activity portion was
                          mixed with cement-forming materials, poured into drums where it
                          solidified into grout (a cement-like material), and remains stored on site,
                          awaiting shipment to an off-site disposal facility.


                          DOE’s new initiative, implemented in 2002, attempts to address the
DOE’s Initiative for      schedule delays and increasing costs DOE has encountered in its efforts to
Accelerating Cleanup      treat and dispose of high-level waste. This initiative is still evolving. As of
                          April 2003, DOE had identified several strategies to help reduce the time
Is Still Evolving, with   needed to treat and dispose of the waste. Based on these strategies, DOE
the Extent of Savings     estimated that it could reduce the waste cleanup schedule by about 20 to
                          35 years at its high-level waste sites and save about $29 billion compared
Uncertain                 to the existing program baseline.4 While some degree of savings is likely if
                          the strategies are successfully implemented, the extent of the savings is
                          still uncertain.




                          3
                           At Savannah River, high-level sludge from the tanks has also been stabilized in glass
                          material and is currently stored on site pending completion of the geologic repository. As
                          of August 30, 2002, Savannah River had produced 1,331 canisters of this stabilized waste.
                          4
                           Unless otherwise noted, all dollar estimates are as reported by DOE and are in
                          current dollars.




                          Page 6                                            GAO-03-930T High-Level Waste Cleanup
Initiative Centers on Ways   Many of DOE’s proposals to speed cleanup and reduce environmental risk
to Speed Disposal and        involve ways to do one or more of the following:
Save Money
                             •   Deal with some tank waste as low-level or transuranic5 waste, rather
                                 than as high-level waste. Doing so would eliminate the need to vitrify
                                 the waste for off-site disposal in the geologic repository for high-level
                                 waste.

                             •   Complete the waste treatment more quickly by using additional or
                                 supplemental technologies. For example, DOE’s Hanford Site is
                                 considering using up to four supplemental technologies, in addition to
                                 vitrification, to process its low-activity waste. DOE believes these
                                 technologies are needed to help it meet a schedule milestone date of
                                 2028 agreed to with regulators to complete waste processing. Without
                                 these technologies, DOE believes waste treatment would not be
                                 completed before 2048.

                             •   Segregate the waste more fully than initially planned and tailor waste
                                 treatment to each of the waste types. By doing so, DOE plans to apply
                                 less costly treatment methods to waste with lower concentrations of
                                 radioactivity.

                             •   Close waste storage tanks earlier than expected, thereby avoiding the
                                 operating costs involved in maintaining the tanks and monitoring the
                                 wastes.

                             Table 1 summarizes the estimated cost savings for each DOE site if
                             accelerated proposals for cleaning up high-level waste are successfully
                             implemented.




                             5
                              Low-level radioactive waste is defined as radioactive material that is not high-level
                             radioactive waste, spent nuclear fuel, transuranic waste, or certain by-product material
                             (the tailings or wastes produced by the extraction or concentration or uranium or thorium
                             from any ore processed primarily for its source material content). 42 U.S.C. 10101(16).
                             Transuranic wastes come primarily from reprocessing of spent nuclear fuel and from
                             fabrication of nuclear weapons. Transuranic waste is defined as waste with radionuclides
                             with atomic numbers greater than 92 (that is, uranium) and having half-lives greater than
                             20 years in concentrations greater than 100 nanocuries per gram.




                             Page 7                                           GAO-03-930T High-Level Waste Cleanup
                               Table 1: DOE’s Estimated Cost Savings from Proposals to Accelerate Cleanup of
                               High-Level Waste

                               Amounts are in billions of current dollars, fiscal year 2003 to the end of cleanup
                                                                   Current baseline          Accelerated            Estimated savings
                                                                      lifecycle cost       lifecycle cost            from accelerated
                                   Site                                    estimate             estimate                    initiatives
                                   Idaho National Laboratory                 $10.07                $ 3.10                        $ 6.97
                                   Hanford                                     56.19                41.67                         14.52
                                   Savannah River                              18.82                11.49                          7.33
                                    Totals                                   $85.08               $56.26                        $28.82
                               Source: DOE.

                               Note: West Valley is not included in this table because high-level waste cleanup at the site was
                               essentially completed in September 2002.




Savings Estimate May Not       Our review indicates that DOE’s current estimate of $29 billion may not
Be Reliable                    yet be reliable and that the actual amount to be saved if DOE successfully
                               implements the alternative waste treatment and disposal strategies may be
                               substantially different from what DOE is projecting. We have several
                               concerns about the reliability and completeness of the estimate. These
                               concerns include the accuracy of baseline cost estimates from which
                               savings are calculated, whether all appropriate costs are included in the
                               analysis, and whether the savings estimates properly reflect the timing of
                               the savings or uncertainties.

Baseline Costs Are Not Fully   DOE’s current lifecycle cost baseline is used as the base cost from
Reliable                       which potential savings associated with any improvements are measured.
                               However, in recent years, we and others have raised concerns about the
                               reliability of DOE’s baseline cost estimates. In a 1999 report, we noted that
                               DOE lacked a standard methodology for sites to use in developing their
                               lifecycle cost baseline, raising a concern about the reliability of data used
                               to develop these cost estimates.6 DOE’s Office of Inspector General also
                               raised a concern in a 1999 review of DOE project estimates, noting that
                               several project cost estimates examined were not supported or complete.
                               DOE acknowledged in its February 2002 review of the cleanup program




                               6
                               U.S. General Accounting Office, Nuclear Waste: DOE’s Accelerated Cleanup Strategy Has
                               Benefits but Faces Uncertainties, GAO/RCED-99-129 (Washington, D.C.: Apr. 30, 1999).




                               Page 8                                                   GAO-03-930T High-Level Waste Cleanup
                                  that baseline cost estimates do not provide a reliable picture of
                                  project costs.7

Estimates of Project Costs May    Some of DOE’s savings may be based on incomplete estimates of the costs
Be Incomplete                     for the accelerated proposals. According to Office of Management and
                                  Budget (OMB) guidance on developing cost estimates, agencies should
                                  ensure that all appropriate costs are addressed in the estimate. However,
                                  DOE has not always done so. For example, the Idaho National
                                  Laboratory’s estimated savings of up to $7 billion is based, in large part, on
                                  eliminating the need to build a vitrification facility to treat its waste.
                                  However, the waste may have to undergo an alternative treatment method
                                  before it can be accepted at a geological repository, and the Idaho
                                  National Laboratory is considering four different technologies for doing
                                  so. Nevertheless, DOE’s current savings estimate reflects the potential
                                  cost of only one of those technologies. DOE has not yet developed the
                                  costs of using any of the other waste treatment approaches. DOE noted
                                  that the accelerated lifecycle estimate could likely change depending on
                                  which one of the technologies is selected and the associated costs of
                                  treating the waste are developed.

Savings Estimates Do Not          According to OMB guidance, agencies should ensure that the timing of
Reflect Timing, Uncertainty, or   when the savings will occur is accounted for, that uncertainties are
Nonbudgetary Impacts              recognized and quantified where possible, and that nonbudgetary impacts,
                                  such as a change in the level of risk to workers, are quantified, or at least
                                  described. We found problems in all three areas.

                                  •   Regarding the time value of money, applying OMB guidance would
                                      mean that estimates of savings in DOE’s accelerated plans should
                                      reflect a comparison of its baseline cost estimate with the alternative,
                                      expressed in a “present value,” where the dollars are discounted to a
                                      common year to reflect the time value of money. Instead, DOE’s
                                      savings estimates generally measure savings by comparing dollars in
                                      different years. For example, the Savannah River Site estimates a
                                      savings of nearly $5.4 billion by reducing by 8 years (from 2027 to 2019)
                                      the time required to process its high-level waste. Adjusting the savings
                                      estimate to present value in 2003 results in a savings of $2.8 billion in
                                      2003 dollars.




                                  7
                                   U.S. Department of Energy, A Review of the Environmental Management Program
                                  (Washington, D.C.: Feb. 4, 2002).




                                  Page 9                                       GAO-03-930T High-Level Waste Cleanup
                        •   Regarding uncertainties, in contrast to OMB guidance, the DOE savings
                            estimates generally do not consider uncertainties. For example, the
                            savings projected in the Idaho National Laboratory’s accelerated plan
                            reflect the proposal to no longer build the vitrification facility and an
                            associated reduction in operations costs. However, the savings do not
                            account for uncertainties such as whether alternatives to vitrification
                            will succeed and at what cost. Rather than reflecting uncertainties by
                            providing a range of savings, DOE’s savings estimate is a single point
                            estimate of $7 billion.

                        •   Regarding nonbudgetary impacts, DOE’s savings estimates generally
                            do not fully assess the value of potential nonbudgetary impacts, such
                            as a change in the level of risk to workers or potential effects on the
                            environment. OMB guidelines recommend identification and, where
                            possible, quantification of other expected benefits and costs to society
                            when evaluating alternative plans. For example, the Idaho National
                            Laboratory’s accelerated plan does not assess potential increases in
                            environmental risk, if any, from disposing of the waste without
                            stabilizing it into a vitrified form. By not assessing these benefits and
                            risks to workers and the environment, DOE leaves unclear how
                            important these risks and trade-offs are to choosing an alternative
                            treatment approach.


                        DOE faces significant legal and technical challenges in achieving the
Key Legal and           cost and schedule reductions proposed in its new initiative. On the legal
Technical Challenges    side, DOE’s proposals depend heavily on the agency’s authority to apply
                        a designation other than “high-level waste” to the low-activity portion
Could Limit Potential   of the waste stream, so that this low-activity portion does not have to
Savings from DOE’s      be disposed of more expensively as high-level waste. The portion of DOE’s
                        order setting out criteria for making such determinations has been
Accelerated Cleanup     invalidated in a recent court ruling. On the technical side, DOE’s proposals
Initiative              rest heavily on the successful application of waste separation methods
                        that are still under development and will not be fully tested before being
                        put in place. DOE’s track record in this regard has not been strong; it has
                        had to abandon past projects that were also based on promising—but not
                        fully tested—technologies. Either or both of these challenges could limit
                        the potential savings from DOE’s accelerated cleanup initiative.




                        Page 10                                    GAO-03-930T High-Level Waste Cleanup
DOE’s Accelerated           DOE has traditionally managed all of the wastes in its tanks as high-level
Initiative Relies on a      waste because the waste resulted primarily from the reprocessing of spent
Process for Reclassifying   nuclear fuel and contains significant amounts of radioactivity. However,
                            by separating the waste into high-level and low-activity portions and
Waste That the Court Has    managing the low-activity portion as something other than high-level
Ruled Invalid               waste, DOE could use less costly and less complicated treatment
                            approaches. DOE has developed guidelines for deciding when waste in the
                            tanks should not be considered high-level waste. In 1999, under Order
                            435.1, DOE formalized its process for determining which waste is
                            incidental to reprocessing (“incidental waste”), not high level waste,
                            and therefore will not be sent to a geological repository for high-level
                            waste disposal. This process provides a basis for DOE to treat and
                            dispose of some portion of its wastes less expensively as low-level or
                            transuranic wastes.

                            DOE’s ability to define some waste as incidental to reprocessing, and to
                            then follow a different set of treatment and disposal requirements for that
                            waste, is central to its overall strategy for addressing its tank waste. For
                            example, DOE planned to use its incidental waste process to manage
                            about 90 percent of its 54 million gallons of tank waste at the Hanford Site
                            as low-level waste, rather than process it through a high-level waste
                            vitrification facility. Using that approach, most of the waste would be
                            eligible for treatment and disposal on site. Such an approach would save
                            billions compared to treating all of the waste as high-level waste and
                            sending it for disposal in a high-level waste geologic repository.

                            A recent court ruling precludes DOE from reclassifying some of its waste
                            as other than high-level waste. In March 2002, the Natural Resources
                            Defense Council and others filed a lawsuit challenging DOE’s authority to
                            manage its wastes through its incidental waste process.8 The plaintiffs
                            alleged that DOE arbitrarily established the incidental waste determination
                            process without proper regard for the law or properly establishing a
                            justification for this process. A primary concern of the plaintiffs was that
                            DOE would use its incidental waste process to permanently leave
                            intensely radioactive waste sediments in the tanks with only minimal



                            8
                             Natural Resources Defense Council, Inc. v. Abraham, No. 01-CV-413 (D. Idaho, filed
                            Mar. 5, 2002). The lawsuit was originally filed in January 2000 in the 9th Circuit Court of
                            Appeals and was subsequently transferred to the federal district court in Idaho. The other
                            parties to the lawsuit are the Snake River Alliance, the Confederated Tribes and Bands
                            of the Yakama Nation, and the Shoshone Bannock Tribes. In addition, the states of
                            Washington, Idaho, Oregon and South Carolina are participating as amicus curiae.




                            Page 11                                            GAO-03-930T High-Level Waste Cleanup
treatment. The lawsuit alleged that DOE’s incidental waste process
improperly allows DOE to reclassify high-level waste as incidental waste
that does not need to be treated in the same way as high-level waste.
According to the plaintiffs, the Nuclear Waste Policy Act defines all waste
originating from a given source—that is, from reprocessing of spent
nuclear fuel—as high-level waste and requires that such waste be managed
as high-level waste, yet DOE has chosen to differentiate its wastes
according to the level of radioactivity and manage them accordingly. In a
July 3, 2003 ruling on the lawsuit, the court agreed with the plaintiffs,
stating that the portion of DOE’s Order 435.1 setting out its incidental
waste determination process violates the Nuclear Waste Policy Act and
thus is invalid.

The court’s ruling could seriously hinder DOE’s efforts to implement its
accelerated treatment and disposal strategies. Under the ruling, DOE’s
incidental waste determinations cannot be implemented. Since the start of
the lawsuit, DOE had not implemented any of its approved incidental
waste determinations and had not yet decided whether to defer or proceed
with its pending incidental waste determinations—such as those for
closing tanks at the Savannah River Site and Idaho National Laboratory.

If DOE appeals the court ruling, a lengthy legal process could follow. A
lengthy legal process will also likely delay treatment plans for this waste
and delay closing tanks on an accelerated schedule. For example, the
Idaho National Laboratory planned to begin closing tanks in the spring of
2003, pending approval of an incidental waste determination that would
allow DOE to close the tanks by managing tank waste residuals as low-
level waste.9 A DOE official at the Idaho National Laboratory told us that
while a delay of several months would not immediately threaten schedule
dates, a delay beyond 24 months would seriously affect the site’s ability to
meet its accelerated 2012 date to close all of the tanks.

If the court’s ruling invalidating DOE’s incidental waste determination
process is upheld, DOE may need to find an alternative that would allow it
to treat waste with lower concentrations of radioactivity less expensively.
Searching for such an alternative could delay progress at all three of
DOE’s high-level waste sites that rely on incidental waste determinations.
If DOE cannot meet its accelerated schedules, then potential savings are



9
Tank closure at the Idaho National Laboratory is also pending completion of its National
Environmental Policy Act process.




Page 12                                          GAO-03-930T High-Level Waste Cleanup
                              in jeopardy. At this point, the department does not appear to have a
                              strategy to avoid the potential effects of challenges to its incidental waste
                              determination authority, either from the current court ruling or future
                              challenges. At the time of our report, DOE officials told us that they
                              believed the department would prevail in the legal challenge. DOE
                              believed it would be premature to explore alternative strategies to
                              overcome potentially significant delays to the program that could result
                              from a protracted legal conflict or from an adverse decision. Such
                              strategies could range from exploring alternative approaches for
                              establishing an incidental waste regulation to asking that the Congress
                              provide legislative authority for DOE to implement an incidental
                              waste policy.


Accelerated Initiative Also   Like the ability to determine that some waste is incidental to reprocessing,
Relies on Waste Separation    the ability to separate the waste components is important to meet waste
Approaches That Will Not      cleanup schedule and cost goals. If the waste is not separated, all of it—
                              about 94 million gallons—may have to be treated as high-level waste and
Be Fully Tested               disposed of in the geological repository. Doing so would require a much
                              larger repository than currently planned, and drive up disposal costs
                              by billions of dollars. Successful separation will substantially reduce the
                              volume of waste needing disposal at the planned repository, as well as the
                              time and cost required to prepare it for disposal, and allow less expensive
                              methods to be used in treating and disposing of the remaining low-
                              activity waste. The waste separation process is complicated, difficult, and
                              unique in scope at each site. The waste differs among sites not only in
                              volume but also in the way it has been generated, managed, and stored
                              over the years.

                              The challenge to successfully separate the waste is significant at the
                              Hanford Site, where DOE intends to build a facility for separating the
                              waste before fully testing the separation processes that will be used. The
                              planned laboratory testing includes a combination of pilot-scale testing of
                              major individual processes and use of operational data for certain of those
                              processes for which DOE officials said they had extensive experience.
                              However, integrated testing will not be performed until full-scale facilities
                              are constructed. DOE plans to fully test the processes for the first time
                              during the operational tests of the newly constructed facilities.

                              This approach does not fully reflect DOE guidance, which calls for
                              ensuring that new or complex technology is mature before integrating it
                              into a project. Specifically, DOE’s Project Management Order 413.3
                              requires DOE to assess the risks associated with technology at various


                              Page 13                                    GAO-03-930T High-Level Waste Cleanup
phases of a project’s development. For projects with significant technical
uncertainties that could affect cost and schedule, corrective action plans
to address these uncertainties are required before the projects can
proceed. In addition, DOE’s supplementary project management guidance
suggests that technologies be developed to a reasonable level of maturity
before a project progresses to full implementation to reduce risks and
avoid cost increases and schedule delays. The guidance suggests that DOE
avoid the risk of designing facilities concurrently with
technology development.

The laboratories working to develop Hanford’s waste separation process
have identified several technical uncertainties, which they are working to
address. These uncertainties or critical technology risks include problems
with separating waste solids through an elaborate filtration system,
problems associated with mixing the waste during separation processes,
and various problems associated with the low-activity waste evaporator.

Given these and other uncertainties, Hanford’s construction
contractor and outside experts have seen Hanford’s approach as
having high technical risk and have proposed integrated testing during
project development. However, DOE and the construction contractor
eventually decided not to construct an integrated pilot facility and instead
to accept a higher-risk approach. DOE officials said they wanted to avoid
increasing project costs and schedule delays, which they believe will result
from building a testing facility. Instead, Hanford officials said that they will
continue to conduct pilot-scale tests of major separation processes. DOE
officials said they believe this testing will provide assurance that the
separation processes will function in an integrated manner. After the full-
scale treatment facilities are constructed, DOE plans to fully test and
demonstrate the separation process during facility startup operations.

The consequences of not adhering to sound technology development
guidelines can be severe. At the Savannah River Site, for example,
DOE invested nearly $500 million over nearly 15 years to develop a waste
separation process, called in-tank precipitation, to treat Savannah River’s
high-level waste. While laboratory tests of this process were viewed as
successful, DOE did not adequately test the components until it started
full-scale operations. DOE followed this approach, in part, because the
technology was commercially available and considered “mature.”
However, when DOE started full-scale operations, major problems
occurred. Benzene, a dangerously flammable byproduct, was produced in
large quantities. Operations were stopped after DOE spent about
$500 million because experts could not explain how or why benzene was


Page 14                                    GAO-03-930T High-Level Waste Cleanup
                         being produced and could not determine how to economically reconfigure
                         the facility to minimize it. Consequences of this technology failure
                         included significant cost increases, schedule delays, a full-scale waste
                         separation process that did not work, and a less-than-optimum waste
                         treatment operation. Savannah River is now developing and implementing
                         a new separation technology at an additional cost of about $1.8 billion and
                         a delay of about 7 years.10

                         Subsequent assessments of the problems that developed at Savannah
                         River found that DOE (1) relied on laboratory-scale tests to demonstrate
                         separation processes, (2) believed that technical problems could be
                         resolved later during facility construction and startup, and (3) decided to
                         scale up the technology from lab tests to full-scale without the benefit of
                         using additional testing facilities to confirm that processes would work at
                         a larger scale. Officials at Hanford are following a similar approach.
                         Several experts with whom we talked cautioned that if separation
                         processes at Hanford do not work as planned, facilities will have to be
                         retrofitted, and potential cost increases and schedule delays would be
                         much greater than any associated with integrated process testing in a
                         pilot facility.


                         In addition to the potential cost savings identified in the accelerated
Opportunities Exist to   site cleanup plans, DOE continues to develop and evaluate other proposals
Explore Additional       to reduce costs but is still assessing them. Although the potential cost
                         savings have not been fully developed, they could be in the range of
Cost Savings and to      several billion dollars, if the proposals are successfully implemented. At
Strengthen Program       the Savannah River and Hanford sites, for example, DOE is identifying
                         ways to increase the amount of waste that can be placed in its high-level
Management               waste canisters to reduce treatment and disposal costs. DOE also has a
                         number of initiatives under way to improve overall program management.
                         However, we are concerned that the initiatives may not be adequate. In
                         our examinations of problems that have plagued DOE’s project
                         management over the years, three contributing factors often emerged—
                         making key project decisions without rigorous analysis, incorporating new
                         technology before it has received sufficient testing, and using a “fast-track”
                         approach (concurrent design and construction) on complex projects.



                         10
                          U.S. General Accounting Office, Nuclear Waste: Process to Remove Radioactive
                         Waste From Savannah River Tanks Fails to Work, GAO/RCED-99-69 (Washington, D.C.:
                         Apr. 30, 1999).




                         Page 15                                      GAO-03-930T High-Level Waste Cleanup
                          Ensuring that these weaknesses are addressed as part of its program
                          management initiatives would further improve the management of the
                          program and increase the chances for success.


DOE Is Considering        DOE is continuing to identify other proposals for reducing costs under
Additional Potential      its accelerated cleanup initiative. Among the proposals that DOE is
Opportunities to Reduce   considering, the ones that appear to offer significant cost savings
                          opportunities would increase the amount of waste placed in each disposal
Costs                     canister. The amount of waste that can be placed into a canister depends
                          on a complex set of factors, including the specific mix of radioactive
                          material combined with other chemicals in the waste, such as chromium
                          and sulfate, that affect the processing and quality of the immobilized
                          product. These factors affect the percentage of waste than can be placed
                          in each canister because they indicate the likelihood that radioactive
                          constituents could move out of the immobilizing glass medium and into
                          the environment. The greater the potential for the waste to become
                          mobile, the lower the allowable percentage of waste and the higher
                          the percentage of glass material that must be used.

                          Savannah River officials believe they can increase the amount of waste
                          loaded in each canister from 28 percent to about 35 percent, and for at
                          least one waste batch, to nearly 50 percent. In June 2003, Savannah River
                          began to implement this new process to increase the amount of waste in
                          each canister. If successful, Savannah River’s improved approach could
                          reduce the number of canisters needed by about 1,000 canisters and save
                          about $2.7 billion, based on preliminary estimates. Other efforts to
                          increase waste loading of the canisters are also under way that, if
                          successful, may permit further cost savings of about $1.7 billion. The
                          Hanford Site is also exploring ways to decrease the numbers of waste
                          canisters that will be needed by using waste forms other than the standard
                          borosilicate glass. This effort is in a very early stage of development and
                          cost-savings estimates have not been fully developed.




                          Page 16                                  GAO-03-930T High-Level Waste Cleanup
DOE Has Opportunities to        In addition to site-specific proposals for saving time and money, DOE is
Improve Management of           also undertaking management improvements using teams to study
the Program by Addressing       individual issues. Nine teams are currently in place, while other teams to
                                address issues such as improving the environmental review process to
Previously Identified           better support decision making have not yet been formed. Each team has a
Weaknesses                      disciplined management process to follow,11 and even after the teams’
                                work is completed, any implementation will take time. These efforts are in
                                the early stages, and therefore it is unclear if they will correct the
                                performance problems DOE and others have identified.

                                We are concerned that these management reforms may not go far enough
                                in addressing performance problems with the high-level waste program.
                                Our concerns stem from our review of initiatives under way in the
                                management teams, our discussions with DOE officials, and our past and
                                current work, as well as work by others inside and outside DOE. We have
                                identified three recurring weaknesses in DOE’s management of cleanup
                                projects that we believe need to be addressed as part of DOE’s overall
                                review. These weaknesses cut across the various issues that the teams are
                                working on and are often at the center of problems that have been
                                identified. Two of these weaknesses have been raised earlier in this
                                testimony—lack of rigor in the analysis supporting key decisions, and
                                incorporating technology into projects before it is sufficiently mature. The
                                final area of weakness involves using “fast-track” methods to begin
                                construction of complex facilities before sufficient planning and design
                                have taken place.

Key Decisions Not Always        DOE’s project management guidance emphasizes the importance of
Supported by Rigorous Current   rigorous and current analysis to support decision making during the
Analysis                        development of DOE projects. Similarly, OMB guidance states that
                                agencies should validate earlier planning decisions with updated
                                information before finalizing decisions to construct facilities. This
                                validation is particularly important where early cost comparisons are
                                susceptible to uncertainties and change.

                                DOE does not always follow this guidance, yet no DOE management team
                                appears to be addressing this weakness. Proceeding without rigorous
                                review has been a recurring cause of many of the problems we have



                                11
                                 Under DOE’s project management principles, for example, teams must define project
                                requirements, conduct preliminary risk assessments, and prepare a risk mitigation plan
                                prior to developing a baseline cost estimate of proposed alternatives.




                                Page 17                                          GAO-03-930T High-Level Waste Cleanup
                            identified in past DOE projects. For example, the decision at Hanford to
                            construct a vitrification plant to treat Hanford’s low-activity waste has not
                            been validated with updated information. Hanford’s primary analysis
                            justifying the cost of this approach was prepared in 1999 and was based on
                            technical performance data, disposal assumptions, and cost data
                            developed in the early to mid-1990s—conditions that are no longer
                            applicable. Subsequent analyses have continued to rely on this data.
                            However, since that time conditions have changed, including the
                            performance capabilities of alternative technologies such as grout, the
                            relative cost of different technologies, and the amount of waste DOE
                            intends to process through a vitrification facility.

                            DOE officials disagree with our assessment of their analysis, stating that a
                            comprehensive analysis was conducted in the spring of 2003. However,
                            DOE’s high-level waste project team agreed that the DOE officials at
                            Hanford had not performed a current, rigorous analysis of low-activity
                            waste treatment options including the use of grout as an alternative to
                            vitrification, and the team encouraged the Hanford site to update its
                            analysis based on current waste treatment and disposal assumptions. DOE
                            officials at Hanford told us they do not plan to reassess the decision to
                            construct a low-activity vitrification facility because their compliance
                            agreement with the state of Washington calls for vitrification of this waste.
                            They also stated that vitrification is a technology needed for destroying
                            hazardous constituents in a portion of the waste.

New Technology Is           Our work on Department of Defense acquisitions has documented a set of
Incorporated before It Is   “best practices” used by industry for integrating new technology into
Sufficiently Mature         major projects. We reported in July 1999 that the maturity of a technology
                            at the start of a project is an important determinant of success.12 As
                            technology develops from preconceptual design through preliminary
                            design and testing, the maturity of the technology increases and the risks
                            associated with incorporating that technology into a project decrease.
                            Waiting until technology is well-developed and tested before integrating it
                            into a project will greatly increase the chances of meeting cost, schedule,
                            and technical baselines. On the other hand, integrating technology that is
                            not fully mature into a project greatly increases the risk of cost increases
                            and schedule delays. According to industry experts, correcting problems



                            12
                             U.S. General Accounting Office, Best Practices: Better Management of Technology
                            Development Can Improve Weapon System Outcomes, GAO/NSIAD-99-162
                            (Washington, D.C.: July 30, 1999).




                            Page 18                                        GAO-03-930T High-Level Waste Cleanup
                                after a project has begun can cost 10 times as much as resolving
                                technology problems beforehand.

                                DOE’s project management guidance issued in October 2000 is consistent
                                with these best practices. The guidance discusses technology development
                                and sets out suggested steps to ensure that new technology is brought to a
                                sufficient level of maturity at each decision point in a project. For
                                example, during the conceptual design phase of a project, “proof of
                                concept” testing should be performed before approval to proceed to the
                                preliminary design phase. Furthermore, the guidance states that
                                attempting to concurrently develop the technology and design the facility
                                for a project poses ill-defined risks to the project.

                                Nevertheless, as we discussed earlier, DOE sites continue to integrate
                                immature technologies into their projects. For example, as discussed
                                earlier, DOE is constructing a facility at the Hanford Site to separate
                                high-level waste components, although integrated testing of the many
                                steps in the separations process has not occurred and will not occur until
                                after the facility is completed. DOE, trying to keep the project on schedule
                                and within budget, has decided the risks associated with this approach are
                                acceptable. However, there are many projects for which this approach
                                created schedule delays and unexpected costs. The continued reliance on
                                this approach in the face of so many past problems is a signal of an area
                                that needs careful attention as DOE proceeds with its management reform
                                efforts. At present, no DOE management team is addressing this issue.

Facility Construction Starts    Finally, we have concerns about DOE’s practice of launching into
before Design Is Sufficiently   construction of complex, one-of-a-kind facilities well before their final
Developed                       design is sufficiently developed, again in an effort to save time and money.
                                Both DOE guidance and external reviews stress the importance of
                                adequate upfront planning before beginning project construction. DOE’s
                                project management guidance identifies a series of well-defined steps
                                before construction begins and suggests that complex projects with
                                treatment processes that have never before been combined into a facility
                                do not lend themselves to being expedited. However, DOE guidance does
                                not explicitly prohibit a fast-track—or concurrent design and
                                construction—approach to complex, one-of-a-kind projects, and DOE
                                often follows this approach. For example, at the Hanford Site, DOE is
                                concurrently designing and constructing facilities for the largest, most
                                complex environmental cleanup job in the United States. Problems are
                                already surfacing. Only 24 months after the contract was awarded, the
                                project was 10 months behind schedule dates, construction activities have
                                outpaced design work causing inefficient work sequencing, and DOE has


                                Page 19                                  GAO-03-930T High-Level Waste Cleanup
              withheld performance fee from the design/construction contractor
              because of these problems.

              DOE experienced similar problems in concurrent design and construction
              activities on other waste treatment facilities. Both the spent nuclear fuel
              project at Hanford and the waste separations facility at the Savannah River
              Site encountered schedule delays and cost increases in part because the
              concurrent approach led to mistakes and rework, and required extra time
              and money to address the problems.13 In its 2001 follow-up report on DOE
              project management, the National Research Council noted that inadequate
              pre-construction planning and definition of project scope led to cost and
              schedule overruns on DOE’s cleanup projects.14 The Council reported that
              research studies suggest that inadequate project definition accounts for
              50 percent of the cost increases for environmental remediation projects.
              Again, no DOE team is specifically examining the “fast-track” approach,
              yet it frequently contributed to past problems and DOE continues to use
              this approach.


              DOE’s efforts to improve its high-level waste cleanup program and to rein
Conclusions   in the uncontrolled growth in project costs and schedules are important
              and necessary. The accelerated cleanup initiative represents at least the
              hope of treating and disposing of the waste in a more economical and
              timely way, although the actual savings are unknown at this time.
              Furthermore, specific components of this initiative face key legal and
              technical challenges. Much of the potential for success rested on DOE’s
              ability to dispose of large quantities of waste with relatively low
              concentrations of radioactivity on site by applying its incidental waste
              process. Recently, a court ruled that the portion of DOE’s order setting out
              its incidental waste determination process violates the Nuclear Waste
              Policy Act and is invalid. Thus, DOE is precluded from implementing this
              element of its accelerated initiative. Success in accelerating cleanup also
              rests on DOE’s ability to obtain successful technical performance from its


              13
               For a discussion of the problems associated with the fast track design/build approach
              on these projects, see U.S. General Accounting Office, Nuclear Waste: DOE’s Hanford
              Spent Nuclear Fuel Storage Project—Cost, Schedule, and Management Issues,
              GAO/RCED-99-267 (Washington, D.C.: Sept. 20, 1999) and Nuclear Waste: Process to
              Remove Radioactive Waste From Savannah River Tanks Fails to Work, GAO-RCED-99-69
              (Washington, D.C.: Apr. 30, 1999).
              14
               National Research Council, Progress in Improving Project Management at the
              Department of Energy (Washington, D.C.: Nov. 2001).




              Page 20                                        GAO-03-930T High-Level Waste Cleanup
as-yet unproven waste separation processes. Any technical problems with
these processes will likely result in costly delays. At DOE’s Hanford Site,
we believe the potential for such problems warrants reconsidering the
need for more thorough testing of the processes, before completing
construction of the full-scale waste separation facility.

DOE’s accelerated cleanup initiative should mark the beginning, not
the end, of DOE’s efforts to identify other opportunities to improve the
program by accomplishing the work more quickly, more effectively, or at
less cost. As DOE continues to pursue other management improvements,
it should reassess certain aspects of its current management approach,
including the quality of the analysis underlying key decisions, the
adequacy of its approach to incorporating new technologies into projects,
and the merits of a fast-track approach to designing and building complex
nuclear facilities. Although the challenges are great, the opportunities for
program improvements are even greater. Therefore, DOE must continue
its efforts to clean up its high-level waste while demonstrating tangible,
measurable program improvements.

In the report being released today, we made several recommendations to
help DOE manage or reduce the legal and technical risks faced by the
program as well as to strengthen DOE’s overall program management.
DOE agreed to consider seeking clarification from Congress regarding its
authority to define some waste as incidental to reprocessing, if the legal
challenge to its authority significantly affected DOE’s ability to achieve
savings under the accelerated initiative. Regarding our recommendations
to conduct integrated pilot-scale testing of the separations facility at
Hanford before construction is completed, and to make other management
improvements to address the weaknesses I just discussed, DOE’s position
is that it has already taken appropriate steps to manage the technology
risks and strengthen its management practices. We disagree and believe
that implementing all of our recommendations would help reduce the risk
of costly delays and improve overall management of DOE’s entire high-
level waste program.

                               -   -   -   -   -

Thank you, Mr. Chairman and Members of the Subcommittee. That
concludes my testimony. I would be pleased to respond to any questions
that you may have.




Page 21                                    GAO-03-930T High-Level Waste Cleanup
           Contacts and Acknowledgements

           For further information on this testimony, please contact Ms. Robin
           Nazzaro at (202) 512-3841. Individuals making key contributions to this
           testimony included Carole Blackwell, Robert Crystal, Doreen Feldman,
           Chris Hatscher, George Hinman, Gary Jones, Nancy Kintner-Meyer, Avani
           Locke, Mehrzad Nadji, Cynthia Norris, Tom Perry, Stan Stenersen, and Bill
           Swick.




(360365)
           Page 22                                 GAO-03-930T High-Level Waste Cleanup
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