oversight

Nuclear Waste: Process to Remove Radioactive Waste From Savannah River Tanks Fails to Work

Published by the Government Accountability Office on 1999-04-30.

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

                 United States General Accounting Office

GAO              Report to the Ranking Minority Member,
                 Committee on Commerce, House of
                 Representatives


April 1999
                 NUCLEAR WASTE

                 Process to Remove
                 Radioactive Waste
                 From Savannah River
                 Tanks Fails to Work




GAO/RCED-99-69
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548                                                           Leter




                   Resources, Community, and
                   Economic Development Division

                   B-281907                                                                   Letter

                   April 30, 1999

                   The Honorable John D. Dingell
                   Ranking Minority Member
                   Committee on Commerce
                   House of Representatives

                   Dear Mr. Dingell:

                   The Department of Energy (DOE) is responsible for cleaning up the nuclear
                   waste legacy created by over 50 years of producing nuclear weapons
                   material. At DOE’s Savannah River Site in South Carolina, 34 million
                   gallons of liquids that contain highly radioactive waste (high-level waste)
                   have accumulated in the storage tanks since the site became operational in
                   1951. The in-tank precipitation (ITP) process was selected in 1983 as the
                   preferred method for separating the high-level waste from the liquid. In
                   1985, DOE estimated that it would take about 3 years and $32 million to
                   construct the ITP facility. After a number of delays, the ITP facility was
                   started up in 1995, but safety concerns about the amount of explosive, toxic
                   benzene gas that the facility was generating halted start-up operations.
                   Ultimately, in February 1998, after about a decade of delays and spending
                   almost a half billion dollars, DOE suspended the ITP project because it
                   would not work safely and efficiently as designed. DOE then directed its
                   contractor, Westinghouse Savannah River Corporation (Westinghouse), to
                   begin a process to identify and select an alternative process.

                   You asked us to (1) examine the factors causing the project’s delays and
                   cost growth, (2) identify the effect of the ITP project’s suspension on the
                   Savannah River Site’s cleanup plans and costs, and (3) provide information
                   on DOE’s plans for developing an alternative technology for separating
                   high-level waste from the liquid.



Results in Brief   A number of factors combined to cause the Department of Energy and
                   Westinghouse to spend almost a half billion dollars and to take about a
                   decade to decide that the in-tank precipitation process would not work
                   safely and efficiently as designed. The most serious factors were the
                   ineffectiveness of the contractor’s management and of the Department’s
                   oversight of the project. For example, in 1993, a technical review team
                   reported that the contractor tended to use “reactive discovery
                   management” to solve problems after they occurred, rather than working
                   to avoid problems in the first place. The team also found that the



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Department lacked the necessary personnel for adequate oversight.
Moreover, the Department and the contractor encountered delays in
starting up the in-tank precipitation facility because they began
construction before the design of the process was completed.
Furthermore, because the Department funded the project with operating
funds, rather than with construction funds, the project was less visible to
congressional oversight. There was also an inadequate understanding by
DOE and the contractor of the in-tank precipitation process and the cause
of the benzene generation.

The failure of the in-tank precipitation process to operate as originally
planned will delay the cleanup of high-level waste at the Savannah River
Site and increase costs. Initially, the facility was planned to begin operating
in 1988, and now, DOE estimates that an alternative process may not be
available until as late as 2007 and could cost from about $2.3 billion to $3.5
billion over its lifetime. As a result, the site has had to modify its plans for
processing waste. Depending on the alternative process selected,
Westinghouse estimated that it could be as late as 2025 before the waste
tanks are empty. Thus, the Department risks missing the dates in its waste
removal plan and schedule agreement with the state of South Carolina and
the U.S. Environmental Protection Agency to close certain high-level waste
tanks by no later than 2022. More importantly, Westinghouse estimated
that it could cost over $75 billion to construct and operate the facilities
necessary to clean up the high-level waste if an alternative process is not
developed for separating the waste in the tanks.

The Department’s plans for selecting an alternative process are still being
formulated. Soon after the in-tank precipitation project was suspended in
1998, Westinghouse began evaluating 142 technologies to replace the
process and pared them down to 4 final alternative technologies. On
October 29, 1998, Westinghouse recommended to the Department that the
small tank precipitation process be selected. Although this process is
similar to the failed one, several differences exist that Westinghouse
believes will address the safety hazards caused by the benzene generated
by the process. For example, because small tanks will be used to process
the waste, the processing time will be cut significantly, thereby reducing
the time during which benzene can build up in the tanks. Westinghouse
officials estimate that it could cost about $1 billion to build the small tank
precipitation facility by 2005. Westinghouse ranked this process as being
the most scientifically mature, having the most manageable risk, and
having the greatest likelihood of success. Westinghouse also
recommended that an alternative process, crystalline silicotitanate ion



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             exchange, be developed as a backup, using a different method to remove
             the high-level waste from the tanks. The Department’s Savannah River Site
             evaluated Westinghouse’s recommendation and announced in December
             1998 that testing and development work should continue on both processes
             before a final decision is made. In addition, the Department concluded that
             another process--direct disposal in grout--should not be eliminated from
             consideration. As a result, DOE has begun additional research and testing
             to obtain the information needed to select the preferred alternative by the
             end of fiscal year 1999.



Background   In the early 1980s, DOE’s Savannah River Site in South Carolina initiated
             efforts to remove 34 million gallons of liquids containing high-level waste
             being stored in 49 underground tanks. It developed plans for constructing
             various facilities to treat the waste and transform it into a more stable glass
             form--a process referred to as vitrification. 1 The glass canisters would then
             be shipped to a repository for permanent disposal. The vitrification
             process is performed at Savannah River’s Defense Waste Processing
             Facility, which began operating in 1996 and cost over $2 billion to
             construct.

             The ITP project was designed to be an integral part of the high-level waste
             cleanup program that would speed up the process and reduce the overall
             cost. Since only about 10 percent of the 31 million gallons of waste in the
             tanks is highly radioactive, separating the high-level waste from the
             remaining liquids greatly reduces the volume to be vitrified. 2 The ITP
             facility was to separate (precipitate) the high-level waste (mainly cesium,
             but also trace amounts of strontium and plutonium) in the waste tanks. To
             remove the cesium, a chemical called sodium tetraphenylborate was to be
             mixed with liquids from the underground tanks in a 1.3 million-gallon
             processing tank. This chemical would react with the waste, causing the
             high-level waste to be separated from the liquids. The high-level waste was
             then to be removed from the tank through a filtering process. To remove
             the trace amounts of strontium and plutonium, another chemical was to be


             1Vitrification is the process of blending liquid high-level waste with other substances and melting them
             at 2,100 degrees Fahrenheit to form a solid glass. Once the high-level waste is immobilized within the
             structure of the glass, it cannot dissolve the glass and migrate into the environment.

             2
               Of the 34 million gallons of waste in the tanks, about 3 million gallons is sludge (highly radioactive
             insoluble waste that settles to the bottom of the storage tanks) that requires different handling than the
             31 million gallons of liquid referred to here.




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used, monosodium titanate. Once the high-level waste was separated, it
was to be sent through a “late wash” facility, where nitrite concentrations
would be reduced, and then sent to the Defense Waste Processing Facility
to be vitrified with sludge wastes. After the separation process, the waste
remaining in the tank would be a solution with a low level of radioactivity
that could be safely treated and disposed of on site at Savannah River’s
saltstone facility.3

DOE officials said that in selecting the ITP process they were looking for a
less costly approach to separating the liquid wastes. The alternative to ITP
available in 1982 was estimated to cost about $700 million to construct.4
DOE officials said that the ITP option was selected because (1) existing
scientific data indicated a reasonable chance for success, (2) the
technological uncertainties were believed to be comparable to those of
alternative technologies, and (3) the process could be performed in
existing waste tanks, thereby eliminating the need to construct a new
major facility and significantly reducing the estimated cost.

The development of the ITP process began in the early 1980s when the
DuPont Chemical Company was DOE’s management and operating
contractor at Savannah River. In 1985, the ITP facility was projected to
cost an estimated $32 million to construct and to be operational in 1988. In
addition, at that time, DOE estimated that it would need to build three
other facilities to support ITP that would cost about $71 million to
construct.5 Westinghouse took over as the site’s management and
operating contractor on April 1, 1989, and thus assumed responsibility for
the ITP project. Ten years after the original completion date, about $489
million had been spent on the ITP process and its related facilities and




3
  The saltstone facility is a disposal facility for low-level radioactive waste that has been mixed with
grout to make a concrete-like substance.

4A February 1982 final environmental impact statement included a construction cost estimate of $700
million (in constant 1980 dollars) for a process called ion exchange, which was to separate the highly
radioactive waste from the tanks. A Westinghouse official said that this cost would have exceeded $900
million if escalated for inflation.

5
  The three facilities were the saltstone facility, the salt processing cell that readies the precipitate
resulting from the ITP process for the Defense Waste Processing Facility melter, and the organic waste
storage tank that would be used to store the benzene recovered from the process.




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                        activities.6 (App. I contains additional information on the costs of the ITP
                        project and its associated facilities.)

                        The ITP facility began start-up operations in September 1995 using 130,000
                        gallons of waste solution and 37,300 gallons of sodium tetraphenylborate.
                        During October and November, test results showed a nearly constant
                        release of benzene. In December 1995, benzene was released at a much
                        higher rate than expected, and the operations were stopped. This led to an
                        expanded scope of experiments to investigate the generation, retention,
                        and release of the excess benzene. In January 1996, the Defense Nuclear
                        Facilities Safety Board7 sent DOE a letter advising that additional safety
                        precautions were needed because of the excess benzene generation and
                        that DOE needed to better understand the mechanisms for the generation
                        and release of the gas. In March 1996, ITP operations were suspended. On
                        August 14, 1996, the Safety Board issued Recommendation 96-1 to address
                        its safety concerns about ITP. In part, it recommended that DOE better
                        understand ITP’s sodium tetraphenylborate chemistry. It was eventually
                        discovered that a catalyst existed in the waste tanks that was causing the
                        excess benzene generation, a discovery that led to the formal suspension of
                        the ITP process in February 1998.



Ineffective             A number of factors combined to cause DOE and Westinghouse to spend
                        almost a half billion dollars and take about a decade to decide that the in-
Management and          tank precipitation technology would not work safely and efficiently as
Oversight and Lack of   designed. The ineffectiveness of management and oversight during the
                        1980s and early 1990s resulted in the problems with the ITP process not
Understanding of the    being dealt with adequately early on in the technology’s development. In
Process Delayed the     addition, the ITP process and the generation of benzene (a toxic, highly
Suspension Decision     flammable, and explosive gas) were not fully understood.




                        6The $489 million includes total estimated construction costs of $157 million; other project costs of
                        $151 million that include the costs of testing, training, and operational readiness reviews; operating
                        costs of $19 million that include the cost to run the facility after it became operational; and other
                        supporting facilities costs of $162 million that include the costs associated with activities needed to
                        enhance the safety and efficiency of the ITP process.

                        7
                          The Defense Nuclear Facilities Safety Board is an independent executive branch organization
                        responsible for providing advice and recommendations to the Secretary of Energy on public health and
                        safety issues at DOE’s defense nuclear facilities.




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Ineffective Management and    Ineffective management and oversight by DOE and its operating contractor
Oversight Led to Project      were principal factors contributing to the delays and increased costs of the
                              ITP project. Management and oversight were ineffective during the 1980s
Delays and Cost Growth
                              and early 1990s primarily for the following reasons:

                              • the weaknesses in the contractor’s management and DOE’s oversight,
                              • the difficulty in managing the project’s start-up, and
                              • the limited oversight and visibility of the project because of the
                                budgetary treatment it received.

Weaknesses Existed in the     In 1993, a DOE technical review team (referred to as the Red Team)
Contractor’s Management and   reported that the contractor tended to use “reactive discovery
DOE’s Oversight               management” to solve problems after they occurred, rather than

                              working to avoid problems in the first place.8 The Red Team found that
                              this approach resulted in a high potential for inadequate process
                              development, lengthening the project and increasing its costs. The Red
                              Team also found that there were inadequacies in ITP testing and in
                              understanding the ITP process as well as uncertainties about whether the
                              equipment to be used would function as expected.

                              The Red Team also reported that DOE Savannah River’s oversight and
                              support functions were not adequate because they lacked the necessary
                              personnel. The Red Team found that, as a result, DOE’s guidance and
                              responsiveness to Westinghouse were limited. Moreover, the team found
                              that DOE’s organizational responsibilities appeared unclear and that the
                              DOE staff were forced to respond in a reactive manner to emerging issues.

                              The contractor’s management problems surfaced repeatedly in the
                              evaluations DOE performed every 6 months to assess Westinghouse’s
                              eligibility for award fees.9 For example, we found that in 14 of the 16
                              evaluations performed from April 1990 through March 1998, DOE identified
                              weaknesses needing attention in contractor management or ITP planning
                              activities. For example, a 1992 evaluation stated that performance against
                              planned work was not adequately monitored and technical documents had

                              8IndependentTechnical Review of In-Tank Precipitation (ITP) at the Savannah River Site, DOE Office
                              of Environmental Restoration and Waste Management (June 1993).

                              9
                                In fiscal year 1995, the evaluation periods were 8 months and 4 months rather than 6 months. An
                              award fee is an incentive for good performance as defined in the contractual agreement that DOE
                              negotiates annually with a contractor.




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                                  deficiencies indicating a lack of management attention. In 1996, an
                                  evaluation noted that while the ITP benzene issue was a key issue, no
                                  single manager had been designated as having overall responsibility for the
                                  resolution of the issue and the implementation of the resolution program
                                  had been fragmented and was not integrated. In addition, a 1995 evaluation
                                  noted that insufficient resources had been assigned to meet the project’s
                                  schedule. (See app. II for examples of the deficiencies identified in the
                                  award fee reports.)

                                  Although DOE included the ITP project in its award fee determination for
                                  the high-level waste program as a whole, there was no indication that the
                                  deficiencies found in the ITP project affected the amount of the award fee
                                  until fiscal year 1998--when the project had been formally suspended.
                                  From 1990 through 1997, Westinghouse received, on average, 69 percent of
                                  the available fee, or about $3 million per fee period, for activities associated
                                  with the high-level waste program. In 1998, after DOE and Westinghouse
                                  had agreed to make the ITP project a performance-based incentive project,
                                  DOE evaluated Westinghouse on ITP performance. Had Westinghouse
                                  resolved the technical issues and put the ITP facility into operation, it could
                                  have earned up to a $2 million award. Instead, DOE deducted $1 million
                                  from Westinghouse's total fee award because the ITP facility remained
                                  inoperable.

                                  The DOE Savannah River officials responsible for overseeing the ITP
                                  project told us that the project was poorly defined up front and that this
                                  had led to higher costs and greater delays. However, according to DOE, the
                                  site has made improvements in project management in recent years. For
                                  example, DOE noted that as a result of a National Research Council report,
                                  DOE and Westinghouse performed a self-assessment of the site’s project
                                  management and developed and implemented a project management
                                  improvement plan in 1998.

Managing the Project’s Start-up   The ITP project was managed on a fast-track schedule--design and
Posed Difficulties                construction being done concurrently--with an emphasis on pushing ahead
                                  in the belief that the problems could be solved later. Wanting to have the
                                  ITP process ready in time to provide precipitate to the Defense Waste
                                  Processing Facility, project managers began construction of the ITP facility
                                  before the design of the ITP process was completed. Rather than
                                  expediting the ITP project, this approach caused a series of delays that
                                  prolonged the project for 10 years while costs mounted. A number of
                                  studies in the early 1990s noted this problem, as the following examples
                                  show:



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• A 1992 Westinghouse management assessment concluded that a number
  of start-up activities were begun prematurely--before the foundation for
  an efficient program was in place.10 The key weaknesses observed
  included a lack of a technical baseline and a potential for disconnects
  and inconsistencies among the project’s various activities because their
  integration was incomplete.
• Our 1992 report on Savannah River’s Defense Waste Processing Facility,
  which included the ITP project, cited the fast-track management method
  being used as having contributed to the project’s cost growth. Our
  report also stated that there was a risk associated with that method,
  especially when used with unique and complex facilities. We
  recommended that an assessment be made comparing ITP to an
  alternative technology.11
• The 1993 Red Team report noted that the project’s start-up was not
  being managed as a first-of-a-kind chemical processing system. It stated
  that Westinghouse was not following the accepted chemical engineering
  practice of completing process development, demonstrating the
  operability of the process on a pilot scale, and assessing all long-term
  impacts and requirements for sustaining the process before beginning
  production plant operations. The Red Team recommended that
  alternatives to the ITP process be considered.

Westinghouse acknowledged that the risks associated with new
applications of existing technologies were not managed well on the ITP
project in terms of building enough time into the schedule to allow for the
kinds of technical problems that arose. DOE Savannah River officials
noted that ITP was a first-of-a-kind process for which no proven technology
was available. They said that the project was complicated by the fact that,
because of funding constraints, they had to scale up the technology from
lab tests to full-scale without the benefit of additional test facilities. DOE
officials explained that they considered alternatives to ITP as the project
progressed. From 1992 through 1994, comparisons were made between
ITP and alternative technologies. DOE said it determined that risks were
inherent in ITP and the alternative processes but that costs still favored the
ITP process, so the project proceeded.



10Management   Assessment: In-Tank Precipitation Project, Westinghouse Savannah River Company
(Mar. 1992).

11
 Nuclear Waste: Defense Waste Processing Facility—Cost, Schedule, and Technical Issues (GAO/
RCED-92-183, June 17, 1992).




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                                Some of the officials we interviewed characterized the ITP project’s
                                schedule as aggressive, while others described it as a fast-track project in
                                which construction began without a complete design package in order to
                                compress the project’s schedule. Westinghouse managed the project’s
                                start-up phase through parallel activities, according to a former director of
                                the DOE Savannah River High-Level Waste Program. The original
                                scheduled completion date of 1988 was never realistic for a technical
                                project like ITP, according to the director. Because DOE wanted to have
                                the ITP process ready in time to provide precipitate to the Defense Waste
                                Processing Facility, the design of the ITP process was completed at the
                                same time as the construction of the ITP facility and was managed in a
                                reactive manner, according to an ITP program manager.

                                In response to a recommendation in a 1998 National Research Council
                                report,12 the DOE Savannah River High-Level Waste Division Director said
                                DOE is now attempting to manage the high-level waste program, of which
                                ITP is a part, using a systems engineering approach that dictates more
                                testing be done up front.

Oversight and Visibility Were   DOE paid for the ITP project with operating funds instead of capital
Limited by the Project’s        construction funds, which caused the project to receive less oversight and
Budgetary Treatment             visibility. Capital construction projects are subject to periodic reviews and
                                reports, and those costing $5 million or more are shown as line items in the
                                budget requests DOE submits to the Congress.13 Projects paid for with
                                operating funds are not subject to these requirements. DOE officials said
                                they used operating funds for the ITP project because throughout the life of
                                the project, they had expected the technical issues to be solved shortly and
                                thus believed the conversion of the project to a line item in the budget was
                                not warranted.

                                We raised concerns about this budgeting practice in 1992, noting that
                                because projects associated with Savannah River’s Defense Waste
                                Processing Facility were being funded from operating accounts, the
                                Congress was not receiving enough information to fully understand the
                                magnitude of the continuing cost increases and delays.14 DOE, however,


                                12
                                 Assessing the Need for Independent Project Reviews in the Department of Energy, National Research
                                Council (Jan. 1998).

                                13Prior   to fiscal year 1997, capital-funded projects costing $2 million or more were to be line items.

                                14
                                     GAO/RCED-92-183, June 17, 1992.




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                              continued its practice of using operating funds for the ITP project because
                              it considered the technical issues to be solvable in the short term.


Inadequate Understanding      For many years, DOE and its contractors did not completely understand
of the ITP Process Extended   the ITP chemistry that caused excess benzene to be generated. Until
                              recently, the Westinghouse staff at the Savannah River Site believed that
the Project
                              the principal cause was the decomposition of the sodium tetraphenylborate
                              that was added to the high-level waste during the ITP process to precipitate
                              cesium from the waste solution. They believed that the benzene became
                              trapped in the solution and was released because of the addition of water
                              and mixing. In 1997, after a recommendation by the Defense Nuclear
                              Facilities Safety Board, additional research into the chemistry revealed that
                              one or more catalysts were present in the waste solution that reacted with
                              the sodium tetraphenylborate and produced large amounts of benzene.

                              The contractor based its initial belief on the results of a full-scale test
                              conducted in 1983 and on subsequent bench-scale tests. For the 1983 test,
                              sodium tetraphenylborate was added to a tank with about 500,000 gallons
                              of waste. During the test, good separation of high-level waste occurred.
                              However, a significant release of benzene was also observed that for 6
                              hours was higher than the instruments in the tank could register. As a
                              result, additional studies were conducted. In the mid-1980s, work at the
                              University of Florida showed similar benzene phenomena but concluded,
                              incorrectly, that the cause was the benzene’s being trapped in the solution
                              and released by water. Defense Nuclear Facilities Safety Board officials
                              told us that the University of Florida laboratory-scale testing provided an
                              incomplete set of data that was consistent with observed data from the
                              1983 demonstration; however, the university’s approach did not include a
                              systematic evaluation of all potential contributors to benzene generation,
                              retention, and release. The Safety Board also told us that additional tests in
                              1987 and 1994 by the Savannah River Technology Center could not
                              reproduce the high benzene rates. These test results were an indication
                              that the ITP process was not fully understood. In 1994, however, a
                              Westinghouse High-Level Waste Review Committee examined the high-
                              level waste process at the Savannah River Site and concluded that the ITP
                              process was well understood and that the understanding of the chemistry
                              was adequate. Until after the 1995 start-up test, no comprehensive analysis
                              was done to determine why the benzene was being produced and released-
                              -DOE Savannah River and the contractor assumed they knew the reasons.




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According to many DOE ITP project employees with whom we spoke, the
test in 1983 was viewed as successful and provided credibility to the
project’s technology. An ITP engineer told us that the fact that the benzene
level went over the instrumentation scale for 6 hours was not widely
known. The test results that indicated that the release of benzene
exceeded the levels the instrumentation could measure seemed to have
been forgotten over time. For example, two ITP project managers involved
with the project since 1997 told us they were unaware of this aspect of the
test.

During the development of the ITP process, we and the Red Team raised
the following concerns about the ITP process:

• In 1992, we raised concerns about the ITP process’s unresolved
  technical issues and delays and recommended that the Secretary of
  Energy direct that an assessment of an alternative technology (the ion
  exchange process) be prepared to determine whether DOE should
  replace the ITP process.15
• In 1993, the Red Team noted that the chemistry of the ITP process was
  not adequately understood and that ITP appeared to cause more
  problems than it solved. These problems included a need to control
  benzene emissions; increased flammability risks; increased risk from
  aerosols, foams, and respirable particulates; increased chemical
  reactivity of high-level waste leading to possible explosions; and the
  introduction of extremely complex organic chemistry.
• The Red Team also questioned whether sodium tetraphenylborate, the
  chemical used in the ITP process, was the best way to remove cesium
  from the liquid waste. It concluded that effective technologies were
  available and could be implemented. It noted that if the environmental
  regulators in South Carolina adopted a more restrictive benzene
  emissions policy, the entire high-level waste complex, as well as the
  Savannah River Site itself, would be better served by a thorough
  reevaluation of alternative technologies.

DOE Savannah River officials told us that they considered the concerns
that were raised but did not change their approach for a number of reasons.
In their view, in 1992 and 1993, ITP was considered to be the best
technology available for the type of high-level waste the Savannah River
Site had. They said that the ion exchange technology for separating waste


15
     GAO/RCED-92-183, June 17, 1992.




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                           that was in use at that time at the West Valley Site in New York would not
                           have worked effectively on the Savannah River wastes. It was not until late
                           1995 that Sandia National Laboratory developed a new resin for ion
                           exchange that should be able to process the Savannah River Site’s type of
                           waste, according to these officials. They noted that this alternative still
                           poses a significant risk since it has only recently become available and has
                           never been used on Savannah River’s type of waste. In addition, they had
                           believed that they understood ITP’s benzene generation problems and
                           thought the problems had been identified, evaluated, and resolved. A
                           number of modifications were made to the ITP facility, primarily to address
                           the generation of benzene and to meet more stringent safety standards that
                           were adopted for all of DOE’s facilities. Throughout this period, DOE
                           Savannah River officials said that they considered the ITP process to have
                           the lowest technical risk and the lowest cost of all the alternatives. They
                           also noted that until the process was started up, there was no known
                           scientifically based reason to believe that ITP would not be successful as
                           designed.



ITP’s Suspension           The failure of the ITP process has caused DOE to reexamine and modify its
                           approach to cleaning up the high-level waste at Savannah River. If building
Altered the Site’s Plans   and operating the alternative process is delayed, cost increases may be
and Delayed Cleanup        expected because the production of additional glass canisters may be
                           necessary. The potential environmental impacts also may increase if delays
                           cause high-level waste to be stored in the site’s higher-risk tanks.

                           Originally, the plan was to clean up the high-level waste by having the
                           Defense Waste Processing Facility produce glass canisters from a mixture
                           of waste sludge and the high-level precipitate produced by the ITP facility.
                           Westinghouse officials stated that the current plans are to rearrange the
                           schedule to allow sludge-only processing until the high-level waste
                           becomes available from whatever alternative process is used in place of
                           ITP. Officials expect that they can process sludge-only canisters until 2007
                           without affecting the total number of canisters to be ultimately produced
                           (about 5,200 canisters at a life-cycle cost of $13.6 billion to $17.4 billion). If
                           the start-up of the alternative process is delayed beyond that time,
                           Westinghouse officials said they would need to consider slowing down the
                           sludge-only production or consider producing precipitate-only canisters.
                           Either of these options may cause the program’s costs to rise.

                           Slowing down the cleanup could raise costs because leaving the high-level
                           waste in the deteriorating storage tanks for a longer period increases the



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risks of leaks and potential environmental impacts that may require
expensive cleanup efforts. Producing precipitate-only canisters will also
raise costs. When precipitate waste and sludge are used in combination,
the waste dissolves into the glass and does not create additional volume;
hence, fewer canisters need to be made if precipitate and sludge can be
combined. If production is switched to precipitate-only and sludge-only
canisters, extra canisters will have to be made. The present average life-
cycle cost for each canister ranges from $2.6 million to $3.3 million.

Delaying the cleanup will also affect the site’s ability to store newly
generated high-level waste, a problem that carries risks and costs of its
own. Savannah River’s current operations could fill the available storage
space by 2007. The site would then have to build additional tanks or use
older storage tanks that are more prone to leaks to store the newly
generated waste. DOE’s 1998 High-Level Waste Plans state that should the
older tanks be needed, they may have to be upgraded by installing modified
leak detection systems and seals, refurbishing ventilation systems,
repairing or upgrading pumps, and installing waste pipes and valves.

Using these older tanks or delays in building and operating the alternative
to the ITP process may have an impact on an agreement the site has with
the state of South Carolina and the U.S. Environmental Protection Agency.
As part of the agreed waste removal plan and schedule for the site, DOE
has committed to closing certain of the older high-level waste tanks by no
later than 2022.

If no alternative is instituted for the ITP process, other approaches to
cleaning up the wastes in Savannah River’s storage tanks would need to be
investigated. Westinghouse told us that if it is not possible to separate the
high-level and low-level components of the liquid waste, all of the waste
will have to be handled as high-level waste. That would mean processing
the 31 million gallons of liquid waste into glass, yielding an additional
118,000 canisters at an estimated cost of over $75 billion. Recognizing the
magnitude of this approach, DOE officials said that other options would
need to be developed and pursued to address the Savannah River tank
waste.




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DOE Is in the Process    Soon after the suspension of the ITP project, a number of teams were
                         formed to recommend an alternative technology and to evaluate the
of Selecting an          selection process. In October 1998, Westinghouse recommended to DOE
Alternative to ITP       Savannah River that the small tank precipitation process be adopted as the
                         preferred alternative and that the ion exchange process be the secondary
                         option. Westinghouse estimates that it could cost as much as $1 billion and
                         take over 7 years to design, develop, construct, and test either of these
                         alternatives. DOE’s Savannah River office did not agree that there was
                         sufficient differentiation between the options to focus only on small tank
                         precipitation and recommended further development of three
                         technologies: small tank precipitation, ion exchange, and direct disposal in
                         grout. DOE’s Office of Environmental Management approved this
                         approach to explore the three alternatives. (See app. III for additional
                         information on the three alternatives.)


The Selection Process    Soon after the ITP project was suspended, DOE and Westinghouse began
Considered a Number of   activities to select an alternative. At DOE’s direction, Westinghouse
                         established the High-Level Waste Salt Disposition Systems Engineering
Alternatives
                         Team (Westinghouse Systems Engineering Team) in March 1998. This team
                         was composed of employees from Westinghouse and its partners, with
                         outside consultant support from academia, the National Laboratories, and
                         the DOE complex. The purpose of this team was to identify and
                         recommend alternative processing options.

                         The Westinghouse Systems Engineering Team began its study by
                         identifying 142 potential alternatives to ITP. The identification process
                         included coordinating with various National Laboratories and conducting a
                         literature search to define the universe of options. The team then
                         narrowed down the options to 18 alternatives for further evaluation. In
                         July 1998, after these alternatives were studied with visits to the facilities
                         and laboratories involved in their development and use, the team further
                         narrowed the selection to four alternatives. The Westinghouse Systems
                         Engineering Team then performed a risk analysis and evaluation of the four
                         alternatives. Using as criteria cost, technical maturity, risk management,
                         safety, professional judgment of the team, historical experience, and the
                         needs of the Savannah River Site and the DOE complex, the team
                         recommended a preferred alternative and a secondary option.




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                  In addition to the Westinghouse Systems Engineering Team, other teams
                  were formed to assist in the process (app. IV provides additional
                  information on the various teams):

                  • The Independent Project Evaluation Team (Independent Review Team),
                    established by DOE headquarters, was to independently provide
                    oversight of the process being followed in selecting the alternative.
                  • The Savannah River Review Team, established by DOE Savannah River,
                    was to oversee the Westinghouse Systems Engineering Team.
                  • The Westinghouse Review Panel Team, established by Westinghouse,
                    was to provide oversight and input on the approach and decision-
                    making process for the final selection of the preferred alternatives. It
                    has concurred with the Westinghouse Systems Engineering Team’s
                    recommendation.


Westinghouse      On October 29, 1998, Westinghouse recommended the use of small tank
Recommended Two   precipitation. This process is similar to the ITP process. It uses the same
                  chemical to cause the precipitation of the high-level waste constituents,
Alternatives
                  and as a result, benzene is generated. However, several differences exist.
                  For example, two 15,000-gallon tanks would be used to treat the high-level
                  waste instead of two 1.3 million-gallon tanks, allowing for the process to be
                  completed in about 24 hours rather than taking weeks and thus reducing
                  the time during which benzene could build up in the tanks. In addition, the
                  tanks would be made of stainless steel and cooled to reduce chemical
                  volatility and benzene production. With these features, Westinghouse
                  believes that the process can be used safely and effectively.

                  In its final report, the Westinghouse Systems Engineering Team noted that
                  while the small tank precipitation process did not have the lowest life-cycle
                  cost, it had the lowest project construction cost, the highest scientific
                  maturity, and the most manageable risk and was judged to have the highest
                  likelihood of success.16 In addition, the report noted that the safety
                  concerns caused by the generation of flammable benzene were considered
                  and were addressed.

                  As a backup technology, the Westinghouse Systems Engineering Team
                  selected crystalline silicotitanate non-elutable ion exchange. This process


                  16
                    Final Report, High-Level Waste Salt Disposition Systems Engineering Team, Westinghouse, RP-98-
                  00170 (Dec. 1998).




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uses a crystalline silicotitanate resin to remove the cesium and
monosodium titanate to remove the strontium, plutonium, and uranium in
the liquid waste. Ion exchange has been used at DOE’s Hanford and West
Valley sites. However, the process recommended for Savannah River
would use a different type of resin to cause the separation of the high-level
waste. Crystalline silicotitanate was developed by Sandia National
Laboratory and has been demonstrated on a small scale at Oak Ridge
National Laboratory. It was selected as the second option because of its
costs, its scientific maturity, and the opportunity for recovery from process
performance problems.

The Savannah River Review Team evaluated the recommendations offered
by Westinghouse. The team concluded that the information evaluated in the
selection process and the resulting conclusions were not sufficiently
discriminating to select a preferred alternative. The team recommended
that additional research and development activities be undertaken to
address the technical uncertainties associated with the ion exchange and
small tank precipitation technologies. In addition, the team concluded that
the option of direct disposal in grout should not be eliminated from
consideration because it provides a way to significantly reduce
construction and operating costs and the team had high confidence in its
technology, safety, and technical feasibility. As a result, the Savannah River
Review Team recommended actions be initiated to identify and resolve the
potential regulatory, public, and legal risks and uncertainties associated
with this option. Table 1 compares the costs and schedules for the small
tank precipitation, ion exchange, and grout processes.17




17
  High-Level Waste Salt Disposition Systems Engineering Team. Dollars presented are escalated for
inflation.




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Table 1: Cost and Schedule Data for Westinghouse’s Recommended Alternatives

                                                               Small tank
                                                               precipitation              Ion exchange                Disposal in grout
Project capital cost                                           $751 million               $843 million                $691 million
Other project costs                                            $417 million               $463 million                $300 million
Estimated life-cycle cost                                      $3,440 million             $3,081 million              $2,335 million
Estimated plant start-up                                       May 2006                   March 2007                  March 2006
Estimated plant start-up, with contingency                     May 2010                   January 2012                June 2015
Baseline date for tank emptying                                October 2020               March 2020                  April 2018
Date for tank emptying, with contingency                       July 2024                  February 2025               April 2028

                                             The Independent Review Team established by DOE headquarters found
                                             that both the small tank precipitation and ion exchange alternatives are
                                             technically feasible and should meet all of Savannah River’s high-level
                                             waste requirements. The team, using the same evidence and qualitative
                                             selection criteria that the Westinghouse Systems Engineering Team used,
                                             also found that ion exchange could have been selected as the preferred
                                             alternative. The Independent Review Team agreed that direct disposal in
                                             grout should be eliminated as an alternative because of large uncertainties
                                             involving institutional and regulatory issues.18 The Independent Review
                                             Team recommended that (1) all essential research and development
                                             activities be completed for both alternatives, (2) quantitative criteria be
                                             formulated and applied at the end of the research and development
                                             activities to choose the primary alternative, and (3) a conceptual design
                                             phase be initiated but complete only those activities common to both
                                             alternatives until the primary alternative is chosen.

                                             The Independent Review Team disagreed with the Westinghouse Systems
                                             Engineering Team’s inclusion of $557 million in the cost of the ion
                                             exchange option to operate an incinerator over the life of the project. The
                                             Independent Review Team noted that the incinerator is not necessary for
                                             ion exchange and that excluding its cost would, over the life of the project,
                                             make ion exchange over $1 billion less expensive than the small tank

                                             18
                                                The Independent Review Team noted that direct disposal in grout would require a full environmental
                                             impact statement be done. In addition, the team concluded that the grout containing the cesium would
                                             need to be reclassified by the Nuclear Regulatory Commission as incidental waste from high-level
                                             waste, which could require many years to complete. In commenting on a draft of this report, DOE
                                             stated that an environmental impact statement is under way considering all three alternatives. In
                                             addition, DOE commented that it, rather than the Nuclear Regulatory Commission, will make the
                                             incidental waste determination since this activity is covered by the Atomic Energy Act.




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              B-281907




              process. Westinghouse officials told us that they disagree and that the
              incinerator costs should be included in the cost of all options. They said
              that the incinerator is already constructed and will be operated regardless
              of the option selected. In addition, the officials told us that the benzene
              produced by the small tank process would be used as fuel for the
              incinerator, reducing the need to purchase fuel.

              DOE Savannah River plans to conduct additional research and testing to
              further evaluate the technical, regulatory, and public acceptance risks
              associated with the three alternatives. (See app. V for information on the
              planned research, testing, and other activities to be conducted before a
              selection decision is made.) Because the three alternatives constitute a
              change in the previously planned operations, a supplemental
              environmental impact statement will be prepared to determine if a
              proposed action is (1) compatible with existing regulatory requirements,
              (2) acceptable to regulatory agencies, and (3) acceptable to the general
              public. DOE Savannah River is also studying ways to maximize the site’s
              existing storage tank space to accommodate any of the three alternatives.
              DOE plans to complete the research and testing activities necessary to
              identify a preferred alternative by September 30, 1999. DOE headquarters
              will make the final decision on the preferred alternative and expects a
              record of decision document to be completed by mid-2000.



Conclusions   A number of factors contributed to the delays and cost increases of the in-
              tank precipitation project. In our view, among the most important were
              ineffective management and oversight. This project was not handled the
              way a high-risk, first-of-a-kind construction project should be, and as a
              result, the associated program structures and project designs were not
              adequate. Allowing the project to be funded with operating funds rather
              than making it a capital line item contributed to this situation because it
              limited the visibility of the project. Additionally, while the Department of
              Energy’s award fee process noted numerous significant deficiencies on the
              part of the contractor, there is no evidence that the deficiencies affected
              the fees until 1998.

              Another contributing factor was the lack of adequate early testing and a
              complete understanding of the in-tank precipitation process. In 1983, when
              the first test was conducted, benzene was produced in amounts that went
              off the scale of the tank’s instruments. However, the test was viewed as a
              success because the high-level waste was separated from the solution.
              Even though we, the Red Team, and others raised concerns, the



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                  Department of Energy and the contractor assumed they knew the reason
                  for the benzene problem and thought they could work out a solution, so
                  they proceeded. Unfortunately, the testing that was done did not correctly
                  identify the specific cause of the excess benzene nor were large-scale tests
                  attempted again before Westinghouse started up the facility in 1995.

                  Since the project’s suspension, the Department and Westinghouse have
                  taken steps that, if fully implemented, should better ensure a successful
                  alternative. For example, the Department and Westinghouse have
                  identified and evaluated numerous alternatives to the in-tank precipitation
                  process. Independent review processes are being used to consider
                  alternatives as well as to examine the selection process being used.



Agency Comments   We provided a draft of this report to the Department of Energy for its
                  review and comment, and the Department provided its comments in a
                  letter and three enclosures. The letter and enclosure I, which contain the
                  Department’s overall comments and a historical and technical perspective
                  on the in-tank precipitation project, are included in this report as appendix
                  VI. DOE’s enclosures II and III, which are not included in this report,
                  contain more detailed comments that we incorporated into the report as
                  appropriate.

                  DOE recognized that weaknesses within the Department and on the part of
                  the contractor contributed to the failure of the in-tank precipitation
                  process. Moreover, DOE stated that it recognized that there were
                  management and oversight issues identified that were not adequately
                  addressed in a timely fashion. DOE also pointed out two other reasons for
                  the difficulty with the in-tank precipitation project: (1) The project was
                  attempting to solve a very challenging technical problem in that no proven
                  technologies were available for the Savannah River high-level waste
                  stream, and (2) the project was implemented at a time of rapidly changing
                  standards as the DOE complex made the transition from chemical to
                  nuclear safety standards. We agree that the two factors that DOE cited
                  could have contributed to the delays and cost growth. For example, our
                  report discusses the technical challenges that DOE and the contractor
                  faced and identifies the changing standards as a reason for some of the
                  delays. While these factors contributed to the delays and cost growth, the
                  weaknesses in management and oversight were the primary factor.

                  DOE also stated that it has taken a number of positive steps in the past 18
                  months to ensure that a safe, economical, and high-confidence alternative



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              is successfully implemented to treat the Savannah River Site’s tank waste.
              Examples the Department cited include (1) the use of a disciplined systems
              engineering approach in the selection of final alternatives; (2) the use by
              both headquarters and Savannah River of independent review teams to
              provide oversight feedback directly to senior management; (3) the use of
              pilot-scale demonstrations to validate technology and engineering; (4) a
              higher level of safety awareness for all aspects of activities at Savannah
              River through the implementation of DOE’s Functions, Responsibilities,
              and Authorities Manual; and (5) the application of lessons learned not only
              to project management but also to high-level waste processing across
              DOE’s complex. This report discusses many of the activities that DOE
              identified. While DOE has taken a number of actions that, if fully
              implemented, should better ensure a successful alternative will be found, it
              will be many months before the selection process is complete and the
              alternative selected is ultimately built. Until that time, it will not be known
              whether these activities have been sufficient to achieve the desired results.



Scope and     To examine the factors for the ITP project’s delays and cost growth, we
              examined various internal and external reports about ITP and the high-
Methodology   level waste cleanup process. In addition, we interviewed DOE and
              contractor officials involved with the project at the Savannah River Site in
              South Carolina and officials at DOE headquarters in Washington, D.C. We
              also discussed the issues with officials of the Defense Nuclear Facilities
              Safety Board and DOE’s Office of Inspector General and with the
              University of Florida professor who was involved with ITP testing.

              To determine the effect of the ITP project’s suspension on the Savannah
              River Site’s cleanup plans and costs, we examined the site’s cleanup plans
              prior to the suspension and afterwards. We also interviewed DOE and
              contractor officials to get their views on any potential impact that the
              suspension may have on the cleanup program.

              To gather information on DOE’s plans for developing an alternative
              technology, we met with the leader of the Westinghouse Systems
              Engineering Team. We also reviewed the team’s final report and the
              supporting documents generated by the team. We discussed the final
              selection with DOE officials at the Savannah River Site and reviewed the
              final report completed by DOE headquarters’ Independent Review Team.

              We conducted our work from April 1998 through April 1999 in accordance
              with generally accepted government auditing standards.



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As arranged with your office, we plan no further distribution of this report
until 15 days after the date of this letter unless you publicly announce the
contents earlier. At that time, we will send copies to the Honorable Bill
Richardson, Secretary of Energy; the Honorable Jacob Lew, Director,
Office of Management and Budget; and other interested parties. We will
make copies available to others on request.

If you or your staff have any questions about this report, please contact me
at (202) 512-3841. Major contributors to this report were Gene M. Barnes,
Gary Malavenda, and Glen Trochelman.

Sincerely yours,




(Ms.) Gary L. Jones
Associate Director, Energy,
 Resources, and Science Issues




Page 21                              GAO/RCED-99-69 In-tank Precipitation Facility
Contents



Letter                                                                         1


Appendix I                                                                    24
Cost of the In-Tank
Precipitation Project
and Its Associated
Facilities

Appendix II                                                                   25
Examples of ITP
Deficiencies Identified
by the Award Fee
Board

Appendix III                                                                  30
Final Three Alternative
Technologies

Appendix IV                                                                   31
Characteristics of
Teams Involved in
Selecting Alternatives
to the ITP Process

Appendix V                                                                    32
Research, Testing, and
Other Activities
Planned to Support the
Final Technology
Decision

                          Page 22   GAO/RCED-99-69 In-tank Precipitation Facility
                       Contents




Appendix VI                                                                                         37
Comments From the
Department of Energy

Tables                 Table 1: Cost and Schedule Data for Westinghouse’s Recommended
                         Alternatives                                                               17




                       Abbreviations

                       CST        crystalline silicotitanate
                       DOE        Department of Energy
                       GAO        General Accounting Office
                       ITP        in-tank precipitation



                       Page 23                            GAO/RCED-99-69 In-tank Precipitation Facility
Appendix I

Cost of the In-Tank Precipitation Project and
Its Associated Facilities                                                                                                  AppIexndi




               Dollars in thousands
                                              Total estimated
                                                construction         Other project          Operating
               Facility                                 costs              costsa               costb                 Total
               In-tank precipitation                   $157,096           $151,234             $18,800           $327,130
               Late wash facilityc                        51,720             10,334               4,000             66,054
               Salt process      celld                    15,000             15,000                     -           30,000
               Organic waste storage                        4,000              1,000                    -             5,000
               tanke
               Saltstone facilityf                        25,392               2,539             32,698             60,629
               Total                                   $253,208           $180,107             $55,498           $488,813
               aOther    project costs include testing, training, and operational readiness reviews.
               b
                   Operating costs include the cost to run the facility after it became operational.
               c
                 This facility reduces the nitrite concentration of the precipitate from the in-tank precipitation (ITP)
               process. If not removed, nitrites could foul the Defense Waste Processing Facility’s heat transfer
               surfaces and plug filters and instrumentation.
               dThis    part of the Defense Waste Processing Facility prepares the precipitate to be fed to the melter.
               e
                   This tank stores benzene for recovery.
               f
                 This facility processes low-level radioactive liquid waste from the ITP facility. The waste remaining
               after the high-level precipitate has been removed is mixed with a blend of cement, fly ash, and blast
               furnace slag to form a grout. This grout is pumped into disposal vaults where it hardens into a
               nonhazardous form of waste.
               Sources: The Department of Energy and Westinghouse Savannah River Corporation.




               Page 24                                                GAO/RCED-99-69 In-tank Precipitation Facility
Appendix II

Examples of ITP Deficiencies Identified by the
Award Fee Board                                                                                   ApIpexndi




               The following examples of deficiencies were identified in Department of
               Energy’s (DOE) Award Fee Board reports covering the period from April 1,
               1990, through March 31, 1998. The deficiencies are shown in chronological
               order.

               April 1, 1990-September 30, 1990. Progress was slow in the
               establishment of detailed schedules and in commitment to meeting
               scheduled dates. Schedules were finally developed for the in-tank
               precipitation (ITP) project but lacked some required details for the
               operations readiness and start-up reviews.

               October 1, 1990-March 31, 1991. Overall start-up management and
               planning is weak (in reference to efforts to meet or exceed commercial
               nuclear industry standards). The lack of overall planning and management
               of restart and start-up activities for ITP continues to further impose delays.

               April 1, 1991-September 30, 1991. The contractor’s performance in the
               ITP start-up activities fell far below expectations as evidenced by a lack of
               commitment to the continually revised schedules. Overall start-up
               management is weak for ITP; Westinghouse’s commitment to schedule is
               lacking. The scheduled start-up for ITP was delayed during this period
               from April 1991 to early 1992. The schedule currently presented to DOE
               has several deficiencies, and it appears that start-up will be further delayed.
               DOE has identified concerns in training, testing, operations readiness
               review, design basis documentation, and the quality of the schedules. The
               management of ITP is a carryover concern from the last award fee period,
               and no improvements have been made. In fact, DOE’s concern has
               heightened over this period. Immediate Westinghouse management
               attention is required to correct this problem. Westinghouse submitted an
               integrated plan for interim waste activities, but there is a concern that
               these schedules may not be effectively treated as a management tool. It
               appears that Westinghouse facility managers are not held accountable to
               these schedules.

               October 1, 1991-March 31, 1992. Management attention was needed to
               ensure the inclusion of complete resource loading for the ITP schedules.
               ITP project work also experienced some problems with project costs. The
               culture change required to improve the conduct of operations sitewide has
               not been effectively emphasized by lower-level management to bring it to
               reality.




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Appendix II
Examples of ITP Deficiencies Identified by
the Award Fee Board




April 1, 1992-September 30, 1992. Westinghouse delayed initiation of
the DOE operational readiness review for the ITP simulant testing phase
because of major deficiencies in the ITP training program. Although this
caused delays in the overall schedule, Westinghouse’s decision to delay the
operations readiness review probably avoided even more significant delays
in the schedule had the training deficiencies not been resolved. The
potential for ITP to experience considerable cost overruns was identified in
April, and the revised budget remains undefined. Performance against
planned work was not adequately monitored, technical documents had
deficiencies indicating a lack of management attention, and performance of
the waste removal program was poor because of the lack of basis and
adequate planning for waste removal to support the Defense Waste
Processing Facility.

October 1, 1992-March 31, 1993. The milestones for initiating
radioactive operation of ITP and starting removal from one storage tank,
Tank 41, were not met. This is evidence of continued poor planning and
management of activities associated with ITP. An unanticipated criticality
issue prevented the milestone to start the removal of waste from Tank 41
from being realized and has required new efforts to identify alternative feed
sources for ITP. A number of prominent technical issues, such as the soils
and geotechnical issue and the benzene stripper issue, continue to delay
ITP start-up.

April 1, 1993-September 30, 1993. Major program milestones were not
met for ITP. Poor budget management resulted in the curtailment of key
activities late in the fiscal year. Because of poor implementation of the cost
collection and maintenance system, Westinghouse reported a shortage of
funding for important programs, including ITP, that would delay work.
Westinghouse has not performed adequate staffing reviews. Engineering
support for equipment and process problems at ITP has been poor.
Weaknesses in the general management of the ITP project resulted in
Westinghouse not being ready for facility start-up. The ITP start-up
schedule revision has not been submitted, even though it has been known
for several months that the October 20, 1993, operations readiness review
date was unachievable. A realistic date for being ready to start the
operations readiness review has not yet been determined. Several other
plant modifications that remain to be completed could further delay the
schedule.

April 1, 1994-September 30, 1994. Cost and schedule overruns incurred
at ITP were not adequately managed to minimize the impact (i.e.,



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Appendix II
Examples of ITP Deficiencies Identified by
the Award Fee Board




forecasting was not timely, effective workarounds were not proposed).
Senior Westinghouse management effort on cost reduction and
productivity initiatives appears to be diminishing, is not integrated, and
lacks creativity and innovation. Inadequate planning resulted in items
being identified by the ITP readiness self-assessment that contributed to
cost overruns. ITP operators have not been adequately trained prior to
conducting drills on emergency operating procedures. Westinghouse did
not take the actions necessary to prevent procedure development from
becoming a critical path to the operations readiness review, and this has
contributed to a delay in the start of the Westinghouse operations readiness
review and potentially in the start of operations. Management of the
readiness self-assessment process following initial field assessments was
not effective in supporting the schedule. Finding closure was not well
organized, and management did not readily make a clear, defensible
declaration of readiness to start the Westinghouse operations readiness
review. Cost overruns on ITP required downturns in other high-level waste
programs during the last half of fiscal year 1994. Downturn actions were
initiated with little or no communication with DOE counterparts.
Consequently, some items that were thought to be priority tasks were
eliminated without DOE’s concurrence. Management attention needs to be
focused on cost control. Accountability for maintaining cost control needs
to be established as a management priority. Cost reduction and
productivity efforts have diminished from what was a fairly aggressive
program at the beginning of the period. Proposed reductions to meet fiscal
year 1995 budget reduction goals lacked innovation and were not
aggressive. Most efforts in this area are driven by DOE’s initiatives.

October 1, 1994-May 31, 1995. ITP scheduling remains a significant
weakness in that it is not always resource-loaded properly, resulting in
missed milestones (e.g., the radiological operations start date is projected
to slip). The commitment date for ITP operating safety requirement
implementation was missed, and a revised commitment date was not
provided. The ITP schedule for completing the activities that are required
to start operations in July 1995 is projected to slip until September 1995 or
later. Schedule deficiencies continue at ITP in that the schedules are not
resource-loaded to project realistic and achievable milestone dates in all
cases. Improvement in recovery planning is needed at ITP to minimize
schedule slippage. ITP lacked aggressive effort to resolve readiness self-
assessment and Westinghouse operations readiness review findings.

October 1, 1995-March 31, 1996. Effective management of critical
engineering issues, project activities, and technology development



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Appendix II
Examples of ITP Deficiencies Identified by
the Award Fee Board




demonstrations at ITP and the tank farms do not meet DOE’s expectations
in that they are not timely or properly resource-loaded to meet projected
schedules. While the ITP benzene issue is a key issue, no single manager
has been designated overall responsibility for resolving it. Schedule logic
and supporting details are not identified. Implementation of the resolution
program for the ITP benzene issue has been fragmented and is not
integrated. In addition, the plan does not clearly identify the actions
necessary to develop a bounding model for benzene generation and release
for future operations. Conduct-of-operations issues were experienced that
involved status control and conduct of special procedures. System status
control involving special procedures resulted in the failure to maintain
proper system status during the performance of a special procedure, which
led to the inadvertent draining of an ITP filter. Communication failure had
a further impact on this multifacility operation, causing uncoordinated
efforts between a tank farm and ITP.

April 1, 1996-September 30, 1996. Progress at ITP toward the
resolution of benzene problems for the precipitate feed to the Defense
Waste Processing Facility was slow. There has been a lack of significant
progress. Significant weaknesses exist in management’s commitment to
the resolution of technical issues, which resulted in inefficiencies in
engineering services, schedule slippage, and ultimately rendered the high-
level waste system inoperable for precipitate feed. Conduct of operations
was less than expected at ITP. During the rating period, management and
leadership did not pursue issues in an effective and integrated manner to
resolve the benzene issue, even with emphasis from DOE. The lack of final
needs input from the chemistry team and authorization basis is resulting in
at-risk designs and schedules. What was projected as a $13 million safety
upgrade in August 1996 has grown to an estimated $28.06 million. An
additional concern is the number of lapses in conduct of operations. The
contractor did not fully meet customer expectations in terms of bringing
ITP into fully integrated operation because of the excessive benzene
generated in the process. DOE’s main concern from the last report—that
is, poor project management resulting in schedule slippage and cost
overruns--was not adequately addressed.

October 1, 1996-March 31, 1997. System status control execution at ITP
is below DOE’s expectations. The development of a path forward and
progress toward the resolution of the ITP vapor space mixing issue
(testing, computer modeling) were unacceptable in support of the ITP
safety analysis report development. This issue was critical to the
successful resolution of the Defense Nuclear Facilities Safety Board’s



Page 28                                      GAO/RCED-99-69 In-tank Precipitation Facility
Appendix II
Examples of ITP Deficiencies Identified by
the Award Fee Board




Recommendation 96-1 and to providing a defensible safety basis for
resuming ITP processing. Attention by Westinghouse management is
needed on the resolution of these issues. Several operational programs
have not progressed as expected. During a January 1996 assessment at ITP,
DOE staff identified numerous deficiencies with the system status files that
resulted in a concern being issued. DOE staff again looked at the status
files in October 1996, and although a noticeable improvement was evident,
numerous deficiencies were still noted.

April 1, 1997-September 30, 1997. ITP had several events that indicated
the need for increased personnel awareness of authorization basis
requirements as well. Examples included the failure to recognize the
requirements for slurry pump lockout during air-based operations and the
use of inoperable equipment to satisfy limited condition for operation
action items. While increased management attention resulted in significant
improvements in many areas, improvement in the basic conduct of
operations principles did not meet DOE’s expectations for the ITP
facilities. Of particular concern was the number of instances involving the
failure to execute the fundamental principle of procedural compliance, and
the number of minor equipment and programmatic deficiencies identified
by DOE personnel that were not been previously identified by facility
personnel and entered into corrective action processes.

October 1, 1997-March 31, 1998. At the ITP facility, high liquid level
conductivity probes were positioned incorrectly, which failed to preserve
assumptions from the safety analysis review. The distributed control
system replacement work at the ITP control room was behind schedule
because it was not well planned; the outage was disorganized without a
predetermined path to complete, test, and exit the outage. Completion of
ITP cost project physical work was slower than expected. Facility
modifications were scheduled to be completed for a June 1997 start-up,
then for an October 1997 start-up, and then for a January 1998 start-up.
None of the dates were met.




Page 29                                      GAO/RCED-99-69 In-tank Precipitation Facility
Appendix III

Final Three Alternative Technologies                                                                                                          AIpIexndi




Alternative                               Description
Small tank precipitation                  This process involves adding sodium tetraphenylborate to remove cesium and monosodium
                                          titanate to remove strontium, plutonium, and uranium. Once these radioactive elements are
                                          removed, some additional processing is done. The solidified chemicals would then be sent to
                                          the Defense Waste Processing Facility for vitrification.
Crystalline silicotitanate ion exchange   A crystalline silicotitanate resin is used to remove cesium, and monosodium titanate is used to
                                          remove strontium, plutonium, and uranium. Once these radioactive elements are removed,
                                          some additional processing is done. The solidified chemicals would be sent to the Defense
                                          Waste Processing Facility for vitrification.
Direct disposal in grout                  In this process, the cesium is not separated from the liquid waste. Instead, the salt solution is
                                          made directly into grout. Monosodium titanate would be used to remove strontium, plutonium,
                                          and uranium; after some additional processing, these radioactive elements would be sent to the
                                          Defense Waste Processing Facility for vitrification.
                                               Source: Westinghouse Savannah River Corporation.




                                               Page 30                                       GAO/RCED-99-69 In-tank Precipitation Facility
Appendix IV

Characteristics of Teams Involved in Selecting
Alternatives to the ITP Process                                                                                                     ApV
                                                                                                                                      Ienxdi




Review team               Members                            Charter and timeframes
Westinghouse Systems      10 members                         Formed in March 1998 by Westinghouse at DOE’s direction.
Engineering Team          (6 from Westinghouse, 3 from
                          external contractors, and 1 from a Determine the best path forward for processing liquid waste.
                          university affiliate)
                                                             Recommendations were provided to DOE Savannah River on October
                                                             29, 1998.
Savannah River Review     10 members                         Formed in March 1998 by DOE Savannah River.
Team                      (8 from DOE Savannah River’s
                          High-Level Waste Division and 2    Provide technical oversight of the day-to-day activities of the
                          from DOE Savannah River’s          Westinghouse Systems Engineering Team.
                          Science and Technology
                          Division)                          Review System Engineering Team’s results and provide a
                                                             recommendation to the Manager of Savannah River.

                                                             Final site team report issued on December 17, 1998.
Independent Review Team   11 members                         Formed in June 1998 by DOE headquarters.
                          (2 from DOE, 8 from private
                          firms, and 1 from a university     Evaluate the process used by, and the results of, the Westinghouse
                          affiliate)                         Systems Engineering Team.

                                                             Review the cost estimates developed by the Systems Engineering
                                                             Team.

                                                             Final review and assessment issued on December 26, 1998.
Westinghouse Review       8 members                          Formed in June 1998 by Westinghouse.
Panel Team                (4 senior Westinghouse
                          managers and 4 outside             Provide oversight and input on the approach and the decision-making
                          consultants)                       process for the final selection of the preferred alternative(s).

                                                             Final report issued November 14, 1998.
                                           Sources: Westinghouse Savannah River Corporation and the Department of Energy.




                                           Page 31                                      GAO/RCED-99-69 In-tank Precipitation Facility
Appendix V

Research, Testing, and Other Activities
Planned to Support the Final Technology
Decision                                                                                          ApV
                                                                                                    enxdi




                DOE Savannah River and Westinghouse are planning to conduct additional
                research and testing before selecting the preferred alternative technology
                for processing the high-level waste at the Savannah River Site. The alterna-
                tive technologies under consideration are small tank precipitation, ion
                exchange, and direct disposal in grout. DOE has developed a management
                plan that describes the actions necessary to (1) further evaluate the techni-
                cal, regulatory, and public acceptance risks associated with the three alter-
                natives; (2) initiate a supplemental environmental impact statement to
                address the alternatives; and (3) further develop the management strate-
                gies for the site’s high-level waste tanks. In addition, a scope-of-work
                matrix has been prepared for each alternative that identifies such items as
                the testing and development activities to be undertaken, their costs, and
                the organizations involved.



Small Tank      The purpose of the small tank precipitation experimental program outlined
                for fiscal year 1999 is to demonstrate that cesium and strontium can be
Precipitation   removed from high-level radioactive waste using a continuous process.
                The precipitation of cesium by tetraphenylborate and the absorption of
                strontium with monosodium titanate have only been demonstrated on a
                batch scale. This proof-of-concept testing has several components,
                including the following:

                • Proper sizing of the components for the continuous processing of the
                  waste is to be determined. Tests are planned in a single continuous test
                  unit to provide such data. These tests will develop data for cesium and
                  strontium removal that will be used to operate the small-scale
                  continuous integrated tests.
                • The impact of washing the sodium from the precipitate is to be studied
                  to ensure that the excess sodium tetraphenylborate that is added to the
                  waste is removed before the precipitate is transferred to the Defense
                  Waste Processing Facility. Tests that determine the dissolution rate will
                  be used to answer this question.
                • Tests are also to be conducted to demonstrate that the filtration
                  required for continuous concentration and washing can be done using
                  equipment that has been demonstrated on a batch basis.

                The results of these tests will be used to provide input for a small-scale
                integrated test that will demonstrate the feasibility of a continuous small
                tank process. These tests will use simulated waste solutions. An
                integrated test using actual waste will be conducted to demonstrate that



                Page 32                               GAO/RCED-99-69 In-tank Precipitation Facility
               Appendix V
               Research, Testing, and Other Activities
               Planned to Support the Final Technology
               Decision




               the simulated tests are representative of the actual expected performance
               of the small tank precipitation process. Testing will also examine the
               continuous stirred tanks and verify that the product from the small tank
               process is compatible with the Defense Waste Processing Facility’s
               requirements. DOE estimates that it will spend about $2 million to conduct
               the research and testing on the small tank precipitation process.



Ion Exchange   One of the principal alternatives to ITP in the 1980s and early 1990s was a
               process referred to as resorcinol-formaldehyde ion exchange. In this
               process, originally developed at the Savannah River Site, a bed of resin-like
               material would capture cesium as waste solution passes over the resin.
               The resin, in this case resorcinol-formaldehyde, would then be washed to
               remove the cesium. DOE officials told us that while this process was a
               promising alternative, significant technical issues and potential costs were
               involved. For example, there were problems with the resin’s swelling and
               shrinking, the instability of the resin in the presence of various chemicals
               and in the presence of radiation, the generation of gases, and a complex
               pretreatment that was required. In 1983, DOE’s contractor estimated that
               the cost of using this technology was similar to the cost of ITP, but the need
               for and cost of additional research and development led to the selection of
               ITP. DOE officials said they continued working on this resin until 1993,
               when work was halted because of budget constraints. DOE was unable to
               provide an estimate of the costs associated with this development effort
               because it funded the activities with operating funds.

               Crystalline silicotitanate (CST) ion exchange was invented by researchers
               at Texas A&M University and Sandia National Laboratory in 1992. CST ion
               exchange appeared to offer a number of advantages over other types of ion
               exchange. For example, it appeared to work on a wide variety of wastes.
               In 1993, as part of DOE’s Office of Science and Technology programs,
               Sandia and a company, UOP, entered into a cooperative research and
               development agreement in which UOP was to develop CST in powder form
               and in an engineered form (beads, pellets, or granules) suitable for ion
               exchange use. It took UOP about 18 months to complete its efforts. In
               1996, Oak Ridge National Laboratory began operating the Melton Valley
               demonstration project, which uses the CST ion exchange technology. Over
               an 8-month period, Oak Ridge processed more than 30,000 gallons of waste




               Page 33                                   GAO/RCED-99-69 In-tank Precipitation Facility
                     Appendix V
                     Research, Testing, and Other Activities
                     Planned to Support the Final Technology
                     Decision




                     and removed more than 1,000 curies of cesium.1 Oak Ridge plans to
                     continue using the demonstration plant to separate the cesium from its
                     tank waste. DOE estimates that about $25 million was spent developing
                     and demonstrating the CST ion exchange process.

                     DOE Savannah River and Westinghouse have identified a number of
                     uncertainties with the CST ion exchange process. The management plan
                     identifies research and development to be conducted to address the
                     following issues:

                     • the effect of the waste solution, pressure, and processing flow rates on
                       CST capacity;
                     • gas generation within the ion exchange column and its effect on
                       performance;
                     • heat generation by radiological decay of large accumulated quantities of
                       cesium and its impact on CST’s stability, waste steam, and heat removal;
                     • chemical stability during long-term exposure to heat and the process
                       stream;
                     • CST’s performance on actual Savannah River waste; and
                     • Defense Waste Processing Facility glass issues, including the effect of a
                       component of CST (titanium) that may exceed the current glass limits
                       and operational issues associated with hydrogen generation and
                       potential foaming.

                     To conduct some of these tests, a bench-scale ion exchange column will be
                     used on actual Savannah River waste. In addition, some tests have been
                     conducted at Oak Ridge National Laboratory’s demonstration plant that
                     uses the CST ion exchange technology. About $2.5 million is expected to
                     be spent conducting the ion exchange activities during fiscal year 1999.



Direct Disposal in   The direct disposal in grout alternative is based on what DOE considers to
                     be generally mature and viable technology. Testing is planned to address
Grout                (1) the use of monosodium titanate, which is needed to ensure that the
                     grout waste form does not exceed radioactive concentration limits, and (2)
                     the leaching characteristics of the grout waste form and its physical
                     characteristics and stability. Other physical properties of the waste form


                     1
                       A curie is the amount of radioactivity in 1 gram of radium. DOE officials told us that the concentration
                     of cesium in the Savannah River Site’s waste is about 150 times that of the Oak Ridge waste that was
                     processed.




                     Page 34                                             GAO/RCED-99-69 In-tank Precipitation Facility
                      Appendix V
                      Research, Testing, and Other Activities
                      Planned to Support the Final Technology
                      Decision




                      will be tested to determine whether they meet DOE’s requirements. For
                      example, according to the management plan, the waste must exhibit higher
                      resistance to cracking when compressed than a similar waste containing a
                      much lower concentration of cesium.

                      DOE Savannah River will take additional actions to evaluate the regulatory,
                      legal, and public acceptance risks associated with the direct disposal in
                      grout alternative. These actions include the following:

                      • development of an “incidental waste” determination to support disposal
                        of the cesium in grout;
                      • discussion and consultation with DOE headquarters’ organizations;
                      • feedback discussions with the U.S. Environmental Protection Agency
                        and the South Carolina Department of Heath, Environment, and
                        Conservation; and
                      • feedback discussions with the Citizen’s Advisory Board and the South
                        Carolina Governor’s Office.



Oversight and Final   According to the management plan, the DOE Savannah River Review Team
                      will provide technical oversight of Westinghouse’s day-to-day activities,
Selection             including attending meetings and discussions, reviewing test plans and
                      engineering documents, and evaluating test results. The team will also
                      review the final results and provide a recommendation to the DOE
                      Savannah River Manager about which of the three alternative technologies
                      should be used. The recommendation is to be based on a selection process
                      that involves both quantitative and qualitative evaluations of the
                      alternatives. For example, a level of confidence will be developed for each
                      alternative in the areas of technical uncertainty, schedule and mission
                      impacts, safety and environmental impacts, and regulator and public
                      acceptance. An evaluation of life-cycle and project costs will be
                      considered in comparing the alternatives and will be weighed against the
                      levels of confidence.

                      The Independent Review Team organized by DOE headquarters is
                      continuing to provide oversight to the Westinghouse and Savannah River
                      activities. The team will conduct an assessment of the research and
                      development plan, perform an analysis of its implementation, review test
                      results, and offer advice and assistance on technical issues to
                      Westinghouse and DOE Savannah River.




                      Page 35                                   GAO/RCED-99-69 In-tank Precipitation Facility
Appendix V
Research, Testing, and Other Activities
Planned to Support the Final Technology
Decision




After the Savannah River Review Team makes its recommendation, the
Savannah River Manager will consider it and provide a recommendation to
DOE’s Environmental Management office. Environmental Management,
with input from the Independent Review Team, is to decide on the
preferred alternative. Once authorization is given, conceptual design
activities are to proceed. Detailed design is not to begin until the
supplemental environmental impact statement process has confirmed the
selection of the preferred alternative by designating it in the final
supplemental environmental impact statement and the record of decision.
DOE estimates that this may occur in mid-2000.




Page 36                                   GAO/RCED-99-69 In-tank Precipitation Facility
Appendix VI

Comments From the Department of Energy                                ApV
                                                                        enxdiI




              Page 37     GAO/RCED-99-69 In-tank Precipitation Facility
Appendix VI
Comments From the Department of Energy




Page 38                                  GAO/RCED-99-69 In-tank Precipitation Facility
Appendix VI
Comments From the Department of Energy




Page 39                                  GAO/RCED-99-69 In-tank Precipitation Facility
                   Appendix VI
                   Comments From the Department of Energy




(141189)   eL
            rtet   Page 40                                  GAO/RCED-99-69 In-tank Precipitation Facility
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