Hanford Waste Treatment: DOE Needs to Evaluate Alternatives to Recently Proposed Projects and Address Technical and Management Challenges
What GAO Found
The Department of Energy's (DOE) two proposed facilities may help achieve Hanford's waste treatment mission by expediting treatment of some waste and addressing some technical challenges within the Waste Treatment and Immobilization Plant's (WTP) Pretreatment facility. However, DOE selected the facilities based on past proposals and excluded other potential alternatives from consideration. One facility is a low-activity waste pretreatment system to treat some of the low-activity waste in the tanks, and the other is a tank waste characterization and staging facility to stage, mix, sample, and characterize high-level waste from the tanks prior to delivery to the Pretreatment facility. The proposed facilities are at the initiation phase of DOE's project management process. During this phase, under its project management order, DOE is to develop statements of mission need that do not identify a particular facility or technology solution in order to preserve the flexibility to explore alternatives. DOE, however, developed narrow statements of mission need based on facilities it had proposed in prior years but never constructed. Without revising these statements to allow DOE flexibility, the scope of alternatives DOE analyzes will exclude consideration of other potentially viable alternatives.
DOE's preliminary cost and schedule estimates for constructing the two proposed facilities are not reliable because they do not meet industry best practices for reliable cost and schedule estimates. DOE estimates that constructing the two proposed facilities could, together, cost at least $1 billion and take 6 to 8 years to construct. These cost and schedule estimates, however, cannot be considered reliable, in part because the department excluded from its estimates some costs of major activities that will be needed to construct the facilities, such as costs to support feeding low-activity waste directly, and did not sequence activities to complete them in accordance with best practices. Without reliable estimates that reflect best practices, DOE may be committing to courses of action that will require undisclosed future resources and will commit DOE to project time frames it may be unable to meet.
Significant technical and management challenges continue to affect the WTP and hinder its completion. According to DOE commissioned reviews, technical challenges continue to affect the Pretreatment facility and the facilities intended to treat low-activity and high-level waste. DOE has increased its technical oversight, but it has not fully developed aggressive risk mitigation strategies that address all technical uncertainties, as required by its project management order. Furthermore, design management challenges continue. The contractor's design management program is to ensure that WTP's design meets nuclear safety requirements. However, contractor data indicate that significant, unresolved design issues remain, and recent internal and external reviews show that some facilities may require extensive and expensive rework. Under the WTP construction contract, and as recommended by a DOE advisory group, DOE can employ an owner's agent to assist the department in reviewing the contractor's approach to design management and mitigating design challenges. Enlisting the services of an external entity to assist in this way may help DOE mitigate some long-standing challenges.
Why GAO Did This Study
The WTP is a key part of DOE's strategy for treating 56 million gallons of radioactive waste held in underground tanks at the Hanford site in Washington State. The WTP is being constructed under a design-build contract and has a history of technical and management challenges. DOE stopped construction in 2012 on parts of the WTP, including the Pretreatment facility, pending resolution of these challenges and has stated that several milestones will likely be missed.
In September 2013, DOE proposed a waste treatment strategy that may allow some waste to be treated before resolving WTP's technical issues, including construction of two new facilities. Senate Report 113-44 accompanying the National Defense Authorization Act for Fiscal Year 2014 included a provision for GAO to examine the status of construction and operations at the WTP. This report examines (1) how DOE's two new proposed facilities help achieve Hanford's waste treatment mission and how they were selected, (2) the extent to which DOE's estimated costs and schedules for constructing the facilities meet best practices for reliable estimates, and (3) the extent to which technical and management challenges continue to affect the WTP. GAO reviewed DOE and contractor data and documents.
GAO recommendations include that DOE (1) broaden the facilities' statements of mission need to allow for a full analysis of alternatives, (2) revise the facilities' cost and schedule estimates in accordance with industry best practices, and (3) enlist the services of an external entity to assist with oversight of the WTP contractor. DOE generally agreed with GAO's recommendations but not some of the conclusions. GAO continues to believe its conclusions are fair and well supported.
Recommendations for Executive Action
|Department of Energy||To improve DOE's management and oversight of the WTP project, the Secretary of Energy should, in assessing the alternatives, revise cost and schedule estimates for the Low Activity Waste Pretreatment System and the Tank Waste Characterization and Staging facility in accordance with industry best practices.||
In April of 2017, DOE headquarters conducted a project peer review of the Low Activity Waste Pretreatment System (LAWPS) facility and concluded that the project would exceed its cost and schedule estimates by at least 50 percent; as a result, the review report recommended that DOE's Office of River Protection revise the cost and schedule estimates for the facility to ensure integration of best practices of GAO, DOE and industry. In September 2017, in response to project cost growth and delivery schedule issues, DOE ordered the LAWPS contractor to develop and recommend an alternative approach to the project. The contractor developed several alternatives for DOE's consideration, and a new project approach has been selected for development. The second project, the Tank Waste Characterization and Staging facility project has been placed on hold indefinitely.
|Department of Energy||To improve DOE's management and oversight of the WTP project, the Secretary of Energy should revise the statements of mission need for the two proposed projects to allow DOE to consider a variety of alternatives without limiting potential solutions, consistent with the DOE requirement that mission need statements should not identify particular solution such as equipment, facility, or technology.||
According to DOE information through January 2018, revision of the statement of mission need for the Low Activity Waste Pretreatment System (LAWPS) "has become overcome by events." Nevertheless, in September 2017, in response to project cost growth and delivery schedule, DOE ordered the LAWPS contractor to develop and recommend an alternative approach to the project. The contractor developed several alternatives for DOE's consideration, and a new project approach was selected for development. The second proposed project, the Tank Waste Characterization and Staging facility, has been put on hold indefinitely.
|Department of Energy||
Priority Rec.To improve DOE's management and oversight of the WTP project, the Secretary of Energy should, in accordance with DOE's Office of River Protection quality assurance policy, conduct an extent-of-condition review for WTP's High Level Waste and Low Activity Waste facilities' systems that have not been reviewed by DOE.
DOE agreed with the recommendation. However, as we reported in GAO-18-241, DOE believes that it is unnecessary for them to review the extent of quality assurance problems for the High Level Waste facility until it is known what parts of the facilities will remain and which parts will not. However, due to the Direct Feed Low Activity Waste Strategy being the priority for the WTP Project, work on the HLW facility has been limited. Regarding the Low Activity Waste Facility, DOE reported in fiscal year 2019 that the contractor plans to continue to incorporate corrective actions required by the previous design and operability review (which was not a full extent-of-condition review) as they complete construction. Given that DOE has not taken action to close this recommendation nor reported any plans to do so, it is unlikely that the recommendation will be implemented.
|Department of Energy||
Priority Rec.To improve DOE's management and oversight of the WTP project, the Secretary of Energy should consider whether or to what extent construction activities for the High Level Waste and Low Activity Waste facilities should be further limited until aggressive risk mitigation strategies are developed and employed to address technical challenges that DOE, the contractor, and others have identified but not yet resolved.
As we reported in GAO-18-241, DOE officials told us that they did not consider it necessary to stop work due to recurrence of problems in certain areas because they plan to evaluate the extent of the contractor's implementation of corrective measures over the next year, and have allowed work to continue because they believe that the contractor's quality assurance program is generally adequate. Regarding the High Level Waste (HLW) facility, an update provided by DOE in fiscal year 2019 said that they have authorized limited construction with additional holds and controls identified, although they have not performed a full extent-of-condition review as recommended. Similarly, with regard to the Low Activity Waste facility (LAW), in fiscal year 2019 DOE reported that construction is nearly complete and that it continues to address new risks as they are identified. Because DOE has not performed a full extent-of-condition review of the LAW facility to identify all potential risks, and has no plans to do so, nor planned to perform the full extent-of-condition for the HLW facility, it is unlikely that this recommendation will be implemented.
|Department of Energy||To improve DOE's management and oversight of the WTP project, the Secretary of Energy should enlist the services of another agency or external entity to serve as an owner's agent to assist the Office of River Protection in reviewing and evaluating the WTP contractor's design and approach to mitigating design challenges.||
Congress required DOE to meet this requirement in the 2016 National Defense Authorization Act, and we confirmed that DOE issued a contract to Parsons Government Services to serve as an owner's agent on September 29, 2015.