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entitled 'Nuclear Waste: Challenges to Achieving Potential Savings in
DOE's High-Level Waste Cleanup Program' which was released on July 17,
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Report to the Chairman, Subcommittee on Oversight and Investigations,
Committee on Energy and Commerce, House of Representatives:
United States General Accounting Office:
GAO:
June 2003:
NUCLEAR WASTE:
Challenges to Achieving Potential Savings in DOE's High-Level Waste
Cleanup Program:
GAO-03-593:
GAO Highlights:
Highlights of GAO-03-593, a report to the Chairman, Subcommittee on
Oversight and Investigations, Committee on Energy and Commerce, House
of Representatives
Why GAO Did This Study:
The Department of Energy (DOE) oversees one of the largest cleanup
programs in history—the treatment and disposal of 94 million gallons
of highly radioactive nuclear waste from the nation’s nuclear weapons
program. This waste is currently at DOE sites in Washington, Idaho,
and South Carolina. In 2002, DOE began an initiative to reduce the
estimated $105-billion cost and 70-year time frame of this cleanup.
GAO was asked to determine the status of this initiative, the legal
and technical challenges DOE faces in implementing it, and any further
opportunities to reduce costs or improve program management.
What GAO Found:
DOE’s initiative for reducing the costs and time required for cleanup
of high-level wastes is still evolving. DOE’s main strategy for
treating high-level waste continues to include separating and
concentrating much of the radioactivity into a smaller volume for
disposal in a geologic repository. Under the initiative, DOE sites are
evaluating other approaches, such as disposing of more waste on site.
DOE’s current savings estimate for these approaches is $29 billion,
but the estimate may not be reliable or complete. For example, the
savings estimate does not adequately reflect uncertainties or take
into account the timing of when savings will be realized.
DOE faces significant legal and technical challenges to realize these
savings. A key legal challenge involves DOE’s authority to decide that
some waste with relatively low concentrations of radioactivity can be
disposed of on site. This authority is being challenged in court, and
a prolonged challenge or an adverse decision could seriously hamper
DOE’s ability to meet its accelerated schedules. A key technical
challenge is that DOE’s approach relies on laboratory testing to
confirm separation of the waste into high-level and low-activity
portions. At the Hanford Site in Washington State, DOE plans to build
a facility before integrated testing of the separation technology—an
approach that has failed on other projects in the past, resulting in
significant cost increases and schedule delays.
DOE is exploring proposals, such as increasing the amount of high-
level waste in each disposal canister, which if successful could
result in billions of dollars in additional savings. However,
considerable evaluation remains to be done. DOE also has opportunities
to improve program management by fully addressing recurring weaknesses
GAO has identified in DOE’s management of cleanup projects.
What GAO Recommends:
GAO recommends that DOE (1) seek clarification of its authority to
designate waste as other than high-level waste if a prolonged legal
challenge occurs; (2) conduct integrated testing of waste separations
components before completing a full-scale facility at the Hanford
Site; and (3) ensure that DOE management practices include conducting
rigorous analyses, following best practices for incorporating new
technologies, and being cautious about using a concurrent design/build
approach for nuclear facilities. In commenting on the report, DOE
agreed to consider seeking clarification of its authority as
appropriate, but said that its practices met the intent of the other
two recommendations. GAO believes further improvements are needed.
www.gao.gov/cgi-bin/getrpt?GAO-03-593.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Robin M. Nazzaro at
(202) 512-3841 or nazzaror@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DOE's High-Level Waste Is a Complex Mixture That Requires a Multi-Step
Process to Prepare for Disposal:
DOE's Initiative for Accelerating Cleanup Is Still Evolving, with the
Extent of Savings Uncertain:
Key Legal and Technical Challenges Could Limit Potential Savings from
DOE's Accelerated Cleanup Initiative:
Opportunities Exist to Explore Additional Cost Savings and
to Strengthen Program Management:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Energy:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Major Short-Lived Radionuclides Contributing to the Current
Radioactivity in DOE's Untreated High-Level Waste:
Table 2: Main Steps in DOE's Approach to Preparing High-Level Waste
for Disposal:
Table 3: Examples of Proposals under Study for Accelerating the High-
Level Waste Treatment Process:
Table 4: DOE's Estimated Cost Savings from Proposals to Accelerate
Cleanup of High-Level Waste:
Table 5: Description and Status of DOE Incidental Waste Determinations
for Tank Waste:
Figures:
Figure 1: Waste Storage Tanks under Construction at DOE's Hanford Site,
September 1947:
Figure 2. Physical Forms of DOE's Untreated High-Level Waste as a
Percentage of Total Waste Volume:
Figure 3: Natural Decay of Radionuclides in DOE's Untreated High-Level
Waste from 2002 to 2102:
Figure 4: Simplified Description of Key Steps in Hanford's Proposed
Process for Separating High-Level Waste Constituents:
Abbreviations:
AEA: Atomic Energy Act of 1954:
DOE: Department of Energy:
EPA: Environmental Protection Agency:
NRC: Nuclear Regulatory Commission:
NRDC: Natural Resources Defense Council:
OMB: Office of Management and Budget:
RCRA: Resource Conservation and Recovery Act of 1976:
United States General Accounting Office:
Washington, DC 20548:
June 17, 2003:
The Honorable James C. Greenwood
Chairman,
Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
House of Representatives:
Dear Mr. Chairman:
The Department of Energy (DOE) oversees one of the largest cleanup
programs in history: the treatment and disposal of nuclear waste
created as a result of the nation's nuclear weapons program. As of
2003, one major aspect of this effort, DOE's high-level waste cleanup
program, was estimated to cost nearly $105 billion and take decades to
complete. High-level waste contains radioactive elements, such as
plutonium and uranium, in concentrations sufficient to require long-
term isolation from the environment. DOE's high-level waste results
from the process of dissolving used (or "spent") nuclear fuel to remove
plutonium, uranium, and other useful materials. During some of the
processing, solvents and other materials can be introduced, creating
waste that is both radioactive and chemically hazardous. About 94
million gallons of untreated high-level waste is stored at DOE
facilities at Hanford, Washington; Savannah River, South Carolina; and
near Idaho Falls, Idaho--primarily in underground tanks. This waste
would fill an area the size of a football field to a depth of about 260
feet. Since the 1980s, DOE has been actively working on ways to prepare
this waste for permanent disposal. These plans center on eventually
placing high-level waste in an underground repository where it can be
safely stored for thousands of years.
After investing more than 20 years and about $18 billion, DOE
acknowledged that the program to clean up its high-level waste was
far behind schedule, far over budget, and in need of major change. In
February 2002, DOE began an initiative to accelerate the schedule and
reduce the costs of cleaning up high-level and other radioactive and
hazardous waste, while focusing its resources on reducing risks to
human health and the environment at its sites. Although this initiative
covers DOE's entire cleanup program, it may have the most significant
impact on DOE's plans for high-level waste, which is the highest
cost component of DOE's cleanup program. In this context, you asked
us to (1) describe the components of DOE's high-level waste and the
process involved in preparing the waste for permanent disposal,
(2) discuss DOE's initiative for accelerating its high-level waste
cleanup and assess the reliability of the associated potential cost
savings, (3) identify the legal and technical challenges DOE faces
regarding this initiative, and (4) determine any additional
opportunities to reduce the costs, as well as opportunities to improve
the management of its high-level waste program.
This report is based largely on our detailed work at DOE sites where
high-level waste is currently stored and our analysis of cost
information and legal documents pertaining to the high-level waste
program. We obtained the assistance of a physicist with extensive
experience in the nuclear field to evaluate the technical aspects of
DOE's high-level waste program. A detailed discussion of our scope and
methodology is included in appendix I.
Results in Brief:
DOE's high-level waste has many types of components, ranging from
radioactive isotopes and corrosive chemicals to the water in which much
of this material was initially discharged. Even the radioactive
components of the waste vary greatly: a small portion will remain
dangerously radioactive for millions of years, while the vast majority
will lose much of their radioactivity more quickly, so that more than
90 percent of the current radioactivity will be gone within 100 years.
To prepare this waste for permanent disposal and meet commitments made
to state and federal regulators, DOE generally plans to separate the
waste into two waste streams, one with high levels of radioactivity and
the other with lower concentrations of radioactivity. DOE expects this
process will concentrate at least 90 percent of the radioactivity into
a volume that is significantly smaller than the current total volume of
waste. DOE plans to immobilize and bury the separated highly
radioactive portion in a permanent underground repository. The
remaining waste components will be immobilized--usually in a cement-
like material--and disposed of at the location where the waste is
currently stored or at some other location.
DOE's initiative to accelerate the cleanup is evolving, and its savings
estimates are changing accordingly, although we have concerns about the
reliability of those estimates. DOE originally estimated it could
shorten the waste cleanup schedule by 20-35 years and achieve up to
$34 billion in savings at its three high-level waste sites. To help
achieve these schedule and cost reductions, DOE has identified
alternative treatment and disposal strategies, involving such steps as
developing ways to permanently dispose of more of the radioactive waste
at current sites rather than moving it to the planned underground
repository. As of April 2003, DOE's strategies were still being
developed, and DOE had lowered the original savings estimate to
$29 billion. However, our assessment of the revised estimate indicates
that it may not be reliable. For example, the analysis does not take
into account all costs associated with alternative treatment
strategies. Also, the estimates of savings do not compare costs on the
basis of "present value," where dollars to be saved in future years are
discounted to a common year to reflect the time value of money. At
Savannah River, such an adjustment would lower the site's savings
estimate of $5.4 billion for accelerated waste processing to
$2.8 billion (in 2003 dollars).
DOE is facing significant legal and technical challenges in
implementing a number of the alternative treatment and disposal
strategies. A key legal challenge linked to the strategies under
consideration at all three sites involves DOE's authority to determine
that some waste components with relatively low concentrations of
radioactivity can be treated and permanently disposed of at the sites
where the waste is currently stored. For example, DOE's Hanford Site
has developed a treatment and disposal approach that will prepare about
90 percent of its tank waste for permanent disposal at Hanford rather
than shipping it to an underground repository. This approach involves
DOE determining that not all of the tank waste is high-level waste.
DOE's authority to make such determinations is being challenged in
court. A prolonged court battle could seriously hamper DOE's ability to
meet accelerated schedules it has set under its new initiative.
Regarding technical challenges, key elements of DOE's accelerated
cleanup strategies rely on technologies for separating the waste
components that have not been fully developed or tested. For example,
because of schedule constraints and concerns about cost increases, the
Hanford Site plans to forgo full integrated testing of its proposed
process for separating wastes into high-level and low-activity portions
until after facility construction is complete. This approach is not
consistent with DOE's project management guidelines or the advice of
several independent technical experts. On a past project to develop
such facilities, failing to fully test the separation technology has
resulted in significant cost increases and schedule delays. For
example, at DOE's Savannah River Site in South Carolina, an attempt to
speed implementation failed, after nearly $500 million had been spent
on the project. DOE now plans to spend an additional $1.8 billion to
develop and implement an alternative separation technology at Savannah
River. We are concerned that DOE's approach at Hanford may also result
in significant schedule delays and cost increases.
DOE is exploring additional potential cost savings. In addition, there
are opportunities to improve program management. Additional potential
cost-saving opportunities have come to light since DOE first developed
its initiative, and DOE is beginning to assess these opportunities. The
proposals that offer potential for significant savings are being
developed by the Savannah River and Hanford sites for increasing the
amount of waste that can be concentrated into the canisters destined
for the permanent underground repository. DOE's data indicates that
these proposals, if successful, could save several billion dollars.
Considerable evaluation of these opportunities remains to be done and
cost-saving estimates have not yet been fully developed, according to
DOE officials. DOE also has opportunities to improve its management of
the cleanup program by addressing management weaknesses that we and
others have identified in the past. When it began the initiative to
reduce costs and accelerate the cleanup schedule, DOE acknowledged it
had systemic problems with the way that the program was managed.
Although DOE has taken steps to improve program management, we have
continuing concerns about management weaknesses in several areas. These
include making key decisions without rigorous supporting analysis,
incorporating technology before it is sufficiently tested, and pursuing
a "fast-track" approach of launching into facility construction before
completing sufficient design work. It does not currently appear that
DOE's management actions will fully address these weaknesses.
We are recommending that if the current challenge to DOE's authority
becomes an extended legal process, DOE should seek clarification from
the Congress on the agency's authority to determine that certain waste
does not need to be treated and disposed of as high-level waste. We are
also recommending that the Secretary of Energy reassess the
approach for incorporating new waste separation technologies at the
Hanford site, so that the technologies are more fully tested to ensure
they will work successfully before a full-scale facility is built.
Finally, we are making recommendations on ways to further strengthen
management of the high-level waste program.
DOE agreed to consider our recommendation regarding clarifying its
legal authority to determine that certain waste does not need to be
treated and disposed of as high-level waste. DOE disagreed with our
recommendation to conduct integrated pilot-scale testing of its waste
separations process at Hanford while constructing a full-scale
facility. In addition, regarding opportunities to improve program
management, DOE responded only about the Hanford Site. DOE said that
the management activities at Hanford were already consistent with our
recommendations to conduct rigorous analysis to support decision-
making, follow best practices when incorporating new technologies into
projects, and be cautious about using a fast-track approach to
designing and building complex nuclear facilities. We continue to
believe that implementing all of the recommendations in this report
would help to reduce the risk of costly delays and improve overall
management of DOE's entire high-level waste program.
Background:
High-level waste[Footnote 1] contains radioactive components that emit
dangerously intense radiation. Radiation is generated through a decay
process in which the atoms of a radioactive component (also known as a
radionuclide) lose their radioactivity by spontaneously releasing
energy in the form of subatomic particles or rays similar to X-rays.
Even short but extremely intense exposure to radiation can cause almost
immediate health problems such as radiation sickness, burns, and, in
severe cases, death. Excessive exposure to these particles or rays
damages cells in living tissue and is believed to cause long-term
health problems such as genetic mutations and an increased risk of
cancer. Because of the intense radiation emitted from high-level waste,
the waste must be isolated and handled remotely behind heavy shielding
such as a layer of concrete in order to protect humans and the
environment. In addition to the intense radioactivity, some of the
radioactive components can be very mobile in the environment and may
migrate quickly to contaminate the soil and groundwater if not
immobilized. Besides radioactive components, DOE high-level waste also
generally contains hazardous components added during the process of
dissolving used nuclear fuel to remove plutonium and other nuclear
materials. These hazardous components include solvents, acids, caustic
sodas, and toxic heavy metals such as chromium and lead. Radioactive
waste components, when combined with hazardous components, are referred
to as "mixed wastes.":
DOE has a vast complex of sites across the nation dedicated to the
nuclear weapons program, but the high-level waste stemming from
reprocessing spent fuel to produce weapons material such as plutonium
and uranium has been limited mainly to three sites--Hanford,
Washington; the Idaho National Engineering and Environmental Laboratory
("Idaho National Laboratory") near Idaho Falls, Idaho; and Savannah
River, South Carolina.[Footnote 2] DOE largely ceased production of
plutonium and enriched uranium by 1992, but the waste remains. Most of
the tanks in which it is stored have already exceeded their design
life. For example, many of Hanford's and Savannah River's tanks were
built in the 1940s to 1960s and were designed to last 10-40 years.
(Figure 1 shows waste storage tanks being constructed at the Hanford
Site.) These tanks, most of which are underground, are used to store
high-level waste. Leaks from some of these tanks were first detected at
Hanford in 1956 and at Savannah River in 1959. Given the age and
deteriorating condition of some of the tanks, there is concern that
some of them will leak additional waste into the soil, where it may
migrate to the water table.[Footnote 3]
Figure 1: Waste Storage Tanks under Construction at DOE's Hanford Site,
September 1947:
[See PDF for image]
[End of figure]
Treatment and disposal of high-level waste produced at DOE facilities
are governed by a number of federal laws, including laws that define
the roles of DOE and the Nuclear Regulatory Commission (NRC) in waste
management. The Atomic Energy Act of 1954 (AEA) and the Energy
Reorganization Act of 1974 established responsibility for the
regulatory control of radioactive materials including DOE's high-level
wastes.[Footnote 4] The Energy Reorganization Act of 1974 assigned the
NRC the function of licensing facilities that are expressly authorized
for long-term storage of high-level radioactive waste generated by DOE
and others.[Footnote 5] The Nuclear Waste Policy Act of 1982, as
amended, defines high-level radioactive waste as "the highly
radioactive material resulting from the reprocessing of spent nuclear
fuel, including liquid waste produced directly in reprocessing and any
solid material derived from such liquid waste that contains fission
products in sufficient concentrations, and…other highly radioactive
material that the [NRC]…determines…requires permanent
isolation."[Footnote 6] The act also established a process for
developing and siting a geologic repository (a permanent deep disposal
system) for the disposal of high-level waste and spent fuel. Regarding
DOE's high-level waste, the act provided that unless the President
determined that a separate repository was required for such waste, DOE
should arrange for the use of commercial repositories developed under
the act for disposal of its defense waste.[Footnote 7] In 1985,
President Reagan decided that a separate repository for defense waste
was not needed. Under amendments the Federal Facility Compliance Act of
1992 made to the Resource Conservation and Recovery Act of 1976 (RCRA),
DOE generally must develop waste treatment plans for its sites that
contain mixed wastes.[Footnote 8] These plans are approved by states
that the Environmental Protection Agency (EPA) has authorized to
administer RCRA or by EPA in states that have not been so authorized.
DOE carries out its high-level waste cleanup program under the
leadership of the Assistant Secretary for Environmental Management and
in consultation with a variety of stakeholders. In addition to the EPA
and state environmental agencies that have regulatory authority in
states where the sites are located, stakeholders include county and
local governmental agencies, citizen groups, advisory groups, and
Native American tribes. These stakeholders advocate their views through
various public involvement processes including site-specific advisory
boards. Over the years, much of the cleanup activity has been
implemented under compliance agreements between DOE and the regulatory
agencies. These compliance agreements provide for establishing legally
enforceable schedule milestones that govern the work to be done.
DOE's High-Level Waste Is a Complex Mixture That Requires a Multi-Step
Process to Prepare for Disposal:
The waste in the tanks at Hanford, Savannah River, and the Idaho
National Laboratory is a complex mixture of radioactive and hazardous
components, and DOE's process for preparing it for disposal is designed
to separate much of the radioactive material from other waste
components. In the tanks, this mixture has transformed into a variety
of liquid and semisolid forms. The radioactive components are of many
different types; some remain dangerous for millions of years, while
others lose much of their radioactivity in relatively short periods of
time. Because most of the radioactive components decay relatively
rapidly, over 90 percent of the current radioactivity will dissipate
within 100 years. DOE plans to isolate the radioactive components and
prepare the waste for disposal through the use of an extensive and
sequential multi-step treatment process. To fulfill its current
commitment to federal and state regulators, DOE expects this process to
concentrate at least 90 percent of the radioactivity into a much
smaller volume that can be permanently isolated for at
least 10,000 years in a geologic repository. DOE plans to dispose of
the remaining waste of relatively low radioactivity on-site near the
surface of the ground, such as in vaults or canisters, or at other
designated disposal facilities.
Waste Has Turned into a Variety of Forms:
High-level waste generally exists in a variety of physical forms and
layers inside the underground tanks, depending on the physical and
chemical properties of the waste components. The waste in the tanks
takes three main forms:
* Sludge: The denser, water insoluble components generally settle to
the bottom of the tank to form a thick layer known as sludge, which has
the consistency of peanut butter.
* Saltcake: Above the sludge may be water-soluble components such as
sodium salts that crystallize or solidify out of the waste solution to
form a moist sand-like material called saltcake.
* Liquid: Above or between the denser layers may be liquids comprised
of water and dissolved salts called supernate.
As figure 2 shows, 44 percent of the total volume of high-level waste
is in saltcake form, followed by liquid and sludges. In addition, a
small portion of the waste volume is also in solid form and is stored
in facilities other than tanks. At the Idaho National Laboratory, some
waste is stored in stainless steel bins, enclosed in concrete vaults,
after having undergone a thermal process that converted the liquid into
a solid granular substance called calcine. At Hanford, some high-level
waste was retrieved from the tanks, dried, and stored as solid material
in stainless steel capsules.[Footnote 9]
Figure 2: Figure 2. Physical Forms of DOE's Untreated High-Level Waste
as a Percentage of Total Waste Volume:
[See PDF for image]
Note: The values in figure 2 are for all untreated high-level waste
across the DOE complex as of August 2002. At the sites, the actual
distribution of the waste into the various physical forms may differ
from that shown above.
[End of figure]
The various layers of waste in the tanks are not uniformly distributed
and often differ from tank to tank and even from place to place within
a tank. Depending on how the waste was generated and whether it was
mixed or transferred from one tank to another, the layers of waste
within any given tank may be unevenly distributed and liquid is
interspersed between layers of saltcake. Some tanks contain all three
main waste forms--sludge, saltcake, and liquid--while others contain
only one or two forms. Tank contents also vary among sites. For
example, at the Idaho National Laboratory most tanks contain primarily
liquid waste because the waste was kept in an acidic form, while at
Hanford and Savannah River, most tanks contain waste in two or three
physical forms.
Much of the Radioactivity Declines Relatively Quickly:
The radioactive components of the high-level waste vary greatly in
terms of how long they remain radioactive, with the vast majority
losing their radioactivity within years or decades. Each radioactive
component, or radionuclide, in high-level waste loses its radioactivity
at a rate that differs for each component. This rate of decay, which
cannot be changed, is measured in "half-lives"--that is, the time
required for half of the unstable atoms to decay and release their
radiation. The half-lives of major radionuclides in the high-level
waste range from 2.6 minutes for barium-137m[Footnote 10] to
24,131 years for plutonium-239. To illustrate, for any given number of
radioactive barium-137m atoms, half will lose their radioactivity
within 2.6 minutes. After another 2.6 minutes, half of the remaining
unstable atoms will lose their radioactivity, leaving only one-fourth
of the original number of unstable atoms still radioactive. The process
is the same, but the half-life intervals much longer, for long-lived
radionuclides, such as plutonium-239 atoms. For radioactive plutonium-
239 atoms, half will lose their radioactivity within 24,131 years, and
half of the remainder will lose their radioactivity after another
24,131 years.
Currently, nearly all of the radioactivity in DOE's high-level waste
originates from radionuclides with half-lives of about 30 years or
less. As table 1 shows, about 98 percent of the radioactivity of the
high-level waste comes from four radionuclides: barium-137m, cesium-
137, strontium-90, and yttrium-90. Of these, cesium-137 is the longest
lived, with a half-life of 30.17 years.
Table 1: Major Short-Lived Radionuclides Contributing to the Current
Radioactivity in DOE's Untreated High-Level Waste:
Major short-lived radionuclides: Barium-137m[A]; Half-life in years:
0.0000049[B]; Percent of total radioactivity in DOE's high-level waste
as of August 2002: 25.6.
Major short-lived radionuclides: Yttrium-90[A]; Half-life in years:
0.0073[C]; Percent of total radioactivity in DOE's high-level waste as
of August 2002: 22.8.
Major short-lived radionuclides: Strontium-90; Half-life in years:
28.6; Percent of total radioactivity in DOE's high-level waste as of
August 2002: 22.8.
Major short-lived radionuclides: Cesium-137; Half-life in years:
30.17; Percent of total radioactivity in DOE's high-level waste as of
August 2002: 27.0.
Major short-lived radionuclides: Major short-lived radionuclides
total; Half-life in years: [Empty]; Percent of total radioactivity in
DOE's high-level waste as of August 2002: 98.2.
Source: GAO analysis of DOE data.
Notes: The radionuclides listed contain the largest amount of
radioactivity in curies relative to other radionuclides in DOE's
untreated high-level waste. Other radionuclides, including those with
longer half-lives, contain the remaining balance of the total current
radioactivity.
[A] Barium-137m and yttrium-90 are generated from the radioactive decay
of cesium-137 and strontium-90 respectively. Consequently, as long as
cesium-137 and strontium-90 are present, barium-137m and yttrium-90
will also be present.
[B] 2.6 minutes.
[C] 2.7 days.
[End of table]
The relatively short half-lives of most of the radionuclides in the
waste means that much of the total current radioactivity will decay
within 100 years. For example, within 30 years, about 50 percent of the
current radioactivity in DOE's wastes will have decayed away, and
within 100 years, this figure will rise to more than 90 percent. Figure
3 shows the pattern of decay, using 2002 to 2102 as the 100-year
period. Extending the analysis beyond the 100-year period shown in the
figure, in 300 years, 99.8 percent of the radioactivity will have
decayed, leaving 0.2 percent of the current radioactivity remaining.
Figure 3: Natural Decay of Radionuclides in DOE's Untreated High-Level
Waste from 2002 to 2102:
[See PDF for image]
Note: Radioactivity is measured in a unit called a curie. One curie
equals 37 billion atomic disintegrations per second.
[End of figure]
Despite the relatively rapid decay of the current radioactivity in
high-level waste, a variety of long-lived radionuclides will remain
radioactive for a very long time and must be isolated from the
environment. Radionuclides with half-lives greater than cesium-137
(30.17 years), such as plutonium-239 and americium-241, which have
half-lives of 24,131 years and 432.2 years respectively, will continue
to pose a threat to human health and the environment for thousands
of years. Once the radionuclides with relatively short half-lives have
decayed away, the longer-lived radionuclides will be the primary source
of radioactivity in the waste. Some of these long-lived radionuclides,
such as technetium-99, are potentially very mobile in the environment
and therefore must remain permanently isolated. If these highly mobile
radionuclides leak out or are released into the environment, they can
contaminate the soil and water.
Processing Can Concentrate the Radioactivity into a Much Smaller
Volume of Waste:
DOE's process for dealing with its high-level waste centers on
separating the various components of the waste so that the portion that
is most radioactive can be concentrated into a much smaller volume.
While currently all high-level waste is radioactive and dangerous,
significant portions of the waste, such as contaminated water, will
have low levels of radioactivity if separated from most of the
radionuclides that are highly radioactive. Contaminated water currently
represents 54 percent of the total waste by volume across the DOE
complex.[Footnote 11] In overview, DOE's process generally involves
separating the waste into two main streams. One, the high-level
portion, will contain at least 90 percent of the radioactivity and a
small portion of the waste volume. The other stream, the low-activity
portion, will contain 10 percent or less of the total radioactivity but
most of the waste volume.
DOE's plans for treating the waste currently call for a set of steps to
be applied to the waste at each site. The primary steps are shown in
table 2.
Table 2: Main Steps in DOE's Approach to Preparing High-Level Waste
for Disposal:
Step in process: Characterization; Description: Determination of the
specific physical, chemical, and radiological components of the wastes
in each tank. This step is important because some tanks contain a
complex mixture of unknown waste constituents, and detailed knowledge
of tank contents is needed to determine how to best retrieve, pretreat,
and treat the wastes. Characterization involves analyzing samples drawn
from the tanks and using process knowledge such as waste transfer
records and results from prior samples.
Step in process: Retrieval; Description: Removal of the stored waste
from the tanks by pumping or other means and its transfer to treatment
facilities. Because the waste exists in liquid, solid, and other forms,
certain steps may be needed to turn the waste into a form that will
allow the pumping to take place.
Step in process: Pretreatment; Description: Separation of the
high-level portion of the waste from the low-activity portion and from
other nonradioactive elements, such as aluminum, organic compounds, and
salts. Evaporation is used during pretreatment to reduce the volume of
contaminated water in the waste. This step is desirable because it
decreases the amount of high-level waste that must be treated and sent
to the high-level waste repository. The remaining low-activity waste
can then be treated and disposed of less expensively on-site.
Step in process: Treatment; Description: Immobilization of the waste.
DOE plans to stabilize the high-level portion of the waste separated
during pretreatment by mixing it with a glass-forming material and
melting the mixture into glass. The molten glass will be poured into
stainless steel canisters to harden. The remaining low-activity portion
of the waste will generally be mixed with cement and other materials so
that it will harden into a cement-like substance called grout.[A].
Step in process: Disposal; Description: Final emplacement of the
immobilized waste so as to ensure isolation from the surrounding
environment until it is no longer dangerously radioactive. DOE plans to
temporarily store the canisters containing the high-level portion of
the waste on-site until an underground geologic repository is ready to
receive them permanently. The remaining immobilized waste will be
disposed of on-site or at other designated near surface disposal
sites.
Source: GAO.
[A] At the Hanford Site, DOE currently plans to vitrify the low-
activity portion of the waste.
[End of table]
DOE plans to permanently dispose of the high-level portion of the
separated waste in a geologic repository developed pursuant to the
Nuclear Waste Policy Act. This repository is intended to isolate highly
radioactive waste materials from the public and the environment for
at least 10,000 years. The remaining low-activity portion would be
immobilized in accordance with federal and state environmental laws and
the agreements made with state regulators and disposed of permanently
on-site or at other designated locations.
Although radionuclides with long half-lives are present in both the
high-level and low-activity portions of the waste after the separations
processes are concluded, the portion of the waste not sent to the
geologic repository will have relatively low levels of radioactivity
and long-lived radionuclides. Based on current disposal standards used
by the NRC, if the radioactivity of this remaining waste is
sufficiently low, it can be disposed of on-site near the surface of the
ground, using less complex and expensive techniques than those required
for the highly radioactive portion.
DOE has successfully applied this process in a demonstration project
at the West Valley site in New York state. At West Valley, separation
of the low-activity portion from the high-level portion of the waste
reduced by 90 percent the quantity of waste requiring permanent
isolation and disposal at a geologic repository. The high-level portion
was stabilized in a glass material (vitrified) and remains stored at
the site pending completion of the high-level waste geologic repository
and resolution of other issues associated with disposal costs.[Footnote
12] The remaining low-activity portion was mixed with cement-forming
materials, poured into drums where it solidified into grout (a cement-
like material), and remains stored on-site, awaiting shipment to an
off-site disposal facility.
DOE's Initiative for Accelerating Cleanup Is Still Evolving, with the
Extent of Savings Uncertain:
DOE's new initiative, implemented in 2002, attempts to address the
schedule delays and increasing costs DOE has encountered in its efforts
to treat and dispose of high-level waste. This initiative is still
evolving. DOE originally identified several strategies to help it
reduce the time needed to treat and dispose of the waste. Based on
these strategies, DOE set a goal of achieving up to $34 billion in
savings at its three high-level waste sites and reducing the waste
cleanup schedule by about 20 to 35 years compared to the existing
program baseline.[Footnote 13] As of April 2003, DOE's strategies were
still under development, and DOE had revised the savings estimate to
$29 billion. However, even the $29 billion estimate may not be
reliable. While savings are likely if the strategies are successfully
implemented, the extent of the savings is still uncertain.
Initiative Centers on Ways to Speed Disposal and Save Money:
For the most part, DOE's past efforts to treat and dispose of
high-level waste have been plagued with false starts and failures,
resulting in steadily growing estimates of the program's total cost.
Since the cleanup activities began about 20 years ago, DOE has spent
about $18 billion in its attempts to prepare high-level waste for
disposal. However, less than 5 percent of the waste has been
successfully treated to date. Uncontrolled cost overruns, numerous
schedule delays, and unsuccessful attempts to develop treatment
processes have pushed the overall estimated cost of the high-level
waste program from about $63 billion in 1996 (when the first
comprehensive estimates were developed) to nearly $105 billion
in 2003.[Footnote 14]
In an attempt to gain control over DOE's waste management program and
to better ensure its affordability, in February 2002 the Assistant
Secretary for Environmental Management undertook a new initiative aimed
at accelerating cleanup at DOE's sites and focusing on more rapid
reduction of environmental risks. The initiative came as a result of an
internal review of the cleanup program, which identified numerous
problems and recommended a number of corrective actions. Among other
things, the review noted that the cleanup program was not based on a
comprehensive, coherent, technically supported risk prioritization;
was not focused on accelerating risk reduction; and was not addressing
the challenges of uncontrolled cost and schedule growth. A main focus
of the initiative is high-level waste, including both the technical
approach to treating the waste and improving how DOE manages the
contracts and project activities.[Footnote 15]
DOE developed strategies to speed the cleanup and reduce risk at all
three sites. Many of these proposals involved ways to do one or more of
the following:
* Dealing with some tank waste as low-level or transuranic[Footnote 16]
waste, rather than as high-level waste. Doing so would eliminate the
need to prepare the waste for off-site disposal in the geologic
repository for high-level waste. Disposing of waste in the repository
currently is based on immobilizing the waste in a glass-like substance
through a process called vitrification.
* Completing the waste treatment more quickly by using additional or
supplemental technologies for treating some of the waste. For example,
DOE's Hanford Site is considering using up to four supplemental
technologies, in addition to vitrification, to process its low-activity
waste. DOE believes these technologies are needed to help ensure it can
meet a schedule milestone date of 2028 agreed to with regulators to
complete waste processing. Without these technologies, DOE believes
waste treatment would not be completed before 2048.
* Segregating the waste more fully than initially planned and tailoring
waste treatment to each of the four segregated waste types. By doing
so, DOE plans to apply less costly treatment methods to waste with
lower concentrations of radioactivity.
* Closing waste storage tanks earlier than expected. DOE plans to begin
closing tanks earlier than scheduled, thereby avoiding the operating
costs involved in maintaining the tanks and monitoring the wastes.
Table 3 shows major site-by-site proposals that have been made.
Table 3: Examples of Proposals under Study for Accelerating the High-
Level Waste Treatment Process:
Site: Hanford (Washington State); Types of proposals: * Building one
higher capacity vitrification facility to process the waste and
eliminating a second large facility; * Developing supplemental
technologies to treat and immobilize a large fraction of the low-
activity waste outside of the vitrification facility; * Using a single
system to retrieve the waste from each tank rather than two systems as
initially planned; * Accelerating the shipment of waste to the
repository; * Closing tanks earlier.
Site: Savannah River (South Carolina); Types of proposals: * Conducting
more thorough waste separations than initially planned and then
tailoring waste treatment separately to each waste stream. This would
allow Savannah River to do the following:; * Apply less costly
treatments than initially planned to the low-activity waste streams.
For example, DOE will remove waste with the lowest concentrations of
radioactivity and treat it directly by grouting it, rather than first
processing it through a more costly pretreatment facility; * Adjust
vitrification of high-level sludges to each individual batch of waste
processed. By doing so, DOE is exploring methods to place about
25 percent more waste in each canister, reducing the overall number of
canisters that will need to be produced and stored at the repository;
Closing tanks 8 years earlier than scheduled.
Site: Idaho National Laboratory (Idaho); Types of proposals: *
Repackaging calcined waste and shipping it directly for disposal at the
geological repository, rather than vitrifying it; * Classifying the
remaining liquid tank wastes as transuranic wastes, which would
require less costly treatment than previously planned before being
shipped off site to a transuranic waste repository.
Source: GAO analysis of DOE information.
[End of table]
DOE's initial estimates in August 2002 were that, if the proposals were
successfully implemented, total savings could be about $34 billion
compared to the baseline cost estimate in place when the accelerated
initiative began. As of April 2003, the savings estimate associated
with the new strategies had been revised to about $29 billion (see
table 4). DOE officials told us many of their new strategies are still
under development and that savings estimates are still subject to
additional revision.
Table 4: DOE's Estimated Cost Savings from Proposals to Accelerate
Cleanup of High-Level Waste:
Dollars in billions.
Idaho National Laboratory; Current baseline lifecycle cost estimate:
$10.07; Accelerated lifecycle cost estimate: $3.10; Estimated savings
from accelerated initiatives: $6.97.
Hanford; Current baseline lifecycle cost estimate: 56.19; Accelerated
lifecycle cost estimate: 41.67; Estimated savings from accelerated
initiatives: 14.52.
Savannah River; Current baseline lifecycle cost estimate: 18.82;
Accelerated lifecycle cost estimate: 11.49; Estimated savings from
accelerated initiatives: 7.33.
Totals; Current baseline lifecycle cost estimate: $85.08; Accelerated
lifecycle cost estimate: $56.26; Estimated savings from accelerated
initiatives: $28.82.
Source: DOE.
Notes: West Valley is not included in this table because high-level
waste cleanup at the site was essentially completed in Sept. 2002.
Amounts are in billions of current dollars, fiscal year 2003 to end of
cleanup.
[End of table]
Current Savings Estimates May Not Be Reliable:
Our review of these savings estimates suggests that they may not yet
be reliable and that the actual amounts to be saved if DOE successfully
implements the strategies may be substantially different from what
DOE is projecting. We have several concerns about the reliability
and completeness of the savings estimates. These concerns include
the accuracy of baseline cost estimates from which savings are
calculated, whether all appropriate costs are included in the analysis,
and whether the savings estimates properly reflect uncertainties or the
timing of the savings.
Baseline Costs Are Not Fully Reliable:
DOE's current lifecycle cost baseline is used as the base cost from
which potential savings associated with any improvements are measured.
However, in recent years, we and others have raised concerns about the
reliability of DOE's baseline cost estimates. In a 1999 report, we
noted that DOE lacked a standard methodology for sites to use in
developing their lifecycle cost baselines, raising a concern about the
reliability of data used to develop these cost estimates.[Footnote 17]
DOE's Office of Inspector General also raised a concern in a 1999
review of DOE project estimates, noting that several project cost
estimates examined were not supported or complete. DOE itself
acknowledged in its February 2002 review of the cleanup program that
baseline cost estimates do not provide a reliable picture of
project costs.[Footnote 18]
The National Research Council, which has conducted research on DOE's
project management, has reported on why DOE's baseline cost estimates
are often unreliable. It noted in 1999 that DOE often sets project
baselines too early and that industry practice calls for completing
from 30 percent to 35 percent of a design before establishing a
baseline cost estimate.[Footnote 19] In a recent example, we found that
the estimated contract price of Hanford's high-level waste treatment
facility is expected to increase to $5.8 billion, about $1.6 billion
above the original $4.2 billion contract price established in December
2000. The original cost estimate was established when less than
15 percent of the facility design was complete. The cost increase is
due to such factors as adding contingency funds for unforeseen
occurrences and making some facility modifications not in the
original contract.
Accelerated Cost Estimates May Be Incomplete:
A second reason for concern about the cost-savings estimates is that
some of the savings may be based on incomplete estimates of the costs
for the accelerated proposals. According to the Office of Management
and Budget's (OMB) guidance on developing cost estimates, agencies
should ensure that all appropriate costs are addressed in the estimate.
However, for example, the Idaho National Laboratory estimates savings
of up to $7 billion, in large part, by eliminating the need to build a
vitrification facility to process waste currently in calcine form and
in tanks, as well as achieving associated reductions in operations
and decommissioning costs. The waste, as is, may have to undergo an
alternative treatment method before it can be accepted at a geological
repository. The Idaho National Laboratory plans to use one of four
different technologies currently being evaluated to treat its tank
waste. DOE's savings estimate reflects the potential cost of only one
of those technologies. DOE has not yet developed the costs of using any
of the other waste treatment approaches. DOE noted that the accelerated
lifecycle estimate could likely change as one of the technologies is
selected and the associated costs of treating the waste are developed.
Savings Estimates Do Not Reflect Timing, Uncertainty
or Nonbudgetary Impacts:
A third area of concern is that DOE's savings estimates generally do
not accurately reflect the timing of when savings will occur, the
uncertainty associated with cost estimates or the reliability of a
technology, or the value of potential nonbudgetary impacts of the
alternative strategies. According to OMB guidance, agencies should
ensure that the timing of when the savings will occur is accounted for,
that uncertainties are recognized and quantified where possible, and
that nonbudgetary impacts, such as a change in the level of risk to
workers, are quantified, or at least described. Regarding the time
value of money, applying OMB guidance would mean that estimates of
savings in DOE's accelerated plans should reflect a comparison of its
baseline cost estimate with the alternative, expressed in a "present
value," where the dollars are discounted to a common year to reflect
the time value of money. Instead, DOE's savings estimates generally
measure savings by comparing dollars in different years. For example,
the Savannah River Site estimates a savings of nearly $5.4 billion by
reducing by 8 years (from 2027 to 2019) the time required to process
its high-level waste. Adjusting the savings estimate to present value
in 2003 results in a savings of $2.8 billion in 2003 dollars.
Regarding uncertainties, in contrast to OMB guidance, the DOE savings
estimates generally do not consider uncertainties. For example, the
savings projected in the Idaho National Laboratory's accelerated plan
reflect the proposal to no longer build the vitrification facility and
an associated reduction in operations costs. However, the savings do
not account for uncertainties, such as whether alternatives to
vitrification will succeed and at what cost. Rather than reflecting
uncertainties by providing a range of savings, DOE's savings estimate
is a single point estimate of $7 billion.
Regarding nonbudgetary impacts, DOE's savings estimates generally
did not fully assess the value of potential nonbudgetary impacts, such
as a change in the level of risk to workers or potential effects on the
environment. OMB guidelines recommend identification and, where
possible, quantification of other expected benefits and costs to
society when evaluating alternative plans. An example where
nonbudgetary impacts were partially, but not fully, considered is the
Idaho National Laboratory. The Idaho National Laboratory's accelerated
plan notes that its proposal not to vitrify its calcined high-level
waste significantly reduces risk to workers and the environment by
eliminating the exposure that would have been incurred in cleaning up
and decommissioning the vitrification facility once waste treatment had
been completed. While site officials told us such analyses are
currently underway, the impact has not yet been reflected in the
savings estimate. However, the proposal does not assess potential
increases in environmental risk, if any, from disposing of the waste
without stabilizing it into a vitrified form. By not assessing these
benefits and risks to workers and the environment, DOE leaves unclear
how important these risks and trade-offs are to choosing an alternative
treatment approach.
Key Legal and Technical Challenges Could Limit Potential Savings from
DOE's Accelerated Cleanup Initiative:
DOE faces significant legal and technical challenges to achieving the
cost and schedule reductions proposed in its new initiative. On the
legal side, DOE's proposals depend heavily on the agency's authority to
apply a designation other than "high-level waste" to the low-activity
portion of the waste stream, so that this low-activity portion does not
have to be disposed of as high-level waste. DOE's authority to make
such determinations is being challenged in court. On the technical
side, DOE's proposals rest heavily on the successful application of
waste separation methods that are still under development and will not
be fully tested before being put in place. DOE's track record in this
regard has not been strong; it has had to abandon past projects that
were also based on promising--but not fully tested--technologies.
Either or both of these challenges could limit the potential savings
from DOE's accelerated cleanup initiative.
DOE's Initiative Relies Heavily on Authority That Is Being Challenged
in Court:
DOE is involved in a lawsuit over whether it has the authority to
manage some tank wastes containing lower concentrations of
radioactivity as other than high-level waste. The outcome could affect
DOE's ability to move forward with waste treatment on an accelerated
schedule. If DOE retains its ability to manage much of the waste as
other than high-level waste, it can apply less expensive treatment
methods to that portion of the waste, dispose of the waste on-site, and
close the tanks more quickly. If DOE loses the legal challenge, these
faster and less expensive treatment alternatives may not be available.
Regardless of the outcome, if an extended legal process ensues, DOE may
be prevented from realizing the full potential savings associated with
its accelerated cleanup initiative.
DOE's Authority and Procedures for Designating Waste as "Incidental":
DOE has traditionally managed all of the wastes in its tanks as
high-level waste because the waste resulted primarily from the
reprocessing of spent nuclear fuel and contains significant amounts of
radioactivity. However, DOE based its approach to treatment and
disposal on the radioactivity and actual constituents in the waste, as
well as the source of the waste. Focusing on the radioactivity and
constituents would allow DOE to use less costly and less complicated
treatment approaches for the majority of what is now managed as
high-level waste.
DOE has developed a process for deciding when waste in the tanks should
not be considered high-level waste. In July1999, DOE issued Order 435.1
setting forth procedures for the management of its radioactive wastes.
Under this order, DOE formalized its process for determining which
waste is incidental to reprocessing ("incidental waste"), not high
level waste, and therefore will not be sent to a geological repository
for high-level waste disposal. This process provides a basis for DOE to
treat and dispose of some portion of its wastes less expensively as
low-level or transuranic wastes.
DOE's Order 435.1 establishes the specific criteria for defining the
waste that could be considered incidental to reprocessing and therefore
is not high-level waste and would not require the vitrification
treatment that high-level waste must undergo for disposal purposes. The
criteria were developed in conjunction with the NRC, the governmental
entity with regulatory authority over disposal facilities for
high-level waste. The criteria generally are that the waste (1) has
been or will be processed to remove key radioactive components to the
maximum extent technically and economically practical; (2) will be
disposed of in conformance with the safety requirements for low-
activity waste as laid out in NRC regulations; and (3) will be put in a
solid physical form and will not exceed radioactivity levels set by the
NRC for the most radioactive category of low-level waste, referred to
as "Class C standard."[Footnote 20] DOE must first satisfy itself
internally that these requirements have been met for waste it wants to
determine is waste incidental to reprocessing and therefore not
high-level waste. DOE then obtains a technical review of its
determination from the NRC, which provides a concurrence that DOE has
met its criteria.[Footnote 21] DOE then considers the waste not to be
high-level waste, but waste that can be managed as either low-level or
transuranic waste.
Designation as "Incidental" Would Apply to Much of the Waste:
DOE's ability to define some waste as incidental to reprocessing, and
to then follow a different set of treatment and disposal requirements
for that waste, is central to its overall strategy for addressing its
tank waste. For example, DOE plans to use its incidental waste process
to manage about 90 percent of its 54 million gallons of tank waste at
Hanford as low-level waste, rather than process it through a high-level
waste vitrification facility. Using that approach, most of the waste
would be eligible for treatment and disposal on-site. Such an approach
would be less expensive than treating all of the waste as high-level
waste and sending it for disposal in a high-level waste geologic
repository. DOE has no current estimate of the cost increase if all 94
million gallons of tank wastes had to be treated in a high-level waste
vitrification facility and stored at a geological repository. However,
a 1996 environmental impact statement at the Hanford Site estimated
such an alternative for the Hanford Site alone would add about
$29 billion to $37 billion (in 1995 dollars), nearly doubling project
costs at that site alone, primarily due to increased disposal costs at
the repository. Furthermore, there would probably not be enough space
at the high-level waste repository to dispose of all of this waste.
Hanford is not the only site affected; as of April 2003, DOE had
developed incidental waste determinations for waste at all four of its
high-level waste sites.[Footnote 22] In all, DOE had used its authority
to designate some of its tank waste as low-level or transuranic waste
in seven separate incidental waste determinations (see table 5).
Although two of these determinations were approved prior to the
issuance of Order 435.1, DOE essentially followed the same criteria
found in the subsequent order. DOE is planning to initiate further
incidental waste determinations as it removes the waste from additional
tanks.
Table 5: Description and Status of DOE Incidental Waste Determinations
for Tank Waste:
Site: Hanford; Waste included in incidental waste determination: Those
tank wastes to be separated from high-activity wastes through using
separations processes; Incidental waste to be managed as: Low-level
waste; Estimated volume of incidental waste: Approximately 90 percent
of Hanford's 54 million gallon waste inventory; Status: DOE approved
this determination prior to issuing its Order 435.1, although DOE
essentially followed the same criteria found in 435.1. The NRC agreed
but said that if DOE decides to treat some of its low-activity waste
with technologies other than vitrification, as it plans under its
accelerated initiative, DOE may need to update its determination.
Site: Savannah River; Waste included in incidental waste determination:
Residual tank waste left in tanks 17 and 20 at closure; Incidental
waste to be managed as: Low-level waste; Estimated volume of
incidental waste: Approximately 3500 gallons of residual waste left in
the two tanks; Status: DOE approved this determination prior to
issuing its Order 435.1, although DOE essentially followed the same
criteria found in 435.1.
Site: Savannah River; Waste included in incidental waste determination:
Saltwaste to be treated through the grout (Saltstone) facility;
Incidental waste to be managed as: Low-level waste; Estimated volume
of incidental waste: Up to 12.3 million gallons of tank waste; Status:
DOE approved the determination, but has not implemented it pending
resolution of a lawsuit and other issues.
Site: Savannah River; Waste included in incidental waste determination:
Residual tank waste left in tank 19 at closure; Incidental waste to be
managed as: Low-level waste; Estimated volume of incidental waste:
12,000 to 13,000 gallons of solids in tank 19 at closure; Status:
Awaiting DOE approval.
Site: Idaho National Laboratory; Waste included in incidental waste
determination: Sodium-bearing waste in tanks; Incidental waste to be
managed as: Transuranic waste (to be disposed of at an off-site
transuranic repository); Estimated volume of incidental waste: 900,000
gallons of acidic liquid in tanks; Status: Awaiting DOE approval.
Site: Idaho National Laboratory; Waste included in incidental waste
determination: Residual waste left in tanks at closure; Incidental
waste to be managed as: Low-level waste; Estimated volume of
incidental waste: Actual amount of residuals left in the tank will be
determined at time of individual tank closure; Status: Awaiting NRC
concurrence and DOE approval.
Site: West Valley; Waste included in incidental waste determination:
Sodium-bearing waste originally in tanks; Incidental waste to be
managed as: Low-level waste; Estimated volume of incidental waste:
12,000 gallons; Status: DOE approved this determination.
Source: DOE.
Note: DOE has incidental waste determinations that apply to items other
than tank waste, such as equipment and materials used in managing
high-level waste, including contaminated transfer pumps and job wastes.
We did not include those determinations in this table.
[End of table]
Legal Challenges to DOE's Authority to Manage Its Tank Waste:
DOE is currently involved in a lawsuit focused on its authority to make
incidental waste determinations. In March 2002, the Natural Resources
Defense Council and others filed a lawsuit challenging DOE's authority
to manage its wastes through its incidental waste process.[Footnote 23]
A primary concern of the plaintiffs is that DOE will use its incidental
waste process to permanently leave intensely radioactive waste
sediments in the tanks with only minimal treatment. The lawsuit alleges
that DOE's incidental waste process improperly allows DOE to reclassify
high-level waste as incidental waste that does not need to be treated
in the same way as high-level waste. According to the plaintiffs, the
Nuclear Waste Policy Act defines all waste originating from a given
source--that is, from reprocessing of spent nuclear fuel--as high-level
waste and requires that such waste be managed as high-level waste, yet
DOE has chosen to differentiate its wastes according to the level of
radioactivity and manage them accordingly.
This is not the first legal action that resulted from DOE's process for
determining which part of its waste can be designated as incidental to
reprocessing and will not be managed as high-level waste. For example,
in 1993, the NRC denied a formal petition from the states of Washington
and Oregon requesting that NRC establish the process and criteria for
determining what part of DOE's radioactive waste could be managed as
other than high-level waste.[Footnote 24] The states' request stemmed
from concerns that the criteria DOE was applying to wastes had not been
formally established by regulation and thus had not been given public
scrutiny. The NRC, in its ruling, concluded that DOE's process for
determining what waste was incidental to reprocessing was appropriate
for making individual tank-by-tank incidental waste determinations, and
that the NRC had no jurisdiction. Later, in 1998, the Natural Resources
Defense Council petitioned the NRC to assume immediate licensing
authority over the 51 tanks at the Savannah River Site, arguing that
DOE invented the term "incidental waste" as a means of circumventing
NRC's authority and oversight and, furthermore, that waste to be left
in the bottom of the tanks at Savannah River did not meet DOE's own
definition of incidental waste. The NRC concluded it did not have
regulatory authority over high-level or residual wastes at Savannah
River.[Footnote 25]
Uncertainty about DOE's Authority Could Delay Implementing
New Initiatives:
The current legal challenge, as well as any future challenges, could
affect DOE's efforts to implement its accelerated treatment and
disposal strategies. For example, the challenge could place on hold
indefinitely all pending incidental waste determinations. Since the
start of the lawsuit, DOE has not implemented any incidental waste
determinations and has not yet decided whether to defer or move forward
with its pending incidental waste determinations--such as for closing
tanks. DOE is concerned that moving forward to implement such
determinations could create a risk that the court could place a general
ban on making any decisions about the waste until the legal challenge
is resolved. In addition, final resolution of the challenge could be
further delayed if either party appeals the decision.
A lengthy legal process could result in delays in moving forward
with treatment plans for this waste and delays in closing tanks on an
accelerated schedule. For example, the Idaho National Laboratory plans
to begin closing tanks in the spring of 2003, but approval for the
incidental waste determination to close the tanks by managing tank
waste residuals as low-level waste is still pending.[Footnote 26] A DOE
official at the Idaho National Laboratory told us that while a delay of
several months in obtaining incidental waste approval would not present
an immediate threat to schedule dates, a delay beyond 24 months would
seriously impact the site's ability to meet its accelerated 2012 date
to close all of the tanks. Savannah River also plans to begin closing
additional tanks starting in early 2004.[Footnote 27] A DOE official at
the Savannah River Site said that if the lawsuit continues, the site
may miss a legally binding date agreed to with regulators to begin
closing the tanks.
If the court invalidated DOE's incidental waste determination process,
DOE may need to find an alternative solution for treating and managing
its wastes that would allow it to treat waste with lower concentrations
of radioactivity less expensively. In that case, DOE could begin
experiencing delays affecting progress at all three of the high-level
waste sites that rely on incidental waste determinations. For example,
as one of its savings strategies, DOE plans to manage about
12.3 million gallons of its waste at Savannah River as low-level waste
and treat this waste through a grout facility. DOE estimates it could
begin treating this waste as early as August 2003. Although DOE has
approved an incidental waste determination for this waste, the grout
treatment facility must receive an operating permit from state
regulators. To date, the state has withheld approval for the permit,
pending resolution of the lawsuit. A site official said without the
permit, DOE cannot go forward with its plans to accelerate treatment of
the waste.
At this point, the department does not appear to have a strategy in
place to avoid the potential effects of challenges to its incidental
waste determination authority, either from the current lawsuit or
future challenges. In a December 2002 internal memorandum, the
Assistant Secretary for Environmental Management issued guidelines for
proceeding with making incidental waste determinations as necessary to
meet cleanup commitments and requirements. However, these guidelines
only include ensuring that such determinations meet the legal
requirements of Order 435.1; the guidelines do not include any
alternative strategies for dealing with the waste. DOE officials told
us that they believe the department will prevail in the legal
challenge. Because the outcome of the lawsuit is so uncertain, DOE
believes it would be premature to explore alternative strategies to
overcome potentially significant delays to the program that could
result from a protracted legal conflict or from an adverse decision. As
of April 2003, DOE had just begun to look at potential delays that
could result from a lengthy legal challenge, but had developed no
formal strategy to deal with those delays. Such strategies could range
from exploring alternative approaches for establishing an incidental
waste regulation to asking that the Congress clarify its intentions
regarding DOE's authority to implement an incidental waste policy.
Initiative Also Relies Heavily on Waste Separation Approaches That Will
Not Be Fully Tested:
DOE's initiative also faces key technical challenges related to the
process for separating the various components of the waste. Waste
separation involves a sequential process of filtering and extracting
each major high-level waste constituent, such as cesium-137 and
strontium-90, from the waste. DOE guidance recognizes the risks
involved in implementing a technology without first thoroughly testing
it. In order to save time, however, DOE managers at the Hanford Site
are planning some of their strategies around waste separation
technologies that will not be fully tested before being implemented.
Past projects that took this approach have experienced major problems,
and outside reviewers have raised cautions about DOE's plans to use the
same approach in this instance.
Separating Waste Is Key to Treating It Economically:
Separating high-level waste into its various components is central to
DOE's treatment and disposal plans. Since the 1980s, federal and state
agreements have reflected DOE's plan that the waste be processed so
that at least 90 percent of the radioactivity in high-level waste is
concentrated into a much smaller waste stream and prepared for
permanent isolation in a geological repository. The low-activity waste
portion, which represents the majority of the waste volume but
significantly less radioactivity, must also be immobilized according to
federal and state agreements.
Separating the waste components is important not only to comply with
federal and state agreements, but also to meet waste cleanup schedule
and cost goals. If the waste is not separated, all of it--about
94 million gallons--may have to be treated as high-level waste and
disposed of in the geological repository. Doing so would require a much
larger repository than currently planned and drive up disposal costs
by billions of dollars. Successful separation will substantially reduce
the volume of waste needing disposal at the repository, as well as the
time and cost required to prepare it for disposal, and allow less
expensive methods to be used in treating and disposing of the remaining
low-activity waste.
The waste separation process is complicated, difficult, and unique in
scope and size at each site. The waste differs among sites not only in
volume but also in the way it has been generated, managed, and stored
over the years.[Footnote 28] Although the main steps in the process may
vary, waste separation generally involves a sequential process of
filtering and extracting various high-level waste constituents from the
tank waste (see figure 4). The waste treatment approach at the Hanford
Site involves designing, building, and operating one-of-a-kind
separations processes and facilities. Developing a successful waste
separations process has proved challenging for DOE in the past,
especially at Savannah River, and the current plans for Hanford are no
less challenging.
Figure 4: Simplified Description of Key Steps in Hanford's Proposed
Process for Separating High-Level Waste Constituents:
[See PDF for image]
[A] Yttrium-90 and barium-137m, which are generated from strontium-90
and cesium-137 respectively, are also present in the waste but
additional steps to separate these constituents are not necessary
because after separation from their related constituents (strontium-90
and cesium-137), they will decay within a few weeks until they are no
longer radioactive.
[B] DOE's original plan was to remove technetium-99 at the same time as
cesium-137. However, DOE officials at the Hanford Site now plan to
leave technetium-99 in the low-activity waste stream rather than
separating and diverting it to the high-level waste stream where it
would be vitrified.
[C] Both the high-level and low-activity waste streams contain various
components of hazardous waste. Some hazardous components will be
destroyed during the vitrification process. DOE plans to apply to the
Environmental Protection Agency to have the remaining hazardous
components declared safe for long-term storage and disposal. If
successful, the components will remain in the immobilized waste.
[End of figure]
Hanford Plans to Build Facilities to Separate Waste before Fully
Testing the Separation Processes to Be Used:
At its Hanford site, DOE intends to build a facility for separating the
waste before fully testing the separation processes that will be used.
The technology for separating waste components at Hanford is being
developed at several laboratories, including the Savannah River
Technology Center. These facilities are performing tests to help
validate underlying assumptions about how the processes will work. The
laboratory testing includes a combination of pilot-scale testing of
major individual processes and use of operational data for certain of
those processes for which DOE officials said they had extensive
experience. However, integrated testing will not be completed until
full-scale facilities are constructed. DOE plans to fully test the
processes for the first time during the operational tests of the newly
constructed facilities.
This approach does not fully reflect DOE guidance for incorporating new
or complex technology into a project, which calls for ensuring that the
technology is mature before integrating it into a project. More
specifically, DOE's project management Order 413.3 requires DOE to
assess the risks associated with technology at various phases of a
project's development. For projects with significant technical
uncertainties that could affect cost and schedule, corrective action
plans are required to determine how the uncertainties will be resolved
before the projects can proceed. In addition to this order, DOE has
drafted supplementary project management guidance. This guidance
suggests that technologies are to be developed to a reasonable level of
maturity before a project can progress to full implementation to reduce
risks and avoid cost increases and schedule delays. The guidance
suggests that DOE avoid the risk of performing concurrent facility
design and technology development.
The laboratories working to develop Hanford's waste separation process
have identified several technical uncertainties, which they are working
to address. These uncertainties or critical technology risks include
problems with separating waste solids through an elaborate filtration
system, problems associated with mixing the waste during separation
processes, and various problems associated with the low-activity waste
evaporator. The contractor is also concerned about the availability and
performance of a special resin for separating out cesium-137, a
radioactive constituent. The resin is currently produced by only one
supplier, and that supplier currently does not have the manufacturing
capability to produce the resin in the quantities needed for DOE's
full-scale operations, according to contractor officials. In an effort
to resolve this uncertainty, DOE's construction contractor has asked
the manufacturer to expand resin production capability, and in April
2003, DOE signed a contract modification that allows alternative resins
to be used in the separation process.
Given these and other uncertainties, Hanford's construction
contractor and outside experts have seen Hanford's approach as
having high technical risk and have recommended integrated testing
during project development.
* In April 2002, concerned about the potential for operational problems
with the waste separation processes, Hanford's construction contractor
proposed building an integrated testing facility to confirm that
Hanford's processes will work at a significantly larger scale than has
been tested to date. The contractor proposed conducting fully
integrated tests in a pilot facility using simulated waste before full-
scale separation facilities are completed. The contractor estimated the
cost of the pilot facility at between $6 million and $12 million.
* In October 2002, an independent peer review group of industry experts
concluded that an integrated pilot plant for interim testing to confirm
the technical processes was a preferred approach. Several other
independent experts we interviewed also shared this view. These experts
are associated with the National Research Council and various research
organizations, universities, and private institutions. These experts
emphasized that performing integrated testing to verify that separation
processes will work is an essential step, especially for treating
Hanford's unique waste in the complicated waste treatment facilities
that Hanford is building.
In contrast to these views, DOE's Office of River Protection and the
construction contractor decided not to construct an integrated pilot
facility and instead to accept a higher-risk approach. DOE officials
said they wanted to avoid increasing project costs and schedule delays,
which they believe will result from building a testing facility.
Instead, Hanford officials said that they will continue to conduct
pilot-scale tests of major separation processes. DOE officials said
they believe this testing will provide assurance that the separation
processes will function in an integrated manner. After the full-scale
treatment facilities are constructed, DOE plans to fully test and
demonstrate the separation process during facility startup operations.
Full testing of Hanford's separation process may be a bigger challenge
than originally envisioned. In April 2003, DOE modified the
construction contract for the waste treatment facilities and adopted a
schedule compressing the facility testing and startup period from
4 years to about 2.5 years. To meet this compressed schedule, Hanford's
construction contractor decided in late April 2003 to drop its proposal
for the pilot plant. Instead, the contractor plans to continue
laboratory testing of separation processes in an effort to simulate the
results of an integrated pilot plant. While contractor officials stated
that their original proposal for an integrated pilot plant was
technically sound, they withdrew the proposal in order to ensure that
they could meet revised contract schedule and budget commitments.
Past Experience at Savannah River Shows Consequences of Deviating from
Technology Development Guidelines:
The consequences of not adhering to sound technology development
guidelines can be severe. At the Savannah River Site, for example,
DOE invested nearly $500 million over nearly 15 years to develop a
waste separations process, called in-tank precipitation, to treat
Savannah River's high-level waste. While laboratory tests of this
process were viewed as successful, DOE did not conduct adequate testing
of the components until it started full-scale operations in the newly
constructed facility. DOE followed this approach, in part, because the
technology was commercially available. When DOE started full-scale
operations, major problems occurred. Benzene, a dangerously flammable
byproduct, was produced in large quantities. Operations were stopped
after DOE spent about $500 million because experts could not explain
how or why benzene was being produced and could not determine how to
economically reconfigure the facility to minimize it. Consequences of
this technology failure included significant cost increases, schedule
delays, a full-scale facility that did not work, and a less-than-
optimum waste treatment operation without a viable separation process.
Savannah River is now taking steps to develop and implement a new
separation technology at an additional cost of about $1.8 billion and a
delay of about 7 years.[Footnote 29]
Subsequent assessments of the problems that developed at Savannah River
found that DOE (1) relied on laboratory-scale tests to demonstrate
separation processes, (2) believed that technical problems could be
resolved later during facility construction and startup, and
(3) decided to scale up the technology from lab tests to full-scale
without the benefit of using additional testing facilities to confirm
that processes would work at a larger scale. Officials at Hanford are
following this same approach. Several experts with whom we talked
cautioned that if separation processes at Hanford do not work as
planned, facilities will have to be retrofitted, and potential cost
increases and schedule delays can be much greater than those associated
with integrated process testing in a pilot facility.
Opportunities Exist to Explore Additional Cost Savings and
to Strengthen Program Management:
In addition to the potential cost savings identified in the accelerated
site cleanup plans, DOE continues to develop and evaluate additional
proposals to reduce costs, but is still in the process of fully
assessing these proposals. Because DOE is still evaluating these
proposals, the potential cost savings have not been fully developed,
but could be in the range of several billion dollars, if successfully
implemented. At the Savannah River and Hanford sites, for example, DOE
is identifying ways to increase the amount of waste that can be placed
in its high-level waste canisters to reduce treatment and disposal
costs. DOE also has a number of initiatives under way to improve
overall program management. However, we are concerned that they may not
be adequate. In our examinations of problems that have plagued DOE's
project management over the years, three contributing factors often
emerged--making key project decisions without rigorous analysis,
incorporating new technology before it has received sufficient testing,
and using a "fast-track" approach (concurrent design and construction)
on complex projects. Ensuring that these weaknesses are addressed as
part of its program management initiatives would further improve the
management of the program and increase the chances for success.
DOE Is Considering Additional Potential Opportunities to Reduce Costs:
DOE is continuing to identify other proposals for reducing costs under
its accelerated cleanup initiative. Senior Environmental Management
officials realize that the proposals to accelerate cleanup identified
in site performance management plans do not represent a complete set of
options for full achievement of DOE's savings goals. To pursue
additional potential opportunities, the Assistant Secretary for
Environmental Management commissioned several special project teams to
evaluate additional program improvements and cost-savings
opportunities. One of these teams, the high-level waste project team,
has completed the initial phase of its work. According to DOE's
high-level waste project team leader, it may be some time before their
proposals are fully assessed and decisions are made about how best to
proceed. The Assistant Secretary will consider the proposals from the
project teams, but has not stated when final decisions will occur.
Among the proposals that DOE is considering, the ones that appear to
offer significant cost-savings opportunities would increase the amount
of waste placed in each disposal canister. We discussed these cost-
savings opportunities with both Savannah River and Hanford officials
during our review. DOE officials at those sites have identified these
potential savings opportunities as deserving further consideration, but
have not yet fully assessed the potential benefits, or overcome
technical and operational barriers.
Opportunities at Savannah River Look Promising but Have Not Been
Fully Demonstrated:
Savannah River officials are working to reduce costs by increasing the
amount of waste immobilized in glass and placed in each disposal
canister. They have proposed increasing the amount of waste in each
canister by developing different blends of glass material, called frit,
that they believe can be tailored to each batch of waste. The amount of
waste that can be placed into a canister depends on a complex set of
factors, including the specific mix of radioactive material combined
with other chemicals in the waste, such as chromium and sulfate, that
affect the processing and quality of the immobilized product. These
factors affect the percentage of waste than can be placed in each
canister because they indicate the likelihood that radioactive
constituents could leach out of the immobilizing glass medium and into
the environment. The greater the potential for leaching, the lower the
allowable percentage of waste and the higher the percentage of glass
frit that must be used. DOE determines that a consistently acceptable
glass is produced by evaluating the leaching rates of the glass, using
a combination of chemical analysis and predictive modeling.
Based on a recent improvement made to DOE's predictive model involving
adjustments to the required temperature of the melted waste, and
changes to the type of glass frit used, Savannah River officials
believe they can increase the amount of waste loaded in each canister
from 28 percent to about 35 percent and, for at least one waste batch,
to nearly 50 percent. Savannah River plans to implement this new
process and begin increasing the amount of waste in each canister in
June 2003. If successful, Savannah River's improved approach could
reduce the number of canisters needed by about 1,000 canisters and save
about $2.7 billion, based on preliminary estimates.
Beyond the specific improvements Savannah River officials have already
identified, there may be an additional way to increase the loading of
waste into disposal canisters, resulting in additional savings for DOE.
During our review, we determined that DOE's Offices of Environmental
Management and Civilian Radioactive Waste Management (Radioactive Waste
Management) have been using different acceptance criteria for
evaluating the rate at which waste could leach out of the glass in the
disposal canisters. By conforming to the less restrictive Radioactive
Waste Management criteria, Environmental Management could possibly
increase the amount of waste in the canisters to a higher
level.[Footnote 30] After examining this possibility, Environmental
Management officials at Savannah River said that, if the higher waste
loading could be achieved, this change could eliminate the need for up
to 650 canisters. This may permit further cost savings of about
$1.7 billion. The Savannah River officials stated that they were
continuing to examine this cost-savings possibility.
Because Opportunities at Hanford Are in Early Development, Savings Are
Not Yet Known:
The Hanford Site has also proposed strategies to decrease the number of
high-level waste canisters that it will need, but its approach is in a
very early stage of development. In November 2002, Hanford proposed
broadening the high-level waste acceptance criteria to allow waste
forms other than standard borosilicate glass--the type of glass being
used at Savannah River and initially planned for Hanford--to be
accepted for immobilizing high-level waste. Hanford's proposal is based
on recent changes to NRC's disposal requirements that will allow for
alternative waste forms to be sent to the repository.[Footnote 31]
These changes may allow Hanford to package its high-level waste in
fewer canisters.
Although it is unclear whether DOE orders will be changed to allow
these other waste forms, DOE has significant incentives to do so.
Reducing the number of canisters at Hanford is especially important
because, based on the expected production capacity of the high-level
waste vitrification plant, only a maximum of 9,600 of the projected
12,800 canisters that DOE will need can be filled with waste by the
2028 scheduled completion date. However, by using other types of glass,
Hanford estimates that it may be able to reduce its need for disposal
canisters by 2,500 to 3,900 canisters.[Footnote 32] If such a
significant reduction in the number of canisters produced is possible,
it could shorten Hanford's high-level waste treatment schedule by
6 years, save billions of dollars, and help to meet its scheduled
completion date. However, the wide range of Hanford's estimate reflects
the rough nature of its proposal and that cost savings have not yet
been fully estimated.
DOE Has Opportunities to Improve Management of the Program by
Addressing Previously Identified Weaknesses:
In addition to DOE's efforts to identify site-specific proposals for
saving time and money, DOE is also undertaking management improvements
using teams to study individual issues. Nine teams are currently in
place, while other teams to address issues such as using breakthrough
business processes in waste cleanup and improving the environmental
review process to better support decision-making have not yet been
formed. Each team has a disciplined management process to
follow,[Footnote 33] and even after the teams' work is completed, any
implementation will take time. These efforts are in the early stages,
and therefore it is unclear if they will be effective in correcting the
causes of the performance problems DOE and others have identified.
We are concerned, however, that these management reforms may not go far
enough in addressing performance problems with the high-level waste
program. Our concerns stem from our review of initiatives underway in
the management teams, our discussions with DOE officials, and our past
and current work, as well as work by others inside and outside DOE. We
have identified three recurring weaknesses in DOE's management of
cleanup projects that we believe need to be addressed as part of this
overall review. These weaknesses cut across the various issues that the
teams are working on and are often found at the center of problems that
have been identified. Two of the three weaknesses have been discussed
earlier in this report, as we have identified these as potentially
significant obstacles to achieving savings--lack of rigor in the
analysis supporting key decisions, and incorporating technology into
projects before it is sufficiently mature. The final area of weakness
involves using "fast-track" methods to begin construction of complex
facilities before sufficient planning and design have taken place.
Key Decisions Not Always Supported by Rigorous Current Analysis:
DOE's project management guidance emphasizes the importance of rigorous
and current analysis to support decision-making during the development
of DOE projects. All DOE projects with costs greater than $5 million
require risk management activities, including a thorough analysis, to
be applied continuously, adjusting these analyses throughout the
process as necessary to ensure DOE is pursuing the best value
alternative at the lowest cost. Similarly, the Office of Management and
Budget guidance states that agencies should validate earlier planning
decisions with updated information before finalizing decisions to
construct facilities. This validation is particularly important where
early cost comparisons are susceptible to uncertainties and change.
However, DOE does not always follow this guidance. Proceeding without
rigorous review has been a recurring cause of many of the problems we
have identified in past DOE projects. For example, regarding the need
to validate planning decisions with updated information before
finalizing decisions, the decision at Hanford to construct a
vitrification plant to treat Hanford's low-activity waste has not
undergone such a validation. Hanford's analysis justifying the cost of
this approach was prepared in 1999 and was based on technical
performance data, disposal assumptions, and cost data developed in the
early to mid-1990s--conditions that are no longer applicable. For
example, the 1999 analysis compared DOE's low-activity vitrification
approach with a disposal approach developed in the early 1990s that
involved large underground grout vaults with elaborate environmental
controls. Although this grout approach was abandoned in 1994, DOE still
used these disposal assumptions for the 1999 comparison and analysis.
Since that time other conditions have changed, including the
performance capabilities of alternative technologies such as grout, the
relative costs of different technologies, and the amount of waste DOE
actually intends to process through a vitrification plant. These
changes suggest that earlier planning decisions need to be validated
with updated information to ensure that the current approach is
reasonable and appropriate. DOE's high-level waste project team also
recognized that the DOE officials at Hanford had not performed a
current, rigorous analysis of low-activity waste treatment options
including the use of grout as an alternative to vitrification, and
encouraged the Hanford site to update its analysis based on current
waste treatment and disposal assumptions. Hanford officials responded
in April 2003 by developing life-cycle cost estimates that compared the
cost of alternate low-activity waste approaches. However, they did not
fully reassess the decision to vitrify low-activity waste. DOE
officials at Hanford told us they do not plan to reassess the decision
to construct a low-activity vitrification facility because their
compliance agreement with the state of Washington calls for
vitrification of this waste. They also stated that vitrification is a
technology needed for destroying hazardous constituents in a portion of
the waste.
In our previous work, we noted a similar lack of rigor in reevaluating
DOE decisions as conditions change. For example, at three sites--
Fernald, Ohio; Oak Ridge, Tennessee; and the Idaho National Laboratory-
-DOE was faced with a decision about whether to dispose of low-level
waste on-site or to use off-site commercial disposal facilities.
Between the time that DOE decided to develop on-site disposal
facilities at these three sites and the time that construction actually
began, conditions changed that affected the usefulness of earlier cost
estimates. However, DOE officials at the sites made little effort to
update and reevaluate the original cost comparisons to validate the on-
site disposal decision.[Footnote 34] In July 2002, DOE's Office of
Environmental Management issued guidance to implement our
recommendation to validate cost comparisons before constructing or
expanding low-level waste disposal facilities at these three sites.
This weakness cuts across the issues that the DOE teams are working on;
no DOE team appears to be currently addressing it. However, DOE
managers need to ensure that it receives proper consideration as these
management improvement efforts proceed.
New Technology Is Incorporated before It Is Sufficiently Mature:
Our work on Department of Defense acquisitions has documented a set of
"best practices" used by industry for integrating new technology into
major projects. We reported in July 1999 that the maturity of a
technology at the start of a project is an important determinant of
success.[Footnote 35] As technology develops from preconceptual design
through preliminary design and testing, the maturity of the technology
increases and the risks associated with incorporating that design into
a project decrease. Waiting until technology is well-developed and
tested before integrating it into a project will greatly increase the
chances of meeting cost, schedule, and technical baselines. On the
other hand, integrating technology that is not fully mature into a
project greatly increases the risk of having cost increases and
schedule delays. According to industry experts, correcting problems
after a project has begun can cost 10 times as much as resolving
technology problems beforehand.
DOE's project management guidance issued in October 2000 is consistent
with these best practices. The guidance discusses technology
development and sets out suggested steps to ensure that new technology
is brought to a sufficient level of maturity at each decision point in
a project. For example, during the conceptual design phase of a
project, "proof of concept" testing should be performed before approval
to proceed to the preliminary design phase. Furthermore, the guidance
states that projects that attempt to concurrently develop the
technology and design the facility proceed with ill-defined risks to
all three baselines--cost, schedule, and technical.
Nevertheless, as we discussed earlier in this report, DOE sites
continue to integrate immature technologies into their projects. For
example, at Hanford, DOE is constructing a facility to separate
high-level waste components, although integrated testing of the many
steps in the separations process has not occurred and will not occur
until after the facility is completed. DOE, trying to keep the project
on schedule and within budget, has decided the risks associated with
this approach are acceptable. However, there are many projects in which
this approach created schedule delays and unexpected costs. The
continued reliance on this approach in the face of so many past
problems is a signal of an area that needs careful attention as DOE
proceeds with its management reform efforts. At present, no DOE
management team is addressing this issue.
Facility Construction Starts before Design Is Sufficiently Developed:
Finally, we have concerns about DOE's practice of launching into
construction of complex, one-of-a-kind facilities well before their
final design is sufficiently developed, again in an effort to save time
and money. Both DOE guidance and external reviews stress the importance
of adequate upfront planning before beginning project construction.
DOE's project management guidance identifies a series of well-defined
steps before construction begins and suggests that complex projects
with treatment processes that have never before been combined into a
facility do not lend themselves to being expedited. However, DOE
guidance does not explicitly prohibit a fast-track--or concurrent
design and construction--approach to complex, one-of-a-kind projects,
and DOE often follows this approach. For example, at the Hanford Site,
DOE is concurrently designing and constructing facilities for the
largest, most complex environmental cleanup project in the United
States. Problems are already surfacing. Only 24 months after the
contract was awarded, the project was 10 months behind schedule dates,
construction activities have outpaced design work causing inefficient
work sequencing, and DOE has withheld performance fee from the design/
construction contractor because of these problems.
DOE experienced similar problems in concurrent design and construction
activities on other waste treatment facilities. Both the spent nuclear
fuel project at Hanford and the waste separations facility at the
Savannah River Site encountered schedule delays and cost increases in
part because the concurrent approach led to mistakes and rework, and
required extra time and money to address the problems.[Footnote 36] In
its 2001 follow-up report on DOE project management, the National
Research Council noted that inadequate pre-construction planning and
definition of project scope led to cost and schedule overruns on DOE's
cleanup projects.[Footnote 37] The Council reported that research
studies suggest that inadequate project definition accounts for
50 percent of the cost increases for environmental
remediation projects.
Again, no team is specifically examining the "fast-track" approach, yet
it frequently contributed to past problems and DOE continues to use
this approach.
Conclusions:
DOE's efforts to improve its high-level waste cleanup program and to
rein in the uncontrolled growth in project costs and schedules are
important and necessary. The accelerated cleanup initiative represents
at least the hope of treating and disposing of the waste in a more
economical and timely way, although the actual savings are unknown at
this time. Furthermore, specific components of this initiative face key
legal and technical challenges. Much of the potential for success rests
on DOE's continued ability to dispose of large quantities of waste with
relatively low concentrations of radioactivity on-site by applying its
incidental waste process. DOE's authority in this regard has been
challenged in a lawsuit that is still pending. Much of the success also
rests on DOE's ability to obtain successful technical performance from
its as-yet unproven waste separation processes. Any technical problems
with these processes will likely result in costly delays. At DOE's
Hanford Site, we believe the potential for such problems warrants
reconsidering the need for more thorough testing of the processes.
DOE's accelerated cleanup initiative should mark the beginning, not
the end, of DOE's efforts to identify other opportunities to improve
the program by accomplishing the work more quickly, more effectively,
or at less cost. As DOE continues to pursue other management
improvements, it should reassess certain aspects of its current
management approach, including the quality of the analysis underlying
key decisions, the adequacy of its approach to incorporating new
technologies into projects, and the merits of a fast-track approach to
designing and building complex nuclear facilities. Although the
challenges are great, the opportunities for program improvements are
even greater. Therefore, DOE must continue its efforts to clean up its
high-level waste while demonstrating tangible, measurable program
improvements.
Recommendations for Executive Action:
To help ensure that DOE's accelerated cleanup initiative is effective
and that cleanup of high-level waste proceeds in a timely and cost-
effective manner, we recommend that the Secretary of the Department of
Energy:
* seek clarification from the Congress regarding DOE's authority for
designating waste as incidental to reprocessing if the current
challenge becomes an extended legal process, in order to help DOE
determine what strategy it needs to move its initiative forward and
realize potential savings;
* reassess the potential risks, costs, and benefits of constructing an
integrated pilot-scale waste separation facility at the Hanford site to
more fully test separation technologies before completing construction
of a full-scale facility; and:
* ensure that DOE's high-level waste projects (1) include a current and
rigorous analysis of the risks, costs, and benefits associated with the
decisions being implemented, in accordance with OMB guidance;
(2) incorporate new technologies consistent with best practices and
DOE guidance so that risks and costs are more effectively managed; and
(3) are carefully evaluated as to the appropriateness of using a fast-
track approach to designing and constructing complex nuclear
facilities, and that the potential risks and costs associated with this
approach are explicitly identified and considered.
Agency Comments:
We provided a draft of this report to the Department of Energy for its
review and comment. DOE's Assistant Secretary for Environmental
Management responded for DOE. DOE's written comments acknowledged the
challenges that DOE faces in its high-level waste program, as discussed
in our report. DOE cited its recent initiative to accelerate cleanup
and reduce environmental risks as its response to those challenges. DOE
agreed to consider our recommendation to seek clarification from the
Congress regarding DOE's authority to determine what waste is
incidental to reprocessing, if legal challenges to DOE's authority to
make such determinations have a significant effect on implementing
proposed cost-saving and risk-reduction initiatives. However, DOE
disagreed with our recommendation that it conduct integrated pilot
testing of its waste separation processes at Hanford while constructing
a full-scale facility. In addition, regarding opportunities to improve
program management, DOE said that at the Hanford project it was already
effectively conducting rigorous analyses to support decision-making,
incorporating new technologies into the project consistent with best
practices and agency guidelines, and using a fast-track approach of
concurrently designing and building complex nuclear facilities.
Regarding our recommendation that DOE pursue integrated, pilot-scale
testing of the waste separations facility at Hanford, DOE believes that
its current approach is adequate to manage the risks associated with
designing and constructing the facility. DOE said that it does not
intend to pursue an integrated pilot test facility that we believe
would increase the chances of success with the full-scale facility.
DOE's position is based on two main arguments. DOE believes that (1)
the technologies planned for the separations facility are commercially
available and thus are mature technologies having low technical risk
and (2) relying on pilot testing of individual components of the
separation processes in the laboratory provides adequate mitigation of
the risks involved.
We disagree with DOE's view that the separations approach planned for
the Hanford Site is low risk. DOE has experience with the individual
technologies, but does not have experience in operating an integrated
separations process that incorporates all of the operations required
for Hanford's unique and complex waste. Furthermore, DOE has
experienced problems with another separation facility where adequate
testing was not done until the facility was fully constructed--the in-
tank precipitation facility at Savannah River. In that case, the
separations process failed after DOE spent about $500 million trying to
make it work properly. And the primary technologies used at Savannah
River were also in use commercially, but had not been fully adapted to
the unique Savannah River wastes.
We also disagree that DOE's plan to conduct extensive testing in the
laboratory to mitigate the technology risks involved with the
separation processes will provide adequate assurance that the full-
scale separations facility will perform effectively. Numerous experts
and DOE's contractor have proposed constructing and operating an
integrated pilot-scale facility. They made the proposals while knowing
about DOE's intention to conduct extensive laboratory testing of
separation processes. The contractor as well as outside experts view
the separations facility as having significant project risk, in
contrast to DOE's statement that the separation processes pose low
project risk. Given the risks associated with fully constructing the
separations facility before conducting integrated testing and the
cost of any delays associated with having significant problems with the
separation processes once the facility is fully constructed, we
continue to believe that conducting integrated pilot-scale testing is
an important risk-and schedule-management tool and that DOE should
reconsider its use for the Hanford project. DOE officials at Hanford
acknowledged that the pilot facility could be included in the project
without extending the project's schedule.
Regarding management improvement issues, DOE said that we inadequately
portrayed the progress it has made in the three areas in which we
recommended management improvements. However, our report addresses the
three management issues from the broader context of DOE's project
activities over several years and at a number of sites. Our past work
has clearly linked these weaknesses to problems on cleanup projects.
Because DOE did not take issue with that broader context in
this report, but did assert improved performance on the Hanford
project, the following comments are limited to needed improvements to
the Hanford project.
Regarding DOE's view that it performed current and rigorous analyses
of risks, cost, and benefits for the Hanford waste treatment project,
our report illustrates our concerns about the analysis DOE performed to
support its decision to vitrify a portion of Hanford's low-activity
waste. DOE stated that this decision, originally made in 1994, has been
revisited numerous times using rigorous analysis and provided us with
three studies that specifically compared the cost of low-activity waste
vitrification with other approaches, such as grout, to support its
decision. None of these studies included a current and rigorous
analysis of risks, costs, and benefits, as called for in OMB guidance.
For example, even the most recent study, completed in 2003, was
primarily based on technical performance, disposal assumptions, and
cost data developed in the early 1990s. The team leader of the high-
level waste project team confirmed that these analyses were not a full
and rigorous assessment of the risks, cost, and benefits of vitrifying
low-activity waste. Thus, we continue to believe that additional
efforts are needed in this area.
Regarding our recommendation to follow best practices and DOE guidance
when incorporating new technology into cleanup projects, DOE commented
that it was continuing to consider opportunities to improve the Hanford
project and that the contractor was using a risk-based management
process to address technical and programmatic project risks. We agree
that a risk-based management process is appropriate on the project.
However, we continue to believe that DOE's approach to incorporating
the separation technologies planned for the Hanford project is not
fully consistent with best practices and DOE guidance because the
approach involves incorporating technologies into the project before
they have been fully tested as an integrated process. This testing of
the integrated process in an operational mode is needed to demonstrate
that the technologies are sufficiently mature to ensure their effective
performance when deployed on the project.
Concerning the appropriateness of using a "fast-track" construction
approach to design and construct complex nuclear facilities for the
Hanford project, DOE said that our report incorrectly portrays the
overall strategy for the Hanford project. We believe our report
accurately describes DOE's approach, which includes using concurrent
design, construction, and technology development. We have previously
reported on the risks associated with this approach, including the
increased potential for project schedule delays and cost increases.
DOE also provided technical clarifications and corrections to our
report, which we incorporated as appropriate. The full text of DOE's
comments and our responses are presented in appendix II.
We conducted our review from July 2002 through May 2003, in accordance
with generally accepted government auditing standards. Appendix I
provides details on our scope and methodology.
As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after the date of this letter. At that time, we will send copies to the
Secretary of Energy. We will also make copies available to others on
request. In addition, the report will be available at no charge on the
GAO Web site at http://www.gao.gov. If you or your staff have any
questions on this report, please call me at (202) 512-3841. Other staff
contributing to this report are listed in appendix III.
Sincerely yours,
Robin M. Nazzaro
Director, Natural Resources and Environment:
Signed by Robin M. Nazzaro:
[End of section]
Appendix I: Scope and Methodology:
To describe the components of DOE's high-level waste and the process
involved in preparing the waste for permanent disposal, we analyzed
information and documents provided by DOE officials and contractors at
the four sites containing DOE high-level waste: Hanford, Washington;
Idaho National Laboratory, Idaho; Savannah River, South Carolina; and
West Valley, New York. We did not independently verify the accuracy of
the information provided by each DOE site. From these same sites, we
also obtained information on the types, age, and condition of the
facilities used to store the high-level waste. To assist in evaluating
technical aspects of high-level waste, we obtained assistance from our
technical consultant, Dr. George Hinman. Dr. Hinman has a Doctor of
Science degree in physics, is Professor Emeritus at the Washington
State University, and has extensive experience in the nuclear energy
field in industry, government, and academia.
To examine DOE's initiative for accelerating its high-level waste
cleanup and the associated potential cost savings, we obtained and
reviewed the Performance Management Plans for each of DOE's four
high-level waste sites (Hanford, Savannah River, Idaho National
Laboratory, and West Valley). We discussed these initiatives thoroughly
with officials from each of the sites and obtained documentation
discussing the proposed initiatives, as well as savings estimates. We
reported all dollar estimates as provided by DOE in current dollars and
did not adjust these figures to constant dollars. We did not verify the
accuracy of cost information provided by DOE. We also reviewed guidance
from the Office of Management and Budget circulars, especially circular
A-94, on the type of analysis that federal agencies should use when
developing benefit and cost estimates, and compared DOE's proposed
savings estimates to that guidance. We analyzed savings estimate
figures provided by DOE's Savannah River staff, discounting the dollars
to provide an estimate in constant dollars.
To identify the legal challenges DOE faces, we obtained documentation
relating to the current Natural Resources Defense Council (NRDC)
lawsuit. We discussed the lawsuit separately with attorneys from the
NRDC, as well as from DOE. We also discussed the waste-incidental-to-
reprocessing process with staff at the NRC. We documented each site's
incidental waste determinations, as well as historical information on
the development of DOE Order 435.1. We also reviewed the appropriate
statutes, related regulations and orders. To identify the technical
challenges and issues that must be resolved to realize potential
savings, we obtained documentation on the technical uncertainties and
risks associated with the waste treatment approaches at the Hanford,
Idaho National Laboratory, and Savannah River sites. Because waste
separation is central to successful high-level waste treatment and
disposal, we documented the status of each site's approach. We
identified the major technical concerns, uncertainties, and risks
associated with the waste separations approaches and discussed them
with DOE and contractor officials at each site. We also visited the
Savannah River Technology Center to review the progress and results of
laboratory tests conducted to develop the Savannah River and Hanford
sites' waste separations technology. With the assistance of our
technical consultant, we contacted a variety of independent experts in
industry and academia to obtain their views on the risks associated
with these technologies.
To determine additional opportunities for reducing high-level waste
program costs, we reviewed DOE waste acceptance policies and
requirements, planning documents, position papers, and internal memos.
We discussed the opportunities with DOE officials, contractors, and
laboratory officials primarily at the Hanford, Idaho National
Laboratory, and Savannah River sites. We compared the cost-savings
concepts with those presented in performance management plans at each
site to document that they represented additional opportunities. We
also relied on the expertise of our technical consultant to help assess
the technical viability of DOE's proposals. To determine opportunities
to improve the management of the program, we reviewed DOE's Top-to-
Bottom report and we discussed management reform proposals with
officials at DOE headquarters. We also obtained documentation on DOE's
project review teams. We reviewed prior reports from GAO, DOE's IG and
the National Research Council to identify recurring weaknesses in DOE
management of its cleanup program, and we developed current examples of
those weaknesses from our work at the high-level waste sites and
meetings with DOE officials. We also compared management weaknesses we
identified to DOE's current reform efforts to determine the extent to
which the weaknesses were being addressed and to identify areas needing
continued attention.
We conducted our review from July 2002 through May 2003 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: Comments from the Department of Energy:
Note: GAO's comments supplementing those in the report text appear at
the end of this appendix.
See comment 3.
Now on p. 2. See comment 2.
See comment 1.
Now on p. 19. See comment 4.
Now on p. 18. See comment 4.
Now on p. 15. See comment 6.
Now on p. 14. See comment 5.
See comment 4.
Now on p. 8. See comment 4.
See comment 10.
See comment 9.
Now on p. 21. See comment 8.
Now on p. 20. See comment 7.
See comment 4.
See comment 13.
Now on p. 23. See comment 12.
See comment 11.
Now on p. 32. See comment 15.
Now on p. 30. See comment 4.
See comment 14.
See comment 4.
Now on p. 37. See comment 4.
Now on p. 37. See comment 4.
Now on p. 36. See comment 4.
Now on p. 36. See comment 4.
Now on p. 40. See comment 16.
Now on p. 39. See comment 15.
Now on p. 43. See comment 15.
Now on p. 43. See comment 15.
Now on p. 43. See comment 15.
Now on p. 41. See comment 15.
Department of Energy Washington, DC 20585:
MAY 30 2003:
Ms. Robin M. Nazzaro:
Director, Natural Resources and Environment
United States General Accounting Office
Washington, D.C. 20548:
Dear Ms. Nazzaro:
Thank you for the opportunity to comment on the draft report entitled
Challenges to Achieving Potential Savings in DOE's High-Level Waste
Cleanup Program (GAO-03-593). As an initial matter, I must preface our
comments with the observation that the matters discussed in the report
and our comments involve numerous complex technical, legal, and other
considerations. Given these complexities, time, and other constraints
on our response, our comments should not be viewed as exhaustive or as
representing the Department's final views on these matters.
I agree that there are a number of challenges that the Department must
meet in order to achieve the savings we have proposed in remediating
DOE's high-level waste (HLW), as these issues are the same as those
identified by our Top-to-Bottom review of the Environmental Management
(EM) program we completed in February 2002. That review confirmed that
the HLW program is the highest-cost, highest-risk area of the EM
cleanup effort and has thus shaped our ongoing initiatives and actions
for the past 15 months.
In response to the Top-to-Bottom review our HLW sites have initiated
actions-to reduce risk and accelerate remediation of our high-level
waste. These activities are documented in site Performance Management
Plans (PMPs), coordinated with regulators, and include a focus on tank
waste retrieval and treatment at Hanford, reducing the overall schedule
for treating the waste, and hence reducing risk, by about 13 years, and
reducing overall program costs by approximately $20 billion. At the
Savannah River Site we are implementing an approach to retrieve and
treat certain tank wastes in an accelerated manner, that will not
require volumes of waste originally projected to be treated at the
Defense Waste Processing Facility (DWPF), enabling an acceleration of
the HLW cleanup program at SRS by almost 20 years. In your report, you
cited opportunities DOE highlighted to you during your review that we
are pursuing to accelerate risk reduction. Obviously, we are already
incorporating many of these initiatives into our contracts and plan to
continue our actions in regard to further realizing the benefits of
these initiatives.
I have also moved to further institutionalize corrective actions to
address the recommendations of the Top-to-Bottom review report through
establishment of
special projects to address specific major program areas within the
Office of Environmental Management, each with a designated project
manager. Through these projects, with dedicated project managers, we
are imbuing EM with a cadre of management and staff personnel with the
discipline to perform the planning, analyses, and evaluations necessary
to implement necessary actions to accelerate risk reduction and
completion of the EM program. I am also restructuring the EM
organization to further this effort and would be happy to meet with you
to fully explain these initiatives.
In regards to the specific recommendation to reassess constructing a
pilot-scale waste separations facility at Hanford, the draft report
does not fully describe the different activities our Office of River
Protection is undertaking to minimize technical, programmatic, cost,
and schedule risk on the Hanford Waste Treatment Project. DOE does not
intend to construct an integrated pilot facility to test the selected
separations technologies; however, as the enclosed comments discuss,
extensive testing is being performed of the unit operations, in a
series manner, to ensure success of the approach.
Regarding the draft report's recommendation to seek clarification from
Congress regarding DOE's ability to make waste incidental to
reprocessing determinations, I will closely monitor the hearings and
upcoming decisions on the legal challenge to DOE's authority and will
keep this option in mind for possible future action.
Enclosed are our detailed set of requirements to clarify specific
topics in the draft report or to provide additional information
regarding DOE activities on draft report topics.
If you have any questions, please call me at (202) 586-7709 or Ms.
Patrice M. Bubar, Associate Deputy Assistant Secretary, Office of
Integration and Disposition, at (202) 586-5151.
Sincerely,
Jessie Hill Roberson
Assistant Secretary for Environmental Management:
Signed by Jessie Hill Roberson:
Enclosure:
DOE Comments on GAO May 2003 Draft Report, "Challenges to Achieving
Potential Savings in DOE's High-Level Waste Cleanup Program":
General Comments on Report:
DOE notes although it is making the following comments, the absence of
a DOE comment on certain statements should not necessarily be construed
as acceptance or endorsement of the factual or legal accuracy or
completeness of any matter for which comments are not submitted.
Throughout the draft report statements are included that note DOE plans
to dispose of the low-activity fraction of separated tank wastes on-
site. While the statement is generally true, it may not be true for the
West Valley Demonstration Project or at the Idaho National Laboratory.
DOE proposes that this be changed to note that such wastes might be
disposed onsite or at other designated locations.
Comments on Summary of Results:
DOE has several comments on these summary results that are discussed
specifically, with comments on specific topical areas. Those comments
will address the following general GAO observations:
Accelerated High-Level Waste (HLW) program cost savings may not be
reliable. Reliance on technologies that are not fully developed or
tested.
Weaknesses in management processes.
DOE should seek clarification from Congress on whether certain wastes
do not need to be treated and disposed as HLW.
Page 6, lines 22 and 23. This sentence implies that all HLW sites are
intending to separate their tank wastes from reprocessing into two
fractions --a high-activity waste fraction and a low-activity fraction.
This is not likely to be true at Idaho, in which plans are not to
separate either the treated calcine or the liquid wastes remaining in
the tanks.
Comments on Background:
Page 6 -Footnote 3.
*The second sentence of the footnote could be interpreted that the
Savannah River Site (SRS), the Idaho National Laboratory (1NL) and the
West Valley Demonstration Project (WVDP) also intentionally discharged
tank wastes to the environment. This is not the case.
*Change second sentence to "In addition, at Hanford, DOE intentionally
discharged about 121 million gallons of relatively low-radioactivity
tank wastes directly into the ground from 1946 to 1966.":
Page 7, third sentence. To reflect actual Congressional language: 1)
add the word "expressly" prior to "authorized," and 2) delete the comma
between "reprocessing" and "and." Also, for the general reader it may
be beneficial to clarify that "long-term storage" in the Congressional
language, and as stated in the draft report, includes disposal.
Page 8, Second sentence. This sentence states that President Reagan
"directed DOE to use the repository being developed under the Nuclear
Waste Policy Act to dispose of defense waste." The exact words from
President Reagan's April 30, 1985, memorandum are "In accordance with
the Act, I find no basis to conclude that a defense only repository is
required and thus, you should proceed with arrangements in conformance
with the Act." The NWPA states "the Secretary shall proceed promptly
with arrangement for the use of one or more of the repositories to be
developed..." In the Government's briefs in NRDC v. Spencer Abraham,
the Department of Justice explains the Government's interpretation that
the President's determination was permissive, allowing DOE to use the
NWPA repository for disposal of defense waste, but that there is no
statutory directive that DOE "shall dispose" of defense waste in such a
repository.
Comments on Section "Processing Can Concentrate the Radioactivity into
a Much Smaller Volume of Waste":
Pages 13 and I4. Use of the term "contaminated water" may introduce new
terminology questions. DOE recognizes this was changed from "waste
water" in the Statement of facts, but rather than inventing a new term
to communicate this point, DOE recommends that the GAO report simply
make the argument that a large constituent of the waste is water.
Therefore, the word "contaminated" could be deleted in the first full
sentence on page 14, and the message would remain the same.
Page 14, Table 2. Under the characterization step, DOE primarily uses
process knowledge to characterize its tanks wastes and performs
sampling to confirm process knowledge, through use of a data-quality
objective process, which is based upon Environmental Protection Agency
approaches.
Comments on Section "Initiative Centers on Ways to Speed Disposal and
Save Money":
Page 17, first bullet. While approaches to HLW acceleration continue to
rely upon treating and managing some tank wastes as low-level or
transuranic waste, this approach has been part of the overall strategy
for managing tank waste since the early 1980s, not just since the late
1980s as stated in this bullet.
Page 18, Table 3. DOE proposes the following corrections to this table:
Change bullets in second column for Hanford as follows:
*First bullet: "Building one higher capacity initial Waste Treatment
and Immobilization Plant (WTP) and eliminating a second large WTP":
*Second bullet: "Developing supplemental technologies to treat and
immobilize a large fraction of the low-activity waste outside of the
WTP.":
Change open bullet under Savannah River, second sentence from "expects"
to "is exploring methods.":
Comments on Section "Baseline Costs Are Not Fully Reliable":
Page I9 and 20. DOE has recognized that it lacked standard
methodologies for developing life-cycle cost baselines. One approach is
to account for costs in constant-year dollars. For purposes of
reporting DOE's liabilities under its Government Results and Reporting
Act requirements, for example, DOE reports its official cost numbers in
constant year 2002 dollars.
Page 20, second paragraph. One of the reasons for the increase in total
project costs was DOE's acknowledgement of risks associated with the
project at the early stages of design. As a result of a contingency
analyses that the Waste Treatment Plant (WTP) contractor conducted to
address cost and schedule project risks, DOE has included a cost
contingency at 80 percent confidence, approximately $500 million. This
contingency accounts for much of the cost growth cited in this section
of the GAO report.
Comments on Section "Accelerated Cost Savings May be Incomplete":
Page 21. Although DOE has not selected a technology for treatment of
its remaining liquid tank wastes at INL, the range of costs for the
candidate technologies was not a factor in developing cost savings
estimates. DOE did not address the costs of treating the liquid tank
wastes in its estimates, since it had not decided upon a technology.
The range of costs for those technologies at $150 to $400 million was
significantly less than the approximate $I billion estimate assumed in
the previous baseline for vitrifying the liquid tank waste. The $7
billion estimate is entirely based upon the differences in strategies
for disposition of the calcine waste.
Comments on Section "Savings Estimates Do Not Reflect Timing
Uncertainty or Non-Budgetary Impacts":
Page 22, first paragraph. Although Idaho HLW program costs do not
reflect a range of costs, the intent of the accelerated program costs
is to provide a basis of general comparison between previous baseline
approaches for accomplishing the EM mission to the new approaches.
There were also uncertainties associated with the previous baseline
approaches; however, a single point estimate was used to define that
baseline. Similarly, a single point estimate is used to define the
expected costs reported in the Idaho Performance Management Plan, but
DOE recognized that uncertainties exist. One mechanism that DOE used to
recognize these risks is a set of issues that need to be worked in
order for each site PMP to be successful. These were catalogued in the
back of each PMP in a section titled "Government Furnished Services and
Items (GFSI)." These GFSI include items the Government must resolve and
time frames for their completion.
Page 22, second paragraph. This paragraph asserts that the INL
accelerated plan does not fully quantify expected environmental and
health risks, associated with packaging HLW calcine as a final waste
form for disposal in a geologic repository. Although a rigorous cost-
benefit analysis was not performed, some advantages are evident:
*The removal of steps associated with: 1) dissolution of the calcine
back to a liquid form; 2) separation of the calcine into high-activity
and low-activity fractions; 3) treating the high-activity fraction via
vitrification; and 4) treating and disposing the low-activity fraction
for disposal as low-level waste, inherently reduce the potential for
worker exposure through reducing the number of activities by which
exposure could occur.
*The deletion of these steps in the approach of sending calcine
directly to the repository also eliminates a number of significant cost
contributors associated with construction and operation of multiple
facilities, while not introducing any new activities that would
increase costs. An exception is the larger number of canisters that
will likely result from packaging the calcine directly for disposal.
Comments on Section "DOE's Authority and Procedures for Designating
Waste as `Incidental"':
Page 24, first paragraph. The characterization of DOE's management of
reprocessing wastes is overly simplistic. For purposes of meeting its
Atomic Energy Act responsibilities, DOE must classify its wastes and
apply its standards for management of those wastes as stated in DOE
Order 435.1, Radioactive Waste Management. This classification process
is dependent upon the definitions and other requirements in DOE Order
435.1. In general these definitions are statutory; however, DOE Order
435.1 includes a process that entails application of criteria that the
report lists in the third paragraph of page 24 of the draft report.
Comments on Section "Designation as 'Incidental' Would Apply to Much of
the Waste":
Page 25, first full paragraph. This paragraph indicates that without
the ability to make waste incidental to reprocessing determinations
"there would probably not be enough space at the HLW repository to
dispose of all this waste." The report should explain instead that
Section 114 of the Nuclear Waste Policy Act, would limit DOE's ability
to dispose of all HLW in the repository.
Page 25, last line; Page 26, Table 5. This sentence should be clarified
to note DOE has not used its authority, under DOE Order 435.1, to
designate some of its tank waste as low-level waste or transuranic
waste in seven separate incidental waste determinations. As noted in
Table 5, two determinations were completed prior to issuance of DOE
Order 435.1, and three are waiting for DOE to approve the
determinations. Only two have been approved under the requirements of
DOE Order 435.1.
Page 26, Table 5. Two corrections to this table are necessary:
While the second INL determination has been provided to NRC for
independent review, NRC does not formally approve the determination as
stated. NRC issues a record of their review including any
recommendations for improvement.
The West Valley determination was for sodium-bearing waste originally
in tanks; however, that waste has been retrieved from the tanks and is
separately stored for subsequent treatment.
Comments on Section "Separating Waste is Key to Treating It
Economically":
Page 30, last paragraph. The second sentence notes that Federal/state
agreements have reflected DOE separating its tank wastes into low-
activity and high-activity fractions; however, at SRS and WVDP such
plans were decided upon in the early 1980s through the National
Environmental Policy Act process and subsequent Records of Decision.
Federal and state agreements also began during this time period.
Page 31, second sentence. For factual accuracy, change "would" to "may.
Pages 31 - 35 Separations Process at Hanford. The report
mischaracterizes the status and approach of the radionuclide
separations process at Hanford. In contrast to GAO's characterization
throughout the report, the separations process for Hanford's tank
wastes is based upon unit operations that DOE and commercial industry
have decades of experience with, i.e., evaporation, filtration, and ion
exchange. For example, in the 1960s and 1970s Hanford used ion exchange
to separate more than twice as much Cs-137 from tank waste as remains
in the tank waste today.
Construction and operation of an integrated pilot plant using simulated
waste was considered by the WTP contractor. However, the information it
would provide would not be available in time to incorporate into the
plant design unless the plant design and construction was delayed
several years. An alternate course was chosen with development and
testing being conducted at the Savannah River Technology Center, in
which each unit operation is pilot tested and the product and recycle
streams produced are collected and process-tested in the receiving unit
operations. This simulates the plant design in that the product from
each unit operation will be collected in tanks and staged before being
fed to the next unit operation. This testing will provide confidence
that the process will function in an integrated manner. Further, when
plant construction is completed, full-scale integrated tests will be
conducted. DOE believes its plan for developing and testing the
separations process poses low project risk based on:
* The extensive DOE and commercial experience with the unit operations
proposed for Hanford's separations process;
* The pilot testing program being conducted that includes product and
recycle stream transfers between unit operations; and:
* The Office of River Protection (ORP) contracted with Bechtel National
Inc. to build a facility that will successfully treat the tank waste.
Under that performance-based
contract, a number of project details are the contractor's
responsibility, including testing and commissioning. Prior to selecting
the current testing approach, the concept of building a pilot
separations plant was identified by the contractor's organization (it
is an obvious consideration) and dismissed by the contractor's
management team. It was one of many alternatives considered on an
ongoing basis by the contractor as part of its continuous improvement
program. Statements that ORP decided not to construct the pilot
facility are misleading.
Comments on Section "DOE is Considering Additional Potential
Opportunities to Reduce Cost":
Page 37, last sentence. This sentence is misleading, and should explain
that while DOE officials at SRS and Hanford have identified potential
savings opportunities and preliminarily quantified these savings, they
continue to overcome technical and operational barriers to increase
canister waste loading.
Page 38, last sentence; Page 39, first two sentences. These sentences
are incorrect and misleading. They appear to confuse two different
issues: I) the RW requirement (as stated in the Waste Acceptance System
Requirements Document) to demonstrate acceptability of HLW borosilicate
glass product consistency using the Product Consistency Test (PCT), and
2) the EM requirement (as stated in the Waste Acceptance Product
Specifications) for using PCT results to demonstrate compliance with
the RW requirement. In the EM document, which provides additional
guidance on acceptable means of demonstrating compliance with the RW
requirements, one acceptable method of meeting the RW requirement is a
statistical analysis of results to demonstrate a high-degree of
confidence that the PCT requirement is met. Additionally, the phrase
"After examining this possibility..." in the second sentence on page 39
is superfluous.
Page 39, footnote #29. This footnote incorrectly interprets the
statistical aspects concerning the PCT (performance confirmation
testing) and the EM guidance. For example, the parenthetical in the
second sentence is a misinterpretation. The PCT generally specifies
that the mean concentrations of lithium, sodium and boron from samples
or process control information are less than the reference or benchmark
glass concentrations. This does not mean that 50 percent of waste will
leach at a higher rate, but rather it means that the actual or
predicted mean will be below the reference or benchmark glass leachate
concentrations for sodium, boron and lithium. RW uses PCT results to
ensure that the glass product is consistently produced within a range
of known composition and phase structures. This provides assurance that
repository-relevant leach testing will provide consistent results to
use to predict glass performance.
Comments on Section "Because Opportunities at Hanford Are in Early
Development, Savings are Not Yet Known":
Page 39, first paragraph. The next to last sentence suggests that
recent changes to NRC's disposal requirements now allow for waste forms
other than standard borosilicate glass to be disposed of in the
repository. This sentence may be misread to suggest that the NRC's
predecessor regulation (10 CFR Part 60) to NRC's current regulation on
repository licensing, 10 CFR Part 63, specified that only HLW in
standard borosilicate glass is acceptable. The NRC's past regulation
did not so specify, nor do the current regulations so specify. Rather,
DOE historically considered borosilicate glass as its reference waste
form for its HLW to be disposed of in the repository.
Comments on Section "Key Decisions Not Always Supported by Rigorous
Current Analysis":
Pages 41 and 42, Low-Activity Waste (LAW) Vitrification. Statements (on
page 42) that DOE did not reassess the decision to vitrify LAW are
incorrect and misleading. The fact that the decision was reassessed and
actions taken is clearly demonstrated by other statements throughout
the report that supplemental LAW treatment technologies, proven in
other venues, are being tested with Hanford wastes, and DOE is planning
to use one or more of those technologies if the testing proves
successful. ORP plans clearly call for using the LAW vitrification
system for only the most problematic portion of the LAW from a disposal
performance perspective (approximately a third of the waste) and to use
alternative systems for other, more easily treated, LAW.
Moreover, GAO auditors were informed that DOE has revisited the
decision numerous times and were made fully aware that during the
period that GAO was conducting its Hanford investigations this spring,
a new internal study had been conducted at the direction of the
Assistant Secretary for Environmental Management. That study developed
life cycle analyses using the best available information (probabilistic
analysis techniques to address data uncertainties) and reported costs
as present values (as recommended by GAO on page 24 of its report). It
analyzed and compared over a dozen combinations of LAW treatment
technologies. Many of the cases evaluated did not include the present
vitrification system as a treatment component while others used it in
combination with other approaches. It concluded that the planned two-
melter LAW vitrification in combination with other supplemental
technologies would provide acceptable performance at the lowest life-
cycle costs if those supplemental technologies prove successful during
ongoing testing with Hanford tank wastes.
The GAO report also did not address the fact that vitrification of at
least a part of Hanford LAW is a preferred technology, due to the
hazardous characteristics in some of the waste that require thermal
destruction.
Page 42, last paragraph. To support consistency in assessments on
whether to site or expand low-level waste disposal sites, DOE will
develop (1) specific recommendations on key factors that should be
included when estimating the life-cycle costs of operating and
maintaining an on-site disposal facility; and (2) guidelines for
developing off-site disposal cost estimates. These cost-estimating
recommendations and guidelines will be incorporated into an Assistant
Secretary for Environmental Management memorandum directing sites to
periodically conduct cost comparisons between on-site and off-site
disposal to ensure that on-site disposal remains the preferred option.
Additionally, DOE issued a guidance memorandum to the field on July 18,
2002, reiterating the need to revisit cost assumptions prior to
expanding existing disposal cells or constructing a new
cell. The guidance provided the field with validated cost comparisons
for DOE sites to use in the decision process for an on-site disposal
facility.
Comments on Section "Facility Construction Starts Before Design is
Sufficiently Developed":
Page 44, second paragraph. DOE believes GAO's comments regarding a fast
track approach and increased waste treatment plant costs wrongly
portray the progress DOE has made in developing the overall strategy
for treating Hanford's tank wastes. The waste treatment plant costs
changed, in part, because of DOE's initiative to accelerate risk
reduction and mission completion and to reduce overall costs. Rather
than initially build a low-capacity plant followed by a second higher
capacity plant a decade later, which would not complete treatment until
2048, DOE has decided to build the first plant to be more capable, to
enable it, along with supplemental LAW treatment, to complete treatment
of the LAW by 2028.
Comments on "Recommendations for Executive Action":
Page 46, first bullet. As noted previously, the separations process to
be implemented in the Separations facility of the WTP is based upon
unit operations that DOE and commercial industry have decades of
experience with, i.e., evaporation, filtration, and ion exchange. DOE
has approved the Hanford WTP contractor's approach for performing
testing and development of the separations process at the Savannah
River Technology Center. The unit operations testing is expected to
provide confidence that the integrated process will function as
intended. Plant tests performed during commissioning will confirm these
results.
Page 46, second bullet. DOE agrees that the current litigation in Idaho
represents some risk to the implementation of its accelerated HLW
remediation program. The Department will continue to explore various
approaches to reduce this programmatic risk, including discussions with
Congressional staff, as part of its regular communications with
Congress.
Page 46, third bullet.
DOE Projects Include Rigorous Analysis:
On page 46, the GAO recommends that DOE projects "... include a current
and rigorous analysis of the risks, cost, and benefits associated with
the decisions being implemented..." At Hanford, DOE included current
and rigorous analyses of risks, cost, and benefits for the Waste
Treatment and Immobilization Plant (WTP) project. The DOE Acquisition
Executive approved the WTP baseline (Critical Decision 2) per the
requirements of DOE's directive on Project Management, DOE Order 413.3,
on April 28, 2003. This approval followed rigorous scope, schedule,
cost, and funding plans review by the DOE Project Office, an External
Independent Review (EIR) Team, and DOE Headquarters offices. Examples
of such activities include the following:
To prepare for the Critical Decision 2 (CD-2) approval for Final Design
request, the WTP contractor performed the following reviews: 1) a
project "due diligence" review, 2) a project "bottom-up" cost estimate
review, and 3) rigorous requirements reviews. The DOE project office
verified all proposals.
In their reviews over a six-month period, the EIR Team concluded the
proposed cost baseline is complete and reasonable, and that there is
high confidence the WTP contractor can complete the design/build/
construction effort within this cost baseline. The EIR also believed
the proposed schedule was achievable and appropriate for DOE approval.
The EIR Team found the cost baseline to be fully documented and
supported by a resource-loaded schedule; the schedule extension and
revised Engineering, Procurement, Construct (EPC) plan outlined a
strategy that decreased the schedule risk to an acceptable level; and
the revised commissioning schedule is more efficient and logical. This
baseline was based on a 40 percent design.
Incorporate New Technologies Consistent with Best Practices:
The GAO recommended DOE projects "... incorporate new technologies
consistent with best practices and DOE guidance so that risks and costs
are more effectively managed..." At Hanford, the DOE Project Office
did, and continues to, consider opportunities to improve the WTP
project. Per the intent of DOE Order 413.3, Project Management:
The WTP contractor conducted a Risk Program to address technical and
programmatic project risks. The Research and Technology (R&T) program
has been adjusted and alternate process technologies considered within
the WTP because of this analysis. A risk analysis is run quarterly. To
date, the effectiveness of this program has permitted the contingency
allocated for technical and programmatic risks to drop 25 percent. The
WTP contractor ran contingency analyses on cost and schedule, and DOE
included contingency at an 80 percent confidence level at this stage of
this project.
The DOE project office is considering alternate technologies to treat
the LAW to reduce the life-cycle cost and accelerate the remediation of
tank wastes. This strategy eliminated a second LAW vitrification
facility from the original plans. The WTP contractor is incentivized
for total project cost reduction, achieving or exceeding project
schedule milestones, and meeting or exceeding operational performance
requirements.
Fast Track Approach:
The GAO recommended DOE projects be "...carefully evaluated as to the
appropriateness of using a fast-track approach to designing and
constructing complex nuclear facilities, and that the potential risks
and costs associated with this approach are explicitly identified and
considered." At Hanford, the WTP project is a design/build/commission
contract. As previously noted the WTP contractor's risk program
considers program, technical, cost and schedule risks. Contingency is
identified
for this complex, very large, and close-coupled design/build/commission
project for both costs and schedule. The DOE Project Office identified
budget for an 80 percent probability the cost and schedule baseline
will be attained. The risk planning and mitigation actions already
reduced program and technical risks by 25 percent. The WTP contractor
did review their close-coupled approach and lengthened design/
engineering schedules to allow more review cycle time and to mitigate
the close coupling between design, procurement, and construction
schedules. The EIR Team determined that this schedule modification is
more typical of a conventional design-build approach, and the 6-month
schedule contingency is appropriate for the revised schedule.
DOE believes GAO's comments regarding a fast track approach and
increased waste treatment plant costs wrongly portray the progress that
DOE has made in developing the overall strategy for treating Hanford's
tank wastes. The waste treatment plant costs changed, in part, because
of DOE's initiative to accelerate risk reduction and mission completion
and reduce overall costs. Rather than initially build a low-capacity
plant followed by a second higher capacity plant a decade later, which
would not complete treatment until 2048, DOE has decided to build the
first plant to be more capable, to enable it, along with supplemental
LAW treatment, to complete treatment of the LAW by 2028.
Whereas the increased costs were characterized as the outcome of
parallel design and construction, the cost changes were largely
attributable to a change in DOE policy that will result in tens of
billions of dollars in savings and a much more rapid reduction in risks
to humans and the environment.
GAO Comments:
1. We agree and have modified the final report to clarify that the
low-activity portion of the separated tank waste would be immobilized
and disposed of permanently on-site, or at other designated locations.
2. We agree and have modified the final report to clarify that DOE's
approach generally involves separating the waste into two main streams.
3. We modified the final report to clarify that the intentional
discharges from the tanks were only at the Hanford Site. We do not
agree with DOE's statement that the tank wastes discharged into the
soil contained relatively low-levels of radioactivity. According to
DOE's records, the tank waste discharged into the soil at the Hanford
Site contained radioactive components with long half-lives, such as
technetium-99. The available records show that, as of December 1989,
decades after the waste was discharged into the soil, the 121 million
gallons still contained more than 65,000 curies of radioactivity.
4. We agree and have modified the final report accordingly.
5. We believe that using the term "contaminated water" when referring
to water from the tanks that may include radioactive and hazardous
components is more accurate. The use of the term "water" by itself
could be misleading for the general reader.
6. We agree and have modified the final report to clarify that the use
of process knowledge is a central part of the characterization step.
7. Although DOE may use constant dollars to report the department's
environmental liabilities under its Government Results and Reporting
Act requirements, it has not done so in its savings estimates or public
disclosures for its accelerated cleanup initiative. In addition, to
correctly compare costs of alternatives with different timing, DOE
should compare "present values" of costs and not merely the constant
dollars. Therefore, we made no change to the final report.
8. We agree and have modified the final report to include the cost
contingency as a factor in the cost growth for the Hanford high-level
waste treatment facility.
9. We believe that this comment reinforces the message in the
draft report that some of the proposed savings may be based on
incomplete estimates of the costs for the accelerated proposals. DOE
commented that the range of costs for the alternative technologies for
the sodium-bearing waste in the tanks--from $150-400 million--was less
than the $1 billion estimated cost of vitrifying the waste, and
therefore was not included in the savings estimate. We continue to
believe that the savings estimates in the accelerated plan should have
reflected all associated costs, including the difference between the
costs for the alternative technologies and the costs for vitrification.
We disagree that the $7 billion in estimated savings is solely
attributable to the differences in strategy for treating calcine waste.
The July 2002 accelerated plan for the Idaho National Laboratory
specifically states that the $7 billion will be saved by the new
cleanup approach for both calcine and sodium-bearing waste that
eliminates the need for a vitrification facility.
10. We believe that this comment reinforces the message in the report
that the use of a single point estimate does not reflect uncertainties.
We disagree that including a section in the accelerated plan that
catalogs the government furnished services and items is the same or
similar to accounting for uncertainties by providing a range of savings
estimates.
11. While the accelerated plan for the Idaho National Laboratory
briefly discusses reductions in risk to workers from less intrusive
characterization and sampling techniques and elimination of a
vitrification facility, it does not fully describe the advantages and
disadvantages to workers and the environment. Therefore, we continue to
believe that the savings estimates do not fully discuss the
nonbudgetary impacts such as environmental risks.
12. We believe this section of the report, including the summary
paragraph, adequately describes DOE's management of waste processing
activities.
13. Although section 114 of the Nuclear Waste Policy Act limits the
amount of nuclear waste that can be deposited in the repository, this
limitation is not relevant to the point in this paragraph. Therefore,
we made no change to the final report.
14. We believe the report adequately conveys this information.
15. We address these comments in the Agency Comments section of the
report.
16. We agree and have modified the final report to acknowledge that
DOE had implemented the GAO recommendation to validate cost comparisons
before constructing or expanding disposal facilities for low-level
waste.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
William R. Swick (206) 287-4800:
Acknowledgments:
In addition to the individual named above, Carole Blackwell, Robert
Crystal, Doreen Feldman, Chris Hatscher, George Hinman, Gary Jones,
Nancy Kintner-Meyer, Avani Locke, Mehrzad Nadji, Cynthia Norris,
Tom Perry, and Stan Stenersen made key contributions to this report.
Public Affairs:
Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800 U.S.
General Accounting Office, 441 G Street NW, Room 7149 Washington, D.C.
20548:
FOOTNOTES
[1] For this report, we use the term "high-level waste" to refer to the
waste that DOE is or was managing as high-level waste at its sites.
[2] DOE also agreed to clean up high-level waste at another site--the
West Valley Demonstration Project at West Valley, New York--where the
state sponsored reprocessing of both commercial and DOE spent nuclear
fuel. Treatment and preparation of this waste for disposal was
completed in September 2002.
[3] DOE has reported that more than one million gallons of waste have
been unintentionally released from the tanks into the soil through
leaks at the Hanford Site. In addition, DOE also intentionally
discharged about 121 million gallons of radioactive tank waste at the
Hanford Site directly into the ground from 1946 to 1966. At the
Savannah River Site, one of the 51 tanks is estimated to have leaked
tens of gallons into the soil.
[4] The AEA authorized the Atomic Energy Commission (AEC) to provide
for the safe storage of radioactive waste from defense-related
activities. 42 U.S.C. 2121(a)(3). Later, the Energy Reorganization Act
of 1974 abolished the AEC, transferring responsibilities to the Energy
Research and Development Administration (ERDA)--DOE's predecessor--and
the NRC. 42 U.S.C. 5814, 5841. In 1977, ERDA was abolished, and its
functions were transferred to the newly established DOE, explicitly
leaving the management of the government's radioactive waste in the
hands of DOE. 42 U.S.C. 7151(a), 7133(a)(8).
[5] 42 U.S.C. 5842.
[6] 42 U.S.C. 10101(12).
[7] 42 U.S.C. 10107(b)(2).
[8] 42 U.S.C. 6939c(b).
[9] From 1967 to 1985, DOE encapsulated cesium and strontium from the
tank waste at the Hanford Site to reduce the amount of heat generated
in the tanks and for lease to non-DOE organizations for beneficial use.
All of the leased capsules have been returned to Hanford.
[10] The "m" in barium-137m denotes barium-137 that has an excess of
energy and will undergo radioactive decay to barium-137, which is not
radioactive.
[11] The percentage of the waste volume that is contaminated water
varies among sites. Contaminated water is a significant constituent of
the waste by volume because water is used to cool the waste, dilute the
waste for treatment and transfer from one location to another, and
flush out waste from pipelines and facilities.
[12] At Savannah River, high-level sludge from the tanks has also been
stabilized in glass material and is currently stored on-site pending
completion of the geologic repository. As of August 30, 2002, Savannah
River had produced 1,331 canisters of this stabilized waste.
[13] Unless otherwise noted, all dollar estimates are as reported by
DOE and are in current dollars.
[14] Both of these lifecycle cost estimates reflect actual program
costs incurred from fiscal year 1982 to the year of the estimates, and
include estimated costs through completion of cleanup.
[15] U.S. Department of Energy, A Review of the Environmental
Management Program (Washington, D.C.: Feb. 4, 2002).
[16] Low-level radioactive waste is defined as radioactive material
that is not high-level radioactive waste, spent nuclear fuel,
transuranic waste, or certain by-product material (the tailings or
wastes produced by the extraction or concentration or uranium or
thorium from any ore processed primarily for its source material
content). 42 U.S.C. 10101(16). Transuranic wastes come primarily from
reprocessing of spent nuclear fuel and from fabrication of nuclear
weapons. Transuranic waste is defined as waste with radionuclides with
atomic numbers greater than 92 (that is, uranium) and having half-lives
greater than 20 years in concentrations greater than 100 nanocuries per
gram.
[17] U.S. General Accounting Office, Nuclear Waste: DOE's Accelerated
Cleanup Strategy Has Benefits but Faces Uncertainties, GAO/RCED-99-129
(Washington, D.C.: Apr. 30, 1999).
[18] U.S. Department of Energy, A Review of the Environmental
Management Program (Washington, D.C.: Feb. 4, 2002).
[19] National Research Council, Improving Project Management in the
Department of Energy (Washington, D.C.: June 1999).
[20] As required by NRC regulations (10 C.F.R. 61.55), Class C low-
level waste must not only meet the most rigorous requirements for low-
level waste form to ensure stability, but also must meet additional
requirements at the disposal site to protect against inadvertent
intrusion. The criteria also allow DOE to authorize and use alternative
requirements for radioactive concentration limits.
[21] Although DOE is not required to gain NRC's concurrence with its
incidental waste determinations, it does so to obtain an independent
assessment of its evaluation of waste as incidental to reprocessing.
[22] Because West Valley separated out and treated its waste before the
waste incidental to reprocessing criteria were formalized in Order
435.1 in 1999, DOE followed criteria established in the NRC
requirements for low-level waste (10 C.F.R. 61.55). We did not include
this action in table 5.
[23] Natural Resources Defense Council, Inc. v. Abraham, No. 01-CV-413
(D. Idaho, filed Mar. 5, 2002). The lawsuit was originally filed in
January 2000 in the 9th Circuit Court of Appeals and was subsequently
transferred to the federal district court in Idaho. The other parties
to the lawsuit are the Snake River Alliance, the Confederated Tribes
and Bands of the Yakama Nation, and the Shoshone Bannock Tribes. In
addition, the states of Washington, Idaho, Oregon, and South Carolina
are participating as amicus curiae.
[24] 58 Fed. Reg. 12,342 (1993).
[25] 65 Fed. Reg. 62,377 (2000).
[26] Tank closure at the Idaho National Laboratory is also pending
completion of its National Environmental Policy Act process.
[27] The Savannah River Site closed its first tanks--tanks 17 and 20--
in 1997.
[28] Progress in successfully separating the waste also varies at each
site. Waste separation operations at the West Valley site were
completed in 1995. As part of its accelerated cleanup plan, the Idaho
National Laboratory is evaluating its need for separation technologies
for its liquid tank wastes. The subsequent discussion focuses on
separation processes at the Hanford and Savannah River sites.
[29] U.S. General Accounting Office, Nuclear Waste: Process to Remove
Radioactive Waste From Savannah River Tanks Fails to Work, GAO/RCED-99-
69 (Washington, D.C.: Apr. 30, 1999).
[30] DOE's standard for leaching establishes a limitation on the rate
at which the glass containing the waste can leach material into the
environment. Radioactive Waste Management, the DOE office responsible
for managing the final disposal of the waste at the geologic
repository, requires that the "mean" or average of leaching rates
measured or predicted for the immobilizing glass must be less than the
average of leaching rates for standard glass. In contrast,
Environmental Management suggests (and the sites have adopted) that the
average of leaching rates measured or predicted for the glass must be
"at least two standard deviations below" the average leaching rates for
standard glass. Environmental Management's more stringent criteria to
limit leaching can, under some circumstances, restrict the amount of
waste that can be placed in the canisters to a greater extent than
Radioactive Waste Management's standard.
[31] In a November 2002 internal memo to Radioactive Waste Management,
the Assistant Secretary for Environmental Management stated the need to
revise its waste acceptance criteria to be consistent with NRC's
disposal requirements. DOE has recently begun to evaluate the steps
necessary to make this revision.
[32] Based on "engineering staff judgment," depending on the waste form
used, a reduction of as many as 500 canisters may be attributable to
changing Environmental Management's more stringent waste quality
criteria to conform to Radioactive Waste Management's standard.
[33] Under DOE's project management principles, for example, teams must
define project requirements, conduct preliminary risk assessments, and
prepare a risk mitigation plan prior to developing a baseline cost
estimate of proposed alternatives.
[34] U.S. General Accounting Office, Nuclear Cleanup: DOE Should
Reevaluate Waste Disposal Options Before Building New Facilities, GAO-
01-441 (Washington, D.C.: May 25, 2001).
[35] U.S. General Accounting Office, Best Practices: Better Management
of Technology Development Can Improve Weapon System Outcomes, GAO/
NSIAD-99-162 (Washington, D.C.: July 30, 1999).
[36] For a discussion of the problems associated with the fast track
design/build approach on these projects, see U.S. General Accounting
Office, Nuclear Waste: DOE's Hanford Spent Nuclear Fuel Storage
Project--Cost, Schedule, and Management Issues, GAO/RCED-99-267
(Washington, D.C.: Sept. 20, 1999) and Nuclear Waste: Process to Remove
Radioactive Waste From Savannah River Tanks Fails to Work, GAO-RCED-99-
69 (Washington, D.C.: Apr. 30, 1999).
[37] National Research Council, Progress in Improving Project
Management at the Department of Energy (Washington, D.C.: Nov. 2001).
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