Hanford Cleanup: DOE Should Take Actions to Improve Inspections and Oversight of Contaminated Excess Facilities

DOE's Hanford site in Washington State contains thousands of contaminated excess facilities and waste sites that remain to be cleaned up. In May 2017, a partial roof collapse at a waste storage tunnel facility for one of the former plutonium nuclear processing plants raised questions about the S&M of Hanford's excess facilities and how RL prioritizes cleanup of these facilities.

GAO was asked to review DOE's cleanup of Hanford's contaminated excess facilities, including how DOE ensures that the Hanford Site contractor inspects and maintains facilities. This report examines, among other things, (1) DOE's actions to evaluate the causes of the PUREX tunnel collapse, and (2) the extent to which DOE ensures that S&M of Hanford's contaminate excess facilities meet DOE requirements.

GAO reviewed DOE documents, administered a questionnaire to collect S&M information about 18 selected facilities representing the majority of the Hanford facilities cleanup effort, conducted in-depth reviews of selected Hanford facilities, and interviewed DOE and Hanford cleanup contractor officials.

The Department of Energy (DOE) has taken some actions to evaluate the physical causes that contributed to the May 2017 partial collapse of the Plutonium Uranium Extraction (PUREX) Tunnel 1, but has not determined the programmatic causes that led to the collapse, such as by completing an accident investigation or a root cause analysis, among other things. For example, although an engineering evaluation of the tunnels was completed at the request of the State of Washington, Richland Operations Office (RL) officials told GAO an accident investigation was not initiated because the event did not meet threshold requirements in a DOE order that includes, among other things, damages or costs exceeding $2.5 million. However, GAO's analysis shows that the costs of responding to the event and stabilizing the tunnel were about $10 million. At the contractor's request, RL also waived performance of a root cause analysis, which DOE guidance states is typically required for such a significant event, and agreed to a less rigorous analysis of the potential physical causes of the event. By conducting a root cause analysis to determine any programmatic weaknesses that contributed to the collapse of PUREX Tunnel 1, and taking action to address any identified weaknesses, DOE will have greater assurance that another, similar event will not take place. According to a DOE report and GAO's review, although the Hanford contractor is generally conducting routine surveillance inspections of contaminated excess facilities, these inspections have weaknesses and GAO found that DOE has not ensured requirements are fully met. Specifically, DOE orders require that processes be in place to ensure that inspections are conducted to detect deterioration and determine whether the structural integrity of facilities is threatened. A December 2017 DOE report and GAO's review found that the surveillance and maintenance (S&M) inspections at several facilities were not comprehensive and that there are areas of some facilities that personnel infrequently or never enter—physically or by remote means—to conduct inspections. For example, parts of the Reduction-Oxidation Facility have not been entered in more than 50 years and structural conditions are unknown. Without conducting comprehensive inspections, RL cannot ensure that it is meeting all of DOE's S&M requirements, such as addressing aging degradation and obsolescence of some facilities, and preventing other potential events similar to the PUREX tunnel collapse.

In addition, GAO's review of oversight reports since 2013 by DOE headquarters offices responsible for evaluating field office operations found that none of these assessments focused on RL's management and oversight of the contractor's S&M activities. DOE's Oversight Policy requires DOE to conduct independent oversight to the extent necessary to evaluate the effectiveness of DOE field office oversight of contractor activities. Without conducting periodic assessments or audits focused on RL's management and oversight of the contractor's S&M activities for contaminated excess facilities, DOE does not have assurance that RL is overseeing S&M activity in a way that ensures these facilities are inspected and maintained in a safe and compliant condition pending final cleanup.

GAO recommends that DOE (1) analyze the programmatic root causes of the tunnel collapse, (2) routinely conduct comprehensive inspections of contaminated excess facilities and take timely action as warranted, and (3) assess RL oversight of S&M of Hanford excess facilities. DOE agreed with GAO's recommendations and stated that it is taking steps to implement all of them by December 2020.

The legacy of more than 40 years of nuclear weapons production at the  Hanford Site in Washington State includes enormous quantities of spent  (used) nuclear fuel, leftover plutonium in various forms, buried waste,  contaminated soil and groundwater, and contaminated excess facilities  that must undergo cleanup. The federal government is responsible for  the cleanup of the Hanford Site, which is estimated to cost more than  $320 billion and take more than 50 years to complete. Of the laboratories  and sites that require cleanup in the Department of Energy’s (DOE)  portfolio, Hanford is the most complex and expensive, comprising nearly  half of DOE’s environmental liability. From 1944 through 1989, more  than 20 million uranium fuel elements were irradiated in nine nuclear  reactors along the Columbia River. Five massive plutonium plants  (referred to as “canyons”), including the Plutonium Uranium Extraction  (PUREX) Plant, operated in the center of the site and processed 110,000  tons of fuel from the reactors, discharging an estimated 450 billion gallons  of liquids in planned and uncontained releases to soil disposal sites and  53 million gallons of radioactive waste to 177 large underground tanks.  In addition to larger facilities, thousands of supporting excess facilities  and waste sites also require cleanup creating the need to identify the  greatest cleanup risks and prioritize work. Given the urgency to protect  the Columbia River, DOE has focused its cleanup effort on contaminated  excess facilities located closest to the river.

In May 2017, Hanford workers discovered a partial collapse of the timber  roof structure in one of the PUREX Plant’s two storage tunnels. While  the PUREX event did not result in any injuries to workers or measurable  release of radioactive or toxic materials into the surrounding environment,  it raised questions about the adequacy of surveillance and maintenance  (S&M) activities for contaminated excess facilities, such as PUREX, that  are not scheduled for final cleanup in the near future. In addition, this  event caused concerns about how DOE prioritizes and schedules cleanup  of contaminated excess facilities at Hanford.

Cleanup of the Hanford Site is governed primarily by the 1989 Hanford  Federal Facility Agreement and Consent Order, or Tri-Party Agreement  (TPA), an agreement among DOE, the Washington State Department of  Ecology, and the Environmental Protection Agency. The TPA  established hundreds of legally enforceable milestones and established a  procedural framework and schedule for developing, prioritizing, and  implementing various waste treatment and cleanup actions and  monitoring appropriate response actions at the Hanford Site. It also  provides the framework for ensuring that cleanup of the Hanford Site  complies with applicable federal and state environmental hazardous waste laws, primarily (1) the Comprehensive Environmental Response,  Compensation, and Liability Act of 1980, as amended; and (2) the  Resource Conservation and Recovery Act of 1976, as amended. DOE’s  Office of Environmental Management (EM) manages the Hanford cleanup  work through the Richland Operations Office (RL) and the Office of River  Protection, headquartered in Richland, Washington. RL is responsible for  managing and overseeing work performed by the Hanford Site cleanup  contractors. The Office of River Protection is responsible for the retrieval,  treatment, and disposal of Hanford tank waste. In addition, RL is  responsible for overseeing the cleanup contractor’s S&M activities, which  are intended to ensure that contaminated excess facilities are maintained  in a safe and environmentally sound manner until final cleanup is  completed. DOE policy requires that nuclear facilities be maintained to  prevent degradation and that the contractor’s S&M activities include  inspections to determine whether the structural integrity of contaminated  excess facilities is threatened.

Since signing the TPA, DOE has made progress at Hanford by starting  cleanup of contaminated excess facilities. However, much work remains,  and DOE faces the task of cleaning up large excess facilities and  hundreds of associated support facilities that are contaminated with  hazardous industrial, chemical, nuclear, or radiological materials. These  excess facilities include contaminated excess facilities identified in the  TPA as presenting sufficient potential environmental concerns that  coordination of DOE’s decommissioning process with regulatory cleanup  requirements is necessary. In addition, there are hundreds of  associated buildings and structures, which may be above or below  ground, that were used for material handling and processing, storage,  maintenance, administrative, or support activities that also need to be  cleaned up.

For years, we have reported on issues with DOE’s management of  nuclear waste cleanup, including cost increases and changes in scope for  major construction projects, technical and management challenges, and  delays in completing cleanup work at Hanford. In 2017, we added the  federal government’s environmental liability, of which DOE is responsible  for the majority, to our High-Risk List. In our 2019 update to the High-Risk  List, we reported that DOE’s environmental liability grew by $110 billion in  fiscal year 2018, primarily due to the estimated cost of cleanup at  Hanford. Most recently, we reported in February 2019 that DOE was not  accurately tracking or reporting whether milestones were met at cleanup  sites, including Hanford.

You asked us to review issues related to the cleanup of Hanford’s  contaminated excess facilities, including how DOE prioritizes and  schedules cleanup and ensures that the Hanford Site contractor inspects  and maintains facilities. This report (1) examines actions DOE has taken  to evaluate the causes of the PUREX tunnel collapse, 2) examines the  extent to which DOE ensures that the contractor’s surveillance and  maintenance of Hanford’s contaminated excess facilities meet DOE  requirements, and (3) describes how DOE determines the priority ranking  and schedule for cleanup of Hanford’s excess facilities.

To examine actions DOE has taken to address the PUREX tunnel  collapse and the extent to which DOE ensures that the contractor’s S&M  of Hanford’s contaminated excess facilities meets DOE requirements, we  reviewed DOE orders, policies, RL procedures, and documents that  describe DOE’s S&M requirements. We also obtained and reviewed DOE  evaluation reports and assessments of S&M activities and operations at  Hanford facilities; these include an EM 2017 Extent of Condition Review  for Excess Facilities report and historic S&M assessment reports on  PUREX tunnel structural stability. In addition, we examined DOE  headquarters oversight assessments conducted by EM’s Office of  Standards and Quality Assurance and DOE’s Office of Enterprise  Assessment, which reviewed RL oversight of the Hanford cleanup  contractor between June 2013 and June 2018. Due to the high number of  Hanford contaminated excess facilities requiring cleanup (approximately  800), we focused our review on 13 of the 15 key excess contaminated  facilities identified in the TPA, as well as five other contaminated excess  facilities. We identified and selected the five other facilities based on our  review of assessments by DOE regarding the risks posed by the facilities,  including questions about their structural integrity. We developed and  administered a questionnaire to RL to collect specific S&M information  about the 18 selected contaminated excess facilities. In addition, we  conducted in-depth reviews regarding S&M of selected Hanford facilities.  For these reviews, we selected four contaminated excess facilities for in- depth review; specifically, we selected two contaminated excess facilities  cited as key facilities in the TPA—the PUREX and the Reduction- Oxidation Facility (REDOX)—and two other contaminated excess  facilities—the 224B Concentration Facility and the 216–Z-9 Crib. For  these contaminated excess facilities, we reviewed DOE’s inspection  records from the start of fiscal year 2008 through the end of fiscal year  2018 to determine if inspections were occurring.

To describe how DOE determines the priority ranking and schedule for  cleanup at Hanford, we focused on contaminated excess facilities. We  reviewed federal environmental regulations, legal agreements, planning  documents from DOE and the Hanford cleanup contractor, DOE  directives and guidance, and reports by the Consortium for Risk  Evaluation with Stakeholder Participation on ways to consider risk in  making cleanup decisions. These documents include, but are not limited  to: the Tri-Party Agreement and associated Action Plan; EM’s Fiscal Year  2020 budget request; RL’s 2015 Vision and 2020 Vision (planning  documents), which include high-level cleanup priorities and goals; the  Hanford cleanup contractor’s Project Evaluation Matrix and its associated  guideline; and RL’s Integrated Priority List.

For all objectives, we also interviewed DOE officials with RL, the DOE  Office of Inspector General at Hanford, and DOE headquarters, including  Environmental Management’s Office of Standards and Quality Assurance  and the Office of Enterprise Assessments. In addition, we interviewed  Hanford cleanup contractors, officials from the Washington State  Department of Ecology, and officials from the Defense Nuclear Facilities  Safety Board. A more detailed discussion of our objectives, scope, and  methodology is presented in appendix I.

We conducted this performance audit from March 2018 to January 2020,  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

This section provides an overview of the Hanford Site, including DOE’s  progress cleaning up the site, and DOE’s requirements and  organizational structure for managing and overseeing cleanup and S&M  activities at the site.

Overview of Hanford Site and Cleanup Progress

Located in southeastern Washington State, the Hanford Site is one of the  most contaminated nuclear waste sites in North America. The site covers  586 square miles upriver from the cities of Richland, Pasco, and  Kennewick. The Columbia River flows through about 50 miles of the site.  The River Corridor and Central Plateau represent the two main  geographic areas for cleanup work. See Figure 1 for a map of the  Hanford Site.

DOE’s primary goal for cleaning up Hanford is to protect the Columbia  River from contamination now and in the future and to restore  groundwater. Since cleanup began in 1989, DOE has made progress  towards these goals, including remediating 1,342 of 2,032 waste sites,  demolishing 889 of 1,715 excess facilities, removing 18.5 million tons of  contaminated soil and debris from areas along the Columbia River, and  treating 20 billion gallons of contaminated groundwater. DOE’s most  recent schedule estimate for completing cleanup of the Hanford Site is  2078, although final decisions for many cleanup actions have not yet  been made. RL’s current overarching set of near-term cleanup goals and  priorities—outlined in its 2020 Vision—include initiating the transfer of  radioactive sludge from the K basin, cleaning up highly contaminated  soils underneath the 324 building, and completing demolition of the  Plutonium Finishing Plant, which is among Hanford’s most contaminated  nuclear facilities.

Hanford Contaminated Excess Facilities Selected for Our Review

Table 1 includes a list and summary descriptions for each of the  contaminated excess facilities we selected for our review. A more detailed  discussion of the scope for our review is presented in appendix I.

DOE Requirements for Surveillance and Maintenance of Hanford’s Contaminated Excess Facilities

The objectives for conducting S&M of contaminated excess facilities are  to ensure adequate containment of any contaminants left in place;  provide physical safety and access controls; and maintain the facility in a  manner that will minimize risk to human health and the environment.  S&M requirements are derived primarily from nuclear facility safety  regulations and DOE orders concerning occupational safety,  environmental protection, security, and emergency response planning.  DOE orders also require that nuclear facility maintenance plans address  aging degradation and obsolescence and that surveillance inspections be  conducted to detect malfunction and deterioration and determine whether  the structural integrity of contaminated excess facilities is threatened.  Under the TPA Action Plan, DOE has established an S&M plan for each  of the key excess facilities. The S&M plan identifies the facility and  associated structures covered by the plan and the specific inspection  activities and frequencies to be conducted. For the other excess facilities,  S&M requirements are established through provisions of the cleanup  contract which require that the contractor perform the S&M activities  necessary to maintain them in a safe and compliant condition.

Due to the wide variation in types of contaminated excess facilities and  associated hazards and risks, RL uses a graded approach that allows for  differences from facility to facility regarding the frequency and extent of  inspections and associated structural integrity engineering evaluations.  Structural integrity engineering evaluations are conducted to determine  the adequacy, structural integrity, and soundness of structures and their  components. Inspections are conducted using a procedural checklist  comprising a list of functional areas from the facility’s inspection plans or  procedures, which personnel performing inspections are to evaluate.  Inspection checklists can include, among other things, structural integrity  (an integral part of excess facility inspections), animal and water intrusion,  electrical hazards, and ground subsidence. The S&M plans for  contaminated excess facilities require interior walk-through inspections  generally on an annual basis but that can vary depending on the facility.  Typically, these inspections follow a designated path intended to  represent conditions that might be present in areas of the facility that are  not visually inspected. In addition, a qualified structural engineer conducts  an inspection of the roof integrity—recognized as the most likely risk of  failure for the contaminated excess facilities—and other associated  structures at those facilities. The frequency, extent of future inspections,  and recommendations resulting from these periodic inspections are to be  documented by the structural engineer.

DOE Framework for Oversight of Hanford Cleanup and S&M of Contaminated Excess Facilities

The program offices at DOE headquarters, RL, and Hanford contractors  have overlapping roles and responsibilities for managing and overseeing  the cleanup and S&M of Hanford excess facilities. These include:

Office of Environmental Management: DOE established EM in  1989 to address the environmental legacy of 50 years of nuclear  weapons production and government-sponsored nuclear energy  research across the country. EM is responsible for the cleanup of  large amounts of radioactive wastes, spent nuclear fuel and nuclear  material, contaminated soil and groundwater, and the  decommissioning and demolition of contaminated excess facilities at  various sites. EM offices involved with oversight of contaminated  excess facilities cleanup and S&M activities include:

Field Operations Oversight/Chief of Nuclear Safety Office.

This office has responsibility for strengthening federal oversight of  EM’s cleanup mission, including maintaining operational  awareness of field office sites’ operations oversight and  implementation of nuclear safety requirements, including  requirements for S&M.

The Standards and Quality Assurance Office. This office  assists with headquarters review of deactivation and  decommissioning project planning documents, configuration  management and controls, and S&M programs.

Office of Enterprise Assessments. This independent office, which  reports directly to the Office of the Secretary, is responsible for  implementing DOE’s Independent Oversight Program for safety and  security in accordance with various DOE policies and orders.  Through this program, the office conducts appraisals of the adequacy  of DOE policy and requirements and the effectiveness of DOE and  contractor line management performance in safety and security.

The Office of Environment, Safety, and Health Assessments.

This office is responsible for conducting assessments to provide  information on programs and performance in protecting DOE  workers, the public, and environment from hazards present at  DOE sites and operations. It also conducts special reviews and  studies of safety and emergency management topics and  activities where warranted based on circumstances or  performance or as directed by DOE management.

Hanford Site. RL is responsible for managing and overseeing non- tank waste cleanup activities at Hanford—including S&M of excess  facilities—in the Central Plateau area and for completion of some  remaining cleanup work in the River Corridor. RL management and  oversight includes verification that work is performed in a safe,  secure, and quality manner that protects the public, the worker, and  the environment and complies with contractual requirements.

Project and Facilities Division. This division is responsible for  managing and overseeing the cleanup and S&M of Hanford’s  excess facilities.

Operations Oversight Division. This division has primary  responsibility for day-to-day oversight to ensure cleanup work is  performed in compliance with requirements for safety, quality  assurance, and quality control. This includes ensuring that S&M  activities follow approved plans and procedures and that the  contractor corrects any deficiencies identified during facility  inspections.

Site Stewardship Division. This division manages the Long  Term Stewardship Program that includes overseeing S&M of the  six cocooned reactors.

Cleanup Contractor. Private firms under contract to DOE perform the  cleanup and S&M work at Hanford.

Central Plateau Cleanup. Since 2008, cleanup and S&M of most  of the contaminated excess facilities discussed in this report have  been performed under the Plateau Remediation Contract by  C2HM HILL Plateau Remediation Company. The S&M activities  for excess facilities, including how often and what parts of the  facility are inspected, are determined by the contractor as  necessary to meet contract requirements.

Mission Support. Mission Support Alliance is the contractor for  the Long Term Stewardship Program and is responsible for  ongoing S&M activities for the six cocooned reactors; these  activities are expected to last for at least 75 years.

DOE Did Not Assess the Programmatic Causes or Fully Implement Key Recommendations Following the PUREX Tunnel Collapse

DOE has taken some actions to evaluate the causes of the PUREX  tunnel 1 collapse, but has not determined the programmatic causes that  contributed to the tunnel collapse, such as by completing an accident  investigation or a root cause analysis. In addition, DOE headquarters’  recommendations to improve S&M of contaminated excess facilities and  the availability of information on the condition of at-risk areas within these  facilities have not been fully implemented.

DOE Did Not Conduct a Root Cause Analysis of the Tunnel Collapse

RL has taken some actions to evaluate the physical causes that  contributed to the PUREX Tunnel 1 collapse, but has not determined the  programmatic causes that led to the collapse, such as by completing an  accident investigation or a root cause analysis, among other things.

Specifically, after the collapse, RL took several actions to comply with a  2017 Washington State Department of Ecology Administrative Order. In  this order, the Washington State Department of Ecology determined that  RL and the Hanford cleanup contractor were not operating and  maintaining the PUREX Tunnel 1 to achieve compliance with the site’s  hazardous waste permit and failed, among other things, to keep the  operation of the tunnel undisturbed until closure of the facility. The  Administrative Order required RL to take several corrective actions to  address violations outlined in the Administrative Order, including  determining the cause of the PUREX Tunnel 1 collapse. To fulfill the 2017  Administrative Order corrective action, the cleanup contractor performed  an engineering evaluation to determine the structural conditions that led  to the collapse of PUREX Tunnel 1. However, the contractor noted in  the evaluation that due to the risks of exposure to high radiation levels  and urgency to seal the collapsed area, there was insufficient information  available to determine the causes of the collapse. Instead, the evaluation  identified three potential causes of the collapse, with the most likely cause  being deterioration and decay of the tunnel’s timber structure. The state  accepted these findings from the engineering evaluation as satisfying the  requirements in the Administrative Order corrective action that RL identify  the causes of the collapse.

Notably, the 2017 structural engineering evaluation of Tunnel 1  conducted after the tunnel collapse did not include a root cause analysis  to determine the underlying programmatic causes that contributed to DOE  not performing previously recommended structural assessments or  detecting through regular S&M activity the imminent collapse of PUREX  Tunnel 1 collapse. DOE had been aware of concerns with the structural  integrity of Tunnel 1 since the 1970s. These concerns lead to the  completion of structural assessments in the late 1970s, early 1980’s, and  in 1991, when it was recommended that the tunnel be reassessed again  in 10 years. Due to elevated risk of contamination and radiation exposure  to inspectors, subsequent structural integrity assessments were  completed using existing information from prior evaluations, including  testing of tunnel structural material, instead of collecting updated  information through physical inspections to determine if the PUREX  tunnels were structurally sound for continued use, according to RL  officials. Figure 2 illustrates the timeline of events related to the tunnels,  showing that while the structural integrity of Tunnel 1 was raised several  times over the last 40 years and it was recommended in 1991 to assess  the tunnel again by 2001, an assessment did not occur until after the May  2017 PUREX Tunnel 1 collapse as part of the corrective actions required  by the state.

DOE’s order on accident investigations contains requirements to initiate  an investigation into both the individual and organizational (programmatic)  root and contributing causes of events resulting in, but not limited to, a  fatality of an employee or member of the public or serious injury requiring  hospitalization; loss of control of radioactive material or environmental  release of hazardous material; or at least $2.5 million in damage to  property or in costs for cleaning, decontaminating, renovating, replacing  or rehabilitating. According to RL officials, RL did not initiate such an  investigation into programmatic causes because management concluded  that the PUREX Tunnel 1 collapse did not reach these threshold  requirements. However, according to RL officials’ written responses to our  questions about incident, the costs of responding to the PUREX Tunnel 1  collapse and stabilizing the tunnel exceeded $10 million.

DOE Order 232.2A, Occurrence Reporting and Processing of Operations  Information, also requires the investigation, categorization, and analysis  of reportable occurrences by facility representatives and contractors using  a graded approach in accordance with locally approved procedures for  implementing the requirements of this order. For an occurrence such as  the May 2017 PUREX tunnel collapse, which constituted noncompliance  with regulatory requirements that created the potential for actual harm,  DOE’s order and related guidance indicates that a causal analysis should  have been performed to identify the root causes, including the  programmatic causal factor or factors that, if corrected, would prevent  similar future occurrences.

According to the cleanup contractor’s condition report on the PUREX  tunnel collapse, the contractor initially classified the incident as a  significant event because it was categorized as an operational emergency  and significant by default. According to this report, under the  contractor’s reporting procedures, such a classification requires the  performance of a root cause analysis to determine the causes and  corrective actions with the intent of preventing recurrence. The  contractor’s condition report related to the incident notes that RL waived  the performance of a root cause analysis in favor of a less rigorous  apparent cause analysis to determine the structural factors that led to the  collapse of PUREX Tunnel 1. According to a written explanation  provided to us by RL management, while the tunnel collapse was due to  structural degradation, RL’s first priority was stabilizing the tunnel to  mitigate the potential for further collapse, and a programmatic root cause  analysis to determine the cause was not warranted. In this written  response, RL did not provide any explanation for why a programmatic  root cause analysis was not warranted. In an email, RL’s Operations and  Oversight Division facility representative granted the cleanup contractor’s  request for a waiver from conducting a root cause analysis and concurred  with their assertion that an apparent cause analysis was more  appropriate. Based on this direction, a root cause analysis was not  performed.

A root cause analysis, performed by either DOE headquarters or RL in  accordance with the requirements of DOE’s orders on accident  investigations and occurrence reporting, would have included an  assessment of the underlying programmatic factors that contributed to the  collapse of PUREX Tunnel 1. For example, a root cause analysis would  determine why PUREX facility inspections that only include visual  observations of the surface areas around the tunnels were insufficient in  identifying the likelihood of the imminent collapse of PUREX Tunnel 1;  why a recommendation made in 1991 for an engineering evaluation to be  completed by 2001 to determine if the tunnel was still structurally sound  for continued use was not completed; or why RL did not make  stabilization or cleanup of the tunnel a higher priority. By conducting a  root cause analysis to determine any programmatic weaknesses that  contributed to the collapse of PUREX Tunnel 1, and taking action to  address any identified weaknesses, DOE would have greater assurance  that another, similar event will not take place at Hanford.

DOE Has Not Fully Implemented 2017 Extent of Condition Review Recommendations

In June 2017, shortly after the PUREX Tunnel 1 collapse, EM initiated an  Extent of Condition Review to investigate program weaknesses and risks  in regard to contaminated excess facilities at three DOE sites, including  Hanford. Although EM’s 2017 Extent of Condition Review concluded  that, overall, the S&M processes for excess facilities were adequate in  mitigating risks, EM’s review identified some weaknesses and made four  recommendations to improve the S&M of contaminated excess facilities  and availability of information on these facilities’ condition. Specifically,  two of these four recommendations addressed weaknesses in inspections  of facilities and improving information about the condition of excess  facilities:

A comprehensive review should be conducted to identify high-risk  areas within excess facilities where inspections have not been  conducted for over 5 years. The results of the review should be used  to inform the risk management process used to prioritize actions and  projects.

For excess facilities for which limited areas may be used for ongoing  operations or storage of nuclear materials, the S&M of the unused  areas should be reviewed to assure long-term integrity and stability  that is comparable to facilities that are excess.

RL has not fully implemented these two recommendations. RL has taken  some actions, including commissioning an engineering team to evaluate  the structural integrity of some facilities similar to the PUREX tunnels that  may pose a future threat of collapse. However, this evaluation of the  structural integrity of Hanford’s contaminated excess facilities was not  comprehensive and did not include an evaluation of the structural integrity  of all excess facilities of concern that may be at risk of structural failure.

For instance, the scope of the evaluation was focused on 27 underground  waste storage structures in the Central Plateau, such as cribs, tanks and  trenches, which were constructed prior to PUREX Tunnel 1. In addition,  this evaluation was largely based on old data and did not include any  physical or non-physical inspection and testing to verify if a facility or part  of a facility needed to be stabilized or prioritized for cleanup, according to  RL officials. In addition, although recommended in EM’s 2017 Extent of  Condition Review, to date, RL has not taken action to direct the cleanup  contractor to carry out comprehensive inspections at all contaminated  excess facilities, and there are areas of some facilities that still have not  been entered, either physically or by remote means, to conduct internal  inspections. RL officials told us that they generally agree that inspections  of aging facilities should include evaluations of their structural integrity.  According to these officials, there have been ongoing discussions about  such inspections, including how often and in what areas to conduct them.  Officials said these decisions would need to be determined on a case-by- case basis depending on the safety consequences of potential incidents.  They also stated that RL has prioritized removing hazards to reduce  potential threats to human health and the environment to reduce future  surveillance and maintenance costs and preparing the canyon areas and  other facilities for final cleanup.

According to EM headquarters officials, the 2017 Extent of Condition  Review recommendations were intended to be considered as  opportunities for improvement which site management could incorporate  as deemed appropriate. EM officials explained that there is no  requirement for sites to take action to implement the review  recommendations or track their progress. However, by not taking actions  to implement the Extent of Condition Review recommendations, RL will  continue to lack information about the condition of high-risk areas within  contaminated excess facilities where inspections have not been  conducted for several years and will miss opportunities to identify and  address any deteriorating conditions that could lead to the collapse of  another contaminated excess facility.

Most Contaminated Excess Facilities Are Inspected as Required, but Some Inspections Are Not Comprehensive

The Hanford contractor is generally conducting surveillance inspections of  most contaminated excess facilities as required. However, EM’s 2017  Extent of Condition Review and our review found that the cleanup  contractor did not conduct comprehensive inspections at all contaminated  excess facilities and that there are areas of some facilities that personnel  infrequently or never enter, physically or by remote means, to conduct  interior inspections. In addition, although EM’s 2017 Extent of Condition  Review team noted that they observed examples where appropriate S&M  activities were taking place at contaminated excess facilities, the team  also acknowledged that such activities do not assure the EM sites’ S&M  programs are adequate to prevent mishaps, as evidenced by the collapse  of PUREX tunnel. Further, DOE headquarters offices responsible for the  evaluation of DOE site activities have not conducted any specific  assessments or audits focusing on management and oversight of Hanford  S&M activities since 2013.

DOE Conducts Inspections of Most Contaminated Excess Facilities, but Some Facilities Are Not Comprehensively or Regularly Inspected

According to EM’s 2017 Extent of Condition Review and our review of  inspection reports at selected facilities, routine surveillance inspections of  Hanford’s contaminated excess facilities are being conducted and the EM  review concluded that Hanford’s surveillance inspections were generally  adequate. However, this same EM review, as well as our review,  identified weaknesses in Hanford’s inspection program.

DOE orders require sites to clearly address aging degradation and  obsolescence and to conduct surveillance inspections at contaminated  excess facilities to detect malfunction and deterioration and determine  whether the structural integrity of contaminated excess facilities is  threatened. Once DOE determines that a facility is excess to mission  needs, the disposition phase of a contaminated excess facility’s life cycle  usually includes deactivation, decommissioning, and S&M activities,  followed by decontamination and demolition. According to RL officials, a graded approach—taking into account the risks posed at each  contaminated excess facility— can be used to tailor S&M activities,  including the frequency of facility inspections. In addition, S&M plans and  procedures are prepared by DOE and implemented by the contractor,  who determines the frequencies and areas of contaminated excess  facilities included in surveillance inspections.

EM’s 2017 Extent of Condition Review found that at three EM sites,  including Hanford, contaminated excess facilities surveillance inspections  were adequate and overall ensured that the S&M programs were  mitigating risks. Additionally, the review found that the sites were giving  appropriate attention to roof integrity through the S&M process. Roof  structural integrity is a key concern at contaminated excess facilities, as  the roof serves as protection against spread of contamination and  represents the most likely failure risk and safety risk for workers.  Further, in our review of selected contaminated excess facilities, we found  that the Hanford cleanup contractor has conducted annual surveillance  inspections of most of these facilities and has taken action to ensure the  structural integrity of some contaminated excess facilities. For example,  RL’s responses to our questionnaire indicated that for 16 of the 18  contaminated excess facilities we selected for our review, the contractor  conducts interior inspections of structural integrity on a periodic basis. In  addition, we found that between 2008 and 2018, the contractor annually  inspected three of the four contaminated excess facilities we selected for  our in-depth reviews.

However, RL responses to our questionnaire revealed concerns with  completeness of structural integrity evaluations and the structural integrity  of some facilities. For five of 18 facilities, RL officials identified structural  integrity or degradation which could lead to the potential release of  hazardous or nuclear materials, such as the May 2017 partial collapse of  PUREX Tunnel 1, as a concern. RL responses also indicated that  engineering analyses to evaluate structural integrity had been conducted  for 13 of the 18 facilities; however, at 10 of these facilities some areas  were not included in the evaluation due to concerns about worker safety  from radiological or other hazards. Further, EM’s 2017 Extent of Condition  Review, other recent DOE reports, and our review of inspection reports  for selected contaminated excess facilities found several instances in  which the cleanup contractor did not conduct comprehensive surveillance  inspections at all excess contaminated facilities, including infrequently or  never entering portions of some facilities, either physically or by remote  means, to conduct interior structural integrity evaluations.

REDOX. According to the 2015 Canyon Risk Mitigation Plan, the  REDOX canyon is not accessed during routine S&M activities. This  report also notes that the canyon deck area is expected to be highly  contaminated, is not inspected, has not been entered in more than 50  years, and structural conditions are unknown. The canyon deck is  located in the central portion of the canyon building and is isolated  from other areas of the facility by thick reinforced concrete walls and  floors. It is located above the facility process cells that were used to  extract plutonium. According to RL officials, these process cells and  other parts of the main canyon building are not accessed during  routine walkthrough inspections due to high levels of radioactive  contamination. Furthermore, in the contractor’s 2016 annual  inspection of the REDOX facility complex, the contractor did not  evaluate three annexes of the canyon facility for structural integrity,  according to RL’s response to our questionnaire. According to RL  officials, the contractor did not carry out these evaluations of the  annexes because RL plans to complete their final cleanup in the near  term. However, according to a 2016 DOE planning document, the  schedule for conducting the cleanup of the annexes is unknown, and  RL officials told us it may be several more years before cleanup  begins.

Because these annexes are not inspected for structural integrity, RL  and the cleanup contractor may not have sufficient information  regarding their condition for planning purposes, such as assessing if  immediate maintenance is required to stabilize a structure or  prioritizing an annex for immediate cleanup. In addition, according to a  2012 DOE report, because the canyon was not deactivated after  shutdown in the 1960s, information is very limited and there is a  significant level of uncertainty about the conditions inside the  building. According to the EM’s 2017 Extent of Condition Review,  despite ongoing S&M activities, if facility deterioration continues and is  left unaddressed, the condition of the facility could present a threat to  human health and the environment, as well as increase the costs of  S&M in the near term.

PUREX. According to EM’s 2017 Extent of Condition Review, parts of  the main PUREX facility are not physically inspected, including the  canyon deck. The canyon deck is in the central portion of the main  canyon building and is isolated from the surrounding areas of the  facility by thick, reinforced concrete walls and floors and has not been  entered in more than 10 years, according to the Hanford cleanup  contractor’s 2015 Canyon Risk Mitigation Plan report. According to  this report, conditions within this space are unknown, and high  contamination levels are expected. Due to lack of information and  concerns about this area, the 2015 Canyon Risk Mitigation Plan  recommended—for data-gathering and planning purposes— inspecting this area either physically or remotely, if physical entry is  not possible due to high levels of radiation. This report also stated that  future cleanup work could not be initiated in this area without sufficient  information related to the condition of the canyon deck. In addition, a  2019 engineering evaluation of the facility determined that  degradation may not be fully addressed by S&M activities and the risk  of release of hazardous substances will increase as degradation  continues or goes undetected. Figure 3 shows the main PUREX  plant and auxiliary facilities.

216-Z-9 Crib. According to the EM’s 2017 Extent of Condition  Review, due to the highly contaminated nature of 216-Z-9 Crib,  inspections of this facility are limited to external surveillance of the  roof and looking down the facility stairwell to the trench area of the  crib. However, a 2006 inspection of the interior of the crib utilized a  remote controlled device to inspect and determine that the structural  integrity of the facility’s roof was suspect. This inspection  recommended that the roof be inspected for structural integrity every  5 years; however RL did not direct the contractor to inspect the facility  until 2016. Furthermore, according to RL officials, when the facility  was inspected in 2016 and then again in 2018, the inspections did not  include an engineering evaluation or use of non-physical engineering  or robotic tools to inspect the structural integrity of the roof, as was  done in 2006, to determine if the facility was safe for continued use.  Despite the lack of an engineering evaluation or interior inspection of  the roof, the 2016 and 2018 inspection reports gave the facility a  passing grade for structural integrity—raising questions about both the  basis and reliability of this assessment. RL officials told us they did  not instruct the contractor to conduct such an evaluation because  recent visual surveillance inspections of the outside of the crib roof did  not indicate that structural failure was imminent. However, in its  January 2019 structural integrity assessment of contaminated excess  facilities at risk of collapse, the contractor reported that this facility  was among 11 facilities needing further evaluation.

Plutonium Finishing Plant 241-Z-361 Settling Tank. According to  RL’s response to our January 2019 questionnaire, the interior of the  Plutonium Finishing Plant 241-Z-361 Settling Tank is not inspected.  RL’s response noted that although there are concerns regarding the  structural integrity of the facility, the facility is safe for continued use.  However, RL’s response is not consistent with prior studies on the  condition of the tank. To support the questionnaire response, RL  referred to the 2018 Documented Safety Analysis and a 1997  Structural Integrity Assessment for Plutonium Finishing Plant 241-Z- 361 Settling Tank. The 2018 Documented Safety Analysis concludes  that the tank is in a structurally degraded condition but is not  considered at risk of imminent failure.

However, the 1997 Structural Integrity Assessment that DOE used to  support the conclusion in its Documented Safety Analysis determined  it was not possible to accurately assess the condition of concrete in  the facility and there were uncertainties associated with the strength  of its structural steel. The 1997 report also concluded that  deteriorating conditions of the facility could lead to the leakage of  radioactive waste material, further accelerating the degradation  through corrosion and conditions that could result in the collapse of  the tank. Notably, a subsequent 1999 video inspection revealed  cracking in the interior roof, dissolving of the interior steel liner, and  deterioration of the concrete sidewall of the tank.

Despite these documented concerns about the structural integrity of  the facility, RL officials that we spoke with could not provide a specific  reason for why the interior of this facility has not been inspected. Most  recently, a structural integrity initial assessment performed for the  contractor in January 2019 identified the Plutonium Finishing Plant  241-Z-361 Settling Tank as the top priority among 11 contaminated  excess facilities needing further evaluation to determine if the facility  is structurally sound for continued use. This report stated that the  facility is currently in a structurally degraded condition, with severe  deterioration of the construction materials supporting the structure.

224B Concentration Facility. This facility is contaminated from past  operations and parts of the facility are not physically inspected,  according to the 2015 Canyon Risk Mitigation report. In addition,  according to a 2015 RL briefing report, the facility’s roof is aging and  will likely require replacement within 5 years. According to RL officials,  the roof of this facility has not been replaced, and according to RL’s  response to our questionnaire, no significant maintenance or  structural work has been conducted since 2008 and none is needed  or planned based upon the current condition of the facility. However,  RL’s response to our questionnaire indicates that RL has not  conducted a structural integrity engineering evaluation of the facility to  support this conclusion. According to RL officials, they are currently in  the process of developing a plan to complete decommissioning and  decontamination of the facility. Under the TPA, the plan is to be  submitted by the end of September 2020. However, RL officials told  us that even with regulatory approval of the plan, DOE likely will use  additional funding to pursue other near-term cleanup priorities rather  than clean up the 224B Concentration Facility.

According to EM’s 2017 Extent of Condition Review, other recent DOE  reports, and our review of inspection reports for selected contaminated  excess facilities, gaps in S&M activities are, in some cases, due to access  challenges at the facilities. According to the EM 2017 Extent of Condition  Review, not all facility areas are inspected regularly due to difficulty of  access or elevated risk of contamination or exposure, or because those  areas are in such a degraded condition they are not safe to enter.  However, the contractor has demonstrated the capability to use  engineering or robotic evaluations to inspect or determine the structural  integrity of the facility, or parts of the facility, and verify whether it needs  to be stabilized or prioritized for cleanup. For example, such analyses  were done at the PUREX tunnels and at the 216-Z-9 Crib, as noted  above. Despite this capability, RL management has not directed the  cleanup contractor to perform such inspections for some of Hanford’s  contaminated excess facilities or parts of facilities. According to RL  officials, decisions on regularity and types of inspections and structural  evaluations will depend on the known risks associated with the facility.  Without directing the contractor to routinely conduct comprehensive  inspections to gather crucial information on the condition of contaminated  excess facilities, RL cannot ensure that it is meeting all of DOE’s S&M  requirements—such as addressing aging degradation and obsolescence  of facilities—and preventing other potential events similar to the PUREX  tunnel collapse.

DOE Headquarters Has Conducted Some Assessments of RL Cleanup Work but Has Not Conducted Oversight Reviews of S&M Activities at Hanford

DOE headquarters offices have conducted some assessments of RL  cleanup work but have not conducted any assessments or audits focused  on RL’s oversight of the cleanup contractor’s S&M activities since 2013.  EM’s Field Operations Oversight/Chief of Nuclear Safety Office and  DOE’s Office of Enterprise Assessments are required to conduct  independent oversight to the extent necessary to evaluate the  effectiveness of DOE field office oversight of contractor activities,  including activities needed to maintain contaminated excess facilities in a  safe and compliant condition pending their final cleanup. We reviewed  21 DOE HQ oversight reports on RL activity from the past 5 years and  determined that none of these assessments or audits focused on RL’s  management and oversight of the contractor’s S&M activities for  contaminated excess facilities.

We spoke with DOE officials from two headquarters offices responsible  for independent oversight of DOE field offices—the EM Field Operations  Oversight/Chief of Nuclear Safety Office and the Office of Enterprise  Assessments. Officials with both headquarters offices confirmed that  neither office has conducted a specific assessment or audit focusing on  RL’s management and oversight of S&M activities for contaminated  excess facilities in the last 5 years. Officials with the Office of Enterprise  Assessments told us that, given the limited resources available to conduct  oversight, they have to prioritize and be selective about the reviews they  plan to conduct in a given year, and conducting an in-depth assessment  of RL’s oversight of Hanford S&M activity has not been a priority with that  office. In December 2018, the office considered whether to conduct a  formal assessment of RL oversight of Hanford S&M activity, but decided  that such an assessment was not needed.

However, the projected overall time in S&M mode underscores the  importance that S&M be adequate to maintain facility safety during the  final stages of cleanup operations through a seamless transition to the  final disposition of the facility to protect human health and the  environment. We found that S&M requirements for selected contaminated  excess facilities will continue for decades. Specifically, our review of 18  contaminated facilities at Hanford found that many of these facilities were  determined to be excess between the 1960s and the late 1980s and  transitioned into S&M status at that time. Notably, our review of these  facilities shows that several of them do not have planned cleanup  completion dates and for those with cleanup completion dates, cleanup is  scheduled to be completed between 1 and 6 decades in the future. Table  2 shows the dates for when the 18 contaminated excess facilities  transitioned into S&M mode and how long RL will need to continue S&M  activities until cleanup is completed.

As S&M of Hanford’s contaminated excess facilities is expected to  continue for many decades, conducting an effective S&M program is  essential to minimize the risks of potential releases of contamination that  could harm the environment or human health before cleanup is  completed. Notably, RL has not established final cleanup dates for  several of the 18 contaminated excess facilities included in our review.  DOE, however, has not conducted independent reviews of S&M oversight  activity necessary to determine whether weaknesses exist in RL’s  management and oversight of the Hanford Site contractor’s S&M  activities for these facilities. Without prioritizing and conducting periodic  assessments or audits focused on RL’s management and oversight of the  Hanford Site contractor’s S&M activities for contaminated excess  facilities, DOE does not have assurance that RL is overseeing S&M  activity in a way that ensures contaminated excess facilities are being  inspected and maintained in a safe and compliant condition pending final  cleanup.

DOE Seeks to Balance Risks with Other Factors to Establish Hanford Site Cleanup Priorities

RL seeks to balance risks with other factors, such as legally enforceable  milestones, available budget, and stakeholder interests, to prioritize  cleanup activities that support achieving its overarching Hanford Site  cleanup goals, according to RL officials and planning documents. While  EM has overall responsibility for managing DOE’s cleanup program,  including deactivation and demolition of excess facilities, it has delegated  prioritization of cleanup activities to the sites through the annual budget  process. As part of the process, EM requests sites develop and submit a  site-specific Integrated Priority List to EM management. The Integrated  Priority List is based on a number of site-specific factors, including  regulatory commitments, agreements with EPA and states, and risks to  worker safety and the environment. According to RL officials, EM does  not provide specific written guidance for the sites to follow in developing  their priority lists, other than a list of seven general factors. RL officials  told us that more specific guidance is not necessary because site  management needs the flexibility in setting and adjusting cleanup  priorities to reflect changes in site conditions and other evolving  circumstances as they arise.

Since 2017, RL and the Hanford cleanup contractor have been using a  new site-wide risk-informed tool, known as the Project Evaluation Matrix,  to help inform decisions on which cleanup priorities to include in the  Integrated Priority List. The matrix is used to produce a prioritized listing  of the stabilization, waste removal, and other activities that need to be  completed as part of the deactivation and decommissioning of the  contaminated excess facilities and their associated buildings, structures,  and waste sites. RL and cleanup contractor officials described the matrix  as a broad, overarching tool to aid in establishing a qualitative basis by  which they can determine and agree on cleanup priorities that are  planned to be executed within the next 1 to 5 years. Neither the  Washington State Department of Ecology nor the Environmental  Protection Agency is directly involved in the development of the rankings  in the matrix.

The contractor’s guidance document explains that the risk evaluation  process used to develop the matrix rankings involves a number of steps.  It starts with the data collection phase, during which RL and the  contractor collect information on site conditions from a variety of sources,  such as historical records, safety assessments, subject matter experts,  and S&M activities. This information is then used to develop relative  ranking scores for the various cleanup and S&M activities using weighted  scores for three criteria: (1) risk reduction; (2) mortgage reduction/cost  avoidance; and (3) TPA milestones/regulatory drivers. The initial scores  also take into consideration other factors such as potential consequences  of failure and overall project lifecycle costs. After developing an initial risk  ranking of cleanup projects and activities, the contractor works with RL  management to evaluate the initial results and make adjustments as  necessary to reflect comments, changes in conditions, or new work  scope. The risk rankings are then updated and used by RL to inform  decisions on which projects to prioritize in its Integrated Priority List  budget submission to EM. As funding decisions are made and cleanup  work proceeds, risks are reassessed and the process starts again.

RL officials explained that planned cleanup priorities established in the  Integrated Priority List can be adjusted as necessary to reflect information  learned through S&M activities and changes in site conditions. For  example, routine annual S&M inspections at one facility identified  concerns with the integrity of the roof. Based on these concerns, a  structural analysis was performed by the cleanup contractor, and RL  adjusted its priorities for fiscal year 2016 to include replacing the facility’s  roof. Similarly, RL may also modify its planned cleanup priorities to reflect  changes in site conditions, such as completing cleanup of a facility or  taking actions to stabilize a facility pending its final disposition. For  example, based on structural evaluations completed after the partial  collapse of Tunnel 1 in May 2017, RL elevated interim stabilization of both  PUREX tunnels as among its top priorities in fiscal years 2018-2019.

The ability of RL management to establish and adjust cleanup priorities  depends on the availability of quality information on site conditions that is  reliable, complete, and current. One source of information for this process  is annual and routine S&M activities for Hanford’s contaminated excess  facilities. These activities, such as facility inspections, structural integrity  evaluations, and radiological monitoring, help provide management with  updated information on potential changes in site conditions that may lead  to an adjustment in previously planned priorities. As discussed above,  however, both EM’s 2017 Extent of Condition Review and our review  found that parts of certain contaminated excess facilities that may be at  risk for structural deterioration—such as the REDOX annexes—are not  included in the routine surveillance inspections and have not been  inspected within the past 5 years, or longer. We also identified instances  where structural integrity evaluations for some facilities, such as for the  216-Z-9 crib and the Plutonium Finishing Plant 241-Z-361 Settling Tank,  appear to have relied on outdated information and reached  determinations seemingly inconsistent with the contractor’s more recent  analyses and conclusions. By conducting comprehensive surveillance  inspections of Hanford’s contaminated excess facilities, DOE would have  greater assurance that RL and the contractor’s process for identifying  cleanup priorities reflects the current status of the potential human health  and environmental risks present at such facilities.

At Hanford, RL has made progress in cleaning up approximately 800  excess facilities, and six major plutonium production reactors are now  cocooned and waiting final dispositioning. Despite efforts to mitigate risks  and cleanup excess facilities, significant vulnerabilities remain at Hanford  due to, among other things, the degrading state of hundreds of  contaminated excess facilities still requiring cleanup. Given the pivotal  role of the S&M program in ensuring that aging and degrading  contaminated excess facilities do not collapse or fail to contain radioactive  or hazardous material, it is important that this program is functioning  effectively and that any weaknesses are addressed in a timely manner.

The partial collapse of PUREX Tunnel 1 was a clear signal that there are  flaws in the S&M program at Hanford. By conducting a root cause  analysis to determine any programmatic weaknesses that contributed to  the causes of the PUREX Tunnel 1 collapse, and taking action to address  any identified weaknesses, DOE will have greater assurance that  another, similar event will not occur at Hanford. Additionally, the PUREX  Tunnel 1 event demonstrates that RL and the cleanup contractor need  complete and updated information regarding the condition of aging  contaminated excess facilities to determine if facilities should be  stabilized to prevent structural failure or prioritized for cleanup. This  information can only be acquired by routinely completing comprehensive  surveillance inspections, to include, if necessary, engineering evaluations  including the use of remote controlled probes. Without directing the  contractor to conduct routine and comprehensive inspections to gather  crucial information on the condition of contaminated excess facilities, RL  cannot ensure that it is meeting all of DOE’s S&M requirements—such as  addressing aging degradation and obsolescence of facilities—and  preventing other potential events similar to the PUREX tunnel collapse.  Furthermore, because DOE headquarters offices have not prioritized and  conducted any assessments or audits focused on RL’s oversight of the  cleanup contractor’s S&M activities within the past 5 years or since the  PUREX Tunnel 1 collapse, they are missing an opportunity to identify and  address any Hanford S&M program weaknesses that may have led to the  collapse.

We are making the following three recommendations to DOE:  The Assistant Secretary of DOE’s Office of Environmental Management  should direct RL to conduct a root cause analysis to identify any  programmatic causes that may have led to the collapse of PUREX Tunnel  1. (Recommendation 1)

The Assistant Secretary of DOE’s Office of Environmental Management,  while ensuring the protection of DOE workers, the public, and the  environment, should ensure that RL directs the Hanford Site cleanup  contractor to explore using robotic or other means to routinely complete  comprehensive surveillance inspections of contaminated excess facilities  to identify aging degradation and obsolescence of facilities and take  timely action as warranted. (Recommendation 2)

The Secretary of Energy should ensure DOE headquarters offices  responsible for the oversight of EM sites’ field offices conduct an  assessment of RL’s management and oversight of the Hanford Site  contractor’s surveillance and maintenance activity for contaminated  excess facilities. Based on the results of this assessment, DOE  headquarters offices should consider whether such assessments should  be conducted on a periodic basis. (Recommendation 3)

We provided a draft of this report to the Secretary of the Department of  Energy.  In its written comments, reproduced in appendix III, DOE agreed  with the report’s findings and concurred with our recommendations. In  addition, DOE described ongoing and planned actions to address our  recommendations by December 31, 2020.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees; the Secretary of Energy; the Director, Office of  Management and Budget; and other interested parties. In addition, the  report will be available at no charge on the GAO website at www.gao.gov.

If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or trimbled@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made major contributions to  this report are listed in appendix IV.

Appendix I: Objectives, Scope, and Methodology

This report reviews issues related to the cleanup, inspection and  maintenance of Hanford’s contaminated excess facilities, such as the  Plutonium Uranium Extraction Plant (PUREX), and how the Department  of Energy (DOE) and the Richland Operations Office (RL) prioritizes and  schedules cleanup and ensures that the Hanford Site contractor inspects  and maintains these facilities. The objectives of our review were to (1)  examine actions DOE has taken to evaluate the causes of the PUREX  Tunnel Collapse, 2) examine the extent to which DOE ensures that the  contractor’s surveillance and maintenance of Hanford’s contaminated  excess facilities meet DOE requirements, and (3) describe how DOE  determines the priority ranking and schedule for cleanup of Hanford’s  excess facilities.

To examine actions DOE has taken to address the PUREX Tunnel  Collapse and the extent to which DOE ensures that the contractor’s  surveillance and maintenance (S&M) of Hanford’s contaminated excess  facilities meets DOE requirements, we reviewed DOE orders, policies, RL  procedures, and documents that describe DOE’s S&M requirements. We  also obtained and reviewed DOE evaluation reports and assessments of  S&M activities and operations at Hanford facilities; these include the  Office of Environmental Management’s (EM) 2017 Extent of Condition  Review for Excess Facilities and historic S&M assessment reports on  PUREX tunnel structural stability.

To describe how DOE determines the priority ranking and schedule for  Hanford cleanup work of Hanford’s contaminated excess facilities, we  reviewed federal environmental regulations, legal agreements, planning  documents from DOE and the Hanford cleanup contractor, DOE  directives and guidance, and reports by the Consortium for Risk  Evaluation with Stakeholder Participation and others on ways to consider  risk in making cleanup decisions. These include, but are not limited to,  the Tri-Party Agreement (TPA) and associated Action Plan; EM’s Fiscal  Year 2020 budget request; RL’s 2015 Vision and 2020Vision, which  include high-level cleanup priorities and goals; the Hanford cleanup  contractor’s Project Evaluation Matrix and its associated guideline; and  RL’s Integrated Priority List.

For all objectives, we also interviewed DOE officials with RL, the DOE  Office of Inspector General at Hanford, and DOE headquarters offices,  including the Office of Enterprise Assessments and EM’s Office of Safety,  Security, and Quality Assurance. In addition, we interviewed Hanford  cleanup contractors, officials from the Washington State Department of  Ecology, and officials from the Defense Nuclear Facilities Safety Board.

Due to the large number of Hanford contaminated excess facilities  requiring cleanup (approximately 800), we focused our review on 18  contaminated excess facilities. These contaminated excess facilities  represent the majority of the excess facilities cleanup effort and include  some of the most challenging of the non-tank waste cleanup efforts  remaining at Hanford, according to DOE officials. We chose key excess  contaminated facilities as identified in the TPA because, among other  things, DOE and its regulators identify these facilities in Section 8 of the  agreement as presenting sufficient potential environmental concern that  coordination of the decommissioning process with cleanup activities  under the agreement was deemed necessary. We also selected the five  other contaminated excess facilities because DOE identified them as  having 1) high risks to the environment, workers, and public safety, 2)  high annual S&M costs, and 3) high disposition costs. See Table 1 in the  report for summary descriptions of each facility we selected.

To gather information about RL’s planning on S&M activities at Hanford  and estimated costs for fiscal year 2019, we administered a  questionnaire to RL facility representatives responsible for overseeing the  cleanup contractor’s implementation of S&M for contaminated excess  facilities. For each facility, the representatives were asked whether there  was an S&M plan for the facility, when it was developed, and when it was  most recently updated. We also asked about the type and frequencies of  facility inspections, whether the facility included areas where structural  integrity was a concern, if any structural integrity evaluations had been  conducted, and whether any significance corrective or preventative  maintenance had been performed. We also asked them to explain the  facility representative’s role in overseeing that the contractor was  conducting S&M activities in accordance with the applicable plan and  DOE requirements. A copy of the complete questionnaire is included in  appendix II.

We conducted two pretests of the questionnaire with RL officials in  November and December 2018, and we revised it in response to their  comments. During this process, we sought to ensure that (1) the  questionnaire questions were clear and unambiguous, (2) terminology  was used correctly, (3) the questionnaire did not place an undue burden  on respondents, and (4) respondents had sufficient information to answer  the questions.

For the questionnaire we identified an initial set of 21 contaminated  excess facilities based on the following criteria: (1) whether they were a  key facility identified by DOE and its regulators in Section 8 of the Tri- Party Agreement Action Plan and (2) whether we considered them to be a  contaminated excess facility that poses high risks to the environment,  workers, and public safety; (3) whether it has potentially high annual  surveillance and maintenance costs; and (4) whether it has high final  disposition costs based on information we gathered from DOE. After  further correspondence with RL officials, we agreed that three of the  contaminated excess facilities on our list could be deleted because they  were not in S&M mode, as cleanup was completed for one facility, one  was undergoing active cleanup, and the other was in operational status.  We sent the questionnaire by email in a password-protected Word  document to which respondents could return electronically after marking  checkboxes or entering responses into open-answer boxes. We sent the  questionnaire with a cover letter to DOE officials on January 10, 2019,  with a request to complete and return it by January 31, 2019. By February  25, 2019, we received completed questionnaires for each of the 18  selected contaminated excess facilities.

In addition, to provide further context for all objectives, we conducted in- depth reviews regarding S&M of selected Hanford facilities. For these  reviews, we selected four high-risk facilities: PUREX, REDOX, the 224B  Concentration Facility, and the 216–Z-9 Crib. We used a judgmental  (non-probability) sample to select four contaminated excess facilities for  in-depth review. These facilities have been identified by DOE, the DOE  Office of Inspector General, or the Consortium for Risk Evaluation with  Stakeholder Participation as contaminated excess facilities with concerns  regarding high risks to the environment, workers, and public safety and  risk of potential release of radioactive material and other hazardous  materials due to aging degradation and weakening structural integrity. In  addition, these contaminated excess facilities are moderate- to high-risk  priority facilities for cleanup, according to the contractor’s June 2018  Project Evaluation Matrix, but not scheduled to start cleanup for at least 5  years. For these reviews, we examined DOE documents, including  inspection records dating back to the start of fiscal year 2008 through the  end of fiscal year 2018 to determine if inspections were occurring, and  interviewed RL officials.

We conducted this performance audit from March 2018 to January 2020  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Appendix III: Comments from the Department of Energy

Appendix IV: GAO Contact and Staff Acknowledgments

In addition to the individual named above, Ned Woodward, Assistant  Director; Tara Congdon; Justin Fisher; Richard Johnson; Michael  Meleady; Peter Ruedel; Sara Sullivan; and Roxanne Sun made key  contributions to this report.

Nuclear facilities that are no longer used await cleanup at the Department of Energy’s site in Hanford, WA. Contractors inspect and maintain these facilities, but DOE hasn’t ensured that these activities fully meet requirements. For example, structural conditions are unknown in parts of a facility that inspectors haven’t entered in 50 years.

In 2017, workers found a partial roof collapse in a storage tunnel. DOE evaluated physical causes, but did not examine all inspection and maintenance practices that may have contributed to the accident. We recommended doing so and taking steps to improve inspections and maintenance.