Nuclear Waste: DOE Should Reassess Whether the Bulk Vitrification
Demonstration Project at Its Hanford Site Is Still Needed to
Treat Radioactive Waste (12-JUN-07, GAO-07-762).
The Department of Energy (DOE) is demonstrating a technology
called bulk vitrification, in parallel with the Hanford waste
treatment plant, to treat a portion of the radioactive waste
stored in 177 tanks at its Hanford site in southeastern
Washington state. DOE faces technical and management problems
that have affected the original objectives to justify
demonstrating the bulk vitrification technology. This report
discusses the extent to which DOE (1) has managed the bulk
vitrification demonstration project consistent with DOE
management guidance and (2) continues to need a supplemental
technology, such as bulk vitrification, to treat a portion of the
low-activity tank waste. To assess DOE's management of the
project, GAO reviewed reports by DOE and others and discussed the
project with DOE and contractor officials.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-762
ACCNO: A70592
TITLE: Nuclear Waste: DOE Should Reassess Whether the Bulk
Vitrification Demonstration Project at Its Hanford Site Is Still
Needed to Treat Radioactive Waste
DATE: 06/12/2007
SUBJECT: Needs assessment
Nuclear facility safety
Nuclear waste disposal
Program evaluation
Program management
Radioactive waste disposal
Requirements definition
Schedule slippages
Technology
Waste management
Waste treatment
Cost growth
DOE Hanford Waste Vitrification Plant
Project
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GAO-07-762
* [1]Results in Brief
* [2]Background
* [3]Management Weaknesses during the Bulk Vitrification Demonstr
* [4]DOE Did Not Follow Project Management Requirements during th
* [5]The Demonstration Project Faced a Number of Technical and Sa
* [6]DOE Began Following Management Requirements in the Third Yea
* [7]The Extent to Which the Bulk Vitrification Demonstration Is
* [8]The Original Objectives That Justified Developing the Bulk V
* [9]DOE Does Not Plan to Reassess the Need for Continuing the De
* [10]Conclusions
* [11]Recommendations for Executive Action
* [12]Matter for Congressional Consideration
* [13]Agency Comments and Our Evaluation
* [14]Appendix I: Scope and Methodology
* [15]Appendix II: Comments from the Department of Energy
* [16]Appendix III: GAO Contact and Staff Acknowledgments
* [17]GAO Contact
* [18]Staff Acknowledgments
* [19]Order by Mail or Phone
Report to Congressional Committees
United States Government Accountability Office
GAO
June 2007
NUCLEAR WASTE
DOE Should Reassess Whether the Bulk Vitrification Demonstration Project
at Its Hanford Site Is Still Needed to Treat Radioactive Waste
GAO-07-762
Contents
Letter 1
Results in Brief 5
Background 7
Management Weaknesses during the Bulk Vitrification Demonstration Project
Contributed to Technical Problems, Cost Increases, and Schedule Delays 8
The Extent to Which the Bulk Vitrification Demonstration Is Still Needed
Is Unclear; However, DOE Does Not Plan to Reassess Its Need Before
Continuing with the Demonstration 13
Conclusions 17
Recommendations for Executive Action 17
Matter for Congressional Consideration 18
Agency Comments and Our Evaluation 18
Appendix I Scope and Methodology 21
Appendix II Comments from the Department of Energy 23
Appendix III GAO Contact and Staff Acknowledgments 25
Table
Table 1: Original Objectives for Demonstrating and Deploying Bulk
Vitrification Technology Compared with Current Conditions 13
Abbreviations
AMEC AMEC Earth and Environmental, Inc.
DOE Department of Energy
EPA Environmental Protection Agency
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separately.
United States Government Accountability Office
Washington, DC 20548
June 12, 2007
The Honorable Byron L. Dorgan
Chairman
The Honorable Pete V. Domenici
Ranking Minority Member
Subcommittee on Energy and Water Development
Committee on Appropriations
United States Senate
The Honorable Peter J. Visclosky
Chairman
The Honorable David L. Hobson
Ranking Minority Member
Subcommittee on Energy and Water Development
Committee on Appropriations
House of Representatives
The Department of Energy (DOE) is responsible for one of the world's
largest environmental cleanup programs--the treatment and disposal of
nuclear waste created as a by-product of producing nuclear weapons.
Decades of nuclear weapons production have left a legacy of chemical,
hazardous, and radioactive wastes to be cleaned up at DOE sites across the
country. One of the most contaminated nuclear waste sites in North America
is DOE's Hanford site located along the Columbia River in southeastern
Washington state. This site occupies 586 square miles upriver from the
cities of Richland, Pasco, and Kennewick, with a combined regional
population of over 200,000. Since 1989, DOE has spent more than $10
billion to manage about 56 million gallons of high-level radioactive and
hazardous waste at the site and explore ways to treat and dispose of it.
However, to date, none of the tank waste at Hanford has been treated for
final disposal. Over the years, including testimony before this
subcommittee in April 2006, we have criticized DOE's management of
Hanford's tank waste and its efforts to design and build facilities that
are capable of treating the waste.^11The Department of Energy (DOE) is
responsible for one of the world's largest environmental cleanup
programs--the treatment and disposal of nuclear waste created as a
by-product of producing nuclear weapons. Decades of nuclear weapons
production have left a legacy of chemical, hazardous, and radioactive
wastes to be cleaned up at DOE sites across the country. One of the most
contaminated nuclear waste sites in North America is DOE's Hanford site
located along the Columbia River in southeastern Washington state. This
site occupies 586 square miles upriver from the cities of Richland, Pasco,
and Kennewick, with a combined regional population of over 200,000. Since
1989, DOE has spent more than $10 billion to manage about 56 million
gallons of high-level radioactive and hazardous waste at the site and
explore ways to treat and dispose of it. However, to date, none of the
tank waste at Hanford has been treated for final disposal. Over the years,
including testimony before this subcommittee in April 2006, we have
criticized DOE's management of Hanford's tank waste and its efforts to
design and build facilities that are capable of treating the waste.
^1GAO, Hanford Waste Treatment Plant: Contractor and DOE Management
Problems Have Led to Higher Costs, Construction Delays, and Safety
Concerns, [20]GAO-06-602T (Washington, D.C.: Apr. 6, 2006).
DOE currently manages this waste in 177 large, aging, underground storage
tanks. The waste contains high-level radioactive constituents (less than
10 percent by volume) to be stabilized on the Hanford site and then sent
to a geologic repository for permanent disposal. DOE plans to stabilize
the low-activity radioactive constituents (more than 90 percent by volume)
and dispose of it on-site in near-surface burial facilities. DOE is
required to complete treatment of all of the Hanford tank waste by 2028,
as part of the Tri-Party Agreement between DOE, the Environmental
Protection Agency (EPA), and the Washington State Department of Ecology.^2
DOE manages its projects under a project management order and implementing
guidance^3 that require a formal set of internal and external reviews and
approvals during the planning and execution of a project to help ensure
work is completed on schedule, within budget, and according to mission
needs.
To address the tank waste, DOE is constructing the Hanford Waste Treatment
and Immobilization Plant (waste treatment plant), a large complex of
treatment and support facilities.^4 DOE's initial plan for the waste
treatment plant was a phased approach to first demonstrate treatment
technologies and then add capacity by constructing additional treatment
facilities within the plant. DOE initially expected that treating all of
the tank waste would take until about 2046, but during the design and
early construction years of the plant the department began to explore ways
to accelerate the cleanup and treat all of the waste by 2028, as required
by the Tri-Party Agreement. DOE's contractor subsequently modified the
plant design to expand the capacity or "throughput" of the facilities
under construction by, for example, requiring larger waste treatment
equipment. Based on those changes, DOE expected that the waste treatment
plant would be able to treat all of the high-level waste and about half of
the low-activity waste by 2028.
^2The Tri-Party Agreement is a legally binding agreement that incorporates
the requirements of federal environmental laws and guides the process
under which DOE will address the wastes and environmental contamination at
the Hanford site.
^3DOE Order 413.3, Program and Project Management for the Acquisition of
Capital Assets, issued Oct. 13, 2000. DOE issued a revised order as DOE
Order 413.3A on July 28, 2006.
^4The waste treatment plant includes three primary waste processing
facilities--the pretreatment facility, which will receive waste from
Hanford's underground tanks and separate it into its high-level and
low-activity waste components; the high-level waste facility that will
immobilize high-level waste for off-site disposal through a process known
as vitrification, which mixes nuclear waste with molten glass; and the
low-activity waste facility that will immobilize the low-activity waste
for on-site disposal. In addition, a large analytical laboratory and more
than 20 other buildings will support waste treatment activities.
To treat the other half of the low-activity waste without adding to the
cost of the waste treatment plant that was already under construction, DOE
began exploring options to develop a supplemental technology that would be
low cost, capable of being rapidly developed, and could help complete all
waste treatment by 2028. In 2003, after examining a variety of
alternatives, DOE decided to develop a separate supplemental technology
called bulk vitrification to see if it had the potential to treat the
remaining low-activity tank waste.^5 Bulk vitrification involves drying
and placing low-activity waste in large steel containers, mixing the waste
with other feed material--such as soil and other glass-forming
materials--heating it with electrical currents inside the containers until
the mixed materials melt, and then letting them cool into a solid, glass
material. The waste is then permanently stored on-site in those
containers.^6 DOE selected the bulk vitrification technology because the
department believed it would add flexibility to DOE's tank waste treatment
effort and be less costly, relatively rapid and straightforward to
develop, and likely to meet a more aggressive schedule compared with other
options. In addition, the bulk vitrification technology was acceptable to
federal and state environmental agencies because it would stabilize the
waste in glass that would meet or exceed the disposal standards agreed to
in the Tri-Party Agreement. A contract was awarded in June 2004 to design
and build a pilot plant that would both test and demonstrate the viability
of the technology and treat about 200,000 gallons of tank waste within 2
years.
By 2006, DOE planned to compare bulk vitrification with other viable
alternatives, and, if selected, design, build, and then beginning in 2011,
operate a full-scale bulk vitrification facility in parallel with the
waste treatment plant. DOE initially estimated the Demonstration Bulk
Vitrification System (demonstration project) would cost $62 million.
However, since awarding the contract in 2004, the project's estimated cost
has increased from $62 million to $230 million, and its scheduled
completion date has been extended from 2006 to 2012.^7 In mid-2005, DOE
suspended construction activities and decided not to request continued
project funding from Congress in fiscal years 2007 and 2008 until it had a
better understanding of the project's scope and technical uncertainties.
To date, DOE has spent about $93 million on the demonstration project. If
bulk vitrification is selected as the supplemental technology for treating
a portion of Hanford's tank waste, DOE's plans include eventually building
and operating two full-scale bulk vitrification facilities located near
the underground storage tanks in the east and west areas of the Hanford
site.
^5To examine the alternatives, DOE conducted a review that included an
assessment of studies and a series of workshops with experts from national
laboratories, industry, and academia. The experts grouped the technologies
into potential treatment approaches involving various methods of
preparing, treating, and solidifying the waste for permanent on-site
storage. In all, DOE compared about 10 available technical approaches for
treating Hanford's low-activity waste.
^6In contrast to a bulk vitrification facility, the low-activity waste
vitrification facility for the waste treatment plant would consist of a
vitrification technology that involves feeding the waste and other feed
material into a device, called a melter, where the waste is heated to a
molten state, then poured into stainless steel canisters, where it is
allowed to cool into a solid form and permanently stored on-site.
Because of the significant technical and management problems DOE is facing
on the waste treatment plant project and the important role DOE assigned
to the bulk vitrification demonstration in achieving the overall
objectives for stabilizing the tank waste at Hanford, you asked us to
review the status of the demonstration project. On October 12, 2006, we
briefed your staff on the preliminary results of our review. To respond to
your remaining concerns, this report addresses the extent to which DOE (1)
has managed the bulk vitrification demonstration project consistent with
departmental management guidance and (2) continues to need a supplemental
technology, such as bulk vitrification, to treat a portion of the
low-activity tank waste.
To determine how the bulk vitrification demonstration has been managed, we
compared project management practices with project management guidance and
documented any differences. We also documented the steps the department
has taken to improve management of the demonstration. To determine the
extent to which DOE continues to need a supplemental technology, we
reviewed external technical studies and cost reviews on the project and
discussed with DOE and contractor officials the steps they have taken to
resolve problems experienced to date. In addition, since the purpose of
the bulk vitrification technology is to supplement the capacity of the
Hanford waste treatment plant, we spoke with DOE's Office of River
Protection and contractor officials to determine the extent to which the
waste treatment plant's cost, schedule, and technical changes may affect
the bulk vitrification demonstration project. A more detailed description
of our scope and methodology is provided in appendix I. We performed our
work between June 2006 and May 2007 in accordance with generally accepted
government auditing standards.
^7The initial contract price of $62 million included a smaller work scope
involving a modular, mobile waste treatment facility, while the $230
million contract price involves a larger, stationary treatment facility
that includes the capacity to accept waste retrieved from an underground
storage tank.
Results in Brief
DOE did not follow departmental project management requirements during the
first 2 years of the demonstration in an effort to accelerate the tank
waste cleanup, which contributed to a nearly fourfold increase in
estimated project costs from $62 million to $230 million, and a 6-year
delay on the project. Specifically, early in the demonstration, DOE did
not conduct key internal and external reviews that would have evaluated
the project's design, procurement, and construction management approach
and that were designed to identify potential problems and address them
before starting construction. In addition, DOE did not fully develop or
update key project planning documents, such as a project execution plan,
an acquisition plan, and a validated project cost baseline. Without these
management tools, DOE initially overlooked a number of technical and
safety problems facing the demonstration project, such as uncertainties
about the quality of the glass formed using the bulk vitrification
technology and inadequate systems to shield and confine radioactive
material from workers and the environment. These problems contributed to
an increase in the project's estimated cost and a delay in the estimated
completion date. In late 2005, largely because of these problems, DOE
determined that the project should be managed in accordance with
departmental guidance, including focusing on completing the facility
design before continuing construction activities, updating project
execution and acquisition plans, and commissioning two independent reviews
to assess the viability of the project's approach, as well as its cost and
schedule estimates.
DOE's need for a supplemental technology to treat a portion of the
low-activity tank waste at Hanford is no longer clear, but DOE does not
plan to reassess the need for the bulk vitrification project before
continuing with the demonstration. In the 4 years since DOE selected the
bulk vitrification technology for further development, conditions have
changed. Originally, DOE justified bulk vitrification as a relatively
low-cost, supplemental technology that could be rapidly deployed to
complement the waste treatment plant and treat all of the remaining tank
waste at Hanford by 2028. However, none of the key components to this
justification remains today. First, technical and safety problems during
the project have not only led to higher project costs, but have also led
DOE to make changes to the facility design. These problems have also
resulted in increases to the estimated life-cycle cost of future
full-scale bulk vitrification facilities from about $1.3 billion to $3
billion. This is about the same cost as another alternative DOE previously
considered--adding a second low-activity waste treatment facility to the
waste treatment plant. Second, the technology is no longer rapidly
deployable because, as discussed above, the project faces at least a
6-year delay. DOE now estimates that the bulk vitrification demonstration
project would not be completed until 2012 and that the full-scale bulk
vitrification facilities would not be fully available until late 2019.
Finally, it is now apparent that completing waste treatment at Hanford by
2028 is not possible under any reasonable scenario and that the waste
treatment plant must operate for longer than DOE previously planned. This
is significant since longer operating periods may reduce the need for a
supplemental technology. Given the plant's estimated treatment capacity,
more of the low-activity waste could be treated in the waste treatment
plant facilities.
DOE's project management guidance specifies that when conditions have
significantly changed, the department should reassess the mission need, as
well as the benefits and appropriateness of continuing with a project.
Despite this fact, DOE plans to renew requests for project funding in
fiscal year 2009 but does not intend to reassess the overall need for the
project until much later. DOE project officials acknowledged that the need
for bulk vitrification may be less compelling than when initially
selected, but they said that developing more information about bulk
vitrification would provide additional treatment flexibility that may have
value in the future. As part of the effort to develop more information,
DOE is in the process of comparing various combinations of treatment
options for completing tank waste treatment at Hanford. The purpose of
this comparison is to support near-term tank waste funding decisions
rather than assess bulk vitrification or the need for a supplemental
technology. However, proceeding with the demonstration project before
reaffirming the need for a supplemental technology, or reassessing the
need for the bulk vitrification project, increases the risk that DOE will
spend an additional $137 million or more to develop a technology that may
not be needed or is no longer the best option for treating Hanford's
low-activity tank waste.
We are recommending that, before continuing with the bulk vitrification
demonstration project, the Secretary of Energy direct the Assistant
Secretary for Environmental Management to (1) reassess the continuing need
for a supplemental technology to treat a portion of Hanford's low-activity
tank waste; (2) if a reassessment shows that a supplemental technology is
still needed, reassess the relative costs and benefits of demonstrating
and deploying bulk vitrification compared with other available
technologies; and (3) report to Congress on the results of the
reassessment before requesting additional funding for the bulk
vitrification demonstration. If DOE does not reassess the bulk
vitrification project before requesting additional funding for the
project, we are recommending that Congress consider withholding the
additional funding until DOE implements these recommendations.
DOE commented on a draft of the report and disagreed with the report's
assertions that the bulk vitrification project did not follow the
department's project management requirements. In addition, DOE commented
that the project has been subject to multiple, formal independent project
management, technical, and safety reviews. Furthermore, DOE stated that it
is already performing an assessment of options to complete the cleanup of
Hanford's waste tanks and that bulk vitrification is one of several
supplemental treatment technologies being evaluated. We disagree with
DOE's comment that the bulk vitrification project followed DOE's project
management requirements. Documents that DOE provided during our review
indicate it was not until September 2005--after the project had
experienced numerous problems and significant cost and schedule
increases--that DOE decided the demonstration project would be subject to
the department's project management order. Regarding DOE's assessment of
options to complete tank waste cleanup, we do not believe it constitutes
the reassessment of the need for a supplemental technology or the relative
costs and benefits of demonstrating and deploying bulk vitrification
compared with other viable technologies that our report recommends.
Although DOE did not comment on our recommendations, we believe that
implementing them will enhance the available data on the bulk
vitrification project and improve the basis for future DOE decisions.
Background
DOE carries out its waste cleanup program at Hanford under the direction
of the Assistant Secretary for Environmental Management and in
consultation with a variety of stakeholders. EPA and the Washington State
Department of Ecology provide regulatory oversight of cleanup activities
at the site. The Defense Nuclear Facilities Safety Board (Safety Board)
also oversees DOE's operations.^8 Other stakeholders involved in the
Hanford cleanup project include county and local governmental agencies,
Native American tribes, advisory groups, and citizen groups. These
stakeholders advocate their views through various processes, including
site-specific advisory boards. DOE manages the tank waste at Hanford
through its Office of River Protection, which Congress directed DOE to
establish in 1998. The office has a staff of about 110 DOE employees and a
fiscal year 2007 budget of about $1 billion. It manages Hanford's tank
waste through two main contracts: a tank farm operations contract with
CH2M Hill Hanford Group, Inc., to maintain safe storage of the waste in
underground tanks and to prepare it for retrieval, and a construction
contract with Bechtel National, Inc., to design, construct, and commission
the waste treatment plant. DOE's tank farm contractor, CH2M HILL Hanford
Group, Inc., awarded a subcontract to AMEC Earth and Environmental, Inc.
(AMEC), to begin testing the bulk vitrification technology.
^8The Safety Board was created by Congress in 1988 to provide an
independent assessment of safety conditions and operations at defense
nuclear facilities, including DOE's Hanford site. See 42 U.S.C. SS
2286-2286i.
Management Weaknesses during the Bulk Vitrification Demonstration Project
Contributed to Technical Problems, Cost Increases, and Schedule Delays
As part of the effort to accelerate the tank waste cleanup at the Hanford
site, DOE site officials decided not to follow a number of project
management requirements on the bulk vitrification demonstration project.
Without the management tools that these requirements provide, DOE
initially overlooked a number of technical and safety problems facing the
demonstration, which contributed to an increase in the project's estimated
cost and a delay in the estimated completion date. In late 2005, largely
because of the technical and safety problems, DOE determined that the
project should be managed in accordance with departmental requirements and
is currently in the process of implementing these requirements.
DOE Did Not Follow Project Management Requirements during the First 2 Years of
the Demonstration
DOE's project management requirements outlined in the DOE order specify
that a number of steps be taken throughout the development of a project.
These requirements apply to all capital projects having a total cost of at
least $20 million and are intended to ensure that projects are effectively
delivered on schedule and within budget and that both DOE and its
contractors are held accountable. According to the Secretary of Energy,
the purpose of the requirements is to provide for a documented
decision-making process that fosters a disciplined project planning
approach and a method for measuring progress toward defined goals. As
such, the order includes a requirement to follow a strict set of decision
points outlining specific actions that DOE must take before beginning the
construction and operations of a new facility. Some of these specific
actions include conducting various internal and external reviews,
developing key project documents, such as an acquisition strategy and a
project execution plan, and developing and validating a cost and schedule
estimate.^9 These requirements are applicable to both DOE and its
contractors on the project.
However, during the first 2 years of the bulk vitrification project, DOE
did not follow its management requirements. In an effort to expedite
cleanup activities in 2003, as part of DOE's accelerated cleanup
initiative, DOE officials at the Hanford site determined that activities
connected to Hanford's tank waste cleanup effort would not be subject to
the project definition requirements of the DOE order. Specifically, DOE
made two key determinations to justify its decision to accelerate the
project. First, DOE reasoned that since the tank farm cleanup effort, as a
whole, did not technically meet the definition of a project--work that has
a defined start and end point and that creates a "product, facility, or
system"--related activities would not be subject to DOE's strict project
management requirements. Based on that decision, in 2004, DOE officials at
Hanford determined that the bulk vitrification demonstration project,
which was managed as part of DOE's tank farm activities, would also not be
subject to DOE's project management requirements. However, this
determination was not consistent with DOE's requirements since the
demonstration project is expected to have a start and end point and result
in a facility. Second, DOE officials further justified the decision to not
apply the project management requirements by asserting that the
demonstration project was a minor research and development effort.
However, specific language in the DOE order states that "technology
development activities," such as the bulk vitrification project, should be
subject to the requirements in the order.
As a result of DOE's decision not to apply some of the requirements of its
order during the early stages of the demonstration project, DOE and its
contractor did not take a number of key project management steps called
for in the order. For example, DOE is required to conduct internal and
external reviews to evaluate a project's mission need and cost estimate in
the development of a project. However, DOE did not conduct these reviews
that could have helped identify potential problems during the first 2
years of the bulk vitrification demonstration. Similarly, DOE's guidance
requires project managers and DOE contractors to develop and update key
project planning documents, such as a project execution plan and an
acquisition strategy. While both of these documents were created in early
2004, neither was updated when the contractor was awarded the contract for
the demonstration several months later. Instead, the contract called for a
fast-track, design-build approach where design, construction, and
technology development occur simultaneously. This approach increases the
risk of encountering problems that can adversely affect a project's cost
and schedule.^10 Finally, the project management order requires DOE to
develop, validate, and maintain an updated cost and schedule baseline for
its projects and to notify the proper DOE headquarters officials when
significant changes to these estimates occur. However, DOE did not
develop, and still does not have, a validated cost and schedule baseline
for the project about 3 years after awarding the contract. DOE now plans
to follow the management order by developing and validating a cost and
schedule estimate for the demonstration project in early fiscal year 2008.
^9According to the DOE order, an "acquisition strategy" is a document
describing the high-level business and technical management approach that
includes a master schedule, along with details about planning, organizing,
and controlling a project; a "project execution plan" is the core document
for managing a project and includes policies and procedures to be followed
and how the project is to be accomplished.
The Demonstration Project Faced a Number of Technical and Safety Problems
Resulting in Cost Increases and Schedule Delays
The bulk vitrification technology posed a number of technical and safety
problems very early on in the development of the project. Even before the
contract was awarded in 2004, DOE's contractor was aware of potential
problems that could affect the demonstration. For example, during initial
testing of the technology in 2003, which involved melting simulated waste,
not all of the simulated waste--intended to mimic the properties of
hazardous materials, such as technetium 99--was retained in the glass. In
subsequent large-scale tests, some of the simulated waste collected near
the surface of the container and began leaking out through the joints in
the container. Similarly, testing in 2003 indicated that the contractor
was aware of potentially dangerous emissions during operations of the
facility that could have safety implications to demonstration workers. In
August 2005, the Safety Board reported that the facility, as designed,
would not adequately contain radioactive and hazardous emissions during
and after melting operations. The Safety Board pointed out that the
facility design did not comply with DOE's own facility safety requirements
and requested that DOE resolve these weaknesses.
^10Since 1992, we have reported frequently on the problems and risks of
this approach to managing projects. See, for example, [21]GAO-06-602T .
These technical and safety problems contributed to an increase in the
demonstration's estimated cost and a delay in the projected completion
date. One month after awarding the $62 million contract for the
demonstration, the contractor informed DOE that to address these issues,
the cost estimate had nearly doubled to an estimated $102 million. The
cost estimate has since risen to about $230 million--nearly a fourfold
increase from the initial contract price--as DOE and its contractors have
taken steps to address these problems. These steps included upgrading
facility designs, such as changes to accommodate more robust safety
systems than had originally been anticipated; additional testing; and
other scope changes, such as adding the cost to accept waste retrieved
from one of Hanford's tanks for testing. In addition, these changes caused
the initial estimated completion date for the demonstration to slip from
2006 to the current estimate of 2012.
DOE's decision not to follow its project management requirements likely
contributed to these problems. Without the management tools called for in
DOE's requirements, such as updated timely reviews, project documents, and
a validated cost and schedule baseline, these problems were not brought to
the attention of DOE headquarters. For example, even though the costs
increased significantly during the first few months of the project,
without a validated baseline for the project, DOE's contractor did not
file an official baseline change request that would have alerted DOE
management of the cost increases. Similarly, because DOE and its
contractor did not follow the strict set of approvals required by DOE's
order at key decision points, there was no way for DOE to formally
reassess the risks and mission needs as the project became more expensive
and complex. According to a review of the project conducted in September
2005, having these key management tools in place when the project began
would have provided DOE with an opportunity to identify and address these
problems.^11 Without these tools, however, DOE was not fully informed, and
the contractor was allowed to continue at an accelerated pace. Despite the
problems facing the project, construction began on the demonstration
facility in January 2005, with detailed facility design only about 30
percent complete.
^11Demonstration Bulk Vitrification System Independent Review Report,
Longenecker and Associates, September 2005.
DOE Began Following Management Requirements in the Third Year of the
Demonstration
In 2005, facing numerous problems, DOE halted construction on the project
and determined that it should be managed in accordance with departmental
project management requirements. In May 2005, 4 months after construction
had begun, DOE's contractor began slowing down its activities related to
the demonstration in order to assess the reasons behind the cost increases
and schedule delays. In addition, in August 2005, the Secretary of Energy
instructed all program offices to follow DOE's order "scrupulously,
without exception." As a result, in September 2005, DOE officials at
Hanford instructed the contractor to more rigorously follow project
management requirements, including focusing on completing facility design
before continuing construction activities, updating project execution and
acquisition plans, and commissioning two independent reviews to assess the
demonstration's technical approach and cost and schedule estimates. DOE
decided not to request funding for the project in fiscal years 2007 and
2008 while the problems are being resolved.
DOE is currently in the process of implementing a number of its project
management requirements to address the problems facing the project and to
better control costs. Because the project was at an advanced stage of
design development when DOE chose to begin following its management order,
DOE has had to implement some of the requirements retroactively. For
example, DOE updated the project initiation documents, such as the project
execution plan and the mission needs statement, and obtained internal
approvals for those documents even though the project was past the
initiation stage. DOE also commissioned external independent reviews
called for in its order, including two external technical reviews of the
demonstration,^12 as well as a management review of the project. Finally,
DOE is currently in the process of developing and validating a cost and
schedule baseline for the demonstration and plans to submit the entire
project package for another review by the department's Office of
Engineering and Construction Management in early fiscal year 2008, as
required by DOE's order.
^12One of these reviews of the project identified 19 technical issues that
could result in a failure of the bulk vitrification demonstration to meet
performance requirements unless addressed before operational startup, and
26 areas of concern that could result in a change to facility design or
require additional testing to determine if the design is adequate. See A
Comprehensive Technical Review of the Demonstration Bulk Vitrification
System, Technical Assessment Conducted by an Independent and External Team
of Experts, Volume 1, chartered by CH2M Hill Hanford Group, Inc.
(Richland, Wash.: Sept. 28, 2006).
The Extent to Which the Bulk Vitrification Demonstration Is Still Needed Is
Unclear; However, DOE Does Not Plan to Reassess Its Need Before Continuing with
the Demonstration
The extent to which DOE continues to need a supplemental technology to
treat a portion of the low-activity tank waste at Hanford is unclear. In
the years since DOE selected bulk vitrification as the preferred
technology, significant changes to the objectives that originally existed
have raised questions about whether bulk vitrification is the most viable
option for treating a portion of Hanford's low-activity tank waste.
Despite these questions, DOE does not plan to reassess the project before
continuing with the demonstration and has not developed an acquisition
strategy that clearly shows how the bulk vitrification and waste treatment
plant projects will be integrated to control costs and meet tank waste
cleanup requirements.
The Original Objectives That Justified Developing the Bulk Vitrification
Technology Are No Longer Achievable
The original objectives DOE used to justify demonstrating and deploying
the bulk vitrification technology are no longer achievable. Table 1
compares DOE's original objectives for demonstrating and deploying the
bulk vitrification technology with the current conditions.
Table 1: Original Objectives for Demonstrating and Deploying Bulk
Vitrification Technology Compared with Current Conditions
Source: DOE.
aThese figures are in constant 2006 dollars.
DOE's goals of rapidly demonstrating and deploying bulk vitrification as a
supplemental technology in conjunction with waste treatment plant
operations are no longer achievable. DOE initially planned to use a
fast-track, design-build approach to demonstrate bulk vitrification as the
preferred supplemental technology by 2006 and have a facility fully
operational by 2011 when the waste treatment plant was scheduled to begin
operations. Although DOE has not been able to demonstrate and deploy the
bulk vitrification technology at this aggressive pace, the urgency to do
so no longer exists because of delays with the waste treatment plant
schedule, of at least 8 years, to late 2019. DOE has not yet finalized the
design of the bulk vitrification demonstration, resumed construction of
the demonstration facilities, or validated the project's estimated cost
and schedule. Instead of demonstrating the technology by 2006, as
originally planned, DOE estimated that the bulk vitrification
demonstration project may be completed in 2012, or about 6 years behind
schedule. Recently updated demonstration project schedules show that the
demonstration may be delayed even further until early 2013. Similarly,
instead of having a full-scale treatment facility operational by 2011, DOE
now estimates that supplemental treatment facilities may not be fully
operational until 2019, or about 8 years later than originally planned.^13
Further, DOE expected that a supplemental technology would be less
expensive than expanding the waste treatment plant, but DOE is no longer
able to develop and deploy a supplemental technology at low cost. As
discussed earlier, during the years that the bulk vitrification
demonstration has been under way, costs increased primarily because of the
technical and safety problems that have plagued the project. Such problems
required DOE to make changes to the demonstration project's design and
resulted in increased costs to demonstrate the bulk vitrification
technology. These problems have also increased the expected cost of a
full-scale operating bulk vitrification facility. DOE's life-cycle cost
estimate of a full-scale bulk vitrification facility has increased from
about $1.3 billion to about $3 billion. This is about the same cost as
another alternative DOE previously evaluated in 2003--adding a second
low-activity waste treatment facility to the waste treatment plant--and
which DOE considered to be too expensive.^14 In addition, the latest bulk
vitrification life-cycle cost estimate is expected to increase further
because it is based on assumptions that are no longer current^15 and,
according to project officials, is a conceptual estimate that is subject
to change as DOE proceeds with the demonstration.
^13Based on the project schedule, a full-scale bulk vitrification facility
in the west area of the Hanford site may be operational between 2014 and
2016. The planned facility in Hanford's east area is not scheduled to be
operational until late 2019.
^14Although the estimated life-cycle costs of the two facilities are about
the same, their technologies are at different stages of development. A
low-activity waste treatment facility, like the one currently under
construction on the waste treatment plant project, represents a more
mature technology than bulk vitrification because it has already been
extensively demonstrated, its detailed design is more than 90 percent
complete, and construction of the facility will be about 50 percent
complete by the end of fiscal year 2007.
DOE also based its need for a supplemental technology, in part, on the
expectation that it could accelerate the overall cleanup effort by
treating about half of Hanford's low-activity waste by 2028, the legal
milestone for completing tank waste treatment. However, given the recent
schedule delays for both the bulk vitrification and waste treatment plant
projects, this goal is no longer achievable, and it is no longer clear
when, or if, a supplemental technology will be needed. DOE now estimates
that the waste treatment plant may begin treating waste in late 2019, or
about 8 years later than originally scheduled. A variety of factors
affecting the operation of the waste treatment plant remain unresolved,
including the actual capacity of the waste treatment plant facilities and
the operational reliability of those facilities. Given these
uncertainties, DOE has not yet defined how long waste treatment plant
operations will extend. However, the length of plant operations may range
from 20 to 55 years.^16 This wide range reflects DOE's uncertainty about
the amount of waste that the waste treatment plant can treat each year and
the outcome of future negotiations DOE will have with federal and state
environmental agencies to set a new time frame for completing tank waste
treatment operations. This is significant as longer operating periods may
reduce the need for a supplemental technology because, given the plant's
estimated treatment capacity, more of the low-activity waste could be
treated in waste treatment plant facilities. For example, based on the
plant's maximum estimated treatment capacity, for tank waste treatment to
be completed in 20 years, a supplemental technology would need to treat
about half of the low-activity waste. If treatment operations extend for
more than 40 years, supplemental technology may not be needed because the
waste treatment plant would be able to treat all of the tank waste.
^15One such assumption in the bulk vitrification life-cycle cost estimate
is that tank waste treatment would be completed by 2036. In contrast,
DOE's fiscal year 2008 budget request states that treatment will not be
completed until 2042, or at least 6 years later than previously estimated.
DOE contractor officials acknowledged that an extension to the estimate's
schedule would result in increased costs, but they had not updated the
estimate because the length of the operating schedule is not yet known.
^16Although the fiscal year 2008 budget request indicates an operating
schedule through 2042, DOE has not specifically defined the length of the
waste treatment plant's operating schedule. DOE's project managers stated
that the operating schedule may range from 22 to 35 years. However, an
internal engineering study estimated operations may range from 20 to 55
years. We include the latter range because it reflects the full range of
estimates.
DOE Does Not Plan to Reassess the Need for Continuing the Demonstration and
Risks Additional Spending on a Technology That May Not Be Needed or Is Not a
Viable Option for Treating Hanford's Radioactive Waste
Even though the conditions justifying the bulk vitrification demonstration
have changed significantly, DOE does not plan to reassess the need for the
project and plans to continue the demonstration. This decision runs
contrary to DOE's project management requirements that specify that when
conditions have significantly changed, the department should reassess the
mission need and reexamine available alternatives as well as the benefits
and appropriateness of continuing with a project. Furthermore, DOE plans
to renew requests for project funding in fiscal year 2009 but does not
intend to reassess the overall need for the project before proceeding.
Instead, DOE decided to continue with the demonstration to obtain more
information on the performance of bulk vitrification technology and
compare the technology with other available alternatives by 2012 or later.
DOE project officials acknowledged that the need for bulk vitrification
may be less compelling than when initially selected but said that
developing more information on this technology would provide additional
treatment flexibility that may have value in the future. As part of this
effort to develop more information, DOE initiated an internal study in
late April 2007 to compare advantages, disadvantages, and risks for
various combinations of treatment options, including bulk vitrification,
for successfully completing tank waste treatment at Hanford. Although this
study, which is to be completed by June 30, 2007, is not a decision-making
document or a comprehensive reassessment of individual technologies or the
overall need for a supplemental technology, it will be used to support
near-term funding decisions for the tank waste cleanup program. After
completing the demonstration project in 2012 or later, DOE plans to
compare the bulk vitrification technology with other viable technical
alternatives, such as building a second low-activity waste facility, as
required by the Tri-Party Agreement.^17 However, DOE's decision to proceed
with the demonstration before reassessing the need for the project
increases the risk that it may spend an additional $137 million or more^18
to develop a technology that may not be needed or is no longer the most
viable option for treating Hanford's low-activity tank waste.
^17Tri-Party Agreement milestone M-62-08 required DOE to conduct a final
assessment of supplemental technologies and submit a Hanford tank waste
supplemental treatment technologies report by July 31, 2005. DOE missed
this milestone but has agreed to perform this assessment by 2012. However,
a revised milestone has not yet been formally negotiated with federal and
state environmental agencies.
Conclusions
Nearly 4 years after selecting bulk vitrification as the preferred
technology for treating about half of Hanford's low-activity tank waste,
DOE is faced with a host of technical, safety, and management
uncertainties on the demonstration project, as well as more fundamental
questions as to whether a supplemental waste treatment technology is still
needed. Although bulk vitrification was initially viewed as a relatively
low-cost technology that could be rapidly developed, demonstrated, and
deployed to supplement the operations of the waste treatment plant,
technical problems, rising costs, and schedule delays with the bulk
vitrification demonstration project raise questions about DOE's overall
strategy for addressing the waste. In light of these questions, it is
unclear if pursuing the demonstration of this particular technology,
instead of other technologies, is the best approach. Furthermore, because
DOE now expects the waste treatment plant to operate for much longer than
originally planned, the plant may be capable of treating most or all of
the low-activity waste a supplemental technology was originally intended
to treat. However, despite this significant uncertainty about how much
waste, if any, a supplemental technology would actually need to treat, DOE
is not planning to reexamine the need for bulk vitrification before
proceeding with the demonstration project. In taking this approach, DOE is
not following its guidelines that specify that when conditions have
significantly changed, the department should reassess the benefits and
appropriateness of continuing with a project. Without this reassessment,
DOE risks spending an additional $137 million or more to demonstrate a
technology that may not be needed or is no longer the best available
option for treating Hanford's low-activity tank waste.
Recommendations for Executive Action
In light of major changes that have occurred on both the bulk
vitrification demonstration and the waste treatment plant, which may
affect the demonstration's costs, schedule, and mission justification, we
recommend that the Secretary of Energy direct the Assistant Secretary for
Environmental Management to take the following three actions:
^18To date, DOE has spent about $93 million of the estimated $230 million
for the bulk vitrification demonstration project.
o Reassess the need for a supplemental technology to treat a
portion of Hanford's low-activity tank waste. The reassessment
should clearly identify how a supplemental technology would
complement and be integrated with waste treatment plant
operations.
o If a reassessment shows that a supplemental technology is still
needed, reassess the relative costs and benefits of demonstrating
and deploying bulk vitrification compared with other viable
technologies, such as constructing a second low-activity waste
vitrification facility.
o Report to Congress on the results of the reassessment before
requesting additional funding for the bulk vitrification project.
Matter for Congressional Consideration
Congress should consider withholding future funding for the
demonstration until the department conducts and reports on a
reassessment that clearly confirms the need for a supplemental
technology at Hanford and bulk vitrification as a viable
alternative for treating Hanford's low-activity waste.
Agency Comments and Our Evaluation
We provided a draft of this report to DOE for its review and
comment. In written comments, DOE's Assistant Secretary for
Environmental Management expressed areas of disagreement with the
report's findings but did not comment on our recommendations.
DOE's written comments on our draft report are included in
appendix II. DOE also provided technical comments that we have
incorporated where appropriate.
In its written comments, DOE disagreed with the draft report's
finding that the bulk vitrification project did not follow the
department's project management requirements. In addition, DOE
commented that the project has been subject to multiple, formal
independent project management, technical, and safety reviews.
Furthermore, DOE stated that it is already performing an
assessment of options to complete the cleanup of Hanford's waste
tanks and that bulk vitrification is one of several supplemental
treatment technologies being evaluated.
Based on our review of available documentation, we continue to
believe that the bulk vitrification project did not follow DOE's
project management requirements. Multiple documents provided by
DOE during our review demonstrate that the department determined
in 2003 that activities related to the Hanford tank farm cleanup
effort, such as the bulk vitrification project, would not be
subject to all of DOE's project management requirements. In fact,
DOE even advised its contractor that it would not be required to
follow the formal decision process outlined in DOE's project
management order. Because of this decision, DOE proceeded from the
initiation phase of the project to the construction phase without
taking preliminary steps called for in the order, such as
developing a cost and schedule baseline. DOE commented that, as
early as November 2004, it recognized that additional project
management oversight would be warranted as the project matured.
However, documents provided to us by DOE indicate that it was not
until September 2005--after the project had experienced numerous
problems and significant cost and schedule increases--that DOE
decided that the demonstration would, from that time forward, be
subject to the requirements of its project management order.
We agree with DOE that the bulk vitrification project has been
subject to multiple, formal independent project management and
technical and safety reviews by organizations inside and outside
of the department. Our draft report discussed many of these
reviews. Although these reviews have addressed important
management, technical, and safety problems of the project, they
are not reassessments of the need for a supplemental technology.
It is also important to note that the assessment of options to
complete the cleanup of Hanford's waste tanks that DOE refers to
in its comments is likewise not a reassessment of the need for a
supplemental technology or of bulk vitrification technology. In
fact, as stated in its charter, the assessment--which is for
information purposes only and is not intended as a decision-making
document--assumes the continued need for a supplemental technology
and development of the bulk vitrification technology. Furthermore,
as our draft report noted, it is only after the bulk vitrification
demonstration project is completed in 2012 or later that DOE plans
to compare bulk vitrification technology with other technical
alternatives. Given the scope and purpose of this assessment, we
do not believe it constitutes the reassessment of the need for a
supplemental technology or the relative costs and benefits of
demonstrating and deploying bulk vitrification compared with other
viable technologies that our draft report recommends.
While DOE agrees that the extent to which a supplemental
technology would be used is imprecise, it continues to assert that
there is a very high likelihood that the cleanup mission at
Hanford would benefit from added capacity to treat low-activity
waste. Although DOE may be correct, we are uncertain whether the
department has adequately demonstrated the basis for this
assertion. As our draft report discussed, the original cost and
schedule conditions DOE used to justify the need for supplemental
technology have changed significantly, and the original objectives
that justified developing the technology are no longer achievable.
In light of these significant changes, we continue to believe that
the department should reassess the mission need and benefits of
continuing the project, rather than simply assuming that the need
still exists. Contrary to DOE's contention, we are not
recommending that the department cancel its evaluation of the bulk
vitrification approach before it has data on which to base a
decision. Indeed, we believe that our recommendation that DOE
reassess the need for supplemental technology and the costs and
benefits of bulk vitrification compared with other viable
technologies would actually enhance the available data on the
project and improve the basis for future DOE decisions.
We are sending copies of this report to other interested
congressional committees and to the Secretary of Energy. We also
will make copies available to others upon request. In addition,
this report will be available at no charge on the GAO Web site at
http://www.gao.gov.
If you or your staff has any questions on this report, please
contact me at (202) 512-3841 or by e-mail at [email protected].
Contact points for our Offices of Congressional Relations and
Public Affairs may be found on the last page of this report. Key
contributors to this report are listed in appendix III.
Gene Aloise
Director, Natural Resources and Environment
Appendix I: Scope and Methodology
To determine how the Department of Energy (DOE) has managed the
bulk vitrification demonstration project, we compared project
management practices with project management guidance and
documented any differences. We reviewed project planning and
acquisition documents to understand the original objectives and
assumptions DOE used to justify demonstrating bulk vitrification
technology and for managing the demonstration project. We
documented the management problems the contractor has experienced
on the project from contract award to the present. We also
documented the steps the department has taken to improve
management of the demonstration. We discussed these steps with
department and contractor officials to determine their status and
to assess DOE's progress. We also discussed project oversight
efforts with officials of DOE's Office of Engineering and
Construction Management in Washington, D.C.
To determine the extent to which DOE continues to need a
supplemental technology, we reviewed internal and external
technical studies and reviews on the project and discussed with
DOE and contractor officials the steps they have taken to resolve
problems experienced to date. We also discussed these issues with
key representatives of federal and state environmental agencies.
We visited the bulk vitrification demonstration site, interviewed
DOE and contractor officials, and reviewed key studies and project
documents that describe how DOE and the contractor plan to conduct
the demonstration. To assist in evaluating the technical aspects
of the demonstration project, we obtained assistance from a
technical consultant, Dr. George Hinman, who has a Doctor of
Science degree in physics and is Professor Emeritus at Washington
State University. Dr. Hinman has extensive nuclear energy
experience in industry, government, and academia. Since the
purpose of the bulk vitrification technology is to supplement the
capacity of Hanford's waste treatment plant, we spoke with DOE's
Office of River Protection and contractor officials to determine
the extent to which the waste treatment plant's cost, schedule,
and technical changes may affect the bulk vitrification
demonstration project. We also obtained documentation and
discussed with these officials the life-cycle cost of a second
low-activity waste facility as part of the waste treatment plant.
We compared this cost with the current life-cycle cost estimate
for a full-scale bulk vitrification facility.
We relied on dollar figures provided by DOE and its contractors
but took various steps, such as analyzing cost estimating
documents and reviewing cost estimating assumptions, reviewing
budget documents, and obtaining clarifications from the officials
who prepared them, to ensure that the data were sufficiently
reliable for purposes of this report. We performed our work
between June 2006 and May 2007 in accordance with generally
accepted government auditing standards.
Appendix II: Comments from the Department of Energy
Appendix III: GAO Contact and Staff Acknowledgments
GAO Contact
Gene Aloise, (202) 512-3841, [email protected]
Staff Acknowledgments
In addition to the individual named above, William R. Swick,
Assistant Director; Ryan T. Coles; John Delicath; Doreen Feldman;
George Hinman; Jeffrey Larson; and Thomas Perry made significant
contributions to this report. Others who made important
contributions included Mark Braza, Doreen Eng, and Mehrzad Nadji.
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(360731)
www.gao.gov/cgi-bin/getrpt?GAO-07-762 .
To view the full product, including the scope
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Highlights of [29]GAO-07-762 , a report to congressional committees
June 2007
NUCLEAR WASTE
DOE Should Reassess Whether the Bulk Vitrification Demonstration Project
at Its Hanford Site Is Still Needed to Treat Radioactive Waste
The Department of Energy (DOE) is demonstrating a technology called bulk
vitrification, in parallel with the Hanford waste treatment plant, to
treat a portion of the radioactive waste stored in 177 tanks at its
Hanford site in southeastern Washington state. DOE faces technical and
management problems that have affected the original objectives to justify
demonstrating the bulk vitrification technology.
This report discusses the extent to which DOE (1) has managed the bulk
vitrification demonstration project consistent with DOE management
guidance and (2) continues to need a supplemental technology, such as bulk
vitrification, to treat a portion of the low-activity tank waste. To
assess DOE's management of the project, GAO reviewed reports by DOE and
others and discussed the project with DOE and contractor officials.
[30]What GAO Recommends
GAO recommends that DOE (1) reassess the need for a supplemental
technology and the costs and benefits of bulk vitrification compared with
other viable technologies and (2) report to Congress the results of the
reassessment. In addition, Congress should consider withholding additional
funding for the project until DOE does so. DOE disagreed with several of
the report's findings but did not comment on GAO's recommendations.
DOE did not follow its management requirements during the first 2 years of
the demonstration project in an effort to accelerate tank waste cleanup.
This decision contributed to a nearly fourfold increase in estimated costs
from $62 million to $230 million and a 6-year delay on the project. DOE
did not conduct key internal and external reviews and did not fully
develop or update key project planning documents as required. Without
these management tools, DOE initially overlooked a number of technical and
safety problems facing the project, such as uncertainties about the
quality of the glass formed using the bulk vitrification technology and
inadequate systems to shield radioactive material from workers and the
environment. In late 2005, largely because of these problems, DOE began
taking steps to implement its management requirements on the project.
DOE's need for a supplemental technology to treat a portion of the
low-activity tank waste at Hanford is no longer clear, but DOE does not
plan to reassess the need for the project before completing the
demonstration. Originally, DOE justified the bulk vitrification project as
a relatively low-cost, rapidly deployable supplemental technology to
assist the department to complete tank waste treatment at Hanford by 2028.
However, none of the key components to this justification remains today
(see table). First, the price of a full-scale bulk vitrification facility
has risen to $3 billion or more, about the same cost as adding a second
low-activity waste treatment facility to the waste treatment plant.
Second, the technology is no longer rapidly deployable because, as
discussed above, the project faces at least a 6-year delay. Finally, it is
now apparent that completing tank waste treatment at Hanford by 2028 is
not possible under any reasonable scenario and that the waste treatment
plant must operate for longer than DOE previously planned. This is
significant since longer operating periods may reduce the need for a
supplemental technology. Given the plant's estimated treatment capacity,
more of the low-activity waste could be treated in the waste treatment
plant facilities. Although DOE's management guidance specifies that when
conditions have significantly changed DOE should reassess the mission need
of a project, DOE does not intend to conduct this reassessment because DOE
officials said they want more information about the technology. Proceeding
with the demonstration project before reaffirming the need for the project
increases the risk that DOE will spend an additional $137 million or more
to develop a technology that may not be needed.
Original Objectives and Current Conditions of DOE's Demonstration Project
Source: DOE.
References
Visible links
20. http://www.gao.gov/cgi-bin/getrpt?GAO-06-602T
21. http://www.gao.gov/cgi-bin/getrpt?GAO-06-602T
29. http://www.gao.gov/cgi-bin/getrpt?GAO-07-762
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