This facility is to receive the low-activity  waste from the Pretreatment facility and immobilize it by vitrification. DOE’s Quality Assurance Framework and Requirements

A set of federal regulations, DOE orders, and ORP procedures  collectively make up DOE’s quality assurance framework that aims to  ensure that all WTP quality assurance problems can be identified and that  identified problems do not recur. The MIP is intended to  ensure that the WTP could operate in compliance with DOE-approved  safety and quality requirements. Actions Taken to Identify and Address Quality Assurance Problems at the WTP

ORP has taken several actions to identify and address quality assurance  problems at the WTP. In addition, of the 39 measures that the contractor considers complete,  some do not appear to be fully implemented, according to one ORP  quality assurance expert that we spoke to. According to ORP’s MIP oversight plan, it  will take the office until at least December 2018 to verify the extent to  which the contractor has implemented each of the 52 MIP corrective  measures. ORP Has Not Ensured That All Quality Assurance Problems Have Been Identified, and Some Previously Identified Problems Are Recurring

According to DOE documents we reviewed and ORP quality assurance  experts we spoke with, ORP’s actions have not ensured that all quality  assurance problems have been identified at the WTP, and some  previously identified problems are recurring. First, a  2016 DOE Office of Enterprise Assessment report found quality  assurance deficiencies that neither ORP nor the contractor had identified  at the time the work was conducted. These quality assurance experts told us that quality assurance  problems are recurring in several key areas, including those areas  identified in the documents described above: (1) procurement of items  and services that do not meet established requirements or perform as  specified; (2) software that does not meet established requirements; and  (3) a maintenance program that does not prevent damage, loss, or  deterioration of WTP structures, systems, and components. ORP’s Organizational Structure May Not Provide Sufficient Independence for Effective Oversight of the WTP Contractor’s Quality Assurance Program

A 2017 assessment from DOE headquarters and our interviews with nine  ORP quality assurance experts suggest that ORP’s organizational  structure does not provide the quality assurance function with sufficient  independence from upper management—which includes the ORP  Manager and the WTP Federal Project Director—to effectively oversee  the contractor’s quality assurance program. A February 2017 external assessment from DOE headquarters noted that  ORP’s Quality Assurance Division’s effectiveness has been limited  because, in some instances, its findings have been mischaracterized by  ORP upper management, and in others, ORP upper management has not  used this division effectively to evaluate the extent of potential quality  assurance problems. Further, the assessment found that ORP management  sometimes mischaracterized the seriousness of the Quality Assurance  Division’s findings and, as a result, did not require the contractor to  conduct extent-of-condition review for significant quality assurance  problems. After 10 years of  construction and more than $2 billion spent,  the company abandoned its effort to construct  the plant. For example, we found that an  organization should be structurally distinct and separate from DOE  program offices to avoid management interference or conflict between  program office mission objectives, such as cost and schedule  performance and safety. Given that some previously identified problems are recurring at the WTP,  including some in areas where the contractor had implemented corrective  measures, and given the findings of the 2017 headquarters assessment  and the statements of ORP’s quality assurance experts outlined above,  we are concerned that ORP’s organizational structure may not entirely  ensure that the Quality Assurance Division meets key elements for a  nuclear safety oversight organization to provide effective independent  oversight. When and where problems have  recurred, ORP has not always required the contractor to determine the  extent to which the problems may affect all parts of the WTP. By directing  ORP to require the WTP contractor, where quality assurance problems  have been identified, to determine the full extent to which problems exist  in all WTP structures, systems, and components, DOE will gain a  comprehensive understanding of all quality assurance problems at all  WTP facilities. By revising ORP’s organizational structure so  that the quality assurance function is independent of ORP upper  management, DOE can have better assurance that compliance with  nuclear safety requirements will not be subordinated to meeting cost and  schedule targets. In  its written comments, reproduced in appendix I, DOE generally agreed  with the findings in the report and its recommendations.
Why GAO Did This Study

DOE and its contractor are building the WTP—which consists of multiple facilities—to treat a large portion of nuclear waste at Hanford. The project has faced persistent challenges, including quality assurance problems that have delayed it by decades and more than tripled its costs, to nearly $17 billion. DOE's quality assurance framework aims to ensure that all problems are identified and do not recur.
Senate Report 114-49 accompanying the National Defense Authorization Act for Fiscal Year 2016 included a provision for GAO to carry out an ongoing evaluation of the WTP. This first report examines (1) the actions DOE has taken to identify and address WTP quality assurance problems, (2) the extent to which DOE has ensured that quality assurance problems have been identified and do not recur, and (3) the extent to which DOE's organizational structure at ORP provides the Quality Assurance Division with independence to effectively oversee the contractor's quality assurance program. GAO reviewed DOE documents and obtained the insights of ORP's internal experts on WTP quality assurance efforts and outcomes.

What GAO Found

The Department of Energy (DOE) has taken several actions to identify and address quality assurance problems at the Waste Treatment and Immobilization Plant (WTP) at its Hanford site in Washington. Among the actions taken is the implementation of the Managed Improvement Plan by DOE's Office of River Protection (ORP) and the WTP contactor. The plan is intended to ensure that the WTP can operate in compliance with DOE-approved safety and quality requirements. The contractor has stated that the plan is fully implemented, but GAO found that a number of key activities may be incomplete and ORP officials will not be able to verify the extent of implementation until December 2018.
According to DOE documents that GAO reviewed and ORP quality assurance experts GAO spoke with, ORP has not ensured that all WTP quality assurance problems have been identified and some previously identified problems are recurring. For example, a 2016 DOE report found quality assurance problems, such as engineering errors and construction deficiencies, that neither ORP nor the contractor had identified when the work was conducted. ORP quality assurance experts GAO spoke with reiterated the issues identified in reports. In addition, DOE audits have found that previously identified quality assurance problems have recurred in key areas, such as the procurement of items that do not meet requirements or perform as specified. These problems were also raised by several of the ORP quality assurance experts GAO interviewed. According to these experts, such recurring problems may lead to significant rework at WTP facilities in the future if work is not stopped and the issues addressed. ORP's quality assurance framework requires the contractor to determine the extent to which quality assurance problems exist in all WTP structures, systems, and components when such problems are identified, and allows ORP to stop work at a facility if recurring issues arise. However, ORP has neither directed the contractor to make this determination nor stopped work when problems recur because it has confidence in the Managed Improvement Plan.
ORP's organizational structure may not provide its Quality Assurance Division with sufficient independence from the office's upper management to oversee the contractor's quality assurance program effectively. GAO has previously found that an oversight organization should be structurally distinct and separate from program offices responsible for cost and schedule performance to avoid conflict between mission objectives and safety. However, a 2017 DOE headquarters assessment found that ORP's Quality Assurance Division's effectiveness has been limited. This is because in some cases ORP upper management had mischaracterized its findings, and in other instances, ORP upper management had not used this division to evaluate the extent of potential quality assurance problems. ORP quality assurance experts GAO spoke to were also concerned that ORP's organizational structure does not always ensure the independence of the division. For example, two of these experts described instances when ORP upper management had downgraded the division's findings so that the contractor could take less stringent corrective measures. By providing the Quality Assurance Division adequate independence, DOE can better ensure that compliance with nuclear safety requirements will not be subordinated to other project management goals, such as meeting cost and schedule targets.

What GAO Recommends

GAO recommends that DOE direct the WTP contractor to determine the extent of problems in WTP structures, systems, and components and order work stops when problems recur, and DOE should direct ORP to revise its organizational structure to ensure the independence of the Quality Assurance Division. DOE generally agreed with GAO's recommendations.