In March this year the US Department of Energy’s Office of Environmental Management (DOE EM) announced that it had completed the commissioning of a large-scale ventilation system at its Waste Isolation Pilot Plant, the DOE’s geologic repository for defence-related transuranic waste in New Mexico (see panel).
The so-called Safety Significant Confinement Ventilation System (SSCVS) is one of two major capital projects being conducted at WIPP that will increase airflow to the underground sections, allowing full waste emplacement, mining, and maintenance operations to resume. The other is a new utility shaft. WIPP’s ventilation capacity was reduced following an underground fire in 2014 and an unrelated radiological release.
The new facility includes the Salt Reduction Building, which prefilters salt-laden air coming from the underground repository, and the New Filter Building, which houses fans and HEPA filtration to further clean the air.
“This is a big step in getting the SSCVS fully operational and providing additional airflow to the WIPP underground,” said Mark Bollinger, DOE-EM Carlsbad Field Office manager.
The SSCVS will work in tandem with the new utility shaft, which provides a new entry point for air into the WIPP underground. The utility shaft includes a vertical shaft to replace the existing air intake shaft and two hallways to support a new underground ventilation system. The SSCVS will pull air through the repository, remove salt when required, and send the air through HEPA filtration units before it is released to the environment. The new ventilation system will increase underground airflow from 170,000 cubic feet per minute (4800 m3/min) up to a maximum of 540,000 cuf/min (15,290 m3/min).
The Utility Shaft is proposed to house a new, larger capacity hoisting capability to transport materials in and out of the repository.
Work began on the new SSCVS in May 2018 and at that time the cost was projected to be $288m and the work was due for completion by November 2022. However, WIPP terminated its contract with Critical Applications Alliance in August 2020, and a year later in 2021 it awarded a $163m contract to The Industrial Company to complete the project. The project was investigated by the US financial watchdog, the Government Accountability Office (GAO), which in July 2024 published a report titled ‘Nuclear waste cleanup: More effective oversight is needed to help ensure better project outcomes.’
As of April last year, the total cost of the SSCVS project had risen to $494m, with a completion date of June 2026 – almost four years late and $206m over the baseline budget plan.
DOE EM now expects the SSCVS to be fully operational and on-line this year following assessments and reviews intended to demonstrate that all primary and backup systems are functional and operating as expected, and that operators are proficient and fully understand the ventilation system.
The Utility Shaft project began construction in 2020 and is currently estimated to be completed in November 2026 for $288m, around three years late and $91m over the previously approved plan.
Assessing the projects
GAO reviewed WIPP’s SSCVS as one of five DOE EM capital asset projects and found that for those with cost overruns and schedule delays – including SSCVS – officials did not use quality assurance oversight processes as intended.
Measuring performance
According to the review, the SSCVS project did not have consistently compliant Earned Value Management Systems (EVMS), which help measure cost and schedule performance and can also alert officials to problems.
DOE’s Office of Project Management certified the contractor’s EVMS in August 2018. However, an internal surveillance review completed by the contractor in April 2022 found multiple EVMS deficiencies, raising concerns about whether the EVMS was still compliant with requirements.
When a replacement contractor took over the SSCVS project in February 2023 it elected to take over the EVMS used by the previous contractor. To mitigate concerns about EVM data, the project began using alternate project controls. However, by March 2024 – almost two years after the deficiencies were identified and a year after assuming responsibility for the project – the new contractor was unable to bring the system into compliance, and DOE’s Office of Project Management revoked the EVMS certification.
Project peer reviews in 2022 and 2023, described the EVMS as the authoritative source for planning and managing the SSCVS project, so without a certified EVMS, project officials lack a key oversight tool.
Contractor inexperience
Another root cause of delays discussed by the GAO was the contractor’s inexperience in managing capital asset projects. This had been flagged by DOE EM in a 2021 analysis of SSCVS.
The GAO reported in 2022 that the contract for the SSCVS project was awarded to WIPP’s existing management and operating contractor based in part on assurances that the contractor could rely on support from its parent company, but the support was insufficient to prevent or mitigate a downturn in performance. As a result, according to the analysis, the contractor “did not properly evaluate subcontractors or hire staff with the necessary experience to conduct adequate risk management”.
Personnel support
One of DOE’s quality assurance criteria is to train and qualify personnel to be capable of performing their assigned work. Even though EM knew that the contractor was not qualified, EM did not provide sufficient oversight of that contractor to ensure the quality of the project.
GAO found shortcomings in peer reviews that made it hard to assess EM’s oversight. For example, the 2023 project peer review for SSCVS stated that the project was being partially managed effectively, but the support cited was on the effectiveness of the contractor rather than the effectiveness of EM oversight.
Peer reviews
GAO found that when EM conducts root cause analyses, they do not always identify all root causes, particularly those related to DOE and EM management. For example, in a 2021 root cause analysis, EM reported that SSCVS experienced several cost and scheduling issues because of an inexperienced contractor. However, in its analysis EM did not acknowledge its own role in hiring an inexperienced contractor and failing to ensure the contractor received sufficient support. This might have been picked up if the team conducting the root cause analysis had guidance on what to evaluate, but GAO noted that EM used ‘off the shelf’ root cause analysis tools without additional guidance. “In turn, that could have led to a deeper dive into why EM hired an inexperienced contractor, which could be useful information for EM officials across the complex.”
The GAO said, “DOE knew when it awarded the contract for the SSCVS project that the contractor was inexperienced in managing capital asset projects. If EM had provided additional oversight of the project from the beginning of its lifecycle, officials may have been able to identify issues sooner. In addition, with that additional oversight officials may have been able to prevent some of the issues, such as hiring an unqualified subcontractor.”
The GAO report made several suggestions on how EM could improve oversight:
- Providing guidance in how to assess federal management performance and oversight effectiveness during capital asset project reviews, including root cause analyses.
- Actively utilise mechanisms DOE already has for holding contractors accountable for maintaining a compliant EVMS and decide whether additional mechanisms are needed. It says, “when project officials know that the systems are compliant, they have confidence that the data are high quality”.
- Do not miss opportunities to fully leverage lessons learned. Evaluation would show EM management that additional guidance, policies or practices are needed to ensure lessons learned are being utilised to their fullest extent. “For example, EM management could determine they need a standardised practice to evaluate if certain best practices that have resulted from analysis of lessons learned should be embedded in contract language to ensure that issues seen on previous projects do not recur”.
- DOE’s current policy focuses on providing additional oversight after issues have been identified, but DOE and EM should establish a process to identify particularly high-risk or complex projects that may need proactive oversight. This could avoid repeating some of the issues experienced on recent projects.
Overall, the GAO said that “Given the significant cost and complexity of many of EM’s capital asset projects, it is essential for DOE and EM to commit to and establish quality assurance oversight practices that will help prevent issues. In addition, such practices could help ensure that issues that do arise do not recur on the same project or on other EM projects.”
The next steps
During the next 10 years, approximately 25,000 m3 of TRU waste from EM, the National Nuclear Security Site and small quantity sites will be emplaced, according to the site strategy. WIPP will also work closely with the EM Los Alamos Field Office to expedite the shipping of legacy waste from that site. Los Alamos has an “at ready” arrangement with WIPP, which means that when the site has waste ready to ship, WIPP will accept it. This is a unique arrangement.
With the SSCVS and new utility shaft completed and other refurbishment underway, the WIPP will be ready to place more waste in its deep repository. Further infrastructure improvements are also planned to ensure the facility can continue to play its important role in the function of the EM complex.
Additional site infrastructure improvements scheduled for completion during the next decade include:
- Recapitalisation of key safety systems
- Replace or refurbish shaft and hoist systems
- Upgrade monitoring systems
- Replace electrical substations
- Install additional backup generators
- Modernise underground equipment to zero-emission, battery-electric vehicles, or very low-emission Tier IV diesel-powered equipment
- Replace underground electrical system switch stations
- Install a new digital geotechnical monitoring system.
WIPP also plans to replace disposal capability that was lost following the radiological incident in 2014. It has applied to the state of New Mexico for approval to mine two new ‘panels’. Panels 11 and 12 will be replacement panels for space lost in Panels 1-7 and from the abandonment of Panel 9.
