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Nuclear Waste: DOE Should Take Actions to Improve Oversight of Cleanup Milestones

GAO-19-207 Published: Feb 14, 2019. Publicly Released: Feb 14, 2019.
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Fast Facts

The Department of Energy is tasked with cleaning up waste from Cold War nuclear weapons production, much of which is hazardous or radioactive. DOE spends about $6 billion a year on this cleanup, and faces about $500 billion in future liabilities.

Agreements between DOE and its regulators set requirements and milestones (deadlines) for the work at each cleanup site.

We found that DOE didn't accurately track or report whether milestones were met, missed, or postponed. We also found that sites continually renegotiate milestones they are at risk of missing.

We made 4 recommendations to address these and other issues we found.

Department of Energy Sites Where Cleanup Remains

This is a map of the United States marking the 16 sites.

This is a map of the United States marking the 16 sites.

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Highlights

What GAO Found

The cleanup process at the 16 sites overseen by the Department of Energy's (DOE) Office of Environmental Management (EM) is governed by 72 agreements and hundreds of milestones specifying actions EM is to take as it carries out its cleanup work. However, EM headquarters and site officials do not consistently track data on the milestones. EM headquarters and site officials provided GAO with different totals on the number of milestones in place at the four sites GAO selected for review. These discrepancies result from how headquarters and selected sites define and track milestones. First, not all sites make the same distinction between major (i.e., related to on-the-ground cleanup) and non-major milestones and, as a result, are not consistently reporting the same milestones to EM headquarters. Second, sites do not consistently provide EM headquarters with the most up-to-date information on the status of milestones at each site. These inconsistencies limit EM's ability to use milestones to manage the cleanup mission and monitor its progress.

EM does not accurately track met, missed, or postponed cleanup-related milestones at the four selected sites, and EM's milestone reporting to Congress is incomplete. EM sites renegotiate milestone dates before they are missed, and EM does not track the history of these changes. This is because once milestones change, sites are not required to maintain or track the original milestone dates. GAO has previously found that without a documented and consistently-applied schedule change control process, program staff may continually revise the schedule to match performance, hindering management's insight into the true performance of the project. Further, since 2011, EM has not consistently reported to Congress on the status of the milestones each year, as required, and the information it has reported is incomplete. EM reports the most recently renegotiated milestone dates with no indication of whether or how often those milestones have been missed or postponed. Since neither EM headquarters nor the sites track renegotiated milestones and their baseline dates at the sites, milestones do not provide a reliable measure of program performance.

EM officials at headquarters and selected sites have not conducted root cause analyses on missed or postponed milestones; thus, such analyses are not part of milestone negotiations. Specifically, EM has not done a complex-wide analysis of the reasons for missed or postponed milestones. Similarly, officials GAO interviewed at the four selected sites said that they were not aware of any site-wide review of why milestones were missed or postponed. Best practices for project and program management outlined in GAO's Cost Estimating and Assessment Guide note the importance of identifying root causes of problems that lead to schedule delays. Additionally, in a 2015 directive, DOE emphasized the importance of conducting such analysis. Analyzing the root causes of missed or postponed milestones would better position EM to address systemic problems and consider those problems when renegotiating milestones with regulators. Without such analysis, EM and its cleanup regulators lack information to set more realistic and achievable milestones and, as a result, future milestones are likely to continue to be pushed back, further delaying the cleanup work. As GAO has reported previously, these delays lead to increases in the overall cost of the cleanup.

Why GAO Did This Study

EM manages DOE's radioactive and hazardous waste cleanup program using compliance agreements negotiated between DOE and other federal and state agencies. Within the agreements, milestones outline cleanup work to be accomplished by specific deadlines. EM's cleanup program faces nearly $500 billion in future environmental liability, which has grown substantially.

GAO was asked to review DOE's cleanup agreements. This report examines the extent to which EM (1) tracks the milestones in cleanup agreements for EM's cleanup sites; (2) has met, missed, or postponed cleanup-related milestones at selected sites and how EM reports information; and (3) has analyzed why milestones are missed or postponed and how EM considers those reasons when renegotiating milestones.

GAO reviewed agreements and milestones at EM's 16 cleanup sites and compared information tracked by EM headquarters and these sites; interviewed officials from four selected sites (chosen for variation in location and scope of cleanup, among other factors); and reviewed EM guidance related to milestone negotiations.

Recommendations

GAO is making four recommendations, including that EM establish a standard definition of milestones across the cleanup sites, track and report original and renegotiated milestone dates, and identify the root causes of why milestones are missed or postponed. In commenting on a draft of this report, DOE agreed with three of the recommendations and partially agreed with a fourth.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Energy The Assistant Secretary of DOE's Office of Environmental Management should update EM's policies and procedures to establish a standard definition of milestones and specify requirements for both including and updating information on milestones across the complex. (Recommendation 1)
Closed – Implemented
In August 2021, DOE issued a new standard operating procedure that standardized requirements for sites to enter milestone information into DOE's project planning and tracking system. These revised procedures included clarifications on (1) the definitions of milestones and (2) the requirements for including and updating milestone information monthly. As a result of this new guidance, EM's tracking and reporting on the status of cleanup milestones will be more accurate and reliable in the future.
Department of Energy The Assistant Secretary of DOE's Office of Environmental Management should track original milestone dates as well as changes to its cleanup milestones. (Recommendation 2)
Closed – Implemented
In August 2021, DOE issued a new standard operating procedure that standardized requirements for sites to enter into DOE's project planning and tracking systems. These revised procedures included a requirement for EM site offices to include the original milestone dates in its reporting. As a result of this new guidance, EM's reporting on the status of cleanup milestones will be more accurate and useful to decision-makers in the future.
Department of Energy The Assistant Secretary of DOE's Office of Environmental Management should comply with the requirements in the National Defense Authorization Act by reporting annually to Congress on the status of its cleanup milestones and including a complete list of cleanup milestones for all sites required by the act. The annual reports should also include, for each milestone, the original date along with the currently negotiated date. (Recommendation 3)
Open
DOE agreed with the recommendation, but as of November 2022, DOE has not fully implemented the recommendation. DOE officials told us that they have collected data from each of the cleanup sites and are now evaluating the information after which DOE will be able to provide a standard report on milestones at each site. As of October 2023, we are following up with DOE and will update this recommendation when we receive additional information.
Department of Energy The Assistant Secretary of DOE's Office of Environmental Management should conduct root cause analyses of missed or postponed milestones. (Recommendation 4)
Closed – Implemented
In June 2020, DOE selected two sites and conducted a root cause analysis on dozens of delayed, missed, or cancelled milestones. Following this analysis, DOE determined that additional root cause analyses at other sites would be "time consuming and potentially infeasible." However, in August 2021, also in response to this recommendation, DOE did publish procedures that require EM officials to annually assess root cause trends for modified milestones at sites. As a result of this new guidance, EM's reporting on the status of cleanup milestones will be more accurate and useful to decision-makers in the future.

Full Report

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Topics

Compliance oversightEnvironmental cleanupsEnvironmental liabilitiesEnvironmental managementHazardous wastesNuclear wasteProject managementRadioactive wastesProject milestonesNuclear reactors