Cooperative Threat Reduction
DOD Has Improved Its Management and Internal Controls, but Challenges Remain
Gao ID: GAO-05-329 June 30, 2005
Section 3611 of the National Defense Authorization Act for Fiscal Year 2004 mandates that GAO assess the Department of Defense's (DOD) internal controls for the Cooperative Threat Reduction (CTR) program and their effect on the program's execution. In addressing the mandate, we assessed DOD's management and internal controls over implementing CTR projects since 2003 by using the control standards for the federal government as criteria. In response to the mandate, we focused on those management and internal control areas considered most relevant to CTR project implementation: (1) building a management structure, (2) risk assessments, (3) performance measures, (4) program reviews, (5) communications, and (6) project monitoring. The Congress also mandated that GAO describe the status of DOD's implementation of legislative mandates covering the CTR program.
Through the CTR program, DOD provides assistance to help the former states of the Soviet Union secure and eliminate their weapons of mass destruction. Since 2003, DOD has improved its management and internal controls over the CTR program. Prior to 2003, DOD had problems managing the program and ensuring that the program was meeting its objectives. These inadequacies became apparent in 2003 following two project failures in Russia that cost the CTR program almost $200 million, including the never used liquid rocket fuel disposition facility. Following these incidents, DOD implemented a more structured approach to managing the CTR program. In July 2003, DOD filled vacancies in the office responsible for managing the program, providing a level of leadership and oversight that did not previously exist. Once in place the new leadership made important improvements to the program's internal controls in the areas of organizational structure, risk assessments, performance measures, program reviews, and communication. For example, DOD now assesses and balances risks with project requirements and measures project performance at each phase. DOD also conducts semi-annual meetings to review commitments and responsibilities of CTR-recipient governments and to minimize risk. Although enhancing its internal controls helps mitigate the risks that stem from having to rely on the cooperation of CTR-recipient governments, DOD can never fully eliminate the project risks associated with recipient governments' cooperation. Furthermore, while DOD's enhancements are an improvement over previous internal controls, current mechanisms do not include a separate review of CTR projects upon their completion. As such, DOD lacks a system for evaluating projects upon their completion and applying lessons learned to future projects.
Recommendations
Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director:
Team:
Phone:
GAO-05-329, Cooperative Threat Reduction: DOD Has Improved Its Management and Internal Controls, but Challenges Remain
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Report to Congressional Committees:
June 2005:
Cooperative Threat Reduction:
DOD Has Improved Its Management and Internal Controls, but Challenges
Remain:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-329]
GAO Highlights:
Highlights of GAO-05-329, a report to congressional committees:
Why GAO Did This Study:
Section 3611 of the National Defense Authorization Act for Fiscal Year
2004 mandates that GAO assess the Department of Defense‘s (DOD)
internal controls for the Cooperative Threat Reduction (CTR) program
and their effect on the program‘s execution. In addressing the mandate,
we assessed DOD‘s management and internal controls over implementing
CTR projects since 2003 by using the control standards for the federal
government as criteria. In response to the mandate, we focused on those
management and internal control areas considered most relevant to CTR
project implementation: (1) building a management structure, (2) risk
assessments, (3) performance measures, (4) program reviews, (5)
communications, and (6) project monitoring. The Congress also mandated
that GAO describe the status of DOD‘s implementation of legislative
mandates covering the CTR program.
What GAO Found:
Through the CTR program, DOD provides assistance to help the former
states of the Soviet Union secure and eliminate their weapons of mass
destruction. Since 2003, DOD has improved its management and internal
controls over the CTR program. Prior to 2003, DOD had problems managing
the program and ensuring that the program was meeting its objectives.
These inadequacies became apparent in 2003 following two project
failures in Russia that cost the CTR program almost $200 million,
including the never used liquid rocket fuel disposition facility.
Following these incidents, DOD implemented a more structured approach
to managing the CTR program. In July 2003, DOD filled vacancies in the
office responsible for managing the program, providing a level of
leadership and oversight that did not previously exist. Once in place
the new leadership made important improvements to the program‘s
internal controls in the areas of organizational structure, risk
assessments, performance measures, program reviews, and communication.
For example, DOD now assesses and balances risks with project
requirements and measures project performance at each phase. DOD also
conducts semi-annual meetings to review commitments and
responsibilities of CTR-recipient governments and to minimize risk.
Although enhancing its internal controls helps mitigate the risks that
stem from having to rely on the cooperation of CTR-recipient
governments, DOD can never fully eliminate the project risks associated
with recipient governments‘ cooperation. Furthermore, while DOD‘s
enhancements are an improvement over previous internal controls,
current mechanisms do not include a separate review of CTR projects
upon their completion. As such, DOD lacks a system for evaluating
projects upon their completion and applying lessons learned to future
projects.
Facility to Destroy Liquid Rocket Fuel Cost $95 Million but Was Never
Used:
[See PDF for image]
[End of figure]
What GAO Recommends:
GAO recommends that the Secretary of Defense conduct performance
reviews of CTR projects upon their completion. Such reviews would
provide a mechanism to document lessons learned and apply them to
future project planning and implementation. DOD concurred with our
recommendation.
www.gao.gov/cgi-bin/getrpt?GAO-05-329.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Joseph Christoff at (202)
512-8979 or christoffj@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DOD Has Improved Its Management and Internal Controls over the CTR
Program:
Conclusion:
Recommendation for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Two Project Failures Cost the CTR Program Nearly $200
Million:
Appendix II: Legislative Mandates Covering the CTR Program:
Appendix III: Scope and Methodology:
Appendix IV: Current CTR Program Areas:
Appendix V: DOD's Current Management and Internal Controls for the CTR
Program Compared with Internal Control Standards:
Appendix VI: Comments from the Department of Defense:
Appendix VII: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Internal Control Standards and Factors Compared with DOD
Internal Controls:
Figures:
Figure 1: DOD Management Structure for the CTR Program:
Figure 2: Russian SS-24 Missile Engine Undergoing Dismantlement:
Figure 3: CTR Program Legislative Mandates (Fiscal Years 1992-2004):
Figure 4: CTR Program Area Descriptions and Obligations as of April
2005:
Abbreviations:
AT&L: Office of the Under Secretary of Defense for Acquisition,
Technology, and Logistics:
CT: Cooperative Threat Reduction Directorate:
CTR: Cooperative Threat Reduction program:
DOD: Department of Defense:
DTRA: Defense Threat Reduction Agency:
GAO: Government Accountability Office:
IG: Inspector General:
JRIP: Joint Requirements and Implementation Plans:
MDA: Milestone Decision Authority:
TRSC: Threat Reduction Support Center:
Letter June 30, 2005:
The Honorable John Warner:
Chairman:
The Honorable Carl Levin:
Ranking Minority Member:
Committee on Armed Services:
United States Senate:
The Honorable Duncan Hunter:
Chairman:
The Honorable Ike Skelton:
Ranking Minority Member:
Committee on Armed Services:
House of Representatives:
Since 1992, Congress has authorized the Department of Defense (DOD) to
provide more than $5 billion for the Cooperative Threat Reduction (CTR)
program to help the former states of the Soviet Union[Footnote 1]
secure and eliminate their weapons of mass destruction and prevent
their proliferation. Through the CTR program, the United States has
supported activities such as eliminating nuclear missiles, building
storage facilities for nuclear materials, eliminating chemical weapons,
securing biological pathogens, and employing former weapons scientists.
Recent project failures in Russia, however, have raised congressional
concerns about the program's management. Specifically, from 1993
through 2003, DOD spent nearly $200 million to construct a liquid
rocket fuel disposition facility that was never used and to design a
solid rocket motor elimination facility that was never constructed. In
2003, as a result of these incidents, DOD began to revise its
management and internal controls over the CTR program. (For more
detailed information on these CTR project failures, see app. I.)
The Deputy Assistant to the Secretary of Defense for Chemical
Demilitarization and Threat Reduction within the Office of the Under
Secretary of Defense for Acquisition, Technology, and Logistics
(AT&L)[Footnote 2] is responsible for developing CTR implementation
plans and making sure that CTR contractual obligations are met.
Concurrently, the CTR Policy Office, within the Office of the Under
Secretary of Defense for Policy, is responsible for developing and
coordinating CTR policy guidance and defining CTR program objectives.
The Defense Threat Reduction Agency (DTRA) reports to the Deputy
Assistant to the Secretary of Defense for Chemical Demilitarization and
Threat Reduction and oversees the execution of CTR projects on a daily
basis.
Section 3611 of the National Defense Authorization Act for Fiscal Year
2004 mandates that GAO assess DOD internal controls for the CTR program
and their effect on the program's execution.[Footnote 3] The mandate
specifies that our analysis focus on controls intended to ensure that
projects are being executed consistent with the program's objectives.
In addressing the mandate, we evaluated DOD's management and internal
controls for implementing CTR projects since 2003 by using the
applicable control standards for the federal government.[Footnote 4] To
respond to the mandate, we identified those management and internal
control areas most relevant to CTR project implementation: (1) program
management, (2) risk assessments, (3) performance measurement, (4)
program reviews, (5) communications, and (6) project monitoring.
Congress also mandated that we describe the status of DOD's
implementation of legislative mandates covering the CTR program. (See
app. II for information on CTR legislative mandates.)
In reviewing DOD's management and internal controls for implementing
the CTR program, we collected and analyzed DOD documents and developed
a semi-structured interview guide and questioned 30 DOD officials
responsible for managing and implementing the CTR program. We met with
other DOD officials, reviewed DOD documents including DOD acquisition
management guidance, and analyzed legislation. In addition, we traveled
to Russia and Kazakhstan to observe CTR project implementation and to
obtain information from American, Russian, and Kazakhstani government
officials and contractor personnel. To determine the reliability of the
data we used in this report, we reviewed relevant agency documents and
obtained information from agency officials to ensure that the data used
are sufficiently reliable for our work. We performed our work from
April 2004 through May 2005 in accordance with generally accepted
government auditing standards. (See app. III for more details on our
scope and methodology.)
Results in Brief:
Since 2003, DOD has improved its management and internal controls over
the CTR program. Previously, DOD had problems managing the CTR program
and ensuring that CTR program objectives were being met. Following two
project failures in Russia, DOD implemented a series of new measures in
2003 that provided a more structured approach to managing the CTR
program. DOD's goal is to mitigate risks to an appropriate level.
Despite the introduction of new and revised management approaches and
controls, DOD cannot fully mitigate the risks involved in cooperating
with CTR recipient governments. In addition, DOD's current procedures
and controls do not include final reviews of CTR projects upon their
completion. Therefore, DOD has no systematic or formal mechanism to
document and apply the lessons learned from such evaluations to new and
ongoing projects.
To improve management of the CTR program, DOD has addressed five key
areas.
* Program management. DOD's original management plan for the CTR
program called for AT&L to oversee planning, issue written guidance on
how projects should be implemented, and develop processes to ensure
that projects were meeting objectives. However, DOD did not have
officials in key positions in this office from 1998 through 2003. CTR
policy and DTRA officials attempted to fill this void but lacked
expertise and training in acquisition and project management. In July
2003, following the heptyl and Votkinsk project failures, DOD filled
these vacancies within AT&L. AT&L officials now actively participate in
program risk assessments, performance measurement, ongoing program
reviews, and regular communication regarding details on project status.
* Risk assessments. DOD uses several new methods to assess and mitigate
the risks associated with CTR projects. DOD designates one official
with overall management responsibility to balance the requirements of
each project with potential risks. DOD divides CTR projects into three
phases and requires management approval that the project is on track to
meet its objectives before the project enters its next phase and
additional funds are obligated. DOD also instituted periodic meetings
with stakeholders[Footnote 5] to evaluate and minimize risk associated
with CTR projects. With these new methods in place, all stakeholders
are now cognizant of CTR project risks and managers are required to
develop concrete strategies for addressing identified risks.
* Performance measurement. DOD devised and implemented new written
guidelines on developing and reporting CTR project objectives,
schedules, and cost estimates. In a new training course required for
all CTR program and project managers, managers are instructed on
developing measures for how, when, in what sequence, and at what cost,
specific project tasks will be completed. According to CTR project
managers, the current guidance on performance measurement is clearer
and more consistent than in the past and helps with the review of
ongoing projects.
* Ongoing program reviews. DOD introduced a new process to more
systematically and consistently review CTR projects. In quarterly and
other meetings, a designated manager, in consultation with all
stakeholders, oversees the project's performance measures including
cost, schedule, and performance objectives, and determines whether the
project proceeds to its next phase or whether corrective actions need
to be taken. According to CTR managers, the new program review system
has resulted in more consistently conducted program evaluations that
provide management with significant project details not previously
included in program reviews.
* Communication. Communication among the DOD offices involved in the
CTR program is more structured. All stakeholders communicate project
issues and problems through daily email, weekly reports, and quarterly
meetings. Through ongoing program reviews and new reporting
requirements stakeholders and managers now have regular opportunities
to learn about project developments and provide input on project
implementation. DOD has also improved its external communications with
CTR-recipient countries by more clearly defining the responsibilities
and expectations of all parties, including the recipient countries
involved in each project. These controls provide assurance that each
party is held accountable for its responsibilities.
Despite the introduction of new and revised internal controls, DOD
continues to face the challenge of gaining the cooperation of CTR-
recipient governments to jointly implement projects and ensure that
assistance is used to meet program objectives. Successful projects
require signed agreements between DOD and CTR recipient countries, as
well as U.S. access to sites to ensure that program goals are being
achieved. However, reaching agreement on project issues and obtaining
necessary access can involve lengthy negotiations. For example, after
more than 10 years of discussion, Russia and DOD have yet to negotiate
an agreement that would allow U.S. personnel access to monitor the
loading of the CTR-funded fissile material storage facility at Mayak.
Such an agreement would assure DOD that the facility is being used as
intended.
DOD also lacks internal controls that would provide a system for
monitoring projects upon their completion and applying lessons learned
to future projects. According to internal control standards, monitoring
includes assessing both ongoing activities and separate evaluations of
completed activities and should assess the quality of performance over
time. By conducting final reviews of completed CTR projects and
addressing the findings of such reviews, DOD can further improve its
current and future management of the program.
To further improve DOD internal controls for the CTR program, we are
recommending that the Secretary of Defense conduct final reviews of CTR
projects at their completion to evaluate whether projects were
conducted in an efficient manner or were effectively meeting the
objectives of the program. Such reviews would provide a mechanism for
documenting lessons learned and applying them to future project
planning and implementation.
DOD concurred with our recommendation to conduct evaluations of CTR
projects upon their completion. DOD also provided technical comments
that we incorporated as appropriate.
Background:
Congress created the CTR program in 1991 to help the states of the
former Soviet Union secure and eliminate their weapons of mass
destruction and prevent their proliferation. Through the CTR program,
the United States has supported activities to eliminate nuclear
missiles, build a storage facility for nuclear materials, eliminate
chemical weapons, secure biological pathogens, and employ former
weapons scientists. As of January 2005, the CTR program has assisted in
the elimination of about 570 intercontinental ballistic missiles and
nearly 30 nuclear powered ballistic missile submarines. In 2004,
Congress authorized DOD to expand the scope of the CTR program to
countries outside the former Soviet Union. For example, beginning in
2005, CTR assistance will help Albania destroy its chemical weapons
stockpile.
Figure 1 shows the DOD management structure for the CTR program. Within
the Office of the Under Secretary of Defense for Policy, the CTR Policy
Office is responsible for developing and coordinating policy guidance,
defining program objectives for the CTR program, and negotiating
agreements with CTR recipients. The CTR Policy Office works with the
office of the Under Secretary of Defense for Acquisition, Technology,
and Logistics through the Deputy Assistant to the Secretary of Defense
for Chemical Demilitarization and Threat Reduction. DTRA reports to the
Assistant to the Secretary of Defense for Nuclear and Chemical and
Biological Defense Programs. The Deputy Assistant to the Secretary of
Defense for Chemical Demilitarization and Threat Reduction provides
strategic implementation guidance on and oversight of CTR projects, and
interacts daily with DTRA on CTR matters. Within DTRA, the Cooperative
Threat Reduction (CT) directorate manages the program's daily
operations. The directorate is organized into five program areas:
Biological Weapons Proliferation Prevention, Chemical Weapons
Elimination, Nuclear Weapons Safety and Security, Strategic Offensive
Arms Elimination, and Weapons of Mass Destruction (WMD) Proliferation
Prevention.[Footnote 6] (For a more detailed description of these
program areas, see app. IV.) The directorate is located at Ft. Belvoir,
Virginia, and several DTRA offices throughout the former Soviet
Unionprovide in-country support for CTR program
implementation.[Footnote 7]
Figure 1: DOD Management Structure for the CTR Program:
[See PDF for image]
[End of figure]
At the beginning of the program in 1992, DOD primarily purchased and
provided equipment such as cranes, cutting tools, and vehicles to
recipient countries. As the program matured, CTR assistance provided
more services, such as hiring U.S. contractors who helped recipient
countries dismantle nuclear delivery systems and missiles. Currently,
CTR provides most assistance to recipient countries through contracts
with American firms. DOD executes, manages, and reviews the contracts
according to DOD and federal acquisition requirements. Specifically, in
2001, the CTR program began using special contracts with prime
contractors who, with their teams of supporting subcontractors,
implement the majority of CTR projects in the recipient countries.
These five contractors are known as CTR Integrating
Contractors.[Footnote 8] DTRA has also contracted with the Science
Applications International Corporation's Threat Reduction Support
Center (TRSC). TRSC staff provide support to CTR program and project
managers in the areas of operations, logistics, engineering, financial,
and program management.
DOD Has Improved Its Management and Internal Controls over the CTR
Program:
Since 2003, DOD has improved its management and internal controls over
the CTR program. Prior to 2003, DOD's internal controls over the
program were limited and did not ensure that CTR program objectives
were being met. Following two project failures in Russia, DOD
implemented a series of new measures in 2003 that provided a more
structured approach to managing the CTR program. Most importantly, in
July 2003, DOD filled vacancies within AT&L, the office responsible for
ensuring that DTRA's implementation of CTR projects was meeting cost,
schedule, and performance goals. After DOD filled these positions, the
new leadership worked closely with DTRA officials to introduce
important enhancements to the program's internal controls. For example,
DOD adopted several new methods to assess and mitigate the risks
involved in cooperating with CTR-recipient governments. Although these
methods attempt to reduce risk to an acceptable level, DOD cannot fully
mitigate the risks involved in working jointly with CTR-recipient
governments. While DOD's enhancements are an improvement over the
previous management and internal controls for the program, CTR
procedures do not include final reviews of CTR projects upon their
completion. As such, DOD has no mechanism for assessing the success of
completed projects and applying lessons learned to future projects.
Improved Program Management and Internal Controls Allow for Improved
Implementation of CTR Program:
Beginning in 2003, DOD implemented several new and enhanced management
processes to allow program managers to better assess the progress of
CTR projects and address program implementation weaknesses to reduce
the risk of program failures. For example, DOD filled vacant AT&L
positions; developed specific guidance for project managers on
reporting objectives, schedules, and cost estimates; and improved
communication within the program and with recipient countries. (For a
comparison of DOD's CTR internal controls with selected control
standards for the federal government, see app. V.) DOD developed a
training course that all CTR project and program managers are required
to complete, which provides detailed instruction on incorporating the
new requirements of the internal control framework into all CTR
projects. According to 24 of the 30 CTR program, policy, and
acquisition officials responding to our structured interview, the new
framework has helped improve CTR project implementation. For example,
CTR officials stated that now the program management review system is
more rigorous and project managers know what is expected of them in
reporting on the cost, schedule, and performance of their projects.
Key Leadership and Oversight Vacancies Filled for CTR Program:
In July 2003, DOD filled AT&L vacancies, closing a critical gap in the
department's ability to ensure that the CTR program was meeting cost,
schedule, and performance goals. Previously, DOD had not been carrying
out its own management plans for ensuring that CTR projects were
meeting stated goals. Specifically, in May 1994, the Deputy Secretary
of Defense approved a plan to strengthen the implementation of CTR
projects. Under this plan, the CTR policy office was responsible for
negotiating agreements with recipient countries, establishing policy
guidance, working on the CTR budget, and notifying Congress of
developments in the program. After CTR policy approved a project and
signed an agreement to begin work, AT&L was responsible for developing
detailed implementation plans, monitoring ongoing work, and ensuring
that work was meeting cost, schedule, and performance goals. However,
DOD left several AT&L positions vacant until 2003, leaving a critical
gap in oversight over the CTR program. The CTR policy office began
managing daily CTR project activities to fill this leadership gap.
However, according to the director of the policy office, staff in that
office were not qualified to manage the activities of the program
because they were not familiar with DOD acquisition guidelines nor did
they have the technical expertise necessary to manage CTR programs.
According to a 2004 DOD Inspector General (IG) report on the management
of the CTR program, if the AT&L positions had been filled, those
officials might have identified some of the risks involved in the two
failed CTR projects that cost DOD nearly $200 million.
Since the AT&L positions were filled in July 2003, the office now
participates in CTR program planning and review, overseeing program
review meetings, and providing guidance on issues such as performance
measurement and reporting requirements. The Deputy Assistant Secretary
of Defense for Chemical Demilitarization and Threat Reduction attends
informal monthly meetings with CTR program managers to be updated on
the status of projects and other management issues. He also serves as
the program reviewer for several CTR projects, making him responsible
for overseeing the cost, schedule, and performance of each of those
projects and approving them at the end of each project phase. For
example, in July 2004, he approved a biological weapons proliferation
prevention project's acquisition program baseline and authorized the
program manager to move the project into the demonstration phase. CTR
officials stated that it is now clear who they need to report to and
when.
DOD Uses Several New Methods to Assess CTR Project Risk:
DOD uses several new methods to assess and mitigate risks associated
with CTR projects. DOD identifies a senior official responsible for
ensuring the potential risks to meeting objectives are evaluated for
each project, requires stakeholders on each project to meet regularly
to conduct specific risk management activities, and implements each
project in three phases. According to DOD's risk management guide, risk
is defined as a measure of the potential inability of a program to
achieve its overall program objectives within defined cost, schedule,
and technical constraints.[Footnote 9]
DOD's approach to assessing program risks was limited prior to 2003. In
September 1996, we reported that the CTR multiyear plan did not
indicate whether program officials had omitted risk and contingencies
from project cost estimates.[Footnote 10] In addition, a 2003 DOD IG
report found that DOD did not identify risks or have adequate controls
in place to mitigate risk when managing projects.[Footnote 11]
According to a CTR official, CTR program and project managers
periodically included risk assessments in planning their projects, but
did not include actions to control the risks identified if problems
occurred. The DOD IG reported that the CTR program management's failure
to fully assess project risks contributed to DOD spending nearly $200
million on projects in Russia to construct a liquid rocket fuel
disposition facility that was never utilized and to design a solid
rocket motor elimination facility that was never constructed.
In an effort to improve assessments of the risks associated with CTR
projects, DOD began designating an official, known as the Milestone
Decision Authority (MDA), to be responsible for ensuring that project
managers, with assistance from project stakeholders, assess the risks
to meeting project objectives and formulate plans to mitigate these
risks. MDAs are assigned to projects based on several factors,
including the project's risk and expected cost. According to an AT&L
official, the Deputy Assistant to the Secretary of Defense for Chemical
Demilitarization and Threat Reduction is usually assigned as the MDA
for high-cost or high-risk projects. For projects with less risk or
expense, the MDA is usually the director of the DTRA/CT directorate.
MDAs review the risks identified by the project managers and evaluate
the plans they have developed to mitigate these risks.
In addition, DOD instituted periodic stakeholders meetings to assess
and minimize risks associated with CTR projects and to discuss major
project issues and milestones. In these meetings, project managers
present assessments of potential risks that could impact their ability
to meet project objectives. For example, a risk identified for the
Russian SS-24 missile elimination project was that political or
economic developments in Russia might unexpectedly affect the project's
costs. After the project managers present their assessments, the
stakeholders provide input to address these risks and consider
additional problems that may arise during project implementation.
According to CTR management officials, this team approach to risk
assessment ensures consensus early in each phase of the project. It has
resulted in more informed decision making because stakeholders meet
regularly to receive updates on project status and make decisions on
the next phase of project implementation based on the facts presented
during those meetings. Of the 30 DOD and CTR officials we interviewed
using our structured interview guide, 9 said that this new process of
stakeholder involvement was one of the most important new internal
controls for the CTR program.[Footnote 12]
Furthermore, DOD now uses a new phased-contract approach that divides
each CTR project into three phases. These phases can vary according to
project, but usually include phases covering project development,
project execution, and project maintenance, according to a CTR
official. This approach helps to minimize risk by allowing managers to
make the appropriate changes, delay, or stop a project if a problem
occurs. For example, in 2003, in the development phase of a Ukrainian
SS-24 missile elimination project, DOD decided not to proceed with the
project because the risks associated with the missile destruction
method that the Ukrainians wanted to use were too high. Project
managers are required to develop exit criteria for each project phase
that clearly state under what conditions the project will be permitted
to move into the next phase and under what conditions DOD will stop the
project. For example, for a CTR project tasked with eliminating
Russia's SS-25 missiles, one of the exit criteria for moving into the
project's maintenance phase is that DOD complete negotiations on the
contract to maintain the missile elimination facility that is being
constructed.
DOD Has New Guidelines for Reporting Project Performance:
In 2003, DOD devised and implemented new guidelines that provide CTR
project managers with written instructions on developing and reporting
project objectives, schedules, and cost estimates. According to the
internal control guidelines for the federal government, it is important
for an organization to establish measures to gauge its performance on
critical activities and determine if the organization is meeting its
objectives. CTR program area and project managers we interviewed stated
that prior to 2003 there were no established procedures for developing
performance measures, evaluating project performance, or reporting
(either orally or in writing) on project implementation to management.
In addition, project plans were not comprehensive and lacked
established baselines against which to measure performance.
According to CTR project managers, the current guidance on performance
measurement is clearer and more consistent than in the past. For
example, in a training course required for all CTR program and project
managers, project managers are instructed on developing measures for
how, when, in what sequence, and at what cost specific project tasks
will be completed. Our fieldwork included a site visit to a CTR project
in Russia that had developed such measures. One measure used to gauge
performance on that project is whether the elimination of Russian SS-24
missiles complies with arms control treaty requirements. For each
measure, project managers develop objectives - the indicator's desired
outcome - and thresholds - the minimum acceptable performance for that
measure. For example, one objective for the SS-24 missile elimination
project is to eliminate Russia's SS-24 missiles by March 2008. However,
if the missiles cannot be eliminated by then, they must be eliminated
by the threshold date of August 2008. (Figure 2 shows the elimination
of an SS-24 engine.)
Figure 2: Russian SS-24 Missile Engine Undergoing Dismantlement:
[See PDF for image]
[End of figure]
If the threshold is not met at the end of a particular project phase,
the project manager and DOD management officials may consider stopping
the project. When an indicator is in danger of not being met, the
project manager is required to submit a warning report to the project's
MDA to ensure that management is aware of potential delays and that the
project manager is addressing the problem. If the indicator is not met,
DOD management officials may stop the project until a plan is in place
to bring the indicator up to the threshold level.
DOD Has More Systematic and Consistent Tools to Review Programs:
In 2003, DOD introduced a new process to review projects and programs
to provide a more systematic and consistent structure to management's
review of CTR projects. According to the internal control guidelines
for the federal government, program reviews are important for program
management because they provide comparisons of actual performance to
planned or expected results and help management assess its programs.
Program reviews lacked the detail that allowed senior management to
evaluate projects and risks consistently. However, according to CTR
program managers we interviewed, before 2003 there was no standardized
guidance to assist program managers on developing program reviews or
implementing their programs. For example, CTR program area and project
managers did not receive any guidance on how to report on the daily
management of program operations or on the type of information that
status reports should include.
Under the new program review system, the designated MDA conducts
reviews of a project's cost, schedule, and performance objectives.
During program reviews, which take place periodically throughout the
course of a project, project managers report to their MDAs on the
status of their projects and whether the objectives are being met. In
addition, these review meetings are more detailed than they were before
the new system was in place. For example, a project review in 2004 for
a CTR project tasked with installing nuclear detection devices in
Uzbekistan included details on the project's schedule over the next 3
years, with specific dates for completion of certain milestones. It
also included a detailed breakdown of funding for the project over the
next 3 years and a thorough discussion of project risks. The
information was not included in the project's 2003 review. According to
several CTR project managers, the new program review system has
resulted in more consistently conducted project evaluations. Of the 30
DOD officials we interviewed, 19 said the program review process,
conducted by the MDA, was one of the most important new internal
controls for the CTR program.[Footnote 13] They reported that, with the
introduction of the MDA, program reviews are occurring at the same
intervals for each project and that project managers report cost,
schedule, and performance data in the same format to their MDAs during
the reviews. Through the course of work we reviewed copies of various
MDA project review documents.
Communication Is More Structured:
According to DOD officials, communication within the CT directorate and
among the DOD offices involved in the CTR program, has improved with
the introduction of new internal controls. DOD also has improved its
external communications with CTR-recipient countries. Internal control
guidelines for the federal government state that communication
mechanisms should exist within an organization to allow the easy flow
of information down, across, and up the organization. However, before
2003, internal communications within the CTR program office were not
clear, according to DOD officials. For example, all CTR stakeholders
were not present during project development meetings nor were they
involved in early decision making about project risks. Communications
between DOD and CTR recipient governments also were not clear. DOD
assumed, without getting written documentation that CTR recipient
countries would carry out the responsibilities and commitments to which
they agreed.
Since 2003, communication among the DOD offices working on the CTR
program has improved. Stakeholders on specific projects meet more
frequently now than in the past to discuss project issues and problems.
Project managers involve stakeholders in the earliest stages of project
development on through to the final phase of project completion to
assure that stakeholders and managers have regular opportunities to
learn about project developments and provide input on project
implementation. This system has now been institutionalized and all CTR
project managers are instructed in a new training course to convene
meetings with stakeholders throughout the life of their projects. In
addition, new reporting requirements help ensure that all stakeholders
are informed of project developments. All of the 30 DOD officials we
interviewed said that they are required to report on the cost,
schedule, and performance of their programs and projects periodically,
including daily, weekly, monthly, and quarterly. For example, DOD now
requires program managers to submit monthly project status reports to
ensure that potential problems are documented and stakeholders are
informed of them. In addition, 28 of the 30 DOD officials in our
structured interview reported that the amount of communication within
the CT directorate allows them to effectively implement their projects.
Project managers are in frequent contact with contractors implementing
projects in recipient countries. We observed a meeting in Russia
between a CTR project manager and the Russian contractors implementing
the project he manages. During the meeting, they negotiated revisions
to a new contract and discussed the project's status. The project
manager makes similar trips at least once a month to the project site
to oversee progress and meet with the contractors. Other project
managers we interviewed in Russia and in the U.S. stated that they hold
weekly phone conferences with contractors, exchange emails, and make
regular visits to project sites.
Contracting officials in Russia stated that they hold weekly telephone
conferences with their CTR project managers and contact them regularly
when project implementation issues arise. We observed such a weekly
telephone communication during our visit to the International Science
and Technology Center in Moscow. Contractors also submit monthly
written reports. Project managers also are in daily contact with their
program managers and CT directorate management. According to a CTR
official, at quarterly program review meetings, program and project
managers present detailed information, both orally and in writing, on
the status of their projects to all involved stakeholders.
DOD has also improved its external communications with CTR-recipient
countries. DOD and recipient government officials now consistently
share more detailed information on project developments and issues of
concern. CTR management officials and program and project managers are
in frequent contact with their recipient government counterparts
throughout project implementation. In 2004 CTR teams made 165 trips,
compared with 70 trips in fiscal year 2001, to meet recipient
government officials and improve their monitoring of CTR projects.
Russian government officials working on CTR projects stated that they
communicate with CTR officials continually and meet regularly with the
director of the CT directorate. They also hold weekly teleconferences
with project managers, and project managers visit project sites
regularly. While traveling with CTR project managers in Russia and
Kazakhstan, we observed extensive discussions of important issues
during site visits and meetings with contractors and recipient
government officials.
Furthermore, DOD has introduced and updated its controls to ensure that
commitments made by the CTR program and recipient governments are
regularly documented and discussed. These controls also are a means to
ensure that each party is held accountable for its responsibilities. In
2003, DOD began using Joint Requirements and Implementation Plans
(JRIP) to document the commitments and responsibilities agreed to by
each party involved in project implementation. For example, a
requirements plan for a CTR project tasked with eliminating a specific
type of Russian nuclear missile states that one of DOD's
responsibilities in implementing the project is to design and construct
storage facilities for the missiles to be eliminated. One of the
Russian government's responsibilities on the same project is to provide
DOD with a schedule for the delivery of the missiles to the proper
facility for elimination. If either party fails to meet its obligations
as articulated in the document, the other party can stop progress on
the project. For example, DOD officials halted new construction from
March to June 2004 at the CTR-funded chemical weapons destruction
facility at Shchuch'ye until the Russian government stopped insisting
on unnecessary design changes for the construction of a boiler house on
the site. To further enhance communication between CTR program
officials and CTR recipient countries, DOD also holds biannual meetings
where officials from both sides meet to review and discuss project
implementation and revise plans when necessary. According to CTR
management officials and JRIP documents we reviewed, these meetings
provide a regular forum for discussion that was not previously
available and have improved communication between DOD officials and CTR-
recipient governments.
Inherent Risks Remain in Working with Recipient Governments:
DOD faces significant challenges in collaborating with CTR-recipient
governments to jointly implement projects and ensure that assistance is
used to meet program objectives. Successful implementation of CTR
projects requires the cooperation of recipient governments, but DOD
cannot fully mitigate the risks involved in working jointly with these
governments. First, working with CTR-recipient governments often
involves lengthy negotiations to reach agreements on various issues
throughout a project's implementation. This can delay U.S. funded
efforts to help secure or dismantle weapons of mass destruction by
months or years. Second, risks to the project can increase when
implementation begins before the necessary agreements are in place.
Third, after agreements are reached and implementation is under way,
additional risk is introduced by the control environment[Footnote 14]
within the recipient governments. For instance, if a recipient
government has a poor control environment risk increases that the
agreed to objectives and conditions will not be met.
In cooperating with CTR-recipient governments, DOD must negotiate a
variety of agreements that can require lengthy negotiations. The
highest level of agreements, called umbrella agreements, provide an
overall legal framework for U.S. and CTR-recipient countries'
cooperation in implementing projects.[Footnote 15] Implementing
agreements outline the types and amounts of assistance to be provided
for specific CTR projects. For instance, projects to eliminate
strategic nuclear arms, including strategic bombers, missiles, and
related equipment are conducted under the Strategic Nuclear Arms
Elimination Implementing Agreement signed by DOD and the Ukrainian
Ministry of Defense in December 1993.[Footnote 16] Agreement amendments
update the annual amount of funding that CTR will provide for a
specific project within a recipient country. For example, the December
2004 agreement amendment for biological weapons proliferation projects
with the government of Kazakhstan provides for $30 million in CTR
funding during fiscal years 2004 and 2005. The recipient governments
must sign agreements or agreement amendments before projects can begin
and funding can be provided or increased, but this may take time and
delay projects, according to CTR officials. According to a CTR program
area manager, the Russian government took more than 18 months to sign
an implementing agreement for nuclear weapons transportation and
security projects because it did not want to reveal the location of
nuclear weapons storage sites that the government planned to close. In
2004, the government of Kazakhstan took more than 6 months to sign the
annual agreement amendment for biological weapons proliferation
projects. According to CTR contractors and officials at Kazakhstani
biological research facilities, the government's delay slowed efforts
to improve the security and safety of biological pathogens at their
institutes. For CTR biological weapons proliferation prevention
projects in Russia, however, DOD has no implementing agreement. These
projects are implemented through the International Science and
Technology Center in Moscow.[Footnote 17] Until it can conclude a
biological threat reduction implementing agreement with the Russian
government, DOD has limited the types of projects it initiates in
Russia.
Risks to CTR projects can increase when DOD begins implementation
before the necessary agreements are in place with CTR recipient
governments. After more than 10 years, Russia and DOD have yet to
negotiate a transparency agreement that would allow U.S. personnel
access to the CTR-funded fissile material storage facility at Mayak to
ensure that it is being used as intended. DOD designed and built the
facility to provide centralized, safe, secure, and ecologically sound
storage for weapons-grade fissile material from dismantled Russian
nuclear warheads. In December 2003, DOD completed the CTR-funded Mayak
facility at a cost of about $335 million,[Footnote 18] and the Russian
government assumed full responsibility for its operation and
maintenance. Although the Russian government has pledged its commitment
to transparency, it has not signed an agreement with DOD. Therefore,
the United States has no reasonable assurance that Russia will only use
the facility to store materials from dismantled nuclear weapons and not
reuse the materials. According to CTR program officials, the Russian
government may soon begin storing nuclear materials at the Mayak
facility without an agreement in place. We first raised concerns about
the lack of a transparency agreement for the Mayak facility in
1994.[Footnote 19] Later, in April 1999, we voiced concerns that the
United States still lacked clear assurances that Russia would use the
Mayak facility in a manner consistent with all U.S. national security
objectives for the project.[Footnote 20]
Furthermore, two CTR project failures in Russia illustrate the
consequences of DOD not having the necessary agreements in place (see
app. I for additional information). In the early 1990s, DOD agreed to
assist Russia in constructing a facility to dispose of liquid missile
propellant, known as heptyl, which had been drained from
intercontinental and submarine-launched ballistic missiles. DOD spent
nearly $95 million over 10 years to build a facility to destroy the
heptyl, only to learn in January 2002 that Russia had diverted the
heptyl to its commercial space program, rather than storing it for
eventual destruction. As a result, the facility was never used. The DOD
IG reported in 2002 that CTR program officials negotiated a weak
implementing agreement with the Russian government. Specifically, the
agreement did not require the Russian government to provide the heptyl
or provide access for CTR program officials to inspect the heptyl
storage facilities and verify the quantities present.[Footnote 21]
Similarly, DOD had agreed in the early 1990s to build a facility in
Russia to dispose of solid rocket motors from dismantled missiles. DOD
spent almost $100 million over nearly 10 years to design the facility,
despite the concerns of local residents about the possible
environmental impact. In January 2003, Russian officials notified DOD
that the regional government had denied the land allocation permit
necessary to begin construction due to the opposition from local
residents. As a result, DOD never began construction on the facility.
The DOD IG found that the implementing agreement for the design of the
solid rocket motor elimination facility at Votkinsk failed to specify
Russian responsibilities for the project. Primarily, the Russian
government was to obtain the necessary land allocation permits. CTR
officials accepted in good faith that Russia would help implement
program objectives and therefore assumed that they did not need to
document the Russian government's responsibilities. In addition,
despite local protests against construction of the facility from the
beginning of the project, DOD project managers did not identify land
allocation as a potential risk until April 2002.[Footnote 22]
Even after DOD concludes appropriate agreements, however, risks still
may exist due to the control environment of the recipient governments.
For instance, if a recipient government has a poor control environment
risk increases that the agreed to objectives and conditions will not be
met. A good control environment requires that an organization's
structure clearly defines key areas of authority and responsibility.
When the Russian government reorganized in early 2004, it was uncertain
which agencies and officials were in charge of working with DOD. While
the names of some of the agencies had merely changed, other agencies
were subsumed into larger organizations or completely dissolved.
According to CTR program officials, the reorganization had a
significant impact on program implementation. For example, the CTR
Policy Office is renegotiating its implementing agreements to reflect
the new Russian government entities. CTR projects also experienced
delays when the Russian government reorganized the committee that
granted tax exemptions and resolved customs issues for all CTR
assistance entering Russia. Work on the CTR-funded chemical weapons
destruction facility in Russia was delayed until needed equipment was
cleared through customs. Furthermore, CTR recipient governments may not
provide adequate access to project sites or may pursue priorities that
compete with CTR program objectives. DOD's inability to gain access to
all sites where CTR assistance is provided has been an issue since the
CTR program began in 1992. The U.S. government has been concerned with
its ability to examine the use of its CTR-provided assistance, while
CTR-recipient countries have security concerns regarding U.S. access to
sensitive sites.[Footnote 23] For example, as we reported in March
2003, DOD had made only limited progress installing security upgrades
at Russian nuclear weapons storage sites and former biological weapons
facilities because Russia would not provide DOD access to several
sites.[Footnote 24] Since March 2003, Russia has granted DOD access to
some nuclear weapon storage sites, and continues to restrict access to
some former biological weapons facilities.
DOD Does Not Have a Mechanism to Review CTR Projects Once They Are
Completed:
While CTR program officials monitor the progress of ongoing projects,
DOD has no mechanism to monitor and evaluate the results of completed
projects in relation to their meeting program objectives. According to
internal control standards, monitoring should assess the quality of
project performance over time. Conducting program evaluations, such as
reviewing completed CTR projects, may be warranted after major changes
in management plans. DOD does not conduct final evaluations of
completed CTR projects and currently has no mechanism to document
lessons learned and apply them to future project planning and
implementation. At its inception, the CTR program primarily provided
equipment to recipient countries, but now the vast majority of
assistance is provided through contracted services. Although the
program has shifted to funding costly, complex, and sometimes high-risk
projects that can last for many years, DOD has not expanded the scope
of its project monitoring process to include evaluations of the
efficiency and effectiveness of CTR projects upon their completion.
In June 2001, we recommended that DOD conduct such evaluations to
improve DOD's overall program oversight. In response, DOD agreed to
periodically assess the efficiency and effectiveness of CTR assistance,
including contracted services. However, DOD lacks a final review
process to assess the efficiency and effectiveness of completed CTR
projects. As of June 2005, DOD had completed 77 projects, but program
officials did not evaluate and record what went well during a project's
implementation and what could have been improved to better meet program
objectives. While CTR officials discuss ongoing individual projects
performance through the MDA process, senior CTR management officials
acknowledged that projects are not evaluated upon their completion and
such information is not shared program wide in a systematic manner. As
such, it is difficult to apply lessons learned to future CTR projects
as they are being planned and implemented and avoid past mistakes.
Officials stated that conducting final evaluations could further
improve their management of the CTR program,especially as the program
expands into countries outside the former Soviet Union. Since DOD does
not assess the efficiency and effectiveness of projects as they are
completed, it cannot apply the lessons learned from such evaluations to
new and ongoing projects in a systematic way.
Conclusion:
Since 1992, CTR assistance has helped the states of the former Soviet
Union eliminate and protect their weapons of mass destruction. Although
the CTR program has helped reduce the threat that these weapons could
be stolen or misused, incidents such as the heptyl disposition and
solid rocket motor elimination projects demonstrated significant
problems with DOD's program management. In the aftermath of these
incidents, DOD has worked to revamp its CTR program management to
achieve greater assurance that projects are implemented according to
program objectives. By standardizing its management approach and
applying it consistently across all CTR program areas, DOD is improving
its management of the CTR program. DOD has greater assurance that all
stakeholders, including recipient governments, are involved in project
implementation. CTR program and project managers have clearer guidance
on how to conduct their work and report on it. Furthermore, DOD has
made progress in more clearly articulating and documenting its
cooperative arrangements with CTR recipient countries, as well as
holding recipient governments more accountable for implementing the CTR
projects in their respective countries.
These improved controls cannot eliminate the risks inherent in the
program, but the goal is to mitigate risk to an appropriate level given
the circumstances. Most significantly, the success of the CTR program
requires the cooperation of recipient governments. Good internal
controls help mitigate the risks from having to rely on recipient
governments to sign agreements, provide access, and support project
implementation. Still, governments can change their project goals, deny
access to U.S. contractors and officials, or withhold permits to allow
work to proceed. DOD's more robust internal controls have helped
minimize the impact of these actions, but they cannot guarantee a
project's success. The U.S. government remains concerned about its
ability to determine how CTR-provided assistance is being used, while
CTR recipient countries continue to have security concerns regarding
U.S. access to their sensitive facilities and sites.
In addition, while DOD has made progress over the past 2 years in
improving its management of the CTR program, it still does not review
the overall performance of projects upon their completion. As projects
are completed, assessing and documenting lessons learned will allow DOD
to further improve CTR project implementation. As the CTR program
completes more projects and the program begins to expand beyond the
former Soviet Union, such a mechanism will become more important to
overall program management.
Recommendation for Executive Action:
We recommend that the Secretary of Defense conduct performance reviews
upon the completion of CTR projects. Such reviews would provide a
mechanism for documenting lessons learned and applying them to future
project planning and implementation.
Agency Comments and Our Evaluation:
DOD provided comments on a draft of this report, which are reproduced
in appendix VI. DOD concurred with our recommendation that reviews of
completed CTR projects should be conducted to document and apply
lessons learned. DOD also provided technical comments, which we have
incorporated where appropriate.
We are providing copies of this report to the Secretary of Defense and
other interested congressional committees. We will also make copies
available to others upon request. In addition, this report will be
available on the GAO Web site at [Hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-8979 or [Hyperlink, christoffj@gao.gov].
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who
made major contributions to this report are listed in appendix VII.
Signed by:
Joseph A. Christoff, Director:
International Affairs and Trade:
[End of section]
Appendixes:
Appendix I: Two Project Failures Cost the CTR Program Nearly $200
Million:
By 2003, two CTR program project failures caused DOD to reassess its
management of the program. In the early 1990s, DOD agreed to assist
Russia in constructing a facility to dispose of liquid missile
propellant, known as heptyl, and build a solid rocket motor disposition
facility. However, DOD terminated these projects after spending nearly
$200 million over almost a decade.
In the case of the heptyl disposition facility, DOD spent more than $95
million over 10 years on the facility at Krasnoyarsk, Russia, that was
never used. In 1993, the Russian government asked for CTR assistance to
dispose of heptyl from intercontinental and submarine-launched
ballistic missiles that were being destroyed in compliance with arms
control agreements.[Footnote 25] At the time, Russian government
officials claimed that existing heptyl storage facilities were full and
that they needed a way to dispose of the propellant, according to DOD
officials. DOD officials also stated that Russian officials had told
them that the heptyl could not be used for the Russian commercial space
program. However, when CTR officials were ready to test the almost
completed facility in January 2002, officials from the Russian Aviation
and Space Agency revealed that nearly all of the heptyl had been
diverted to the commercial space program. In February 2003, the Deputy
Secretary of Defense approved the dismantlement and salvage of the no-
longer needed heptyl disposition facility.
According to the DOD IG, a variety of inadequate management controls
contributed to the heptyl project failure.[Footnote 26] The IG reported
that AT&L was not assuming its role in managing the CTR program by
providing input and direction for projects. Rather, the CTR Policy
Office, which had little experience in following DOD acquisition
guidelines, establishing milestones, and identifying risks, was
managing daily CTR project activities. Because AT&L was not performing
adequate oversight of the program, CTR program officials negotiated an
implementing agreement[Footnote 27] without specific programmatic
commitments from the Russian government and did not thoroughly identify
the risks associated with eliminating the heptyl. Specifically, the
agreement did not require the Russian government to provide the heptyl
or provide access for CTR program officials to inspect the heptyl
storage facilities and verify the quantities present. CTR officials
accepted in good faith that Russia would provide the heptyl and
therefore assumed that they did not need to document or oversee the
Russian government's responsibilities. In assessing the risks of the
heptyl project, CTR project officials failed to identify the
possibility that the Russian government would use the heptyl for other
purposes and therefore developed no mitigation plan.
A second project failed in January 2003. After spending almost 10 years
to design the facility at Votkinsk to destroy solid rocket motors, CTR
program officials ended the project at a cost of almost $100 million.
In the early 1990s, Russia had requested CTR assistance to destroy
motors from dismantled missiles in compliance with an arms control
agreement. Originally, the facility was to be located at Perm, but
pending construction of the facility generated environmental opposition
from local residents. The facility was thus moved to Votkinsk in
February 1998, where local residents concerned with the environmental
impact of the facility also began protests. Still, CTR program
officials continued with the design of the facility, remaining
optimistic that the regional government would issue the required
permits regardless of opposition. Officials from the Russian Aviation
and Space Agency told CTR program officials in July 2002 that land for
the facility would be allocated no later than September 2002. In a
January 2003 letter, however, Russian officials notified DOD that the
regional government had denied the land allocation permit due to the
opposition from local residents.
Inadequate management practices also contributed to the failure of the
solid rocket motor disposition project at Votkinsk. As with the failed
heptyl project, the DOD IG reported that AT&L did not assume its
management role in overseeing the CTR program.[Footnote 28] The CTR
Policy Office was managing daily CTR project activities. The
implementing agreement for the Votkinsk project failed to specify
Russian responsibilities, such as obtaining the necessary land
allocation permits. In addition, despite the local environmental
protests against construction of the facility from the beginning,
project managers did not identify land allocation as a risk until April
2002. Furthermore, the contracting processes that were in place
contained no mechanism to terminate the project when costs increased
and the schedule was delayed. DTRA awarded the project contract for the
complete design and construction of the facility rather than
contracting in phases so that possible CTR program losses could be
minimized.
[End of section]
Appendix II: Legislative Mandates Covering the CTR Program:
As required by section 3611 of the National Defense Authorization Act
for Fiscal Year 2004, we reviewed the status of DOD's implementation of
legislative mandates covering the CTR program. Since 1992, Congress has
passed 25 pieces of legislation that guide CTR project activities.
Specifically, Congress has established a series of (1) requirements
that must be met before DOD can fund CTR projects, (2) conditions on
CTR expenditures, and (3) reporting requirements on the CTR program and
project implementation. Figure 3 illustrates the types of congressional
legislation covering the CTR program from fiscal year 1992 to 2004 and
includes those legislative requirements that have lapsed. Over the
years, DOD has mostly complied with these requirements, except for
several occasions when it was late in providing required reports to
Congress. Legislation has recently been proposed that would repeal some
DOD requirements.
Congress has established a variety of requirements that must be met
before DOD can fund CTR projects. For example, in establishing the CTR
program in 1991, Congress required that CTR assistance provided to the
countries of the former Soviet Union could not be expended until the
President certified to Congress that the recipient governments were
committed to reducing their weapons arsenals.[Footnote 29] According to
CTR officials, verifying CTR program compliance with legislation can be
a time-consuming process and may delay the implementation of projects,
but they cannot spend CTR funds unless all legislative conditions are
met. DOD officials involved with managing the CTR program recognize
that Congress is exercising its oversight responsibilities over the CTR
program.
Congress has also placed limits or conditions on how DOD can spend CTR
money. For instance, in Congress placed conditions on CTR money to
prohibit spending in certain areas, such as conventional weapons
destruction[Footnote 30] and housing for retired or current members of
CTR-recipient countries' military forces.[Footnote 31] Also in 2000,
Congress halted CTR funding for construction of the Russian chemical
weapons destruction facility at Shchuch'ye[Footnote 32] until fiscal
year 2004 when it granted a waiver.[Footnote 33]
Congress also requires DOD to submit reports on overall program
implementation, as well as specific projects. Since the beginning of
the CTR program, DOD has mostly complied with its congressional
reporting requirements. However, as we previously reported, from 1994
through 1999 DOD was late in providing its annual report, which
accounts for CTR assistance.[Footnote 34] Specifically, DOD was 16
months late in submitting its report for 1997 and more than 10 months
late in submitting its report for 1998. Beginning in fiscal year 2001,
the reporting requirement to account for CTR assistance became part of
the annual CTR report.[Footnote 35] For fiscal years 2002 through 2004,
DOD provided its annual CTR report to Congress late.[Footnote 36]
However, DOD provided its annual report to Congress for fiscal years
2005 and 2006 mostly on time.
Recently, some members of Congress have introduced bills that may
lesson the legislative burden on the CTR program. In February 2005,
Senator Lugar introduced the Nunn-Lugar Cooperative Threat Reduction
Act of 2005.[Footnote 37] The bill, among other actions, would repeal
some of the restrictions that Congress had previously placed on the CTR
program. If enacted the bill would remove (1) a Presidential
certification[Footnote 38] requirement for all CTR recipient countries
to receive CTR assistance and (2) the funding constraints placed on the
construction of the CTR- funded chemical weapons destruction facility
in Russia. In February 2005, members of the House of Representative
introduced the Omnibus Nonproliferation and Anti-nuclear Terrorism Act
of 2005.[Footnote 39] This bill also includes a provision for the
repeal of the same restrictions outlined in the bill introduced by
Senator Lugar.
Figure 3: CTR Program Legislative Mandates (Fiscal Years 1992-2004):
[See PDF for image]
[End of figure]
[End of section]
Appendix III: Scope and Methodology:
To assess DOD's management and internal controls over the CTR program,
we collected and analyzed DOD documents, including CTR project plans,
briefings, annual reports, and milestone decision authority
memorandums. We also obtained and analyzed all legislation passed since
1992 that covers the CTR program. We applied the internal standards as
described in GAO's Standards for Internal Control in the Federal
Government.[Footnote 40] We focused on those controls most relevant to
the CTR program, including organizational structure, risk assessments,
performance measures, program reviews, communications, and monitoring
of projects. We also reviewed DOD acquisition management guidance as
contained in the Defense Threat Reduction Agency's Instruction 5000.01
for our assessment of CTR management controls.[Footnote 41] Using the
federal government standards and DOD's guidance, we developed and
tested a semi-structured interview guide that included questions
regarding DOD's internal controls for the CTR program. We included
steps in the development and administration of the semi-structured
interview guide to minimize errors resulting from the respondents'
interpretation of the questions or from differences in information
available to respondents answering the questions. We pretested the
instrument with three DOD officials. In addition, an internal survey
specialist reviewed our semi-structured interview guide. We modified
the interview guide to reflect the questions and comments from the
pretests and internal review. We used the semi-structured interview
guide to interview 30 DOD officials responsible for managing and
implementing the CTR program. We also held meetings with 17 other
officials. Specifically, we met with officials from the CTR Policy
Office, AT&L, and DTRA's Business and Cooperative Threat Reduction (CT)
directorates. Within CT, we obtained information from the director,
deputy director, program and project managers from all five program
areas,[Footnote 42] and officials from the Program Integration office.
In addition, we met with officials from DTRA offices in Moscow and
Almaty and the Threat Reduction Support Center in Springfield,
Virginia. We traveled to the Russian Federation to observe CTR projects
involving strategic offensive arms elimination and biological weapons
proliferation prevention. We met with Russian officials at the Federal
Space Agency, the Federal Agency for Industry, and the Federal Atomic
Energy Agency. We also visited the Republic of Kazakhstan to observe
CTR-funded projects involving biological weapons proliferation
prevention. While in Russia and Kazakhstan, we met with representatives
from all five CTR Integrating Contractors[Footnote 43] to obtain
information on their roles in implementing CTR projects. We also
reviewed our prior work on the CTR program.
Although information about funding for the CTR program and the
program's accomplishments is used for background purposes only, we
assessed the reliability of these data by reviewing relevant agency
documents and obtaining information from agency officials. We
determined that the data used were sufficiently reliable for the
purposes of this report.
We performed our work from April 2004 through May 2005 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix IV: Current CTR Program Areas:
Since 1992, Congress has authorized DOD to provide more than $5 billion
for the CTR program to help the former states of the Soviet Union,
including Russia, Ukraine, Belarus, Kazakhstan, Uzbekistan, Azerbaijan,
Moldova, and Georgia, secure and eliminate their weapons of mass
destruction and prevent their proliferation. As of April 2005, DOD has
obligated about $4.5 billion in support of the CTR program. Of this
obligated amount, about $2.7 billion funds projects are being
implemented under CTR's five program areas of biological weapons
proliferation prevention, chemical weapons elimination, nuclear weapons
safety and security, strategic offensive arms elimination, and weapon
of mass destruction proliferation prevention initiative, as shown in
figure 4. The remaining obligations cover completed CTR projects or
other program support areas.[Footnote 44]
Figure 4: CTR Program Area Descriptions and Obligations as of April
2005:
[See PDF for image]
[A] Ukraine may also receive CTR assistance under the BWPP program.
[B] The U. S. Army Corps of Engineers and other government agencies are
involved with the construction of the chemical weapons destruction
facility at Shchucy'ye.
[C] NWSS includes Nuclear Weapons Storage Security projects and Nuclear
Weapons Transportation Security projects in Russia.
[End of figure]
[End of section]
Appendix V: DOD's Current Management and Internal Controls for the CTR
Program Compared with Internal Control Standards:
In managing the CTR program, standards for internal controls in the
federal government provide an overall framework for DOD to establish
and maintain management controls and identify and address major
performance challenges and areas at risk for mismanagement. The five
overall standards for internal control are control environment, risk
assessment, control activities, information and communications, and
monitoring. Each standard contains numerous factors that an
organization's management can use to evaluate its internal controls.
For example, under the control environment standard, there are about 30
factors listed such as whether an agency's organizational structure has
appropriate and clear internal reporting requirements. For this report,
we focused on those factors most relevant to CTR program
implementation. The scope of our work thus covered factors such as
organizational structure, risk assessments, performance measures,
program reviews, communications, and monitoring of projects. Table 1
describes the factors selected in reviewing DOD's current internal
controls for the CTR program.
Table 1: Internal Control Standards and Factors Compared with DOD
Internal controls:
Standards: Control environment: Establish and maintain an environment
throughout the organization that sets a positive and supportive
attitude toward internal control and conscientious management;
Factors: Organizational structure: Key areas of authority and
responsibility are defined and communicated throughout the
organization; Appropriate and clear internal reporting relationships
have been established;
Current DOD internal controls: DOD filled vacancies in the office of
the Under Secretary of Defense for Acquisitions, Technology, and
Logistics (AT&L) to provide oversight of the program. Specifically,
within AT&L, the office of the Deputy Assistant to the Secretary of
Defense for Chemical Demilitarization and Threat Reduction participates
in CTR program planning, including overseeing program review meetings
and providing guidance to program and project managers. This office
also interacts with the CTR Policy Office and conveys policy guidance
to the Cooperative Threat Reduction Directorate; DOD uses designated
Milestone Decision Authority (MDA) to perform oversight of all CTR
program areas. The MDA chairs program reviews and approves project
acquisition and implementation strategies. The MDA has the authority to
approve all project phases or to withhold approval subject to revised
planning; CTR project managers regularly report to their MDAs to
provide updates on project status and to report on cost, schedule, and
performance. With the introduction of the MDA process, program reviews
occur at the same intervals for each project and project managers are
reporting similar types of information to their MDAs; DTRA Implementing
Instructions for Major Program Guidance (DTRA 5000.01) now defines the
roles and responsibilities for management and oversight of DTRA major
programs, including CTR projects.
Standards: Risk assessment: Provide for an assessment of the risks the
agency faces from both external and internal sources;
Factors: Risk identification, risk analysis, and managing risk during
change: Management comprehensively identifies risk using various
methodologies as appropriate; Management has developed an approach for
risk management and control based on how much risk can be prudently
accepted. For example, specific control activities are identified to
manage or mitigate specific risks at each activity level; The agency
has mechanisms in place to anticipate, identify, and react to risks
presented by changes in governmental, economic, industry, regulatory,
operating, or other conditions that can affect the achievement of
entity-wide or activity-level goals and objectives; Adequate mechanisms
exist to identify risks to the agency arising from external factors;
Current DOD internal controls: Since the two CTR project failures in
2003, DOD now uses several methods to assess and mitigate risks
associated with CTR projects; An MDA is designated for each CTR project
based on several factors, including the project's risk and expected
cost; CTR program officials now use a phased-contract approach in
managing project implementation. Under this approach, projects are
evaluated in three phases to minimize project risk; DOD has instituted
periodic meetings of stakeholders to assess and minimize risks
associated with CTR projects; The CTR program uses amendments to
implementing agreements to convert recipient government assumptions or
responsibilities into firm commitments. Implementing agreements have
been used to limit CTR program risks; CTR's new and revised internal
controls provide a mechanism for addressing and mitigating the specific
risks associated with each project, but the CTR program must still rely
on the good will of recipient governments to help implement projects.
DOD cannot fully mitigate the risks of cooperating with these
governments.
Standards: Control activities: Help ensure that management's directives
are carried out effectively and efficiently in accomplishing the
agency's objectives; Agency managers review actual performance against
targets;
Factors: Top-level and management reviews at the functional or activity
level: Top-level management regularly reviews actual performance
against budgets, forecasts, and prior results;
Current DOD internal controls: The MDA for CTR projects is responsible
for balancing requirements with risks, approving and overseeing cost,
schedule, and performance baselines; DOD has introduced a new process
to review CTR projects whereby the designated MDA conducts periodic
reviews of a project's cost, schedule, and performance objectives;
Monthly review meetings of CTR projects include more detailed
discussions of project plans that now include objectives, exit
strategies, and project status. Project plans are submitted to CTR
management for review regularly.
Factors: Performance measures and indicators: The agency has
established and monitors performance measures and indicators;
Current DOD internal controls: CTR project baselines now include the
thresholds and objectives for key parameters such as cost, schedule,
and performance; DTRA had developed and implemented guidelines that
provide CTR project managers with written instructions on developing
and reporting project objects, schedules, and cost estimates.
Standards: Information and communications: Should be recorded and
communicated to management and others who need it;
Factors: Communications: Mechanisms should exist to allow the easy flow
of information down, across, and up the organization, and easy
communications exist between functional activities, such as between
procurement and production activities;
Current DOD internal controls: DTRA Implementing Instructions for Major
Program Guidance (DTRA 5000.01) documents the roles and
responsibilities for management and oversight of DTRA major programs,
including CTR projects; All CTR stakeholders are provided with
consistent information on a regular basis through emails, weekly
reports, and periodic meetings; CTR project managers hold weekly phone
conferences with contractors implementing projects in recipient
countries to ensure proper program implementation. Contractors are
required to submit monthly written reports to CTR officials; DOD has
improved its external communications with CTR-recipient countries. To
more clearly define the project commitments of CTR-recipient
governments and minimize risk at the outset of each project and
throughout its life cycle, DOD has introduced and updated controls to
ensure that commitments made by the CTR program and governments
receiving CTR assistance are clearly defined and documented.
Standards: Monitoring: Should assess the quality of performance over
time and ensure that the findings of audits and other reviews are
promptly resolved;
Factors: Ongoing monitoring: Management has a strategy to ensure that
ongoing monitoring is effective and will trigger separate evaluations
where problems are identified; Separate evaluations are often prompted
by events such as major changes in management plans or strategies;
Current DOD internal controls: CTR program officials now monitor the
performance of ongoing projects through a variety of controls, but they
do not assess the performance of CTR projects upon their completion;
DTRA has developed and implemented guidance that provides CTR project
managers with written instructions on how to measure performance for
meeting project objectives, schedules, and cost estimates. The metrics
described in this guidance are intended to establish meaningful goals
and track milestones for each project; During periodic program reviews,
CTR project managers report to their MDAs on the status of their
projects, primarily whether objectives are being met; CTR project
managers interact regularly with contractors and recipient government
officials through emails, phone conferences, and project visits. In
fiscal year 2003, CTR teams made 165 project trips compared with 70
trips in 2001.
Source: GAO analysis.
[End of table]
[End of section]
Appendix VI: Comments from the Department of Defense:
OFFICE OF THE UNDER SECRETARY OF DEFENSE:
POLICY:
2000 DEFENSE PENTAGON:
WASHINGTON, DC 20301-2000:
09 JUN 2005:
Mr. Joseph A. Christoff:
Director, International Affairs and Trade:
U.S. General Accounting Office:
441 G Street, N.W.:
Washington, DC 20548:
Dear Mr. Christoff:
This is the Department of Defense (DoD) response to the GAO draft
report, "COOPERATIVE THREAT REDUCTION: DOD Has Improved its Management
and Internal Controls but Challenges Remain," dated May 27, 2005 (GAO
Code 320264/GAO-05-329).
My office has received the draft GAO report and concurs with the
recommendation that the Secretary of Defense conduct performance
reviews of CTR projects upon their completion to document lessons
learned and apply them to future project planning and implementation.
My point of contact for this report is James H. Reid at (703) 696-7737,
james.reid@osd.mil.
Sincerely yours,
Signed by:
Lisa Bronson:
Deputy Under Secretary of Defense, Technology Security Policy and
Counterproliferation:
cc:
ATSD (NCB);
DATSD (CD&TR);
Director, DTRA:
[End of section]
Appendix VII: GAO Contact and Staff Acknowledgments:
GAO Contact:
Joseph A. Christoff (202) 512-8979:
Staff Acknowledgments:
In addition to the contact named above, Dave Maurer, Beth Hoffman León,
Josie Sigl, Stephanie Robinson, Nima Patel Edwards, Stacy Edwards, Lynn
Cothern, Judy Pagano, and Mark Dowling contributed to this report.
Etana Finkler also provided assistance.
(320264):
FOOTNOTES
[1] CTR recipient states of the former Soviet Union include Russia,
Ukraine, Belarus, Kazakhstan, Uzbekistan, Azerbaijan, Moldova, and
Georgia.
[2] For the purposes of this report, we are using the acronym AT&L to
refer to the office of the Deputy Assistant to the Secretary of Defense
for Chemical Demilitarization and Threat Reduction within the Office of
the Under Secretary of Defense for Acquisition, Technology, and
Logistics.
[3] Public Law 108-136 also requires GAO to assess the management and
coordination activities of the threat reduction and nonproliferation
programs of the Departments of Defense and Energy. See GAO, Weapons of
Mass Destruction: Nonproliferation Programs Need Better Integration,
GAO-05-157 (Washington, D.C.: Jan. 28, 2005). GAO is also assessing the
Department of Energy's management of its nonproliferation programs.
[4] GAO, Standards for Internal Control in the Federal Government, GAO/
AIMD-00-21.3.1 (Washington, D.C.: Nov. 1999); and Internal Control
Management and Evaluation Tool, GAO-01-1008G (Washington, D.C.: Aug.
2001).
[5] Stakeholders include all CTR management, acquisition, and policy
decision makers as well as other government agency officials who are
involved with implementing a particular CTR project.
[6] The CT directorate also has a program integration component and an
executive language service to support program implementation.
[7] Currently, the CTR program has offices in Moscow, Russia; and Kiev,
Ukraine; and has plans to establish permanent offices in Tashkent,
Uzbekistan; Almaty, Kazakhstan; Baku, Azerbaijan; and Tbilisi, Georgia.
[8] The five CTRIC contractors are Parsons Delaware, Inc; Bechtel
National, Inc; Raytheon Technical Services Company; Kellogg, Brown, &
Root; and Washington Group International, Inc.
[9] DOD, Risk Management Guidebook for DOD Acquisition, Fifth Edition,
June 2003.
[10] GAO, Weapons of Mass Destruction, Status of the Cooperative Threat
Reduction Program, GAO/NSIAD-96-222 (Washington, D.C.: Sept. 27, 1996).
[11] DOD, Office of the Inspector General, Cooperative Threat
Reduction: Solid Rocket Motor Disposition Facility (D-2003-131), Sept.
11, 2003.
[12] Using our structured interview guide, we asked DOD officials what
they believed the most important new internal controls for the CTR
program are. This was an open-ended question and each official could
provide multiple answers. We obtained the following responses from the
30 officials we interviewed as to which new internal controls are the
most important: 19 said the MDA review process, 9 said periodic
meetings with stakeholders, 9 said the involvement of the AT&L office
in the program, 8 said new reporting requirements, 7 said the new
methods for communicating with and documenting the responsibilities of
recipient government officials, and 7 said the program's new focus on
the acquisition process.
[13] See footnote 12 for a full list of responses.
[14] The governments maintain and establish an environment throughout
their bureaucracies that sets a positive and supportive attitude toward
internal control and management. It provides discipline and structure
as well as the climate, which influences the quality of internal
control.
[15] Umbrella agreements contain a comprehensive set of rights,
exemptions, and protections for U.S. personnel and CTR program
activities. Currently, DOD has umbrella agreements with the governments
of Albania, Azerbaijan, Georgia, Kazakhstan, Moldova, Russia, Ukraine,
and Uzbekistan.
[16] Agreement Between the Department of Defense of the United States
of America and the Ministry of Defense of Ukraine Concerning the
Provision of Material, Services, and Related Training to Ukraine in
Connection with the Elimination of Strategic Nuclear Arms, dated
December 5, 1993, and as amended.
[17] The International Science and Technology Center was established by
the United States, the European Union, Russia, and Japan in November
1992 to provide peaceful research opportunities to former Soviet
weapons scientists and redirect their skills away from producing
weapons of mass destruction.
[18] As of April 2005, DOD had spent $14.9 million on the design of the
facility and $319.6 on the facility's construction. The amount does not
include $69.3 million spent on fissile material containers for the
facility.
[19] GAO, Weapons of Mass Destruction: Reducing the Threat From the
Former Soviet Union, GAO/NSIAD-95-7 (Washington, D.C.: Oct. 6, 1994).
[20] GAO, Weapons of Mass Destruction: Effort to Reduce Russian
Arsenals May Cost More, Achieve Less Than Planned, GAO/NSIAD-99-76
(Washington, D.C: Apr. 13, 1999.)
[21] DOD Office of the Inspector General, Cooperative Threat Reduction:
Cooperative Threat Reduction Program Liquid Propellant Disposition
Project, D-2002-154 (Washington, D.C.: Sept. 2002).
[22] DOD Office of the Inspector General, Cooperative Threat Reduction:
Solid Rocket Motor Disposition Facility Project, D-2003-131
(Washington, D.C.: Sept. 2003).
[23] GAO, Cooperative Threat Reduction: DOD Has Adequate Oversight but
Procedural Limitations Remain, GAO-01-694 (Washington, D.C.: June 19,
2001).
[24] GAO, Weapons of Mass Destruction: Additional Russian Cooperation
Needed to Facilitate U.S. Efforts to Improve Security at Russian Sites,
GAO-03-482 (Washington, D.C.: Mar. 24, 2003).
[25] The Strategic Arms Reduction Treaty (START) I, signed July 31,
1991, by the United States and the Soviet Union, limited the number of
intercontinental ballistic missiles, submarine-launched ballistic
missiles, and heavy bombers each side could have as well as the number
of warheads the missiles could carry. START II, signed in 1993 by the
United States and the Russian Federation, was to eliminate multiple
warheads on all intercontinental ballistic missiles except for
submarine-launched missiles.
[26] DOD Office of the Inspector General, Cooperative Threat Reduction:
Cooperative Threat Reduction Program Liquid Propellant Disposition
Project, D-2002-154 (Washington, D.C.: Sept. 2002).
[27] Implementing agreements, signed by DOD and the executive agents of
CTR recipient countries, outline the types and amounts of assistance to
be provided for specific projects.
[28] DOD Office of the Inspector General, Cooperative Threat Reduction:
Management Structure of the Cooperative Threat Reduction Program, D-
2004-050 (Washington, D.C.: Feb. 2004).
[29] Public Law 102-228, Section 211.
[30] Public Law 106-65, Section 1303.
[31] Public Law 106-79, Section 8078.
[32] Public Law 106-65, Section 1305.
[33] Public Law 106-65, Section 1305 and Public Law 108-136, Section
1306.
[34] GAO, Cooperative Threat Reduction: DOD's 1997-1998 Reports on
Accounting for Assistance Were Late and Incomplete, GAO/NSIAD-00-40
(Washington, D.C.: Mar. 15, 2000). GAO, Cooperative Threat Reduction:
DOD Has Adequate Oversight of Assistance, but Procedural Limitations
Remain, GAO-01-694 (Washington, D.C.: June 19, 2001).
[35] Public Law 106-398, Section 1308(a). The annual report describes
CTR activities and assistance provided during the preceding fiscal
year. Subsequent legislation has added required information to this
report. See Public Law 107-107, Section 1309; Public Law 107-314,
Section 1304.
[36] GAO, Cooperative Threat Reduction Program Annual Report, GAO-03-
341R (Washington, D.C.: Dec. 2, 2002). GAO, FY 2003 Annual Report on
the Cooperative Threat Reduction Program, GAO-03-627R (Washington,
D.C.: Apr. 8, 2003). GAO, FY 2004 Annual Report on the Cooperative
Threat Reduction Program, GAO-03-1008R (Washington, D.C.: July 18,
2003).
[37] S. 313.
[38] Public Law 102-228, Section 211, as amended, specifies that the
President must state in writing that CTR recipient countries are
committed to (1) making substantial investment of their own resources
to dismantle or destroy weapons, (2) forgoing a military modernization
program that exceeds legitimate defense requirements, (3) forgoing any
use of components of destroyed nuclear weapons in new weapons, (4)
facilitating U.S. verification of weapons destruction, (5) complying
with all relevant arms control agreements, and (6) observing internally
recognized human rights.
[39] H.R. 665 was introduced by Representatives Schiff, Shays,
Butterfield, Chandler, Davis, Edwards, Grijalva, Holt, Israel, Maloney,
Scott, Sherman, and Watson.
[40] GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1999). We also referred
to GAO's publication, Internal Control Management and Evaluation Tool,
GAO-01-1008G (Washington, D.C.: Aug. 2001).
[41] DTRA Instruction 5000.01: Defense Threat Reduction Agency (DTRA)
Major Programs (Ft. Belvoir, VA: Nov. 15, 2004).
[42] The five program areas are Biological Weapons Proliferation
Prevention, Chemical Weapons Elimination, Nuclear Weapons Safety and
Security, Strategic Offensive Arms Elimination, and Weapons of Mass
Destruction Proliferation Prevention.
[43] The five contractors are Parsons; Bechtel International Systems,
Inc; Raytheon Technical Services Company; Kellogg, Brown, and Root; and
Washington Group International.
[44] Other program support areas include Defense and Military Contacts,
Arctic Nuclear Waste, and administrative costs.
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