Nuclear Waste
DOE's Environmental Management Initiatives Report Is Incomplete Gao ID: GAO-09-697R June 2, 2009The Department of Energy (DOE) spends billions of dollars annually to clean up nuclear waste at sites across the nation that produced nuclear weapons from the 1940s through the end of the Cold War. This waste can threaten public health and the environment. For example, contaminants at DOE's Hanford site in Washington have migrated through the soil into the groundwater, which generally flows toward the Columbia River. The river is a source of irrigation for agriculture and drinking water for downstream communities as well as a major route for migrating salmon. Cleanup projects decontaminate and demolish buildings, remove and dispose of contaminated soil, treat contaminated groundwater, and stabilize and dispose of solid and liquid radioactive wastes, among other things. DOE's Office of Environmental Management currently oversees more than 80 of these cleanup projects, primarily at government-owned, contractor-operated sites throughout the nation. Some of these highly complex projects have completion dates beyond 2050. We have issued numerous reports on DOE's management of its cleanup projects. For example, since 2006 we have issued 12 reports examining DOE's contract and project management. In March 2009, we testified that 9 of the 10 major cleanup projects that we reviewed had experienced cost increases--in total, DOE estimated that it needed an additional $25 billion to $42 billion to complete these cleanup projects. We also reported in September 2008 that these major cleanup projects had experienced delays from 2 to 15 years. These problems were the result of inconsistent application of project management tools and techniques on the part of DOE and its contractors. Furthermore, since 1990, we have designated DOE's contract management as a high-risk area for fraud, waste, abuse, and mismanagement because of the department's record of inadequate management and oversight of its projects. In January 2009, we narrowed the scope of this high-risk area to focus on the two major offices remaining within DOE that continue to experience significant problems--the Office of Environmental Management and the National Nuclear Security Administration (NNSA). Together, these two program offices account for about 60 percent of the department's annual budget. Under Section 3130 of the National Defense Authorization Act for Fiscal Year 2008 (the Act), DOE was required to report to the congressional defense committees and to the Comptroller General of the United States by September 30, 2008, on the status of the environmental management initiatives that it has undertaken to more rapidly reduce the environmental risks and challenges resulting from the legacy of the Cold War. In particular, the Act required DOE to include five elements in its report, (1) a discussion and assessment of progress made in reducing environmental risks and challenges; (2) an assessment of whether legislative changes or clarifications would improve or accelerate environmental management activities; (3) a listing of major mandatory milestones and commitments DOE faces; (4) an estimate of the life-cycle cost of DOE's current environmental management program; and (5) a description of the process DOE follows for nominating and accepting new work scope into the environmental management program, and schedules to address new work. DOE's Office of Environmental Management issued the required report in January 2009. Section 3130 of the Act also required GAO to review DOE's report and report to the congressional defense committees. As agreed with congressional staffs, this report addresses the extent to which the report that DOE prepared discusses the five elements called for under the Act.
DOE's report only partially addresses the five elements required by the Act. Specifically, only one element--an estimate of the life-cycle cost of DOE's current environmental management program--was fully discussed. Three elements--discussing progress in reducing environmental risks and challenges, listing major mandatory milestones, and describing new work scope processes--were partially discussed. For example, in discussing progress in reducing environmental risks and challenges, DOE did not always clearly connect progress in environmental cleanup with environmental risk reduction. The remaining element--an assessment of whether legislative changes or clarifications would improve or accelerate environmental management activities--was not discussed in the report. DOE officials told us that certain elements were only partially discussed or were not discussed for several reasons, including, in the case of suggested legislative changes, because the department did not want to preempt any nuclear cleanup policy changes the new presidential administration might announce.
GAO-09-697R, Nuclear Waste: DOE's Environmental Management Initiatives Report Is Incomplete
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GAO-09-697R:
United States Government Accountability Office:
Washington, DC 20548:
June 2, 2009:
Congressional Committees:
Subject: Nuclear Waste: DOE's Environmental Management Initiatives
Report Is Incomplete:
The Department of Energy (DOE) spends billions of dollars annually to
clean up nuclear waste at sites across the nation that produced nuclear
weapons from the 1940s through the end of the Cold War. This waste can
threaten public health and the environment. For example, contaminants
at DOE's Hanford site in Washington have migrated through the soil into
the groundwater, which generally flows toward the Columbia River. The
river is a source of irrigation for agriculture and drinking water for
downstream communities as well as a major route for migrating salmon.
Cleanup projects decontaminate and demolish buildings, remove and
dispose of contaminated soil, treat contaminated groundwater, and
stabilize and dispose of solid and liquid radioactive wastes, among
other things. DOE's Office of Environmental Management currently
oversees more than 80 of these cleanup projects, primarily at
government-owned, contractor-operated sites throughout the nation. Some
of these highly complex projects have completion dates beyond 2050.
We have issued numerous reports on DOE's management of its cleanup
projects. For example, since 2006 we have issued 12 reports examining
DOE's contract and project management. In March 2009, we testified that
9 of the 10 major cleanup projects that we reviewed had experienced
cost increases--in total, DOE estimated that it needed an additional
$25 billion to $42 billion to complete these cleanup projects.[Footnote
1] We also reported in September 2008 that these major cleanup projects
had experienced delays from 2 to 15 years.[Footnote 2] These problems
were the result of inconsistent application of project management tools
and techniques on the part of DOE and its contractors. Furthermore,
since 1990, we have designated DOE's contract management as a high-risk
area for fraud, waste, abuse, and mismanagement because of the
department's record of inadequate management and oversight of its
projects. In January 2009, we narrowed the scope of this high-risk area
to focus on the two major offices remaining within DOE that continue to
experience significant problems--the Office of Environmental Management
and the National Nuclear Security Administration (NNSA).[Footnote 3]
Together, these two program offices account for about 60 percent of the
department's annual budget.
Under Section 3130 of the National Defense Authorization Act for Fiscal
Year 2008 (the Act),[Footnote 4] DOE was required to report to the
congressional defense committees and to the Comptroller General of the
United States by September 30, 2008, on the status of the environmental
management initiatives that it has undertaken to more rapidly reduce
the environmental risks and challenges resulting from the legacy of the
Cold War. In particular, the Act required DOE to include five elements
in its report, (1) a discussion and assessment of progress made in
reducing environmental risks and challenges; (2) an assessment of
whether legislative changes or clarifications would improve or
accelerate environmental management activities; (3) a listing of major
mandatory milestones and commitments DOE faces; (4) an estimate of the
life-cycle cost of DOE's current environmental management program; and
(5) a description of the process DOE follows for nominating and
accepting new work scope into the environmental management program, and
schedules to address new work. DOE's Office of Environmental Management
issued the required report in January 2009.[Footnote 5]
Section 3130 of the Act also required GAO to review DOE's report and
report to the congressional defense committees. As agreed with your
staffs, this report addresses the extent to which the report that DOE
prepared discusses the five elements called for under the Act.
To determine the extent to which the DOE report contains all of the
elements required by the Act, we reviewed the report and compared it
with the Act's requirements. We also reviewed prior GAO work on DOE's
management of its cleanup projects. In addition, we interviewed DOE
Office of Environmental Management officials at DOE headquarters in
Washington, D.C. We conducted this performance audit from January
through June 2009 in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings based on our audit objectives. We
believe that the evidence obtained provides a reasonable basis for our
findings.
DOE's Report Fully Discusses One Element, Partially Discusses Three
Elements, and Does Not Discuss One Element:
DOE's report only partially addresses the five elements required by the
Act. Specifically, only one element--an estimate of the life-cycle cost
of DOE's current environmental management program--was fully discussed.
Three elements--discussing progress in reducing environmental risks and
challenges, listing major mandatory milestones, and describing new work
scope processes--were partially discussed. For example, in discussing
progress in reducing environmental risks and challenges, DOE did not
always clearly connect progress in environmental cleanup with
environmental risk reduction. The remaining element--an assessment of
whether legislative changes or clarifications would improve or
accelerate environmental management activities--was not discussed in
the report. DOE officials told us that certain elements were only
partially discussed or were not discussed for several reasons,
including, in the case of suggested legislative changes, because the
department did not want to preempt any nuclear cleanup policy changes
the new presidential administration might announce.
Element One--Environmental Risk Reduction: DOE's Report Discusses
Cleanup Progress at Its Sites, but in Some Cases Does Not Explain How
This Progress Reduced Environmental Risks:
Section 3130(b)(1) of the Act required DOE's report to include "a
discussion and assessment of the progress made in reducing the
environmental risks and challenges" in the following areas:
* acquisition strategy and contract management;
* regulatory agreements;
* interim storage and final disposal of high-level waste, spent nuclear
fuel, transuranic waste, and low-level waste;
* closure and transfer of environmental remediation sites;
* achievements in innovation by contractors of the department with
respect to accelerated risk reduction and cleanup; and:
* consolidation of special nuclear materials and improvements in
safeguards and security.
DOE's report discusses progress in each of these areas. For example,
the report has significant detail on improvements that the department
has made in acquisition, contract, and project management. These
improvements include, among other things, transitioning to performance-
based contracts, standardizing the acquisition process, and enhancing
personnel capabilities as well as applying project management
principles and monitoring project performance. In addition, in its
discussion of regulatory agreements, DOE's report notes that the
department is working with its regulators to identify actions that can
accelerate cleanup, because setting cleanup priorities solely on the
basis of achieving compliance milestones would not necessarily support
the greatest risk reduction. Furthermore, the report discusses many
examples of cleanup progress, such as the disposal of approximately 9
million cubic meters of low-level waste and mixed low-level waste; the
removal of all spent nuclear fuel from basins at Hanford; and the
removal of transuranic waste from 14 sites.[Footnote 6] DOE also
discusses innovations in cleanup technologies, including, for example,
a technology to reduce the amount of strontium--a metal found in
nuclear waste--that can contaminate groundwater.
Nevertheless, in some cases, DOE's report does not sufficiently assess
the progress made in reducing environmental risks as required. For
example, the report cites 1,000 acres of soil remediated at DOE's Oak
Ridge Reservation in Tennessee as evidence of its progress. However,
the report does not note whether these 1,000 acres were of high,
medium, or low environmental risk, nor does it describe the potential
environmental consequences of failing to remediate this soil.
Similarly, DOE's report notes that the department has deactivated 112
buildings and structures totaling 1.3 million square feet at DOE's
Idaho National Laboratory since May 2005. However, the report does not
assess how deactivating these buildings--some of which may have housed
offices and other nonhazardous operations--reduced environmental risks
at the site.
Element Two--Legislative Changes: DOE's Report Does Not Assess
Potential Legislative Changes to Improve or Accelerate Environmental
Management Activities:
Section 3130(b)(2) of the Act required DOE's report to include an
assessment of whether legislative changes or clarifications would
improve or accelerate environmental management activities. Despite this
requirement, DOE's report does not contain such an assessment.
DOE officials told us that the department did not want to suggest
legislative changes for nuclear cleanup in advance of decisions the new
presidential administration might issue, nor did the department want to
be perceived as dictating policy changes. These officials also said
that DOE could provide suggested new legislation upon congressional
request.
Element Three--Major Mandatory Milestones: DOE's Report Lists Major
Mandatory Milestones as Required, but Does Not Include Categories for
Noncompliance:
Section 3130(b)(3) of the Act required DOE's report to list the major
mandatory milestones and commitments, by site, type of agreement, and
year, to the extent that they are currently identified. The report is
also required to contain a summary of the major mandatory milestones,
by site, that are projected to be missed or are in jeopardy of being
missed, along with categories to explain the reason for noncompliance.
For 12 DOE cleanup sites, the department lists 345 mandatory milestones
as well as identifies 47 of these milestones at 4 sites that are at
risk of not meeting commitment dates. However, DOE does not provide
categories of reasons for noncompliance as required by the Act.
Instead, DOE states that certain circumstances, such as unanticipated
obstacles that affected the original scope of work, explain the
majority of at-risk milestones. According to DOE officials, the
department did not include categories of reasons for noncompliance
because the list would not provide a clear picture of reasons for
noncompliance. Specifically, 23 of 47 milestones had noncompliance
reasons that fell into two or more of the four categories--funding,
technical difficulty, project performance, and unrealized assumptions.
DOE officials provided us with the list of milestones and categories
for noncompliance that had been created for an earlier draft of their
report. In commenting on a draft of our report, DOE officials told us
that site-specific reasons for noncompliance were not included in their
report because they believed a higher-level summary would be more
useful to the reader. They also noted that the specific reasons for
noncompliance are reported to the appropriate states and are available
to the public.
Element Four--Life-Cycle Costs: DOE's Report Discusses Cleanup
Projects' Life-Cycle Costs:
Section 3130(b)(4) required DOE's report to include an estimate of the
life-cycle cost of the current scope of the environmental management
program by project baseline summary, and summarized by site. The Act
states that this discussion should include the assumptions impacting
cost projections and descriptions of the work to be done at each site.
As required, DOE discusses life-cycle cost estimates for the current
scope of the environmental management program from 1997 to 2008 by
project baseline summary, provides a list of work to be done, and
describes assumptions affecting cost projections for the program. DOE's
report estimates the current life-cycle cost of the environmental
management program to be from $274 billion to $330 billion. In
addition, the department provides an estimated cost range of $205
billion to $261 billion and planned completion dates for 25 sites
through 2062. The report also describes the remaining work at each of
these sites.
Element Five--New Work Scope: DOE's Report Discusses the Process for
Adding New Work Scope to the Environmental Management Program, but Does
Not Include a Schedule for Addressing This Work:
For environmental cleanup liabilities and excess facilities projected
to be transferred to the environmental management program, Section
3130(b)(5) of the Act required DOE's report to include a description of
the process for nomination and acceptance of new work scope into the
program, a listing of pending nominations, and life-cycle cost
estimates and schedules to address them.
To comply with this section, DOE provides a list of pending nominations
and life-cycle cost estimates for cleanup activities that may be
transferred to the environmental management program from other DOE
entities, such as NNSA and DOE's Office of Science. Specifically, the
department reports that approximately 5.8 million square feet of excess
facilities have been proposed for transfer to the environmental
management program, and that these facilities would add approximately
$3.7 billion to $9.1 billion of life-cycle cleanup costs to current DOE
estimates. DOE's report notes that the environmental management program
requests other DOE offices to nominate cleanup activities annually. The
program then consolidates this information and formalizes it with
agreements between the environmental management program and the other
DOE offices concerning the proposed transfer period and budget
responsibilities.[Footnote 7]
However, DOE's report does not include schedules for addressing new
work scope as required by the Act. DOE officials told us that the
report does not include schedules because the program cannot accept
additions to its current scope of work until 2017, and, thus, it would
be unreasonable to develop schedules for cleanup that cannot occur
until then. In commenting on a draft of this report, DOE officials told
us the department was able to accept additional work scope into the
environmental management program using funding received as a result of
the American Recovery and Reinvestment Act.[Footnote 8]
Agency Comments and Our Evaluation:
We provided a draft of this report to DOE for its review and comment.
On May 15, 2009, we met with DOE officials, including DOE's Acting
Assistant Secretary of Environmental Management, to obtain oral
comments on our draft report. DOE officials generally agreed with our
findings that the report the department prepared to comply with the Act
does not discuss legislative changes to improve or accelerate
environmental management activities, and that DOE's report lacks
schedules for addressing excess facilities that could be transferred
into the program. These officials noted that additional cleanup work
associated with excess facilities will be transferred to the
environmental management program and will be addressed using funding
obtained as a result of the American Recovery and Reinvestment Act.
However, DOE officials disagreed with our assessment of this element as
"partially discussed" because, according to these officials, "the Act
required numerous data points regarding excess facilities" and "only
one specific data point was not fully addressed." Nevertheless, the Act
specifically required DOE's report to contain a discussion of the
schedules to address additional cleanup work. This discussion, as DOE
officials conceded, is not included. Therefore, we maintain that our
assessment of this element as partially discussed is appropriate.
DOE officials also agreed that the department's report lacks the
linkage of specific reasons for noncompliance to at-risk milestones
identified in the report, but disagreed that this omission was the
result of a desire to protect DOE from legal action as our draft report
stated. These officials explained that numerous factors affect the
ability to meet compliance milestones, and that DOE could not always
link at-risk milestones to one specific category. Instead, DOE
officials said that categories for noncompliance with major mandatory
milestones were omitted because they believed a higher-level summary
would be more helpful to the reader. We modified our report
accordingly. DOE officials again disagreed with our assessment of this
element as "partially discussed" because they believed this assessment
does not fully indicate the quantity of information DOE's report
includes in this element. Nevertheless, the Act specifically required
DOE's report to contain a "summary of the major mandatory milestones by
site that are projected to be missed or are in jeopardy of being missed
along with categories to explain the reason for noncompliance."
Notwithstanding DOE officials' belief that a higher-level summary would
be more helpful to the reader, DOE's failure to include categories to
explain the reason for noncompliance as required by the Act justifies
our assessment of this element as partially discussed.
DOE officials also disagreed with our finding that the department's
report only partially discussed the first element required by the Act-
-a discussion and assessment of the progress made in reducing
environmental risks and challenges. Again, DOE officials felt that our
assessment of this element as "partially discussed" insufficiently
captured the extensive amount of information DOE included in its report
to demonstrate its progress in reducing environmental risk. We agree
that DOE's report contains extensive discussion of the department's
cleanup progress to date, and we have modified our report to include
several more examples that DOE cited in its report. However, we
maintain that, in some cases, the examples that DOE's report uses as
evidence of the progress it has made do not clearly demonstrate a
reduction in environmental risk. For example, the report's discussion
of the number of buildings that DOE has demolished at several of its
sites does not clearly indicate a corresponding reduction in
environmental risk. This is because these demolished buildings may have
consisted of offices or contained other nonhazardous activities.
Without a clear explanation of the relative environmental risks posed
by specific buildings, we maintain that an aggregated measure of
demolished buildings does little to demonstrate a reduction in
environmental risk.
Finally, given our report's objective of addressing the extent to which
the report that DOE prepared discusses the five elements called for
under the Act, DOE officials questioned the relevance of our discussion
in our draft report's introduction of the cost increases and schedule
delays experienced by DOE cleanup projects. These officials also
questioned the relevance of our discussion of DOE's contract management
as a high-risk area for fraud, waste, abuse, and mismanagement. We
disagree. In our view, the discussion of the significant cost increases
and schedule delays experienced by major cleanup projects managed by
the DOE's Office of Environmental Management provides important context
to understand the challenges that the department faces in completing
this cleanup work. Furthermore, the first element of the Act requires a
discussion of the progress that DOE has made in addressing the
department's contract management challenges. Therefore, our discussion
of DOE contract management as a high-risk area is appropriate, given
the objective of our report. We made no changes to our report as a
result of this comment.
DOE officials also provided technical comments that we have
incorporated throughout the report, as appropriate.
We are sending copies of this report to the Secretary of Energy, the
appropriate congressional committees, and other interested parties.
This report will be available at no charge on the GAO Web site at
[hyperlink, http://www.gao.gov].
If you or your staffs have any questions about this report, please
contact me at (202) 512-3841 or aloisee@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report include
Ryan T. Coles, Assistant Director; Sandra Kerr; and Michelle K.
Treistman. Omari Norman and Cheryl Peterson also contributed to this
report.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
List of Committees:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable Daniel K. Inouye:
Chairman:
The Honorable Thad Cochran:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
United States Senate:
The Honorable Ike Skelton:
Chairman:
The Honorable John M. McHugh:
Ranking Member:
Committee on Armed Services:
House of Representatives:
The Honorable John P. Murtha:
Chairman:
The Honorable C.W. Bill Young:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
House of Representatives:
[End of section]
Footnotes:
[1] GAO, Department of Energy: Contract and Project Management Concerns
at the National Nuclear Security Administration and Office of
Environmental Management, [hyperlink,
http://www.gao.gov/products/GAO-09-406T] (Washington, D.C.: Mar. 4,
2009).
[2] GAO, Nuclear Waste: Action Needed to Improve Accountability and
Management of DOE's Major Cleanup Projects, [hyperlink,
http://www.gao.gov/products/GAO-08-1081] (Washington, D.C.: Sept. 26,
2008).
[3] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January
2009).
[4] Pub. L. No. 110-181 (2008).
[5] DOE, Status of Environmental Management Initiatives to Accelerate
the Reduction of Environmental Risks and Challenges Posed by the Legacy
of the Cold War (Washington, D.C.: Jan. 16, 2009).
[6] Low-level waste includes items that have become contaminated with
radioactive material or have become radioactive through exposure to
neutron radiation, and mixed low-level waste is low-level waste that
also contains a hazardous chemical. Spent nuclear fuel is generated
from research associated with nuclear power, and production of nuclear
materials for use in nuclear weapons, scientific research, and
medicine. Transuranic waste is a type of radioactive waste that
contains elements with atomic numbers greater than uranium, which has
an atomic number of 92.
[7] Detailed information on the process that DOE uses to nominate and
accept additional cleanup work is available in DOE Guide 430.1-5,
Transition Implementation Guide.
[8] The American Recovery and Reinvestment Act is Pub. L. No. 111-5
(2009).
[End of section]
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