Department of Energy:

Improved Guidance, Oversight, and Planning Are Needed to Better Identify Cost-Saving Alternatives for Managing Low-Level Radioactive Waste

GAO-06-94: Published: Oct 31, 2005. Publicly Released: Oct 31, 2005.

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In 2004, the Department of Energy (DOE) disposed of more than 378,000 cubic meters of low-level radioactive waste (LLRW)--contaminated building rubble, soil, and debris. In 2002, DOE directed its sites to use life-cycle cost analysis to manage LLRW. Life-cycle cost analysis examines the total cost of various options to manage LLRW over its life, including its packaging, treatment, transport, and disposal, to identify the lowest-cost alternative. GAO determined whether (1) DOE sites use life-cycle cost analysis to evaluate LLRW management alternatives and (2) DOE has a strategy for cost-effectively managing LLRW departmentwide, including state actions that may affect this strategy.

The six DOE sites we visited, representing more than 70 percent of the LLRW disposed of by DOE during 2003 and 2004, did not consistently use life-cycle cost analysis because of weak DOE guidance and a lack of oversight of contractors' implementation of this guidance. As a result, DOE cannot ensure that lowest-cost LLRW management alternatives are identified, so that managers make decisions that fully weigh costs against noncost factors, such as safety and schedule. For example, DOE contractors at two sites did not consistently consider alternative transportation modes or postclosure maintenance and surveillance costs of disposal sites in their analyses for fiscal year 2004 disposal decisions. GAO also could not always determine how contractors used cost analyses in disposal decisions because of incomplete documentation. While DOE's guidance requires each site to develop the mechanisms necessary to ensure use of life-cycle cost analysis, it does not specify, for example, (1) a systematic, consistent method of analyzing all cost elements to determine the lowest cost, or (2) when analyses should be performed. Also, no such guidance was incorporated into site contracts, and DOE site offices had not evaluated contractors' use of life-cycle cost analysis. DOE has recognized that its current approach--having each site responsible for developing mechanisms necessary to control costs--may result in cost inefficiencies and may limit its ability to meet departmentwide strategic objectives. As a result, DOE plans to begin implementing a national LLRW disposition strategy by March 2006 to better coordinate disposal efforts--specific schedules have not yet been established for when the strategy will be fully in place. However, DOE faces challenges in developing and implementing this strategy. First, it needs to gather complete data on the amount of LLRW needing disposal. Second, the fact that DOE's multiple program and site offices have differing missions and oversee many contractors presents coordination challenges. For example, one program office dismantled and disposed of a supercompactor used to reduce the volume of large LLRW items without a DOE-wide assessment of LLRW compacting needs and without considering other potential cost-effective uses for the supercompactor that might benefit other DOE sites. Third, DOE faces state actions that have restricted access to disposal facilities, making it more difficult to coordinate and integrate disposal departmentwide.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: This recommendation is linked to recommendation 1, which we have classified as "closed-not implemented."

    Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should direct DOE to oversee contractors to ensure that site contractor officials properly use life-cycle cost analyses in evaluating LLRW management alternatives.

    Agency Affected: Department of Energy

  2. Status: Closed - Not Implemented

    Comments: This recommendation is linked to recommendation 1, which we have classified as "closed-not implemented."

    Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should incorporate the revised life-cycle cost guidance into new or existing site contracts or into the departmental orders cited in those contracts.

    Agency Affected: Department of Energy

  3. Status: Closed - Not Implemented

    Comments: According DOE's September 2010 DARTS report, DOE prepared draft guidance that provides the analytical framework for continued evaluation of waste disposal planning. The report also notes that efforts to formalize this guidance were suspended due to a variety of actions underway within the department related to waste management. The report explains that actions underway to update DOE waste disposal requirements (Order 435.1), that these actions will satisfy the GAO recommendation, and these actions will take approximately 2 years to complete. Based on these planned actions, DOE closed the recommendation. Given all the actions underway that are intended to satisfy the GAO recommendation, it is unclear why DOE closed the recommendation. DOE's December 2010 DARTS report deletes reference to the planned actions and instead reference memos from June and August 2009 that are vague and unclear as to how they specifically respond to the GAO recommendation. DOE has had more than 5 years to respond to this recommendation and they have presented no evidence they have completed actions in response to this recommendation. Until DOE presents specific evidence that they have complied with this recommendation, this recommendation will be classified as "closed-not implemented."

    Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should prepare comprehensive guidance on life-cycle cost analysis that, at a minimum, specifies (1) a systematic, consistent method of analyzing all cost elements or of comparing key alternatives within these cost elements to determine the lowest cost; (2) when and under what circumstances sites should prepare cost analyses; (3) relevant DOE orders, manuals, or other reference materials that should be consulted to provide consistent direction on how and when to perform the analysis; and (4) how final LLRW management decisions should be documented to demonstrate that life-cycle cost factors were adequately weighed against noncost factors, such as safety, health, or schedule.

    Agency Affected: Department of Energy

  4. Status: Closed - Not Implemented

    Comments: This recommendation is linked to recommendation 1, which we have classified as "closed-not implemented."

    Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should actively promote and monitor the development of a timely, national LLRW management strategy that is based on departmentwide data on LLRW needing disposal, and ensure that the implementation of the strategy is fully carried out.

    Agency Affected: Department of Energy

 

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