Nuclear Waste Cleanup:

DOE Could Improve Program and Project Management by Better Classifying Work and Following Leading Practices

GAO-19-223: Published: Feb 19, 2019. Publicly Released: Mar 5, 2019.

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(202) 512-3841
trimbled@gao.gov

 

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The Cold War arms race created a buildup of nuclear waste in the United States that needs to be cleaned up. This almost-30-year-old effort will take another 70 years and cost about $500 billion more.

Yet the Department of Energy program responsible for this effort categorizes most of its work in a way that does not adequately involve independent experts and DOE senior leadership. It also has not followed leading practices for program and project management that could help keep the cleanup on schedule and control costs.

We made 7 recommendations to address the management challenges we found.

Construction of tanks to store nuclear waste at the Hanford site in the state of Washington

This is a photo of 8 tanks being constructed to store nuclear waste on land in the state of Washington.

This is a photo of 8 tanks being constructed to store nuclear waste on land in the state of Washington.

Additional Materials:

Contact:

David C. Trimble
(202) 512-3841
trimbled@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

What GAO Found

The Department of Energy's (DOE) Office of Environmental Management (EM) manages most of its cleanup of nuclear waste (77 percent of its fiscal year 2019 budget) under a category that EM refers to as operations activities, using less stringent requirements than a category of work, known as capital asset projects. (See figure) Capital asset projects—which involve the acquisition of land and other assets, including through environmental remediation—must undergo a series of reviews by independent experts and DOE's senior leadership. In contrast, operations activities are not reviewed outside of EM. EM's policy defines operations activities as reoccurring facility or environmental operations, as well as activities that are project-like, with defined start and end dates. EM cleanup site managers have discretion on how to classify cleanup work because DOE and EM have not established classification requirements. Since 2015, experts in DOE's Office of Project Management have raised concerns that some operations activities should be classified as capital asset projects, and that managing them under less stringent requirements poses cost and schedule risks. For example, the experts stated the cleanup of tanks of radioactive liquid waste should be designated as capital asset projects. However, these experts also stated that EM did not respond to their concerns, even though the office has department-wide responsibilities for overseeing project management. Until EM works with DOE's Office of Project Management to establish requirements for classifying cleanup work, the department may incur more cost and schedule risks than it should.

Examples of Requirements for Operations Activities and Capital Asset Projects

Examples of Requirements for Operations Activities and Capital Asset Projects

EM's cleanup policy does not follow any of 9 selected program management leading practices or 9 of 12 selected project management leading practices. For example, EM's 2017 cleanup policy does not follow the program management leading practice of conducting risk management throughout the life of a program or the project management leading practice of requiring independent reviews of operations activities. These leading practices help ensure that a program optimizes scope, cost, and schedule performance and that it achieves its goals and intended benefits. Until EM revises its cleanup policy to follow leading practices, EM's operations activities are at risk of uncontrolled changes to scope, exceeding initial budget and schedule, and failing to meet their original goals.

Why GAO Did This Study

EM's mission is to complete the cleanup of nuclear waste at 16 DOE sites and to work to reduce risks and costs within its established regulatory framework. In December 2018, DOE reported that it faced an estimated $494 billion in future environmental cleanup costs—a liability that roughly tripled during the previous 20 years.

GAO was asked to examine EM's operations activities. This report examines, among other objectives, (1) how EM manages its cleanup work and (2) the extent to which EM's cleanup policy follows selected leading practices for program and project management.

To do this work, GAO reviewed agency documents and interviewed DOE project management experts and EM officials. GAO compared EM's policy with selected leading practices endorsed by the Project Management Institute for program and project management related to scope, cost, schedule, and independent review.

What GAO Recommends

GAO is making seven recommendations, including that EM (1) establish cleanup work classification requirements and (2) revise its cleanup policy to follow program and project management leading practices. DOE generally agreed with GAO's recommendations.

For more information, contact David C. Trimble at (202) 512-3841 or trimbled@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: DOE partially concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that DOE developed a draft Cleanup Project Management Policy to clarify the expectations for EM's management of discrete work, such as operations activities that could be considered projects. In February 2020, EM officials stated that they are addressing this recommendation in two steps. First, EM is working with DOE's Office of Project Management to draft a Cleanup Project Management Policy (expected to be completed in spring 2020) to address the Decommissioning and Deactivation (D&D) phase of cleanup. This policy will become an appendix in DOE's Order 413.3B. EM officials further stated that EM plans to develop an additional Cleanup Program Management Policy that would classify the remaining types of activities not covered by the Cleanup Project Management Policy, including what EM currently classifies as operations activities. EM plans to implement this policy by the end of fiscal year 2020.

    Recommendation: The Secretary of Energy should direct the Director of the Office of Project Management and the Assistant Secretary of the Office of Environmental Management to work together to establish requirements for classifying cleanup work as capital asset projects or operations activities. (Recommendation 1)

    Agency Affected: Department of Energy

  2. Status: Open

    Comments: DOE partially concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that DOE developed a draft Cleanup Project Management Policy to clarify the expectations for EM's management of discrete work, such as operations activities that could be considered projects. In February 2020, EM officials stated that they are addressing this recommendation in two steps. First, EM is working with DOE's Office of Project Management to draft a Cleanup Project Management Policy (expected to be completed in spring 2020) to address the Decommissioning and Deactivation (D&D) phase of cleanup. This policy will become an appendix in DOE's Order 413.3B. EM officials further stated that EM plans to develop an additional Cleanup Program Management Policy that would classify the remaining types of activities not covered by the Cleanup Project Management Policy, including what EM currently classifies as operations activities. EM plans to implement this policy by the end of fiscal year 2020.

    Recommendation: The Secretary of Energy should direct the Director of the Office of Project Management and the Assistant Secretary of the Office of Environmental Management to work together to asses EM's ongoing operations activities to determine if they should be reclassified as capital asset projects based on the newly established requirements. (Recommendation 2)

    Agency Affected: Department of Energy

  3. Status: Open

    Priority recommendation

    Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to replace its current EM Cleanup Policy with two separate project and program management policies that will incorporate leading practices related to scope, cost, and schedule, and independent reviews, as appropriate. In February 2020, EM officials stated that EM is working on a Cleanup Project Management Policy (expected to be completed in spring 2020) that will cover the Decommissioning and Deactivation (D&D) phase of cleanup. EM plans to develop an additional Cleanup Program Management Policy (expected to be completed by the end of fiscal year 2020), which will supersede EM's current cleanup policy and include leading program management practices-and possibly also project management practices-related to scope, cost, schedule performance, and independent reviews.

    Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to review and revise EM's 2017 cleanup policy to include program management leading practices related to scope, cost, schedule performance, and independent reviews. (Recommendation 3)

    Agency Affected: Department of Energy

  4. Status: Open

    Priority recommendation

    Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to replace its current EM Cleanup Policy with two separate project and program management policies that will incorporate leading practices related to scope, cost, and schedule, and independent reviews, as appropriate. In February 2020, EM officials stated that EM is working on a Cleanup Project Management Policy (expected to be completed in spring 2020) that will cover the Decommissioning and Deactivation (D&D) phase of cleanup. EM plans to develop an additional Cleanup Program Management Policy (expected to be completed by the end of fiscal year 2020), which will supersede EM's current cleanup policy and include leading program management practices-and possibly also project management practices-related to scope, cost, schedule performance, and independent reviews.

    Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to review and revise EM's 2017 cleanup policy to include project management leading practices related to scope, cost, schedule performance, and independent reviews. (Recommendation 4)

    Agency Affected: Department of Energy

  5. Status: Open

    Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to replace its current EM Cleanup Policy with two separate project and program management policies that will incorporate earned value management best practices, as appropriate. In February 2020, EM officials stated that EM's forthcoming Cleanup Project Management Policy (expected to be completed in spring 2020) will require capital asset projects covered under the policy to use earned value management (EVM) systems that have been independently certified, which is an EVM best practice. However, EM officials told us that this policy will not require operations activities to follow EVM best practices. EM officials stated that EM is also considering including this requirement in its forthcoming Cleanup Program Management Policy (expected to be completed by the end of fiscal year 2020). In addition, EM officials told is that EM plans to require future end-state contracts to use EVM systems that have either been certified by the DOE Office of Project Management or been subject to a "compliance review" conducted by EM itself, depending on the dollar value of the contract.

    Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to update its cleanup policy to require that earned value management (EVM) systems be maintained and used in a way that follows EVM best practices. (Recommendation 5)

    Agency Affected: Department of Energy

  6. Status: Open

    Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to include requirements related to the categorization of level of effort work in the project and program management policies EM is developing.

    Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to develop a policy to ensure that work is categorized as level of effort only in appropriate, specified circumstances, such as when work is not measurable or when measurement is impractical. (Recommendation 6)

    Agency Affected: Department of Energy

  7. Status: Open

    Comments: DOE partially concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that DOE is in the process of developing a Cleanup Program Management Policy that will, among other things, incorporate changes relative to the integration of EVM data into performance metrics as appropriate. As of February 2020, EM officials told us that the new policy is expected to be completed by the end of fiscal year 2020. In February 2020, EM officials stated that EM plans to begin a new performance review process for operations activities that will include EVM-based performance metrics as part of annual reporting to the Assistant Secretary. The new process is expected to begin in October 2020, but EM officials have not determined whether this will be a requirement included in EM's forthcoming Cleanup Program Management Policy.

    Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to integrate EVM data into EM's performance metrics for operations activities. (Recommendation 7)

    Agency Affected: Department of Energy

 

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