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 05, 2019.
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Fast Facts

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.

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Highlights

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.

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Recommendations

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.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Energy 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)
Closed – Implemented
In November 2020, EM issued a Program Management Protocol to replace EM's 2017 cleanup policy. The protocol establishes requirements for classifying all of EM's cleanup work as either "project activities" or "operations activities." Project activities include both capital asset construction and demolition projects, both of which must adhere to DOE's order governing the management of capital assets. Operations activities include the remainder of EM's work, and include two subcategories of activities: (1) "mission activities," which are cleanup activities with discrete end points and measurable accomplishments that result in a reduction of future liabilities, such as decontamination, decommissioning, and legacy waste processing; and (2) "mission support activities," which are routine or recurring activities to support and enable mission activities, such as providing security. According to EM officials, EM worked with the DOE Office of Project Management in the context of developing the protocol. We determined that EM's new protocol contains requirements for classifying cleanup work as project activities or operations activities and thereby satisfies our recommendation.
Department of Energy 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)
Closed – Implemented
In November 2020, EM issued a Program Management Protocol to replace EM's 2017 cleanup policy. The protocol establishes requirements for classifying all of EM's cleanup work as either "project activities" or "operations activities." Project activities include both capital asset construction and demolition projects, both of which must adhere to DOE's order governing the management of capital assets. Operations activities include the remainder of EM's work, and include two subcategories of activities: (1) "mission activities," which are cleanup activities with discrete end points, such as decontamination, decommissioning, and legacy waste processing; and (2) "mission support activities," which are routine or recurring activities to support site management, such as providing security. In follow-up communications with GAO, EM officials stated that EM determined that no EM work has required reclassification following the publication of EM's new protocol. We determined that EM's approach--of issuing the new protocol and not reclassifying any of its operations activities--satisfies our recommendation for two reasons. First, EM's new protocol provides requirements for classifying EM's work as either capital asset projects or operations activities. Second, EM's provides an updated definition of operations activities to include cleanup work that is project-like, with discrete end points and measurable accomplishments, and applies key elements of project and program management practices to these activities. As we reported in February 2019, EM's former cleanup policy did not apply such practices to operations activities, which was a key rationale for this recommendation.
Department of Energy
Priority Rec.
This is a priority 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)
Closed – Implemented
In November 2020, EM issued a Program Management Protocol to replace EM's 2017 cleanup policy. The new protocol includes key elements of program management leading practices that we found EM's former cleanup policy lacked. The protocol applies some of the key elements complex-wide, and applies others on a site-specific basis. For example, according to EM's new protocol, EM now requires an EM Program Plan, which will include a description of the planned work at each of the sites and serve as a roadmap. The protocol also states that EM will develop and maintain an EM Program Life-Cycle Estimate, which is a comprehensive life-cycle cost estimate and associated integrated master schedule that, together, encompass all work that remains to complete EM's mission. The protocol also incorporates some site-specific program management leading practices, such as annually updating site-specific life-cycle cost and schedule estimates, and developing site-specific risk management plans and site/program peer reviews. The protocol also states that, should these evaluations identify performance concerns, a root cause analysis may be conducted. We determined that EM's protocol addresses a sufficient number of program management leading practices to satisfy our recommendation.
Department of Energy
Priority Rec.
This is a priority 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)
Closed – Implemented
In November 2020, EM issued a Program Management Protocol to replace EM's 2017 cleanup policy. The new protocol includes key elements of project management leading practices that EM's former cleanup policy lacked, and applies these practices to operations activities through EM's new end-state contracting and task order mechanisms. Specifically, EM's protocol discusses GAO's project management leading practices not as applied to operations activities per se, but to contracts or task orders, especially in relation to EM's End State Contracting Model, which EM will apply now to operations activities, among other things. For example, the protocol states that contracts, and any associated task orders, must be aligned to the EM mission, contain clear scope requirements, contain completion requirements and measures, and be supported by reliable cost estimates in accordance with cost estimating best practices and guidance. In addition, the protocol discusses, among other things, the application of contract planning and contract baselines, as well as the development of root cause analyses and corrective action plans, if contracts encounter cost overruns, schedule delays, missed or postponed milestones, or performance shortcomings. We determined that EM's approach--of considering contracts and task orders, which are used for operations activities, as projects that must follow project management leading practices--satisfies our recommendation.
Department of Energy 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)
Closed – Implemented
On November 6, 2020, EM issued a Program Management Protocol. One of the objectives of the protocol is to incorporate GAO's leading practices for program and project management. The protocol references using an EVM System (EVMS) as part of the contract management process. We determined that EM's approach-of considering contracts and task orders, which are used for operations activities, as projects that must follow project management leading practices-satisfies one of our other recommendations in this report. The document states that EVMS is the most common control system used by DOE EM and that the EVMS system must comply with Electronic Industries Alliance Standard (EIA) 748, which is considered a national standard for EVM. EIA 748 lists 32 guidelines that should be followed. Many of the GAO EVM best practices are Included in these 32 guidelines. One important part of EVM which is not included in any of the 32 guidelines of the EIA 748 is ongoing surveillance. However DOE includes this in the new protocol by stating that EM conduct periodic surveillance to ensure continuous compliance and validity of data and costs. We therefore determined that EM's approach satisfies our recommendation.
Department of Energy 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)
Closed – Implemented
On November 6, 2020, EM issued a Program Management Protocol, which replaces EM's former cleanup policy The protocol provides a general breakdown of EM's cleanup work into "project activities" or "operations activities." The protocol further breaks down operations activities into (1) "mission activities," which are cleanup activities with discrete end points, such as decontamination, decommissioning, and legacy waste processing; and (2 )"mission support activities," which are routine or recurring activities to support site management, such as providing security. The protocol states that characterizing work activities as level of effort will be minimized to the greatest extent possible. Specifically, level of effort work activities include the non-measurable elements of mission support activities, facility maintenance to maintain safe conditions, and storage activities. Moreover, the protocol states that, where possible, level of effort work should be reallocated as a component of an existing, discrete activity. We determined that EM's approach satisfies our recommendation.
Department of Energy 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)
Open
On November 6, 2020, EM issued a Program Management Protocol, which replaces EM's former cleanup policy, and among other things, discusses EM's plan to assess contractor performance on a monthly basis using contractor EVM data. We will continue to monitor EM's implementation of this recommendation. As of May 2022, EM has not yet demonstrated how it integrated EVM data into its performance metrics for operations activities.

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