NUCLEAR 

NONPROLIFERATION

NNSA Needs to 

Improve Its Program 

Management Policy 

and Practices

Report to Congressional Committees

September 2017

GAO-17-773

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-773, a report to 

congressional committees

September 2017

NUCLEAR NONPROLIFERATION

NNSA Needs to Improve Its Program Management

Policy and Practices

What GAO Found

The 4 selected subprograms from the National Nuclear Security Administration’s 

(NNSA) Office of Defense Nuclear Nonproliferation (DNN) GAO reviewed 

generally do not use selected program management leading practices to 

manage schedule and cost. According to generally recognized leading practices

from the Project Management Institute (PMI) and GAO, programs should (1) 

establish schedules necessary to achieve the program’s goal, (2) establish lifecycle cost estimates, and (3) measure performance against schedule and cost 

baselines. However, none of the DNN subprograms have schedule and cost 

estimates covering their planned life cycles and none measure performance 

against schedule and cost baselines. The following figure illustrates the extent to 

which the selected subprograms have established schedule and cost estimates 

compared to their planned life cycles.

Extent of Selected Defense Nuclear Nonproliferation Subprograms’ Schedule and Cost

Estimates Compared to Their Planned Life Cycles

NNSA officials said that the subprograms do not have schedules and cost 

estimates that cover their life cycles and do not measure performance against 

baselines, in part, because DNN management does not require such estimates 

or baseline measurements.

The lack of a requirement is consistent with the limitations in DNN’s revised 

program management policy, which does not address leading practices on 

establishing schedule estimates, estimating life-cycle costs, and measuring 

against such baselines. According to leading practices, in developing schedule 

and cost estimates a program should define assumptions tailored to the program

such as its life-cycle phases. Updating the DNN policy to include requirements 

and guidance on cost estimating and tracking performance against schedule and 

cost baselines could help ensure that NNSA managers and Congress have 

better information on how much DNN programs and subprograms may cost, the 

time they may need to achieve their goals, and how effectively they are being 

executed compared to plans.

View GAO-17-773. For more information, 

contact Shelby S. Oakley at (202) 512-3841 or 

oakleys@gao.gov.

Why GAO Did This Study

The threat posed by the proliferation of 

nuclear and radiological weapons 

remains a pressing national security 

challenge. DNN implements nuclear 

nonproliferation programs worldwide.

To carry out its mission, for fiscal year 

2018 DNN requested an appropriation 

of about $1.5 billion for its 4 major 

programs and their 13 subprograms.

A House Armed Services Committee 

report, accompanying a bill for the 

National Defense Authorization Act for 

Fiscal Year 2017, included a provision 

for GAO to review and assess DNN’s

project and program management

processes and systems. GAO’s report 

examines the extent to which (1) 

selected DNN subprograms use 

program management leading 

practices to manage schedule and cost

(2) DNN has incorporated leading 

practices in its revised program 

management policy.

GAO selected 4 DNN subprograms to 

review that had defined end dates 

and/or work scope and that GAO had 

not recently examined. GAO reviewed 

documentation on DNN and NNSA’s

program management policies and 

practices; reviewed selected leading 

practices published by PMI and GAO; 

and interviewed agency officials.

What GAO Recommends

GAO recommends that DNN revise its

program management policy to require 

DNN programs and subprograms to 

follow life-cycle program management, 

such as requiring life-cycle estimates 

and measuring against baselines. 

NNSA neither agreed nor disagreed 

with the recommendation but plans to 

take action to revise its policy.
Page i GAO-17-773 Nonproliferation Program Management

Letter 1

Background 6

Selected DNN Subprograms Generally Do Not Use Selected 

Leading Practices to Manage Schedule and Cost 8

DNN’s Program Management Policy Includes Some Leading 

Practices, but Does Not Address Life-Cycle Schedule and Cost 

Management 19

Conclusions 24

Recommendation for Executive Action 24

Agency Comments and Our Evaluation 25

Appendix I Objectives, Scope, and Methodology 30

Appendix II Scope and Completion Dates for the Highly Enriched Uranium Reactor 

Conversion Subprogram 33

Appendix III Scope and Completion Dates for the Radiological Security 

Subprogram’s Source Protection Component 36

Appendix IV Comments from the National Nuclear Security Administration 37

Appendix V GAO Contact and Staff Acknowledgments 40

Tables

Table 1: Selected Defense Nuclear Nonproliferation (DNN) 

Subprograms and Their Components 7

Table 2: U.S. Highly Enriched Uranium (HEU) Research Reactor 

Conversions in the Planned Scope of Work of The Office 

of Defense Nuclear Nonproliferation’s HEU Reactor 

Conversion Subprogram and Estimated Completion 

Dates, as of July 2017 33

Contents
Page ii GAO-17-773 Nonproliferation Program Management

Table 3: International Highly Enriched Uranium (HEU) Reactors 

and Facilities in the Planned Scope of The Office of 

Defense Nuclear Nonproliferation’s HEU Reactor 

Conversion Subprogram and Estimated Completion 

Dates, as of July 2017 34

Table 4: International Molybdenum 99 Reactor Conversions and 

Planned New U.S. Production Facilities in the Scope of 

The Office of Defense Nuclear Nonproliferation’s Highly 

Enriched Uranium Reactor Conversion Subprogram and 

Estimated Completion Dates, as of July 2017 35

Table 5: The Office of Defense Nuclear Nonproliferation 

Radiological Security Subprogram’s Work Scope 

Completed and Planned for the Radiological Source 

Protection Component for Fiscal Years 2004 through 

2033 36

Figures

Figure 1: NNSA’s Office of Defense Nuclear Nonproliferation, 

Major Programs, and Subprograms 2

Figure 2: Selected Defense Nuclear Nonproliferation 

Subprograms Estimated Life-Cycle Completion Dates 

and Years Covered by Their Schedule and Cost 

Estimates Starting in Fiscal Year 2017 10

Abbreviations

DNN Office of Defense Nuclear Nonproliferation

DOE Department of Energy

FYNSP Future Years Nuclear Security Program

HEU Highly Enriched Uranium

Mo99 Molybdenum 99

NNSA National Nuclear Security Administration

PMI Project Management Institute, Inc.

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Page 1 GAO-17-773 Nonproliferation Program Management

441 G St. N.W.

Washington, DC 20548

September 28, 2017

Congressional Committees

The threat of nuclear and radiological proliferation, including the concern 

that non-state actors or additional countries could obtain nuclear or 

radiological weapons, poses one of the greatest challenges to U.S. and 

international security. To address this threat, the National Nuclear 

Security Administration (NNSA)—a separately organized agency within 

the Department of Energy (DOE)—implements nuclear nonproliferation 

programs worldwide under its Office of Defense Nuclear Nonproliferation 

(DNN). DNN’s mission is to develop and implement policy and technical 

solutions to eliminate nuclear and radiological materials, enhance the 

security of nuclear material in place and during transport, and limit or 

prevent the spread of these materials, technology, and expertise related 

to nuclear and radiological weapons and programs around the world.1 To 

support this mission, for fiscal year 2018, DNN requested an 

appropriation of approximately $1.5 billion for its 4 major programs, which 

organize work under 13 subprograms, as shown in figure 1.

 1

Nuclear weapons-useable materials include highly enriched uranium and plutonium. 

Radiological materials are used worldwide for medical procedures, such as treating 

cancer and purifying blood, and for industrial processes in the oil and gas, aerospace, 

food sterilization, and other sectors. These materials could be fabricated into a “dirty 

bomb” or device to disperse radioactive materials.

Letter
Page 2 GAO-17-773 Nonproliferation Program Management

Figure 1: NNSA’s Office of Defense Nuclear Nonproliferation, Major Programs, and 

Subprograms

Note: DNN is led by a Deputy Administrator and each of its major programs and subprograms is led 

by an Assistant Deputy Administrator and Office Director, respectively. DNN subprograms manage 

projects and other activities under various components.

In recent years, we have reported on program management challenges in 

DOE and NNSA, including those within DNN. For example, in November 
Page 3 GAO-17-773 Nonproliferation Program Management

2014, we found that DOE and NNSA programs were not required to meet 

any cost-estimating best practices, such as developing a life-cycle cost 

estimate. We recommended, among other things, that DOE revise its 

departmental directives that apply to programs to require that DOE, 

NNSA, and its contractors develop cost estimates in accordance with best 

practices.2 We also found in November 2016 that DOE had not 

established a department-wide policy addressing internal control 

standards or leading practices related to program management, and we 

recommended that DOE develop such a policy.3 DOE is in the process of 

taking actions to address these recommendations or has plans to do so.4

At the time of our November 2016 review, we also learned that DNN did 

not have a program management policy in effect because its 2005 policy 

was outdated and fell out of use around 2010.

In February 2017, DNN approved a revised program management 

policy.5 The revised policy outlines program management processes, 

roles, and responsibilities for DNN programs and subprograms. The 

policy requires that program management functions be conducted over 

the next 5 fiscal years, referred to as the Future Years Nuclear Security 

 2

DOE directives are the department’s primary means to set, communicate, and 

institutionalize policies, requirements, responsibilities, and procedures for departmental 

elements (including NNSA) and contractors. DOE classifies its directives into several 

types, including orders and guides. GAO, Project and Program Management: DOE Needs 

to Revise Requirements and Guidance for Cost Estimating and Related Reviews, 

GAO-15-29 (Washington, D.C.: Nov. 25, 2014). 

3

GAO, Program Management: DOE Needs to Develop a Comprehensive Policy and 

Training Program, GAO-17-51 (Washington, D.C.: Nov. 21, 2016). 

4

Regarding the recommendation that DOE develop a department-wide program 

management policy, DOE indicated that it will address the recommendation as part of its 

effort to meet the requirements of the Program Management Improvement Accountability 

Act. Pub. L. No. 114-264, 130 Stat. 1371 (2016). The act requires, among other things, 

that the Office of Management and Budget adopt government-wide standards, policies, 

and guidelines for program and project management for agencies no later than December 

14, 2017 and for certain agencies, including DOE, to implement program management 

policies established by the agency pursuant to the Office of Management and Budget 

standards, policies, and guidelines.

5

DNN’s program management policy is titled Management System Description although it 

is referred to as a policy in the document and by officials. Department of Energy, National 

Nuclear Security Administration, Office of Defense Nuclear Nonproliferation, Management 

System Description, Feb. 17, 2017.
Page 4 GAO-17-773 Nonproliferation Program Management

Program (FYNSP).6 In addition, the policy’s objectives include 

establishing a DNN-wide policy that incorporates leading practices for 

program management and that facilitates the implementation of methods 

for programs and subprograms to monitor, measure, analyze, and 

improve management processes.

Program management involves aligning multiple components to achieve 

the program’s goals and allows for optimized or integrated cost, schedule, 

and effort.7 The Project Management Institute (PMI) and GAO have 

established standards and guides that are generally recognized as 

leading practices for program management.8 When organizations apply 

leading program management practices they may be able to enhance 

their chances of achieving success across a range of programs.9

A House Armed Services Committee report, accompanying a bill for the 

National Defense Authorization Act for Fiscal Year 2017, included a 

provision for us to review and assess DNN’s project and program 

management processes and systems.10 Our report examines the extent 

to which (1) selected DNN subprograms use program management 

leading practices to manage schedule and cost, and (2) DNN has 

 6

NNSA submits an annual justification of the President’s budget request that provides 

program plans and budget estimates for the next 5 years, called the FYNSP. The FYNSP 

documents, submitted to Congress each year, contain the estimated expenditures and 

proposed appropriations for the fiscal year for which the budget request is being submitted 

and the four succeeding fiscal years, covering nuclear defense programs, naval reactors, 

and defense nuclear nonproliferation. 

7

Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013.

8

PMI is a not-for-profit association that provides global standards for, among other things, 

project and program management. These standards are utilized worldwide and provide 

guidance on how to manage various aspects of projects, programs, and portfolios. PMI 

defines program management as the application of knowledge, skills, tools, and 

techniques to a program to meet the program requirements and to obtain benefits and 

control not available by managing projects individually. Project Management Institute, Inc., 

The Standard for Program Management, Third Edition, 2013. GAO, GAO Cost Estimating 

and Assessment Guide: Best Practices for Developing and Managing Capital Program 

Costs, GAO-09-3SP (Washington, D.C.: March 2009); and GAO Schedule Assessment 

Guide: Best Practices for Project Schedules, GAO-16-89G (Washington, D.C.: December 

2015). GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).

9

Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013. 

10H.R. Rep. No. 114-537, at 399 (2016). 
Page 5 GAO-17-773 Nonproliferation Program Management

incorporated program management leading practices in its revised 

program management policy. 

To conduct this work, we reviewed 4 selected DNN subprograms – the 

Nuclear Material Removal and Highly Enriched Uranium (HEU) Reactor 

Conversion subprograms, which DNN manages under its Material 

Management and Minimization program and the Radiological Security 

and International Nuclear Security subprograms, which DNN manages 

under its Global Material Security program. We selected these 

subprograms for review because they had defined start dates, end dates, 

and/or work scope and were not the subject of other ongoing or recently 

completed GAO reviews.11 The information we obtained from these 

subprograms is not generalizable, but we obtained important insights into 

DNN’s schedule and cost management of these subprograms.

To examine the extent to which the selected DNN subprograms use 

program management leading practices to manage schedule and cost, 

we identified selected leading practices from PMI and GAO.12 The 

selected leading practices we identified were the use of a master 

schedule necessary to achieve a program’s goals, cost estimates that 

cover the full life cycle of a program, and schedule and cost baselines to 

measure performance. We reviewed documentation on the use of these 

practices by the 4 selected DNN subprograms including documentation 

on their schedule and cost estimates and their use of baselines, and we 

compared the documentation to the leading practices. We also 

interviewed NNSA officials who manage the selected DNN subprograms 

about the use of these practices.

To examine the extent to which DNN has incorporated leading practices 

into its revised program management policy, we reviewed the revised 

DNN policy and interviewed NNSA officials about the development of the 

new policy. We also reviewed program management plans for the 

selected subprograms. We reviewed program management leading 

practices identified by PMI in The Standard for Program Management and 

 11We did not include “capital asset acquisition projects” in the scope of our review. DOE 

defines capital assets as land, structures, equipment, and intellectual property, which are 

used by the federal government and have an estimated useful life of 2 years or more. For 

capital asset projects, DOE and NNSA have specific requirements that do not apply to 

other types of projects.

12Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013; GAO-09-3SP; and GAO-16-89G. 
Page 6 GAO-17-773 Nonproliferation Program Management

by GAO in its schedule and cost guides and federal internal control 

standards.13 We compared these practices with DNN guidance and 

requirements contained in the revised DNN policy. During interviews with 

NNSA officials, we obtained their views on why specific practices were 

included in the revised policy and others were not.

We conducted this performance audit from June 2016 to September 2017 

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 and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Appendix I provides more 

detail on our scope and methodology.

Within DNN, the work of the four selected subprograms—Nuclear 

Material Removal, HEU Reactor Conversion, Radiological Security, and 

International Nuclear Security—focuses on efforts to remove and dispose 

of excess nuclear material from civilian sites worldwide, convert civilian 

research reactors to the use of non-weapons-useable nuclear fuel, secure 

radiological materials at their source in the United States and abroad, and 

improve the security of weapons-useable nuclear material in key 

countries. The selected subprograms organize their work in programmatic 

areas which we refer to as components, and under each component the 

subprograms manage projects. Table 1 below describes the work of each 

subprogram and the components in which the subprogram organizes its 

work scope.

 13Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013; GAO-09-3SP; GAO-16-89G; and GAO-14-704G. 

Background

DNN Selected 

Subprograms
Page 7 GAO-17-773 Nonproliferation Program Management

Table 1: Selected Defense Nuclear Nonproliferation (DNN) Subprograms and Their Components 

Subprogram Description 

Nuclear Material Removal The subprogram’s work began in 1996 and focuses on removing or confirming the disposition of excess 

highly enriched uranium (HEU) and plutonium used worldwide for civilian purposes. These nuclear 

materials originated in the United States, Russia, or certain other countries. The subprogram organizes 

its work in three components: (1) U.S.-origin material removal, (2) Russian-origin material removal, and 

(3) gap material removal, which addresses material that falls outside the first two categories. 

HEU Reactor Conversion The subprogram’s work began in 1978 and focuses on converting civilian HEU research and test 

reactors and isotope production facilities to use of low-enriched uranium or verifying their shutdown. The 

subprogram also works to establish new non-HEU Molybdenum 99 (Mo99) medical isotope production 

facilities in the United States. The subprogram organizes its work under three components: (1) U.S. 

reactor conversions, (2) international reactor conversions, and (3) international Mo99 reactor 

conversions and new U.S. non-HEU Mo99 production facilities.a

Radiological Security The subprogram’s work began in 2004 and was reorganized in 2015 under the current subprogram, 

which focuses on protecting radiological sources through security upgrades at buildings that hold highpriority radiological material worldwide, removing excess and unwanted sealed radiological sources from 

locations in the United States, and expanding support for the voluntary replacement of high-activity 

radiological sources with alternative nonradioisotopic technologies. The subprogram organizes its work 

under three components: (1) protect radiological sources, (2) remove and dispose of radiological 

sources, and (3) encourage the adoption of nonradioisotopic or non-source-based technologies. 

International Nuclear 

Security

The subprogram was formed in 2015 from the consolidation of the nuclear security work of two 

predecessor DNN programs. It focuses on working with partners to enhance security of nuclear material 

in place and during transport by providing support for nuclear material protection, control, and accounting 

upgrades and, when applicable, supports the sustainability of U.S.-funded security upgrades. The 

subprogram organizes its work under two components: (1) nuclear security cooperation, and (2) nuclear 

security engagement. 

Source: GAO analysis of National Nuclear Security Administration information. | GAO-17-773

a

Research and test reactors – also called “non-power” reactors – are nuclear reactors primarily used 

for research, training, and development. These reactors contribute to almost every field of science, 

including physics, chemistry, biology, medicine, geology, archaeology, and environmental sciences. 

Most research and test reactors are at universities or colleges in the United States. The Department 

of Energy also manages research reactors at several national laboratories.

PMI’s The Standard for Program Management and GAO’s schedule and 

cost guides identify program management leading practices related to 

schedule and cost estimating and measuring performance against 

baselines, as follows:

• PMI guidelines. According to PMI’s guidelines, programs practice 

life-cycle management, which involves schedule and financial 

management throughout the course of the program’s life-cycle 

phases—program definition, benefits delivery, and closure. In 

particular, PMI states that in conducting program schedule 

management, programs use a master schedule that integrates the 

schedules of program components necessary to achieve the 

Program Management 

Leading Practices Related 

to Schedule and Cost 

Management
Page 8 GAO-17-773 Nonproliferation Program Management

program’s goal.14 In program financial management, program cost 

estimates should be clearly defined and should consider the full lifecycle costs of the program. According to PMI, programs should also 

establish and measure performance against baselines for both 

schedule and cost.15

• GAO schedule and cost guides. GAO’s schedule and cost guides, 

which draw from federal organizations and industry, define best 

practices about the processes needed for the development and 

management of high-quality and reliable schedule and cost 

estimates.16 Similar to PMI’s guidelines, according to the GAO guides, 

programs should establish and use an integrated master schedule, 

establish cost estimates that cover the full life cycle of the program, 

document and define assumptions tailored to the program, 

incorporate analysis of program risk and uncertainty in schedule and 

cost estimates, and manage a program’s schedule and cost by 

measuring against a baseline.17

The four DNN subprograms we chose for review generally do not use 

selected leading program management practices to manage schedule 

and cost. Specifically, at the time of our review, none of the subprograms 

had schedule and cost estimates that encompassed its entire life cycle, 

although one subprogram planned to develop such estimates for its 

recently-extended life cycle. In addition, none of the selected 

subprograms measure their overall schedule and cost performance 

against baseline estimates. NNSA officials said that the subprograms had 

not developed schedule and cost estimates that cover their life cycles and 

did not measure the subprograms against baselines due, in part, to 

uncertainty in planning scope and schedules that rely on the cooperation 

of other countries. DNN also does not require subprograms to have such 

 14Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013.

15Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013.

16GAO-16-89G and GAO-09-3SP. 

17Risk and uncertainty refer to the fact that because schedule durations and cost 

estimates are forecasts, there is always a chance that the actual schedule and cost will 

differ from the estimate. Risk and uncertainty analysis can quantify potential error in 

estimating schedule and cost estimates and can involve the use of statistical analysis 

tools to model such effects as schedules slipping and proposed solutions not meeting user 

needs.

Selected DNN 

Subprograms 

Generally Do Not Use 

Selected Leading 

Practices to Manage 

Schedule and Cost
Page 9 GAO-17-773 Nonproliferation Program Management

estimates or to measure performance against schedule and cost 

baselines. Following these practices, however, would provide NNSA 

managers and other stakeholders more complete information to evaluate 

how much the subprograms may cost to achieve their goals, the amount 

of time they may need to achieve these goals, and their actual versus 

planned performance.

According to leading practices, programs should (1) establish a master 

schedule that integrates the schedules of program components 

necessary to achieve the program’s goal, such as specified performance 

to be achieved over a defined life cycle, (2) determine costs that consider 

the full life-cycle costs of the program, and (3) measure performance 

against baselines for both schedule and cost. Figure 2 illustrates the 

extent to which the selected subprograms have established schedule and 

cost estimates compared to their planned life-cycle completion dates, if 

any.
Page 10 GAO-17-773 Nonproliferation Program Management

Figure 2: Selected Defense Nuclear Nonproliferation Subprograms Estimated LifeCycle Completion Dates and Years Covered by Their Schedule and Cost Estimates 

Starting in Fiscal Year 2017

a

Several of the subprogram’s projects are scheduled to complete nuclear material removals and 

dispositions in fiscal year 2022, but final close out activities for the projects will carry over into fiscal 

year 2023.

b

The subprogram’s cost estimate included the remaining life-cycle costs of two of the subprogram’s 

three components but not the remaining life-cycle costs of a third component that has an estimated 

completion date of fiscal year 2035.

The Nuclear Material Removal subprogram had schedule and cost 

estimates that encompassed all three of its subprogram components 

through the subprogram’s previously planned completion date of fiscal 

year 2022. However, the subprogram had yet to update its schedule and 

cost estimate through its new planned completion date of fiscal year 

2027, which was established in May 2017. The subprogram did not have 

readily available information on performance against its former schedule

and cost estimates. Specifically:

Nuclear Material Removal
Page 11 GAO-17-773 Nonproliferation Program Management

• Schedule. As of April 2017, the subprogram’s schedule, which 

encompassed all three subprogram components, included 52 ongoing 

and planned projects with estimated completion dates by the end of 

fiscal year 2022 for most of these projects to reach a goal to remove 

or disposition a total of 8,466 kilograms of nuclear material.18 In May 

2017, the subprogram extended its life cycle from fiscal year 2022 to 

fiscal year 2027 but at the time of our review had yet to update its 

schedule of planned projects to be completed during fiscal years 2023 

through 2027. According to NNSA officials, they extended the 

subprogram’s life cycle in part because certain projects planned to be 

completed by fiscal year 2022 were delayed and the subprogram’s 

work was expanded.19

• Cost. The subprogram had a cost estimate for its planned work 

through fiscal year 2022 but at the time of our review had yet to 

update its cost estimate for the overall subprogram through its new 

planned completion date of fiscal year 2027.20 Specifically, as of June 

2017, the subprogram had a cost estimate of about $595 million, 

according to our analysis of information provided by the subprogram. 

This estimate covered the planned work scope of all three 

subprogram components to be completed during fiscal year 2017 

through 2022. The subprogram, however, did not have estimated 

costs for completing work scope planned during fiscal years 2023 

through 2027. According to NNSA officials, as of June 2017, they 

were developing a cost estimate for the remaining years, although the 

officials did not specify when the cost estimate would be completed.

• Measuring performance against baselines. The subprogram did 

not measure its overall performance against schedule and cost 

baselines. NNSA reported to Congress in July 2014 that the 

 18Several of the subprogram’s projects are scheduled to complete nuclear material 

removals and dispositions in fiscal year 2022, but final close out activities for the projects 

will carry over into fiscal year 2023.

19The Nuclear Material Removal subprogram reported in NNSA’s fiscal year 2018 

congressional budget justification that its cumulative end-point metric was 7,680 kilograms 

of nuclear material by fiscal year 2027. According to NNSA officials, the subprogram sets 

a cumulative performance target that is lower and more conservative than the total 

amount of nuclear material identified for potential removal in its planned work scope 

because the subprogram cannot successfully execute removals without the explicit 

agreement and cooperation of international partners. Therefore, the subprogram must 

assume a degree of risk when setting out-year performance targets.

20The Nuclear Material Removal subprogram provided information that showed the 

subprogram’s actual costs from fiscal year 2007 through 2016 were about $1.11 billion.
Page 12 GAO-17-773 Nonproliferation Program Management

subprogram planned to remove or disposition approximately 3,000 

kilograms of nuclear material by fiscal year 2022 at an estimated cost 

of about $600 million.21 However, the subprogram did not track 

information on its performance against the cost estimate. According to 

NNSA officials, removal projects have too many uncertain costs. 

Instead, NNSA officials said that they update the subprogram’s lifecycle cost each year as part of the annual planning for the next fiscal 

year’s budget request. Until the subprogram develops schedule and 

cost estimates to support the recently revised life-cycle completion 

date of fiscal year 2027, it does not have the baselines it needs to 

measure its overall schedule and cost performance. Although the 

subprogram did not measure its overall performance against 

established schedule and cost baselines, according to monthly 

performance reports, the subprogram baselined and measured the 

schedule performance of individual removal projects by tracking the 

difference in number of days between forecasted project completion 

dates and baseline completion dates. However, the subprogram did 

not have information that integrated project performance information 

to provide an overall picture of schedule performance for the entire 

subprogram.

The HEU Reactor Conversion subprogram had schedule and cost 

estimates that covered the remaining work scope to complete two of three 

subprogram components by fiscal year 2033 but not for a third 

component estimated to be completed in fiscal year 2035. The 

subprogram also did not measure its overall performance against 

schedule and cost baselines. Specifically:

• Schedule. The HEU Reactor Conversion subprogram did not have a 

schedule for the overall subprogram through completion of its life 

cycle. Instead, the subprogram had a schedule for all work scope 

planned for the 5-year FYNSP, which included the schedule for the 

remaining work to complete one of the three subprogram 

 21NNSA reported that the total cost to remove or disposition the targeted 3,000 kilograms 

was estimated to be about $1.1 billion, of which $600 million would come from the United 

States and $500 million would come from international partners, over an estimated 8-year 

period. Department of Energy, National Nuclear Security Administration, The Four Year 

Effort: Progress Report and Remaining Challenges, Report to Congress (Washington, 

D.C.: July 2014). 

HEU Reactor Conversion
Page 13 GAO-17-773 Nonproliferation Program Management

components–Molybdenum 99 (Mo99) efforts.22 Beyond the FYNSP 

planning period, the subprogram has an estimated completion date of 

fiscal year 2033 for a second component—U.S reactor conversions—

and has developed a schedule for completion of the component. For 

the third subprogram component—international reactor conversions—

the subprogram estimates a fiscal year 2035 completion date for its 

remaining work scope to convert or verify the shutdown of 44 

international reactors, but it had not developed a complete schedule 

to meet that date. Specifically, the subprogram’s schedule was not upto-date for 22 of the 44 international reactors in the subprogram’s 

planned work scope to support the estimated fiscal year 2035 

completion date for these reactors. Instead, in the subprogram’s 

schedule, these reactors had estimated completion dates by fiscal 

year 2030. NNSA officials explained that the schedule was not up-todate for these reactors because the reactors are in countries where 

the subprogram cannot currently plan or implement the conversions 

due to limitations in cooperation with these countries. For example, 

DNN cannot plan the schedule for conversion of reactors in Russia 

that are in the subprogram’s scope until the United States and Russia 

resume joint nuclear security activities that the United States 

discontinued following Russia’s invasion of Ukraine in 2014. NNSA 

officials said that the 2035 date is their best judgment of the earliest 

date when the subprogram could complete the conversions or verify 

certain reactors’ shutdowns based on the assumption that the United 

States and Russia may resume nuclear security cooperation in the 

2020s. Because of the high degree of uncertainty with this date, the 

subprogram did not update the schedule to reflect the 2035 date, 

according to the officials. Appendix II provides tables that list the 

planned reactor and facility projects in the HEU Reactor Conversion 

subprogram, their locations, and estimated conversion or shutdown 

completion dates.

• Cost. The HEU Reactor Conversion subprogram did not have a lifecycle cost estimate for the overall subprogram, but had overall lifecycle cost estimates for two of the three subprogram components.23

The subprogram had cost estimates that totaled approximately $1.1 

 22This component includes 11 projects: 7 projects to convert international Mo99 isotope 

production reactors from using HEU to using low-enriched uranium and 4 projects to 

accelerate the establishment of reliable, commercial production of non-HEU-based Mo99 

in the United States. Appendix II provides a list of these projects in table 4.

23The HEU Reactor Conversion subprogram provided information that showed the 

subprogram’s actual costs from fiscal year 2007 through 2016 were about $895 million.
Page 14 GAO-17-773 Nonproliferation Program Management

billion through fiscal year 2033 and that included the remaining 

estimated life-cycle costs for the subprogram’s U.S. reactor 

conversions component and its Mo99 efforts. For the third 

component—international reactor conversions—the subprogram only 

estimated costs for the 5-year FYNSP, not through the estimated

completion date for the component of fiscal year 2035. According to 

NNSA officials, developing a cost estimate that includes all remaining 

international reactor conversions through 2035 would be challenging 

because the costs for these projects are highly uncertain and vary 

depending on the willingness of each country to cooperate as well as 

the unique technical, regulatory, and other factors that vary for each 

reactor in each country. The subprogram, however, had established 

estimated life-cycle budgets for completing the conversion or verifying 

the shutdown of each reactor in its work scope, which could be used, 

along with other information, to develop a cost estimate for the 

subprogram component.

• Measuring performance against baselines. The subprogram did

not measure overall subprogram performance against schedule and 

cost baselines. Specifically, as mentioned above, the subprogram did 

not have schedule and cost estimates for the overall subprogram that 

it could use to establish baselines to measure the performance of the 

overall subprogram. Although the subprogram had life-cycle estimates 

for its U.S. reactors and Mo99 components, the subprogram did not 

use these estimates as baselines to measure the overall subprogram 

components’ performance. The subprogram measured schedule 

performance of individual projects under its three components against 

baselines by tracking the difference in number of days and months 

between forecasted project completion dates and baseline completion 

dates. However, it did not integrate and roll up the project information 

to provide an assessment of its overall schedule performance. In 

addition, the subprogram baselined and measured cost performance 

of the U.S. High Performance Research Reactor project—which 

constitutes six of the seven reactors under its U.S. reactor 

conversions component—by tracking changes in the project’s 

estimated life-cycle cost.24 However, the subprogram did not have 

similar information that tracked changes in cost estimates of other 

projects under its three components.

 24According to the information provided by the subprogram, in fiscal year 2010, the U.S. 

High Performance Research Reactor project had an estimated cost of about $463 million 

from fiscal years 2010 through 2019, whereas its current estimated life-cycle cost at 

completion is about $1.15 billion with an estimated completion date of fiscal year 2033. 
Page 15 GAO-17-773 Nonproliferation Program Management

The Radiological Security subprogram did not have schedule and cost 

estimates for three components through the subprogram’s planned 

completion date in fiscal year 2033. The subprogram also did not 

measure overall subprogram performance against schedule and cost 

baselines. Specifically:

• Schedule. The subprogram has an estimated completion date of 

fiscal year 2033 but did not have an overall schedule that covered its 

three components for meeting the 2033 date. Instead, the subprogram 

had a schedule that covered work to be completed under its three 

components during the 5-year FYNSP (fiscal years 2017 through 

2021). Specifically, for two of the three subprogram components—

radiological source removal and nonradioisotopic technologies—the 

subprogram has not established specific work scope and schedules 

beyond fiscal year 2021 because of uncertainty about the future. For 

example, according to the subprogram’s director, planning the 

adoption of nonradioisotopic technologies is uncertain because the 

timing of when such technologies can be adopted depends, in part, on 

regulations and international laws, making it challenging for the 

subprogram to define the scope of work. For the third subprogram 

component—radiological source protection—the subprogram has an 

estimated completion date of fiscal year 2033 to reach a total target to 

secure 4,394 buildings in its inventory of sites worldwide with highpriority radiological sources. However, the subprogram had not 

developed a schedule of specific projects to be completed beyond the 

5-year FYNSP to meet that date and target. NNSA officials said that 

they are often uncertain when a project will be able to start because it 

depends greatly on circumstances in each country. Appendix III 

provides the Radiological Security subprogram’s planned work scope 

for the radiological source protection component from fiscal years 

2017 through 2033.

• Cost. The Radiological Security subprogram did not have a life-cycle 

cost estimate for the overall subprogram through its estimated 

completion date of fiscal year 2033.25 Specifically, the subprogram 

had a cost estimate of about $849 million for all three components 

covering the 5-year FYNSP. However, for two of the three 

subprogram components—radiological source removal and 

nonradioisotopic technologies—the subprogram had not developed 

cost estimates beyond the 5-year FYNSP because, as mentioned 

 25The Radiological Security subprogram provided information that showed the 

subprogram’s actual costs from fiscal year 2007 through 2016 were about $1.3 billion.

Radiological Security
Page 16 GAO-17-773 Nonproliferation Program Management

above, it had not developed work scope for these components in the 

out-years. For example, according to the subprogram’s director, the 

subprogram’s radiological source removal component depends on the 

voluntary participation of users of radiological sources that register 

their sources with the subprogram. Therefore, the subprogram cannot 

estimate the number of sources to be removed in out-years. For the 

third subprogram component—radiological protection—the 

subprogram had assumed a stable budget to complete its target to 

secure 4,394 buildings by fiscal year 2033. However, according to the 

director of the subprogram, this budget assumption was not intended 

to be a reliable life-cycle cost estimate.

• Measuring performance against baselines. As mentioned above, 

the subprogram did not have schedule and cost estimates for the 

overall subprogram needed to establish baselines to measure their 

overall performance. The subprogram, however, baselined and 

measured the schedule performance of individual projects under its 

three components by tracking the difference in number of days 

between forecasted project completion dates and baseline completion 

dates. The subprogram, however, did not integrate and roll up the 

project schedule performance information to provide performance 

information for the overall subprogram.

The International Nuclear Security subprogram maintained schedule and 

cost estimates for the 5-year FYNSP (fiscal years 2017 through 2021) but 

did not have schedule and cost estimates for work scope in the years 

beyond the FYNSP. In addition, the subprogram did not measure overall 

performance against baselines. Specifically:

• Schedule. The International Nuclear Security subprogram had not 

established a life-cycle schedule for the overall subprogram or its two 

component efforts, as it had not identified specific work scope or endpoint targets beyond fiscal year 2021 and considers its mission to be 

enduring (i.e. without an end-date). Instead, the subprogram had only 

estimated a schedule for work scope in individual countries during the 

5-year FYNSP. According to the subprogram director, the subprogram 

is expected to operate indefinitely and continue as long as nuclear 

materials exist to improve security in countries possessing such 

materials. However, the subprogram had not planned project-specific 

work scope in years beyond the FYNSP because, according to the 

subprogram director, it is difficult to estimate the subprogram’s likely 

level of foreign counterpart engagement in individual countries beyond 

5 years.

International Nuclear Security
Page 17 GAO-17-773 Nonproliferation Program Management

• Cost. Because it has not identified out-year work scope, the 

International Nuclear Security subprogram did not have an overall lifecycle cost estimate and only had an estimate of about $530 million for 

the work to be completed during the 5-year FYNSP period.26

According to NNSA officials, they have not developed a cost estimate 

for work scope in the years beyond the FYNSP because assumptions 

about future work will likely change due to the uncertainty in 

relationships with partner countries.

• Measuring performance against baselines. The International 

Nuclear Security subprogram did not measure performance of the 

subprogram against schedule and cost baselines. Specifically, as 

mentioned above, the subprogram did not have the schedule and cost 

estimates for the subprogram’s life cycle beyond fiscal year 2021 

needed to establish baselines to measure its overall performance. In 

addition, the subprogram did not use its 5-year FYNSP estimates as 

baselines to measure performance. Instead, the subprogram updates 

the FYNSP estimates each year in planning the next fiscal year’s 

budget request. Moreover, unlike the other three subprograms, the 

International Nuclear Security subprogram did not have project 

schedule baseline information that could be integrated and rolled up 

to provide information on the performance of the overall subprogram.

In general, NNSA officials explained that uncertainty in planning the 

selected subprograms’ work scope or schedules, particularly for 

components with projects that rely on the cooperation of foreign 

countries, was among the reasons they did not have schedule and cost 

estimates that covered the subprograms’ life cycles or that went beyond 

the 5-year required planning period. In addition, according to these 

officials, DNN senior management does not require subprograms to 

establish schedule and cost estimates that cover the entire subprogram 

life cycle and to use these estimates as baselines to measure 

subprogram performance.

 26As mentioned above, the International Nuclear Security subprogram was formed in 2015 

when NNSA consolidated nuclear security work from two predecessor programs. 

According to information provided by the International Nuclear Security subprogram, 

actual costs of the subprogram and the nuclear security work implemented by the 

predecessor programs totaled about $2.64 billion from fiscal years 2007 through 2016. 

The two predecessor programs were the former Material Protection Control and 

Accounting program, itself part of a larger former DNN program called International 

Material Protection and Cooperation program, and the Nonproliferation and Arms Control 

program.
Page 18 GAO-17-773 Nonproliferation Program Management

However, uncertainty should not prevent these subprograms from 

establishing more complete or longer-term estimates to account for the 

time and resources they need to achieve their goals. As mentioned 

above, without such estimates, the subprograms do not have the baseline 

information they need to track their performance. According to leading 

practices, developing reliable schedule and cost estimates can be 

achieved by following steps that address data limitations and risks and 

uncertainties for a program. For example, according to the GAO schedule 

guide, a reliable schedule should reflect all of a program’s activities and 

recognize that uncertainties and unknown factors in schedule estimates 

can stem from, among other things, data limitations.27 In addition, 

according to the GAO cost guide, the cost-estimating process involves 

defining and documenting assumptions that are tailored to the specific 

program, such as about the program’s life-cycle phases, political issues, 

or technology development.28 Assumptions should be based on historical 

data to minimize uncertainty and risk. These same assumptions should 

also be used to develop the program schedule. For management to make 

good decisions, the program estimate must reflect the degree of 

uncertainty so that a level of confidence can be given about the 

estimate.29 Accordingly, because assumptions defined for a particular 

program’s schedule and cost estimate can vary, they should always be 

inputs to the program’s risk analyses of cost and schedule.

Programs use different methods to quantify uncertainty and risk in 

developing a schedule or cost estimate. DOE’s cost estimating guide 

describes approaches for programs to incorporate risk and uncertainty in 

cost estimates such as the use of lower- and upper-bound cost ranges 

that are developed based on risk analysis.30 Other NNSA programs use 

these approaches in developing schedule and cost estimates for highly 

uncertain, long-term program plans. In particular, NNSA’s Office of 

Defense Programs develops and reports high- and low-range cost 

estimates for elements of NNSA’s nuclear weapons modernization 

 27GAO-16-89G. 

28GAO-09-3SP. 

29GAO-09-3SP. 

30The guide is primarily intended to provide suggested, non-mandatory approaches for 

use in managing DOE’s capital asset acquisition projects. However, the guide states that 

the suggested approaches could be used in all programs and projects in DOE for 

preparing cost estimates. DOE, Cost Estimating Guide, DOE G 413.3-21 (Washington, 

D.C.: Oct. 22, 2015). 
Page 19 GAO-17-773 Nonproliferation Program Management

programs in part to account for the uncertainty in these long-term 

program estimates.31 As mentioned above, such estimates would provide 

NNSA managers and other stakeholders information to help evaluate 

resources and compare the costs and benefits of different programs and 

priorities. Because the selected subprograms do not measure their overall 

schedule and cost performance against baselines, NNSA managers, 

stakeholders, and Congress have incomplete information about these 

subprograms’ actual-versus-planned schedule and cost performance over 

their duration and are, therefore, at risk of being unable to assess when a 

subprogram is likely to be completed or whether it will cost more or less 

than planned.

DNN’s 2017 revised policy includes new sections that address leading 

practices on risk and quality management that all DNN programs and 

subprograms should follow.32 NNSA officials said they added these 

sections based on their review of leading practices in PMI’s The Standard 

for Program Management and GAO’s Standards for Internal Control in the 

Federal Government to ensure these leading practices were incorporated 

and required for DNN programs.

• Risk management. According to leading practices on risk 

management, programs should have processes to manage risks, 

including processes to identify, assess, and respond to risks. In the 

 31For example, see National Nuclear Security Administration, Fiscal Year 2017 Stockpile 

Stewardship and Management Plan (Washington, D.C.: March 2016).

32DNN, Management System Description, Feb. 17, 2017.

DNN’s Program 

Management Policy 

Includes Some 

Leading Practices, 

but Does Not Address 

Life-Cycle Schedule 

and Cost 

Management

DNN’s Revised Policy 

Includes Leading 

Practices on Risk and 

Quality Management
Page 20 GAO-17-773 Nonproliferation Program Management

revised DNN policy, under a new section on risk management, all 

DNN programs and subprograms are required to prepare risk 

management plans to help identify, analyze, handle, and monitor risk. 

For example, a DNN subprogram may identify the risk of schedule 

slippage due to political constraints in working with foreign countries 

and could incorporate and monitor that risk in planning.

• Quality management. According to program management leading 

practices on quality management, program quality should be 

continuously monitored.33 A new DNN policy section on continual 

improvement requires DNN programs and subprograms to plan and 

implement methods, such as program evaluations and management 

assessments, in order to monitor and improve processes. For 

example, a DNN subprogram may use an independent review by the 

NNSA Office of Management and Budget to help improve its program 

management processes, such as how it tracks cost, scope, and 

schedule. The revised policy also outlines steps for corrective actions 

to be taken when noncompliance is detected. These steps range from 

determining the cause of noncompliance to reviewing the 

effectiveness of corrective actions taken.

These new sections added requirements for DNN program management 

that were not previously documented. For example, in the prior policy, risk 

management was not a requirement for DNN programs and 

subprograms.34 In addition, NNSA officials said that they added the 

continual improvement section to the revised policy after reviewing PMI’s 

practices on quality assurance, which they believed would clarify 

responsibilities regarding management assessments and independent 

reviews.

The revised DNN policy does not address or require leading practices on 

life-cycle schedule and cost management for DNN programs or 

subprograms. Specifically, the revised policy does not outline 

requirements for programs or subprograms to establish life-cycle cost 

estimates or measure performance against schedule or cost baselines. 

Instead, the revised policy provides requirements on schedule and cost 

management limited to the NNSA budgeting process covering the 5-year 

 33Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013.

34We did not assess the risk management processes used by the selected DNN 

subprograms prior to the publication of the revised policy as part of our review.

The Revised DNN Policy 

Does Not Include Leading 

Practices on Life-Cycle 

Schedule and Cost 

Management
Page 21 GAO-17-773 Nonproliferation Program Management

FYNSP. For example, according to the revised DNN policy, programs and 

subprograms must conduct program management activities, such as

budget formulation, in alignment with anticipated resources in the FYNSP. 

Additionally, the policy requires programs and subprograms to establish 

performance measurement data and track cost or schedule performance, 

but only within the FYNSP.

According to leading practices, life-cycle management is important to 

program management and includes schedule and cost management 

activities that span the duration of the program. According to PMI, all 

programs, regardless of length, have life cycles; furthermore, leading 

practices indicate that activities related to managing the schedule, cost, 

and scope of a program should be conducted for the life of the program.35

For example, leading practices call for calculating cost estimates as close 

to the beginning of a work effort as possible that consider the full program 

life cycle, and then documenting this baseline to measure performance.36

According to NNSA officials, the revised DNN policy does not include 

requirements to practice life-cycle management, including life-cycle 

schedule and cost management, because officials determined that lifecycle management did not apply to some DNN programs that NNSA 

officials believe are enduring or continuous. For example, as mentioned 

above, the director of the International Nuclear Security subprogram said 

that the subprogram will phase out of certain areas or reduce 

engagement with certain countries in the future but that it is expected to 

continue as long as nuclear materials exist and will work to improve 

security in countries possessing such materials.

We disagree that life-cycle program management does not apply to 

programs or subprograms that may have an enduring mission. Managers 

need to make informed decisions about whether a program is affordable 

within the agency’s portfolio. NNSA and DNN should be able to compare 

DNN’s various programs’ requirements several years beyond its 5-year 

planning period. According to the GAO cost guide, in developing 

estimates, programs should define assumptions tailored to the program, 

such as assumptions about the program’s life-cycle phases. For example, 

 35Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013. GAO-16-89G and GAO-09-3SP. 

36Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013. GAO-16-89G and GAO-09-3SP.
Page 22 GAO-17-773 Nonproliferation Program Management

the International Nuclear Security subprogram could take steps to define 

end-point targets for when it may phase out work in certain areas or 

countries in the future. In addition, according to the GAO schedule guide, 

a comprehensive schedule should reflect all of a program’s activities and 

recognize that uncertainties and unknown factors in schedule estimates 

can stem from, among other things, data limitations. Moreover, because 

assumptions themselves can vary, they should always be inputs to 

program risk analyses of cost and schedule.

According to NNSA officials, although the revised policy does not include 

requirements for life-cycle cost estimating, DNN programs could address 

this in their individual program management plans. NNSA officials stated 

that these program management plans for programs and subprograms 

should be detailed enough to also provide information on how the 

program will track progress, including by identifying changes to the 

planned schedule.

However, the revised DNN policy does not clearly require DNN programs 

or subprograms to have program management plans, nor does it specify 

elements of such plans. Specifically, the revised DNN policy requires 

each program to develop “program management documentation” that 

identifies program scope, schedule, and cost during the fiscal year and 

operating procedures for the fiscal year, but it does not outline similar 

requirements for the program’s life cycle.37 In addition, the revised policy 

does not specify requirements or guidance, such as on cost estimation, 

for what programs or subprograms are to include in the program 

management documentation. In contrast, PMI indicates that programs 

should develop a program management plan that includes plans for 

program financial management, schedule management, and scope 

management for all phases of the program’s life cycle. According to 

NNSA officials, the revised DNN policy is the only directive or 

documentation that spells out what is needed or required to be included in 

a program management plan.

Although the revised DNN policy does not clearly require DNN programs 

or subprograms to have program management plans, some DNN 

programs have developed or are developing such plans. For example, the 

Global Material Security program, which oversees the Radiological 

 37The revised DNN policy mentions the use of a program management plan in an 

appendix; however, it does not specify requirements or guidance for programs or 

subprograms to include in the plans. 
Page 23 GAO-17-773 Nonproliferation Program Management

Security and International Nuclear Security subprograms, issued a new 

program management plan in April 2017. The Global Material Security 

program management plan requires that each subprogram maintain a 5-

year budget for the FYNSP with cost estimates, but it does not require or 

provide guidance on developing life-cycle schedule or cost estimates. 

NNSA officials said that DNN underwent a major reorganization of its 

programs in January 2015, and some of the new program offices are still 

preparing their program management plans. For example, the Material 

Management and Minimization program that oversees the Nuclear 

Material Removal and HEU Reactor Conversion subprograms is still 

developing its program management plan, according to NNSA officials.

In addition, the four selected subprograms had various documented 

plans, but none fully addressed life-cycle schedule and cost 

management.

• Nuclear Material Removal. The subprogram did not have a current 

program management plan that had been updated since the 2015 

reorganization of DNN but instead relied on an older plan that covered 

a different scope than the scope of the current subprogram.

• HEU Reactor Conversion. The subprogram did not have a program 

management plan for the overall subprogram. Instead, the 

subprogram had project execution plans for its U.S. reactor 

conversion projects and its Mo99 projects and relied on an outdated 

document for its international reactor conversion projects.

• Radiological Security. The subprogram had a program management 

plan that included requirements for the use of project life-cycle 

baselines and for conducting cost estimation for the 5-year FYNSP. 

However, the plan had no requirement for developing a cost estimate 

for the life cycle of the subprogram and for using such an estimate to 

measure performance of the overall subprogram.

• International Nuclear Security. The subprogram had a program 

management plan that required cost estimating for 1 fiscal year. 

However, the plan did not include requirements for life-cycle estimates 

and for using initial or updated baselines to measure performance.

NNSA subprogram officials said that they do not have readily available 

life-cycle cost estimates and baseline measurement data in part because 

they are not asked to provide it. For example, NNSA officials from the 

HEU Reactor Conversion subprogram said that they did not have 

sufficient staff to track performance against initial baselines because it 

was not a priority for management, although it would be possible to do so 
Page 24 GAO-17-773 Nonproliferation Program Management

if required. One of the stated goals of the revised DNN policy is to 

facilitate DNN-wide implementation of methods for programs and 

subprograms to monitor, measure, and improve management processes. 

However, because the policy does not require more complete information 

from DNN programs and subprograms on their cost, schedule, and 

performance against baselines—consistent with leading practices—it is 

not clear that this policy goal can be achieved.

When organizations apply leading program management practices—such 

as establishing schedules and cost estimates covering their planned life 

cycles and measuring performance against such baselines—they may be 

able to enhance their chances of achieving success across a range of 

programs. However, the four selected DNN subprograms are generally 

not applying these selected leading practices for life-cycle program 

schedule and cost management, due in part to the uncertainty and risks 

in working with international partners. However, methods and approaches 

exist that allow programs to account for uncertainty and risk in developing 

schedule and cost estimates for their planned scope of work. 

Furthermore, while the revised DNN program management policy has 

incorporated some leading practices, it does not include requirements 

and guidance for DNN programs and subprograms to practice life-cycle 

schedule and cost estimating and does not require program management 

plans that could be the vehicle for DNN programs and subprograms to 

specify the use of such estimates. Updating the DNN program 

management policy to include requirements for DNN programs and 

subprograms to follow leading practices for life-cycle program 

management would help NNSA ensure that managers, stakeholders, and 

Congress have better information on how much DNN programs and 

subprograms may cost to achieve their goals, the amount of time they 

may need to achieve these goals, and how efficiently and effectively they 

are actually being executed compared to plans.

The NNSA Deputy Administrator for DNN should revise the DNN program 

management policy to require DNN programs and subprograms to follow 

life-cycle program management. These requirements should include 

development of schedule and cost estimates that cover the life cycle of 

DNN programs and subprograms, use of methods to account for 

uncertainty and risk in such estimates, use of cost and schedule 

baselines to measure performance over program and subprogram life 

cycles, and development of program management plans. 

(Recommendation 1)

Conclusions

Recommendation for 

Executive Action
Page 25 GAO-17-773 Nonproliferation Program Management

We provided NNSA with a draft of this report for its review and comment. 

In written comments, which are summarized below and reproduced in 

appendix IV, NNSA neither agreed nor disagreed with our 

recommendation to revise the DNN program management policy to 

require DNN programs and subprograms to follow life-cycle program 

management. However, NNSA stated that it plans to take action in 

response to the recommendation. 

In general, NNSA stated that DNN will update its program management 

policy to formally document current practice and clarify expectations for 

addressing uncertainty. Specifically, NNSA said it will update the policy 

to: (1) reflect that life-cycle cost and schedule management should be 

applied at the project or subprogram level where appropriate, considering 

the extent of uncertainty impacting scope, potential timelines, and 

executability; (2) define the methodologies to (a) account for uncertainties 

where applying these techniques would result in a reasonable range of 

estimates that would be useful for planning and scheduling purposes or 

(b) document risk and track actions to reduce uncertainty where 

applicable; (3) address expectations for assessing cost and schedule 

performance, commensurate with the level of certainty present at 

baselining; and (4) address requirements for documenting program 

management plans.

Although we acknowledge NNSA’s plan to update its policy, we have 

concerns regarding whether its proposed actions will ensure that DNN 

programs and subprograms effectively follow leading practices for lifecycle schedule and cost management in the future. First, we do not 

believe that updating the DNN program management policy to formally 

document current program management practice addresses our 

recommendation. NNSA’s response suggests that its update to the policy 

is intended to reflect current DNN program management practices rather 

than signal a need for corrective action to address the DNN program 

management limitations we identified. Specifically, as we stated in our 

report, none of the four subprograms we reviewed had schedule and cost

estimates that encompassed the entire life cycle, although one 

subprogram planned to develop such estimates for its recently-extended 

life cycle. In addition, NNSA’s proposed update to the DNN program 

management policy to reflect life-cycle schedule and cost management 

“where appropriate” is vague, and may give programs and subprograms

too much discretion to avoid the requirement. To have an effective 

requirement on life-cycle program management and to be responsive to 

our recommendation, NNSA will need to clearly define the criteria for 

Agency Comments 

and Our Evaluation
Page 26 GAO-17-773 Nonproliferation Program Management

when a program should be exempt from a requirement to follow life-cycle 

program management. 

Finally, the meaning of NNSA’s proposed update to the policy to address 

expectations for assessing cost and schedule performance, 

commensurate with the level of certainty present at baselining is unclear. 

Specifically, it is unclear whether NNSA plans to require that DNN 

subprograms use cost and schedule baselines to measure performance, 

or whether it plans to exempt programs or subprograms from such 

practices based on unstated expectations. As we stated in our report, 

none of the subprograms we reviewed measured their overall schedule 

and cost performance against baseline estimates. To ensure that DNN 

subprograms take steps to measure schedule and cost performance 

against baselines and to be responsive to our recommendation, NNSA 

will need to define clear expectations for DNN programs and 

subprograms to follow.

NNSA also provided general comments in its written comments regarding 

DNN program management. 

First, NNSA commented that DNN currently implements elements of lifecycle program management where appropriate and reasonable. However, 

according to NNSA, the majority of its international activities operate with 

an unusually high level of uncertainty regarding potential international 

cooperation and with limited information on international operations to 

understand the scope of work required to support useful planning and 

estimating. In NNSA’s view, the high uncertainty would result in range 

estimates so broad as to serve no useful purpose, and there is no 

appreciable cost-benefit to expending resources on such calculations. 

We recognize that organizations need flexibility to determine when it is 

appropriate and useful to apply leading practices on life-cycle program 

management. However, as noted in our report, managers need to make 

informed decisions about whether a program is affordable within the 

agency’s portfolio. Without more complete schedule and cost information 

on DNN subprograms, NNSA managers and other stakeholders have 

degraded information on the elements of DNN’s portfolio, which may limit 

their ability to assess and justify the affordability of long-term plans. If 

NNSA believes that some of DNN’s planned international work scope is 

too uncertain for subprograms to develop estimates of schedule and cost 

that cover their life cycles, then NNSA should evaluate whether it is 

appropriate to identify such work scope in DNN’s long-term plans at all. 
Page 27 GAO-17-773 Nonproliferation Program Management

Second, NNSA commented that no specific requirement exists for DNN 

programs and subprograms to implement life-cycle cost estimates, and 

that DNN complies with current requirements. NNSA also commented 

that the proper application of leading practices recognizes that costbenefits, as well as the potential usefulness and reliability of estimates, 

are important considerations. In instances in which uncertainty is 

extremely high, NNSA stated that focus shifts to disclosure of risks, and 

the establishment and tracking of actions to reduce the level of 

uncertainty. According to NNSA’s comments, DNN discloses risks and 

tracks actions to reduce the level of uncertainty extensively, and this was 

reflected in the most recent update to the DNN program management 

policy with the addition of a new section on risk management. NNSA also 

stated that as uncertainty is reduced, then other principles can be applied 

where appropriate. 

We stated in our report that no specific requirement exists for DNN 

programs and subprograms to implement life-cycle cost estimates. 

Specifically, we noted that the DNN policy required that program 

management functions be conducted over the 5-year FYNSP. Therefore, 

we agree that the DNN subprograms we chose to review complied with 

current requirements. However, our review was not focused on 

compliance with requirements but rather on the use of leading or good 

program management practices. We also noted that NNSA’s stated 

objectives for the DNN policy include establishing a DNN-wide policy that 

incorporates leading practices for program management and that 

facilitates the implementation of methods for programs and subprograms 

to monitor, measure, analyze, and improve management processes. 

Leading practices on life-cycle program management are important for an 

organization to successfully plan the resources it needs to achieve its 

goals and assess its performance in doing so. DNN’s revised policy did 

not acknowledge management of the program life-cycle as an essential 

program management function and did not include any requirements on 

leading practices on life-cycle schedule and cost management. 

We agree that risk management processes should be used to monitor 

risks and track actions to reduce uncertainty. As we stated in our report, 

the revised DNN policy included a new section on risk management 

under which all DNN programs and subprograms will be required to 

prepare risk management plans to help identify, analyze, handle, and 

monitor risk. However, the new section did not include criteria for DNN 

subprograms to follow when uncertainty related to risks being monitored 

is low enough to allow a subprogram to develop life-cycle schedule and 

cost estimates.
Page 28 GAO-17-773 Nonproliferation Program Management

We are sending copies of this report to the appropriate congressional 

committees, the NNSA Administrator, the NNSA Deputy Administrator for 

Defense Nuclear Nonproliferation, and other interested parties. In 

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-3841 or oakleys@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 key contributions to this report 

are listed in appendix V.

Shelby S. Oakley

Director, Acquisition and Sourcing Management
Page 29 GAO-17-773 Nonproliferation Program Management

List of Committees

The Honorable John McCain

Chairman

The Honorable Jack Reed

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Lamar Alexander

Chairman

The Honorable Dianne Feinstein

Ranking Member

Subcommittee on Energy and Water Development

Committee on Appropriations

United States Senate

The Honorable Mac Thornberry

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Mike Simpson

Chairman

The Honorable Marcy Kaptur

Ranking Member

Subcommittee on Energy and Water Development

Committee on Appropriations

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-17-773 Nonproliferation Program Management

This report examines the extent to which (1) selected subprograms within 

the National Nuclear Security Administration’s (NNSA) Office of Defense 

Nuclear Nonproliferation (DNN) use program management leading 

practices to manage schedule and cost, and (2) DNN has incorporated 

program management leading practices in its revised program 

management policy.

To conduct this work, we reviewed 4 selected DNN subprograms. DNN 

has 4 major programs that manage a total of 13 subprograms (a 

subprogram is a program managed as part of another program). 

Specifically, we selected the Nuclear Material Removal and Highly 

Enriched Uranium (HEU) Reactor Conversion subprograms, which DNN 

manages under its Material Management and Minimization program. In 

addition, we selected the Radiological Security and International Nuclear 

Security subprograms, which DNN manages under its Global Material 

Security program.1 We selected these subprograms for review because 

they had defined start dates, end dates, and/or work scope indicating that 

they had project-like aspects. These subprograms organize their work in 

programmatic areas which we refer to as components and under each 

component the subprograms manage various types of projects, such as 

projects to remove nuclear material from civilian sites worldwide. We also 

selected the 4 subprograms because they were not the subject of other 

ongoing or recently completed GAO reviews.2 The information we 

obtained from these subprograms is not generalizable, but we believe 

that we obtained important insights into DNN’s cost and schedule 

management of these subprograms.

To examine the extent to which the selected DNN subprograms use 

program management leading practices to manage cost and schedule, 

we identified selected leading practices by the Project Management 

Institute (PMI) in The Standard for Program Management and by GAO in 

 1

DNN’s 4 major programs are Material Management and Minimization, Global Material 

Security, Nonproliferation and Arms Control, and Research and Development. The 9 

subprograms that we did not select for this review are Nonproliferation Construction and 

Program Analysis, Material Disposition, Nuclear Smuggling Detection and Deterrence, 

International Nuclear Safeguards, Nuclear Controls, Nuclear Verification, Nonproliferation 

and Arms Control Policy, Proliferation Detection, and Nuclear Detonation Detection.

2

We did not include “capital asset acquisition projects” in the scope of our review. DOE 

defines capital assets as land, structures, equipment, and intellectual property, which are 

used by the federal government and have an estimated useful life of 2 years or more. For 

capital asset projects, DOE and NNSA have specific requirements that do not apply to 

other types of projects.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-17-773 Nonproliferation Program Management

its schedule and cost guides.3 The selected leading practices we 

identified were the use of a master schedule necessary to achieve a 

program’s goals, cost estimates that cover the full life-cycle of a program, 

and schedule and cost baselines to measure performance. We collected 

and reviewed subprogram planning documents, monthly performance 

reports, and spreadsheet data on work scope, historical costs, schedules 

and cost estimates established by the subprograms, and their use of 

project baselines to measure performance. We also reviewed information 

the subprograms reported in NNSA’s fiscal year 2017 and 2018 

congressional budget justifications. We also interviewed NNSA officials 

and their contractors who manage the program management information 

system used by 3 of the 4 subprograms to manage schedule and cost 

information to understand its capabilities. We interviewed NNSA officials 

who manage the selected DNN subprograms about the use of these 

practices and their views on challenges or limitations in using them. We 

also interviewed representatives at Argonne National Laboratory and 

Pacific Northwest National Laboratory, which operate projects for the 

subprograms, to identify how projects develop schedule and cost 

estimates and pass information on to the subprograms.

To assess the reliability of the schedule and cost estimates on the 

selected subprograms, we interviewed NNSA officials and national 

laboratory contractors who were knowledgeable about the process 

followed to develop and update the estimates and the program 

management information systems used to manage the schedule and cost 

information and generate reports. We determined that the data were 

sufficiently reliable for our purposes, which were to report the 

subprograms’ estimated schedule completion dates and cost estimates, 

as well as report the fiscal years and subprogram components and 

projects covered by the subprogram schedule and cost estimates.

To examine the extent to which DNN has incorporated leading practices 

into its revised program management policy, we reviewed DNN’s revised 

 3

PMI is a not-for-profit association that provides global standards for, among other things, 

project and program management. These standards are utilized worldwide and provide 

guidance on how to manage various aspects of projects, programs, and portfolios. Project 

Management Institute, Inc., The Standard for Program Management, Third Edition, 2013. 

GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009); and 

GAO Schedule Assessment Guide: Best Practices for Project Schedules, GAO-16-89G 

(Washington, D.C.: December 2015). 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-17-773 Nonproliferation Program Management

program management policy approved in February 2017.4 We compared 

the revised policy to the 2005 version to identify the changes included in 

the revised policy. We reviewed program management leading practices 

by PMI in The Standard for Program Management and by GAO in its 

schedule and cost guides and federal internal control standards.5 For 

example, we considered the applicable leading practices on schedule and 

cost management identified above as well as other practices such as 

those on risk management, quality management, and development of 

program management plans. We compared these practices to DNN’s 

requirements and guidance contained in the revised DNN policy. We 

interviewed NNSA officials about the development of the new policy and 

their views on the reasons specific leading practices were included in the 

revised policy and others were not, as well as challenges DNN’s 

programs and subprograms face in managing program schedule and 

cost. We also reviewed program management plans for the 4 selected 

subprograms and the major programs under which these subprograms 

operate. We then interviewed NNSA officials from the selected 

subprograms to determine their involvement in developing the revised 

DNN program management policy and the status of individual program 

management plans that were under development at the time of our 

review.

We conducted this performance audit from June 2016 to September 2017 

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 and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 4

Department of Energy, National Nuclear Security Administration, Office of Defense 

Nuclear Nonproliferation, Management System Description, Feb. 17, 2017. 

5

Project Management Institute, Inc., The Standard for Program Management, Third 

Edition, 2013. GAO-09-3SP, GAO-16-89G, and GAO-14-704G.
Appendix II: Scope and Completion Dates for 

the Highly Enriched Uranium Reactor 

Conversion Subprogram

Page 33 GAO-17-773 Nonproliferation Program Management

The Office of Defense Nuclear Nonproliferation’s Highly Enriched 

Uranium (HEU) Reactor Conversion subprogram consists of three 

components: (1) U.S. research reactor conversions, (2) international 

research reactor conversions, and (3) Molybdenum 99 (Mo99) efforts, 

which include international Mo99 isotope production reactor conversions 

and projects to establish new U.S. non-HEU Mo99 production facilities. 

The subprogram’s current goal is to convert or verify shutdown of 156 

HEU reactors and isotope production facilities and to support the 

establishment of a domestic, non-HEU-based Mo99 production capability. 

Tables 2 through 4 below list the U.S. reactor conversions, international 

reactor conversions or shutdowns, and Mo99 projects in the HEU Reactor 

Conversion subprogram’s planned scope of work, for each of the 

subprogram’s three components, as of July 2017.

Table 2: U.S. Highly Enriched Uranium (HEU) Research Reactor Conversions in the 

Planned Scope of Work of The Office of Defense Nuclear Nonproliferation’s HEU 

Reactor Conversion Subprogram and Estimated Completion Dates, as of July 2017

Reactor Location Estimated completion 

Advanced Test Reactor 

Critical Assembly

Idaho National Laboratory, Idaho 

Falls, Idaho

October 2029

Advanced Test Reactor Idaho National Laboratory, Idaho 

Falls, Idaho

February 2030

High Flux Isotope Reactor Oak Ridge National Laboratory in 

Oak Ridge, Tennessee

June 2033

Massachusetts Institute of 

Technology Research 

Reactor

The Massachusetts Institute of 

Technology, Cambridge, 

Massachusetts

July 2027

National Bureau of 

Standards Reactor

National Institute of Standards 

and Technology, Gaithersburg, 

Maryland

August 2027

Transient Reactor Test 

Facility

Idaho National Laboratory, Idaho 

Falls, Idaho

September 2025

Missouri University 

Research Reactor

University of Missouri, Columbia, 

Missouri

February 2028

Source: National Nuclear Security Administration documentation. | GAO-17-773

Appendix II: Scope and Completion Dates 

for the Highly Enriched Uranium Reactor 

Conversion Subprogram
Appendix II: Scope and Completion Dates for 

the Highly Enriched Uranium Reactor 

Conversion Subprogram

Page 34 GAO-17-773 Nonproliferation Program Management

Table 3: International Highly Enriched Uranium (HEU) Reactors and Facilities in the 

Planned Scope of The Office of Defense Nuclear Nonproliferation’s HEU Reactor 

Conversion Subprogram and Estimated Completion Dates, as of July 2017

Country Facility Estimated completion

Belarus Hyacinth September 2019

Belarus Yalena B September 2018

Belgium BR-2 August 2027

Canada Slowpoke Saskatchewan November 2017

Canada Slowpoke Alberta December 2018

China MNSR-SZ September 2019

China CFER 2035a

China Zero Power Fast Critical 2035a

France Jules Horowitz April 2029

France RHF June 2028 

France Minerve November 2021

France ORPHEE December 2020

France Masurca 2035a

Germany FRM-II July 2020 

Ghana GHARR-1 MNSR Completed July 2017

Iran MNSR-Esfahan October 2019

Israel IRR-1 November 2017

Italy RSV-Tapiro November 2022

Japan KUCA-Dry October 2020

Japan KINDAI September 2021

Japan KUCA-Wet June 2020 

Kazakhstan IVG-1 (EWG-1) September 2020

Kazakhstan IGR November 2024

Nigeria NIRR-0001 November 2017

North Korea IRT-DPRK 2035a

Pakistan MNSR PARR-2 September 2019

Russia ASTRA 2035a

Russia FM PIK 2035a

Russia Gidra 2035a

Russia IR-8 2035a

Russia IRT-MEPhI 2035a

Russia IRT-T 2035a

Russia IVV-2M 2035a

Russia MIR.M1 2035a
Appendix II: Scope and Completion Dates for 

the Highly Enriched Uranium Reactor 

Conversion Subprogram

Page 35 GAO-17-773 Nonproliferation Program Management

Country Facility Estimated completion

Russia OR 2035a

Russia PhM MIR.M1 2035a

Russia PIK 2035a

Russia RBT-10/2 2035a

Russia RBT-6 2035a

Russia SM-3 2035a

Russia SM-3 CA 2035a

Russia WWR-M 2035a

Russia WWR-TS 2035a

Syria SRR-1 2035a

Source: National Nuclear Security Administration documentation. | GAO-17-773.

a

Reactors with a completion date of 2035 are in the subprogram’s planned scope of work but the 

subprogram is not currently engaged in planning or implementing these conversion or shutdown 

projects. The year 2035 represents the subprogram’s best estimate of when the reactor may be 

converted.

Table 4: International Molybdenum 99 Reactor Conversions and Planned New U.S. 

Production Facilities in the Scope of The Office of Defense Nuclear 

Nonproliferation’s Highly Enriched Uranium Reactor Conversion Subprogram and 

Estimated Completion Dates, as of July 2017

Country Reactors and facilities Estimated completion

International

Belgium IRE December 2018

Canada Shutdown March 2018

Netherlands Mallinckrodt December 2017

Pakistan PINSTECH December 2020

Russia Karpov December 2018

Russia RIAR December 2018

South Africa NTP September 2017

Domestic

United States General Atomics September 2019

United States NorthStar (Neutron Capture 

750 6d Ci and 3000)

December 2017

United States NorthStar (accelerator) July 2019

United States SHINE June 2020

Source: National Nuclear Security Administration documentation. | GAO-17-773
Appendix III: Scope and Completion Dates for 

the Radiological Security Subprogram’s 

Source Protection Component

Page 36 GAO-17-773 Nonproliferation Program Management

The Office of Defense Nuclear Nonproliferation’s Radiological Security 

subprogram’s current goal for the radiological source protection 

component is to upgrade security in 4,394 buildings worldwide by fiscal 

year 2033. Table 5 shows the estimated number of buildings to be 

completed each year as of June 2017.

Table 5: The Office of Defense Nuclear Nonproliferation Radiological Security 

Subprogram’s Work Scope Completed and Planned for the Radiological Source 

Protection Component for Fiscal Years 2004 through 2033

Fiscal year Cumulative planned 

building security 

upgrades

Annual number of planned 

building upgrades

Prior years (2004-2016) 2,027 -

2017 2,116 89

2018 2,206 90

2019 2,311 105

2020 2,416 105

2021 2,521 105

2022 2,671 150

2023 2,841 170

2024 3,091 250

2025 3,356 265

2026 3,631 275

2027 3,884 253

2028 4,116 232

2029 4,269 153

2030 4,314 45

2031 4,354 40

2032 4,379 25

2033 4,394 15

Cumulative Total 4,394

Source: GAO analysis of National Nuclear Security Administration documentation. | GAO-17-773

Note: The planned building security upgrades reflect the total number of buildings worldwide in 

eligible partner countries assessed as having high priority radiological material and being in need of 

security upgrades.

Appendix III: Scope and Completion Dates 

for the Radiological Security Subprogram’s 

Source Protection Component
Appendix IV: Comments from the National 

Nuclear Security Administration

Page 37 GAO-17-773 Nonproliferation Program Management

Appendix IV: Comments from the National 

Nuclear Security Administration
Appendix IV: Comments from the National 

Nuclear Security Administration

Page 38 GAO-17-773 Nonproliferation Program Management
Appendix IV: Comments from the National 

Nuclear Security Administration

Page 39 GAO-17-773 Nonproliferation Program Management
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 40 GAO-17-773 Nonproliferation Program Management

Shelby S. Oakley, (202) 512-3841 or oakleys@gao.gov.

In addition to the individual named above, William E. Hoehn (Assistant 

Director), Natalie M. Block, R. Scott Fletcher, Brian M. Friedman, Cindy 

Gilbert, Jason T. Lee, TyAnn Lee, Duc Ngo, Jeanette Soares, Sheryl 

Stein, and Sara Sullivan made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100979)
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