Report to the Chairman and Ranking 

Minority Member, Subcommittee on 

Energy and Water Development, 

Committee on Appropriations, House of 

Representatives 

United States Government Accountability Office

GAO

July 2005 NUCLEAR WASTE

Better Performance 

Reporting Needed to 

Assess DOE’s Ability 

to Achieve the Goals 

of the Accelerated 

Cleanup Program 

GAO-05-764 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-764.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Gene Aloise at 

(202) 512-3841 or aloiseg@gao.gov. 

Highlights of GAO-05-764, a report to 

Chairman Hobson and Ranking Minority 

Member Visclosky, Subcommittee on 

Energy and Water Development, 

Committee on Appropriations, House of 

Representatives 

July 2005

NUCLEAR WASTE

Better Performance Reporting Needed to 

Assess DOE's Ability to Achieve the 

Goals of the Accelerated Cleanup 

Program 

Since implementing its accelerated cleanup plan, DOE’s progress in reducing 

environmental risks has been mixed. By March 2005, DOE was on track or 

ahead of schedule for many of the 16 cleanup activities it measures, 

including packaging nuclear materials for disposition, disposing of low-level 

waste, and removing buildings. In contrast, DOE was behind its accelerated 

schedule for 3 challenging and costly activities--disposing of transuranic and 

radioactive tank wastes and closing tanks that had contained radioactive 

wastes. These three cleanup activities had technical problems, such as 

developing waste separation technology, or regulatory issues, such as 

determining when a storage tank is clean enough to close. Furthermore, 

DOE has had problems with other treatment and disposal activities not 

reflected in its performance measures, such as delays in shipping plutonium 

from sites, resulting in additional costs to secure and store the material. 

DOE is not likely to achieve the full $50 billion estimated cost reduction, a 

key goal of the accelerated cleanup plan. First, DOE’s method of calculating 

its $50 billion cost reduction likely overstated the potential reductions. 

Second, DOE based estimated cost reductions on assumed improvements 

that are highly uncertain, such as technology development, revised 

contracting strategies, and regulatory requirements. Third, while DOE 

expected cost reductions to come from most of its sites, key sites are already

experiencing delays and, by the end of fiscal year 2004, had incurred cost 

increases. Recognizing these problems, DOE no longer cites its $50 billion 

estimate but still expects to achieve some cost reductions. 

DOE performance reporting does not allow for an adequate understanding of

its progress toward achieving overall cleanup goals because of limitations in 

how DOE uses its performance measures. First, in its performance 

reporting, DOE does not clearly link accomplishments with the incurred 

costs. Second, DOE does not clearly highlight critical activities, such as 

preparing radioactive tank waste for disposal, that have the greatest impact 

on progress toward meeting overarching cleanup goals. 

Key Assumptions Contributing to DOE’s $50 Billion Estimated Cost Reduction 

Work finished sooner

Technology

improvements

Revised contracting

strategies

Other

Revised cleanup agreements

9%

10%

10%

29%

42%

Source: GAO analysis of DOE data.

In February 2002, following years 

of rising costs to its nuclear waste 

cleanup program, the Department 

of Energy (DOE) announced a new 

initiative—the accelerated cleanup 

plan—and committed to reduce 

costs of cleanup by $50 billion, 

shorten the cleanup schedule by 35 

years, and reduce risks to human 

health and the environment. 

GAO reviewed (1) the progress 

DOE has made under its 

accelerated cleanup plan, (2) the 

likelihood DOE will achieve its 

estimated $50 billion in cost 

reductions, and (3) whether DOE’s 

performance reporting allows for a 

full understanding of progress 

toward achieving the accelerated 

plan goals. 

What GAO Recommends

GAO recommends that DOE (1) 

improve the linkage between 

performance measures so that 

there is a clearer, discernable 

relationship between how much 

cleanup has been accomplished 

and costs incurred in doing the 

work and (2) identify and highlight 

in its progress reports to the 

Congress and others those 

performance measures that are the 

most critical to assessing overall 

progress toward meeting 

accelerated cleanup plan goals. In 

commenting on the report, DOE 

agreed with our recommendations. 
Page i GAO-05-764 DOE's Accelerated Cleanup Program 

Letter 1

Results in Brief 5 

Background 7 

Progress in Accelerating Cleanup at DOE’s Sites Has Been Mixed 11 

DOE Is Unlikely to Achieve Its Estimated $50 Billion in Cost 

Reductions 20 

DOE’s Performance Reporting Does Not Clearly Reflect Progress 

Made toward Achieving the Overarching Goals of the 

Accelerated Cleanup Plan 29 

Conclusions 36 

Recommendations for Executive Action 37 

Agency Comments and Our Evaluation 37 

Appendix I Scope and Methodology 40 

Appendix II DOE’s Estimated Cost Reductions under the 

Accelerated Cleanup Plan 44 

Appendix III Comments from the Department of Energy 46 

Appendix IV GAO Contact and Staff Acknowledgments 48 

Tables 

Table 1: Types, Estimated Quantities, and Planned Treatment and 

Disposal Approach for DOE’s Surplus Special Nuclear 

Materials and Waste Materials 8

Table 2: Cleanup Activities for Which DOE Was Ahead of Schedule 

as of March 2005 12

Table 3: Cleanup Activities for Which DOE Was Generally on 

Schedule as of March 2005 14

Table 4: Cleanup Activities for Which DOE Is Behind the 

Accelerated Schedule as of March 2005 16

Table 5: Selected Cleanup Activities Experiencing Problems That 

Are Not Included in DOE’s Risk Reduction Measures 18

Contents 
Page ii GAO-05-764 DOE's Accelerated Cleanup Program 

Table 6: Comparative Features of DOE’s Risk Reduction Measures 

and Cost Performance Measures 31

Table 7: Performance Information on Idaho National Laboratory 

Transuranic Waste Shipments as of March 2005 32

Table 8: Accelerated Cleanup Estimates 44

Figures 

Figure 1: Contributions of Key Assumptions to DOE’s Estimated 

$50 Billion in Cost Reductions 24 

Figure 2: DOE’s Expected Cost Reduction by Office 25 

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Page 1 GAO-05-764 DOE's Accelerated Cleanup Program 

July 29, 2005 

The Honorable David L. Hobson 

Chairman 

The Honorable Peter J. Visclosky 

Ranking Minority Member 

Subcommittee on Energy and Water Development 

Committee on Appropriations 

House of Representatives 

The Department of Energy (DOE) is responsible for one of the world’s 

largest environmental cleanup programs. Decades of nuclear weapons 

production have left a legacy of chemical, hazardous, and radioactive 

wastes, including high-level and transuranic wastes1

 to be cleaned up at 

sites across the United States. In 1989, DOE established the Office of 

Environmental Remediation and Waste Management (now the Office of 

Environmental Management) to address the cleanup of these wastes. In 

carrying out the cleanup program, DOE receives regulatory oversight from 

various federal agencies, including the Environmental Protection Agency, 

the Nuclear Regulatory Commission, and the Department of 

Transportation, and the states where DOE’s sites are located. 

During the 1990s, we and others criticized DOE’s nuclear waste cleanup 

program for being expensive, slow, and lacking in commitment and 

accountability. In response, DOE implemented or attempted to implement 

a number of management initiatives to improve its performance and 

address uncontrolled cost and schedule growth. These initiatives included 

launching a major reform to its contracting practices in 1994, establishing 

an initiative to privatize certain projects in 1995, and developing an 

approach to close sites on a compressed schedule in 1996. These 

initiatives affected how DOE approached the cleanup work, the agency’s 

 1

Radioactive waste includes liquid, sludge, and solid waste. Radioactive tank waste—which 

DOE manages as high-level waste—is largely liquid waste and sludge resulting from the 

reprocessing of spent nuclear fuel and containing highly radioactive fission products, longlived isotopes, hazardous chemicals, and heavy metals. DOE intends to dispose of the highlevel constituents of this waste in a geologic repository now under development at Yucca 

Mountain in Nevada. DOE intends to dispose of the remaining waste constituents at its 

sites. Transuranic waste includes equipment, tools, and clothing contaminated with 

plutonium or other elements with atomic numbers higher than uranium. DOE disposes of 

its transuranic waste in a geologic repository in New Mexico. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-764 DOE's Accelerated Cleanup Program 

relationship with its contractors, and in some cases, the schedule for 

completing cleanup work. 

Despite these initiatives, DOE’s cleanup program continued to experience 

cost and schedule growth. By 2001, DOE’s estimates of the total cost and 

timeframes for completing its cleanup program had climbed to about $192 

billion2

 and up to 70 years to complete. DOE reported that after having 

spent over $60 billion (current dollars) on nuclear waste cleanup since 

1989, little progress had been made toward reducing risks to the public 

and the environment. DOE concluded that without significant reform the 

cleanup program would continue to experience uncontrolled cost and 

schedule growth.3

To address this cost and schedule growth, the Assistant Secretary for 

Environmental Management announced a new initiative in February 2002, 

to improve management of the program. This initiative—known as the 

accelerated cleanup plan—had three main goals: rapidly reducing 

environmental risks, decreasing the projected time to clean up sites, and 

reducing the overall cost of the cleanup program. To implement the new 

initiative, DOE took a number of steps including realigning the program to 

focus on rapid reduction of environmental risks; improving contract 

management; and restructuring how DOE managed the cleanup program 

to better support an accelerated, risk-based approach. Other changes 

included implementing procedures that require more discipline in 

controlling costs and cleanup schedules and holding DOE managers more 

accountable for achieving results. 

DOE began implementing the accelerated cleanup plan late in 2002. In a 

March 2003 congressional testimony before a House Appropriations 

subcommittee, the department declared that its new strategy would 

 2

DOE reports cost estimates that add actual (current) dollars for pre-2001 values, and 

constant 2003 dollars for values reported past 2001, which DOE calls “2003 constant 

dollars.” Unless otherwise noted, the numbers are reported in DOE’s 2003 constant dollars 

and without any adjustments. 

3

U.S. Department of Energy, A Review of the Environmental Management Program 

(Washington, D.C.: Feb. 4, 2002). 
Page 3 GAO-05-764 DOE's Accelerated Cleanup Program 

reduce the total cost of the program by an estimated $50 billion.4 DOE also 

committed to a strict schedule for timely completion of its cleanup 

activities by 2035, 35 years earlier than called for in previous plans. To 

expedite the acceleration of activities under this new plan, DOE said it 

would need increased funding for its cleanup program in the first 3 years 

of the accelerated approach—from fiscal years 2003 through 2005—after 

which funding would begin to decline. DOE estimated that by fiscal year 

2008, it will have reduced its annual funding requirements by one-third, to 

approximately $4.5 billion per year (constant 2003 dollars), although the 

actual amounts requested in the budget would differ due to inflation. 

To improve performance monitoring and reporting on its cleanup 

activities, DOE developed and began reporting on progress toward 

reducing environmental risks primarily through 16 risk reduction 

measures that DOE refers to as “gold chart metrics.” These measures track 

progress toward completing cleanup activities, such as the quantities of 

waste disposed of and the number of buildings demolished at each DOE 

site.5

 DOE also uses an earned value management system to monitor 

progress of about 60 large cleanup projects. Earned value provides DOE 

managers with information about whether budgeted work was performed 

within cost and schedule parameters. Following findings by the Office of 

Management and Budget (OMB) in a performance review during fiscal 

year 2005 stating that DOE had not developed adequate annual cost and 

schedule performance measures to monitor progress towards completing 

the cleanup program, DOE has been working to more fully implement its 

 4

According to DOE, the department’s adjusted cost estimates of both cleanup and longterm stewardship work in 2001 and 2003, were $192 billion (before accelerated strategy) 

and $142 billion (under its accelerated strategy), in DOE’s “2003 constant dollars,” 

respectively, and resulted in the $50 billion cost reduction. Although DOE’s $50 billion 

estimate was not adjusted for the time value of money, it is the cost reduction estimate that 

DOE has cited publicly, such as in a November 2002 public meeting of the Environmental 

Management Advisory Board in Washington, D.C., and a March 2003 congressional 

testimony before the House Appropriations Committee, Subcommittee on Energy and 

Water Development, so it is used throughout this report. When it implemented its 

accelerated strategy, DOE was managing to a $129 billion lifecycle cost, which is the 2003 

estimate of $142 billion without long-term stewardship costs. 

5

DOE’s risk reduction measures address the following 16 cleanup activities: packaging 

plutonium, packaging enriched uranium, packaging plutonium and uranium residues, 

packaging depleted uranium, packaging high-level solid wastes, packaging spent nuclear 

fuels, eliminating liquid tank wastes, closing waste tanks, disposing of transuranic wastes, 

disposing of low-level and low-level mixed wastes, remediating release sites, eliminating 

material access areas, removing nuclear facilities, removing radioactive facilities, removing 

industrial facilities, and closing geographic sites. 
Page 4 GAO-05-764 DOE's Accelerated Cleanup Program 

earned value management system. This work includes ensuring all 

mission-related projects are covered by earned value management and 

monitoring these projects against their long-term costs, rather than the 

contract period, as DOE currently does. 

Given the significant cost of cleaning up DOE’s wastes and the importance 

of effectively managing the cleanup effort, you asked us to review the 

progress DOE has made under its accelerated cleanup plan. Specifically, 

our report examines (1) the progress DOE has made in accelerating 

cleanup at its sites, (2) the likelihood that DOE will achieve its estimated 

$50 billion in cost reductions, and (3) whether DOE’s performance 

reporting allows for a full understanding of progress toward achieving the 

accelerated cleanup plan goals. 

To determine what progress DOE has achieved under its accelerated 

cleanup plan, we obtained and analyzed DOE’s cost, schedule, and earned 

value data for each site and each project. In addition, we determined how 

DOE developed its performance measures. We also obtained cost, 

schedule, and performance information on selected projects from five 

DOE sites chosen on the basis of location, cost, and type of waste—the 

Hanford Site in Washington state; the Savannah River Site in South 

Carolina; the Idaho National Laboratory in Idaho; the Miamisburg Closure 

Project in Ohio, and the West Valley Demonstration Project in New York 

state. To determine the basis of DOE’s estimated $50 billion in cost 

reductions, we obtained and evaluated information regarding the changes 

that DOE made to its cleanup program and DOE’s plan to implement those 

changes. We also obtained and analyzed DOE’s cost estimates to 

determine how, where, and when DOE expects to reduce the cost and 

schedule for the cleanup work. We did not adjust the cost estimates to 

correct for the time value of money or the effect of inflation. To evaluate 

DOE’s performance measures, we reviewed reports and studies on 

performance measurement and discussed with DOE officials how the 

department develops and uses its performance measures. We also 

reviewed and analyzed DOE’s most recent performance reports and 

compared that information to the actual progress documented at various 

DOE sites. To assess the reliability of the data provided by DOE, we 

obtained and analyzed information about the methods for compiling cost, 

schedule and performance data, and steps taken to ensure its accuracy 

and completeness from the sites we included in our analysis. A more 

detailed description of our scope and methodology is presented in 

appendix I. We performed our work between June 2004 and July 2005 in 

accordance with generally accepted government auditing standards, 

including an assessment of data reliability. 
Page 5 GAO-05-764 DOE's Accelerated Cleanup Program 

DOE has made progress in the 2 years since it implemented the 

accelerated cleanup plan, but the most difficult cleanup challenges remain. 

Specifically, by March 2005, 13 of the 16 risk reduction measures—

including packaging nuclear materials for disposition, removing buildings, 

and disposing of low-level and low-level mixed waste—had met, nearly 

met, or were ahead of the accelerated cleanup schedule. In contrast, DOE 

was behind its accelerated schedule for 3 challenging and costly 

activities—disposing of transuranic waste, disposing of radioactive tank 

waste, and closing tanks that had contained radioactive wastes. These 3 

cleanup activities often had technical problems, such as developing waste 

separation technology, or regulatory issues such as determining when a 

storage tank is clean enough to close. Furthermore, DOE has had 

problems with other treatment and disposal activities not reflected in its 

performance measures, such as delays in shipping plutonium from sites, 

resulting in additional costs to continue storing and securing the material 

until long-term storage issues are resolved. 

DOE will likely not fully achieve its projected $50 billion in cost 

reductions, a key goal of the accelerated cleanup plan, for three main 

reasons. First, DOE’s method for calculating cost reductions does not take 

into account the time value of money. Considering the time value of 

money, the actual cost reduction from the accelerated plan, if 

implemented as intended, would likely be much lower. For example, in 

2004, we recalculated DOE’s estimated cost reduction for the Hanford 

waste treatment plant, which DOE estimated to be $20 billion, not 

considering the time value of money. However, considering the time value 

of money, the estimated cost reduction was reduced by about 40 percent 

to about $12 billion. Second, DOE based the estimated cost reductions on 

the assumption that there would be improvements in cleanup technology, 

revisions to contracting strategies, and changes in regulatory requirements 

that govern the level of required cleanup. However, evidence is mounting 

that some of the improvements and regulatory changes may not be 

realized. For example, some of the technologies, such as new methods for 

treating a portion of the tank waste at Hanford, are not fully tested and the 

costs to operate the technology are not known. Although ultimately these 

technologies may be effective in treating waste, it is uncertain whether 

anticipated cost reductions will be realized. Additionally, regulators—such 

as the state of New Mexico and the Environmental Protection Agency—

have not yet approved some of DOE’s proposed regulatory revisions, such 

as its plan to send certain types of tank waste now located at the Idaho 

National Laboratory to the Waste Isolation Pilot Plant in New Mexico. 

Third, DOE expected nearly all of the total cost reductions to come from 

accelerating cleanup at three major sites—Hanford in Washington state, 

Results in Brief 
Page 6 GAO-05-764 DOE's Accelerated Cleanup Program 

Savannah River in South Carolina, and the Idaho National Laboratory. 

However, DOE is behind schedule in some of its cleanup activities at these 

sites and cost estimates for completing the work are rising. In addition, 

DOE’s planned high-level waste repository at Yucca Mountain in Nevada is 

expected to be delayed at least 2 years, which could also increase cleanup 

costs. Recognizing the uncertainty of achieving the full $50 billion cost 

reduction it committed to achieving with its accelerated plan, DOE has 

recently stopped citing a specific estimate of potential cost reductions it 

believes it can achieve; however, the department still believes it will 

achieve some cost reductions with its accelerated strategy. 

DOE’s performance reporting does not clearly reflect progress made 

toward the overall cleanup plan goals of a $129 billion total program cost 

and a 2035 completion date, because of two main shortcomings. 

• First, in reporting on its progress, DOE does not establish how 

accomplishments made in addressing wastes, which DOE measures 

through its risk reduction measures, are associated with the costs 

incurred, which DOE measures through its cost performance measures. 

This makes it difficult to clearly understand whether cleanup activities, 

such as the amount of waste disposed of, were accomplished within 

projected costs. For example, as of March 2005, DOE’s Idaho National 

Laboratory was more than one year—or more than 1,000 shipments—

behind the planned number of shipments of transuranic waste to a 

repository. However, DOE had no corresponding indicator to show how 

this delay has affected estimated costs. 

• Second, DOE’s performance reporting does not clearly highlight that 

certain performance measures are more important than others in 

indicating whether DOE is on track toward achieving its overall 

performance goals. For example, DOE expects a significant portion of its 

cost reductions to result from improvements in addressing radioactive 

tank wastes and transuranic wastes. Radioactive tank wastes alone 

account for almost $30 billion of DOE’s estimated $50 billion cost 

reductions—or 60 percent—under the accelerated plan. Although DOE’s 

performance measures show that DOE has fallen behind in both 

transuranic and radioactive tank waste cleanup activities, its performance 

reporting does not highlight the relative significance that these critical 

measures have in providing a full understanding of overall progress 

toward the goals of the accelerated cleanup plan. Falling behind in these 

activities could significantly add to overall cleanup costs and, therefore, 

make it difficult for DOE to achieve its $129 billion overall cost target. 
Page 7 GAO-05-764 DOE's Accelerated Cleanup Program 

We are recommending that the Secretary of Energy ensure that DOE’s 

performance reporting (1) includes a clearer, discernible relationship 

between cleanup accomplishments and cost and (2) highlights the status 

of performance measures that are the most critical to achieving cost and 

schedule goals. DOE agreed with our recommendations to ensure its 

performance reporting provides a clearer linkage between cleanup 

accomplishments and costs incurred, and highlights performance 

measures most critical to achieving its accelerated goals. 

The Department of Energy’s Office of Environmental Management is 

responsible for addressing nuclear and hazardous wastes, including some 

of the most dangerously radioactive wastes in the world, and special 

nuclear materials, such as plutonium, resulting from more than 50 years of 

nuclear weapons production. DOE has planned or implemented a variety 

of treatment and disposal approaches, depending on the nature and extent 

of the waste (see table 1). 

Background 
Page 8 GAO-05-764 DOE's Accelerated Cleanup Program 

Table 1: Types, Estimated Quantities, and Planned Treatment and Disposal 

Approach for DOE’s Surplus Special Nuclear Materials and Waste Materials 

Description Estimate 

Planned treatment and 

disposal approach 

Special nuclear materials 

Enriched uranium 8,428 containers Blend high quality material 

into reactor fuel. 

Plutonium 

Plutonium/uranium residues 

5,850 containers 

107,782 kilograms 

Stabilize, package, and 

dispose in either the 

transuranic or high-level 

waste repositories. 

Depleted uranium and uranium 685,161 metric tons Convert to a stable form, 

package, and dispose as lowlevel waste or reuse. 

Radioactive tank wastea 

Liquid, saltcake, and sludges 

stored in tanks 

88 million gallons Separate waste into highlevel and low-activity 

portions. Stabilize the highlevel portion in a glasslike 

material (vitrification) and 

package in canisters and 

then dispose in planned highlevel waste repository. Treat 

low-activity portion and bury 

in near surface burial 

grounds, generally at sites 

where it is currently located. 

Sodium-bearing tank waste 900,000 gallons Treat, package, and dispose 

in a geologic repository. 

Vitrified waste 18,735 canisters Dispose of vitrified waste at 

planned high-level waste 

repository. 

Solidified low-activity waste About 1,000,000 cubic 

metersb

Dispose in near surface burial 

grounds at sites where it is 

currently located. 

Dried high-level waste called 

calcine 

4,400 cubic meters Treat, if necessary, 

repackage and dispose in 

planned repository. 

Transuranic waste 

Various types of materials 

contaminated with plutonium and 

other man-made elements and 

may also contain hazardous 

waste 

141,892 cubic meters Treat and repackage, as 

necessary, and dispose in 

transuranic waste repository. 
Page 9 GAO-05-764 DOE's Accelerated Cleanup Program 

Description Estimate 

Planned treatment and 

disposal approach 

Low-level and low-level mixed 

waste

 

Various waste material including 

soil, building debris, operational 

by-products 

1,190,463 cubic 

meters 

Treat, repackage and bury in 

DOE or commercial near 

surface disposal facilities. 

Actual techniques to be used 

depend on the material. 

Hazardous waste 

Chemicals, heavy metals and 

other materials 

No comprehensive 

measure 

Recycle, incinerate, or use 

other treatment approach and 

dispose at DOE or 

commercial facilities. 

Spent nuclear fuel 

Fuel rods stored in pools and dry 

storage casks 

2,420 metric tons Prepare fuel, package, and 

dispose in planned high-level 

waste repository. 

Facilities 

Nuclear facilities such as 

reactors, processing facilities 

and storage buildings 

Radioactive facilities such as 

labs, shops, and warehouses 

Industrial facilities of many 

different types 

515 facilities 

822 facilities 

3,103 facilities 

Decontaminate and 

decommission followed by 

demolition or reuse. 

Underground radioactive waste 

tanks 

241 tanks Empty tanks and fill with 

grout or other material to 

prevent collapse. 

Waste site 

Burial grounds, dried ponds, 

spills and leaks, and many other 

types of sites 

10,416 sites Depending on the nature and 

extent of contamination, 

approach varies from removal 

and disposal of waste 

material to release of site for 

reuse. 

Source: Compiled by GAO from DOE data. 

a

DOE has traditionally managed all of the wastes in its tanks as high-level waste because the waste 

resulted primarily from the reprocessing of spent nuclear fuel and contains significant amounts of 

radioactivity. However, DOE based its approach to treatment and disposal of this waste on separating 

the high-activity portion from the low-activity portion, allowing DOE to use less costly treatment 

approaches for the majority of what is now managed as high-level waste. In this report, we refer to 

the tank waste—which DOE manages as high-level waste—as “radioactive tank waste.” 

b

DOE’s lifecycle estimate of solidified low-activity waste is based on anticipated separation 

efficiencies and treatment processes. 
Page 10 GAO-05-764 DOE's Accelerated Cleanup Program 

Numerous legal and regulatory requirements govern various aspects of 

DOE’s cleanup effort. Many of the cleanup activities are governed by the 

Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980, as amended, and the Resource Conservation and Recovery Act of 

1976, as amended, through various agreements with regulators. Additional 

laws affecting high-level waste and transuranic wastes are the Nuclear 

Waste Policy Act of 1982, as amended, which establishes the program to 

develop a geologic repository for storing high-level waste and spent 

nuclear fuel, and the Waste Isolation Pilot Plant Land Withdrawal Act, 

which establishes the requirements for operation of a repository for 

transuranic wastes. In addition, under the Federal Facility Compliance Act 

of 1992, DOE has entered into agreements with federal and state 

regulators that establish milestones for accomplishing specified cleanup 

activities and a mechanism to obtain approval to change priorities and 

approaches. For example, under the agreement at Hanford, 10 percent of 

the tank waste is to be processed by 2018 and a report on the plans for the 

remaining 90 percent was due to regulators in January 2005, but now has 

been extended to June 30, 2006. 

DOE, under the direction of the Secretary of Energy, carries out its 

environmental cleanup program under the leadership of the Assistant 

Secretary for Environmental Management and in consultation with a 

variety of stakeholders. In addition to U.S. Environmental Protection 

Agency and state environmental and health agencies that have regulatory 

authority in states where the sites are located, stakeholders include county 

and local governmental agencies, DOE community advisory groups, and 

Native American tribes. DOE’s Office of Environmental Management is 

primarily responsible for cleaning up the wastes, largely through the use of 

contractors overseen by DOE staff. In addition, DOE’s Office of Civilian 

Radioactive Waste Management is responsible for the high-level waste 

repository being developed at Yucca Mountain in Nevada, which is the 

repository where DOE plans to dispose of spent nuclear fuel and high-level 

waste. DOE’s Office of Legacy Management, created in 2003, is responsible 

for managing DOE’s postclosure responsibilities at its former nuclear 

weapons production sites to ensure the continued protection of human 

health and the environment. 
Page 11 GAO-05-764 DOE's Accelerated Cleanup Program 

Over 2 years after implementing the accelerated cleanup plan, DOE has 

made progress in a number of areas, but the most difficult cleanup 

challenges remain. By March 2005, DOE was ahead or on its planned 

schedule in 13 of 16 risk reduction activities.6

 Activities that had met or 

were ahead of the accelerated schedule included packaging nuclear 

materials for disposition, disposing of low-level and low-level mixed 

waste, and removing buildings. In some cases where DOE was meeting or 

exceeding current risk reduction targets, only a small percentage of the 

overall work had been accomplished. In contrast, DOE was behind its 

schedule for key activities that will have a major impact on DOE’s overall 

cleanup goals. These activities involve some of the more complex cleanup 

activities, including disposing of transuranic waste, treating high-level 

liquid waste, and closing tanks that had contained radioactive wastes. 

These activities account for at least 30 percent of the total expenditures 

DOE expects on cleanup and more than half of the cost reductions it 

hopes to achieve under the accelerated cleanup plan. Finally, DOE has had 

problems with other treatment and disposal activities not reflected in its 

performance measures, such as significant delays in shipping plutonium 

from sites to final storage locations, and delays in design and construction 

of key facilities. Taken together, these results suggest that DOE may 

already be at risk of not achieving its accelerated cleanup goals. 

 6

As previously noted, DOE also uses an earned value management system to monitor large 

projects’ progress toward cost and schedule goals. An earned value system, when fully 

implemented, is intended to provide managers the ability to examine cost, schedule and 

performance accomplishments on a project. We do not discuss DOE’s earned value as a 

measure of progress in this report for two reasons. First, DOE has not fully implemented its 

earned value management system to measure all of its mission-related projects against a 

lifecycle cost estimate. In response to OMB recommendations noted above, DOE is 

currently working toward this goal. Second, we and others have raised concerns about the 

reliability of DOE’s earned value data. For example, the National Research Council 

reported in 2004 that the Department’s earned value management information may not be 

completely accurate. See National Academy of Sciences, Progress in Improving Project 

Management at the Department of Energy: 2003 Assessment (2004) (Washington, D.C.: 

2004). In addition, we reported in March 2005 that for several major projects, earned value 

management principles had not been properly implemented to measure cost and schedule 

performance. See U.S. Government Accountability Office, Department of Energy: Further 

Actions Are Needed to Strengthen Contract Management for Major Projects, GA0-05-123 

(Washington, D.C.: Mar. 18, 2005). 

Progress in 

Accelerating Cleanup 

at DOE’s Sites Has 

Been Mixed 
Page 12 GAO-05-764 DOE's Accelerated Cleanup Program 

DOE’s cleanup was ahead of its planned accelerated schedule for several 

activities, and other activities appeared to be on track. As of March 2005, 

DOE was ahead of schedule in 9 risk reduction measures that fell into the 

following cleanup categories7

—(1) tearing down and disposing of 

facilities, (2) packaging and disposing of special nuclear materials, (3) 

cleaning up low-level and low-level mixed waste, and (4) completing 

cleanup of specific locations where releases of contamination occurred. 

For example, in disposing of low-level and low-level mixed waste, DOE 

was more than 181,000 cubic meters—or 35 percent—ahead of its 

accelerated target goal. Table 2 shows the progress DOE has made in four 

categories, as of March 2005. 

Table 2: Cleanup Activities for Which DOE Was Ahead of Schedule as of March 

2005 

Risk reduction measure (unit 

measured) 

Lifecycle 

totala

Cumulative 

units 

planned as 

of March 

2005 

Cumulative 

units 

completed 

as of 

March 

2005

Cumulative 

units 

ahead as 

of March 

2005

Tearing down and disposing of facilities

Industrial facilities (number 

complete) 3,103 734 985 251

Nuclear facilities (number complete) 515 27 44 17

Radioactive facilities (number 

complete) 822 180 219 39

Special nuclear materials 

Plutonium packaged (number of 

containers) 5,850 5,724 6,314 590

Enriched uranium packaged 

(number of containers) 8,428 3,373 4,508 1,135

Plutonium/uranium residues 

packaged (kilograms packaged) 107,782 107,744 107,752 8b

Depleted uranium and uranium 

packaged (metric tons) 685,161 4,915 9,293 4,378c

Low-level/low-level mixed waste 

Low-level/low-level mixed waste 

disposed (cubic meters) 1,190,463 524,981 706,587 181,606

 7

For purposes of this report, we grouped DOE’s 16 risk reduction measures into eight 

broad categories. 

Progress Has Been Made 

on Several Cleanup 

Activities, Such as 

Disposing of Low-Level 

Waste and Removing 

Buildings 
Page 13 GAO-05-764 DOE's Accelerated Cleanup Program 

Risk reduction measure (unit 

measured) 

Lifecycle 

totala

Cumulative 

units 

planned as 

of March 

2005 

Cumulative 

units 

completed 

as of 

March 

2005

Cumulative 

units 

ahead as 

of March 

2005

Areas of Contamination 

Remediation complete (number of 

contamination areasd

) 10,416 5,425 5,605 180

Source: Compiled by GAO from DOE data. 

a

DOE’s lifecycle totals are based on estimates of the total amount of material required to be cleaned 

up. In 2003, these estimates were placed under DOE’s configuration control system—that is, the 

estimates cannot be changed unless approved by a DOE Environmental Management review board. 

b

This measure was slightly ahead of schedule and nearly complete. 

c

As of March 2005, DOE had packaged less than 2 percent of the lifecycle inventory for depleted 

uranium. A rapid increase in packaging is planned in 2009. 

d

Contaminated areas include burial grounds, dried ponds, and spills. 

These risk reduction measures show that DOE has made progress at an 

accelerated pace for a variety of cleanup activities that often require more 

readily available technology or standard treatment processes. For 

example, facility disposal primarily involves decontaminating and tearing 

down a building, and disposing of the rubble at established disposal sites. 

In addition, DOE’s measures show that it had nearly completed its activity 

to package plutonium and uranium residues, a highly dangerous activity 

due to the potential for a nuclear accident or worker exposure. 

While DOE has made progress in several areas, a significant part of the 

progress was due to accelerated activities at relatively few sites and 

reflects completion of only a small percentage of the overall work to be 

performed. For example, DOE’s Rocky Flats site alone accounted for more 

than 180,000 of the total 181,600 cubic meters of low-level and low-level 

mixed waste that DOE disposed of ahead of schedule. Similarly, more than 

half of the progress made ahead of schedule in remediating potential 

contamination areas was due to work performed at Rocky Flats. And 

although DOE made progress on many of its risk reduction measures, 

some individual sites did not make progress at an accelerated pace. For 

example, although DOE was ahead of schedule in disposing of low-level 

and low-level mixed waste, both the Oak Ridge site and the Lawrence 

Livermore National Laboratory were slightly behind their site targets on 

this measure. In addition, DOE’s progress in a few areas reflected 

achieving only a small portion of the overall work to be completed. The 

most extreme example shows that DOE was ahead in packaging depleted 

uranium; however, this reflects about 1 percent of the nearly 700,000 
Page 14 GAO-05-764 DOE's Accelerated Cleanup Program 

metric tons to be packaged. In tearing down and disposing of nuclear 

facilities, DOE had completed about 9 percent of the 515 facilities it has to 

clean up. 

In addition to areas in which DOE was ahead of schedule, cleanup 

progress was on track or nearly on track for four risk reduction measures 

in the following cleanup categories: (1) packaging high-level waste for 

disposal, (2) cleaning up special nuclear materials, (3) packaging spent 

nuclear fuel for disposal, and (4) eliminating geographic sites (see table 3). 

These cleanup activities involve difficult and hazardous work. 

Table 3: Cleanup Activities for Which DOE Was Generally on Schedule as of March 

2005 

Risk reduction measure (unit 

measured) 

Lifecycle 

totala

Cumulative 

units 

planned as 

of March 

2005 

Cumulative 

units 

completed 

as of 

March 

2005

Status of 

cumulative 

units as of 

March 

2005

Radioactive tank waste 

High-level waste packaged for 

disposition (number of containers)b

18,735 2,118 2,116 -2

Special nuclear materials 

Material access areasc eliminated 

(areas eliminated) 14 7 8 1

Spent nuclear fuel 

Spent nuclear fuel packaged for 

disposition (metric tons of heavy 

metal) 2,420 2,129 2,125 -4

Site closures 

Geographic sites eliminated (entire 

site complete) 114 76 75 -1d

Source: Compiled by GAO from DOE data. 

a

DOE’s lifecycle totals are based on estimates of the total amount of material required to be cleaned 

up. In 2003, these estimates were placed under DOE’s configuration control system—that is, the 

estimates cannot be changed unless approved by a DOE Environmental Management review board. 

b

Work accomplished under this cleanup activity reflects the processing, vitrifying, and packaging of 

high-level waste sludge primarily at the Savannah River Site. 

c

A material access area is a secure area that offers protection and control for a variety of special 

nuclear materials. 

d

DOE was behind in closing the Salmon, Mississippi, site scheduled for 2003. Completion is expected 

in fiscal year 2005. 
Page 15 GAO-05-764 DOE's Accelerated Cleanup Program 

Making progress on cleanup activities is an important step in reducing 

environmental risks and annual operating costs, and in demonstrating 

results under the accelerated cleanup plan. DOE officials told us that 

achieving cleanup results for these waste activities helps reduce future 

mortgage costs such as surveillance and maintenance of unneeded 

facilities, avoids potentially higher remediation costs in the future, and 

demonstrates actual cleanup progress. To achieve such progress in 

reaching its risk reduction goals, DOE took a number of steps including 

changing the sequence of some cleanup activities to complete tasks earlier 

than originally scheduled and reducing work scope where warranted for 

other activities. Site officials credited the achievements to remediating 

targeted areas such as contaminated burial grounds, waste sites, facilities, 

and plutonium production reactors along the Columbia River at Hanford 

and a variety of obsolete buildings at Idaho and Savannah River. 

According to DOE officials at these sites, many of these areas were 

scheduled for decommissioning and disposal in the future, but because 

they were no longer needed, they were disposed of earlier than originally 

planned. In addition, making progress in certain areas can free up funding 

for use on other, more complex projects. For example, at DOE’s Idaho 

National Laboratory, officials told us that completing disposal of most of 

its low-level and low-level mixed waste 2 years ahead of schedule has 

allowed them to apply the funds originally planned for managing this 

waste to other cleanup activities at the site. 

In contrast to progress on cleanup activities for which DOE is ahead of or 

on schedule, DOE is having difficulty with other cleanup work that could 

have a major impact on its accelerated cleanup goals. As of March 2005, 

DOE was falling behind in three risk reduction measures under two 

cleanup categories that account for a significant portion of the potential 

cost reductions DOE was expecting—radioactive tank waste and 

transuranic waste. See table 4 for a list of cleanup activities for the two 

waste types on which DOE has fallen behind since implementing the 

accelerated cleanup plan. 

Problems Have Occurred 

on Major Activities, 

Including Disposing of 

Transuranic Waste and 

Radioactive Tank Waste 

and Shipping Plutonium to 

Storage Locations 
Page 16 GAO-05-764 DOE's Accelerated Cleanup Program 

Table 4: Cleanup Activities for Which DOE Is Behind the Accelerated Schedule as of 

March 2005 

Risk reduction 

measure (unit 

measured) 

Lifecycle 

totala

Cumulative 

units planned 

as of March 

2005 

Cumulative 

units 

completed as 

of March 2005

Cumulative 

units 

behind as of 

March 2005

Radioactive tank waste

Liquid waste eliminated 

(gallons)b

 88,000,000 2,960,000 0 -2,960,000

Liquid waste tanks 

closed (number of tanks) 241 13 2 -11

Transuranic waste 

Transuranic waste 

disposed (number of 

cubic meters) 141,892 30,926 24,461 -6,465

Source: Compiled by GAO from DOE data. 

a

DOE’s lifecycle totals are based on estimates of the total amount of material required to be cleaned 

up. In 2003, these estimates were placed under DOE’s configuration control system—that is, the 

estimates cannot be changed unless approved by a DOE Environmental Management review board. 

b

While this cleanup activity is active at DOE’s Savannah River Site, no liquid waste has yet been 

eliminated, primarily because technology has not been fully developed and regulatory issues have not 

been fully resolved. 

DOE efforts to treat and dispose of radioactive waste from its tanks are 

primarily at three DOE sites—Hanford, Idaho, and Savannah River.8

However, because the Hanford and Idaho sites have not yet begun to treat 

their liquid radioactive tank waste, the measure for eliminating liquid 

waste from underground tanks applies to the Savannah River Site. 

Although Savannah River has been processing radioactive tank waste 

sludge since 1996, it was behind in processing and eliminating from its 

tanks nearly 3 million gallons of liquid primarily because the site was still 

developing waste separation technology and lacked operational treatment 

facilities for disposing of liquid tank waste.9

 While all three of DOE’s sites 

had performance goals for closing radioactive waste tanks through March 

 8

DOE’s West Valley site completed treatment of its high-level tank waste in 2002. 

9

As part of its radioactive tank waste treatment and disposal strategy, DOE plans to 

eliminate a large volume of low-activity waste in the tanks in its Salt Stone Facility where 

the waste is permanently immobilized on site using a concrete material called grout. 

However, efforts to operate this facility have been delayed. 
Page 17 GAO-05-764 DOE's Accelerated Cleanup Program 

2005, no tanks have been closed since 1997.10 Plans to close tanks at the 

three sites have been delayed because DOE continues to work with 

regulators to reach agreement on closure requirements and due to a legal 

challenge to DOE’s tank closure strategy. DOE’s authority to proceed with 

its tank closure plans at its Savannah River Site and the Idaho National 

Laboratory was resolved by federal legislation enacted in 2004; however, 

the law excluded the Hanford Site.11 Even so, Savannah River and the 

Idaho National Laboratory are still behind schedule in preparing waste 

removal facilities and obtaining regulatory approval to close the tanks. 

Although DOE is preparing 12 of its 241 radioactive waste tanks for 

closure, no tanks have actually been closed since the accelerated cleanup 

plan was implemented in 2003. 

Transuranic waste is present at several DOE sites, but lagging 

performance is due primarily to the Idaho National Laboratory. Disposing 

of transuranic waste involves specialized characterization and treatment, 

packaging, and shipping in specially designed containers to a repository in 

New Mexico. As of March 2005, DOE had fallen behind its accelerated 

schedule by about 6,500 cubic meters, achieving about 80 percent of the 

goal. Delays in Idaho’s transuranic waste disposal were primarily due to 

contractor performance problems in preparing the waste for shipment and 

difficulties in implementing a specially designed treatment technology. 

The activities and projects for which DOE was falling behind the 

accelerated schedule involve technically complex and costly cleanup 

activities, and usually require specialized treatment technologies. 

Radioactive tank waste, for example, involves treating highly radioactive 

waste generated from the reprocessing of reactor fuel that contains a mix 

of hazardous and radioactive constituents, and requires relatively complex 

treatment technologies such as waste separation and vitrification. 

Cleaning up radioactive tank waste accounts for about 30 percent—or 

almost $40 billion—of DOE’s estimated total cleanup costs. To date, key 

facilities DOE needs to use to treat and dispose of this waste are still being 

 10The Savannah River Site closed two tanks in 1997. DOE planned to close 11 additional 

tanks through March 2005. However, this has been delayed due to legal and regulatory 

issues, discussed in this paragraph. 

11Pub. L. No. 108-375, § 3116 authorizes DOE to pursue activities that would allow tank 

closure at its Savannah River Site and the Idaho National Laboratory, subject to certain 

criteria, existing cleanup orders and agreements, and monitoring by the Nuclear Regulatory 

Commission. Section 3116 states that the authority does not apply to sites in the state of 

Washington, where the Hanford Site is located. 
Page 18 GAO-05-764 DOE's Accelerated Cleanup Program 

designed and built, and waste treatment technologies continue to be 

developed and tested. Similarly, some of the greatest risks, cleanup costs, 

and technical challenges involve the disposal of transuranic waste. This 

waste often requires an extensive retrieval, characterization, and 

treatment process as well as repackaging in containers before it can be 

shipped to and disposed of in the designated geologic repository for 

transuranic waste in New Mexico. Transuranic waste disposal is behind 

schedule and DOE will have difficulties catching up if this activity 

continues to fall behind. 

In addition to the cleanup activities that DOE measures, other cleanup 

activities not included in DOE’s risk reduction measures are experiencing 

problems further impacting overall cleanup progress. Although no 

comprehensive list of these cleanup activities was available from DOE, we 

found several examples, some of which are listed below, that involve 

constructing facilities critical to DOE’s cleanup mission and relocating 

certain wastes or nuclear materials (see table 5). 

Table 5: Selected Cleanup Activities Experiencing Problems That Are Not Included 

in DOE’s Risk Reduction Measures 

Sites Project or activity Problem or uncertainty 

Potential impact on 

future progress 

Hanford Shipment of plutonium 

to offsite location 

Planned shipping of 

plutonium to designated 

site has been deferred 

while long-term storage 

issues are resolved 

Increased costs for 

extended onsite 

storage and security 

requirements 

Hanford Construction of waste 

treatment plant 

Delays primarily due to 

contractor performance 

problems and design 

changes to comply with 

seismic requirements 

Increased 

construction costs, 

extension of facility 

startup beyond 2011 

Idaho 

National 

Laboratory 

Storage of spent 

nuclear fuel 

Construction of storage 

facility is behind 

schedule 

At least a 3-year 

schedule delay in 

facility construction 

and operation and 

potential cost 

increases. Delays 

may be offset by 

delay in opening the 

planned disposal 

repository 
Page 19 GAO-05-764 DOE's Accelerated Cleanup Program 

Sites Project or activity Problem or uncertainty 

Potential impact on 

future progress 

Miamisburg Cleanup of landfill Disagreement with local 

community over further 

cleanup of landfill 

Increased cleanup 

costs 

West Valley Decommissioning of 

contaminated process 

facility 

Dispute over who is 

responsible 

Increased costs and 

extension of schedule 

beyond 2012 

Source: Compiled by GAO from DOE data. 

These cleanup activities can involve significant technical and operational 

problems. Even though DOE does not track the status of these problems in 

its risk reduction measures, DOE officials are aware of these problems and 

are working to resolve them. However, because these problems remain 

unresolved and their potential impact on the accelerated cleanup plan is 

uncertain, DOE may already be at risk of not achieving the kind of 

progress it predicted under its accelerated cleanup plan. For example, the 

Hanford Site must construct key facilities and test complex technologies 

before it can treat 55 million gallons of radioactive tank waste. Recently, 

work on this project has been delayed due to engineering and contractor 

performance problems, leading DOE to reevaluate its ability to complete 

the project under current cost and schedule constraints. DOE expects to 

revise project cost and schedule goals in fiscal year 2006. Despite these 

problems, DOE does not have a risk reduction measure that shows the 

progress of these activities or their potential impact on overall cleanup 

progress. Consequently, DOE will not be able to quantify progress in 

treating radioactive tank waste at Hanford until facilities are operational—

now planned for 2011, or later. Similarly, DOE’s strategy under the 

accelerated cleanup plan to consolidate Hanford’s plutonium offsite has 

been deferred while long-term storage issues are being resolved. DOE 

Hanford officials estimate that if the plutonium remains on-site, the 

additional costs to continue storing and securing the material may amount 

to more than $2 billion. Despite this problem, DOE’s plutonium risk 

reduction measure, which focuses on completing stabilization and 

packaging of the material, shows that this cleanup activity was ahead of 

schedule. 

When considered together, the results of DOE’s risk reduction measures 

for two main types of cleanup activities—radioactive tank waste and 

transuranic waste, which are behind schedule and require additional 

cleanup activities—suggest that DOE may already be at risk of not 

achieving its overall risk reduction goals. Each of these problems 

represents a significant obstacle to DOE successfully completing cleanup 

activities under its accelerated plan. Success hinges on DOE’s ability to 
Page 20 GAO-05-764 DOE's Accelerated Cleanup Program 

continue reducing risks by making cleanup progress and keeping costs 

and schedules within the constraints of DOE’s plan. 

DOE’s accelerated plan is unlikely to achieve the $50 billion cost reduction 

goal for three main reasons. First, DOE’s method for calculating cost 

reductions has limitations that raise questions about its reliability. The 

actual cost reduction from the accelerated cleanup plan, if implemented as 

intended, would likely be much lower. Second, the accelerated plan is 

based on a number of key assumptions about improvements to the 

cleanup approach—such as shortened schedules and technology 

improvements—that may not occur as planned. Third, the three sites that 

account for most of the cost reduction are already facing challenges and 

have either increased their cost estimates or plan to increase their funding 

requests, raising doubts about DOE’s ability to achieve its full expected 

cost reductions. While DOE believes the accelerated cleanup plan will 

reduce costs, the actual amount of those cost reductions is uncertain. 

DOE calculated its estimated $50 billion in cost reductions by comparing 

its fiscal year 2001 cost estimate for the program—the last cost estimate 

before DOE implemented its accelerated strategy—with its fiscal year 

2003 cost estimate for the program—the first complete cost estimate 

under the new accelerated strategy.12 DOE’s 2001 cost estimate for the 

program was $192 billion, reflecting its prior approach to cleaning up its 

radioactive and hazardous wastes by 2070.13 The 2001 estimate represented 

forecasts generated by DOE’s field staff at each of its sites and for each of 

its activities. Aggregating these site-developed estimates, DOE arrived at 

its 2001 cost estimate for the program. In contrast, to develop its 2003 

estimate—reflecting an accelerated approach—DOE provided several of 

the sites with target costs that the sites were to work towards meeting.14

These target costs were based on assumptions from the headquarters 

officials about how and when the work should be completed. Under this 

 12DOE began implementing the accelerated plan in 2002, but the accelerated cost estimates 

were not in place until fiscal year 2003. 

13In 2001, when the estimate was developed, the scope of work included both waste 

cleanup activities and postcleanup stewardship activities at the sites once the cleanup 

work is complete. 

14According to DOE officials, sites were allowed to request a higher target cost estimate, 

but had to have this approved by the Assistant Secretary. Four sites did make this request 

for their 2003 cost estimate. 

DOE Is Unlikely to 

Achieve Its Estimated 

$50 Billion in Cost 

Reductions 

DOE Estimates Overstated 

Potential Cost Reductions 
Page 21 GAO-05-764 DOE's Accelerated Cleanup Program 

new strategy, DOE’s 2003 estimate for completing the cleanup work was 

$142 billion. DOE subtracted the 2003 estimate for the new strategy ($142 

billion) from the 2001 estimate under the original strategy ($192 billion) to 

arrive at its $50 billion cost reduction estimate.15

However, DOE’s estimated $50 billion in cost reductions from accelerating 

cleanup at its sites may not be fully reliable for several reasons: 

• Pre-acceleration baseline cost estimate may be unreliable. In a February 

2002 review of the cleanup program, DOE specifically acknowledged that 

its cost estimate of the program did not provide a reliable estimate of 

project costs. DOE officials explained that the site-level estimates of 

cleanup work were based on calculations that were highly uncertain 

beyond the life of the contracts. We and others have previously raised 

concerns that DOE’s cleanup cost estimates may not be fully reliable. In 

our prior work, we noted that in preparing baseline cost estimates, DOE 

lacked a standard methodology for sites to use.16 Further, in the past, 

DOE’s Office of Inspector General and the National Research Council have 

raised similar concerns about DOE’s estimates being incomplete and 

unreliable.17

• Estimates did not include contingency costs. Because of the high 

uncertainty surrounding the cleanup work, DOE computes additional 

uncertainty costs—called contingency estimates18—which are added to the 

 15To make these figures comparable, DOE made some adjustments. For example, DOE 

subtracted approximately $10 billion from its 2001 cleanup estimate of $202 billion to 

account for work that was included in its pre-accelerated scope but had not yet been 

included in 2003, and added approximately $13 billion of long-term stewardship work to its 

2003 cleanup estimate of $129 billion. DOE currently manages to the $129 billion cost 

estimate. For comparison purposes, the adjusted estimates of both cleanup and long-term 

stewardship work in 2001 and 2003 were $192 billion and $142 billion, in DOE’s stated 

“2003 constant dollars,” respectively. See also footnote 2. 

16U.S. General Accounting Office, Nuclear Waste: Challenges to Achieving Potential 

Savings in DOE’s High-Level Waste Cleanup Program, GAO-03-593 (Washington, D.C.: 

June 17, 2003). 

17U.S. Department of Energy Office of Inspector General, Audit of the U.S. Department of 

Energy’s Consolidated Financial Statements for Fiscal Year 1998, IG-FS-99-01 

(Germantown, Md: Feb. 25, 1999). See also National Research Council, Improving Project 

Management in the Department of Energy (Washington, D.C.: June 1999). 

18As defined in DOE’s fiscal year 2004 financial statements, contingency estimates are 

intended to account for the uncertainties associated with the technical cleanup scope of 

the program. 
Page 22 GAO-05-764 DOE's Accelerated Cleanup Program 

overall cleanup estimates in its annual financial statements. These costs 

are intended to cover any underestimated or unforeseen cleanup work. In 

2001, DOE estimated that because of uncertainty related to the cleanup, it 

would add a contingency estimate equal to an additional 17 percent of its 

cleanup cost estimate. In contrast, following implementation of the 

accelerated plan, DOE estimated in 2003 that increased uncertainty called 

for nearly doubling the contingency estimate to 29 percent of the cleanup 

cost estimate. However, when calculating its expected cost reduction 

under the accelerated plan, DOE did not include either of these 

contingency estimates in its comparison of the two estimates. Doing so 

would likely have lowered the estimated cost reductions to below $50 

billion. 

• No present value analysis was performed. DOE’s estimate of potential 

cost reductions did not consider the time value of money. As we noted in 

our previous report,19 according to standard economic analysis and 

guidance developed by OMB,20 cost-comparison analyses should be based 

on lifecycle costs of competing alternatives with future costs discounted 

to present value; that is, adjusted both for inflation and the time value of 

money.21 According to OMB’s cost-estimating guidance, DOE should have 

first converted the annual expected costs of cleanup for both its 2001 and 

its 2003 estimates to their present value in 2003, and then compared the 

two present-value costs. While DOE’s comparison of its estimates is based 

on values that are expressed in constant 2003 dollars (to account for 

inflation), DOE did not adjust its figures to account for the time value of 

future costs.22 Had DOE compared present value estimates for 2001 and 

2003, the resulting cost reduction would likely have been much lower. For 

example, when we adjusted DOE’s estimated $20 billion cost reduction for 

 19U.S. General Accounting Office, Nuclear Waste: Absence of Key Management Reforms on 

Hanford’s Cleanup Project Adds to Challenges of Achieving Cost and Schedule Goals, 

GAO-04-611 (Washington, D.C.: June 9, 2004). 

20OMB Circular No. A-94, Guidelines and Discount Rates for Benefit-Cost Analysis of 

Federal Programs (Washington, D.C.: Oct. 29, 1992). 

21DOE’s own guidance requires a present value analysis to discount future dollars to reflect 

the time value of money. Present value analysis is a method used to evaluate alternative 

expenditures that occur at different times and put them on a common basis for 

comparison. It goes beyond adjusting the values for inflation, which is a correction for 

changes in the purchasing power of the dollar. Therefore, conducting a present value 

analysis goes beyond computing cost estimates in constant year dollars. 

22In addition, DOE’s cost estimate includes actual (current) dollars for pre-2001 values, 

rather than calculating these in constant 2003. As a result, DOE’s 2001 and 2003 baselines 

do not fully reflect constant 2003 dollars. 
Page 23 GAO-05-764 DOE's Accelerated Cleanup Program 

the Hanford waste treatment project to consider the time value of money, 

the potential cost reduction decreased by about 40 percent—to about $12 

billion. 

As part of its plan to reduce the expected cost of the cleanup and 

eliminate risks more quickly, DOE made several assumptions about ways 

to improve the cleanup work. These assumptions included (1) developing 

new technologies, such as a technology to allow more efficient 

vitrification of some wastes; (2) implementing new acquisition strategies 

that encourage and reward contractor efficiencies, such as performancebased contracts; (3) revising site cleanup agreements to simplify treatment 

and disposal requirements, such as reclassifying some wastes allowing for 

disposal on site rather than remotely; and (4) completing work sooner 

than planned thereby eliminating out-year costs. 

Assumed improvements in DOE’s cleanup approach resulted in DOE’s 

estimated $50 billion in cost reductions (see figure 1). 

Cost Reductions Were 

Based on Assumed 

Performance 

Improvements That May 

Not Occur 
Page 24 GAO-05-764 DOE's Accelerated Cleanup Program 

Figure 1: Contributions of Key Assumptions to DOE’s Estimated $50 Billion in Cost 

Reductions 

a

When DOE collected its cost reduction data from each site, some of the improvements related to 

finishing cleanup work sooner were also closely tied to the other assumed improvements resulting in 

some overlap among the categories. 

The assumptions enabled DOE to develop revised cleanup cost estimates 

at most sites that reflected cost reductions (see figure 2). 

Work finished soonera

Technology improvements

Revised contracting strategies

Other

Revised cleanup agreements

9%

10%

10%

29%

42%

Source: GAO analysis of DOE data.
Page 25 GAO-05-764 DOE's Accelerated Cleanup Program 

Figure 2: DOE’s Expected Cost Reduction by Office 

a

Includes both the Office of River Protection and the Richland Operations office. 

b

DOE did not estimate large cost reductions from Rocky Flats because that site had already 

implemented many of the accelerated strategies and reduced its cost estimate before 2001. 

c

Includes Headquarters and Program Direction costs. 

d

Because of work transfers within the Office of Environmental Management, some costs changed in 

2003 at sites that closed before 2003. 

Although these assumed improvements may have the potential to reduce 

cleanup costs, many of them are still uncertain and may not occur. For 

example, 

• Technology improvements. DOE assumed that significant cost reductions 

would result from improved technologies that would allow treatment and 

disposal of waste faster and at lower costs. Nearly all of the estimated cost 

reduction pertains to improvements in the technologies at the Idaho 

National Laboratory and Hanford sites. For example, DOE expected a $4.7 

billion cost reduction at the Idaho National Laboratory by using a 

technology for separating a portion of the tank waste, but that technology 

has still not been successfully tested and implemented on DOE tank waste. 

Similarly, at the Hanford site, DOE is testing a technology that officials 

estimated would speed up the stabilization of some low-activity wastes 

reducing costs by an estimated $8.9 billion. However, the technology has 
Page 26 GAO-05-764 DOE's Accelerated Cleanup Program 

not been fully implemented or tested on Hanford’s unique waste, and costs 

of operating the new technology are not yet known, so the extent of cost 

reductions DOE assumed could be incorrect. For example, an official for 

the contractor developing the pilot plant to test this technology said the 

project is already projecting cost increases and is currently estimated to 

begin operating about 6 months late. 

• Contract reform. DOE estimated that revised contracting strategies would 

also result in significant cost reductions. However, at two of DOE’s largest 

sites—Savannah River and Hanford—DOE will not award some major new 

contracts until 2006. Until then, the final price of DOE’s new contracts and 

any potential cost reductions associated with them are uncertain. For 

example, DOE has assumed it will reduce overall costs by more than 20 

percent under its new Savannah River Site contract. However, the details 

and final cost of the contract will not be finalized until the contract is 

awarded. External auditors acknowledged this uncertainty at Hanford in 

their assessment of DOE’s fiscal year 2004 environmental liabilities 

estimate, noting that it was “not appropriate” to assume cost reductions 

from future contracts since those reductions are “neither probable nor 

susceptible of reasonable estimation.” 

• Revisions to cleanup agreements. DOE estimated additional cost 

reductions would result from revising site-specific waste cleanup 

agreements with federal and state regulators. However, regulators have 

not agreed to or are resisting revisions to agreements that accounted for 

most (at least 75 percent) of these expected cost reductions. For example, 

DOE expected to be able to determine that some radioactive tank waste is 

not high-level waste but transuranic waste, thereby allowing DOE to ship 

the treated waste to the Waste Isolation Pilot Plant for permanent disposal 

and reducing costs by $1.5 billion. However, in late 2004, the head of New 

Mexico’s Environment Department—the state regulator for the 

repository—said the state would refuse to accept DOE’s tank waste for 

disposal at the repository because New Mexico considers that waste to be 

high-level, not transuranic, waste. In addition, because of the uncertainty 

about the disposal path for this radioactive tank waste, the state of 

Idaho—which has a regulatory agreement with DOE to treat and dispose 

of the waste out of the state—prefers that DOE apply more extensive highlevel waste treatment technologies. 

• Work completed sooner. DOE also expected cost reductions resulting from 

completing work sooner through improvements that, in many cases, also 

depend on the assumptions discussed above. Because of the uncertainty 

surrounding assumed improvements in its cleanup operations, DOE’s 

anticipated cost reductions from completing work sooner are also in 
Page 27 GAO-05-764 DOE's Accelerated Cleanup Program 

jeopardy. For example, DOE estimated approximately $2.8 billion in cost 

reductions at its Savannah River Site from accelerating the cleanup of 

radioactive tank waste. However, that reduction depends on implementing 

a new waste treatment technology that has not yet been fully tested 

outside a laboratory. As a result, the uncertainties surrounding 

technological improvements raise doubts about DOE’s ability to accelerate 

its schedule. In addition, several of the projects that DOE expects to 

complete in less time are already experiencing problems. For example, 

DOE estimated that an approximately $2.8 billion cost reduction would 

result, in part, from revising its schedule for shipping transuranic waste to 

the repository in New Mexico. However, as we noted above, transuranic 

waste packaging and shipping is already behind schedule. 

DOE expected cost reductions to occur at nearly all of its cleanup sites, 

but most of the total estimated cost reduction was expected from 3 sites 

that account for the largest portion of DOE’s overall cleanup costs—

Hanford, Savannah River, and Idaho National Laboratory. However, these 

sites are already facing challenges to their cleanup efforts which may 

jeopardize DOE’s ability to achieve its estimated $50 billion cost reduction. 

Although it is impossible to precisely predict the impact that these 

challenges will have on DOE’s overall cleanup costs, any cost increases at 

these sites could offset cost reductions at other sites and lower the 

potential for overall cost reductions from the accelerated plan. 

The types of challenges that could increase cleanup costs at these three 

DOE sites include the following: 

• Delays in disposing of highly radioactive wastes. In early 2005, DOE 

reported that a slip in the scheduled opening of DOE’s planned repository 

at Yucca Mountain, Nevada would delay shipment of waste by at least 2 

years—and possibly for as long as 7 years—due to technical and 

regulatory issues. As a result, sites now storing high-level waste and spent 

nuclear fuel have been reevaluating their waste disposal plans and 

associated cost and schedule estimates. The sites potentially affected 

include Hanford, Idaho National Laboratory, Savannah River, and West 

Valley. Most sites expect costs to increase as disposal schedules slip. In its 

fiscal year 2006 budget request, DOE estimated that a five year delay in 

opening the Yucca Mountain repository could increase costs by as much 

as $720 million at its three largest sites. This includes building additional 

storage buildings and added operating costs. 

• Legal obstacles preventing DOE from implementing aspects of its 

cleanup approach. DOE faces challenges to its planned treatment strategy 

Nearly All of the Cost 

Reductions Were to Occur 

at Three Sites Where DOE 

Is Having Significant 

Technical, Regulatory, or 

Management Challenges 
Page 28 GAO-05-764 DOE's Accelerated Cleanup Program 

at the Hanford Site that could potentially increase costs. A 2002 lawsuit 

challenged DOE’s plans to separate and determine that a portion of its 

waste could be treated and disposed of as other than high-level waste, and 

to DOE’s plans to close tanks leaving some radioactive residual in the 

tanks. In October 2004, a federal appeals court overturned a district court 

ruling against DOE and held that it was premature to rule on the matter 

until DOE implemented its strategy.23 Federal legislation passed in October 

2004 provided authority for DOE to carry out its acceleration completion 

strategy at its Savannah River Site and Idaho National Laboratory. 

However, the law excluded the Hanford Site.24 If similar authority is not 

provided for the Hanford Site, costs at the site could increase 

significantly—up to $67 billion, according to DOE’s estimate. Similarly, 

uncertainty surrounds Hanford’s ability to accept waste from other DOE 

sites as the result of two ongoing lawsuits: one involving a challenge by 

the state of Washington to DOE’s plan to ship low-level, low-level mixed, 

and transuranic waste into the state,25 and one concerning a recent 

Washington state citizens’ initiative that could prohibit Hanford from 

accepting additional waste until existing waste is cleaned up.26 Although 

DOE believes it will ultimately prevail in these lawsuits, some cleanup 

activities at the other sites may face delays and increased storage costs 

until the issue is resolved. 

• Other pressures increasing costs at key sites. By the end of fiscal year 

2004, the total cost estimate of the cleanup work at two of DOE’s largest 

sites had already increased above cost targets established in 2003. At the 

Savannah River Site and Idaho National Laboratory overall cleanup 

estimates in 2004 were over $2.0 billion higher than in 2003. Similarly, 

officials at DOE’s Hanford Site indicated in recent public meetings that 

they are requesting cleanup funding above previously established funding 

targets for fiscal year 2007, which, if approved, will also add to the plan’s 

total cost. According to the site officials, the additional funds are being 

 23Natural Resources Defense Council v. Abraham, 388 F.3d 701 (9th Cir. 2004). 

24Pub. L. No. 108-375, § 3116 (2004). 

25State of Washington v. Bodman, No. CV-03-5018-AAM (E.D. Wash.). 

26Washington state voters passed Initiative 297, the Cleanup Priority Act, now codified in 

chapter 70.105E of the Revised Code of Washington (RCW), in November 2004. Its scope 

and constitutionality are currently being litigated in the federal district court and in the 

Supreme Court of Washington. United States v. Hoffman, No. CV-04-5128-AAM (E.D. 

Wash., filed Dec. 1, 2004), certified to Washington state to address interpretation of state 

law, United States v. Hoffman, No. 76629-1 (Wash. Feb 8, 2005). 
Page 29 GAO-05-764 DOE's Accelerated Cleanup Program 

requested primarily to address higher than expected waste management 

and treatment costs. 

Because of the limitations and uncertainties discussed above, DOE’s $50 

billion cost reduction goal is unlikely to occur. Recognizing that achieving 

the full $50 billion in cost reductions may be in jeopardy, DOE officials 

recently stopped citing any specific estimate in connection with the 

accelerated plan. However, DOE continues to believe it will achieve some 

cost reductions with its accelerated strategy. 

DOE’s performance reporting does not present a clear understanding of 

progress toward meeting the $129 billion cost target and 2035 completion 

date of the accelerated cleanup plan. While DOE performance measures, 

as discussed earlier in this report, provide useful information about the 

current status of cleanup activities, there are two main shortcomings in 

the way DOE uses these measures to report its progress toward meeting 

the overarching goals of the accelerated plan. First, in reporting on its 

performance, DOE does not clearly relate cleanup accomplishments with 

their associated costs. Second, DOE reports its performance in a way that 

does not highlight key cleanup activities or events that have significant 

implications for achieving overall cleanup goals. These shortcomings 

make it difficult for the Congress and the public to fully understand how 

likely DOE will be able to achieve its accelerated cleanup cost target and 

completion date. 

We and others have emphasized the importance of ensuring that reporting 

on program performance allows a clear understanding of how well a 

program is meeting goals; that is, linking performance goals with program 

costs. In a February 2005 study, we noted that federal accountability 

laws—the Government Performance and Results Act of 1993 (GPRA) and 

the Chief Financial Officers Act of 1990—emphasize the importance of 

linking program performance information with financial information as a 

key feature of sound management and an important element in presenting 

to the public a useful and informative perspective on federal spending.27

Additionally, OMB indicated to federal agencies that annual performance 

 27U.S. Government Accountability Office, Performance Budgeting: Efforts to Restructure 

Budgets to Better Align Resources with Performance, GAO-05-117SP (Washington, D.C.: 

Feb. 2005). 

DOE’s Performance 

Reporting Does Not 

Clearly Reflect 

Progress Made 

toward Achieving the 

Overarching Goals of 

the Accelerated 

Cleanup Plan 

Performance Reporting 

Practices Make It Difficult 

to Clearly Understand the 

Relationship Between 

Cleanup Progress and Cost 

Performance 
Page 30 GAO-05-764 DOE's Accelerated Cleanup Program 

budgets should clearly link performance goals with costs for achieving 

those goals, both long-term and annual performance goals.28

DOE’s performance reporting does not provide for a clear understanding 

of how well the cleanup program is performing. In reporting on its 

progress, DOE does not establish how accomplishments made in 

addressing wastes—which DOE measures through its risk reduction 

measures—are associated with the costs incurred—which DOE measures 

through its cost performance measures. Rather, DOE reports separately on 

the waste treatment and disposal goals it has achieved using one measure 

and reports on whether cleanup activities are being performed within cost 

parameters using another measure. These separate measures are 

organized around different categories and have different units of measure, 

making it difficult to link the information the two measures provide (see 

table 6). 

 28Executive Office of the President, Office of Management and Budget, OMB Circular No. 

A-11 (2004), Part 6, Section 220-1—Preparing and Submitting Performance Budgets 

(Washington, D.C.: July 2004). 
Page 31 GAO-05-764 DOE's Accelerated Cleanup Program 

Table 6: Comparative Features of DOE’s Risk Reduction Measures and Cost 

Performance Measures 

Comparative features Risk reduction measures 

Cost performance 

measures 

Organization of 

measure 

Organized around 16 specific 

categories or outcomes 

Organized around 7 

project categories 

Information included May have more than one measure 

for the same waste type, for 

example, radioactive tank waste 

has 3 risk reduction outcomes 

May include costs 

associated with more than 

one cleanup activity, such 

as packaging transuranic 

waste and disposing of 

low-level waste 

Time period measured Measures progress against the 

lifecycle plan 

Measures against costs in 

contract period 

Type of measurement Scored as a positive or negative 

variance, indicating number of 

units ahead/behind the target 

An overall score indexed 

to 1.0, where greater than 

1 is on or ahead of 

schedule and below 1 is 

behind schedule 

Scope limitations Does not cover all activities 

associated with a waste group, for 

example radioactive tank waste 

measures do not include shipping 

activities 

Does not cover all costs 

related to specific waste 

activities, for example, 

does not cover security 

costs 

Source: GAO analysis. 

The difficulty of understanding the relationship between cleanup 

accomplishments and cost performance can be illustrated by comparing 

the performance information available on transuranic waste. DOE’s risk 

reduction measure provides useful information about how much 

transuranic waste was processed and disposed of, but DOE does not 

separately report cost information related to transuranic waste 

accomplishments. Instead, DOE includes costs associated with 

transuranic waste activities as part of a larger project category titled “solid 

waste stabilization and disposition.” Therefore, DOE and others generally 

do not have a complete picture of performance for this activity, such as 

the impact on cost and schedule of falling behind in processing and 

disposing of the waste. For example, as of March 2005, DOE’s Idaho 

National Laboratory was more than one year—or more than 1,000 

shipments—behind its planned number of shipments of transuranic waste 

to the federal repository. However, DOE reports no corresponding cost 

performance measure to indicate the impact of this delay on cost and 

schedule (see table 7). During the same time period, Idaho’s solid waste 

stabilization and disposition cost performance score indicated the project 

category was “green,” or remaining within cost and schedule goals. 
Page 32 GAO-05-764 DOE's Accelerated Cleanup Program 

However, because of the delays in transuranic waste shipments, DOE is 

significantly behind schedule, has recently ended the contract, and is now 

in the process of determining the cost impact of these delays. 

Table 7: Performance Information on Idaho National Laboratory Transuranic Waste 

Shipments as of March 2005 

Risk reduction performance Cost performance 

Total units to ship overall 66,139 

cubic 

meters 

Total lifecycle cost Not 

separately 

reported 

Planned units shipped to date 14,581 

cubic 

meters 

Planned cost to date Not 

separately 

reported 

Actual units shipped to date 4,160 

cubic 

meters 

Actual cost to date Not 

separately 

reported 

Variance -10,421 

cubic 

meters 

Variance Not 

separately 

reported 

Source: DOE. 

The importance of directly linking progress on cleanup with cost 

performance has been recognized by OMB. In a fiscal year 2005 program 

review of DOE, OMB found that DOE’s cleanup program had not 

developed annual cost and schedule performance measures to monitor 

progress towards completing the cleanup mission. OMB officials said that 

better linking cleanup progress and cost performance in DOE’s 

performance reporting would allow for tracking DOE’s performance 

against its long term goals. 

DOE acknowledged that its performance reporting practices currently do 

not directly link progress on cleanup with performance against cost and 

schedule targets. According to a senior DOE adviser to the Principal 

Deputy Assistant Secretary for Environmental Management, the 

Department’s earned value management system could eventually provide 

this linkage, but DOE is still working to fully implement the system and to 

ensure that it provides reliable data. He said that DOE’s earned value 

management system will eventually produce information on the cost, 

schedule, and work completed over the lifecycle of all projects related to 

its cleanup mission, and may eventually provide an aggregate earned value 

score for the entire cleanup program. 
Page 33 GAO-05-764 DOE's Accelerated Cleanup Program 

While these steps may be useful, for DOE’s performance reporting using 

earned value to provide for a full understanding of cleanup performance, 

DOE will need to also report on the linkage between cost, schedule, and 

performance data by (1) generating comparable cost, schedule, and 

performance data at an activity level, such as processing and disposing of 

transuranic waste and (2) ensuring that the cost data is reported in 

relation to lifecycle cost targets, not just for a specific year or contract 

period. While DOE is working toward including lifecycle cost targets and 

performance in its earned value data, it is not taking steps to directly link 

risk reduction measures with cost performance at the activity level. 

According to a senior adviser to the Principal Deputy Assistant Secretary 

for Environmental Management, the department has been focused on 

ensuring that site cost estimates are reliable and that all mission-related 

projects are covered under the earned value system. However, unless this 

linkage is established, DOE performance reporting will not provide for a 

full understanding of progress being made by individual cleanup activities 

or whether it is on track with its overall $129 billion cost target for 

completing the cleanup program. 

Performance reporting should provide for a clear understanding by the 

Congress and the public of how an agency is progressing in achieving its 

program goals. In assessing how various government agencies reported on 

their progress, we noted in a 2004 report that agencies need to consider 

the needs of the information’s user and best tailor performance 

information so that a clear picture of the agency’s progress is presented. 

We found that an agency’s performance data can have real value only if the 

data are used to highlight actual performance against an agency’s planned 

goals.29

DOE publicly reports on its progress toward achieving accelerated 

cleanup plan goals through various means, including providing 

information to the Congress in annual budget submissions, reporting 

progress against selected annual goals in the agency’s annual performance 

and accountability report, and making information accessible on the 

department’s Web site. In all three cases, DOE primarily relies on the risk 

reduction measures as the indicator of cleanup progress. For example, in 

 29U.S. Government Accountability Office, Results-Oriented Government: GPRA Has 

Established a Solid Foundation for Achieving Greater Results, GAO-04-38 (Washington, 

D.C.: Mar. 10, 2004). 

Performance Reporting 

Does Not Highlight Critical 

Activities that Are Best 

Indicative of Overall 

Performance 
Page 34 GAO-05-764 DOE's Accelerated Cleanup Program 

its fiscal year 2006 budget request to the Congress, DOE provided 

information on all 16 risk reduction measures, including the amount of 

work estimated to be completed through fiscal year 2006, such as number 

of buildings torn down, and the estimated total amount of work to 

accomplish. In the budget request, DOE also included a variety of other 

program information, such as general cleanup achievements to date, and 

identified 7 risk reduction measures it would use to assess progress at the 

end of the fiscal year. Similarly, in accordance with federal reporting 

requirements, DOE provides performance information each year in its 

annual performance and accountability report that accompanies the 

department’s annual financial statement. In the performance and 

accountability report, DOE describes the general goals of the cleanup 

program, external factors that could affect DOE’s ability to achieve those 

goals, and its progress against selected performance goals for the year. 

Finally, on its Web site, DOE provides descriptive information for its 16 

risk reduction measures, including how much work has been 

accomplished to date for each measure and the estimated total amount of 

work to accomplish for each measure. 

Although this information is useful, DOE’s performance reporting does not 

present a complete picture of progress toward accelerated cleanup plan 

goals. For example, DOE has, up to now, reported on its progress as 

measured against annual goals, rather than its progress in meeting its 

overall $129 billion cost target and 2035 completion date. By doing so, 

DOE provided a different picture of the department’s progress than if 

progress was compared with longer term goals. Two examples from the 

agency’s performance reporting in its 2004 Performance and 

Accountability Report illustrate this point. In its 2004 report, DOE 

reported it met less than 80 percent of its annual goal of closing 9 liquid 

waste tanks in fiscal year 2004. In fact, DOE met 0 percent of its goal, has 

closed no tanks since 1997, and is currently significantly behind its 

estimated lifecycle target for this activity. To regain its performance 

schedule, DOE would need to complete the regulatory process and close 

19 waste tanks by the end of fiscal year 2005. However, this is an unlikely 

achievement given the length of time of remediation and regulatory work 

that is required before the tanks can be closed. In a second example, DOE 

reported it had met less than 80 percent of its annual planned target for 

packaging plutonium and uranium residues because it was 175 kilograms 

behind its accelerated schedule. However, calculating DOE’s performance 

for this activity against the estimated lifecycle target indicates that DOE 

was actually 33 kilograms ahead of its cumulative goal by the end of 2004. 

According to a senior DOE adviser to the Principal Deputy Assistant 

Secretary in the Office of Environmental Management, DOE plans to begin 
Page 35 GAO-05-764 DOE's Accelerated Cleanup Program 

reporting its progress against lifecycle goals in the department’s fiscal year 

2005 performance and accountability report. 

Another area of concern is that DOE’s performance reporting does not 

highlight performance on critical cleanup activities that could best provide 

information about whether the department is on track to meet its $129 

billion cost target. Among DOE’s various performance measures, certain 

ones are more important for indicating whether DOE is on track with its 

overall accelerated cost and schedule goals, and may provide a different 

picture of progress than DOE is currently reporting. In the longer term, to 

provide an indication of progress toward overall accelerated goals, 

projects that account for a large portion of DOE’s spending—and 

correspondingly contribute the most towards cost reductions—can serve 

as key indicators of progress. For example, DOE expects a significant 

portion of accelerated plan cost and schedule reductions to be achieved 

from two waste types that are the most difficult to address—radioactive 

tank waste and transuranic waste. DOE’s radioactive tank waste program 

alone accounts for nearly 60 percent—almost $30 billion—of DOE’s 

estimated cost reductions under the accelerated plan. Highlighting 

performance in these areas would provide a better indication of how well 

DOE is progressing toward its longer term accelerated cleanup goals. As 

previously discussed, both radioactive tank waste and transuranic waste 

are the two areas where DOE’s progress has fallen behind. In three of four 

risk reduction measures the department uses to track progress of its 

radioactive tank waste and transuranic waste activities, DOE has 

experienced delays that could impact cost. Furthermore, work on DOE’s 

$5.7 billion waste treatment construction project at Hanford—an activity 

not tracked by a risk reduction measure—has been delayed, creating 

potentially significant cost and schedule increases. While DOE includes 

radioactive tank waste and transuranic waste in its performance reporting, 

the department does not identify the significance of these cleanup 

activities for meeting overall cleanup cost and schedule goals. 

In the short term, closure sites and key activities that are contributing to 

planned budget declines over the next few years may provide a good 

indication of whether DOE is currently on track to meet its planned 

accelerated cost target. DOE’s accelerated plan calls for a decrease in 

annual funding requirements between 2005 and 2008. That is, DOE’s 

annual funding requirement is planned to drop from about $7.3 billion in 

fiscal year 2005, to about $4.5 billion by 2008—or a decline of about $2.8 

billion. Almost 90 percent of this decline is attributable to 10 sites 

scheduled to be closed in 2006, and progress on eight key projects. 

Currently, the indicators for these sites and projects show that at least half 
Page 36 GAO-05-764 DOE's Accelerated Cleanup Program 

are behind in some or all cleanup activities. For example, DOE’s 

Miamisburg, Fernald, and Lawrence Livermore Laboratory sites—all 

scheduled to complete cleanup by 2006—are behind in at least one risk 

reduction activity. Similarly, DOE’s spent nuclear fuel project at Hanford 

was in danger of exceeding its cost target as of April 2005. Providing 

aggregate information on the potential cost increases or schedule delays in 

this group of sites could help gauge DOE’s ability to achieve a funding 

decline over the next few years. 

It is not clear what impact the challenges DOE faces will have on its 

overall ability to achieve near-term or longer-term cost reduction goals. 

However, DOE’s performance reporting does not highlight this 

information nor does DOE report which activities are the most significant 

to achieving its overall cost and schedule goals. DOE officials said that, in 

their view, the department’s current reporting of its performance in the 

annual performance and accountability report and in its budget 

submission is sufficient to provide an understanding of progress towards 

the program’s long-term goals. DOE officials also noted that, internally, 

senior DOE managers use a variety of performance measures to monitor 

more critical elements of the program that are not included in any public 

reporting of accelerated cleanup progress. Nevertheless, because DOE 

reporting methods do not identify critical indicators such as progress on 

key cleanup activities, the department is not providing the Congress and 

the public the basis for a full understanding of its progress toward 

achieving the goals of the accelerated cleanup plan. 

DOE expected that its accelerated cleanup plan would allow it to clean up 

contaminated sites faster and at significantly lower cost than previously 

planned. While DOE has made progress toward its cleanup goals, 

important challenges remain and DOE is not likely to achieve its original 

goal of $50 billion in estimated cost reductions. While DOE’s performance 

reporting provides information on some aspects of cleanup progress, it 

does not provide for a full understanding of how the many uncertainties 

DOE faces could affect achieving cleanup goals and does not include a 

meaningful analysis of the significance of the data. Furthermore, because 

DOE’s reporting methods do not directly correlate cleanup results with the 

associated costs and fail to identify critical indicators, such as progress on 

key cleanup activities, DOE is not providing an adequate picture of its 

overall progress toward staying within the $129 billion total program cost 

and 2035 completion date goals. We believe that improving DOE’s 

performance reporting to address these limitations would provide more 

Conclusions 
Page 37 GAO-05-764 DOE's Accelerated Cleanup Program 

complete information and allow for a more accurate assessment of DOE’s 

progress toward achieving accelerated cleanup plan goals. 

To help DOE and the Congress monitor progress toward meeting DOE’s 

accelerated cleanup plan cost and schedule goals, we recommend that the 

Secretary of Energy take the following two actions: 

• Improve DOE’s performance reporting so that there is a clearer, 

discernable relationship at the activity level between cleanup 

accomplishments and the costs incurred in doing the work and 

• Identify in DOE’s performance reporting to the Congress and others 

those performance measures that are the most critical to achieving 

cost and schedule goals, and summarize the progress on these 

measures and the potential impact of any problems that could affect 

achieving accelerated cleanup plan goals. 

We provided a draft of this report to DOE for review and comment. In 

written comments, DOE’s Principal Deputy Assistant Secretary for 

Environmental Management agreed with the report’s recommendations. 

The Principal Deputy Assistant Secretary also provided technical 

comments as an enclosure to the letter. We have incorporated these 

comments as appropriate. DOE’s written comments on our draft report are 

included in appendix III. 

Regarding the report’s two recommendations, DOE agreed to improve its 

performance reporting so that there is a clearer, discernable relationship 

between cleanup accomplishments and the costs incurred in doing the 

work. DOE also agreed to identify and highlight in its progress reports to 

the Congress and others those performance measures that are the most 

critical to achieving cost and schedule goals, and summarize the progress 

on those measures and the potential impact of any problems that could 

affect achieving the goals. To aid in implementing these recommendations, 

DOE said it will continue to improve its earned value management system 

to serve as a link between performance measures and cost. 

In technical comments to us accompanying the letter, DOE disagreed with 

our discussion in the report that it should use present value analysis in 

calculating the estimated cost reduction it expects to achieve under its 

accelerated cleanup plan. DOE stated that we have misinterpreted OMB 

Circular A-94, Guidelines and Discount Rates for Benefit-Cost Analysis 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 38 GAO-05-764 DOE's Accelerated Cleanup Program 

of Federal Programs, regarding the use of present value analysis. DOE 

said that present value calculations are more applicable to cost-benefit 

analyses, particularly when attempting to analyze the costs and benefits to 

various options or alternatives. DOE emphasized that its cost estimating 

methodology was developed solely for the purpose of estimating the 

program’s environmental liability, and its cost reduction estimate is simply 

the difference between fiscal year 2001 and fiscal year 2003 environmental 

liability estimates. DOE believes that since it was not attempting to 

calculate benefits, a present value analysis is not appropriate. 

In our view, our interpretation of the OMB circular is correct and, in fact, 

is supported by DOE’s own guidance, which recommends using present 

value analysis as a standard methodology for cost comparisons of different 

alternatives. OMB Circular A-94 (revised October 29, 1992), standard 

economic analysis, and DOE’s guidance (Report to Congress, July 2002, 

Appendix A–Lifecycle Cost Analysis) recommend present value analysis as 

the appropriate technique for analysis of alternative options even if the 

benefits from different approaches are the same or a comparison of the 

benefits is not possible. As we previously reported, although using current 

dollar estimates may be appropriate for budget purposes, present value 

analysis is the standard methodology to be used for comparing costs of 

different alternatives that occur at different times, such as comparing 

DOE’s accelerated and baseline cleanup alternatives. 
Page 39 GAO-05-764 DOE's Accelerated Cleanup Program 

We are sending copies to other interested congressional committees and 

to the Secretary of Energy. We will also make copies available to others 

upon request. In addition the report will be available at no charge on the 

GAO Web site at http://www.gao.gov. 

If you or your staff have any questions on this report, please call me on 

(202) 512-3841. Contacts points for our Office of Congressional Relations 

and Public Affairs may be found on the last page of this report. Other staff 

contributing to this report are listed in Appendix IV. 

Gene Aloise 

Director, Natural Resources 

 and Environment 
Appendix I: Scope and Methodology 

Page 40 GAO-05-764 DOE's Accelerated Cleanup Program 

To determine what progress DOE has achieved under its accelerated 

cleanup plan, we identified the measures DOE uses to monitor and report 

its performance. We found that DOE uses two primary measures to 

monitor progress: its “Gold Chart” metrics (risk reduction measures) and 

earned value metrics. For DOE’s risk reduction measures, we discussed 

with DOE officials—both at headquarters and at specific sites—how these 

measures were developed. We also discussed how these measures are 

used by DOE—both internally and for external reporting. We obtained and 

analyzed DOE’s current risk reduction measures to determine both current 

status and implications of out year requirements for the overall cleanup. In 

reviewing DOE’s efforts to develop earned value data, we reviewed 

various reports on DOE’s earned value system, including a recent GAO 

report discussing the data and a 2004 National Academy of Sciences 

report.1

 We reported in March 2005, that for several major projects, earned 

value management principles had not been properly implemented at the 

department to measure cost and schedule performance. In addition, the 

National Research Council reported in 2004 that the quality of earned 

value management in the department was inconsistent and may not be 

completely accurate. We also discussed DOE’s earned value measures 

with DOE officials in its Environmental Management, Office of 

Performance Assessment and with DOE officials in the Office of 

Engineering and Construction Management. In part due to the concerns 

raised by GAO and others about the reliability of information from DOE’s 

earned value system and in part because DOE had not completed 

addressing these concerns by more fully implementing its earned value 

management system, we did not report on earned value data as a measure 

of DOE’s progress in achieving its accelerated goals. 

To determine how DOE implemented its accelerated strategy, we reviewed 

several documents at DOE headquarters providing the status of 10 

restructuring initiatives implemented when the accelerated initiative was 

started. We reviewed DOE policy and procedure documents, and 

discussed DOE’s strategy to implement its accelerated plan with DOE 

headquarters officials in its Office of Environmental Management. We 

further reviewed site performance management plans—a document laying 

out each site’s strategy for implementing the accelerated initiative. 

 1

U.S. Government Accountability Office, Department of Energy: Further Actions Are 

Needed to Strengthen Contract Management for Major Projects, GAO-05-123 (Washington, 

D.C.: Mar. 18, 2005), and National Academy of Sciences, Progress in Improving Project 

Management at the Department of Energy: 2003 Assessment (2004) (Washington, D.C.: 

2004). 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 41 GAO-05-764 DOE's Accelerated Cleanup Program 

To understand how the accelerated cleanup plan was being implemented 

at the site level and progress made, we selected a nonprobability sample of 

5 sites to review, based on several criteria.2

 We started with a list given to 

us by DOE that contained all DOE cleanup sites, each site’s expected 

completion date, each site’s 2003 estimated lifecycle target, and each site’s 

contribution to cost reductions under the accelerated initiative. We 

eliminated from consideration any site that (1) had completed cleanup by 

2004; (2) had a 2003 estimated lifecycle target less than $1 billion, and (3) 

contributed less than $100,000 in cost reductions to DOE’s overall $50 

billion estimated cost reductions from implementing its accelerated 

initiative. This gave us a list of sites, which we placed into three 

categories, based on DOE’s budget accounts: (1) sites expected to close by 

2006, (2) sites expected to close by 2012, and (3) sites expected to close by 

2035. We selected a minimum of one site from each category. In making 

our selection, we considered the following factors: geographic dispersion 

of the sites, the site’s estimated contribution to DOE’s annual budget, the 

diversity of waste types represented at the site, and contribution to DOE’s 

estimated $50 billion cost reduction from acceleration. Applying these 

criteria, we selected the following five sites: Hanford Site—both DOE’s 

Office of River Protection and Richland Operations Office; Savannah River 

Site; Idaho National Laboratory; the West Valley Demonstration Project, 

and DOE’s Miamisburg Closure Project. For each site we selected, we 

reviewed and obtained information regarding cost, schedule, and 

performance under DOE’s risk reduction measures. We independently 

verified, to the extent possible, the dollar figures and waste cleanup 

performance data provided to us by DOE, by taking various steps. For 

example, we analyzed budget formulation documents, documented waste 

cleanup assumptions, and obtained information on cost validation 

procedures. We determined that these data were sufficiently reliable for 

purposes of this report. In addition, at each site, we discussed with site 

officials implementation of the accelerated cleanup plan, progress toward 

meeting cost and performance goals, and any obstacles to meeting those 

goals. 

To develop information on the key assumptions underlying the 

Department of Energy’s accelerated cleanup plan, we analyzed 

information and documents provided by DOE officials and contractors at 

 2

Results from nonprobability samples cannot be used to make inferences about a 

population, because in a nonprobability sample some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample. 
Appendix I: Scope and Methodology 

Page 42 GAO-05-764 DOE's Accelerated Cleanup Program 

DOE headquarters and various sites. For many of the sites, we reviewed 

the performance management plans to assess how their approach to site 

cleanup would change under the accelerated plan. To determine how 

those assumptions affected achieving the accelerated cleanup goals, we 

evaluated site estimates of how the proposed changes under acceleration 

would impact site cleanup activities. Analyzing the reports provided by 

DOE, we determined the key contributors to the planned cost reductions. 

We then assessed through review of various reports and interviews with 

responsible officials the status of the key initiatives. We also discussed the 

progress of the plan with state regulators and Environmental Protection 

Agency officials, DOE headquarters officials, including the acting Assistant 

Secretary for Environmental Management, and officials from other 

headquarters offices. 

In order to assess the reliability of the gold chart metrics and the cost and 

schedule data provided to us by DOE, we took several steps. First, we 

obtained and reviewed selected site baselines. These included reviews by 

DOE’s Office of Engineering and Construction Management, as well as 

DOE’s Office of Environmental Management. We also obtained and 

examined the review of DOE’s fiscal year 2004 environmental liability 

estimate by DOE’s independent auditor, KPMG. KPMG audits DOE’s 

environmental liability estimate as part of its annual audit of DOE’s 

financial statements. In addition to these steps, for the sites we visited, we 

obtained information on data reliability procedures from site and 

contractor officials to determine internal controls used to ensure accurate, 

complete, and timely data. Finally, we developed and administered a data 

reliability form to each site we reviewed, obtaining information including 

what types of tests are administered in database systems to ensure the 

accuracy and completeness of data entered into the system, if and how 

frequently data are reviewed by independent parties, and how DOE 

ensures risk reduction measures are independently verified. The forms 

were completed by DOE and contractor officials. We asked follow-up 

questions whenever necessary. Based on the information we obtained and 

our analysis of the information provided, we determined that the reliability 

of the data provided was adequate for the purposes of this report. As we 

noted throughout the report, we found methodological problems with 

DOE’s reporting of cost data and estimation of cost reductions. In 

reporting its cost data, DOE incorrectly added cost numbers in actual 

(current) dollars for years prior to 2001 to cost numbers in constant 2003 

dollars for years post-2001. DOE also incorrectly estimated cost reductions 

of $50 billion without adjusting for the time value of money. Since in our 

previous work we demonstrated the effect of these problems by correcting 

and re-estimating DOE’s cost reductions, we did not do so again in this 
Appendix I: Scope and Methodology 

Page 43 GAO-05-764 DOE's Accelerated Cleanup Program 

report.3 Therefore, we used DOE’s estimates throughout as reported by 

DOE with no further correction. We conducted our review from June 2004 

through July 2005 in accordance with generally accepted government 

auditing standards. 

 3

U.S. General Accounting Office, Nuclear Waste: Absence of Key Management Reforms on 

Hanford’s Cleanup Project Adds to Challenges of Achieving Cost and Schedule Goals, 

GAO-04-611 (Washington, D.C.: June 9, 2004). 
Appendix II: DOE’s Estimated Cost 

Reductions under the Accelerated Cleanup 

Plan 

Page 44 GAO-05-764 DOE's Accelerated Cleanup Program 

Table 8: Accelerated Cleanup Estimates 

Dollars in thousands (2003 constant) 

Office Site/Program 

Closure date 

change from 

FY01

Cost change from 

FY01(includes longterm stewardship)a

FY03 Lifecycle 

Cost 

(does not include 

long-term 

stewardship)b

Albuquerque Kansas City Plant -1 year $1,440 $28,199

 Los Alamos Laboratory 0 -$726,528 $1,436,564

 Operations – $256,797 $437,280

 Pantex -9 $23,220 $186,539

 Sandia National Laboratory -3 -$39,887 $228,846

Carlsbad Waste Isolation Pilot Plant -4 -$3,697,077 $4,967,519

Chicago Argonne National Laboratory 6 -$28,120 $62,239

 Brookhaven National 

Laboratory 3 $83,469 $362,166

 Operations – $36,833 $97,649

Idahoc Idaho National Laboratory -35 -$10,936,713 $11,599,306

Nevadac Nevada Test Site -2 -$54,657 $1,940,373

Oak Ridge Oak Ridge Reservation 2 -$1,503,154 $6,883,568

Oakland Energy Technology 

Engineering Center 0 -$2,044 $198,982

 Lawrence Berkeley National 

Laboratory 2 -$24,611 $33,165

 Laboratory Energy-related 

Health Research -1 -$846 $40,464

 Lawrence Livermore National 

Laboratory -1 $30,473 $504,405

 Operations – -$2,066 $49,461

 Stanford Linear Accelerator 

Center 2 $7,477 $20,139

 Separations Process 

Research Unit 0 -$5,085 $207,881

Ohio Ashtabula Environmental 

Management Project 0 -$44,921 $154,977

 Columbus Environmental 

Management Project 0 -$2,504 $161,095

 Fernald Environmental 

Management Project -4 -$55,294 $3,329,720

 Miamisburg Environmental 

Management Project 0 -$128,648 $1,304,317

 Operations – $453,820 $453,820

Appendix II: DOE’s Estimated Cost 

Reductions under the Accelerated Cleanup 

Plan 
Appendix II: DOE’s Estimated Cost 

Reductions under the Accelerated Cleanup 

Plan 

Page 45 GAO-05-764 DOE's Accelerated Cleanup Program 

Dollars in thousands (2003 constant) 

Office Site/Program 

Closure date 

change from 

FY01

Cost change from 

FY01(includes longterm stewardship)a

FY03 Lifecycle 

Cost 

(does not include 

long-term 

stewardship)b

 West Valley Demonstration 

Project -29 -$326,532 $1,109,463

Paducah Paducah Gaseous Diffusion 

Plant 20 $3,827,024 $3,476,147

Portsmouth Portsmouth Gaseous 

Diffusion Plant 6 $7,539,895 $4,469,936

Richland Hanford Site -15 -$5,695,324 $20,380,244

River Protection Office of River Protection -18 -$16,710,839 $24,309,630

Rocky Flats Rocky Flats Environmental 

Technology Site 0 -$223,022 $6,949,013

Savannah River Savannah River Site -13 -$14,089,347 $23,725,375

Other 

Sites closed before 2003d -$701,188 $203,757

Environmental Management-wide 

costse

-$6,545,128 $9,655,527

Costs transferred out in 2003 -$723,818 $0

Total -$50,006,905 $128,967,766

Source: DOE. 

a

Because of the difficulty in separating long-term stewardship and cleanup activities from the preaccelerated cost estimates, DOE included both when calculating the cost change under the new plan. 

b

The FY03 lifecycle cost estimate includes cleanup costs only since most long-term stewardship costs 

were transferred to other offices under the accelerated plan. 

c

Includes operations office costs. 

d

Because of work transfers within Environmental Management, some costs changed in 2003 at sites 

that closed before 2003. 

e

Includes Headquarters and Program Direction costs. 
Appendix III: Comments from the Department 

of Energy 

Page 46 GAO-05-764 DOE's Accelerated Cleanup Program 

Appendix III: Comments from the 

Department of Energy 
Appendix III: Comments from the Department 

of Energy 

Page 47 GAO-05-764 DOE's Accelerated Cleanup Program 
Appendix IV: GAO Contact and Staff 

Acknowledgments 

Page 48 GAO-05-764 DOE's Accelerated Cleanup Program 

Gene Aloise (202) 512-3841 

In addition to the individual named above, Chris Abraham, John Delicath, 

Doreen Eng, Doreen Feldman, Nancy Kintner-Meyer, Jeffrey Larson, 

Gregory Marchand, Mehrzad Nadji, Judy Pagano, Thomas Perry, and Bill 

Swick made key contributions to this report. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(360499) 
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