DEPARTMENT OF 

ENERGY

Continued Actions Needed 

to Address Management 

Challenges

Statement of David C. Trimble, Director 

Natural Resources and Environment

Testimony 

Before the Subcommittee on Strategic 

Forces, Committee on Armed Forces, 

U.S. Senate

For Release on Delivery 

Expected at 2:30 p.m. ET

Wednesday, March 14, 2018

GAO-18-438T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-438T, a testimony 

before the Subcommittee on Strategic Forces, 

Committee on Armed Services,

U.S. Senate

March 14, 2018

DEPARTMENT OF ENERGY

Continued Actions Needed to Address Management 

Challenges

What GAO Found

The Department of Energy’s (DOE) National Nuclear Security Administration 

(NNSA) faces challenges related to the affordability of its nuclear modernization 

programs. In April 2017, GAO found a misalignment between NNSA’s 

modernization plans and the estimated budgetary resources needed to carry out 

those plans. Specifically, GAO found that NNSA’s estimates of funding needed

for its modernization plans sometimes exceeded the budgetary projections 

included in the President’s planned near-term (fiscal years 2018 through 2021)

and long-term (fiscal years 2022 through 2026) modernization budgets. GAO 

also found that the costs of some major modernization programs—such as for 

nuclear weapon refurbishments—may also increase and further strain future 

modernization budgets. GAO recommended in April 2017 that NNSA include an

assessment of the affordability of its modernization programs in future versions 

of its annual plan on stockpile stewardship; NNSA neither agreed nor disagreed 

with that recommendation.

DOE also faces challenges with addressing its environmental liabilities—the total 

cost of its cleanup responsibilities. According to the Fiscal Year 2017 Financial 

Report of the United States Government, DOE is responsible for $383.8 billion—

about 83 percent—of the federal government’s $464.5 billion total reported

environmental liability. GAO and other organizations have reported that DOE has 

not consistently taken a risk-informed approach to decision making for 

environmental cleanup, which could reduce costs while also reducing 

environmental risks more quickly. For example, in May 2017, we found that DOE 

may be able to save tens of billions of dollars and accelerate its waste treatment 

mission by reconsidering its approach for treating a portion of tank waste at 

DOE’s Hanford Site in Washington State. Since 1994, GAO has made at least 30 

recommendations to DOE and other federal agencies, which could reduce longterm costs and environmental risks more quickly. Of these, 15 remain 

unimplemented.

DOE has taken several important steps that demonstrate its commitment to 

improving contract and project management, but challenges persist. Specifically, 

DOE’s revised project management order, issued in May 2016, made several 

changes in response to recommendations GAO made in prior years, such as 

recommending that projects develop cost estimates and analyses of alternatives 

according to GAO’s best practices. However, DOE’s recent efforts do not 

address several areas, such as acquisition planning for major contracts and 

aspects of program and project management with which the department 

continues to struggle. GAO has made several recommendations related to these 

areas, and DOE has generally agreed with most of them.

Finally, NNSA faces challenges in implementing its nonproliferation programs. 

For example, in September 2017, GAO found that selected programs in NNSA’s 

Office of Defense Nuclear Nonproliferation (DNN) did not measure performance 

against schedule and cost baselines, as recommended by program management 

leading practices because DNN’s program management policy did not require 

programs to measure performance in this way. GAO recommended that DNN 

revise its policy to require programs to measure performance against cost and 

schedule baselines. NNSA indicated it plans to take action to revise its policy.

View GAO-18-438T. For more information, 

contact David Trimble at (202) 512-3841 or 

trimbled@gao.gov.

Why GAO Did This Study

DOE’s NNSA is responsible for 

managing the nuclear weapons 

stockpile and supporting nuclear 

nonproliferation efforts. DOE’s Office of 

Environmental Management works to

decontaminate and decommission 

facilities contaminated from decades of

nuclear weapons production. 

Over the last few years, GAO has

reported on a wide range of challenges 

facing DOE and NNSA. These 

challenges contribute to GAO’s 

continuing inclusion of DOE’s 

management of major contracts and 

projects on the list of agencies and 

program areas that are at high risk of

fraud, waste, abuse, and 

mismanagement. GAO also recently 

added the U.S. government’s 

environmental liabilities to this list.

This statement is based on 18 GAO 

reports issued from October 2014

through February 2018 and discusses 

(1) challenges related to the 

affordability of NNSA's nuclear 

modernization plans; (2) challenges 

related to DOE’s environmental 

liabilities; (3) the status of DOE’s 

efforts to improve its management of 

contracts, projects, and programs; and 

(4) challenges facing NNSA’s 

nonproliferation program. With NNSA

documents, GAO updated its prior 

work on the affordability of NNSA’s

modernization plans.

What GAO Recommends

GAO is not making any new 

recommendations. GAO has 

suggested that Congress consider 

taking certain actions and that DOE 

continue to act on the numerous 

recommendations GAO has made to 

address these challenges.
Letter

Page 1 GAO-18-438T Department Of Energy

Chairman Fischer, Ranking Member Donnelly, and Members of the 

Subcommittee:

Thank you for the opportunity to discuss our recent work on some of the 

pressing management challenges facing the Department of Energy’s 

(DOE) National Nuclear Security Administration (NNSA) and Office of 

Environmental Management (EM).1 NNSA is responsible for managing 

the nation’s three nuclear security missions: ensuring a safe, secure, and 

reliable nuclear deterrent; achieving designated reductions in the nuclear 

weapons stockpile; and supporting the nation’s nuclear nonproliferation 

efforts. In support of these missions, in November 2017, NNSA issued its 

Stockpile Stewardship and Management Plan, which included about $10 

billion for weapons activities for fiscal year 2018. More recently, NNSA’s 

February 2019 budget justification for the Weapons Activities 

appropriations account requested about $61 billion for fiscal years 2019 

through 2023 to carry out its mission, including its weapons 

modernization plans.

In support of its missions, NNSA implements a range of nonproliferation 

programs under its Office of Defense Nuclear Nonproliferation.2 These 

programs include efforts to secure, consolidate, and dispose of weaponsusable nuclear materials and radiological sources;3 reduce the risks of 

nuclear smuggling; enhance international export controls and 

International Atomic Energy Agency nuclear safeguards;4 and support 

research and development of new nonproliferation technologies.

 1

NNSA is a separately organized agency within DOE. It was created under Title 32 of the 

National Defense Authorization Act for Fiscal Year 2000, Pub. L. No. 106-65, §§ 3201-

3299, 113 Stat. 512, 953-971 (1999) (codified as amended at 50 U.S.C. §§ 2401-2484 

(2017)).

2

DOE defines a program as an organized set of activities directed toward a common 

purpose or goal in support of an assigned mission area.

3

Weapons-usable nuclear materials are highly enriched uranium, uranium-233, and any 

plutonium containing less than 80 percent of the isotope plutonium-238. Such materials 

are also often referred to as fissile materials or strategic special nuclear materials. 

4

The International Atomic Energy Agency is an independent international organization 

based in Vienna, Austria, that is affiliated with the United Nations and has the dual mission 

of promoting the peaceful uses of nuclear energy and verifying that nuclear material 

subject to safeguards is not diverted to weapons development efforts or other proscribed 

purposes. Safeguards allow the agency to independently verify that nuclear material and 

other specified items are not diverted by, among other things, inspecting all facilities and 

locations containing nuclear material declared by countries to verify its peaceful use. 

Letter
Page 2 GAO-18-438T Department Of Energy

EM is responsible for decontaminating and decommissioning nuclear 

facilities and sites that are contaminated from decades of nuclear 

weapons production and nuclear energy research. In February 2017, we 

reported that since its inception in 1989, EM has spent more than $164 

billion on cleanup efforts, which include retrieving, treating, and disposing 

of nuclear waste.5

Both NNSA and EM face critical challenges in fulfilling their missions. 

Since the end of the Cold War, key portions of the nuclear security 

enterprise’s weapons production infrastructure have become outdated, 

prompting congressional and executive branch decision makers to call on 

DOE to develop plans to modernize this infrastructure.6 Most recently, in 

January 2017, the President directed the Secretary of Defense to initiate 

a new Nuclear Posture Review to ensure that the U.S. nuclear deterrent 

is modern, robust, flexible, resilient, ready, and appropriately tailored to 

deter 21st-century threats and reassure our allies. This review was 

released in February 2018.7 Previously, the 2010 Nuclear Posture Review

had identified long-term modernization goals and requirements, including 

sustaining a safe, secure, and effective nuclear arsenal through 

increasing investments to rebuild and modernize the nation’s nuclear 

infrastructure, some of which dates back to the 1940s.8

As NNSA works to modernize the nuclear security enterprise, EM must 

address the legacy of 70 years of nuclear weapons production and 

energy research by DOE and its predecessor agencies. These activities 

generated large amounts of radioactive waste, spent nuclear fuel, excess 

plutonium and uranium, and contaminated soil and groundwater. They 

also contaminated thousands of sites and facilities, including land, 

buildings, other structures, and systems and equipment. Various federal 

laws, agreements with states, and court decisions require the federal 

 5

GAO, High-Risk Series: Progress on Many High-Risk Areas, While Substantial Efforts 

Needed on Others, GAO-17-317 (Washington, D.C.: Feb. 15, 2017). 

6

The end of the Cold War caused a dramatic shift in how the United States approaches 

nuclear weapons. Instead of designing, testing, and producing new nuclear weapons, U.S. 

strategy shifted to maintaining the existing nuclear weapons stockpile indefinitely.

7

Department of Defense, Nuclear Posture Review (Washington, D.C.: Feb. 2018). The 

Nuclear Posture Review establishes the nation’s nuclear weapons requirements and 

policy.

8

Department of Defense, Nuclear Posture Review Report (Washington, D.C.: Apr. 6, 

2010).
Page 3 GAO-18-438T Department Of Energy

government to clean up environmental hazards at federal sites and 

facilities, such as nuclear weapons production facilities. DOE’s approach 

to addressing these environmental liabilities is often influenced by 

numerous site-specific factors, stakeholder agreements, and legal 

provisions. For years, we and others have reported on shortcomings in 

DOE’s approach to addressing its environmental responsibilities, 

including incomplete data on the extent of cleanup needed.

DOE relies primarily on contractors to carry out its programs, and it is the 

largest civilian contracting agency in the federal government. In fiscal 

year 2017, it spent approximately 90 percent of its $32 billion in annual 

funding on contracts and major capital asset projects.9 We designated 

DOE’s contract management—which has included both contract 

administration and project management—as a high-risk area in 1990 

because DOE’s record of inadequate management and oversight of 

contractors had left it vulnerable to fraud, waste, abuse, and 

mismanagement. In our 2017 High Risk List update, we reported that 

NNSA and EM continued to demonstrate a strong commitment and top 

leadership support to improve contract and project management—a key 

criterion for removing agencies and program areas from our High Risk 

List.10 However, we also found that DOE still needed to make progress on 

the other four criteria for removal: organizational capacity, corrective 

action planning, monitoring effectiveness, and demonstrating progress.

Further, in our 2017 High Risk List update, we added the federal 

government’s environmental liabilities to our High Risk List. DOE is 

responsible for more than 80 percent of reported federal environmental 

liabilities.11 In our 2017 High Risk List update, we reported that because 

of incomplete information and often inconsistent approaches to making 

cleanup decisions, DOE does not always approach environmental 

cleanup using a risk-informed approach to reduce health and safety risks 

in a cost-effective manner.

 9

Major capital asset projects are projects estimated to cost $750 million or more. DOE 

defines a capital asset project as a project with defined start and end points required in the 

acquisition of capital assets.

10GAO-17-317. GAO’s high-risk program identifies government operations with greater 

vulnerabilities to fraud, waste, abuse, and mismanagement or the need for transformation 

to address economy, efficiency, or effectiveness challenges.

11GAO-17-317. 
Page 4 GAO-18-438T Department Of Energy

My testimony today discusses (1) challenges related to the affordability of 

NNSA’s nuclear weapons modernization plans; (2) challenges in 

addressing DOE’s environmental liabilities; (3) the status of DOE’s efforts 

to improve its management of contracts, projects, and programs; and (4) 

challenges facing NNSA’s nonproliferation program. My statement is 

based primarily on our work from 18 GAO reports issued from October 

2014 through February 2018—including 7 reports issued since I testified 

on this issue in May 2017 (see the end of this testimony for a list of 

related reports).12 Detailed information about the scope and methodology 

we used to conduct our prior work can be found in each of our issued 

reports. With information from the Fiscal Year 2018 Stockpile 

Stewardship Management Plan and the 2018 Nuclear Posture Review,

we updated our prior work on the affordability of NNSA’s modernization 

plans. We provided new information to NNSA for review and incorporated 

one technical comment. The work upon which this testimony is based 

was conducted in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

 12GAO, Department of Energy: Continued Actions Needed to Address Management 

Challenges, GAO-17-651T (Washington, D.C.: May 24, 2017). 
Page 5 GAO-18-438T Department Of Energy

Based on our prior work, NNSA faces challenges in the face of 

affordability concerns. In our past reports on NNSA’s 25-year plans to 

modernize the nation’s nuclear weapons stockpile and its supporting 

infrastructure, we have identified concerns regarding the alignment of 

NNSA’s plans with budget estimates as presented in NNSA’s annual 

Stockpile Stewardship and Management plans.13 For example, in April 

2017, we issued our most recent report on the Fiscal Year 2017 Stockpile 

Stewardship and Management Plan, in which we identified two areas of 

misalignment between NNSA’s modernization plans and the estimated 

budgetary resources needed to carry out those plans, which could result 

in challenges to NNSA’s ability to afford its planned portfolio of 

modernization programs.14 First, we found that NNSA’s estimates of the 

funding needed for its modernization plans sometimes exceeded the 

budgetary projections included in the President’s planned near- and longterm modernization budgets. In the near-term (fiscal years 2018 through 

2021), we found that NNSA may have to defer certain modernization work 

beyond that time period to execute its program within the planned budget, 

which could increase modernization costs and schedule risks. This is a 

pattern we have previously identified as a “bow wave”—an increase in 

future years’ estimated budget needs that occurs when agencies are 

undertaking more programs than their resources can support. In the longterm (fiscal years 2022 through 2026), we found that NNSA’s 

modernization program budget estimates sometimes exceeded the 

projected budgetary resources planned for inclusion in the President’s 

budget, raising additional questions about whether NNSA will be able to 

afford the scope of its modernization program. Second, we found that the 

costs of some major modernization programs—such as for nuclear 

weapon refurbishments—may also increase and further strain future 

modernization budgets.

To help NNSA put forth more credible modernization plans, we 

recommended in our April 2017 report that the NNSA Administrator 

include an assessment of the affordability of NNSA’s portfolio of 

modernization programs in future versions of the Stockpile Stewardship 

and Management Plan, such as by presenting options (e.g., potentially 

 13The Stockpile Stewardship and Management Plan is updated annually and is NNSA’s 

formal means of communicating to Congress information on modernization and operations 

plans and budget estimates over the next 25 years.

14GAO, National Nuclear Security Administration: Action Needed to Address Affordability 

of Nuclear Modernization Programs, GAO-17-341 (Washington, D.C.: Apr. 26, 2017).

Misalignment 

between NNSA’s 

Modernization Budget 

Estimates and Plans 

Presents Challenges 

Raised by 

Affordability Concerns
Page 6 GAO-18-438T Department Of Energy

deferring the start of or canceling specific modernization programs) that 

NNSA could consider taking to bring its estimates of modernization 

funding needs into alignment with potential future budgets. In commenting 

on our report, NNSA neither agreed nor disagreed with our 

recommendation.

It does not appear that NNSA has taken steps to address our 

recommendation or address questions regarding the affordability of its 

modernization plans. Notably, the Fiscal Year 2018 Stockpile 

Stewardship Management Plan was released in November 2017, but 

NNSA did not assess the affordability of the plan, and the fiscal year 2018 

plan did not include the long-term projections of the President’s budget for 

modernization, which help provide insights on the affordability of the 

plans. The Fiscal Year 2018 Stockpile Stewardship Management Plan 

stated that no policy decision had been made on the topline budget totals 

for NNSA’s modernization efforts beyond fiscal year 2018. However, the 

plan indicated that these totals would be refined for the fiscal year 2019 

budget in accordance with the National Security Strategy, National 

Defense Strategy, and the Nuclear Posture Review, which were under 

development at the time of the fiscal year 2018 plan’s release.

In February 2018, the Department of Defense released the Nuclear 

Posture Review, which proposed a range of nuclear policy proposals, 

including initiatives to support NNSA’s nuclear weapon infrastructure and 

workforce, accelerating one warhead replacement program, and 

developing two new nuclear weapon capabilities, including modifying a 

small number of existing warheads on submarine launched ballistic 

missiles to provide a low-yield option and pursuing a nuclear-armed sealaunched cruise missile. NNSA’s fiscal year 2019 budget request for the 

Weapons Activities appropriations account proposes a 19 percent 

increase for nuclear modernization programs from the fiscal year 2017 

enacted budget and states that the budget is consistent with the Nuclear 

Posture Review. However, the budget request notes that the Nuclear 

Posture Review’s policy initiatives need to be translated into requirements 

and that the options for meeting some Nuclear Posture Review goals—

such as the low-yield submarine launched ballistic missile warhead—

have not yet been developed. As a result, it is not clear whether the fiscal 

year 2019 budget estimates for NNSA’s modernization programs are 

aligned with a changing set of modernization requirements. We are 

currently reviewing NNSA’s Fiscal Year 2018 Stockpile Stewardship and 
Page 7 GAO-18-438T Department Of Energy

Management Plan, and we expect to conduct a review of the Fiscal Year 

2019 Stockpile Stewardship and Management Plan after it is released.15

In its November 2014 report, the Augustine-Mies Panel observed that 

NNSA’s Stockpile Stewardship Management Plans, which are intended to 

communicate long-range plans and cost estimates, have varied from year 

to year in the costs and schedules for the delivery of several major life 

extension programs and nuclear facilities.16 The panel concluded that the 

lack of a stable, executable plan for modernization is a fundamental 

weakness for NNSA. As NNSA considers new modernization plans and 

programs as the 2018 Nuclear Posture Review’s policy initiatives are 

translated into requirements and options, aligning its modernization needs 

with potential future budgets will continue to be important.

DOE also faces challenges with addressing its environmental liabilities 

and its cleanup mission. In February 2017, we added the federal 

government’s environmental liabilities to our High Risk List.17 Specifically, 

we found that the federal government’s environmental liabilities have 

been growing for the past 20 years and are likely to continue to increase. 

According to the Fiscal Year 2017 Financial Report of the United States 

Government, DOE’s environmental liabilities estimate had increased to 

$383.8 billion—which is about 83 percent of the $464.5 billion of the 

federal government’s total reported environmental liability. Notably, these 

estimates do not reflect all of the future cleanup responsibilities that DOE 

 15The National Defense Authorization Act for Fiscal Year 2013 includes a provision that 

we annually review a joint DOE-DOD report that addresses, among other things, the plan 

for the nuclear weapons stockpile and its delivery systems.

16Mr. Norman R. Augustine and Admiral Richard W. Mies served as the Co-Chairmen of 

the Congressional Advisory Panel on the Governance of the Nuclear Security Enterprise 

(known as the “Augustine-Mies Panel”). Section 3166 of the National Defense 

Authorization Act for Fiscal Year 2013 established the Congressional Advisory Panel on 

the Governance of the Nuclear Security Enterprise and tasked the advisory panel with 

offering a recommendation “with respect to the most appropriate governance structure, 

mission, and management of the nuclear security enterprise.” The panel’s November 2014 

report summarizes the panel’s findings on the current health of the enterprise, examines 

the root causes of its governance challenges, and offers its recommendations to address 

the identified problems.

17GAO-17-317.

DOE Annually 

Spends Billions on 

Cleanup, but the Cost 

of Its Environmental 

Liabilities Continues 

to Increase
Page 8 GAO-18-438T Department Of Energy

may face.18 In addition, as discussed below, DOE has not consistently 

taken a risk-informed approach to decision making for environmental 

cleanup, and DOE may therefore be missing opportunities to reduce 

costs while also reducing environmental risks more quickly. Our recent 

work in this area has also identified opportunities where DOE may be 

able to save tens of billions of dollars.

As we have previously reported, DOE’s total reported environmental 

liabilities have generally increased over time.19 Since 1989, EM has spent 

more than $164 billion to retrieve, treat, and dispose of nuclear and 

hazardous waste and, as of 2017, it had completed cleanup at 91 of 107 

sites across the country (the 91 sites were generally viewed by DOE as 

the smallest and least contaminated sites to address). Even with billions 

spent on environmental cleanup, DOE’s estimated environmental liability 

has roughly doubled from $176 billion in fiscal year 1997 to $383.8 billion 

in fiscal year 2017.20 From 2011 through 2016, EM spent $35 billion, 

primarily to treat and dispose of nuclear and hazardous waste and 

construct capital asset projects to treat the waste (see fig. 1 for EM’s 

annual spending and growing environmental liability). According to 

documents related to DOE’s fiscal year 2016 financial statements, half of 

DOE’s environmental liability resides at two cleanup sites: the Hanford 

Site in Washington State and the Savannah River Site in South Carolina.

 18Federal accounting standards require agencies responsible for cleaning up 

contamination to estimate future cleanup and waste disposal costs and to report such 

costs in their annual financial statements as environmental liabilities. Per federal 

accounting standards, federal agencies’ environmental liability estimates are to include 

probable and reasonably estimable costs of cleanup work. 

19GAO-17-317.

20We did not adjust environmental liability estimates for inflation because information 

about the amount of the liability applicable to each future fiscal year was not available.
Page 9 GAO-18-438T Department Of Energy

Figure 1: Department of Energy’s Office of Environmental Management’s Annual 

Spending and Growing Environmental Liability

Notes: EM is the organization within the Department of Energy responsible for managing 

environmental cleanup and is responsible for cleaning up 107 sites across the country. To date, EM 

has completed cleanup at 91 of these sites. EM spending includes money to treat and dispose of 

nuclear and hazardous waste and to construct capital asset projects to treat the waste. We did not 

adjust environmental liability estimates for inflation because information about the amount of the 

liability applicable to each future fiscal year was not available.

In its fiscal year 2016 financial statement, DOE attributed recent 

environmental liability increases to (1) inflation adjustments for the current 

year; (2) improved and updated estimates for the same scope of work, 

including changes resulting from deferral or acceleration of work; (3) 

revisions in technical approach or scope for cleanup activities; and (4) 

regulatory and legal changes. Notably, in recent annual financial reports, 

DOE has cited other significant causes for increases in its liability. Other 

causes have included the lack of a disposal path for high-level radioactive 

waste—because of the termination of the Yucca Mountain repository 

program—and delays and scope changes for major construction projects 

at the Hanford and Savannah River sites.
Page 10 GAO-18-438T Department Of Energy

We also reported in February 2017 that DOE’s estimated liability does not 

include billions in expected costs.21 According to federal accounting 

standards, environmental liability estimates should include costs that are 

probable and reasonably estimable, meaning that costs that cannot yet 

be reasonably estimated should not be included in total environmental 

liability.22 Examples of costs we reported on that DOE could not yet 

estimate include the following:

• DOE has not yet developed a cleanup plan or cost estimate for the 

Nevada National Security Site and, as a result, the cost of future 

cleanup of this site was not included in DOE’s fiscal year 2015 

reported environmental liability. The nearly 1,400-square-mile site has 

been used for hundreds of nuclear weapons tests since 1951. These 

activities have resulted in more than 45 million cubic feet of 

radioactive waste at the site. According to DOE’s financial statement, 

since DOE is not yet required to establish a plan to clean up the site, 

the costs for this work are excluded from DOE’s annually reported 

environmental liability.

• DOE’s reported environmental liability includes an estimate for the 

cost of a permanent nuclear waste repository, but this estimate is 

highly uncertain. In 2010, DOE terminated its efforts to license a 

repository at Yucca Mountain near Las Vegas, Nevada. In 2013, DOE 

proposed a repository at a different location and in 2015 proposed 

separate repositories for defense and commercial waste. We reported 

in October 2014 that estimated future costs for any repository become 

more uncertain with each year of delay.23 We also reported in January 

2017 that DOE’s cost estimates for its 2015 proposal were uncertain 

and excluded billions of dollars in estimated costs.24 In April 2017, we 

reported that using a comprehensive assessment of the benefits, 

costs, and schedules to inform DOE’s waste disposal plan may show 

 21GAO-17-317.

22Federal Accounting Standards Advisory Board, FASAB Handbook of Federal 

Accounting Standards and Other Pronouncements, as Amended (Washington, D.C.: June 

30, 2016).

23GAO, Spent Nuclear Fuel Management: Outreach Needed to Help Gain Public 

Acceptance for Federal Activities That Address Liability, GAO-15-141 (Washington, D.C.: 

Oct. 9, 2014).

24GAO, Nuclear Waste: Benefits and Costs Should Be Better Understood Before DOE 

Commits to a Separate Repository for Defense Waste, GAO-17-174 (Washington, D.C.: 

Jan. 31, 2017).
Page 11 GAO-18-438T Department Of Energy

that tens of billions of dollars could be saved if DOE reverted to its 

original plan to have a single repository for defense and commercial 

nuclear waste.25 In June 2017, a bill to renew efforts to open the 

Yucca Mountain repository was introduced in the House of 

Representatives.26 Further, the President’s budget requests for fiscal 

years 2018 and 2019 proposed resuming the license application 

process for the repository at Yucca Mountain, but Congress has not 

yet funded these DOE activities.

In addition, according to the DOE Inspector General, DOE may have 

insufficient controls in place to accurately account for its environmental 

liabilities. In November 2016, the DOE Inspector General reported a

significant deficiency in internal controls related to the reconciliation of 

environmental liabilities.27

Moreover, DOE has not consistently taken a risk-informed decisionmaking approach to its environmental cleanup mission to more efficiently 

use resources. As our reports and those by other organizations issued 

over the last 2 decades have found, DOE’s environmental cleanup 

decisions have not been risk-based, and there have been inconsistencies 

in the regulatory approaches followed at different sites. As we discuss 

below, we and others have pointed out that DOE needs to take a 

nationwide, risk-based approach to cleaning up these sites, which could 

reduce costs while also reducing environmental risks more quickly.

• In May 2017, we reported on DOE’s efforts to treat a significant 

portion of the waste in underground tanks at the Hanford Site.28 We 

found that DOE chose different approaches to treat the less 

radioactive portion of its tank waste—which DOE refers to as “low-

 25GAO, 2017 Annual Report: Additional Opportunities to Reduce Fragmentation, Overlap, 

and Duplication and Achieve Other Financial Benefits, GAO-17-491SP (Washington, D.C.: 

Apr. 26, 2017).

26Nuclear Waste Policy Amendments Act of 2017, H.R. 3053, 115th Cong. (2017).

27U.S. Department of Energy, Office of the Inspector General, The Department of 

Energy’s Fiscal Year 2016 Consolidated Financial Statements, OAI-FS-17-02 

(Washington, D.C.: Nov. 15, 2016).

28Our report focused on “low-activity waste,” which is DOE’s term for the portion of tank 

waste with low levels of radioactivity. DOE estimates that low-activity waste contains less 

than 10 percent of the radioactivity of the tank waste but more than 90 percent of the tank 

waste by volume. See GAO, Nuclear Waste: Opportunities Exist to Reduce Risks and 

Costs by Evaluating Different Waste Treatment Approaches at Hanford, GAO-17-306 

(Washington, D.C.: May 3, 2017).
Page 12 GAO-18-438T Department Of Energy

activity waste” (LAW)—at the Hanford and Savannah River sites.29

We found that the best available information indicates that DOE’s 

estimated costs to grout LAW at the Savannah River Site are 

substantially lower than its estimated costs to vitrify LAW at Hanford, 

and DOE may be able to save tens of billions of dollars by 

reconsidering its waste treatment approach for a portion of the LAW at 

Hanford. Moreover, according to experts who attended a meeting we 

convened with the National Academies of Sciences, Engineering, and 

Medicine, both vitrification and grout could effectively treat Hanford’s 

LAW. Experts at our meeting also stated that developing updated 

information on the effectiveness of treating a portion of Hanford’s 

waste, called supplemental LAW, with other methods, such as grout, 

may enable DOE to consider waste treatment approaches that would 

accelerate DOE’s tank waste treatment mission, thereby potentially 

reducing certain risks and lifecycle treatment costs. We recommended 

that DOE (1) develop updated information on the performance of 

treating supplemental LAW with alternate methods, such as grout, 

before it selects an approach for treating supplemental LAW; and (2) 

have an independent entity develop updated information on the 

lifecycle costs of treating Hanford’s supplemental LAW with alternate 

methods.30 DOE agreed with both recommendations.

31

• In 2015, a review organized by the Consortium for Risk Evaluation 

with Stakeholder Participation reported that DOE was not optimally 

 29At the Savannah River Site, DOE has grouted about 4 million gallons of LAW since 

2007. DOE plans to treat a portion of the Hanford Site’s LAW with vitrification, but it has 

not yet treated any of Hanford’s LAW and faces significant unresolved technical 

challenges in doing so. Grout immobilizes waste in a concrete-like mixture. Vitrification 

immobilizes waste in glass.

30We are currently in the process of completing a report on DOE’s Waste Treatment and 

Immobilization Plant quality assurance program.

31The National Defense Authorization Act for Fiscal Year 2017, section 3134, requires the 

Secretary of Energy to enter into an arrangement with a federally funded research and 

development center to conduct an analysis of approaches for treating Hanford’s 

supplemental LAW, as well as concurrently enter into an arrangement with the National 

Academies of Sciences, Engineering, and Medicine to conduct a review of the analysis 

conducted by the federally funded research and development center. The National 

Academies is currently reviewing an analysis being carried out by a federally funded 

research and development center on approaches for treating supplemental LAW at the 

Hanford Site. Specifically, the National Academies plans to evaluate the technical quality 

and completeness of the analysis, such as the methods used to conduct risk, cost-benefit, 

schedule, and regulatory compliance assessments and the results of the assessments. 

The National Academies is also currently conducting a second assessment of EM’s 

technology development efforts, including technologies and/or alternative approaches that 

could reduce EM’s long-term costs, accelerate schedules, or mitigate risks.
Page 13 GAO-18-438T Department Of Energy

using available resources to reduce risk.32 According to the report, 

factors such as inconsistent regulatory approaches and certain 

requirements in federal facility agreements caused disproportionate 

resources to be directed at lower-priority risks. The report called for a 

more systematic effort to assess and rank risks within and among 

sites, including through headquarters guidance to sites, and to 

allocate federal taxpayer monies to remedy the highest priority risks 

through the most efficient means.

• In 2006, the National Research Council reported that the nation’s 

approach to cleaning up nuclear waste—primarily carried out by 

DOE—was complex, inconsistent, and not systematically riskbased.33 For example, the National Research Council noted that the 

current regulatory structure for LAW is based primarily on the waste’s 

origins rather than on its actual radiological risks. The National 

Research Council concluded that by working with regulators, public 

authorities, and local citizens to implement risk-informed practices, 

waste cleanup efforts can be done more cost-effectively. The report 

also suggested that statutory changes were likely needed.

Since 1994, we have made at least 30 recommendations related to 

addressing the federal government’s environmental liability to DOE and 

others and 4 suggestions to Congress to consider changes to the laws 

governing cleanup activities. Of these, 15 recommendations remain 

unimplemented. If implemented, these recommendations would improve 

the completeness and reliability of the estimated costs of future federal 

cleanup responsibilities and lead to more risk-based management of the 

cleanup work.34 We believe these recommendations are as relevant, if not 

more so, today.

 32The Consortium for Risk Evaluation with Stakeholder Participation is a multi-university 

consortium organized in 1995 that provides several types of independent, multidisciplinary reviews of DOE documents, projects, and reports. Omnibus Risk Review 

Committee, A Review of the Use of Risk-Informed Management in the Cleanup Program 

for Former Defense Nuclear Sites (August 2015).

33National Research Council of the National Academies, Improving the Regulation and 

Management of Low-Activity Radioactive Wastes (Washington, D.C.: National Academies 

Press, 2006).

34We have ongoing work examining the consistency of DOE’s compliance agreements, 

looking specifically at the extent to which milestones within select compliance agreements 

are tailored to the environmental and human health risks that DOE is faced with 

addressing and the extent to which DOE’s cleanup remedies are based on up-to-date 

assessments of conditions at sites and of DOE’s technical capabilities.
Page 14 GAO-18-438T Department Of Energy

The Secretary of Energy has taken several important steps that 

demonstrate DOE’s commitment to improving the management of 

contracts, projects, and programs. However, our recent work indicates 

that, even with these efforts, NNSA and EM continue to face longstanding challenges in several areas.

As we noted in our 2017 High Risk List update, DOE has made progress 

in its contract and project management. DOE continued to meet the 

criterion for demonstrating a strong commitment and top leadership 

support for improving project management.35 The Secretary of Energy 

issued two memorandums, in December 2014 and June 2015, that lay 

out a series of changes to policies and procedures to improve project 

management. These changes were included in DOE’s revised project 

management order, DOE Order 413.3B, issued in May 2016. As noted in 

the memorandums, some of these changes are in response to 

recommendations we made in prior years, such as recommending that 

projects develop cost estimates and analyses of alternatives according to 

our best practices.

DOE also made significant efforts to improve its performance in 

monitoring and independently validating the effectiveness and 

sustainability of corrective measures and now partially meets our 

monitoring criterion for removing agencies and program areas from our 

High Risk List. For example, the Secretary improved the department’s 

senior-level monitoring capability and strengthened the Energy Systems 

Acquisition Advisory Board by changing it from an ad hoc body to an 

institutionalized board responsible for reviewing all capital asset projects 

with a total project cost of $100 million or more. The Secretary also 

created the Project Management Risk Committee, which includes senior 

DOE officials and is chaired by a new departmental position—the Chief 

Risk Officer. The committee is chartered to assess the risks of projects 

 35GAO-17-317. 

DOE Has Taken 

Steps to Improve 

Management of 

Contracts, Projects, 

and Programs, but 

Challenges Remain

DOE Has Made Progress 

in Managing Contracts 

and Projects
Page 15 GAO-18-438T Department Of Energy

across DOE and advise DOE senior leaders on cost, schedule, and 

technical issues for projects.36

We have previously reported that DOE’s recent efforts do not address 

several areas where it continues to have challenges, including (1) 

acquisition planning for its major contracts, (2) the quality of enterprisewide cost information available to DOE managers and key stakeholders, 

(3) program and project management, and (4) major legacy projects.

As we have previously reported, during the acquisition planning phase for 

contracts, DOE makes critical decisions that have significant implications 

for the cost and overall success of an acquisition. The size and duration 

of DOE’s management and operating (M&O) contracts37—22 M&O 

contracts with an average potential duration of 17 years, representing 

almost three-quarters of DOE’s spending in fiscal year 2015—underscore 

the importance of planning for every M&O acquisition. In August 2016, we 

examined DOE’s use of M&O contracts.38 According to DOE officials we 

interviewed at that time, one of the primary reasons DOE uses M&O 

contracts is because they are easier to manage with fewer DOE 

personnel because they are less frequently competed and have broadly 

written scopes of work, among other attributes. We found that DOE did 

not consider acquisition alternatives beyond continuing its long-standing 

M&O contract approach for 16 of its 22 M&O contracts. We concluded 

that without considering broader alternatives in the acquisition planning 

phase, DOE cannot ensure that it is selecting the most effective scope 

 36As we stated in our 2017 High Risk List update, additional time is needed for us to 

assess how effectively these recent monitoring improvements will validate the 

sustainability of corrective measures. We have not yet evaluated the operations of the 

newly created Project Management Risk Committee. In addition, DOE’s new oversight 

and monitoring efforts are not comprehensive, as certain activities within EM are not 

subject to review by the committee, even though together they cost billions of dollars and 

last for numerous years. Finally, the effectiveness of DOE’s monitoring of its contracts, 

projects, and programs depends on the availability of reliable enterprise-wide cost 

information on which to base oversight activities. See GAO-17-317.

37M&O contracts are agreements under which the government contracts for the operation, 

maintenance, or support, on its behalf, of a government-owned or government-controlled

research, development, special production, or testing establishment wholly or principally 

devoted to one or more of the major programs of the contracting federal agency. 48 

C.F.R. § 17.601 (2018).

38GAO, Department of Energy: Actions Needed to Strengthen Acquisition Planning for 

Management and Operating Contracts, GAO-16-529 (Washington, D.C.: Aug. 9, 2016).

Challenges Persist in 

Several Areas

Acquisition Planning for Major 

Contracts
Page 16 GAO-18-438T Department Of Energy

and form of contract, raising risks for both contract cost and performance. 

We recommended in our August 2016 report that DOE establish a 

process to analyze and apply its experience with contracting alternatives. 

DOE generally concurred with our recommendation and in November 

2016 issued updated guidance that acquisition planning documents are to 

contain a thorough discussion of alternatives beyond simply extending or 

competing M&O contracts.39

We have previously reported that the effectiveness of DOE’s monitoring 

of its contracts, projects, and programs depends on the availability of 

reliable enterprise-wide cost information on which to base oversight 

activities. For example, reliable enterprise-wide cost information is 

needed to identify the cost of activities, ensure the validity of cost 

estimates, and provide information to Congress to make budgetary 

decisions. However, we have found that meaningful cost analyses across 

programs, contractors, and sites are not usually possible because 

NNSA’s contractors use different methods of accounting for and tracking 

costs. NNSA developed a plan to improve and integrate its cost reporting 

structures; however, we found in January 2017 that this plan did not 

provide a useful road map for guiding NNSA’s efforts.40 For example, we 

found that NNSA did not define strategies and identify resources needed 

to achieve its goals, which is a leading practice for strategic planning. 

NNSA’s plan contained few details on the elements it must include, such 

as its feasibility assessment, estimated costs, expected results, and an 

implementation timeline. We concluded that until a plan is in place that 

incorporates leading strategic planning practices, NNSA cannot be 

assured that its efforts will result in a cost collection tool that produces 

reliable enterprise-wide cost information that satisfies the information 

needs of Congress and program managers. We recommended that 

NNSA develop a plan for producing cost information that fully 

incorporates leading planning practices. NNSA agreed with our 

 39We currently have four ongoing reviews related to contract management, including (1) 

performance management of DOE’s management and operating contracts, (2) DOE and 

NNSA’s subcontractor management, (3) NNSA’s contract document management, and (4) 

NNSA’s support service contracts.

40GAO, National Nuclear Security Administration: A Plan Incorporating Leading Practices 

Is Needed to Guide Cost Reporting Improvement Effort, GAO-17-141 (Washington, D.C.: 

Jan. 19, 2017).

Quality of Enterprise-Wide 

Cost Information
Page 17 GAO-18-438T Department Of Energy

recommendation. We are monitoring implementation of this 

recommendation.41

In addition, as we have previously noted, DOE needs quality data to 

manage its risk of fraud. The Fraud Reduction and Data Analytics Act of 

2015 establishes requirements aimed at improving federal agencies’

controls and procedures for assessing and mitigating fraud risks through 

the use of data analytics.42 In a March 2017 report, however, we found 

that because DOE does not require its contractors to maintain sufficiently 

detailed transaction-level cost data that are reconcilable with amounts 

charged to DOE, it is not well positioned to employ data analytics as a 

fraud detection tool.43 We found that the data were not suitable either 

because they were not for a complete universe of transactions that was 

reconcilable with amounts billed to DOE or because they were not 

sufficiently detailed to determine the nature of costs charged to DOE. We 

concluded that without requiring contractors to maintain such data, DOE 

will not be well positioned to meet the requirements of the Fraud 

Reduction and Data Analytics Act of 2015 and manage its risk of fraud 

and other improper payments. We recommended that DOE require 

contractors to maintain sufficiently detailed transaction-level cost data that 

are reconcilable with amounts charged to the government.

DOE did not concur with our recommendation. According to DOE, the 

recommendation establishes agency-specific requirements for DOE 

contractors that are more prescriptive than current federal requirements, 

and its M&O contractors, not DOE, are responsible for performing data 

analytics and determining what data are needed to do so. DOE’s 

response to our recommendation is concerning because it demonstrates 

that DOE does not fully appreciate its responsibility for overseeing 

contractor costs. We believe that the use of data-analytic techniques by 

DOE employees could help mitigate some of the challenges that limit the 

effectiveness of DOE’s approach for overseeing M&O contractor costs. 

However, effectively applying data analytics depends on the availability of 

 41Senate Report 115-125, accompanying S. 1519, the National Defense Authorization Act 

for 2018, includes a provision for us to examine NNSA’s financial integration efforts, and 

we have initiated this work.

42Data analytics enable an organization to analyze transactional data to obtain insights 

into the operating effectiveness of internal controls and to identify improper cost charges, 

potential indicators of fraud, or actual fraudulent payments or activities.

43GAO, Department of Energy: Use of Leading Practices Could Help Manage the Risk of 

Fraud and Other Improper Payments, GAO-17-235 (Washington, D.C.: Mar. 30, 2017).
Page 18 GAO-18-438T Department Of Energy

complete and sufficiently detailed contractor data. Therefore, by 

implementing our recommendation, DOE could take the important steps 

necessary to require that contractors maintain sufficiently detailed 

transaction-level cost data that are reconcilable with amounts charged to 

the government.

Although, as mentioned previously, DOE has taken some steps to 

improve program and project management, our recent work has shown 

that DOE continues to face several challenges in these areas, including 

the following:

• In February 2018,44 we found that NNSA’s preliminary plan for 

analyzing options to supply unobligated low-enriched uranium (LEU) 

for various missions, including certain national security needs, is 

inconsistent with DOE directives for program and project management 

that state that mission need should be independent of and not defined 

by a particular solution.45 For example, NNSA’s analysis of 

alternatives showed preference toward a particular solution—building 

a new uranium enrichment capability—and the agency has not 

included other technology options for analysis. Moreover, NNSA has 

prepared preliminary cost estimates for two uranium enrichment 

technology options—large and small centrifuges—that the agency 

considers to be the most feasible. However, these estimates are 

limited in scope and do not fully meet best practices for reliable cost 

estimates. We recommended that NNSA revise its mission need 

statement and adjust the range of options it considers in the analysis 

of alternatives process and that NNSA ensure its cost estimates are 

consistent with best practices. NNSA neither agreed nor disagreed 

with our recommendations and stated that it will take future actions 

consistent with these recommendations.

 44GAO, Nuclear Weapons: NNSA Should Clarify Long-Term Uranium Enrichment Mission 

Needs and Improve Technology Cost Estimates, GAO-18-126 (Washington, D.C.: Feb. 

16, 2018).

45NNSA has several mission needs for enriched uranium, including providing LEU to fuel 

a nuclear reactor that produces tritium—a key isotope used in nuclear weapons. NNSA 

has a pressing defense need for unobligated LEU to fuel this reactor, meaning the 

uranium, technology and equipment used to produce the LEU, must be U.S. in origin. 

Because the United States lost its only source of unobligated LEU production in 2013, the 

supply is finite.

Program and Project 

Management
Page 19 GAO-18-438T Department Of Energy

• In a January 2018 report, we found management challenges 

associated with NNSA’s life extension programs (LEP).46 For 

example, we found that NNSA had begun implementing requirements 

for using earned value management (EVM)47—a tool used across 

industry and government for conducting cost and schedule 

performance analysis—in three LEPs, but it had not adopted a key 

best practice that could help the agency better manage risk for LEPs. 

Specifically, we found that NNSA does not require an independent 

team to validate the EVM systems used by NNSA’s contractors for 

LEPs against the national EVM standard. We concluded that without 

requiring validation of EVM systems, NNSA may not have assurance 

that its LEPs are obtaining reliable EVM data for managing their 

programs and reporting their status. We recommended that NNSA 

require an independent team to validate contractor EVM systems 

used for LEPs. NNSA agreed with our recommendation but stated 

that it already relies on a DOE project management office to 

independently validate contractor EVM systems. However, as we 

reported, DOE has not independently validated contractor EVM 

systems at six of the seven contractor sites that are responsible for 

conducting LEP activities.

• In November 2017, we found that NNSA had established program 

management requirements, such as developing cost and schedule 

estimates for its uranium, plutonium, tritium, and lithium programs and 

had established managers’ roles and responsibilities for these 

programs.48 However, officials told us that the programs had not fully 

met these requirements primarily because of staff shortages. We 

recommended that NNSA determine the critical staff skills it will need 

for these programs and use that information to address staffing 

shortages. NNSA agreed with our recommendation.

• In our September 2017 report on NNSA’s Plutonium Disposition 

Program, we found that DOE does not have sufficient space at the 

Waste Isolation Pilot Plant (WIPP) to dispose of all defense 

 46GAO, Nuclear Weapons: NNSA Should Adopt Additional Best Practices to Better 

Manage Risk for Life Extension Programs, GAO-18-129 (Washington, D.C.: Jan. 30, 

2018).

47EVM measures the value of work accomplished in a given period and compares it with 

the planned value of work scheduled for that period and the actual cost of work 

accomplished. 

48GAO, Nuclear Weapons: NNSA Needs to Determine Critical Skills and Competencies 

for Its Strategic Materials Programs, GAO-18-99 (Washington, D.C.: Nov. 14, 2017). 
Page 20 GAO-18-438T Department Of Energy

transuranic waste.49 Moreover, DOE officials recognize that 

expansion of WIPP’s disposal space may be necessary in the future, 

but they had not analyzed or planned for the facility’s expansion 

because their focus has been on resuming operations at WIPP, which 

had been suspended in 2014 after two separate accidents at the 

facility. Without developing a plan for WIPP that includes an 

integrated schedule for completing a regulatory approval process and 

constructing new space before WIPP’s existing space is full, DOE 

does not have reasonable assurance that it will be able to expand the 

repository in a timely manner. We made four recommendations, 

including that DOE develop a plan for expanding WIPP’s disposal 

space that includes a schedule for completing the expansion before 

existing space is full. DOE concurred with our recommendations.

• In September 2017, we found that DOE’s program to re-establish the 

production of a plutonium isotope used to provide electrical power for 

National Aeronautics and Space Administration missions had made 

progress but faced a number of challenges to meeting production 

goals.50 Specifically, we found that DOE had not developed an 

implementation plan that identifies milestones and interim steps that 

can be used to demonstrate progress in meeting production goals. 

Our prior work has shown that plans that include milestones and 

interim steps help an agency to set priorities, use resources efficiently, 

and monitor progress in achieving agency goals. In our September 

2017 report, we made three recommendations, including that DOE 

develop such a plan for its plutonium isotope production approach and 

that DOE assess the long-term effects of known production 

challenges and communicate these effects to the National 

Aeronautics and Space Administration. DOE concurred with our 

recommendations.

• In a September 2017 report on NNSA’s uranium program, we found 

that NNSA had not developed a complete scope of work, a life-cycle 

cost estimate, or an integrated master schedule for the overall 

uranium program—all of which are considered leading practices—and 

 49GAO, Plutonium Disposition: Proposed Dilute and Dispose Approach Highlights Need 

for More Work at the Waste Isolation Pilot Plant, GAO-17-390 (Washington, D.C.: Sept. 5, 

2017). WIPP is an underground repository for the disposal of transuranic nuclear waste, 

which is waste contaminated by nuclear elements heavier than uranium, such as diluted 

plutonium.

50GAO, Space Exploration: DOE Could Improve Planning and Communication Related to 

Plutonium-238 and Radioisotope Power Systems Production Challenges, GAO-17-673 

(Washington, D.C.: Sept. 8, 2017). 
Page 21 GAO-18-438T Department Of Energy

that it had no time frame for doing so.51 We reported that NNSA plans 

to do so for the specific Uranium Processing Facility project,52 as 

required by DOE’s project management order. However, NNSA had 

not developed a complete scope of work for key program 

requirements, including important and potentially costly repairs and 

upgrades to existing buildings in which NNSA intends to house some 

uranium processing capabilities. We concluded that because NNSA 

had not developed a complete scope of work for the overall uranium 

program, it did not have the basis to develop a life-cycle cost estimate 

or an integrated master schedule for the entire uranium program, 

which runs counter to best practices identified in GAO’s cost 

estimating and scheduling guides. We recommended that NNSA set a 

time frame for completing the scope of work, life-cycle cost estimate, 

and integrated master schedule for the overall uranium program. 

NNSA generally agreed with this recommendation and stated that it 

has ongoing efforts to complete these actions.53

 51GAO, Modernizing the Nuclear Security Enterprise: A Complete Scope of Work Is 

Needed to Develop Timely Cost and Schedule Information for the Uranium Program, 

GAO-17-577 (Washington, D.C.: Sept. 8, 2017). The scope of work reflects all activities as 

defined in the program’s work breakdown structure, which defines in detail the work 

necessary to accomplish a project’s objectives. A life-cycle cost estimate provides an 

exhaustive and structured accounting of all resources and associated cost elements 

required to develop, produce, deploy, and sustain a particular program. An integrated 

master schedule is a document that integrates the planned work, the resources necessary 

to accomplish that work, and the associated budget for a program, as called for in best 

practices.

52In 2004, NNSA initiated plans for the construction of a new Uranium Processing Facility, 

a facility that would consolidate some of its existing uranium processing facilities—which 

are located at the Y-12 National Security Complex in Oak Ridge, Tennessee, were built in 

the 1940s and 1950s, and are outdated and deteriorating—into a single, more modern 

facility.

53Senate Report 112-26 accompanying S. 1253, a bill for the National Defense 

Authorization Act for Fiscal Year 2012, includes a provision for us to review independent 

cost estimates of the Chemical and Metallurgical Research Replacement Nuclear Facility 

and the Uranium Processing Facility conducted by NNSA to ensure the accuracy of the 

cost estimates and that all cost savings measures have been considered. According to 

DOE’s February 2018 monthly project portfolio status report, NNSA plans to release its 

final independent cost estimate report in late February 2018.
Page 22 GAO-18-438T Department Of Energy

Our previous work has found that NNSA also faces challenges 

implementing its nonproliferation programs under its Office of Defense 

Nuclear Nonproliferation (DNN), which implements nuclear 

nonproliferation programs worldwide. In recently completed reviews of 

DNN programs, we have identified several challenges NNSA faces in how 

it measures performance and conducts program management of these 

efforts. Specifically,

• In September 2017, we found that four DNN programs did not have 

schedule and cost estimates covering their planned life cycles and did 

not measure performance against schedule and cost baselines as is 

recommended by program management leading practices.54 NNSA 

officials explained that this is due in part to high levels of uncertainty 

in planning the selected programs’ work scope or schedules, 

particularly in working with partner countries. However, we noted that 

uncertainty should not prevent these programs from establishing more 

complete or longer-term estimates to account for the time and 

resources they need to achieve their goals and track their 

performance. In addition, we observed that DOE’s cost estimating 

guide, which applies to NNSA programs, describes approaches for 

programs to incorporate risk and uncertainty in estimates. But we 

found that DNN’s program management policy, which was updated in 

February 2017, did not outline requirements for programs to establish 

life-cycle estimates or measure performance against schedule and 

cost baselines. We recommended that DNN revise its program 

management policy to require DNN programs to follow life-cycle 

program management leading practices, such as requiring life-cycle 

estimates and measuring against baselines. Updating the DNN policy 

to include requirements and guidance on cost estimating and tracking 

performance against schedule and cost baselines could help ensure 

that NNSA managers and Congress have better information on (1) 

how much DNN programs may cost, (2) the time they may need to 

achieve their goals, and (3) how effectively they are being executed 

compared to plans. Although NNSA neither agreed nor disagreed with 

the recommendation, it indicated that it plans to take action to revise 

its policy to address the recommendation.

 54GAO, Nuclear Nonproliferation: NNSA Needs to Improve Its Program Management 

Policy and Practices, GAO-17-773 (Washington, D.C.: Sept. 28, 2017). We reviewed four 

selected DNN programs: Nuclear Material Removal, Highly Enriched Uranium Reactor 

Conversion, Radiological Security, and International Nuclear Security.

NNSA’s 

Nonproliferation 

Program Faces 

Performance 

Measurement and 

Program 

Management 

Challenges
Page 23 GAO-18-438T Department Of Energy

• In February 2017, we found that NNSA was unable to demonstrate 

the full results of its research and development technology for 

preventing nuclear proliferation.55 Specifically, we reported that DNN’s 

Research and Development program did not consistently track and 

document projects that result in technologies being transitioned or 

deployed. Furthermore, we found that DNN’s Research and 

Development project performance was difficult to interpret because 

the program’s performance measures did not define criteria or provide 

context justifying how the program determined that it met its targets. 

We concluded that this, in turn, could hinder users’ ability to determine 

the program’s progress. NNSA officials said that final project reports 

did not document their assessment of performance against baseline 

targets and that there was no common template for final project 

reports. We noted that documenting assessments that compare final 

project performance results against baseline targets for scope of work 

and completion date could enhance NNSA’s ability to manage its 

programs in accordance with these standards. We also concluded 

that more consistently tracking and documenting the transitioned and 

deployed technologies that result from DNN’s projects could facilitate 

knowledge sharing within DNN. This would also provide a means by 

which to present valuable information to Congress and other decision 

makers about the programs’ results and overall value. We 

recommended that NNSA consistently track and document results of 

DNN Research and Development projects and document 

assessments of final project results against baseline performance 

targets. NNSA agreed to take actions in response to both 

recommendations.

• In June 2016, we found that the Nuclear Smuggling Detection and 

Deterrence (NSDD) program had developed a program plan but that 

the plan did not include measurable goals and performance measures 

aligned to the goals.56 As a result, we concluded that the NSDD 

program may not be able to determine when it has fully accomplished 

its mission, and it risked continuing to deploy equipment past the point 

 55GAO, Nuclear Nonproliferation: Better Information Needed on Results of National 

Nuclear Security Administration’s Research and Technology Development Projects, 

GAO-17-210 (Washington, D.C.: Feb. 3, 2017). A transitioned technology is provided to 

users outside of the project team for further development or deployment. A deployed 

technology is one that is being actively used in the field by a federal agency or foreign 

partner. 

56GAO, Combating Nuclear Smuggling: NNSA’s Detection and Deterrence Program Is 

Addressing Challenges but Should Improve Its Program Plan, GAO-16-460 (Washington, 

D.C.: June 17, 2016).
Page 24 GAO-18-438T Department Of Energy

of diminishing returns. We recommended that NSDD develop a more 

detailed program plan that articulates when and how it will achieve its 

goals, including completing key activities, such as the deployment of 

radiation detection equipment to partner countries. NNSA agreed with 

this recommendation, and in February 2017, NSDD issued a revised 

program plan. As a result of NNSA’s implementation of this 

recommendation, Congress and NNSA decision makers will have 

additional information to assess the status, benefits, and performance

of the NSDD program.

Chairman Fischer, Ranking Member Donnelly, and Members of the 

Subcommittee, this completes my prepared statement. I would be 

pleased to respond to any questions you may have at this time.

If you or your staff members have any questions about this testimony, 

please contact me at (202) 512-3841 or trimbled@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this statement. GAO staff who made key 

contributions to this testimony are Jonathan Gill, Assistant Director; 

Antoinette Capaccio; Ricki Gaber; William Hoehn; and Amanda Kolling.

GAO Contact and 

Staff 

Acknowledgements
Related GAO Products

Page 25 GAO-18-438T Department Of Energy

The following is a selection of GAO’s recent work assessing the 

Department of Energy’s management efforts, including at the National 

Nuclear Security Administration and at the Office of Environmental 

Management:

Nuclear Weapons: NNSA Should Clarify Long-Term Uranium Enrichment 

Mission Needs and Improve Technology Cost Estimates. GAO-18-126. 

Washington, D.C.: February 16, 2018.

Nuclear Weapons: NNSA Should Adopt Additional Best Practices to 

Better Manage Risk for Life Extension Programs. GAO-18-129. 

Washington, D.C.: January 30, 2018.

Nuclear Weapons: NNSA Needs to Determine Critical Skills and 

Competencies for Its Strategic Materials Programs. GAO-18-99. 

Washington, D.C.: November 14, 2017.

Nuclear Nonproliferation: NNSA Needs to Improve Its Program 

Management Policy and Practices. GAO-17-773. Washington, D.C.: 

September 28, 2017.

Modernizing the Nuclear Security Enterprise: A Complete Scope of Work 

Is Needed to Develop Timely Cost and Schedule Information for the 

Uranium Program. GAO-17-577. Washington, D.C.: September 8, 2017.

Space Exploration: DOE Could Improve Planning and Communication 

Related to Plutonium-238 and Radioisotope Power Systems Production 

Challenges. GAO-17-673. Washington, D.C.: September 8, 2017.

Plutonium Disposition: Proposed Dilute and Dispose Approach Highlights 

Need for More Work at the Waste Isolation Pilot Plant, GAO-17-390. 

Washington, D.C.: September 5, 2017.

Nuclear Waste: Opportunities Exist to Reduce Risks and Costs by 

Evaluating Different Waste Treatment Approaches at Hanford. 

GAO-17-306. Washington, D.C.: May 3, 2017.

2017 Annual Report: Additional Opportunities to Reduce Fragmentation, 

Overlap, and Duplication and Achieve Other Financial Benefits.

GAO-17-491SP. Washington, D.C.: April 26, 2017.

Related GAO Products
Related GAO Products

Page 26 GAO-18-438T Department Of Energy

National Nuclear Security Administration: Action Needed to Address 

Affordability of Nuclear Modernization Programs. GAO-17-341. 

Washington, D.C.: April 26, 2017.

Department of Energy: Use of Leading Practices Could Help Manage the 

Risk of Fraud and Other Improper Payments. GAO-17-235. Washington, 

D.C.: March 30, 2017.

High-Risk Series: Progress on Many High-Risk Areas, While Substantial 

Efforts Needed on Others. GAO-17-317. Washington, D.C.: February 15, 

2017.

Nuclear Nonproliferation: Better Information Needed on Results of 

National Nuclear Security Administration’s Research and Technology 

Development Projects. GAO-17-210. Washington, D.C.: February 3, 

2017.

Nuclear Waste: Benefits and Costs Should Be Better Understood Before 

DOE Commits to a Separate Repository for Defense Waste. 

GAO-17-174. Washington, D.C.: January 31, 2017.

National Nuclear Security Administration: A Plan Incorporating Leading 

Practices Is Needed to Guide Cost Reporting Improvement Effort. 

GAO-17-141. Washington, D.C.: January 19, 2017.

Department of Energy: Actions Needed to Strengthen Acquisition 

Planning for Management and Operating Contracts. GAO-16-529. 

Washington, D.C.: August 9, 2016.

Combating Nuclear Smuggling: NNSA’s Detection and Deterrence 

Program Is Addressing Challenges but Should Improve Its Program Plan.

GAO-16-460. Washington, D.C.: June 17, 2016.

Spent Nuclear Fuel Management: Outreach Needed to Help Gain Public 

Acceptance for Federal Activities That Address Liability. GAO-15-141. 

Washington, D.C.: October 9, 2014.

(102627)
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