GAO 

United States Government Accountability Office

Report to the Subcommittee on Energy 

and Water Development, Committee on 

Appropriations, House of 

Representatives 

NUCLEAR 

NONPROLIFERATION

DOE Needs to Address 

Uncertainties with and 

Strengthen 

Independent Safety 

Oversight of Its 

Plutonium Disposition 

Program 

March 2010 

GAO-10-378 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 2010

NUCLEAR NONPROLIFERATION 

DOE Needs to Address Uncertainties with and 

Strengthen Independent Safety Oversight of Its

Highlights of GAO-10-378, a report to the Plutonium Disposition Program 

Subcommittee on Energy and Water 

Development, Committee on 

Appropriations, House of Representatives 

The end of the Cold War left the 

United States with a surplus of 

weapons-grade plutonium, which 

poses proliferation and safety risks. 

Much of this material is found in a 

key nuclear weapon component 

known as a pit. The Department of 

Energy (DOE) plans to dispose of 

at least 34 metric tons of plutonium 

by fabricating it into mixed oxide 

(MOX) fuel for domestic nuclear 

reactors. To do so, DOE’s National 

Nuclear Security Administration 

(NNSA) is constructing two 

facilities—a MOX Fuel Fabrication 

Facility (MFFF) and a Waste 

Solidification Building (WSB)—at 

the Savannah River Site in South 

Carolina. GAO was asked to assess 

the (1) cost and schedule status of 

the MFFF and WSB construction 

projects, (2) status of NNSA’s plans 

for pit disassembly and conversion, 

(3) status of NNSA’s plans to obtain 

customers for MOX fuel from the 

MFFF, and (4) actions that the 

Nuclear Regulatory Commission 

(NRC) and DOE have taken to 

provide independent nuclear safety 

oversight. GAO reviewed NNSA 

documents and project data, toured 

DOE facilities, and interviewed 

officials from DOE, NRC, and 

nuclear utilities. 

What GAO Recommends

GAO recommends, among other 

things, that NNSA improve its plans 

for the maturation of critical 

technologies related to pit 

disassembly and conduct 

additional outreach to potential 

MOX fuel customers. In 

commenting on a draft of this 

report, DOE agreed with GAO’s 

recommendations. 

The MFFF and WSB projects both appear to be meeting their cost targets for 

construction, but the MFFF project has experienced schedule delays. 

Specifically, the MFFF and WSB projects are on track to meet their respective 

construction cost estimates of $4.9 billion and $344 million. However, the 

MFFF project has experienced some delays over the past 2 years, due in part 

to the delivery of reinforcing bars that did not meet nuclear quality standards. 

Project officials said that they expect to recover from these delays by the end 

of 2010 and plan for the start of MFFF operations on schedule in 2016. The 

WSB project appears to be on schedule. 

NNSA is reconsidering its alternatives for establishing a pit disassembly and 

conversion capability. However, it seems unlikely that NNSA will be able to 

establish this capability in time to produce the plutonium feedstock needed to 

operate the MFFF, due to the amount of time and effort needed to reconsider 

alternatives and construct a facility as well as the amount of uncertainty 

associated with NNSA’s current plans. NNSA had previously planned to build 

a stand-alone facility near the MFFF construction site to disassemble pits and 

convert the plutonium into a form suitable for use by the MFFF. However, 

NNSA is now considering a plan to combine this capability with another 

project at an existing facility at the Savannah River Site. NNSA officials could 

not estimate when the agency will reach a final decision or establish more 

definitive cost and schedule estimates for the project. However, NNSA’s new 

alternative depends on an aggressive, potentially unrealistic schedule. In 

addition, NNSA has not sufficiently planned for the maturation of critical 

technologies to be used in pit disassembly and conversion operations, some of 

which are being tested at the Los Alamos National Laboratory in New Mexico.

NNSA has one potential customer for most of its MOX fuel, but outreach to 

other utilities may be insufficient. NNSA is in discussions with the Tennessee 

Valley Authority to provide MOX fuel for five reactors. NNSA plans to offer 

several incentives to potential customers, including offering to sell MOX fuel 

at a discount relative to the price of uranium fuel. In interviews with the 

nation’s nuclear utilities, GAO found that while many of the utilities expressed 

interest in NNSA’s proposed incentives, the majority of utilities also expressed 

little interest in becoming MOX fuel customers. This suggests that NNSA’s 

outreach to utilities may not be sufficient. 

NRC is currently reviewing the MFFF’s license application and has identified 

several issues related to construction. However, oversight of the MFFF and 

the WSB by DOE’s independent nuclear safety entities has been limited. For 

example, DOE’s Office of Health, Safety, and Security has not conducted any 

oversight activities or participated in any project reviews of the WSB, despite 

the WSB’s status as a high-hazard nuclear facility. In addition, NNSA’s Chief of 

Defense Nuclear Safety has not conducted any nuclear safety oversight 

activities for the MFFF project and has not conducted all oversight activities 

for the WSB project that are required by DOE order. 

View GAO-10-378 or key components.

For more information, contact Gene Aloise at 

(202) 512-3841 or aloisee@gao.gov. 
Page i GAO-10-378 

Contents 

Letter 1

Background 4 

Construction Projects Appear to Be Meeting Cost Targets, but the 

MFFF Has Had Schedule Delays 8 

NNSA Is Reconsidering Alternatives for Its Pit Disassembly 

Mission That Could Delay Production of Material Needed for the 

MFFF 12 

NNSA Has One Potential Customer for Most of Its MOX Fuel, but 

Outreach to Others May Be Insufficient 22 

NRC Has Been Providing Oversight for the MFFF, but DOE’s 

Independent Oversight of the MFFF and the WSB Has Been 

Limited 28 

Conclusions 38 

Recommendations for Executive Action 39 

Agency Comments and Our Evaluation 41 

Appendix I Scope and Methodology 43 

Appendix II Extent to Which the MFFF Project’s Schedule 

Used Key Practices 46 

Appendix III Extent to Which the WSB Project’s Schedule Used 

Key Practices 48 

Appendix IV Summary Results of Interviews with 22 Utilities 50 

Appendix V Nuclear Regulatory Commission’s Notices of 

Violation for the MFFF 57 

Appendix VI Comments from the Department of Energy 59 

 Nuclear Nonproliferation 
Appendix VII Comments from the Nuclear Regulatory Commission 63 

Appendix VIII GAO Contact and Staff Acknowledgments 64 

Tables 

Table 1: Technology Assessments of Critical Pit Disassembly and 

Conversion Technologies Conducted in 2008 and 2009 20 

Table 2: Factors Affecting a Utility’s Interest in the MOX Fuel 

Program 26 

Table 3: Number of Utilities Indicating Increased Interest in the 

MOX Fuel Program Due to Possible Incentives 27 

Table 4: Status of NRC’s Review of the MFFF’s Operating License 

as of January 2010 29 

Figures 

Figure 1: Cumulative Cost and Schedule Variances for MFFF over a 

2-Year Period (2007-2009) 9 

Figure 2: Cumulative Cost and Schedule Variances for the WSB, 

January through November, 2009 11 

Figure 3: The MFFF Planned Production Schedule for MOX Fuel 

Assemblies 23 

Page ii GAO-10-378 Nuclear Nonproliferation
Abbreviations 

ARIES Advanced Recovery and Integrated Extraction System 

CDNS Chief of Defense Nuclear Safety 

DOE Department of Energy 

EVM earned value management 

HSS Office of Health, Safety, and Security 

LANL Los Alamos National Laboratory 

MFFF Mixed Oxide Fuel Fabrication Facility 

MOX mixed oxide 

NNSA National Nuclear Security Administration 

OECM Office of Engineering and Construction Management 

NRC Nuclear Regulatory Commission 

PDCF Pit Disassembly and Conversion Facility 

SRS Savannah River Site 

TRL technology readiness level 

TVA Tennessee Valley Authority 

WSB Waste Solidification Building 

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Page iii GAO-10-378 Nuclear Nonproliferation
Page 1 GAO-10-378 

 

United States Government Accountability Office

Washington, DC 20548 

 

March 26, 2010 

The Honorable Peter J. Visclosky 

Chairman 

The Honorable Rodney P. Frelinghuysen 

Ranking Member 

Subcommittee on Energy and Water Development 

Committee on Appropriations 

House of Representatives 

The end of the Cold War left a legacy of fissile material that the United 

States no longer required for national security. This fissile material 

includes large quantities of weapons-grade plutonium, such as the 

plutonium used in the pit of a nuclear warhead.1

 Plutonium is a man-made, 

radioactive element that poses a danger of nuclear weapons proliferation 

and a risk of environmental, safety, and health consequences. For 

example, internal exposure in humans to plutonium through inhalation or 

consumption poses an extremely serious health hazard by exposing organs 

and tissues to ionizing radiation and increasing the risk of cancer. 

In 1997, the Department of Energy (DOE) established a strategy to provide 

for the disposition of surplus, weapons-grade plutonium.2

 The National 

Nuclear Security Administration (NNSA), a separately organized agency 

within DOE, manages this program, now called the U.S. Plutonium 

Disposition program. NNSA’s goal is to dispose of at least 34 metric tons of 

surplus, weapons-grade plutonium by (1) combining it with uranium to 

produce mixed oxide (MOX) fuel and (2) selling the MOX fuel to domestic 

utilities that own nuclear reactors. Once the MOX fuel is irradiated in a 

nuclear reactor, it would be rendered useless to potential proliferators. 

According to NNSA officials, the sale of MOX fuel over a 15-year period 

could return over $1 billion to the U.S. Treasury. To achieve this goal, 

NNSA is currently constructing the following two facilities at the 

Savannah River Site (SRS) in South Carolina: 

1

Weapons-grade plutonium is plutonium with an isotopic ratio of plutonium-240 to 

plutonium-239 of no more than 0.10. The pit is a key nuclear weapon component that 

begins the chain reaction leading to a nuclear explosion. 

2

This program is linked to a larger, international effort with Russia. In 2000, the United 

States and Russia entered into a Plutonium Management and Disposition Agreement, in 

which each country pledged to dispose of at least 34 metric tons of surplus weapons-grade 

plutonium. 

 Nuclear Nonproliferation 
 

• MOX Fuel Fabrication Facility (MFFF)—The MFFF is projected to use up 

to 3.5 metric tons of plutonium a year to fabricate about 1,700 MOX fuel 

assemblies over a 15-year period. NNSA began construction on the MFFF 

in August 2007. As we reported in March 2007, NNSA initially estimated 

that the MFFF would cost about $1.4 billion and be completed by 

September 2004.3

 NNSA currently projects that the MFFF will cost about 

$4.9 billion, be ready for operations by October 2016, and begin producing 

MOX fuel assemblies in 2018. 

• A Waste Solidification Building (WSB) will process radioactive waste from 

the MFFF and related facilities. NNSA began construction on the WSB in 

December 2008, and it is projected to cost $344 million and to be ready for 

operations by September 2013. 

In addition, because NNSA expects to obtain the majority of the plutonium 

from nuclear pits, it also plans to build a facility at SRS to disassemble pits 

and convert the plutonium into a plutonium oxide form suitable for use in 

MOX fuel. 

Several entities oversee nuclear safety for the Plutonium Disposition 

program. The National Defense Authorization Act of 1999 amended the 

Energy Reorganization Act of 1974 to require the Nuclear Regulatory 

Commission (NRC), an independent oversight agency, to regulate and 

license the operation of the MFFF. DOE is responsible for regulating the 

nuclear safety of the WSB and the planned Pit Disassembly and 

Conversion Facility (PDCF), with NNSA taking the primary role. Several 

other DOE offices and entities have provided independent nuclear safety 

oversight for all three facilities, including the DOE Office of Health, Safety, 

and Security (HSS); the NNSA Central Technical Authority; and the NNSA 

Chief of Defense Nuclear Safety (CDNS). 

This report assesses (1) the performance status of the MFFF and WSB 

construction projects with respect to cost and schedule, (2) the status of 

NNSA’s plans to establish a pit disassembly and conversion capability to 

supply plutonium to the MFFF, (3) the status of NNSA’s plans to obtain 

customers for MOX fuel from the MFFF, and (4) the actions that NRC and 

 

3

GAO, Department of Energy: Major Construction Projects Need a Consistent Approach 

for Assessing Technology Readiness to Help Avoid Cost Increases and Delays, 

GAO-07-336 (Washington, D.C.: Mar. 27, 2007). 

Page 2 GAO-10-378 Nuclear Nonproliferation
 

DOE have taken to provide independent nuclear safety oversight of the 

MFFF and WSB construction projects. 

To assess the performance status of the MFFF and WSB construction 

projects with respect to cost and schedule, we reviewed earned value 

management (EVM) data and assessed the reliability of EVM data by 

evaluating each project’s schedule against GAO’s scheduling best 

practices.4

 We also interviewed key NNSA and contractor officials and 

reviewed data and key processes used to conduct a risk analysis of the 

MFFF project’s schedule. To assess the status of NNSA’s plans to establish 

a pit disassembly and conversion capability to supply plutonium to the 

MFFF, we reviewed documentation provided by NNSA and its contractors 

for the MFFF, WSB, and PDCF projects, including project execution plans, 

project status reports, EVM data, and independent project reviews. We 

also reviewed project plans and research and development data related to 

the Advanced Recovery and Integrated Extraction System (ARIES) project 

at DOE’s Los Alamos National Laboratory (LANL) in New Mexico; toured 

site facilities at SRS and LANL; and interviewed DOE, NNSA, and 

contractor officials. To assess the status of NNSA’s plans to obtain 

customers for MOX fuel from the MFFF, we reviewed documentation 

provided by NNSA and its contractors, including project plans, studies, 

and MOX fuel production schedules. We also interviewed NNSA and 

contractor officials. In addition, we analyzed responses to structured 

interviews we administered to U.S. utilities that own nuclear reactors. We 

received data from utility officials representing 22 of the 26 utilities, for a 

response rate of 85 percent. Finally, to assess the actions that NRC and 

DOE have taken to provide independent nuclear safety oversight of the 

MFFF and WSB construction projects, we reviewed NRC and DOE 

regulations related to nuclear safety, NRC inspection reports, and DOE 

independent review reports. We also spoke with officials in NRC’s Office 

of Nuclear Materials Safety and Safeguards and the Division of 

Construction Projects; NNSA’s program offices responsible for the MFFF 

and WSB projects; the CDNS; DOE’s HSS; and the Defense Nuclear 

Facilities Safety Board to discuss their oversight roles in relation to the 

MFFF and the WSB, respectively. Appendix I contains additional 

information on our scope and methodology. 

 

4

These practices are found in GAO, GAO Cost Estimating and Assessment Guide: Best 

Practices for Developing and Managing Capital Program Costs, GAO-09-3SP

(Washington, D.C.: March 2009). 

Page 3 GAO-10-378 Nuclear Nonproliferation
 

We conducted this performance audit from January 2009 to March 2010, 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. 

A number of events are important in the history of DOE’s U.S. Plutonium 

Disposition program. Background 

• In 1994, the United States declared 38.2 metric tons of weapons-grade 

plutonium as surplus to national security needs. 

• In 1997, DOE announced a plan to dispose of surplus, weapons-grade 

plutonium through the following dual approach: (1) conversion into MOX 

fuel and (2) immobilization in glass or ceramic material. According to 

DOE, its approach would require the construction of three facilities—a pit 

disassembly and conversion facility, a MOX fuel fabrication facility, and an 

immobilization facility. 

• In 2000, the United States and Russia entered into a Plutonium 

Management and Disposition Agreement, in which each country pledged 

to dispose of at least 34 metric tons of surplus, weapons-grade plutonium, 

including the disposition of no less than 2 metric tons of plutonium per 

year. 

• In 2000, DOE announced in a record of decision that it would construct a 

pit disassembly and conversion facility, a MOX fuel fabrication facility, and 

an immobilization facility at SRS. 

• In 2002, NNSA canceled the immobilization portion of its surplus 

plutonium disposition strategy due to budgetary constraints. In addition, 

according to NNSA officials, NNSA canceled the immobilization portion 

because (1) Russia would not dispose of its plutonium if the United States 

adopted an immobilization-only approach and (2) the technology for MOX 

fuel fabrication had been in use in Europe for three decades, whereas 

immobilization of weapons-grade plutonium in glass or ceramic had never 

before been demonstrated. 

• In 2003, NNSA announced that it was pursuing a MOX-only plutonium 

disposition program to dispose of 34 metric tons of surplus, weaponsgrade plutonium. 

Page 4 GAO-10-378 Nuclear Nonproliferation
 

The majority of the 34 metric tons of surplus, weapons-grade plutonium is 

in the form of pits, clean metal, and oxides.5

 The remainder is in nonpit 

forms, such as contaminated metal, oxides, and residues from the nuclear 

weapons production process. While NNSA plans to build a pit disassembly 

and conversion facility to obtain plutonium from pits, it also plans to use 

the ARIES project—a technology development and demonstration project 

for pit disassembly and conversion located at LANL—to obtain a small 

amount of plutonium from pits. In addition, according to NNSA 

documents, NNSA plans to obtain plutonium from nonpit forms in two 

ways. First, the K-Area Facility at SRS is storing 4.1 metric tons of 

plutonium in nonpit form that is already suitable for use by the MFFF.6

Second, NNSA plans to prepare and process additional quantities of 

plutonium (3.7 metric tons) already at the K-Area Facility or planned for 

storage at the facility. 

Prior work by GAO has identified persistent problems with cost overruns 

and schedule delays on the PDCF project. For example, in our March 2007 

report on major DOE construction projects, we found that ineffective DOE 

project oversight, poor contractor management, and external factors were 

among the primary reasons for the cost increases and schedule delays 

associated with the PDCF project.7

 In addition, according to a May 2005 

DOE Inspector General report, NNSA officials attributed schedule delays 

for the PDCF to the disagreement between the United States and Russia 

about liability for work performed by U.S. contractor personnel working in 

Russia and a change in funding priorities.8

NNSA project directors are responsible for managing the MFFF, WSB, and 

PDCF projects and overseeing the contractors that design and construct 

these facilities. In doing so, project directors follow specific DOE 

 

5

In addition to the 34 metric tons of weapons-grade plutonium pledged for disposal in 2000, 

the Secretary of Energy declared 9 metric tons of weapons-grade plutonium as surplus to 

defense needs in September 2007. According to NNSA documents, NNSA plans to convert 

this additional material into MOX fuel at the MFFF but has not made an official decision. 

6

The K-Area Facility is SRS’s only special nuclear material storage facility designated for 

storage of significant quantities of plutonium and highly enriched uranium materials. The 

facility’s principal operations building housed K Reactor, which produced nuclear materials 

to support the United States for nearly four decades. The K Reactor was shut down in 1992. 

7

GAO-07-336. 

8

DOE, Office of Inspector General, National Nuclear Security Administration’s Pit 

Disassembly and Conversion Facility, DOE/IG-0688 (Washington, D.C.: May 3, 2005). 

Page 5 GAO-10-378 Nuclear Nonproliferation
 

directives, policies, and guidance for project management. Among these is 

DOE Order 413.3A, which establishes protocols for planning and executing 

a project. The protocols require DOE projects to go through a series of five 

critical decisions as they enter each new phase of work. These decisions 

are as follows: 

• Critical decision 0, which approves a mission-related need. 

• Critical decision 1, which approves the selection of a preferred solution to 

meet a mission need and a preliminary estimate of project costs—an 

approval that is based on a review of a project’s conceptual design. 

• Critical decision 2, which approves that a project’s cost and schedule 

estimates are accurate and complete—an approval that is based on a 

review of the project’s completed preliminary design. 

• Critical decision 3, which reaches agreement that a project’s final design is 

sufficiently complete and that resources can be committed toward 

procurement and construction. 

• Critical decision 4, which approves that a project has met its performance 

criteria for completion or that the facility is ready to start operations. 

To oversee projects and approve these critical decisions, DOE conducts its 

own reviews, often with the help of independent technical experts. For 

example, for large projects (with a total project cost of greater than $100 

million), DOE’s Office of Engineering and Construction Management 

(OECM) validates the accuracy and completeness of the project’s 

performance baseline as part of the critical decision 2 process. 

DOE Order 413.3A also requires projects to use EVM to measure and 

report the progress of construction projects (with a total project cost of 

greater than or equal to $20 million). EVM measures the value of work 

accomplished in a given period and compares it with the planned value of 

work scheduled for that period and with the actual cost of work 

accomplished. Differences in these values are measured in both cost and 

schedule variances. EVM provides information that is necessary for 

understanding the health of a program and provides an objective view of 

program status. As a result, EVM can alert program managers to potential 

problems sooner than expenditures alone can, thereby reducing the 

chance and magnitude of cost overruns and schedule delays. 

Page 6 GAO-10-378 Nuclear Nonproliferation
 

The following DOE offices and entities provide independent nuclear safety 

oversight: 

• HSS is responsible for policy development, independent oversight, 

enforcement, and assistance in the areas of health, safety, the 

environment, and security across DOE. Among its functions are periodic 

appraisals of the environmental, safety, and health programs at DOE sites, 

including evaluation of a sample of high-hazard nuclear facility at these 

sites to determine whether the program offices and their contractors are 

complying with DOE policies.9

• The NNSA Central Technical Authority is responsible for maintaining 

operational awareness of nuclear safety on NNSA projects, especially with 

respect to complex, high-hazard nuclear operations, and ensuring that 

DOE’s nuclear safety policies and requirements are implemented 

adequately and properly. 

• The CDNS is responsible for evaluating nuclear safety issues and 

providing expert advice to the Central Technical Authority and other 

senior NNSA officials. In particular, the CDNS is responsible for (1) 

validating that efforts to integrate safety into a project’s design include the 

use of a system engineering approach, (2) determining that nuclear 

facilities have incorporated the concept of defense-in-depth into the 

facility design process, and (3) validating that federal personnel assigned 

to an integrated project team as nuclear safety experts are appropriately 

qualified. 

Finally, DOE considers assessments and recommendations from external 

organizations, most prominently the Defense Nuclear Facilities Safety 

Board—an independent, external organization that reviews nuclear safety 

issues at DOE defense facilities and makes nonbinding recommendations 

to DOE. 

 

9

DOE regulations (10 CFR pt. 830, app. A to subpt. B § (C)(2)) define three categories of 

high-hazard nuclear facilities according to their potential to produce significant 

radiological consequences from an event that could either extend beyond the boundaries of 

a DOE site, remain within the boundaries of a site, or remain within the immediate vicinity 

of a nuclear facility. 

Page 7 GAO-10-378 Nuclear Nonproliferation
 

The MFFF and WSB construction projects both appear to be meeting their 

cost targets, but the MFFF project has experienced some delays over the 

past 2 years. In accordance with DOE project management requirements, 

both projects are using EVM to measure and report progress against their 

established cost and schedule estimates (also known as performance 

baselines) for construction. EVM provides a proven means for measuring 

such progress and thereby identifying potential cost overruns and 

schedule delays early, when their impact can be minimized. Differences 

from the performance baseline are measured in both cost and schedule 

variances.10 Positive variances indicate that activities are costing less or 

are completed ahead of schedule. Negative variances indicate that 

activities are costing more or are falling behind schedule. These cost and 

schedule variances can then be used in estimating the cost and time 

needed to complete the project. 

Construction Projects 

Appear to Be Meeting 

Cost Targets, but the 

MFFF Has Had 

Schedule Delays 

Figure 1 presents information on both cumulative cost and schedule 

variances for the MFFF project over the 2-year period ending November 

2009. With respect to cost, the MFFF project has experienced fluctuating 

variances during this period. Overall, these cost variances are relatively 

small compared with the project’s average monthly expenditures of over 

$20 million. In addition, it is normal for variances to fluctuate during the 

course of a project. 

 

10Cost variances compare the earned value of the completed work with the actual cost of 

the work performed. For example, if a contractor completed $5 million worth of work (i.e., 

the earned value of the work) and the work actually cost $6.7 million, there would be a 

negative $1.7 million cost variance. Schedule variances are also measured in dollars, but 

they compare the earned value of the work completed with the value of work that was 

expected to be completed. For example, if a contractor completed $5 million worth of 

work at the end of the month but was budgeted to complete $10 million worth of work, 

there would be a negative $5 million schedule variance. 

Page 8 GAO-10-378 Nuclear Nonproliferation
 

Figure 1: Cumulative Cost and Schedule Variances for MFFF over a 2-Year Period (2007-2009) 

Dollars in millions

Month/Year

Source: Shaw AREVA MOX Services, LLC. 

Schedule variance

Cost variance

-45

-40

-35

-30

-25

-20

-15

-10

-5

0

5

S

Oct. ‘09

Nov. ‘09

Au

ept. ‘09

g. ‘09

July ‘09

Feb. ‘09

Mar. ‘09

Apr. ‘09

May ‘09

June ‘09

Oct. ‘08

Nov. ‘08

Dec. ‘08

Jan. ‘09

S

Au

ept. ‘08

g. ‘08

Oct. ‘07

Nov. ‘07

Dec. ‘07

Jan. ‘08

Feb. ‘08

Mar. ‘08

Apr. ‘08

May ‘08

June ‘08

July ‘08

Sept. ‘07

However, with respect to the project’s schedule, the MFFF project has 

experienced consistently negative variances for most of the past 2 years. 

Specifically, as shown in figure 1, these schedule variances were 

consistently negative for most of 2008, and, for much of 2009, the project 

had not completed almost $40 million in scheduled work. According to the 

data and project officials, delays during 2008 were due primarily to the 

delivery of reinforcing bars that did not meet nuclear quality standards. 

Specifically, in February 2008, NRC inspectors identified numerous pieces 

of reinforcing bars—steel rods that are used in reinforced concrete—that 

did not meet industry standards for nuclear facilities. At that point, 

NNSA’s contractor, Shaw AREVA MOX Services, LLC (MOX Services), had 

accepted delivery of about 10,000 tons of reinforcing bars on-site and had 

installed almost 4,000 tons. Although NRC and MOX Services officials 

determined that the error did not affect the safety of reinforcing bars 

already installed, this issue had a major effect on the overall schedule for 

pouring concrete and installing reinforcing bars in the structure during 

2008. According to project officials, the project switched to a different 

Page 9 GAO-10-378 Nuclear Nonproliferation
 

supplier of reinforcing bars in September 2008 and by April 2009 had a 

sufficient supply of material to support the construction schedule. 

Schedule delays in 2009 occurred primarily because project officials 

decided that they had not allocated sufficient time in the existing schedule 

to ensure the delivery of materials that would meet the stringent safety 

and design standards for nuclear facilities. For example, according to 

project officials, the project extended the amount of time needed to 

produce concrete for the MFFF to provide additional assurance that the 

concrete will meet nuclear quality standards. The rate of concrete 

production will be gradually increased beginning in early 2010, according 

to project officials. In addition, the project extended the amount of time 

needed to fabricate and deliver slab tanks, which are used to hold liquid 

fissile material, to provide additional assurance that these tanks meet 

stringent safety and design standards. 

In recent months, the MFFF project has improved its schedule 

performance, so that it faced roughly $25 million in uncompleted work by 

November 2009, compared with almost $40 million in uncompleted work 

earlier in the year. According to project officials, this amount of negative 

schedule variance is equivalent to about 2 to 3 week’s worth of work on 

the project, and they expect to recover from this variance during 2010. In 

comparison, these officials stated that the project’s schedule includes 16 

month’s worth of contingency to mitigate any risks from additional delays 

before the expected start of MFFF operations. 

Figure 2 presents information on both cumulative cost and schedule 

variances for the WSB project over a 11-month period ending in November 

2009. With respect to cost, the WSB project has experienced consistently 

positive cost variances. However, schedule variances have been 

consistently negative over the same period. By November 2009, the project 

had not completed over $4 million worth of scheduled work, compared 

with average monthly expenditures of roughly $2 million during fiscal year 

2009. According to the NNSA federal project director, the schedule 

variances are due to a variety of factors, including delays in the 

procurement of cementation equipment and in the installation of piping 

due to inclement weather. However, the official said that he expects the 

project to recover from these delays, and that none of these factors will 

affect the overall construction schedule for the project. 

Page 10 GAO-10-378 Nuclear Nonproliferation
 

Figure 2: Cumulative Cost and Schedule Variances for the WSB, January through 

November, 2009 

Schedule variance

Cost variance

-10

-5

0

5

10

Jan. ‘09 Feb. ‘09 Mar. ‘09 Apr. ‘09 May ‘09 June ‘09 July ‘09 Aug. ‘09 Sept. ‘09 Oct. ‘09 Nov. ‘09

Dollars in millions

Source: NNSA.

Month/Year

The reliability of a project’s EVM system depends in large part on the 

reliability of its underlying schedule. A reliable schedule specifies when 

the project’s work activities will occur, how long they will take, and how 

they relate to one another. We have previously identified nine key 

practices necessary for developing a reliable schedule.11 In a March 2009 

testimony before this subcommittee, we identified several instances in 

which the MFFF project’s schedule did not adhere to these practices.12 In 

particular, we found that MFFF project staff had not conducted a risk 

analysis on their current schedule. 

 

11These practices are (1) capturing all activities, (2) sequencing activities, (3) establishing 

the duration of activities, (4) assigning resources to activities, (5) integrating activities 

horizontally and vertically, (6) establishing the critical path for activities, (7) identifying the 

float time between activities, (8) performing a schedule risk analysis, and (9) monitoring 

and updating the schedule. 

12GAO, Department of Energy: Contract and Project Management Concerns at the 

National Nuclear Security Administration and Office of Environmental Management, 

GAO-09-406T (Washington, D.C.: Mar. 4, 2009). 

Page 11 GAO-10-378 Nuclear Nonproliferation
 

However, since our March 2009 testimony, MFFF project officials have 

taken a number of steps to address our concerns. For example, project 

officials conducted a risk analysis of the MFFF project schedule in the 

summer of 2009 and used the results to update their risk management 

plan. In addition, project officials stated that they have significantly 

reduced the number of scheduled activities with long durations—that is, 

activities with start-to-finish durations of over 200 days.13 On the basis of 

these actions, we reevaluated the MFFF project’s schedule against the 

nine key scheduling practices. We also evaluated the WSB project’s 

schedule against these same practices. We found that both projects met 

most of the key practices to a satisfactory degree. For example, one key 

practice is to plan the schedule so that it can meet critical project dates. 

To do so, project officials must logically sequence all planned activities in 

the order that they are to be carried out. In particular, project officials 

must identify both predecessor activities—which must finish prior to the 

start of another activity—as well as successor activities—which cannot 

begin until other activities are completed. We found that the MFFF project 

had logically sequenced all scheduled activities, while the WSB project had 

logically sequenced the vast majority of its scheduled activities. For the 

complete results of our analysis of the projects’ schedules, see appendixes 

II and III. 

NNSA recently announced that it is considering a new alternative for its 

pit disassembly and conversion mission. However, due to the amount of 

time and effort needed to reconsider alternatives and construct a facility, 

as well as the amount of uncertainty associated with the agency’s new 

alternative, it seems unlikely that NNSA will be able to establish this 

capability in time to produce the plutonium oxide feedstock needed to 

operate the MFFF. As result of the likely delay in establishing a pit 

disassembly and conversion capability, NNSA may need to expand the 

ARIES project at LANL to provide additional interim plutonium feedstock 

to the MFFF. However, NNSA has not sufficiently planned for such a 

contingency. In addition, NNSA has not sufficiently planned for the 

maturation of critical technologies to be used in pit disassembly and 

conversion operations. 

NNSA Is 

Reconsidering 

Alternatives for Its Pit 

Disassembly Mission 

That Could Delay 

Production of 

Material Needed for 

the MFFF 

 

13When we conducted our analysis in February 2009, the MFFF project schedule contained 

1,064 activities with durations of over 200 days. According to our more recent analysis and 

interviews with project officials, the MFFF project schedule now has about 30 activities 

with durations of over 200 days. 

Page 12 GAO-10-378 Nuclear Nonproliferation
 

In 1997, DOE decided to establish a pit disassembly and conversion 

capability as part of its strategy for plutonium disposition. Because about 

two-thirds of the plutonium slated for disposition is contained in nuclear 

weapon pit form, the ability to disassemble pits is critical to the success of 

the program. In 2000, DOE decided to construct and operate a PDCF at 

SRS. Through 2009, NNSA’s strategy has been to design and construct the 

PDCF as a new, stand-alone facility on a site adjacent to the current 

construction site of the MFFF. While NNSA has never established a 

definitive cost and schedule estimate for the PDCF project, a 2009 NNSA 

report estimated that the PDCF would cost $3.65 billion to construct and 

be operational by April 2021.14

NNSA Recently 

Announced a New 

Alternative for Pit 

Disassembly, but the 

Alternative Depends on an 

Aggressive, Potentially 

Unrealistic Schedule 

However, DOE recently proposed a new alternative for establishing a pit 

disassembly and conversion capability at SRS. In September 2008, DOE 

authorized a study to review alternatives to the siting location of the PDCF 

capability within existing facilities at SRS and, as a result, to potentially 

improve its approach to disposition of surplus plutonium at SRS. 

Specifically, the study looked at the feasibility of combining the 

capabilities of the PDCF project with the Plutonium Preparation project, 

another project at SRS being managed by DOE’s Office of Environmental 

Management. The purpose of the Plutonium Preparation project, as 

approved by DOE in June 2008, was to prepare for disposition of up to 13 

metric tons of surplus, nonpit, plutonium-bearing materials that are either 

at the SRS K-Area Facility or planned for storage at the facility. According 

to DOE’s plans, the project would be installed in the K-Area Facility and 

would prepare the plutonium-bearing materials for disposition via two 

pathways: (1) converting some of the materials into plutonium oxide 

feedstock for the MFFF and (2) immobilizing the rest of the materials with 

high-level waste in glass using the Defense Waste Processing Facility at 

SRS. According to DOE’s 2008 preliminary estimate, this project would be 

operational in the 2013-2014 time frame at a cost of $340 million to $540 

million. 

 

14NNSA, Savannah River Site, Alternative Study: Pit Disassembly and Conversion at the 

Savannah River Site (June 2009), a predecisional draft for official use only. 

Page 13 GAO-10-378 Nuclear Nonproliferation
 

In November 2008,15 DOE issued a report stating that it would be feasible 

to combine the two projects at the K-Area Facility. According to NNSA’s 

preliminary estimates, the combined project would cost about $3.65 billion 

and would be constructed in two phases. The first phase would include the 

design and installation of equipment in one area of the K-Area Facility to 

provide the capability (formerly associated with the Plutonium 

Preparation project) to process 3.7 metric tons of surplus, nonpit 

plutonium, which would be used as an early source of plutonium oxide 

feedstock to the MFFF. The second phase would include the modification 

of a different area within the facility and the design and installation of 

equipment to provide the pit disassembly and conversion capability.16 In 

December 2008, NNSA suspended many of the activities associated with 

the PDCF project while it performed additional analyses, and DOE 

suspended activities associated with the Plutonium Preparation project. 

Finally, in November 2009, DOE approved the “pursuing” of the combined 

project approach, noting several potential benefits, such as greater funding 

flexibility, greater flexibility regarding DOE’s secure transportation 

system, the avoidance of expenditures associated with constructing a new 

facility, and the avoidance of costs associated with decontaminating and 

decommissioning two Category 1 nuclear facilities, among others. 

However, it appears unlikely that NNSA will be able to establish a pit 

disassembly and conversion capability in time to produce the plutonium 

feedstock needed to operate the MFFF beginning in 2021, due to the 

amount of time and effort needed to reconsider alternatives and construct 

a facility as well as the amount of uncertainty associated with the agency’s 

new proposal. First, according to NNSA officials, they do not expect to 

make a decision in the near future on which approach—either the PDCF 

as a stand-alone facility or the K-Area Facility combination project—they 

will ultimately approve. Specifically, officials told us that prior to making 

any decision, NNSA must first select its preferred alternative as part of the 

DOE critical decision 1 process. To prepare for critical decision 1, NNSA 

will need to develop and manage numerous details, including (1) the 

 

15DOE, Savannah River Site, Alternative Study: Combining the Pit Disassembly and 

Conversion Facility (PDCF) and Plutonium Preparation Project (PuP) within the KArea Complex (KAC) (November 2008), a predecision draft, unclassified controlled 

nuclear information. 

16According to NNSA officials, the majority of pit disassembly and conversion processing 

lines will be installed on the ground level of the facility. However, the project may also 

install a mezzanine level in several areas to house support equipment and electrical 

cabinets. 

Page 14 GAO-10-378 Nuclear Nonproliferation
 

appropriate review and documentation pursuant to the National 

Environmental Policy Act; (2) a transfer by the Secretary of Energy from 

the Office of Environmental Management to NNSA of the necessary 

materials, functions, and facilities to carry out the preferred alternative; 

and (3) issues related to federal and contractor program management, 

contract management, project management, and budget/financial 

management. As a result, NNSA officials said that they are still developing 

plans and schedules for the combination project and cannot provide any 

specific project schedule dates at this time. In addition, they stated that 

once NNSA makes a final decision on its strategy for pit disassembly and 

conversion as part of the critical decision 1 process, it will take several 

additional years to develop definitive cost and schedule estimates for its 

final approach as part of the critical decision 2 process. 

Second, a number of issues with NNSA’s new proposal raise doubts 

regarding whether the agency will be able to construct a facility in time to 

provide the plutonium feedstock necessary to operate the MFFF. For 

example: 

• According to NNSA documents, the K-Area Facility combined project will 

require an aggressive, near-term acquisition strategy and project 

development effort to design, construct, and start a pit disassembly and 

conversion capability under the current time constraints. Phase 1 of the 

project is scheduled to be operational by 2014 to provide an early source 

of feedstock (from nonpit plutonium sources) to the MFFF, and phase 2 

must be operational by 2021 to provide the bulk of the plutonium oxide 

feedstock that the MFFF will require to meet its planned production 

schedule. 

• According to NNSA documents, the existing schedule for the K-Area 

Facility combined project is at an early stage of development and lacks 

any quantified schedule contingency. 

• The project will require construction within an existing, secure, operating 

facility. Specifically, the project will need to excavate material from 

existing walls and floors in numerous locations to install piping and 

utilities, among other things. According to NNSA, during these 

excavations, the project may encounter conditions that have not been 

documented in existing design drawings for the K-Area Facility. 

Construction of a new facility, the original plan for the PDCF project, 

carries fewer risks of encountering unknown conditions—such as 

undocumented electrical wiring or other physical interfaces. 

Page 15 GAO-10-378 Nuclear Nonproliferation
 

• The project will require substantial coordination between NNSA and the 

Office of Environmental Management, as well as various contractor 

organizations, to address competing missions and out-year issues. As a 

result, according to NNSA, DOE may require additional federal resources 

and interface agreements between its various offices to ensure the proper 

integration and execution of the project. 

NNSA Has Not Sufficiently 

Planned for an Expansion 

of the ARIES Project If Pit 

Disassembly Operations 

Are Delayed 

NNSA’s new alternative assumes that the K-Area Facility combined project 

will become operational by the 6th year of MFFF operations (2021). 

However, if the design and construction of the project are delayed, NNSA 

may have to rely on the ARIES project at LANL to provide additional 

plutonium oxide feedstock for the MFFF. The ARIES project includes (1) 

laboratory facility preparation activities, (2) the acquisition of 

gloveboxes,17 (3) the design and assembly of a control system to operate 

the demonstration modules, (4) the preparation of all system 

documentation requirements, (5) the demonstration of the disassembly 

and conversion of all types of surplus nuclear weapon pits, (6) material 

control and accountability, and (7) measurements of personnel radiation 

exposure from all surplus pit types. LANL conducts activities associated 

with the ARIES project at its Plutonium Facility 4 building, which was 

constructed in 1978 as a multiuse plutonium research and development 

facility. NNSA’s current production mission for the ARIES project is to 

produce about 2 metric tons of plutonium oxide feedstock. Specifically, 

LANL is to produce 50 kilograms of plutonium oxide by the end of fiscal 

year 2010, ramp up to a target rate of 300 kilograms per year in fiscal year 

2012, and sustain this rate through fiscal year 2017. However, this 

material—along with additional quantities of plutonium in nonpit form 

currently stored at the K-Area Facility—will only be enough for the first 5 

years of the MFFF production schedule. 

NNSA has examined the possibility of expanding the ARIES project at 

LANL to provide additional plutonium oxide feedstock to the MFFF. 

Specifically, in May 2008, NNSA published a report that estimated NNSA 

might need as much as 12 metric tons of plutonium oxide feedstock to 

bridge a time gap between the startup of operations at the MFFF and the 

PDCF.18 The report’s authors evaluated several potential scenarios for 

increasing the amount of equipment and the number of work shifts at 

 

17A glovebox is a sealed, protectively lined compartment having holes to which are 

attached gloves for use in handling especially dangerous materials inside the compartment. 

18NNSA, Report on ARIES Throughput Options (May 2008), for official use only. 

Page 16 GAO-10-378 Nuclear Nonproliferation
 

LANL and estimated that ARIES could produce up to 16.7 metric tons of 

plutonium oxide at a cost of over $700 million. In conducting its analysis, 

the report’s authors made a number of assumptions, including that space 

would be available within the Plutonium Facility 4 building to 

accommodate an expanded ARIES mission, and that LANL would be able 

to provide the necessary vault space to accommodate an expanded ARIES 

mission. However, recent GAO work raises questions about the validity of 

these assumptions. Specifically, in May 2008,19 we assessed NNSA’s plans 

to expand pit manufacturing operations within the Plutonium Facility 4 

building. We found that NNSA would not be able to substantially increase 

its pit manufacturing capacity in the building for the foreseeable future 

because of several major constraints, including (1) limited vault space in 

the Plutonium Facility 4 building for storing pits and associated wastes 

and (2) competition for available floor space in the building due to the 

presence of other NNSA and DOE programs. For example, we found that 

vault space was one of the major limiting factors for pit production in 

fiscal year 2007, and that the vault was operating at 120 percent of its 

originally designed capacity. 

In a more recent study, NNSA concluded that LANL would not be a viable 

option to perform the entire pit disassembly and conversion mission. 

Specifically, in a November 2009 report,20 NNSA stated that the ARIES 

project would be unable to sustain the annual output of plutonium oxide 

feedstock necessary to support MFFF operations for a number of reasons. 

For example, the report stated that because the Plutonium Facility 4 

building is a one-of-a-kind, mission-critical facility for national defense, 

national defense missions in the facility will continue to take precedence 

over other programs—including the pit disassembly and conversion 

mission—for the foreseeable future. In addition, the report pointed out 

several of the same constraints to expanding operations in the Plutonium 

Facility 4 building that we described in our prior report on pit 

manufacturing. 

NNSA’s November 2009 report also concluded that LANL continues to be a 

viable option to produce some additional plutonium oxide material to fill a 

 

19GAO, Nuclear Weapons: NNSA Needs to Establish a Cost and Schedule Baseline for 

Manufacturing a Critical Nuclear Weapon Component, GAO-08-593 (Washington, D.C.: 

May 23, 2008). 

20NNSA, Plutonium Capacity Option Study (Nov. 19, 2009), unclassified controlled 

nuclear information. 

Page 17 GAO-10-378 Nuclear Nonproliferation
 

potential gap if the PDCF project is delayed further. However, the report 

did not update the prior 2008 report to determine what additional amount 

of material it would be feasible for the ARIES project to produce. The 

report also did not provide estimates for how much an expanded ARIES 

mission would cost or when LANL would be able to produce additional 

plutonium oxide material. Instead, the report noted that NNSA would need 

to prepare and validate a detailed, resource-loaded, integrated schedule 

for an expanded ARIES mission. As a result, it remains uncertain whether 

ARIES could fill a potential gap if NNSA’s main pit disassembly and 

conversion operations are delayed. 

In March 2010, DOE stated that NNSA does not plan on expanding the 

current mission of the ARIES project until LANL demonstrates that it can 

sustain a production rate of 300 kilograms of plutonium oxide a year over 

an extended period of time. In addition, DOE stated that NNSA is 

evaluating other options to provide plutonium oxide feedstock to the 

MFFF prior to the start of pit disassembly and conversion operations. 

These options included (1) the use of 1.4 metric tons of fuel-grade 

plutonium—material originally not intended for use by the MFFF—already 

in storage at the K-Area Facility and (2) starting up “limited but sufficient” 

pit disassembly processes.21

NNSA Has Not Sufficiently 

Planned for the Maturation 

of Critical Technologies 

NNSA’s current strategy relies on a number of technologies that are 

critical to establishing a pit disassembly and conversion capability. These 

technologies include the following systems and components: 

• Pit disassembly—includes a lathe, manipulators, and grippers to cut pits, 

extract the plutonium, and prepare it for oxidation. 

• Hydride dehydride—includes two furnaces to separate plutonium from 

other pieces of material. 

• Direct metal oxidation—includes a furnace to convert plutonium and 

uranium metal into plutonium and uranium oxide. 

• Oxide product handling—includes mill rollers and a blender to size and 

blend the plutonium oxide product. 

 

21Fuel-grade plutonium is plutonium with an isotopic ratio of plutonium-240 to plutonium239 of greater than 0.10 and less than 0.19. 

Page 18 GAO-10-378 Nuclear Nonproliferation
 

• Product canning—includes an automated bagless transfer system to 

package the final product. 

• Sanitization—includes a microwave furnace to melt components that do 

not contain plutonium or uranium. 

To demonstrate the viability of these technological components, DOE 

started the ARIES project at LANL in 1998. In addition, four other 

organizations are conducting testing and development activities in support 

of some of the critical technologies for pit disassembly and conversion: 

DOE’s Savannah River National Laboratory, DOE’s Pacific Northwest 

National Laboratory, the Clemson Engineering Technologies Laboratory, 

and a commercial vendor.22

Assessing technology readiness is crucial at certain points in the life of a 

project. Within DOE’s critical decision framework, such assessments are 

crucial at critical decision 2—acceptance of the preliminary design and 

approval of the project’s cost and schedule estimates as accurate and 

complete—and at critical decision 3—acceptance of the final design as 

sufficiently complete so that resources can be committed toward 

procurement and construction. Proceeding through these critical decision 

points without a credible and complete technology readiness assessment 

can lead to problems later in the project. Specifically, if DOE proceeds 

with a project when technologies are not yet ready, there is less certainty 

that the technologies specified in the preliminary or final designs will work 

as intended. Project managers may then need to modify or replace these 

technologies to make them work properly, which can result in costly and 

time-consuming redesign work. 

DOE has endorsed the use of the technology readiness level (TRL) process 

for measuring and communicating technology readiness in cases where 

technology elements or their applications are new or novel. In March 2008, 

DOE’s Office of Environmental Management published guidance on 

conducting technology readiness assessments and developing technology 

maturation plans. According to the guidance, staff should conduct 

technology readiness assessments using the TRL framework. Specifically, 

staff are to use a nine-point scale to measure TRLs. This scale ranges from 

a low of TRL 1 (basic principles observed) to a midlevel of TRL 6 

 

22The Clemson Engineering Technologies Laboratory is a contract research laboratory 

operated by Clemson University. 

Page 19 GAO-10-378 Nuclear Nonproliferation
 

(system/subsystem model or prototype demonstration in relevant 

environment) to a high of TRL 9 (total system used successfully in project 

operations). According to the guidance, for any critical technologies that 

did not receive a TRL of 6 or higher during such an assessment, staff 

should develop a technology maturation plan, which is supposed to 

describe planned technology development and engineering activities 

required to bring immature technologies up to the desired TRL of 6 or 

higher. This plan should include preliminary schedule and cost estimates 

to allow decision makers to determine the future course of technology 

development. In addition, the guidance stated that once a project reached 

the critical decision 2 stage, all critical technologies should have reached a 

TRL of 6. 

NNSA has undertaken a number of assessments of technological maturity 

and readiness for pit disassembly and conversion over the past decade as 

part of the ARIES project. For example, the PDCF project team carried out 

an evaluation of the maturity of ARIES equipment in 2003. According to 

project officials, the TRL framework was first used to assess the maturity 

of pit disassembly and conversion technologies in November 2008, in 

accordance with the Office of Environmental Management’s 2008 

guidance.23 In addition, as part of an independent review of the PDCF 

project, NNSA issued a report in January 2009 that included a technology 

readiness assessment of the ARIES equipment and other critical 

technologies.24 The results of this assessment, as well as the earlier 

assessment conducted in 2008, are shown in table 1. 

Table 1: Technology Assessments of Critical Pit Disassembly and Conversion 

Technologies Conducted in 2008 and 2009 

TRL 

Technology 

system/component 

As assessed by the 

PDCF project in 2008

As assessed by 

NNSA’s independent 

review in 2009

Pit disassembly 6-7 5

Hydride dehydride 3-4 4

 

23Washington Group International, Inc., Unclassified Summary for Technical Readiness of 

PDCF Processes (U) (Denver, Co: Nov. 10, 2008). 

24NNSA, Final Report: Technical Independent Project Review for the Pit Disassembly and 

Conversion Facility (PDCF) at the Savannah River Site (Jan. 13, 2009), for official use 

only. 

Page 20 GAO-10-378 Nuclear Nonproliferation
 

 TRL 

Technology 

system/component 

As assessed by the 

PDCF project in 2008

As assessed by 

NNSA’s independent 

review in 2009

Direct metal oxidation 7-8 5

Oxide product handling 4-5 4

Product canning 7-8 6

Sanitization 4-6 4-6

Sources: Washington Group International, Inc.; NNSA. 

As table 1 shows, there are a number of key technologies for pit 

disassembly and conversion that had not attained a TRL of 6. In 

accordance with the guidance on TRLs, NNSA should have a technology 

maturation plan in place to describe the planned technology development 

and engineering activities required to bring immature technologies up to 

the desired TRL of 6 or higher. According to NNSA officials, LANL had 

developed such a plan.25 However, we found that LANL’s plan lacked 

several key attributes of a technology maturation plan as described by 

DOE’s guidance. Specifically, we found the following problems with 

LANL’s plan: 

• A technology maturation plan is supposed to be developed to bring all 

immature critical technologies up to an appropriate TRL. However, LANL’s 

plan only addressed the technologies under development at LANL as part 

of the ARIES project. The plan did not address technologies, such as the 

oxide product handling equipment, being tested by the four other 

organizations. 

• For each technology assessed at less than TRL 6, a technology maturation 

plan should include preliminary schedule and cost estimates to allow 

decision makers to determine the future course of technology 

development. However, LANL’s plan did not include preliminary estimates 

of cost and schedule. 

• LANL’s plan is dated November 2007. However, NNSA has conducted or 

sponsored two technology readiness assessments of the PDCF critical 

technologies since that date. As a result, LANL’s plan is out of date and 

 

25LANL, Pit Disassembly and Conversion Integrated Design Support and Test Plan 

(November 2007). 

Page 21 GAO-10-378 Nuclear Nonproliferation
 

does not take into account the current state of maturity of its critical 

technologies. 

NNSA officials told us that while they recognize some of the problems 

with the project’s existing technology maturation plan, they have already 

prepared budget and schedule estimates for technology development 

activities in a number of separate documents (including the overall PDCF 

project schedule). However, they still have not updated the current 

technology maturation plan in accordance with DOE guidance. Until such 

an update is completed, it is uncertain whether these technologies will be 

sufficiently mature in time to meet the current, aggressive schedule for 

establishing a PDCF capability. 

NNSA has offered several incentives to attract customers for its MOX fuel 

and is working toward a formal agreement for the Tennessee Valley 

Authority (TVA) to purchase most of this fuel. However, NNSA’s outreach 

to other utilities may not yet be sufficient to inform potential customers of 

incentives to use MOX fuel. 

NNSA Has One 

Potential Customer 

for Most of Its MOX 

Fuel, but Outreach to 

Others May Be 

Insufficient 

NNSA Has Taken Steps to 

Attract Customers and Is 

in Negotiations with TVA 

NNSA and its contractor for the MFFF project, MOX Services, have 

established a production schedule for the fabrication of MOX fuel 

assemblies from surplus, weapons-grade plutonium. According to the 

current production schedule, the MFFF is to produce 8 MOX fuel 

assemblies in 2018, the initial year of production. The MFFF’s production 

rate is then to increase over the next 5 years up to a maximum rate of 151 

fuel assemblies per year (see fig. 3). The MFFF is expected to produce 

1,700 fuel assemblies during its production run. In addition, according to 

NNSA’s plans, these fuel assemblies will be designed for use in pressurized 

water nuclear reactors, which are the most common type of nuclear 

reactor in use in the United States.26

 

26A pressurized water reactor uses pressurized water to transfer heat from the reactor core 

to the steam generator, which then produces steam to turn the turbine generator. 

Page 22 GAO-10-378 Nuclear Nonproliferation
 

Figure 3: The MFFF Planned Production Schedule for MOX Fuel Assemblies 

0

20

40

60

80

100

120

140

160

2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032

Number of MOX fuel assemblies

Source: Shaw AREVA MOX Services, LLC.

Year

In June 2000, Duke Power (now Duke Energy Carolinas, LLC, or Duke), a 

power utility that operates seven pressurized water reactors in North 

Carolina and South Carolina, signed a subcontract with NNSA’s contractor 

for the MFFF project, MOX Services. According to NNSA officials, this 

subcontract gave the utility the option to purchase up to three-fourths of 

the MOX fuel produced by the MFFF at a discount relative to the price of 

normal reactor fuel, which uses low enriched uranium. According to the 

officials, the subcontract also obligated MOX Services to compensate 

Duke if the MOX fuel was not delivered by December 2007. However, as 

project delays continued to push back the start of construction, Duke, 

MOX Services, and NNSA began discussions in 2005 to renegotiate the 

subcontract. After nearly 3 years of discussions, Duke and MOX Services 

were unable to reach agreement by the negotiation deadline, and the 

subcontract automatically terminated on December 1, 2008. 

As negotiations with Duke came to an end, MOX Services, at NNSA’s 

direction, issued a request to nuclear utilities in October 2008 to express 

their interest in the MOX fuel program. The request outlined a number of 

possible incentives to mitigate the risks to utilities in using MOX fuel—

risks that include the need to modify reactors and obtain an operating 

license amendment from NRC to use MOX fuel. For example, the request 

discussed the possibility of (1) selling MOX fuel at a discount relative to 

Page 23 GAO-10-378 Nuclear Nonproliferation
 

the price of uranium fuel27 and (2) paying for costs associated with 

modifying a reactor and obtaining an operating license amendment from 

NRC. Furthermore, in January 2009, DOE reserved 12.1 metric tons of 

highly enriched uranium from its stockpile and hired a contractor to 

downblend this amount into 155 to 170 metric tons of low enriched 

uranium to serve as a backup supply of fuel if MOX fuel deliveries to 

customers are delayed.28 As of December 2009, NNSA and MOX Services 

were still working on an agreement on liability if fuel is not delivered on 

time. 

According to NNSA officials, three utilities have responded to MOX 

Services’ request and have expressed interest in the MOX fuel program. 

Notably, in February 2010, NNSA and TVA executed an interagency 

agreement to fund TVA studies on the use of MOX fuel in five of TVA’s 

reactors. Under the agreement, TVA will perform work on core design, 

licensing, modifications, and other related activities to evaluate the use of 

MOX fuel in its reactors. According to an NNSA official, using MOX fuel in 

five of TVA’s reactors could account for up to 85 percent of the MFFF’s 

output. The official also stated that an agreement with TVA to become a 

customer could be signed by the fall of 2010. TVA officials stated that they 

believed that familiarity gained by working with DOE during the Blended 

Low Enriched Uranium would help them work with DOE during the MOX 

program and cited this factor in their decision to begin discussions about 

becoming a customer for MOX fuel. Aside from TVA, NNSA officials 

characterized their contact with two other utilities as in the preliminary 

stages, and they could not estimate when or if they would secure them as 

customers for MOX fuel. 

Because utilities typically contract with fuel suppliers at least 5 years in 

advance, NNSA and MOX Services will need to secure customers several 

years before they deliver MOX fuel to them. NNSA officials said that their 

goal is to obtain at least one customer by the end of fiscal year 2010, in 

part because the 5-year period during which the MFFF will increase its 

 

27According to NNSA officials, the sale of MOX fuel over the course of the program would 

return approximately $1.1 billion to the U.S. Treasury, even with a discount relative to the 

price of uranium fuel. This figure assumes that the price of uranium fuel will remain at least 

at March 2009 levels; increases and decreases in uranium fuel price would affect the 

amount of revenue from MOX fuel sales. 

28NNSA officials told us that current plans are for the backup fuel to be stored at the 

contractor’s facility in the form of canisters. If the backup fuel is needed, the canisters can 

be delivered to a utility’s fuel fabricator to be converted into reactor fuel assemblies. 

Page 24 GAO-10-378 Nuclear Nonproliferation
 

production capacity will allow them additional time to secure more 

customers. Furthermore, if TVA agrees to be a customer and uses MOX 

fuel in five of its reactors, these officials said that NNSA may only need 

one additional utility to account for the remainder of the MFFF’s planned 

production of MOX fuel assemblies. 

However, NNSA faces two main obstacles in obtaining TVA as its primary 

customer. First, some of TVA’s reactors that would be candidates for using 

MOX fuel may not be permitted to use the fuel due to their status as 

backup reactors in DOE’s tritium production program. According to NNSA 

officials, the 2000 U.S.-Russian plutonium disposition agreement could be 

interpreted as precluding reactors involved in weapons production from 

being used to dispose of MOX fuel. TVA officials told us that they are 

working with DOE to transfer tritium production responsibilities to 

another TVA reactor that is not presently a candidate for the MOX 

program. Second, although NNSA currently plans to produce MOX fuel 

assemblies for use in pressurized water reactors, three of TVA’s reactors 

that are candidates for burning MOX fuel are boiling water reactors.29

NNSA officials told us that they are studying how the MFFF can be 

reconfigured to produce fuel assemblies for boiling water reactors. In 

particular, they stated that the MFFF’s design is based on a French MOX 

Facility, which can switch production between fuel assemblies for 

pressurized water reactors and for boiling water reactors in about 10 to 20 

days. However, the officials also stated that they might need to conduct 

additional tests on using MOX fuel assemblies in boiling water reactors 

before producing the fuel assemblies in large quantities, and that it was 

unclear whether such tests would delay the MOX production schedule. 

In March 2010, DOE stated that NNSA is evaluating several options for 

providing alternative sources of plutonium oxide material to the MFFF 

prior to the start of pit disassembly and conversion operations. One option 

under consideration is to adjust the “quantity and timing in providing 

initial fuel deliveries” to potential customers. 

 

29In a boiling water reactor, water moves through the reactor core and becomes a watersteam mixture, after which the water is removed and the steam is used to move the turbine 

generator. 

Page 25 GAO-10-378 Nuclear Nonproliferation
 

We interviewed fuel procurement officials at 22 of the nation’s 26 nuclear 

utilities to determine the extent to which nuclear utilities are interested in 

participating in DOE’s MOX fuel program and to evaluate what factors 

may influence their interest.30 The factors we asked about were based on 

input we received from industry experts, DOE officials, and former utility 

officials. (For a list of the structured interview questions that we asked 

utilities, see app. IV.) As shown in table 2, utility officials most often 

identified the following factors as very or extremely important when 

assessing their level of interest in participating in the MOX fuel program: 

NNSA’s Proposed 

Incentives Might Attract 

Customers, but Current 

Outreach May Be 

Insufficient 

• consistent congressional funding of the program, 

• DOE’s ability to ensure timely delivery of MOX fuel, 

• DOE’s ability to ensure the timely delivery of a backup supply of uranium 

fuel, 

• the cost of MOX fuel relative to the cost of reactor fuel, and 

• the opportunity to test MOX fuel in their reactors prior to full-scale use. 

Table 2: Factors Affecting a Utility’s Interest in the MOX Fuel Program 

Factor 

Number of utilities 

characterizing factor as 

“very important” or 

“extremely important”

Congressional funding of the program throughout its 

expected duration 20

DOE’s ability to ensure timely delivery of MOX fuel 20

DOE’s ability to ensure timely delivery of backup 

uranium fuel 19

Cost of MOX fuel relative to reactor fuel 19

Opportunity to test MOX fuel prior to full-scale use 19

Cost of modifying the reactor for MOX fuel use 17

Costs associated with obtaining NRC licensing to use 

MOX fuel 15

 

30To quantify utilities’ responses, we administered a structured interview to utilities, in 

which we asked them identical questions and requested that they select their answers from 

a series of set responses. 

Page 26 GAO-10-378 Nuclear Nonproliferation
 

Factor 

Number of utilities 

characterizing factor as 

“very important” or 

“extremely important”

Public opinion regarding MOX fuel use 14

Storage of MOX fuel on site prior to use 7

Source: GAO analysis of structured interviews of 22 utilities. 

We then asked utilities about possible incentives—some of which have 

already been proposed by NNSA and DOE—that may affect their interest 

in becoming program participants.31 We also asked about scenarios in 

which DOE offered a discount of 15 percent and 25 percent for MOX fuel 

relative to the price of regular reactor fuel. As shown in table 3, DOE’s 

payment for costs associated with reactor modifications and NRC 

licensing to use MOX fuel—two incentives DOE has actually proposed to 

utilities—resulted in the largest number of utilities expressing increased 

interest in participating in the MOX fuel program. 

Table 3: Number of Utilities Indicating Increased Interest in the MOX Fuel Program 

Due to Possible Incentives 

Incentive 

Number of 

utilities expressing 

increased interest

DOE payment for reactor modifications for MOX fuel usea15

DOE payment of costs associated with obtaining NRC 

licensing to use MOX fuela

14

DOE offering a 25 percent discount for MOX fuel in relation to 

regular reactor fuel 

13

DOE funding for MOX fuel testing prior to full-scale use 12

DOE offering a 15 percent discount for MOX fuel in relation to 

regular reactor fuel 

8

Source: GAO structured interview of 22 utilities. 

a

Indicates proposed DOE incentive. 

However, despite the incentives offered, as of October 2009 the majority of 

the utilities that we interviewed expressed little or no interest in becoming 

MOX fuel customers. Specifically, 12 utilities reported they were either not 

interested or not very interested in becoming MOX fuel customers, 8 

 

31During our interviews, we only identified DOE as the party offering potential incentives to 

simplify our questions. 

Page 27 GAO-10-378 Nuclear Nonproliferation
 

utilities were somewhat interested, and only 2 utilities indicated that they 

were currently very interested or extremely interested in the program. 

Three utilities indicated that they were currently interested enough to 

consider contacting DOE about becoming MOX fuel customers. When 

asked to consider the proposed incentives, however, 8 utilities expressed 

such interest.32 NNSA officials stated that they have communicated their 

willingness to provide incentives to potential customers. However, neither 

NNSA nor MOX Services has provided additional outreach or information 

to utilities in general since the October 2008 request for expression of 

interest.33 Furthermore, 11 utilities responded in our interviews that they 

had heard or read very little about the MOX fuel program, while 5 

responded that they had received no information. In our view, the fact that 

so few utilities expressed sufficient interest in even contacting NNSA and 

MOX Services suggests that NNSA’s outreach may not be sufficient. 

NRC has primary regulatory responsibility for nuclear safety at the MFFF, 

and NRC’s activities to date have included authorizing construction, 

identifying safety-related issues with construction, and reviewing the 

license application for the operation of the facility. DOE has primary 

regulatory responsibility for nuclear safety at the WSB and has looked at 

some aspects of nuclear safety for both the MFFF and the WSB as part of 

its management reviews. However, oversight by DOE’s independent 

nuclear safety entities has been limited. 

NRC Has Been 

Providing Oversight 

for the MFFF, but 

DOE’s Independent 

Oversight of the 

MFFF and the WSB 

Has Been Limited 

 

32Specifically, we asked utility officials to estimate what their interest in participating in the 

program would have to be to submit an expression of interest to DOE. 

33An NNSA official told us that, as of February 2010, MOX Services is in discussions with a 

nuclear services company to market and sell a portion of the MFFF’s output. Under this 

agreement, the nuclear services company would purchase a portion of the output of the 

MFFF and then would be responsible for selling the fuel assemblies to nuclear utilities. The 

NNSA official told us that he could not specify when a contract between MOX Services and 

the company will be presented to NNSA for approval, although it could occur at some point 

in 2010. MOX Services is also holding exploratory discussions about potential roles in 

marketing MOX fuel to U.S. utilities with the two other commercial nuclear fuel fabrication 

and services companies that operate in the United States. 

Page 28 GAO-10-378 Nuclear Nonproliferation
 

NRC Has Been Reviewing 

the MFFF’s License 

Application and Has 

Identified Issues with 

Construction Practices 

NRC is responsible for licensing the MFFF to produce fuel for commercial 

nuclear reactors. To do so, NRC is using a two-stage review and approval 

process: the first stage is construction authorization, and the second stage 

is license application approval. The construction authorization stage began 

in February 2001, when the MFFF contractor submitted an application to 

begin construction. As part of the construction authorization review, NRC 

reviewed key documents, including the project’s preliminary safety 

designs, environmental impact statement, and quality assurance plan. NRC 

approved the facility’s construction authorization request in March 2005. 

NRC began its review of the MFFF project’s application for a license to 

possess and use radioactive materials in December 2006. NRC has divided 

the license review into 16 areas, including criticality/safety, chemical 

processing, and fire protection. NRC has issued requests for additional 

information for each of the 16 review areas. According to NRC officials, 

once NRC staff obtain all of the necessary information in a given area, they 

prepare a draft section for that area to be included in the draft Safety 

Evaluation Report for the facility. As shown in table 4, NRC had drafted 

sections for 6 of the 16 review areas as of January 2010. Once all of the 

draft sections are complete, NRC staff will prepare a draft safety 

evaluation report and, after concurrence from NRC management, will 

submit them to NRC’s Advisory Committee on Reactor Safeguards—a 

committee of experts that is independent of the staff and that reports 

directly to NRC’s commissioners—for review and comment. NRC staff are 

then to incorporate, at their discretion, the committee’s comments into the 

license approval document and issue a final safety evaluation report for 

the facility, which NRC expects to occur in December 2010. Once NRC 

completes the licensing review and verifies that MOX Services has 

completed construction of the primary structures, systems, and 

components of the MFFF, it may issue the license. NRC officials stated 

that they could issue the license by 2014 or 2015, depending on the 

construction status of the facility. 

Table 4: Status of NRC’s Review of the MFFF’s Operating License as of January 

2010 

Review area Safety section drafted 

Chemical processing No 

Civil/Structural Yes 

Classified matter handling Yes 

Criticality safety Yes 

Confinement No 

Page 29 GAO-10-378 Nuclear Nonproliferation
 

Review area Safety section drafted 

Emergency planning Yes 

Environmental protection Yes 

Fire protection No 

Human factors No 

Instrumentation and control No 

Integrated safety analysis No 

Management measures No 

Material control and accounting No 

Physical protection No 

Plant systems No 

Radiation protection Yes 

Source: NRC. 

One issue that NRC raised during its review of the MFFF project is the 

design of safety controls to prevent a chemical reaction known as a “red 

oil excursion.”34 Specifically, in January 2004, during the construction 

authorization stage, a senior NRC chemical safety reviewer stated that the 

MFFF’s planned safety controls to prevent a red oil excursion differed 

from those recommended by DOE and the Defense Nuclear Facilities 

Safety Board. In response, NRC convened a panel in March 2005 to 

evaluate the reviewer’s concerns. The panel issued a report in February 

2007 concluding that although NRC’s construction authorization of the 

MFFF did not need to be revisited, there was wide agreement among NRC 

staff and the Advisory Committee on Reactor Safeguards that significant 

technical questions remained unanswered about the MFFF’s planned 

safety controls. To address these technical questions, NRC has taken a 

number of actions, including the following: 

• NRC engaged the assistance of the Brookhaven National Laboratory to 

provide two independent assessments of the risk of a red oil excursion at 

the facility. Brookhaven National Laboratory issued an initial report in 

March 2007 and a follow-up report in August 2009 in which it examined 

 

34A red oil excursion is an explosive, runaway reaction that can occur when organic 

solvents containing tributylphosphates come into contact with nitric acid. While this 

reaction could occur during the manufacture of MOX fuel, it is not specific to the MOX 

process. 

Page 30 GAO-10-378 Nuclear Nonproliferation
 

updated safety information provided by MOX Services.35 The second of the 

two reports concluded that the risk of a red oil excursion at the facility is 

highly unlikely. 

• During the current licensing application stage, NRC officials have 

requested and received additional information from MOX Services related 

to planned safety controls to prevent a red oil excursion. However, as of 

our review, NRC staff had not completed their draft safety evaluation 

report for this area. 

NRC’s oversight responsibilities also include inspecting the construction 

of the MFFF as well as the project’s own quality assurance plan. NRC’s 

Division of Construction Projects, based in NRC’s Region II headquarters 

in Atlanta, conducts periodic inspections of the MFFF that assess the 

design and installation of the facility’s principal structures, systems, and 

components and verify that the project’s quality assurance program is 

adequately implemented. These inspections involve document reviews and 

site inspections over several weeks and can include specialty reviews in 

welding, concrete, and other construction subject areas. NRC evaluates 

the MFFF’s construction against standards set by the American Concrete 

Institute and the American Society of Mechanical Engineers, among 

others. In addition to the Region II inspections, NRC maintains one 

resident inspector at the construction site who conducts day-to-day 

inspection activities, such as walk-throughs. NRC also plans to hire an 

additional full-time resident inspector for the MFFF in fiscal year 2010. 

As part of its ongoing inspection of the construction of the MFFF, NRC has 

issued 16 notices of violation against MOX Services since the start of 

construction in August 2007 related to various subjects, including quality 

assurance and control over design changes. (See app. V for a complete list 

and description of NRC notices of violation.) Although NRC has classified 

all of the violations to date as severity level IV, the lowest safety-

 

35Brookhaven National Laboratory, Risk Assessment of Red Oil Excursions in the MOX 

Facility (Upton, N.Y.: March 2007), for official use only; Brookhaven National Laboratory, 

Risk Assessment of Red Oil Excursions in the MOX Facility (Upton, N.Y.: August 2009), 

for official use only. 

Page 31 GAO-10-378 Nuclear Nonproliferation
 

significant designation in its four-category scale, the violations have had 

an effect on the project’s schedule.36

In addition to its regular construction reviews, NRC issues periodic 

assessments of the contractor’s performance. In its latest assessment, 

released in November 2009, NRC concluded that MOX Services had 

conducted its overall construction activities at the MFFF in an acceptable 

manner. However, NRC also determined that MOX Services must improve 

its control over changes to the MFFF’s design and increase its attention to 

its quality assurance oversight of vendors. NRC identified several 

examples of deficiencies associated with performing, verifying, and 

documenting design changes and noted failures on the part of MOX 

Services to adequately translate requirements into design and construction 

documents. In addition, NRC concluded that its finding of a violation 

related to MOX Services’ vendor oversight indicates “a challenge to [MOX 

Services’] quality assurance staff to provide effective oversight of vendors 

that perform work on, fabricate, or supply components and equipment for 

use at the MFFF.” In its assessment, NRC stated that it will conduct 

additional inspections to assess the effectiveness of MOX Services’ 

corrective actions. In response to NRC’s assessment, MOX Services stated 

that it is taking steps to strengthen its design control process, such as 

increasing training for quality control supervisors; introducing quality 

control checklists into its subcontractor and construction procedures; and 

conducting oversight visits to vendors. 

DOE Included Nuclear 

Safety in Management 

Reviews of the Projects, 

but Oversight by DOE’s 

Independent Nuclear 

Safety Entities Has Been 

Limited 

Although DOE has incorporated elements of nuclear safety in management 

reviews of the MFFF and the WSB projects that were conducted as part of 

its critical decision review process, DOE’s independent nuclear safety 

entities were minimally involved. As part of the critical decisions 2 and 3 

review process for the MFFF project, OECM conducted a review of the 

MFFF project during April and May, 2006, which included nuclear safety 

as one of several review areas. A review team comprising independent 

consultants and former DOE officials evaluated, among other things, the 

integration of nuclear safety into the project’s environmental, safety, and 

health programs, as well the contractor’s process for addressing issues 

found by NRC. The review identified one finding related to safety, noting 

 

36As we have previously described, one of these violations was NRC’s February 2008 

findings and notice of violation related to nonconforming reinforcing bars, which resulted 

in delays in the schedule for the pouring of concrete during 2008. 

Page 32 GAO-10-378 Nuclear Nonproliferation
 

that the ongoing revision of the project contract could introduce conflicts 

with NRC regulations. NNSA accepted the review’s recommendation to 

develop a memorandum of understanding with NRC to resolve this issue. 

Regarding the WSB project, OECM conducted a review during September 

2008—as part of the critical decision 2 process—that included nuclear 

safety as one of several review areas. The review team examined key WSB 

documents related to nuclear safety, including the facility’s safety 

evaluation report, preliminary documented safety analysis, and the design 

hazard analysis report. The review team recommended that an additional 

hazard analysis for one system be performed but determined that overall, 

the hazard analyses and safety assessments for the WSB were 

comprehensive and complete. In addition, NNSA’s Office of Project 

Management and Systems Support conducted another review of the WSB 

project during September 2008 as part of the critical decision 3 process. 

Because it was almost simultaneous with OECM’s review, NNSA’s review 

was less comprehensive and focused specifically on the WSB’s ability to 

protect against a red oil excursion. This review resulted in a single 

recommendation, that is, for additional justification for the inclusion of 

certain equipment in the facility’s design. In response to the 

recommendation, the WSB project team submitted a revised safety 

evaluation report justifying the equipment. 

HSS is responsible for policy development, enforcement, and independent 

oversight in the areas of health, safety, the environment, and security 

across DOE. To accomplish this responsibility, this office performs 

appraisals to verify, among other things, that the department’s employees, 

contractors, the public, and the environment are protected from hazardous 

operations and materials. However, these appraisals are designed to 

complement, not duplicate, program office oversight and self-assessments. 

In particular, HSS conducts visits to DOE sites and reviews a sample of 

facilities at those sites, including construction activities for new facilities. 

In addition, according to HSS officials, the office assists DOE’s program 

offices by conducting reviews of documents supporting the safety basis—

which is a technical analysis that helps ensure the safe design and 

operation of DOE’s nuclear facilities—of a sample of high hazard nuclear 

facilities at a DOE site. For example, in response to our October 2008 

report, which found that HSS was not conducting reviews of the safety 

basis of new, high-hazard nuclear facilities, HSS issued a new appraisal 

process guide in July 2009 that emphasized increased focus on the safety 

Oversight by HSS Has Been 

Limited 

Page 33 GAO-10-378 Nuclear Nonproliferation
 

basis at such facilities.37 Finally, HSS has other oversight and advisory 

responsibilities related to nuclear safety during critical decision reviews 

for major DOE facilities. These responsibilities are spelled out in DOE’s 

Order 413.3A, which provides direction on program and project 

management for the acquisition of capital assets, and include the following 

actions: 

• participating on the Energy Systems Acquisition Advisory Board—a body 

comprising senior DOE officials who advise DOE’s Secretarial Acquisition 

Executive in critical decisions regarding major projects and facilities; 

• advising the DOE Secretarial Acquisition Executive on environmental, 

safety, and security matters related to all critical decision approvals; 

• serving on independent project reviews as a team member at the request 

of the Secretarial Acquisition Executive or program officials; and 

• participating on external independent reviews as an observer at OECM’s 

request. 

Regarding the MFFF project, HSS has provided limited oversight. 

According to HSS officials, a more limited amount of oversight is 

appropriate for the MFFF because of the National Defense Authorization 

Act of 1999, which gave NRC responsibility for regulating nuclear safety at 

the MFFF. HSS has conducted some inspection activities at the MFFF, 

including reviewing reinforced concrete and structural steel at the facility 

during site visits to SRS in August and September, 2009. However, HSS 

officials said that these activities did not include a review of documents 

supporting the MFFF’s safety basis. In addition, while HSS officials stated 

that personnel from HSS’s predecessor office participated in the critical 

decisions 2 and 3 reviews for the MFFF project during 2006, HSS was 

unable to provide any documentation to substantiate this statement.38

According to department officials, HSS had limited resources for 

conducting reviews and needed to focus its resources on facilities that 

were not subject to external regulation. 

 

37GAO, Nuclear Safety: Department of Energy Needs to Strengthen Its Independent 

Oversight of Nuclear Facilities and Operations, GAO-09-61 (Washington, D.C.: Oct. 23, 

2008); and DOE, Office of Health, Safety, and Security, Office of Environment, Safety, and 

Health Evaluations Appraisal Process Guide (Washington, D.C.: July 2009). 

38DOE established HSS in October 2006. 

Page 34 GAO-10-378 Nuclear Nonproliferation
 

Regarding nuclear safety oversight of the WSB project, which is solely 

regulated by DOE, we found that HSS had not conducted any oversight 

activities or participated in any critical decision reviews. Specifically, HSS 

officials told us that they have not reviewed any documents supporting the 

WSB’s safety basis, nor have they conducted any inspection activities at 

the WSB construction site. Despite the issuance of HSS’s new appraisal 

process guide, which contains inspection protocols for new and 

unfinished high-hazard nuclear facilities, an HSS official told us that the 

office has yet to determine when they will inspect the WSB. An HSS 

official told us that he was uncertain whether a WSB inspection would 

occur in 2010 because an ongoing internal DOE review has delayed the 

development of the office’s 2010 inspection schedule. However, if HSS’s 

initial visit occurs later than 2010, NNSA will have already completed at 

least half of the WSB’s construction, according to the project’s schedule. 

Additionally, HSS did not participate in any of the critical decision reviews 

for the WSB project because of existing DOE guidelines. Specifically, 

although the WSB is considered a category 2 (high-hazard) nuclear facility, 

it is categorized as a nonmajor project.39 According to DOE’s order, HSS is 

not required to participate on the review board for a nonmajor project. In 

addition, neither OECM nor NNSA requested HSS to participate on the 

project reviews conducted for critical decisions 2 and 3. 

DOE’s Order 413.3A calls for the NNSA Central Technical Authority to 

maintain operational awareness regarding complex, high-hazard nuclear 

operations, and to ensure that DOE’s nuclear safety policies and 

requirements are implemented adequately and properly. The order also 

directs the CDNS to support the Central Technical Authority in this effort 

by 

Oversight by CDNS Has Been 

Limited 

• participating as part of the Energy Systems Acquisition Advisory Board for 

major facilities, or similar advisory boards for minor facilities; 

• providing support to both the Central Technical Authority and the 

Acquisition Executive regarding the effectiveness of efforts to integrate 

safety into design at each of the critical decisions, and as requested during 

other project reviews; 

 

39DOE Order 413.3A defines a nonmajor project (other than an environmental management 

project) as one with a total project cost of less than $750 million. 

Page 35 GAO-10-378 Nuclear Nonproliferation
 

• determining that nuclear facilities have incorporated the concept of 

defense-in-depth into the facility design process; 

• validating that the integration of design and safety basis activities includes 

the use of a system engineering approach tailored to the specific needs 

and requirements of the project; and 

• validating that federal personnel assigned to projects as nuclear safety 

experts are appropriately qualified. 

The CDNS’s manual for implementing DOE Order 413.3A provides 

additional guidance, such as establishing the responsibilities of CDNS staff 

for evaluating safety activities at nuclear facilities. The manual also directs 

the head of the CDNS to participate in relevant staff meetings for NNSA 

projects that are requesting a decision from the Energy Systems 

Acquisition Advisory Board, an activity that may not be delegated for 

major projects.40

However, according to the head of the CDNS, his office has not 

participated in any safety review activities at the MFFF because NRC is 

regulating nuclear safety at the facility. The head of the CDNS 

acknowledged that his office’s approach to overseeing nuclear safety for 

the MFFF project does not follow the guidance set out in DOE orders and 

related manuals and has not been formally adopted by NNSA. He stated 

this approach is necessary to make more efficient use of CDNS resources 

by focusing oversight activities on facilities regulated entirely by DOE. 

According to NNSA officials, DOE Order 413.3A does not explicitly 

exempt the CDNS from overseeing facilities regulated by NRC. Agency 

officials stated that NNSA is working with the Department to have that 

exemption inserted into the order during an upcoming revision of the 

order. NNSA officials stated that, historically, there was never an intention 

that the CDNS would have responsibilities for facilities regulated by NRC, 

and that this needs to be clarified in the order. 

The CDNS has provided some oversight of the WSB project, but according 

to the head of the CDNS, this oversight has been limited, due in part to 

difficulty in applying DOE’s guidance to the WSB and staffing issues. The 

CDNS participated as an observer on the advisory board for the WSB 

 

40DOE, “Implementation of CDNS Responsibilities Regarding Safety in Design and 

Construction of Nuclear Facilities” (CDNS M 413.3A). 

Page 36 GAO-10-378 Nuclear Nonproliferation
 

project during the project’s critical decisions 2 and 3 processes. However, 

the head of the CDNS said that he had no record of whether his office 

participated in or evaluated the results of OECM’s review during the 

critical decision 2 process, which included several lines of inquiry related 

to nuclear safety. During the critical decision 3 process for the WSB 

project, CDNS staff reviewed key project safety documents to determine 

how the facility would protect against a red oil excursion and determine 

the qualifications of the federal staff person assigned to the project as a 

nuclear safety expert. 

Despite these efforts, the head of the CDNS told us that during the critical 

decision 3 review, his office experienced some difficulty in implementing 

the guidance established in DOE orders for the WSB project. The office’s 

current policy is to review a project’s safety documentation early in the 

design process and determine whether it conforms to DOE’s relevant 

safety standard for integrating safety into design and incorporating 

defense-in-depth.41 The WSB project had completed its design work before 

DOE issued its current standard, and before the CDNS implemented a 

systematic approach to fulfilling its functions. Consequently, the CDNS did 

not perform a systematic review of WSB safety documentation. The CDNS 

head characterized the WSB review as being an ad hoc, qualitative 

assessment of some of the project’s safety documentation. Additionally, 

the CDNS has not evaluated the qualifications of the nuclear safety expert 

that replaced the one evaluated as part of the critical decision 3 review. 

However, according to the head of the CDNS, his office only plans to 

evaluate the qualifications of new staff during technical reviews of the 

project, not after every change to the project team’s composition. 

The head of the CDNS told us that his office has begun developing a more 

systematic approach to evaluating the design safety of DOE facilities. In 

addition, he stated that he would like to conduct additional safety reviews 

of facilities currently in design and construction. However, he said that 

these efforts have been hampered, in part due to staffing shortages. For 

example, the CDNS had a staff of 13 people in 2007. As of December 2009, 

however, only 4 people remained on the CDNS staff due to attrition and 

NNSA’s decision to transfer some of the personnel into other program 

offices. The head of the CDNS stated that current staffing levels have led 

the CDNS to focus its attention on projects that are still in the design 

 

41DOE, “DOE Standard: Integration of Safety into the Design Process,” DOE-STD-1189-2008 

(Washington, D.C.: March 2008). 

Page 37 GAO-10-378 Nuclear Nonproliferation
 

phase. He said that it was doubtful that the CDNS would return to the WSB 

to ensure that safety basis controls are fully integrated during its 

construction. Concerns over CDNS staffing issues also were raised by the 

Defense Nuclear Facilities Safety Board. Specifically, in its March 2009 

letter to the Secretary of Energy, the safety board noted that reduced staff 

levels and the transfer of CDNS personnel into NNSA’s program offices 

have reduced the effectiveness of the office. 

NNSA is already over 2 years into its construction schedule for the MFFF 

and expects the facility to become operational by 2016. It has also 

established a production schedule for fabricating up to 151 MOX fuel 

assemblies per year at full production. However, the agency faces 

uncertainty as to (1) its ability to supply the MFFF with sufficient 

quantities of plutonium oxide feedstock to meet its planned production 

schedule of MOX fuel and (2) the demand for MOX fuel assemblies from 

potential customers. 

Conclusions 

Regarding the supply of plutonium oxide feedstock, NNSA only has a 

limited quantity of feedstock on hand to supply the MFFF prior to the start 

of pit disassembly operations. However, NNSA has not established a 

definitive strategy for pit disassembly operations, nor does it expect to do 

so in the near future. As a result, it appears unrealistic that NNSA will be 

able to meet its current production schedule for MOX fuel without 

obtaining additional sources of plutonium oxide. NNSA has stated that 

while it does not plan on expanding the current mission of the ARIES 

project until LANL demonstrates a sustained production rate over an 

extended period of time, it is evaluating other options to address this 

potential shortfall of plutonium oxide. These options include (1) the use of 

1.4 metric tons of fuel-grade plutonium already in storage at the K-Area 

Facility, (2) starting up “limited but sufficient” pit disassembly processes, 

and (3) adjusting the “quantity and timing” in delivering MOX fuel to 

potential customers. We have concerns with these options, including: 

• NNSA’s use of a “wait-and-see” approach to the ARIES project, and the 

implications this may have on the ability of the ARIES project to meet its 

current and future production goals; 

• the implications of the use of fuel-grade plutonium on the design and 

safety of the MFFF, and the extent to which DOE has adequately 

determined how much additional material throughout the DOE complex 

may be suitable and available for use by the MFFF; 

Page 38 GAO-10-378 Nuclear Nonproliferation
 

• how DOE plans to establish limited pit disassembly processes given the 

current lack of a definitive strategy for pit disassembly operations; and 

• how DOE plans to adjust the MOX fuel production schedule, and the 

implications this may have on the cost and schedule for operating the 

MFFF and DOE’s ability to attract potential MOX fuel customers. 

In addition to these concerns, while NNSA’s strategy relies on critical 

technologies currently under development at LANL and other sites for pit 

disassembly and conversion operations, its current technology maturation 

plan does not meet DOE’s current guidance because the plan is outdated 

and incomplete. Without a plan that provides more details on the options 

DOE has mentioned to increase the supply of plutonium oxide, or a 

comprehensive technology maturation plan, it is uncertain whether NNSA 

will be able to meet the MFFF’s planned production schedule. 

Regarding obtaining customers for MOX fuel assemblies, our survey of 

utilities indicated that some utilities might be interested in becoming 

customers but appear unaware of the incentives NNSA and DOE are 

offering. Without additional outreach, NNSA may not be able to obtain 

sufficient customers for the MOX fuel it plans to produce, which would 

leave the agency with nuclear material it cannot dispose of and the U.S. 

Treasury with a forgone opportunity for revenue. 

Although DOE incorporated some aspects of nuclear safety oversight in its 

management reviews of the MFFF and WSB projects, oversight by HSS 

and the CDNS has been limited. Specifically, HSS has conducted limited 

oversight activities at the MFFF but has played no role in the WSB project 

because of its designation as a nonmajor project. Conversely, the CDNS 

has played no role in the MFFF project and has provided some elements of 

nuclear safety oversight for the WSB project. However, it has not fully met 

the responsibilities laid out for it by DOE order, in part due to a lack of a 

formal, standardized approach for reviewing project safety documents. We 

believe that HSS’s exclusion from the WSB project reviews, as well as the 

limited involvement of the CDNS in the WSB project reviews, creates a gap 

in oversight of the WSB and similar facilities. 

We are making the following five recommendations. 

To address uncertainties associated with NNSA’s plans to establish a pit 

disassembly and conversion capability, we recommend that the 

Recommendations for 

Executive Action 

Page 39 GAO-10-378 Nuclear Nonproliferation
 

Administrator of the National Nuclear Security Administration take the 

following three actions: 

• Develop a plan to mitigate the likely shortfall in plutonium oxide feedstock 

for the MFFF prior to the start of pit disassembly operations. This plan 

should include, at a minimum, the following five items: (1) the actions 

needed to ensure that the ARIES project will meet its existing production 

goals, and the cost and schedule associated with any needed expansion of 

the project; (2) an assessment of how much additional plutonium material, 

including fuel-grade plutonium, is available within the DOE complex for 

use as feedstock for the MFFF; (3) an assessment of the effect on the 

design and safety of the MFFF from the use of fuel-grade plutonium as 

feedstock; (4) an assessment of potential changes to the MOX fuel 

production schedule and the effect of these changes on the cost and 

schedule for operating the MFFF; and (5) an assessment of the cost and 

schedule associated with obtaining a limited but sufficient pit disassembly 

process to produce feedstock for the MFFF. 

• Develop a technology maturation plan for the pit disassembly and 

conversion mission that (1) includes all critical technologies to be used in 

pit disassembly and conversion operations and (2) provides details 

(including preliminary cost and schedule estimates) on planned testing 

and development activities to bring each critical technology up to a 

sufficient level of maturity. 

• Conduct additional outreach activities to better inform utilities about the 

MOX fuel program and related incentives. 

To ensure that the WSB and similar projects receive consistent nuclear 

safety oversight that is independent from the DOE program offices, we 

make the following two recommendations: 

• The Secretary of Energy should revise DOE Order 413.3A to provide that 

HSS participate in key project reviews for the WSB and similar high-hazard 

facilities prior to the beginning of construction activities regardless of 

their status as nonmajor projects. 

• The Administrator of NNSA should ensure that the CDNS conducts 

oversight activities to the extent called for by DOE Order 413.3A and 

establishes a formal, standardized approach to reviewing safety 

documentation. 

Page 40 GAO-10-378 Nuclear Nonproliferation
 

We provided the Department of Energy, the National Nuclear Security 

Administration, and the Nuclear Regulatory Commission with a draft of 

this report for their review and comment. In commenting on the draft 

report, the NNSA Associate Administrator for Management and 

Administration said that DOE agreed with the report and its 

recommendations. 

Agency Comments 

and Our Evaluation 

However, we have concerns about DOE’s response to one of our 

recommendations. Specifically, in commenting on our recommendation in 

a draft report that NNSA should develop a plan for expanding the ARIES 

project to produce additional quantities of plutonium oxide feedstock for 

the MFFF, DOE stated that NNSA is also evaluating other options for 

producing additional feedstock material for the MFFF, including (1) the 

use of 1.4 metric tons of fuel-grade plutonium already in storage at the KArea Facility, (2) starting up “limited but sufficient” pit disassembly 

processes, and (3) adjusting the “quantity and timing” in delivering MOX 

fuel to potential customers. This information was not disclosed to us 

during our review, and we have a number of concerns about these options. 

For example, regarding the option to process fuel-grade plutonium, the 

MFFF was designed to process weapons-grade plutonium, not fuel-grade 

plutonium. As a result, we are concerned about the implications of this 

option on the design and safety of the MFFF. We are also concerned about 

the extent to which DOE has adequately determined how much additional 

material might be available throughout the DOE complex for use as an 

alterative source of feedstock for the MFFF. To address these concerns, 

we revised our conclusions and expanded our original recommendation to 

ensure that NNSA establishes a plan to more clearly explain its strategy for 

mitigating the likely shortfall in plutonium oxide feedstock for the MFFF 

prior to the start of pit disassembly operations. 

DOE’s written comments are reprinted in appendix VI, and NRC’s written 

comments are reprinted in appendix VII. In addition, DOE and NRC 

provided detailed technical comments, which we incorporated as 

appropriate. 

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Energy, the Administrator of NNSA, and 

other interested parties. We will also make copies available at no charge 

on GAO’s Web site at http://www.gao.gov. 

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

me at (202) 512-3841 or aloisee@gao.gov. Contact points for our Offices of 

Page 41 GAO-10-378 Nuclear Nonproliferation
 

Congressional Relations and Public Affairs may be found on the last page 

Gene Aloise 

of this report. Key contributors to this report are listed in appendix VIII. 

Director, Natural Resources and Environment 

Page 42 GAO-10-378 Nuclear Nonproliferation
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To assess the performance status of the MOX Fuel Fabrication Facility 

(MFFF) and the Waste Solidification Building (WSB) construction projects 

regarding cost and schedule, we requested and analyzed earned value 

management (EVM) data contained in the projects’ monthly reports and 

variance reports, as well as EVM data for the MFFF project contained in 

Excel spreadsheets. We assessed the adequacy of the MFFF project’s use 

of EVM reporting by using a set of analysis tasks developed by GAO. In 

addition, we assessed the reliability of the EVM data by evaluating each 

project’s schedule against GAO’s scheduling best practices.1

 We have 

previously identified nine key practices necessary for developing a reliable 

schedule. These practices are (1) capturing all activities, (2) sequencing 

activities, (3) establishing the duration of activities, (4) assigning 

resources to activities, (5) integrating activities horizontally and vertically, 

(6) establishing the critical path for activities, (7) identifying the float time 

between activities, (8) performing a schedule risk analysis, and (9) 

monitoring and updating the schedule. To assist us in these efforts, we 

contracted with Technomics, Inc., to perform an in-depth analysis of data 

used in the MFFF’s integrated master schedule and the WSB’s current 

schedule. For the MFFF project, we also conducted a review of the 

project’s schedule risk analysis, which was performed during the summer 

of 2009. We also interviewed officials from the Department of Energy’s 

(DOE) National Nuclear Security Administration (NNSA) and MOX 

Services regarding their use of EVM data, scheduling practices, and 

schedule risk analyses for the two projects. Finally, we conducted tours of 

the MFFF construction project at DOE’s Savannah River Site (SRS), and 

met officials from the MFFF’s contractor, MOX Services, Inc.; and DOE’s 

NNSA and Office of Engineering and Construction Management (OECM). 

To assess the status of NNSA’s plan to establish a pit disassembly and 

conversion capability to supply plutonium to the MFFF, we reviewed 

documentation provided by NNSA and its contractors for the Pit 

Disassembly and Conversion Facility (PDCF), Plutonium Preparation 

Project, K-Area Complex, and MFFF projects, including project execution 

plans, project status reports, EVM data, and independent project reviews. 

We also requested information from NNSA on risks associated with the 

development of technology used in pit disassembly and conversion. We 

analyzed these risks using DOE guidance on assessing technology 

 

1

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

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

Page 43 GAO-10-378 Nuclear Nonproliferation 
Appendix I: Scope and Methodology 

readiness.2 We also reviewed project plans, testing and development data, 

and feasibility studies related to the Advanced Recovery and Integrated 

Extraction System (ARIES) project. We also toured the ARIES facility at 

DOE’s Los Alamos National Laboratory (LANL) in New Mexico and 

interviewed officials involved in the project. 

To assess the status NNSA’s plans to obtain customers for mixed-oxide 

(MOX) fuel from the MFFF, we reviewed project documents, including 

interest requests communicated to utilities, descriptions of possible 

incentives for participating in the MOX program, and analyses on the 

expected return to the government from the sale of MOX fuel. We also 

interviewed officials from NNSA and the Tennessee Valley Authority 

(TVA) on current efforts to secure TVA as a customer for MOX fuel, as 

well as officials from Duke on factors that caused the utility to end its 

agreement with NNSA’s contractor to purchase MOX fuel. To further 

identify factors affecting utilities’ interest in the MOX fuel program, we 

conducted structured telephone interviews of U.S. nuclear utilities. We 

chose to interview fuel procurement officers because they would be the 

most knowledgeable respondents about factors affecting fuel purchasing 

decisions, including considerations for MOX fuel. We asked fuel 

procurement officers to provide information on their currents interest in 

MOX fuel, important factors in the consideration of using MOX fuel, and 

possible incentives for the adoption of MOX fuel. To develop the 

structured interview questionnaire, GAO social science survey specialists 

and GAO staff developed a draft of the questionnaire on the basis of 

survey design principles and information obtained in interviews with DOE 

and nuclear utility officials. The draft questionnaire underwent a blind 

review by an additional social science survey specialist and was edited to 

ensure consistency among questions and clearly defined terms. The 

revised draft questionnaire was then pretested on three respondents, all of 

whom were familiar with the nuclear fuel procurement process. During 

the pretests, respondents were asked about their understanding of the 

questions, how they would approach constructing their answers, and any 

editorial concerns. The draft questionnaire underwent a final revision 

before being used to conduct the structured telephone interviews. 

Structured interviews were completed by fuel procurement officials from 

22 of the 26 nuclear utilities in the United States, for an overall response 

 

2

DOE, Office of Environmental Management, Technology Readiness Assessment (TRA)/ 

Technology Maturation Plan (TMP) Process Guide (Washington, D.C.:) March 2008. 

Page 44 GAO-10-378 Nuclear Nonproliferation
Appendix I: Scope and Methodology 

rate of 85 percent. All of the interviews were conducted during September 

and October, 2009. Respondents were contacted in advance to schedule a 

time to complete the interview. One of the 22 responding utilities elected 

not to answer three of the interview questions, but the other 21 completed 

the entire questionnaire. Data from the interviews were recorded and 

entered by the interviewer. A social science analyst performed a 100 

percent check of that data entry by comparing them with their 

corresponding questionnaires, to ensure that there were no errors. 

To examine the actions that NRC and DOE have taken to provide 

independent nuclear safety oversight of the MFFF and WSB construction 

projects, we reviewed oversight documentation and reports and 

interviewed oversight officials from both agencies. In relation to NRC’s 

oversight activities, we examined documents related to NRC’s approval of 

the MFFF’s construction authorization request; information requests 

submitted by NRC to MOX Services in support of NRC’s ongoing review of 

the facility’s operating license application; and technical analyses 

conducted by Brookhaven National Laboratory on behalf of NRC 

examining the likelihood of a red oil excursion at the facility. We also 

reviewed documents related to NRC’s construction inspection program, 

including inspection guidance and procedures, inspection reports, periodic 

assessments of MOX Services’ performance, and MOX Services’ responses 

to inspection findings. We also interviewed officials from the Nuclear 

Regulatory Commission’s Office of Nuclear Materials Safety and 

Safeguards and the Region II Division of Construction Projects. In relation 

to DOE’s inspection activities, we reviewed DOE project management and 

nuclear safety oversight guidance, protocols for conducing facility 

inspections, inspection reports, and records of decision related to reviews 

conducted by DOE’s Office of Health, Safety, and Security (HSS) and the 

Chief of Defense Nuclear Safety. We also reviewed reports by the Defense 

Nuclear Facilities Safety Board on DOE oversight and interviewed Safety 

Board officials. We interviewed officials from NNSA’s Office of Fissile 

Materials Disposition, HSS’s Office of Independent Oversight, and the 

Chief of Defense Nuclear Safety. 

We conducted this performance audit from January 2009 to March 2010, 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. 

Page 45 GAO-10-378 Nuclear Nonproliferation
Appendix II: Extent to Which the MFFF 

Project’s Schedule Used Key Practices 

Practice Explanation Rating GAO analysis 

Capturing all activities The schedule should reflect all activities as defined in the 

program’s work breakdown structure, including activities to 

be performed by both the government and its contractors. 

Fully The project has provided evidence 

that the schedule reflects both 

government and contractor activities, 

such as the building and testing of 

software components, as well as key 

milestones for measuring progress. 

Sequencing activities The schedule should be planned so that it can meet critical 

program dates. To meet this objective, activities need to be 

logically sequenced in the order that they are to be carried 

out. In particular, activities that must finish prior to the start 

of other activities (i.e., predecessor activities), as well as 

activities that cannot begin until other activities are 

completed (i.e., successor activities), should be identified. 

By doing so, interdependencies among activities that 

collectively lead to the accomplishment of events or 

milestones can be established and used as a basis for 

guiding work and measuring progress. The schedule should 

avoid logic overrides and artificial constraint dates that are 

chosen to create a certain result. 

Fully Of the approximately 22,000 normal 

activities, all are logically 

sequenced—that is, the schedule 

identifies interdependencies among 

work activities that form the basis for 

guiding work and measuring 

progress. 

Establishing the 

duration of activities 

The schedule should realistically reflect how long each 

activity will take to execute. In determining the duration of 

each activity, the same rationale, historical data, and 

assumptions used for cost estimating should be used. 

Durations should be as short as possible and have specific 

start and end dates. In particular, durations of longer than 

200 days should be minimized. 

Mostly Of the 22,000 normal activities, only 

569 have durations of over 200 

days. In addition, the schedule 

includes 38 activities with a 

remaining duration over 500 days 

and 10 activities with remaining 

duration over 1,000 days (3.9 years).

Assigning resources to 

activities 

The schedule should reflect what resources (e.g., labor, 

material, and overhead) are needed to do the work, whether 

all required resources will be available when needed, and 

whether any funding or time constraints exist. 

Mostly Of the 22,000 normal activities, 

resources are placed on 3,124 of 

these, and 13,988 of these have no 

resources. However, the program 

does have all resources captured in 

an alternate software package. 

According to DOE, the current 

baseline reflects $2.2 billion. 

Integrating activities 

horizontally and 

vertically 

The schedule should be horizontally integrated, meaning 

that it should link the products and outcomes associated 

with other sequenced activities. These links are commonly 

referred to as “handoffs” and serve to verify that activities 

are arranged in the right order to achieve aggregated 

products or outcomes. The schedule should also be 

vertically integrated, meaning that traceability exists among 

varying levels of activities and supporting tasks and 

subtasks. Such mapping or alignment among levels enables 

different groups to work to the same master schedule. 

Mostly Due to concerns about total float 

values discussed below in 

“identifying float between activities,” 

the schedule has not fully integrated 

key activities horizontally. The 

schedule has sufficiently integrated 

key activities vertically. 

Appendix II: Extent to Which the MFFF 

Project’s Schedule Used Key Practices 

Page 46 GAO-10-378 Nuclear Nonproliferation 
Appendix II: Extent to Which the MFFF 

Project’s Schedule Used Key Practices 

Practice Explanation Rating GAO analysis 

Establishing the 

critical path for 

activities 

Using scheduling software, the critical path—the longest 

duration path through the sequenced list of key activities—

should be identified. The establishment of a program’s 

critical path is necessary for examining the effects of any 

activity slipping along this path. Potential problems that 

might occur along or near the critical path should also be 

identified and reflected in the scheduling of the time for highrisk activities. 

Fully The project has established a 

number of critical paths by using the 

scheduling software to identify 

activities with low or zero float, as 

well as by identifying high-risk 

activities. Project officials said that 

they conduct weekly meetings to 

keep track of critical path activities. 

Identifying the “float 

time” between 

activities 

The schedule should identify float time—the time that a 

predecessor activity can slip before the delay affects 

successor activities—so that schedule flexibility can be 

determined. As a general rule, activities along the critical 

path typically have the least amount of float time. Total float 

time is the amount of time flexibility an activity has that will 

not delay the project’s completion (if everything else goes 

according to plan). Total float that exceeds a year is 

unrealistic and should be minimized. 

Partially The schedule contains 8,600 

activities with total float exceeding 

400 days (1.5 years) and 669 

activities with total float exceeding 

1,000 days (3.9 years). Many of the 

activities with large total float values 

are tied to completion milestones, 

rather than to an intermediate 

successor. 

Performing a schedule 

risk analysis 

A schedule risk analysis should be performed using 

statistical techniques to predict the level of confidence in 

meeting a program’s completion date. This analysis focuses 

not only on critical path activities but also on activities near 

the critical path, since they can potentially affect program 

status. 

Fully Project officials conducted a 

schedule risk analysis during the 

summer of 2009. This analysis was 

performed using statistical 

techniques and focused on critical 

path and near-the-critical-path 

activities. Officials said that this 

analysis has provided important 

overall project risk information to 

management. 

Monitoring and 

updating the schedule 

The schedule should be continually monitored to determine 

when forecasted completion dates differ from the planned 

dates, which can be used to determine whether schedule 

variances will affect downstream work. Individuals trained in 

critical path method scheduling should be responsible for 

ensuring that the schedule is properly updated. Maintaining 

the integrity of the schedule logic is not only necessary to 

reflect true status, but is also required before conducting a 

schedule risk analysis. 

Fully Project officials said that they update 

the schedule on a weekly basis. In 

particular, project controls staff are 

associated with each engineering 

group and provide a status update 

on a weekly basis. 

Sources: Shaw AREVA MOX Services, LLC (data); GAO (analysis). 

Note: The ratings we used in this analysis are as follows: Based on the documentation provided, 

"fully" means that the project fully satisfied the criterion; “mostly” means that the project satisfied the 

criterion to a large extent; “partially” means that the project satisfied the criterion in part; “minimally” 

means that the project satisfied the criterion to a minimal extent; and “not” means that the project did 

not satisfy the criterion. 

Page 47 GAO-10-378 Nuclear Nonproliferation
Appendix III: Extent to Which the WSB 

Project’s Schedule Used Key Practices 

Practice Explanation Rating GAO analysis 

Capturing all activities The schedule should reflect all activities as defined in the 

program’s work breakdown structure, including activities to 

be performed by both the government and its contractors. 

Fully The project’s schedule reflects both 

government and contractor activities, 

such as the building and testing of 

cementation equipment, as well as 

key milestones for measuring 

progress. 

Sequencing activities The schedule should be planned so that it can meet critical 

program dates. To meet this objective, activities need to be 

logically sequenced in the order that they are to be carried 

out. In particular, activities that must finish prior to the start of 

other activities (i.e., predecessor activities), as well as 

activities that cannot begin until other activities are 

completed (i.e., successor activities), should be identified. By 

doing so, interdependencies among activities that collectively 

lead to the accomplishment of events or milestones can be 

established and used as a basis for guiding work and 

measuring progress. The schedule should avoid logic 

overrides and artificial constraint dates that are chosen to 

create a certain result. 

Mostly Of 2,066 activities that are currently 

in progress or have not yet started, 

80 are not logically sequenced—that 

is, the schedule does not identify 

interdependencies among work 

activities that form the basis for 

guiding work and measuring 

progress. 

Establishing the 

duration of activities 

The schedule should realistically reflect how long each 

activity will take to execute. In determining the duration of 

each activity, the same rationale, historical data, and 

assumptions used for cost estimating should be used. 

Durations should be as short as possible and have specific 

start and end dates. In particular, durations of longer than 

200 days should be minimized. 

Mostly Ninety-eight of the 2,066 activities 

that are currently in progress or have 

not yet started have durations of 100 

days or more. While durations should 

be as short as possible and have 

specific start and end dates to 

objectively measure progress, 

project officials provided a valid 

rationale for the duration of these 

activities. 

Assigning resources to 

activities 

The schedule should reflect what resources (e.g., labor, 

material, and overhead) are needed to do the work, whether 

all required resources will be available when needed, and 

whether any funding or time constraints exist. 

Fully The schedule reflects $336 million in 

resource costs. The project’s cost 

baseline is $344 million. According to 

project officials, they are aware of 

this discrepancy. They stated that 

while all of the project resources are 

reflected in the schedule, a software 

problem has caused some of these 

resources to not show up. Project 

officials are working to correct this 

software problem. 

Appendix III: Extent to Which the WSB 

Project’s Schedule Used Key Practices 

Page 48 GAO-10-378 Nuclear Nonproliferation 
Appendix III: Extent to Which the WSB 

Project’s Schedule Used Key Practices 

Practice Explanation Rating GAO analysis 

Integrating activities 

horizontally and 

vertically 

The schedule should be horizontally integrated, meaning that 

it should link the products and outcomes associated with 

other sequenced activities. These links are commonly 

referred to as “handoffs” and serve to verify that activities are 

arranged in the right order to achieve aggregated products or 

outcomes. The schedule should also be vertically integrated, 

meaning that traceability exists among varying levels of 

activities and supporting tasks and subtasks. Such mapping 

or alignment among levels enables different groups to work 

to the same master schedule. 

Fully Project officials provided evidence 

that the schedule is sufficiently 

integrated. 

Establishing the critical 

path for activities 

Using scheduling software, the critical path—the longest 

duration path through the sequenced list of key activities—

should be identified. The establishment of a program’s critical 

path is necessary for examining the effects of any activity 

slipping along this path. Potential problems that might occur 

along or near the critical path should also be identified and 

reflected in the scheduling of the time for high-risk activities. 

Fully A critical path has been established. 

The critical path dates are driven by 

the logic of the schedule. 

Identifying the “float 

time” between 

activities 

The schedule should identify float time—the time that a 

predecessor activity can slip before the delay affects 

successor activities—so that schedule flexibility can be 

determined. As a general rule, activities along the critical 

path typically have the least amount of float time. Total float 

time is the amount of time flexibility an activity has that will 

not delay the project’s completion (if everything else goes 

according to plan). Total float that exceeds a year is 

unrealistic and should be minimized. 

Mostly The schedule contains 1,482 

activities that have a float time of 

over 100 days. However, project 

officials provided a valid rationale for 

having activities with large float 

times. 

Performing a schedule 

risk analysis 

A schedule risk analysis should be performed using 

statistical techniques to predict the level of confidence in 

meeting a program’s completion date. This analysis focuses 

not only on critical path activities but also on activities near 

the critical path, since they can potentially affect program 

status. 

Fully Project officials stated that they 

conducted a schedule risk analysis 

using statistical techniques in July 

2008 on the baseline schedule. 

Monitoring and 

updating the schedule 

The schedule should be continually monitored to determine 

when forecasted completion dates differ from the planned 

dates, which can be used to determine whether schedule 

variances will affect downstream work. Individuals trained in 

critical path method scheduling should be responsible for 

ensuring that the schedule is properly updated. Maintaining 

the integrity of the schedule logic is not only necessary to 

reflect true status, but is also required before conducting a 

schedule risk analysis. 

Fully Project officials conduct weekly 

meetings to review and update the 

project schedule. 

Sources: NNSA (data); GAO (analysis). 

Note: The ratings we used in this analysis are as follows: Based on the documentation provided, 

"fully" means that the project fully satisfied the criterion; “mostly” means that the project satisfied the 

criterion to a large extent; “partially” means that the project satisfied the criterion in part; “minimally” 

means that the project satisfied the criterion to a minimal extent; and “not” means that the project did 

not satisfy the criterion. 

Page 49 GAO-10-378 Nuclear Nonproliferation
Appendix IV: Summary Results of Interviews Appendix IV: Summary Results of Interviews with 22 Utilities 

with 22 Utilities 

1. How much information have you heard or read about DOE’s MOX fuel program? 

Response Frequency

A great deal of information 1

Some information 5

Very little information 11

No information 5

2. Does your utility own any reactors that are compatible with AREVA fuel designs? 

Response Frequency

No 2

Yes 19

Note: The numbers in the table do not total to 22 because one utility elected not to respond to this 

question. 

3. Taking into account your current reactor fleet, what is your utility’s current level of 

interest in participating in the MOX fuel program? (Choose One) 

Response Frequency

Not at all interested 2

Not very Interested 10

Somewhat interested 8

Very interested 1

Extremely interested 1

4. What kinds of reactors owned by your utility do you think would be the most likely 

candidates for MOX fuel if your utility decided to participate in the MOX fuel program? 

Please choose only one answer. 

Response Frequency

BWR only 2

PWR only 13

Both 7

Page 50 GAO-10-378 Nuclear Nonproliferation 
Appendix IV: Summary Results of Interviews 

with 22 Utilities 

5. How important is this factor in your assessment of your utility’s current level of interest 

in participating in the MOX fuel program? 

Response Frequency

Somewhat important 3

Very important 9

Extremely important 10

6. If DOE would sell MOX fuel to your utility at a 15% discounted price relative to the 

market price for uranium fuel, what do you think your utility’s level of interest in 

participating in the MOX program would be? 

Response Frequency

Not at all interested 2

Not very Interested 7

Somewhat interested 8

Very interested 5

7. If DOE would sell MOX fuel to your utility at a 25% discounted price relative to the 

market price for uranium fuel, what do you think your utility’s level of interest in 

participating in the MOX program would be? 

Response Frequency

Not at all interested 2

Not very Interested 4

Somewhat interested 8

Very interested 4

Extremely interested 4

8. How important is this factor in your assessment of your utility’s current level of interest 

in participating in the MOX fuel program? 

Response Frequency

Somewhat important 5

Very important 5

Extremely important 12

Page 51 GAO-10-378 Nuclear Nonproliferation
Appendix IV: Summary Results of Interviews 

with 22 Utilities 

9. If DOE would cover the costs associated with reactor modifications for compatibility with 

MOX fuel, what do you think your utility’s level of interest in participating in the MOX 

program would be? 

Response Frequency

Not very interested 2

Somewhat interested 11

Very interested 6

Extremely interested 3

10. How important are the costs associated with NRC licensing requirements, in terms of 

monetary outlays and staff time, to your utility’s current level of interest in participating in 

the MOX fuel program? 

Response Frequency

Not very important 2

Somewhat important 5

Very important 7

Extremely important 8

11. If DOE would cover the costs associated with obtaining NRC licenses, what do you 

think your utility’s level of interest in participating in the MOX program would be? 

Response Frequency

Not at all interested 1

Not very interested 2

Somewhat interested 9

Very interested 8

Extremely interested 2

12. Another factor that may affect your level of interest is the ability to test the quality and 

safety of MOX fuel at your reactor. How important is this factor in your assessment of your 

utility’s current level of interest in participating in the MOX fuel program? 

Response Frequency

Not very important 1

Somewhat important 2

Very important 4

Extremely important 15

Page 52 GAO-10-378 Nuclear Nonproliferation
Appendix IV: Summary Results of Interviews 

with 22 Utilities 

13. If DOE offered to fund a demonstration program of MOX fuel at your reactor, what do 

you think your utility’s level of interest in participating in the MOX program would be? 

Response Frequency

Not at all interested 2

Not very interested 5

Somewhat interested 5

Very interested 6

Extremely interested 3

Note: The numbers in the table do not total to 22 because one utility elected not to respond to this 

question. 

14. Another factor that may affect your level of interest is DOE’s ability to ensure the 

timely delivery of MOX fuel (i.e. – Delivery occurs at an interval that meets a reactor’s 

needed timeline to prepare prior to a refueling outage). How important is this factor in your 

assessment of your utility’s current level of interest in participating in the MOX fuel 

program? 

Response Frequency

Not very important 1

Somewhat important 1

Very important 3

Extremely important 17

15. Another factor that may affect your level of interest is DOE’s ability to provide a 

compatible backup supply of uranium fuel as assurance in case of delays in the delivery of 

MOX fuel. How important is this factor in your assessment of your utility’s current level of 

interest in participating in the MOX fuel program? 

Response Frequency

Not very important 1

Somewhat important 2

Very important 8

Extremely important 11

Page 53 GAO-10-378 Nuclear Nonproliferation
Appendix IV: Summary Results of Interviews 

with 22 Utilities 

16. Another factor that may affect your level of interest is the storage of MOX fuel at your 

reactor site for longer than the interval that meets a reactor’s needed timeline prior to a 

refueling outage. How important is this factor in your assessment of your utility’s current 

level of interest in participating in the MOX fuel program? 

Response Frequency

Not at all important 2

Not very important 3

Somewhat important 10

Very important 4

Extremely important 3

17. Another factor that may affect your level of interest is public opinion regarding the use 

of MOX fuel. How important is this factor in your assessment of your utility’s current level 

of interest in participating in the MOX fuel program? 

Response Frequency

Not at all important 1

Not very important 1

Somewhat important 6

Very important 9

Extremely important 5

18. DOE’s MOX fuel program relies on annual Congressional appropriations. Another 

factor that may affect your level of interest is the consistency of funding for the program 

through 2033. How important is this factor in your assessment of your utility’s current level 

of interest in participating in the MOX fuel program? 

Response Frequency

Somewhat important 2

Very important 8

Extremely important 12

Page 54 GAO-10-378 Nuclear Nonproliferation
Appendix IV: Summary Results of Interviews 

with 22 Utilities 

19. In addition to the factors described above, are there any other factors or issues that 

we have not discussed that affected your assessment of your utility’s current interest in 

participating in the MOX fuel program? 

Open ended responses are not presented in this appendix. 

20. How interested in participating do you think your utility would have to be to actually 

submit such an expression of interest? 

Response Frequency

Somewhat interested 5

Very interested 10

Extremely interested 6

Note: The numbers in the table do not total to 22 because one utility elected not to respond to this 

question. 

21. The MOX Fuel Fabrication Facility is expected to begin delivery of MOX fuel in 2018 

and continue supplying fuel through 2032. How confident are you in DOE’s ability to 

deliver MOX fuel on time throughout this period? 

Response Frequency

Not at all confident 3

Not very confident 11

Somewhat confident 8

22. How confident are you in DOE’s ability to ensure that a compatible backup supply of 

uranium fuel is delivered on time in the case of MOX fuel delays? 

Response Frequency

Not very confident 4

Somewhat confident 15

Very confident 2

Extremely confident 1

Page 55 GAO-10-378 Nuclear Nonproliferation
Appendix IV: Summary Results of Interviews 

with 22 Utilities 

23. How satisfied are you with the amount of outreach that MOX Services and DOE have 

used to obtain interest in the MOX fuel program? 

Response Frequency

Very dissatisfied 1

Somewhat dissatisfied 3

Neither satisfied nor dissatisfied 14

Somewhat satisfied 3

Very satisfied 1

Page 56 GAO-10-378 Nuclear Nonproliferation
Appendix V: Nuclear Regulatory Commission’s 

Notices of Violation for the MFFF 

NRC report date Description of violation Outcome 

October 30, 2009 MOX Services failed to ensure that design 

considerations were considered during installation of 

structures. 

To be determined. 

October 30, 2009 MOX Services’ design control procedures did not 

require that the method of design verification, or the 

results, be adequately documented when design 

verifications were performed. 

To be determined. 

October 30, 2009 MOX Services failed to provide a technical justification 

for an engineering change request. 

To be determined. 

October 30, 2009 MOX Services failed to include a sequential 

description of work to be performed in implementing 

documents. 

To be determined. 

September 11, 2009 MOX Services failed to promptly identify, evaluate, 

correct, and document conditions adverse to quality, 

including incorrect placement of a floor and failure to 

document a rebar deficiency in the corrective action 

program. 

MOX Services conducted a root cause analysis for the 

conditions that led to each of the findings in NRC’s 

September 11, 2009, inspection report and instituted 

actions, including improving communications between 

engineering, construction, and quality control 

personnel; adopting checklists for changes; and 

adding additional training for engineering personnel. 

NRC stated that the actions appeared adequate, and 

that it will verify implementation during later 

inspections. 

September 11, 2009 MOX Services failed to perform quality-affecting 

activities in accordance with approved drawings and 

specifications. 

MOX Services conducted a root cause analysis for the 

conditions that led to each of the findings in NRC’s 

September 11, 2009, inspection report and instituted 

actions, including improving communications between 

engineering, construction, and quality control 

personnel; adopting checklists for changes; and 

adding additional training for engineering personnel. 

NRC stated that the actions appeared adequate, and 

that it will verify implementation during later 

inspections. 

September 11, 2009 MOX Services failed to provide and adequate 

documented justification for changes to final designs. 

MOX Services conducted a root cause analysis for the 

conditions that led to each of the findings in NRC’s 

September 11, 2009, inspection report and instituted 

actions, including improving communications between 

engineering, construction, and quality control 

personnel; adopting checklists for changes; and 

adding additional training for engineering personnel. 

NRC stated that the actions appeared adequate, and 

that it will verify implementation during later 

inspections. 

July 30, 2009 MOX Services failed to correctly translate applicable 

requirements into design documents. 

MOX Services initiated corrective actions to address 

these issues. 

Appendix V: Nuclear Regulatory 

Commission’s Notices of Violation for the 

MFFF 

Page 57 GAO-10-378 Nuclear Nonproliferation 
Appendix V: Nuclear Regulatory Commission’s 

Notices of Violation for the MFFF 

NRC report date Description of violation Outcome 

May 11, 2009 Suppliers were found to fail to meet a basic NQA-1 

requirement, indicating that MOX Services failed to 

ensure that services were controlled to ensure 

conformance with specified technical and QA 

requirements. 

NRC determined that MOX Services’ oversight of its 

contractors was acceptable, despite numerous 

examples of failures to meet the QA requirements. 

January 30, 2009 Testing documentation for two separate tests did not 

include the required information. 

MOX Services revised documentation procedure to 

include the necessary information. 

January 30, 2009 On two separate occasions, the contractor failed to 

incorporate an approved design change in project 

documents, and later did not verify a field drawing, 

which resulted in failure to identify that the drawing did 

not implement design requirements. 

MOX Services took steps to ensure that 

documentation was appropriately revised, and added 

the design change into the corrective action plan to 

initiate correction before concrete placement. 

October 30, 2008 NRC found that some design reviews did not ensure 

that design inputs were correctly incorporated into field 

drawings. 

MOX Services revised the design drawings to match 

the as-built drawings after completing an analysis of 

the structure. 

July 29, 2008 Contractor failed to identify certain conditions adverse 

to quality assurance plan requirements, including 

those related to incorrectly poured concrete. 

MOX Services placed the matter into its corrective 

action program and took steps to ensure adequate 

pouring of concrete. 

April 30, 2008 Contractor failed to take corrective action for 

conditions adverse to quality, including providing 

adequate resolution to justify the use of reinforcing 

steel splices that did not meet industry standards. 

NRC reviewers concluded that MOX Services 

implemented appropriate actions to control purchase 

of items from the reinforcing bar vendor. 

April 30, 2008 Contractor failed to ensure that numerous pieces of 

reinforcing bar met industry standards for bend radius. 

NRC reviewers concluded that MOX Services 

implemented appropriate actions to control purchase 

of items from the reinforcing bar vendor. 

October 30, 2007 NRC found that MOX Services had not followed 

quality insurance procedures, including, for example, 

ensuring that a vendor provided clear instructions for 

operating a concrete batch plant, which resulted in 

improperly mixed concrete. 

MOX Services took over concrete testing and took 

corrective actions, including revising procedures and 

bringing in independent experts to make 

recommendations for improvement. 

Source: NRC. 

Page 58 GAO-10-378 Nuclear Nonproliferation
Appendix VI: Comments from the Department Appendix VI: Comments from the of Energy 

Department of Energy 

Page 59 GAO-10-378 Nuclear Nonproliferation 
Appendix VI: Comments from the Department 

of Energy 

Page 60 GAO-10-378 Nuclear Nonproliferation
Appendix VI: Comments from the Department 

of Energy 

Page 61 GAO-10-378 Nuclear Nonproliferation
Appendix VI: Comments from the Department 

of Energy 

Page 62 GAO-10-378 Nuclear Nonproliferation
Appendix VII: Comments from the Nuclear Appendix VII: Comments from the Nuclear Regulatory Commission 

Regulatory Commission 

Page 63 GAO-10-378 Nuclear Nonproliferation 
Appendix VIII: GAO Contact and Staff Appendix VIII: GAO Contact and Staff Acknowledgments 

Acknowledgments 

Gene Aloise, (202) 512-3841 or aloisee@gao.gov

In addition to the individual named above, Daniel Feehan, Assistant 

Director; Steve Carter; Antoinette Capaccio; Tisha Derricotte; Jennifer 

Echard; Jason Holliday; and Ben Shouse made key contributions to this 

report. 

Page 64 GAO-10-378 Nuclear Nonproliferation

GAO Contact 

Staff 

Acknowledgments 

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