RECOVERY ACT

Most DOE Cleanup 

Projects Are 

Complete, but Project 

Management 

Guidance Could Be 

Strengthened

Report to Congressional Committees

October 2012

GAO-13-23

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-23, a report to 

congressional committees

October 2012

RECOVERY ACT

Most DOE Cleanup Projects Are Complete, but 

Project Management Guidance Could Be 

Strengthened 

Why GAO Did This Study

The Recovery Act aimed to stimulate 

the economy and create jobs. DOE 

received $6 billion in Recovery Act 

funds that it is using to clean up 17 

sites contaminated by radioactive and 

hazardous wastes from decades of 

nuclear research and weapons 

production. The cleanup is primarily 

carried out by contractors. The 

National Defense Authorization Act for 

Fiscal Year 2010 requires GAO to 

periodically report on DOE’s Recovery 

Act-funded EM cleanup projects. In 

response to this mandate, GAO 

examined (1) the number of Recovery 

Act-funded FTEs by quarter; (2) the 

status and performance of cleanup 

projects; and (3) project management 

issues, if any, that arose during project 

implementation and any lessons 

learned. In addition, the Recovery Act 

requires GAO to comment and report 

quarterly on estimates of jobs funded 

and counted as measured by the 

number of FTEs and to conduct 

bimonthly reviews on the use of the 

act’s funds. GAO examined Recovery 

Act FTEs, spending, project 

performance data, and lessons learned 

from Recovery Act projects; and 

interviewed DOE and contractor 

officials.

What GAO Recommends

GAO recommends, among other 

things, that DOE (1) clarify guidance 

on developing and documenting 

project performance baselines and (2) 

issue a policy that sets out the criteria 

with greater specificity for reclassifying 

capital asset projects over $10 million 

into smaller operation activity projects 

under $10 million. DOE agreed with 

GAO’s recommendations.

What GAO Found

From October 2009 through March 2012, the number of full-time equivalent 

(FTE) employees funded by the American Recovery and Reinvestment Act of 

2009 (Recovery Act) and working on Department of Energy’s (DOE) Office of 

Environmental Management (EM) cleanup projects peaked at about 11,000 FTEs 

in the quarter ending September 2010, according to data on the federal 

government’s Recovery Act website. By the second quarter of fiscal year 2012, 

as projects were completed, FTEs had decreased to about 1,400 FTEs; 12 of 17 

sites reported no Recovery Act FTEs; and about $5.6 billion of a total $6 billion in 

Recovery Act funds had been spent.

According to EM data, as of April 30, 2012, 78 of the 112 Recovery Act-funded 

cleanup projects were complete, and 72 of the 78 projects met DOE’s 

performance standard of completing project work scope without exceeding the 

cost target by more than 10 percent. According to EM officials, the completed 

Recovery Act projects have helped accelerate the cleanup at the sites. GAO, 

however, found several inconsistencies in how EM set and documented projects’ 

scope, cost, and schedule targets. Without clear scope, cost, or schedule targets 

in performance baselines, it becomes difficult to assess project performance. For 

example, in some cases, EM set scope targets differently in different documents 

and claimed project success even if key performance parameters were not 

achieved. Current guidance on setting performance baselines is more 

comprehensive for capital asset projects, such as building or demolishing 

facilities or constructing remediation systems, than for projects known as 

operation activity projects, such as operating a groundwater treatment plant. In 

addition, capital asset projects costing under $10 million are classified as 

operation activity projects.

Some of EM’s long-standing project management problems occurred during its 

implementation of several Recovery Act projects, primarily insufficient early 

planning before setting performance baselines. For example, a project to remove 

wastes from a landfill at one site exceeded its $111 million cost target by $20 

million because, after beginning the project, officials determined that the site 

would need to be excavated to a depth of almost double that planned. In 

addition, EM’s new initiative to reclassify projects as either capital asset or 

operation activity projects raised concerns about how projects were reclassified. 

EM does not have a clear policy that sets out under what conditions and how EM 

should break a capital asset project into smaller, discrete operation activity 

projects. Project classification is important, however, because some 

requirements apply only to capital asset projects. EM’s guidance for projects 

classified as operation activity projects under this initiative states that certain 

approval and reporting requirements will not be applied, and others will be 

applied as appropriate. Some DOE and other officials expressed concern that 

projects could be broken into smaller projects to avoid the requirements. For 

example, a $30 million project, partially funded with Recovery Act funds, was 

divided into 18 smaller projects, each below the $10 million threshold. The cost 

for one of these smaller projects eventually doubled—from $8 million to $16 

million—but was not reclassified as a capital asset project. EM has been 

gathering information on lessons learned from Recovery Act projects, some of 

which could be applied as corrective measures to other EM cleanup work.

View GAO-13-23. For more information, 

contact Mark Gaffigan at (202) 512-3841 or 

gaffiganm@gao.gov.
Page i GAO-13-23 DOE Recovery Act Cleanup Projects

Letter 1 

Background 4

EM Recovery Act-Funded Jobs Peaked at about 11,000 FTE 

Employees Late in Fiscal Year 2010 10

EM Has Completed Most Projects, but Inconsistent Data Make 

Assessing Project Performance Difficult 15

Project Management Problems Occurred on EM Recovery Act 

Projects, and EM Is Taking Steps to Identify Lessons Learned 24

Conclusions 34

Recommendations for Executive Action 35

Agency Comments and Our Evaluation 36

Appendix I Objectives, Scope and Methodology 40

Appendix II Administratively Completed Recovery Act Projects Available for 

GAO Analysis as of April 30, 2012 44

Appendix III Comments from the Department of Energy 47

Appendix IV GAO Contact and Staff Acknowledgments 51

Tables

Table 1: EM FTEs Funded by the Recovery Act in the Fourth 

Quarter of Fiscal Year 2010 and Second Quarter of Fiscal 

Year 2012 12

Table 2: EM’s Recovery Act Funds and Spending through Second 

Quarter of Fiscal Year 2012 14

Figures

Figure 1: The Amount of Recovery Act Funds Provided for Cleanup 

Projects at 17 Sites 5

Figure 2: Views Before and After the Demolition of Building K-33, 

East Tennessee Technology Park, Oak Ridge Reservation 7

Contents
Page ii GAO-13-23 DOE Recovery Act Cleanup Projects

Figure 3: Workers Packaging Transuranic Waste, Savannah River 

Site 7

Figure 4: FTEs Funded by the Recovery Act by Quarter, First 

Quarter Fiscal Year 2010 through Second Quarter Fiscal 

Year 2012 11

Figure 5: FTEs and Recovery Act Spending for EM Cleanup 

Projects, First Quarter of Fiscal Year 2010 through Second 

Quarter of Fiscal Year 2012 13

Figure 6: Percentages that the Projects’ Final Costs Are Over or 

Under their Targets for 78 Administratively Completed 

Recovery Act Projects, as of April 2012 17

Abbreviations

DOE Department of Energy

EM Office of Environmental Management

FTE full-time equivalent

IPABS Integrated Planning, Accountability, and Budgeting 

 System

OMB Office of Management and Budget

Recovery Act American Recovery and Reinvestment Act of 2009

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-23 DOE Recovery Act Cleanup Projects

United States Government Accountability Office

Washington, DC 20548

October 15, 2012

Congressional Committees

Since the 1940s, the Department of Energy (DOE) and its predecessor 

agencies have operated a nationwide complex of facilities used to 

research, design, and manufacture nuclear weapons and related 

technologies. Organizationally, DOE supports a wide range of activities 

managed by mission-based offices. These include the Office of 

Environmental Management (EM), which leads the department’s often 

complex and challenging program to clean up nuclear, chemical, and 

other hazardous wastes. EM carries out its work at numerous DOE sites 

and facilities around the country, and like other offices in DOE, EM carries 

out its work primarily through contractors that manage the facilities and 

work under contract to DOE. DOE has estimated that the total cost to 

clean up these sites could exceed $300 billion and take several decades. 

In addition to its annual appropriations, EM received $6 billion under the 

American Recovery and Reinvestment Act of 2009 (Recovery Act).1

The National Defense Authorization Act for Fiscal Year 2010 requires that 

GAO review and periodically report on EM’s efforts to carry out Recovery 

Act projects. As a result, we have been periodically providing—every 120 

days—information to EM’s authorizing and appropriating committees on 

The 

act is intended to promote economic recovery, make investments, and 

minimize or avert reductions in state and local government services. 

Enacted on February 17, 2009, the act directed that priority be given to 

projects that could be started quickly. The administration referred to such 

projects as “shovel-ready.” EM is using its $6 billion to expand and 

accelerate cleanup activities at 17 sites. EM set as one of its Recovery 

Act cleanup goals to reduce EM sites’ footprint of 931 total square miles 

by 40 percent (or 372 square miles) by the end of fiscal year 2011. EM 

defined this as remediating an area to meet all regulatory requirements. 

According to EM officials, EM met its footprint reduction goal in April 

2011, and had reduced its footprint by 70 percent by the end of April 

2012.

 

1

Pub. L. No. 111-5, 123 Stat. 115 (2009). EM also received about $6 billion to spend 

under its 2009 annual appropriation.

 
 

Page 2 GAO-13-23 DOE Recovery Act Cleanup Projects

the progress of these projects. This report primarily serves as a periodic 

update, as required by the mandate. In addition, the Recovery Act 

requires us to comment and report quarterly on estimates of jobs funded 

and counted as measured by the number of full-time equivalent (FTE) 

employees that were reported by recipients of Recovery Act funds2 and to 

conduct bimonthly reviews of how the act’s funds are used. This is one of 

a series of GAO reports that comment on recipient job estimates and 

reports on our reviews of the use of funds made available under the 

act.3,4

In response to these mandates, we examined (1) the number of FTEs 

that EM funded quarterly with Recovery Act funds from October 2009 

through March 2012; (2) the status of EM’s Recovery Act-funded cleanup 

projects and the extent to which completed projects met performance 

baselines (i.e., cost, schedule, and scope targets); and (3) project 

management issues, if any, that arose during the implementation of EM’s 

Recovery Act projects and any lessons EM has learned that it could apply 

to other cleanup efforts.

To conduct our work, we reviewed pertinent provisions of the American 

Recovery and Reinvestment Act of 2009; and Office of Management and 

Budget (OMB) and DOE policies, procedures, and guidance on Recovery 

Act implementation. To describe the number of FTEs that EM funded with 

Recovery Act monies, we examined data on FTEs—the units specified by 

OMB’s guidance for reporting Recovery Act jobs.5

 

2

Pub. L. No. 111-5 § 1512(e), 123 Stat. 115, 288. FTE data provide insight into the use 

and impact of the Recovery Act funds, but recipient reports cover only direct jobs funded 

by the Recovery Act. These reports do not include the employment impact on suppliers 

(indirect jobs) or on the local community (induced jobs). Both data reported by recipients 

and other macroeconomic data and methods are necessary to understand the overall 

employment effects of the Recovery Act.

To understand the 

3

See http://www.gao.gov/recovery for related GAO products.

4

In addition to conducting our analyses of EM Recovery Act cleanup projects, we 

continued, as in prior reports, to perform edit checks and analyses on all prime recipient 

reports to assess data logic and consistency and identify unusual or atypical data.

5

OMB Memorandum “Updated Implementing Guidance for the American Recovery and 

Reinvestment Act of 2009,” Apr. 3, 2009, called for cumulative FTE counts each calendar 

quarter for all reporting quarters. OMB, Memorandum, “Updated Guidance on the

American Recovery and Reinvestment Act – Data Quality, Non-Reporting Recipients, and 

Reporting of Job Estimates,” Dec.18, 2009 asked recipients of Recovery Act funding to 

report job estimates on a purely quarterly, rather than cumulative, basis.
 

Page 3 GAO-13-23 DOE Recovery Act Cleanup Projects

accuracy of FTE data, we discussed DOE’s review process with DOE and 

EM officials. To assess the status and performance of EM projects funded 

by the Recovery Act, we reviewed project documentation and analyzed 

information in EM’s database for managing Recovery Act projects. We 

analyzed the performance of projects that were administratively complete 

by the end of April 2012 (i.e., when an authorized official approves the 

projects’ closure, which occurs after completion of cleanup activities). To 

assess the reliability of the data that EM used to assess projects’ 

performance, we interviewed officials in EM’s Recovery Act program 

office about the Recovery Act data in the Integrated Planning, 

Accountability, and Budgeting System (IPABS) database—which EM 

uses to capture data for all Recovery Act projects—and found these data 

sufficiently reliable for purposes of this report. We also interviewed these 

officials to determine how EM evaluates these data to assess project 

performance and reviewed its performance analysis of completed 

projects. We interviewed officials in DOE’s Office of Project Management 

to discuss DOE’s project management policy and the assessment of 

project performance.6 We selected a nonprobability sample of two EM 

cleanup sites to visit in order to better understand how sites manage their 

Recovery Act projects.7

We conducted this performance audit from May 2011 to October 2012 in 

accordance with generally accepted government auditing standards. 

To examine project management issues that 

arose during the implementation of EM’s Recovery Act projects and any 

lessons EM has learned that it could apply to other cleanup efforts, we 

reviewed lessons learned that site officials had documented or reported 

and interviewed Recovery Act officials. We also reviewed DOE 

documents, such as DOE’s root cause analysis and corrective action 

plan, both of which identified the department’s and EM’s project 

management issues, to determine whether these issues also arose during 

Recovery Act projects. Appendix I presents a more detailed description of 

our objectives, scope, and methodology.

 

6

As the result of reorganization, effective May 2012, the responsibility for project 

management policy in DOE’s Office of Engineering and Construction Management was 

placed in the Office of Project Management, which is within the Office of Acquisitions and 

Project Management that is under the Office of Management. In this report, we refer only 

to the Office of Project Management. 

7

Because this was a nonprobability sample, the information derived from our site visits is 

not generalizeable to all EM cleanup sites but provides illustrative examples of how sites 

manage their Recovery Act projects.
 

Page 4 GAO-13-23 DOE Recovery Act Cleanup Projects

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.

EM selected projects at 17 DOE sites in 12 states for Recovery Act 

funding, with 4 sites receiving most of the money—the Hanford Site in 

Washington State, the Savannah River Site in South Carolina, the Oak 

Ridge Reservation in Tennessee, and the Idaho National Laboratory (see 

fig. 1). Recovery Act funds must be expended by the end of fiscal year 

2015, but EM initially planned to expend these funds and complete work 

by the end of fiscal year 2011. In developing these projects, EM 

establishes a baseline against which it measures project performance. 

This performance baseline includes targets for work scope, or key work 

activities that should be completed; cost; and schedule.

Background 
 

Page 5 GAO-13-23 DOE Recovery Act Cleanup Projects

Figure 1: The Amount of Recovery Act Funds Provided for Cleanup Projects at 17 Sites

The cleanup projects EM selected for Recovery Act funding fall into the 

following four major categories:

• Decontaminating and demolishing facilities. For example, EM used 

the funding to remove hazardous contamination and demolish the K33 building at the Oak Ridge Reservation, which was a two-level 

structure that covered 32 acres and was constructed in 1954 to 

process and enrich uranium for use in nuclear weapons. (See fig. 2.)
 

Page 6 GAO-13-23 DOE Recovery Act Cleanup Projects

• Removing contamination from soil and groundwater. For example, EM 

used the funding to remove and dispose of radioactive and hazardous 

contaminants from soil and groundwater at the Mound Site, a former 

production site for explosives and other weapons’ components.

• Packaging and disposing of transuranic and other wastes.

8 For 

example, EM used Recovery Act funding to characterize and package 

transuranic wastes at multiple DOE sites for shipment to the 

department’s deep geologic repository for permanent disposal.9 (See 

fig. 3.) Transuranic wastes typically consist of discarded rags, tools, 

equipment, soils, or other solid materials that have been contaminated 

by radioactive elements, such as plutonium or americium.

• Supporting the maintenance and treatment of liquid tank waste. For 

example, EM used the funds to upgrade the infrastructure used to 

stabilize and maintain the tanks that store chemical and radioactive 

waste at the Hanford Site.

 

8

Transuranic waste is waste containing more than 100 nanocuries of alpha-emitting 

transuranic elements (radiation) per gram with half-lives greater than 20 years with certain 

exceptions. A half-life is the amount of time required for an element to decay by half, and 

nanocuries are a measure of radioactivity. Alpha-emitting radiation cannot pass through 

objects, including human skin, but it is extremely dangerous if inhaled or ingested.

9

Because these wastes remain radioactive for extremely long periods—hundreds of 

thousands of years in some cases—most are headed for disposal at the Waste Isolation 

Pilot Plant, a deep geologic repository near Carlsbad, New Mexico, designed for 

transuranic waste disposal. 
 

Page 7 GAO-13-23 DOE Recovery Act Cleanup Projects

Figure 2: Views Before and After the Demolition of Building K-33, East Tennessee Technology Park, Oak Ridge Reservation

Figure 3: Workers Packaging Transuranic Waste, Savannah River Site
 

Page 8 GAO-13-23 DOE Recovery Act Cleanup Projects

In 1990, we first designated DOE’s contract management, including both 

contract administration and project management, at high risk for fraud, 

waste, abuse, and mismanagement.10 In the decades that followed, DOE 

has taken steps to improve its project and contract management. For 

example, in 2000, DOE issued, and has periodically updated, Order 

413.3, which established a management process with five major 

milestones—or critical decision points—that span the life of a project, 

from the identification of need through project completion.11 However, we 

have consistently reported that EM faced difficulties in developing and 

achieving realistic cost and schedule targets for its cleanup activities, in 

part because of challenges in addressing complex technical issues, 

negotiating contracts, coordinating with regulators, and ensuring safety.12

In 2009, EM developed a new initiative to improve project management, 

called the new management framework. Under this initiative—which was 

first applied to Recovery Act projects—EM separated large projects—

which are composed of a mix of projects at various stages between 

planning and completion that could overall last for decades—into smaller 

discrete projects of shorter duration that the agency deemed easier to 

oversee and manage. The smaller cleanup projects are classified into two 

major types as follows:

 

10GAO designated DOE’s contract management as high risk in 1990 and then evaluated 

and reported on the fundamental causes of problems in this high-risk area in: High-Risk 

Series: Department of Energy Contract Management, GAO/HR-93-9 (Washington, D.C.: 

December 1992). 

11Critical decision 2, for instance, marks the approval of the project’s performance 

baseline, specifying the planned scope (particularly, specific requirements known as key 

performance parameters); cost; and schedule that should be met at project completion. At 

this critical decision point, DOE completes its preliminary design and develops a definitive 

cost estimate for the work.

12See, GAO, Department of Energy: Actions Needed to Develop High-Quality Cost 

Estimates for Construction and Environmental Cleanup Projects, GAO-10-199 

(Washington, D.C.: Jan. 14, 2010); 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); GAO, 

Department of Energy: Further Actions Are Needed to Strengthen Contract Management 

for Major Projects, GAO-05-123 (Washington, D.C.: Mar. 18, 2005); GAO, Hanford Waste 

Treatment Plant: Contractor and DOE Management Problems Have Led to Higher Costs, 

Construction Delays, and Safety Concerns, GAO-06-602T (Washington, D.C.: Apr. 6, 

2006). 
 

Page 9 GAO-13-23 DOE Recovery Act Cleanup Projects

• Capital asset projects. These projects cost $10 million or more and 

include construction, such as the expansion of a waste disposal 

facility; environmental remediation construction, such as digging wells 

to remove contaminated groundwater; and cleanup activities, such as 

excavating contaminated soil or demolishing facilities contaminated 

with hazardous chemical or radioactive substances.

• Operation activity projects. These projects can either be “project like,” 

with definable start and end dates, discrete scopes of work, and 

measurable accomplishments or routine or recurring operations, 

according to EM’s operations protocol.13 For example, operation 

activity projects include construction and cleanup projects that are 

similar to capital asset projects but that cost less than $10 million; 

operation activities, such as packaging, storing, transporting, and 

disposing of waste and nuclear materials; operating a groundwater 

treatment plant; and program activities, such as maintaining and 

repairing inactive facilities.14

In February 2011, recognizing improvements DOE had made, we 

narrowed the focus of the high-risk designation but retained EM’s contract 

and project management on our high-risk list because DOE had not yet 

consistently improved EM’s contract and management performance.15 In 

particular, we reported that DOE must ensure that the corrective action 

measures it is taking to improve its cost-estimating policies and 

procedures ultimately result in cost estimates for its major projects that 

are more accurate and reliable.

 

13Office of Environmental Management, Operations Activities Protocol, February 28, 2012.

14DOE does not consider operation activities, as discussed in this report, to be “projects” 

as designated under the DOE order that is applicable for capital asset projects. However, 

for purposes of this report, we refer to these operation activities as projects because we 

are collectively referring to all Recovery-Act funded efforts as projects.

15GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011). 
 

Page 10 GAO-13-23 DOE Recovery Act Cleanup Projects

From October 2009 through March 2012, the number of FTEs EM funded 

with Recovery Act funds peaked at a high of 11,000 FTEs in the last 

quarter of fiscal year 2010 and decreased to about 1,400 FTEs in the 

second quarter of fiscal year 2012,16 according to the data on the federal 

government’s Recovery Act website. In fiscal year 2011, the number of 

FTEs fluctuated from about 8,000 to 10,000 FTEs per quarter, as some 

projects were completed and other projects (called buy-back projects) 

were started with excess funds from those completed.17 According to EM 

officials, these excess funds resulted when contractors performed work 

more efficiently or avoided potential problems that would have required 

spending management reserves or contingency funds.18

 

16Under OMB guidance, agencies should calculate FTEs by totaling the number of hours 

that workers charge to Recovery Act projects in a given quarter of the fiscal year and 

dividing the sum by the total number of work hours representing a full-time work schedule. 

OMB, Memorandum, “Updated Guidance on the American Recovery and Reinvestment 

Act – Data Quality, Non-Reporting Recipients, and Reporting of Job Estimates,” Dec.18, 

2009.

In the first 

quarter of fiscal year 2012, the number of FTEs dropped sharply—to 

about 2,700—as EM completed more projects. (See fig. 4.) These trends 

were largely in line with EM’s initial plan to start Recovery Act projects 

quickly and to generally complete them by the end of fiscal year 2011. 

The number of FTEs is expected to continue to decline through fiscal year 

2013, as EM completes the last of the projects funded by the Recovery 

Act.

17By the end of the second quarter of fiscal year 2012, DOE had started a total of 20 buyback projects.

18A management reserve is a portion of the contract price managed by the contractor and 

is available to address realized risks that are within the scope of the contract. A 

government contingency fund, which is controlled by the government and is not part of the 

contract price, is used to manage risks affecting cost and schedule, such as changed 

requirements and delays in government-furnished services, equipment, and items; and 

other influences outside the contractor’s control.

EM Recovery ActFunded Jobs Peaked 

at about 11,000 FTE 

Employees Late in 

Fiscal Year 2010
 

Page 11 GAO-13-23 DOE Recovery Act Cleanup Projects

Figure 4: FTEs Funded by the Recovery Act by Quarter, First Quarter Fiscal Year 

2010 through Second Quarter Fiscal Year 2012

a

Since the third quarter of fiscal year 2010, EM’s prime, or chief, contractors for projects at each site 

have been required to report quarterly on the number of FTEs—their own as well as the FTEs of 

subcontractors they hired to perform specific portions of the work—funded with Recovery Act funds. 

Before that time, only prime contractor FTEs were reported. As a result, comparable information is 

not available for the first and second quarters of fiscal year 2010. EM sites reported subcontractor 

FTEs for these quarters, which are shown in red.

As of the end of the second quarter of fiscal year 2012, the 17 EM 

cleanup sites were in different stages of reducing their number of 

Recovery Act-funded FTEs. Twelve of the 17 EM cleanup sites reported 

no FTEs,19

 

19Some of these 12 sites reported less than one-half FTE for the quarter, which rounds to 

zero FTE. 

and 5 sites—Argonne National Laboratory, Richland Office at 
 

Page 12 GAO-13-23 DOE Recovery Act Cleanup Projects

the Hanford Site, Idaho National Laboratory, Oak Ridge Reservation, and 

Savannah River Site—continued to report FTEs, but their FTEs had 

decreased significantly from the fourth quarter of fiscal year 2010 when 

the overall number of EM FTEs peaked. (See table 1.)

Table 1: EM FTEs Funded by the Recovery Act in the Fourth Quarter of Fiscal Year 

2010 and Second Quarter of Fiscal Year 2012

FTEs fundeda

Sites 

4th quarter

FY 2010

2nd quarter

FY 2012

1. Argonne National Laboratory (IL) 86 42

2. Brookhaven National Laboratory (NY) 97 0 

3. Energy Technology Engineering Center (CA)b 12 0 

4. Hanford Site

Office of River Protection (WA) 581 0 

Richland Office (WA) 3,114 316

5. Idaho National Laboratory (ID) 949 160

6. Los Alamos National Laboratory (NM) 382 0 

7. Moab UMTRA Site (UT) 230 0 

8. Mound Site (OH) 32 0 

9. Nevada National Security Site (NV) 76 0 

10. Oak Ridge Reservation (TN) 2,240 302

11. Paducah Site (KY) 193 0 

12. Portsmouth Site (OH) 399 0 

13. Savannah River Site (SC) 1,997 572

14. Separations Process Research Unit (NY) 94 2 

15. SLAC National Accelerator Laboratory (CA) 35 0 

16. Waste Isolation Pilot Plant (NM) 323 0 

17. West Valley Demonstration Project (NY) 103 0 

Otherc 89 10

Total 11,030d 1,405d

Source: GAO analysis of DOE data.

Note: Overall, FTEs peaked in the fourth quarter of fiscal year 2010. FTEs for sites reporting less than 

one-half of an FTE were rounded to zero.

a

FTEs funded include both prime contractor and subcontractor FTEs.

b

At the Energy Technology Engineering Center, DOE works in a partnership with the Environmental 

Protection Agency (EPA). According to DOE officials, the FTEs for EPA’s efforts are separately

reported and are not included in the counts in this table.
 

Page 13 GAO-13-23 DOE Recovery Act Cleanup Projects

c

Other includes FTEs for managing the direction of the Recovery Act program, which are at DOE sites 

as well as DOE headquarters, according to an EM official, and FTEs associated with the Title X 

uranium and thorium reimbursement program.

d

The total number of FTEs may not equal the sum of all sites’ FTEs because of rounding.

EM’s spending on Recovery Act projects has largely been consistent with 

EM’s plan to start Recovery Act projects quickly. As figure 5 shows, EM’s 

quarterly spending has generally tracked the rise and fall of FTEs. Its 

quarterly Recovery Act spending peaked at $668 million in the fourth 

quarter of fiscal year 2010 and thereafter quarterly spending generally fell 

as EM completed projects.

Figure 5: FTEs and Recovery Act Spending for EM Cleanup Projects, First Quarter 

of Fiscal Year 2010 through Second Quarter of Fiscal Year 2012

EM had initially expected to spend all Recovery Act funds by the end of 

fiscal year 2011 but, according to an EM document, had actually spent 88 

percent of the funds by that time. By the end of the second quarter of 

fiscal year 2012, EM had spent about $5.6 billion of its $6 billion of 

Recovery Act funds, leaving about 6 percent to be spent. According to 
 

Page 14 GAO-13-23 DOE Recovery Act Cleanup Projects

EM officials, EM now expects to spend its remaining Recovery Act funds 

by the end of fiscal year 2013.

According to an EM official, three factors contributed to slower than 

expected spending. First, EM recognized early in the program that 

technical and contracting award delays required extending some projects’ 

completion beyond fiscal year 2011.20

Sites have spent all or almost all of their allotted Recovery Act funds (see 

table 2). By the end of the second quarter of fiscal year 2012, six sites 

reported spending 100 percent of their Recovery Act allotted funds; eight 

other sites spent from 96 to 99 percent of their funds; and three sites 

spent from 85 to 90 percent of their funds.

Second, as projects were being 

undertaken, EM recognized that performance issues at some sites would 

delay projects and thus spending. Third, EM was planning new buy-back 

projects but generally had to complete the original projects before it could 

use excess funds from them to begin buy-back projects.

Table 2: EM’s Recovery Act Funds and Spending through Second Quarter of Fiscal Year 2012

Dollars in thousands

Allotted funds that have been spent 

Total Recovery 

Act funds allotted Amount Percentage

1. Argonne National Laboratory (IL) $79,000 $70,302 89

2. Brookhaven National Laboratory (NY) 70,810 70,808 100

3. Energy Technology Engineering Center (CA) 51,675 51,675 100

4. Hanford Site

Office of River Protection (WA) 326,035 326,000 100

Richland Office (WA) 1,634,500 1,613,912 99

5. Idaho National Laboratory (ID) 467,875 451,310 96

6. Los Alamos National Laboratory (NM) 211,975 211,748 100

7. Moab UMTRA Site (UT) 108,350 108,204 100

8. Mound Site (OH) 17,900 17,526 98

 

20Technical delays included discovery of unanticipated wastes or the inability to obtain 

needed materials or equipment in a timely manner. For example, DOE officials stated that 

containers needed to ship transuranic waste to the Waste Isolation Pilot Plant were not 

issued a certification of compliance by the Nuclear Regulatory Commission until June 

2010, thus delaying project progress.
 

Page 15 GAO-13-23 DOE Recovery Act Cleanup Projects

Dollars in thousands

Allotted funds that have been spent 

Total Recovery 

Act funds allotted Amount Percentage

9. Nevada National Security Site (NV) 44,325 44,301 100

10. Oak Ridge Reservation (TN) 755,110 640,991 85

11. Paducah Site (KY) 80,400 79,705 99

12. Portsmouth Site (OH) 119,800 118,393 99

13. Savannah River Site (SC) 1,615,400 1,459,872 90

14. Separations Process Research Unit (NY) 58,575 58,033 99

15. SLAC National Accelerator Laboratory (CA) 14,300 14,300 100

16. Waste Isolation Pilot Plant (NM) 172,175 169,385 98

17. West Valley Demonstration Project (NY) 62,875 61,570 98

Othera 108,920 95,237 a

Totalb $6,000,000 $5,663,271 94%

Source: GAO analysis of DOE data.

Note: Numbers are as provided by DOE and are not adjusted for inflation. Because of rounding, some 

percentages show 100 percent even if the allotted and spent amounts are not equal.

a

Other includes DOE’s Title X uranium and thorium reimbursement program, which is funded with 

Recovery Act funds, as well as funding for management and oversight of the Recovery Act program. 

DOE was unable to provide us with spending data for $11 million of the nearly $109 million allotted 

because, according to a DOE official, DOE combines these Recovery Act funds with other funds for 

department-level management and oversight of Recovery Act programs and does not separately 

track them.

b

Because DOE was unable to provide us with spending data for $11 million of the allotted funds in the 

other category, we did not report any spending for these funds. If DOE has spent all of the funds, total 

spending could actually be as high as $5,674 million, or 95 percent, of the $6 billion of Recovery Act 

funds.

According to EM data, as of April 2012, EM had administratively 

completed 78 of the 112 Recovery Act-funded projects, but inconsistent 

data on projects’ scope, cost, and schedule targets make it difficult to 

assess the extent to which completed projects met performance 

baselines.

EM Has Completed 

Most Projects, but 

Inconsistent Data 

Make Assessing 

Project Performance 

Difficult
 

Page 16 GAO-13-23 DOE Recovery Act Cleanup Projects

Of the 112 Recovery Act-funded projects, 78 projects were completed 

and approved for closure, called administrative completion, as of April 

2012, according to EM data (see app. II for a list of the completed 

projects). EM expects to complete the remaining projects by the end of 

fiscal year 2013. According to EM officials, the Recovery Act projects 

have helped accelerate the cleanup of contaminated facilities and land, 

including the completion of EM’s cleanup responsibilities at the Mound 

site and the SLAC National Accelerator Laboratory. EM analyzed project 

performance using information in project closure documents and the 

IPABS database and concluded that 72 of the 78 projects (92 percent) 

met scope and cost targets. DOE’s standard for performance is to 

complete all scope targets without exceeding the cost targets by more 

than 10 percent. For the remaining 6 projects, some ended without 

completing all scope targets and some of the projects’ exceeded their 

cost targets by more than 10 percent. For example, a project to 

accelerate the demolition of a graphite research reactor at Brookhaven 

National Laboratory in New York State exceeded its original estimated 

cost by over 25 percent. EM demolished the remaining portion—

approximately 37 percent—of one structure using a project funded with 

annual appropriations.

As shown in figure 6, most projects finished significantly below their cost 

targets. Specifically, EM documents show that 42 of these 78 projects (54 

percent) were completed more than 10 percent under their cost targets, 

with 22 finishing from 20 to 70 percent under their cost targets.

EM’s Analysis of Reported 

Data Indicate That Most 

Recovery Act Projects 

Were Completed, 

Generally Below Planned 

Costs 
 

Page 17 GAO-13-23 DOE Recovery Act Cleanup Projects

Figure 6: Percentages that the Projects’ Final Costs Are Over or Under their Targets 

for 78 Administratively Completed Recovery Act Projects, as of April 2012

DOE and EM officials told us that Recovery Act-funded projects could be 

completed under their cost targets for any number of reasons. According 

to EM officials, when projects come in under their cost targets, it is 

generally because contractors found more efficient ways of completing 

the project scope and did not encounter risks that required the use of 

management reserves or contingency funds. In addition, some EM 

officials stated that the Recovery Act projects may have been budgeted 

with assumptions supporting the higher end of reasonably estimated 

costs to ensure that projects did not go over cost targets. For instance, 

site officials at the Savannah River Site in South Carolina told us that one 

project included infrastructure work in its budget, such as roadway 

projects that would be required to support the additional Recovery Act 

work at the site. Upon the project’s completion, officials found that $32 

million of the planned funding for these infrastructure projects was not 

needed, in part because less roadwork was needed than assumed.

For projects that were more than 20 percent under their cost targets, 

however, EM and other DOE officials told us that, typically, cost 
 

Page 18 GAO-13-23 DOE Recovery Act Cleanup Projects

efficiencies and risk avoidance could not explain why these projects were 

so far under their cost targets. Instead, these projects were likely to have 

had their scope significantly altered or had their scope completed in an 

entirely different way than was considered when the cost targets were 

established. However, there was no complex-wide information to explain 

why these projects were completed so far below cost targets. The EM 

Consolidated Business Center, which is responsible for ensuring that EM 

cost and schedule estimates are reliable, was unable to provide additional 

information on why final costs were below those in the performance 

baselines. Officials at the center told us that they track final project costs 

to improve future estimates but do not compare targets and final costs. 

According to Office of Project Management officials, DOE does not 

currently designate a project’s performance as unsuccessful if its final 

cost fell too far below its cost targets. However, these officials did say that 

it is a poor project management practice to obligate significantly more 

funding to projects than required. These funds could be put to a more 

productive use by assigning them to other projects that require additional 

funding or by beginning additional cleanup work. Under EM’s Recovery 

Act program, when original projects were completed or both the 

headquarters and site office teams were certain the originally funded 

effort could be completed, any excess funds then became available to 

fund additional cleanup projects, which allowed another 20 Recovery Act 

projects to begin by mid-April 2012.

In analyzing EM data, we identified a variety of issues with how EM 

established and documented scope, cost, or schedule targets. Scope 

targets were not consistently set and documented for some capital asset 

and operation activity projects; cost targets were flexibly set for operation 

activity projects; and schedule completion targets for both capital asset 

and operation activity projects were typically set for the end of a fiscal 

year, regardless of when a project was actually expected to be 

completed. Without clear scope, cost, or schedule targets in performance 

baselines, it becomes difficult to assess project performance.

For both capital asset and operation activity projects, our analysis showed 

that scope targets—or the key performance parameters that are to be 

completed in order for a project to be deemed complete and successful—

were neither consistently established nor consistently used by EM to 

measure project completion and success. At times, key performance 

parameters were articulated in very general terms (e.g., demolish a 

building); at other times, they were articulated in specific terms 

(e.g., remove 1.6 million cubic yards of soil). Such variability in key 

Problems with 

Establishing Scope, Cost, 

or Schedule Targets Raise 

Questions about Actual 

Project Performance

Inconsistencies in How EM 

Established and Documented 

Projects’ Scope Targets 
 

Page 19 GAO-13-23 DOE Recovery Act Cleanup Projects

performance parameters can make it difficult to accurately determine 

when a project has truly been completed or whether it has successfully 

achieved its goals. Examples include the following:

• A project at the Paducah Site in Kentucky included only a single 

general key performance parameter requiring the demolition of one 

building. This parameter did not describe what activities the demolition 

was to entail, such as the removal of the building’s foundation, 

removal of equipment, or cleanup of the site. Even though many of 

these activities were described in a separate description of the 

project’s scope, the key performance parameter itself did not explicitly 

specify any of these activities as being required for the project to be 

determined complete or successful. By not doing so, the key 

performance parameter did not identify what successful demolition 

would actually entail when completed.

• A project to expand a waste disposal facility at the Hanford Site in 

Washington State, on the other hand, included a key specific 

performance parameter for excavating 1.6 million cubic yards of soil, 

but the project’s design specifications defined the project in terms of 

the size of the pit from which soil was to be removed. EM determined 

that the project was complete when the pit met the dimensions stated 

in the design document (1,000 feet long by 500 feet wide by 70 feet 

deep) even though the amount of soil removed was 1.5 million cubic 

yards. EM officials told us that the original key performance parameter 

of 1.6 million cubic yards was a planned-for approximation, not a 

hard-and-fast functional requirement for project completion.

Capital asset projects are subject to specific requirements set forth in 

Order 413.3B, whereas operation activity projects are not. This order 

requires that scope targets incorporating key performance parameters are 

to be documented in a critical decision memorandum usually issued at 

the end of a planning period. Nevertheless, we found that either key 

performance parameters were not specified in critical decision 

memorandums or project success at closure was assessed against more 

than one scope target. Specifically, over one-third (13 out of 33) of 

completed Recovery Act capital asset projects did not specify scope 

targets or key performance parameters and, in other cases, projects were 

assessed against more than one scope target description. Following are 

some examples:

• For a project to expand a waste disposal facility at the Oak Ridge 

Reservation in Tennessee, neither the critical decision memorandum 
 

Page 20 GAO-13-23 DOE Recovery Act Cleanup Projects

nor the execution plan specified scope targets or key performance 

parameters. Yet on the basis of other documents—design drawings 

and specifications—the project closure report stated that all key 

performance parameters had been completed. Office of Project 

Management officials told us that when a critical decision 

memorandum lacks key performance parameters, such parameters 

sometimes cannot be reconstructed to establish scope targets. In 

such cases, they said, no audit trail exists to compare planned key 

performance parameters with those cited at project completion, 

making it difficult to demonstrate the extent to which projects were 

successfully completed.

• For a waste remediation project at the Hanford Site, two different 

scope targets were used as measures of success. One project plan 

called for the complete remediation of 24 waste sites [emphasis 

added], whereas another project plan called for the remediation of 

53,000 cubic meters of soil at 18 sites. The closure report for this 

project pieced together both of these scope targets, stating that 1 of 

24 sites was not completely remediated because unexpected 

contamination was found, and remediating that contamination would 

have exceeded 53,000 cubic meters of soil. Thus, depending on 

which source is used to describe the project scope, the project could 

be assessed as having failed to completely remediate 24 sites or as 

having successfully remediated 18 sites plus 6 more sites, to the 

called-for maximum amount of soil.

Because operation activity projects are not subject to Order 413.3B, EM 

has greater flexibility in terms of when it sets scope targets and where 

targets are documented. According to an EM official, operation activity 

projects are to be assessed against key performance parameters as 

documented in the IPABS database. EM’s 2011 guidance on preparing 

closure documents for Recovery Act projects, on the other hand, directs 

sites to measure success against key performance parameters in project 

plans. Moreover, we found cases in which a project’s scope targets as 

documented in the project plan differed from the scope targets 

documented in IPABS. Examples we found include the following:

• The scope set forth in IPABS for a project to clean up a nuclear facility 

at Argonne National Laboratory in Illinois included shipping up to 15 

casks of material for disposal. At the end of the project, however, 

EM’s closure document labeled the project a success because it met 

the key performance parameter found in the project plan, which was 
 

Page 21 GAO-13-23 DOE Recovery Act Cleanup Projects

stated in terms of linear inches of nuclear fuel packaged into shipping 

tubes.

• An EM official told us that another project, at Brookhaven National 

Laboratory, had failed because it did not complete a key scope 

requirement—the removal of an exhaust stack for air cooling in a 

facility—as recorded in IPABS. The official stated the site’s closure 

document inappropriately indicated that all key performance 

parameters were completed on the basis of a more limited scope 

described in the project plan.

Such uses of two different scope targets may thus lead to differing or 

inaccurate assessments of performance.

In addition to inconsistencies in how and where EM set and documented 

scope targets, we found flaws in EM’s evaluation of project 

performance—in particular, claims of project success even if key 

performance parameters were not achieved. According to EM officials, 

EM is committed to implementing Order 413.3B principles as applicable 

to all EM activities, including operation activity projects. In discussions 

with us, EM officials offered a number of explanations for determining that 

certain key project parameters of operation activity projects were 

successfully completed, even though these explanations ran counter to 

specific provisions in Order 413.3B, and an official from the Office of 

Project Management questioned the validity of these explanations. 

Following are some examples:

• According to EM officials, an operation activity project at the Energy 

Technology Engineering Center in California—a project including site 

characterization and analyses to support site cleanup—was deemed 

successful even though not all key performance parameters were 

completed. EM officials stated that these parameters were not 

completed for reasons outside of the office’s control because 

Recovery Act funding arrived later than expected and because state 

regulators changed regulatory requirements. However, an Office of 

Project Management official told us that if the provisions in Order 

413.3B applied, the unavailability of funds when expected appears to 

result from EM’s inadequate up-front planning rather than a matter 

outside of its control. Moreover, the official observed, under Order 

413.3B, EM would have had to demonstrate that the state had 

changed its regulatory requirements or its agreement with DOE before 

EM could argue that a change in project scope was justified.
 

Page 22 GAO-13-23 DOE Recovery Act Cleanup Projects

• A project to demolish contaminated buildings at the Portsmouth Site in 

Ohio did not fulfill a key performance parameter—the removal of two 

buildings’ concrete slab foundations—because after officials had set 

the parameters, they determined that these slabs could be used as a 

staging area for future cleanup work, and it was, therefore, in the 

government’s interest to retain them. Nevertheless, an Office of 

Project Management official told us that not meeting a key 

performance parameter would have been considered a failure under 

Order 413.3B. He stated that regardless of a later determination of 

what is in the government’s interest, setting the removal of the 

buildings’ foundations as a key performance parameter appears to be 

a failure of front-end project planning.

Planned costs for operation activity projects—unlike those of capital asset 

projects, for which Order 413.3B establishes specific requirements—were 

more flexibly set. Specifically, operation activity projects had no single 

original cost targets they were to adhere to, and EM sometimes altered 

cost targets, in response to changes in funding or planning 

circumstances, to final cost targets while the projects were under way. 

Without a fixed cost target against which to measure a project’s success, 

it is possible that EM could claim that a project was on budget by 

successively altering the cost targets.

For example, EM asserted that a project to ship and dispose of 

contaminated waste from the Hanford Site was successfully completed at 

a cost of $47.5 million—slightly below its final cost target of $47.9 

million—even though IPABS information indicated that the project’s cost 

target was originally approximately $43 million. Thus, rather than coming 

in under budget, this project exceeded its original cost target by more 

than 10 percent. According to EM officials, resetting to a higher original 

cost target was appropriate because the commercial costs of waste 

treatment and disposal had gone up since the original performance 

baseline was established. An EM official told us that this decision was 

consistent with changing cost targets under Order 413.3B. An Office of 

Project Management official, however, noted that the possibility of 

changing commercial costs should have been taken into consideration 

during project planning stages and, therefore, did not constitute a basis 

for changing this project’s cost target under Order 413.3B.

EM’s data do not generally support a meaningful assessment of whether 

Recovery Act projects were completed within schedule targets. According 

to EM officials, the target completion dates for Recovery Act projects 

were generally set to be the end of a fiscal year and not at the point when 

Cost Targets Were Not 

Consistently Documented for 

Operation Activity Projects 

Schedule Targets Usually Did 

Not Reflect Expected Project 

Completion Dates
 

Page 23 GAO-13-23 DOE Recovery Act Cleanup Projects

projects were actually expected to be completed. For 72 of the 78 

completed projects, EM data showed a target completion date either at 

the end of EM’s Recovery Act program (initially slated for the end of fiscal 

year 2011) or the end of EM’s budget period at the end of fiscal year 

2012.

Using the end-of-program or budget periods as the target date for project 

completion raises concerns about the accuracy of resulting assessments 

of individual project’s schedule performance. Our analysis of EM 

headquarters’ data shows that some projects appeared to be completed 

as much as 50 to 80 percent earlier than planned. However, the closure 

documentation for these projects sometimes presented a very different 

picture about the scheduled completion of work at the site. For example, 

EM’s headquarters data show that the project to prepare the K-27 

building for demolition at Oak Ridge had a target date for completion at 

the end of fiscal year 2012, but all elements of the project’s scope were 

actually completed on December 30, 2010, over 21 months earlier. A 

review of project-specific documentation, however, revealed that the work 

was completed only a few weeks early compared with target dates in that 

documentation. According to an EM official, schedule completion dates 

for Recovery Act projects were left at the end of the fiscal year to provide 

additional flexibility in completing the projects on time. After final contracts 

were agreed upon, he told us, EM did not change schedule dates to the 

target completion date in the contract because the office believed that the 

contractor schedule estimates were generally too optimistic and might not 

fully reflect risks that could delay the projects.

Guidance is available for both capital asset and operation activity 

projects, but the guidance for capital asset projects—DOE Order 

413.3B—is more comprehensive than the protocols for operation activity 

projects. Nevertheless, according to Office of Project Management 

officials, Order 413.3B does not address how to develop key performance 

parameters for capital asset cleanup projects or provide examples. 

Rather, it is up to individual sites to develop such parameters on a caseby-case basis. This shortage of specific guidance, including examples, for 

how to develop key performance parameters may contribute to the 

inconsistencies we describe in this report.

EM’s 2012 operations protocol, the available guidance for operation 

activity projects, omits a number of key elements related to setting scope, 

cost, and schedule targets in performance baselines. For example, key 

performance parameter is mentioned only in the glossary. Moreover, 

unlike Order 413.3B, which defines permissible changes to projects’ 

Guidance for Both Capital 

Asset and Operation Activity 

Projects Has Gaps 
 

Page 24 GAO-13-23 DOE Recovery Act Cleanup Projects

performance baselines, the protocol for operation activity projects 

provides only a partial list of such changes. Moreover, the protocol does 

not define when and how projects’ performance baselines are to be 

documented—documentation critical for accurately assessing a project’s 

success or failure.

Some of EM’s long-standing project management problems occurred 

during its implementation of Recovery Act projects, primarily insufficient 

early planning before setting a performance baseline; new problems also 

occurred, particularly about how projects were classified as capital asset 

or operation activity projects. EM has been gathering information on 

lessons learned from Recovery Act projects, some of which could apply to 

other EM cleanup work, but some lessons may have limited applicability 

for future work, and the lessons to date do not provide a basis for EM to 

assess the effectiveness of its initiative.21

DOE noted in its 2008 root cause analysis of project management issues 

that a key issue affecting project performance was insufficient front-end 

planning before setting project baselines.22

 

21In June 2011, a House committee report directed EM to develop lessons learned, 

including problems encountered and best practices identified in its Recovery Act projects. 

EM’s resulting report is expected to provide the committee with specific recommendations 

on how those lessons learned can and will be applied to managing ongoing and future 

projects. ( H.R. Rep. No. 112-118 (2011). 

According to Order 413.3B for 

capital asset projects, project planning, including site characterization, 

should be conducted prior to establishing a project’s performance 

baseline to help ensure the project can be completed within that baseline. 

Similarly for operation activity projects, EM’s initiative stated that EM 

would monitor the projects using credible performance baselines with 

well-defined scope. Nevertheless, according to our analysis of EM 

documents, several Recovery Act capital asset and operation activity 

projects did not seem to benefit from sufficient early project planning. 

Consequently, the projects’ final scope, cost, or schedule did not conform 

to their performance baselines. Some examples are as follows:

22Department of Energy, Root Cause Analysis: Contract and Project Management

(Washington, D.C.: April 2008).

Project Management 

Problems Occurred 

on EM Recovery Act 

Projects, and EM Is 

Taking Steps to 

Identify Lessons 

Learned 

Some Recovery Act 

Projects Demonstrated 

Insufficient Early Planning 

before EM Set Project 

Performance Baselines
 

Page 25 GAO-13-23 DOE Recovery Act Cleanup Projects

• Unexpected volumes of wastes changed project scope. The scope of 

a Recovery Act capital asset project at the Los Alamos National 

Laboratory in New Mexico to remove hazardous and radioactive 

wastes from a landfill dating to the 1940s increased significantly when 

it was determined that the site would need to be excavated to a depth 

of 30 feet rather than the planned for 12 to 18 feet. EM site officials 

reported that more site characterization would have helped identify 

the extent of contamination, but more characterization was not done 

because of schedule and budget constraints. The cost of the project 

increased from $111 million to $130 million when the amount of waste 

needing excavation exceeded the original target. At the Mound Site in 

Ohio, a Recovery Act capital asset project was to remove and dispose 

of three types of waste to certain maximums: 406,000 cubic feet of 

low-level waste, 27,000 cubic feet of mixed low-level waste, and 

15,000 cubic feet of hazardous waste.23 According to EM documents, 

the project was completed under planned cost but with an actual 

scope almost unrelated to that in its performance baseline. The 

project disposed of all the waste at the site, but the mixture of wastes 

disposed of was completely different than expected: 73 percent more 

low-level waste was disposed of than planned, 1 percent of the 

planned mixed low-level waste was disposed of, and no hazardous 

waste was found.

• Unexpected challenges affected project cost or schedule. At Idaho 

National Laboratory, during the decommissioning and demolition of a 

former nuclear reactor, the contractor discovered asbestos 

contamination that had not been identified before the project’s scope 

and cost targets had been established, which slowed work while the 

contractor planned how to address this unexpected contamination; 

this delay contributed to the operation activity project’s missing its 

completion date of the end of fiscal year 2011. Similarly, at the 

Brookhaven National Laboratory, the contractor demolishing a 

radioactively contaminated concrete shield around a former reactor 

found that the shield was much denser than expected, which delayed 

the completion of the capital asset project and raised costs; the 

additional funds EM provided were also exhausted before the 

 

23The Environmental Protection Agency defines hazardous waste as waste that is 

dangerous or potentially harmful to health or the environment. Low-level waste includes 

radioactively contaminated debris, rubble, and soils from the decommissioning and 

cleanup of nuclear facilities. Mixed low-level waste contains both radioactive and 

chemically hazardous waste.
 

Page 26 GAO-13-23 DOE Recovery Act Cleanup Projects

contractor completed the project, and the remaining demolition was 

transferred to a project funded with annual appropriations. 

Furthermore, as part of a Recovery Act capital asset project at the 

Separations Process Research Unit site in New York state, EM was 

demolishing a building that had been contaminated from nuclear 

research dating to the 1950s. In September 2010, a wrecking crew’s 

work resulted in the accidental spread of radioactive contamination. 

The building’s footprint was posted as a contamination area, and 

demolition work was suspended while the contractor prepared a 

corrective action plan to ensure no further accidents occurred. 

Moreover, in part because the cost to remediate the accident was 

expected to exceed $1 million, EM conducted an accident 

investigation, which concluded that the contractor’s failure to fully 

characterize the building before demolition contributed to the accident.

According to DOE’s 2008 corrective action plan, one obstacle to sufficient 

planning is managers’ strong desire to begin executing their projects.24

EM’s plan to complete Recovery Act work by the end of fiscal year 2011 

added to existing pressures to complete planning quickly and start 

executing projects. According to an official at EM’s Consolidated 

Business Center, most hiring would occur to execute jobs, not plan the 

projects. Even though EM sought to begin Recovery Act projects quickly, 

Office of Project Management officials told us that, for the sake of 

establishing better cost targets, EM should resist external pressures to 

start projects without sufficient site characterization; otherwise, EM’s 

performance baselines will need large contingencies to cover the risks of 

finding more contamination than expected.

According to a senior EM official, when deciding how much site 

characterization to conduct in determining scope, EM faces a trade-off: 

(1) spend little time and money on site characterization and then face the 

risk of finding more or different contamination than expected when the 

cleanup project begins or (2) spend significant time and money on site 

characterization, although additional contamination may still be found 

when cleanup project begins.

According to an EM document, these types of scoping problems would be 

partially addressed by its initiative, which was intended to break very 

 

24Department of Energy, Root Cause Analysis: Contract and Project Management 

Corrective Action Plan (Washington, D.C.: July 2008).
 

Page 27 GAO-13-23 DOE Recovery Act Cleanup Projects

large projects—composed of a mix of projects at different stages of being 

defined or executed—into smaller, discrete, projects that could be better 

defined. Discrete projects were also a key element of DOE’s corrective 

action plan to address the department’s long-standing project 

management issue of ensuring that performance baselines are sufficiently 

planned. According to EM documents, this approach, in combination with 

better planning, including site characterization, would allow EM to have 

better performing projects, as well as better estimated final costs.

However, some of the Recovery Act cleanup projects were actually work 

segments of larger projects rather than discrete projects. The lines 

between the Recovery Act projects and large projects funded with annual 

appropriations sometimes became blurred, making it difficult to determine 

the scope, cost, and schedule targets for the Recovery Act-funded work. 

Following are some examples:

• The scope of a Recovery Act capital asset project included 

constructing three of several tent-like structures over excavation sites, 

according to the project’s closure document. This project was part of a 

larger overall project to retrieve buried waste contaminated with 

solvents, transuranic waste, and uranium at the Idaho National 

Laboratory. However, an EM official told us that one of these tents 

was mistakenly included in the project’s approved performance 

baseline, and it was instead constructed by an annual appropriationsfunded project. The Recovery Act project also removed contaminated 

waste—part of an effort supported by other Recovery Act and annual 

appropriations-funded projects.

• Since the Recovery Act funding for a capital asset project to expand a 

waste disposal facility at the Oak Ridge site was unavailable when the 

site wanted to take advantage of the full construction season, 

according to the project’s closure documents, the project’s initial 

steps, including site preparation, were funded with annual 

appropriations. When the site later realized that an additional 

expansion would be built for the waste disposal facility, certain final 

construction activities for the Recovery Act project were moved to the 

new construction project.

• The scope for a Recovery Act project at the Energy Technology 

Engineering Center included submitting to state regulators a work 

plan for the study of feasible technologies to support site cleanup and 

closure, but that work was completed using annual appropriations 

prior to the start of the Recovery Act project. As a result, EM used the 
 

Page 28 GAO-13-23 DOE Recovery Act Cleanup Projects

freed-up Recovery Act funds for other work at the center, including 

completing the model to predict the flow of contaminated groundwater 

at the site, an analysis that had been started with annual 

appropriations.

Project classification dictates whether EM must follow Order 413.3B in 

implementing a project. Capital asset projects have to be managed 

according to the order, which established a management process with 

five major milestones—called critical decision points—involving multiple 

reviews and approvals. EM’s initiative allowed EM considerable flexibility 

in determining whether it classified some Recovery Act projects as capital 

asset or operation activity projects. EM does not have a clear policy that 

sets out under what conditions and how EM should break a capital asset 

project into smaller, discrete projects. According to EM’s initiative, the 

classification of capital asset and operation activity projects depends, in 

part, on project costs, with a total project cost of $10 million or more being 

classified as a capital asset project; below this threshold, the project is 

classified as an operation activity project.25

EM’s 2012 operations protocol provides considerable flexibility about 

what project management principles from Order 413.3B the office applies 

to operation activity projects. The protocol clarifies that critical decisions 

and another control mechanism required under Order 413.3B will not be 

In effect, this classification 

could allow EM to determine which projects would, or would not, be 

passing through critical decision points by breaking larger projects into 

smaller projects. According to EM’s initiative, EM would manage 

operation activity projects much as it does capital asset projects but 

would not use critical decision points.

 

25Cleanup work, the cost of which could determine its project type, includes construction 

projects and the construction phase of environmental remediation; the decommissioning 

of nuclear facilities, radiological facilities, and contaminated facilities; and, the demolition 

of nonnuclear facilities and noncontaminated facilities. Other cleanup work, such as 

operating a waste processing plant, is classified by its nature—regardless of its cost—as 

an operation activity project and not a capital asset project.

EM’s Initiative to 

Reclassify Projects
 

Page 29 GAO-13-23 DOE Recovery Act Cleanup Projects

applied to operation activity projects.26 Beyond addressing these specific 

exclusions from Order 413.3B, EM’s protocol states only that project 

management principles will be applied as appropriate and that some 

operations are project-like and others are routine or recurring 

operations.27 This distinction would seem to imply that at least routine and 

recurring operations may not appropriately be managed as projects with 

predetermined scope targets. According to an EM official, one advantage 

of separating operation activity projects from larger capital asset projects 

and the requirements of Order 413.3B is the greater flexibility to adjust 

the scope of operations—by slowing down or stopping work—to manage 

realized risks rather than having to apply contingency funds that have 

been set aside.28

Office of Project Management officials supported the concept behind the 

project management initiative, noting that it could be useful to break out 

projects into smaller, discrete capital asset projects. However, they 

This de-emphasis on managing to a scope target for 

operation activity projects is illustrated in a Recovery Act closure 

document for an Oak Ridge project. According to this document, key 

performance parameters are not applicable for this operation activity 

project, which had successfully met its objective of operating the waste 

treatment facilities at Oak Ridge National Laboratory at exactly the 

planned cost over the contract period. That is, this project’s success was 

defined in terms of operating within a cost and schedule—without 

reference to completing a defined scope.

 

26In addition to the management process in Order 413.3B, it contains another control 

mechanism, known as earned value management system, which provides a measure for 

gauging progress against a cost and schedule baseline. Earned value data in this system 

make it possible for managers and others to determine how a project has been performing 

and to predict future performance trends. DOE Order 413.3B (and its version applicable 

when the Recovery Act began in 2009) requires this system’s use for capital asset 

projects costing $20 million or more, and EM’s 2009 initiative also requires it for operation 

activity projects.

27EM’s first version of its operations protocol (April 2010) also established flexibility; that 

is, EM headquarters and the sites could reach an agreement on which project 

management principles from DOE’s order for capital asset projects would apply to 

operation activity projects. It further indicated that EM should apply more of the project 

management principles to project-like activities than to routine or recurring operations.

28EM’s 2010 version of its operations protocol, but not its 2012 revision, explicitly 

describes managing scope as a contingency: “If a program risk is realized and 

contingency is required, a baseline change proposal shall be processed to move scope to 

future years, or delete scope, if appropriate, from the baseline to remain within the funding 

target for the execution year or request additional funding.” 
 

Page 30 GAO-13-23 DOE Recovery Act Cleanup Projects

expressed concern that an integrated capital asset project could be 

inappropriately divided into smaller project fragments that would be 

classified as operation activity projects costing less than $10 million. As a 

result of such classification, they were concerned that these smaller 

projects would be subject to less stringent controls than required by Order 

413.3B.

Office of Project Management officials told us this classification issue 

arose on several occasions. At the Hanford and Savannah River Sites, 

Office of Project Management officials noticed scope within Recovery Actfunded operation activity projects that the office saw as integral to larger 

capital asset projects funded by annual appropriations. For example, at 

Hanford, EM had designated a project to remediate soil and groundwater 

contamination as an operation activity project, but EM officials told us that 

they determined, in consultation with the Office of Project Management, 

that about half of this $90 million project was, in fact, part of a capital 

asset project.29

 

29As noted earlier, some cleanup work, such as operating a waste processing plant, is 

classified by its nature—regardless of its cost—as an operation activity project and not a 

capital asset project.

According to Office of Project Management officials, EM 

was constructing wells and a groundwater pump and treatment facility 

that should be considered part of an existing capital asset project funded 

by annual appropriations, and only EM’s pumping and treating of 

contaminated water should be considered an operation activity project. In 

addition, closure documents indicated that the operation activity project 

had also included the construction of a maintenance facility complex that 

included utility upgrades, 27 mobile office and restroom facilities, and four 

shop and warehouse buildings of approximately 15,450 square feet each. 

In another project—to clean up contaminated soil and buildings at the 

SLAC National Accelerator Laboratory in California—Office of Project 

Management officials told us that they and EM officials originally agreed 

that the project was a capital asset project. The project was to cost 

approximately $30 million using both Recovery Act and annual 

appropriations. However, EM subsequently divided the project’s scope 

into 18 separate operation activity projects, each costing under $10 

million. Furthermore, according to our analysis of EM documents on the 

Recovery Act-funded portion of the overall project, EM took advantage of 

the flexibility under the initiative to create a Recovery Act project costing 

$8 million and designated it as an operation activity project. However, EM 

later added to the scope and increased the Recovery Act funding to this 
 

Page 31 GAO-13-23 DOE Recovery Act Cleanup Projects

project, increasing its cost at completion to almost $16 million, but the 

office never reclassified the project as a capital asset project.

Office of Project Management officials did not know how many Recovery 

Act operation activity projects might actually be part of a capital asset 

project because projects that EM starts as operation activity projects are 

not likely to be reviewed by the Office of Project Management, which 

does not participate in the classification of operation activity projects. 

Moreover, these officials expressed concerns that EM may be 

misclassifying capital asset projects as operation activity projects, with the

result that projects are implemented without the appropriate project 

controls required by Order 413.3B. They said the disagreement over 

project classifications applies to work funded by both EM’s Recovery Act 

and annual appropriations. In a report about its partnership with EM to 

help improve project management on some projects funded by annual 

appropriations, the Army Corps of Engineers made similar observations, 

stating that the Corps had observed EM efforts to disaggregate projects 

by size and type to avoid the application of Order 413.3B for project 

management. According to the report, these practices of overly 

subdividing projects are inconsistent with good project management 

practice and can result in a fragmented view of overall project health.30

In contrast, EM officials stated that EM appropriately avoids critical 

decision points for an aptly classified operation activity project, and the 

more streamlined decision making does not preclude managing the 

project in accordance with best project management principles. 

Particularly given the pressure to quickly execute Recovery Act projects, 

according to another EM official, being freed from formal critical decision 

steps required by the order allowed EM to more quickly start operation 

activity projects. However, without a clear principle for establishing the 

boundaries of project scope, the expediency of avoiding the requirements 

of Order 413.3B could become the decisive factor in classifying work as 

not a capital asset project. For instance, a project review team at the 

Idaho National Laboratory suggested that the site consider subdividing 

the financial accounts of a Recovery Act-funded capital asset project with 

an aggregate cost of over $10 million—separating the demolishment of 

shielded rooms for working with radioactive materials (hot cells) from the 

 

30U.S. Army Corps of Engineers, Report to the Department of Energy, Office of 

Environmental Management: Analysis of USACE-DOE Project Management Partnership 

Potential (Washington, DC: June 3, 2011).
 

Page 32 GAO-13-23 DOE Recovery Act Cleanup Projects

demolishment of the surrounding building—because as a capital asset 

project, the work must follow the Order 413.3B requirement for a critical 

decision point approval, potentially delaying the project’s execution by 

several months.

EM has been analyzing which lessons learned from its Recovery Act 

program are applicable to other cleanup efforts. EM has gathered lessons 

learned from the 17 sites on Recovery Act projects and plans to report on 

lessons learned in August 2012, according to the Director of EM’s 

Recovery Act Program Office.

EM may be able to use some of the materials that the sites submitted to 

identify lessons learned to improve project management, particularly in 

areas that have been problems in the past, such as early planning and 

contracting, which DOE determined it had addressed as part of DOE’s 

corrective action plan. Some examples are as follows:

• Early planning. Some of the lessons learned reported as of June 2012 

discussed how early planning can affect a project’s success. For 

example, before demolishing an obsolete nuclear research building at 

Los Alamos National Laboratory, managers for the Recovery Act 

project coordinated with managers for a project funded by annual 

appropriations responsible for remediating under-building soil and 

developed a characterization plan for the potentially contaminated soil 

under the building’s basement concrete floor. Early work showed that 

no contaminants needed to be removed, enabling the site to place 

uncontaminated fill into this basement rather than undertaking a more 

costly removal of the basement’s walls and floor that would have 

involved greater safety risks for workers. Conversely, at the SLAC 

National Accelerator Laboratory, sufficient early site characterization 

of contaminated soil had not been performed before starting 

excavation. Without this characterization, the project experienced 

costly downtime for work crews when more contamination was found 

at the edges of the initial excavation and further characterization had 

to be done.

• Contracting. Some of the lessons learned discussed the importance of 

using an appropriate type of contract for the work to be performed—

Some of EM’s Lessons 

Learned May Be 

Applicable to Other EM 

Projects
 

Page 33 GAO-13-23 DOE Recovery Act Cleanup Projects

specifically fixed-price contracts or cost reimbursement contracts.31

According to the lessons learned, DOE’s use of fixed-price contracting 

was appropriate when projects were, among other things, welldefined. When projects were not well-defined, however, cost overruns 

and schedule delays could occur under such a contract. For example, 

one lesson learned stated that a fixed-price contract worked well for 

the demolition of the Oak Ridge site’s K-33 building, a former uranium 

enrichment facility, because the project’s well-defined scope limited 

the possibility of unexpected conditions, changes to the contract, and 

cost adjustments. The Los Alamos National Laboratory, however, 

used a fixed-price contract for a landfill excavation project that did not 

have a well-defined scope, and significant cost adjustments resulted 

when the contractor found unexpected types and volumes of waste.

Other lessons may have limited applicability to non-Recovery Act work 

because they address issues specific to EM’s Recovery Act program. For 

example, some lessons learned address personnel issues, such as 

methods to rapidly hire and train large numbers of new employees for a 

window of a few years of Recovery Act funding. These lessons learned 

may not be applicable unless EM receives another large-scale boost in 

funding for environmental cleanup projects. Similarly, a few lessons 

learned that addressed methods of coordinating the new Recovery Act 

projects with projects funded by annual appropriations may have limited 

use after Recovery Act funding is exhausted.

Furthermore, some lessons learned may have resulted from unique 

circumstances that also may not be replicated in future EM projects. For 

instance, one Savannah River Site official said that depressed market 

conditions resulted in very strong competition among subcontractors for 

work to decommission reactors; as a result, the site contracted for the 

work at a price that was lower than expected. Another official at 

Savannah River told us that the site was able to negotiate a unit cost for 

waste treatment that was about 40 percent below the cost expected when 

the Recovery Act project’s performance baseline was set. In this case, 

the official said there is no lesson learned about cost savings for future 

 

31Under a cost-reimbursement contract, the government pays a contractor’s allowable 

incurred costs to the extent provided in the contract, regardless of whether the work is 

completed. Under a fixed-price contract, a contractor accepts responsibility for completing 

a defined amount of work for a fixed price, which places the risk of cost overruns on the 

contractor rather than the government.
 

Page 34 GAO-13-23 DOE Recovery Act Cleanup Projects

projects because the Recovery Act funding allowed the site to get the 

reduced rates by sending higher volumes of waste for treatment, but after 

the Recovery Act funds are expended and volumes of waste treated are 

reduced, the site will not be able to get the lower rates. In addition, EM 

selected shovel-ready projects that it expected could be completed 

quickly, and these lessons therefore may not be applicable to its more 

complex projects.

The main features of EM’s initiative—such as breaking projects into 

smaller and shorter-term capital asset projects and operation activity 

projects and increasing project oversight—were not addressed in the 

lessons learned that had been developed through June 2012. EM did not 

specifically ask sites to comment on how the initiative affected their ability 

to manage Recovery Act projects, and the sites did not so comment. 

However, without lessons learned about the initiative, EM may not be 

able to determine whether this initiative will better support its cleanup 

efforts in the future. Furthermore, in response to our 2010 

recommendation for EM to assess project management and oversight 

steps adopted for Recovery Act projects, EM stated it would determine 

whether such steps, such as the initiative, have proven beneficial for 

Recovery Act projects and whether they would be effective and 

appropriate for cleanup projects funded by annual appropriations.32 In 

May 2012, EM officials told us that a quantitative study has not yet been 

done to do such an assessment, but that it will be based on the lessons 

learned submitted by the sites. However, these lessons learned as of 

June 2012 have not focused on the effectiveness of the initiative.

When EM received $6 billion in Recovery Act funds—an amount nearly 

equal to its 2009 annual appropriation for its cleanup efforts—it faced a 

daunting task to quickly plan and begin this cleanup work. EM was 

generally successful in several areas—quickly selecting and starting 

dozens of cleanup projects, funding thousands of FTEs, accelerating 

cleanup work, and reducing the number of remaining facilities and the 

size of the areas needing to be cleaned up. Of the projects completed, 

most were completed at a lower-than-planned cost—some projects so 

much so that they raised questions about whether EM has effectively 

 

32GAO, Recovery Act: Most DOE Cleanup Projects Appear to Be Meeting Cost and 

Schedule Targets, but Assessing Impact of Spending Remains a Challenge GAO-10-784 

(Washington, D.C.: July 29, 2010).

Conclusions 
 

Page 35 GAO-13-23 DOE Recovery Act Cleanup Projects

addressed its long-standing challenge of developing realistic performance 

baselines.

The Recovery Act-funded work is almost complete, but effective EM 

project management remains a critical area because completing EM’s 

cleanup work will take decades and cost billions of dollars. First used for 

Recovery Act projects, the new initiative—which breaks large projects into 

smaller projects to better manage them—holds potential as a way to help 

improve DOE project management. The guidance describing how 

projects can be broken out, however, does not clearly set out the 

conditions under which and how EM should break a capital asset project 

into smaller, discrete projects. Without a clear policy guiding how a 

project should be broken out, the initiative could allow managers to avoid 

DOE’s more stringent Order 413.3B project controls by classifying some 

larger capital asset projects as smaller operation activity projects. Officials 

in the Office of Project Management, who are responsible for project 

management policy, told us that they did not know how many Recovery 

Act operation activity projects might actually be part of capital asset 

projects and have expressed concern that, under the initiative, some 

capital asset projects had been broken into operation activity projects in a 

way that bypasses project controls required by Order 413.3B. The project 

controls, established to improve project management, are only required 

for capital asset projects. Order 413.3B has been an important step in 

DOE’s efforts to improve project management. Even this order and 

associated guides, however, do not adequately address how to develop 

key performance parameters for capital asset cleanup projects or provide 

examples of such parameters in a way that would help ensure that scope 

is always defined so that it would help officials and others accurately 

assess project performance. EM’s 2012 operations protocol, the guidance 

for operation activity projects, is less specific than Order 413.3B and 

allows for wide variation in how and when performance baselines are 

established and documented. Without sufficient project controls and 

sufficient guidance to ensure that specific performance baselines are 

established at a consistent point in a project’s development and clearly 

documented, it may continue to be difficult for EM and others to assess 

project performance, as we have previously reported.

To help ensure that EM more effectively manages all its projects, we 

recommend that the Secretary of Energy direct the Senior Advisor for 

Environmental Management and the Director of the Office of 

Management, as appropriate, to take the following four actions: 

Recommendations for 

Executive Action
 

Page 36 GAO-13-23 DOE Recovery Act Cleanup Projects

• Develop and issue a policy that clearly sets out the criteria with more 

specificity for reclassifying capital asset projects over $10 million into 

smaller operation activity projects under $10 million in value.

• Provide the Office of Acquisition and Project Management with 

information on EM’s project classification decisions to ensure that all 

capital asset projects have been appropriately classified and are 

managed in accordance with DOE Order 413.3B. 

• Develop guidance to supplement DOE Order 413.3B to explain how 

EM should develop scope targets—specifically key performance 

parameters—for capital asset cleanup projects and include specific 

examples for such parameters to help ensure that scope is always 

defined in a way that it would help officials and others accurately 

assess project performance, including cleanup projects.

• Clarify guidance for operation activity projects to specify how and 

when performance baselines (i.e., for scope, cost, and schedule

targets), which EM calls key performance metrics for operations 

activity projects, are to be established and documented to help ensure 

consistent assessment of performance.

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

written comments, which are reproduced in appendix III, DOE did not 

comment on the report findings but agreed with the recommendations in 

our report, subject to some wording modifications. We incorporated most 

of DOE’s suggested wording changes. However, DOE objected to our 

referring to operation activity projects as “projects” because it wants to 

avoid any confusion about the applicability of its project management 

order that applies to only capital asset projects. We understand the 

distinction DOE is making and explained that distinction in the report. For 

purposes of this report, we refer to the operation activities as projects 

because we are collectively referring to all Recovery-Act funded efforts as 

projects. DOE also provided technical comments, which we incorporated 

as appropriate.

We are sending copies of this report to the Secretary of Energy, 

appropriate congressional committees, and other interested parties. In 

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

http://www.gao.gov

Agency Comments 

and Our Evaluation
 

Page 37 GAO-13-23 DOE Recovery Act Cleanup Projects

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

contact me at (202) 512-3841 or gaffiganm@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix IV. 

Mark Gaffigan

Managing Director, Natural Resources and Environment
 

Page 38 GAO-13-23 DOE Recovery Act Cleanup Projects

List of Committees

The Honorable Carl Levin

Chairman

The Honorable John McCain

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Joseph I. Lieberman

Chairman

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Dianne Feinstein

Chairman

The Honorable Lamar Alexander

Ranking Member

Subcommittee on Energy and Water Development

Committee on Appropriations

United States Senate

The Honorable Howard P. McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Darrel E. Issa

Chairman

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives
 

Page 39 GAO-13-23 DOE Recovery Act Cleanup Projects

The Honorable Rodney P. Frelinghuysen

Chairman

The Honorable Peter Visclosky

Ranking Member

Subcommittee on Energy and Water Development

Committee on Appropriations

House of Representatives
Appendix I: Objectives, Scope and 

Methodology

Page 40 GAO-13-23 DOE Recovery Act Cleanup Projects

To determine the number of full-time equivalent (FTE) jobs the 

Department of Energy’s (DOE) Office of Environmental Management 

(EM) funded with Recovery Act funds from October 2009 through March 

2012, we reviewed pertinent provisions of the American Recovery and 

Reinvestment Act of 2009 and Office of Management and Budget (OMB) 

guidance on reporting FTEs. We obtained data from EM on the number of 

FTEs that EM’s contractors reported to the government’s official 

Recovery Act website since October 2009. To assess the accuracy of the 

FTE data, we discussed DOE’s process for reviewing these data with 

officials from DOE’s Office of the Chief Financial Officer and EM’s 

Recovery Act Program Office. These officials told us that DOE does 

accuracy reviews, including EM’s comparison of the information 

contractors submitted to the website with the information that contractors 

provide directly to EM site officials. We also compared the quarterly FTE 

data that EM provided us from the government website with two other 

sources—from the Recovery.gov website, as downloaded by GAO, and 

from contractors, as directly collected by EM at sites. The FTE counts 

from the three sources generally do not vary more than a few percentage 

points. In accordance with Recovery Act reporting requirements, prime 

contractors reported only prime, and not subcontractor, FTEs for the first 

and second quarters of fiscal year 2010.1

To determine the status of EM’s Recovery Act-funded cleanup projects 

and the extent to which completed projects met performance baselines, 

we reviewed pertinent DOE and EM policies and guidance on project 

management, including for Recovery Act projects; analyzed project 

documents and data recorded in EM’s corporate database—called the 

Integrated Planning, Accountability, and Budgeting System (IPABS); and 

interviewed DOE, EM, EM’s Recovery Act Program Office, and Office of 

To provide a meaningful FTE 

trend, we used subcontractor FTEs reported by EM sites for those two 

quarters to reconstruct a combined total for prime and subcontractors. We 

believe the counts for subcontractors are sufficiently reliable for the 

purposes of this report because the site-reported counts for prime 

contractors’ FTEs for the same quarters are no more than 5 percent 

different than the numbers in the government’s website. Overall, on the 

basis of these steps, we concluded the FTE data included in our report 

are sufficiently reliable for our reporting purposes. 

 

1

Only starting in the third quarter of fiscal year 2010 were EM prime contractors at each 

site required to report FTEs for both prime and subcontractors combined.

Appendix I: Objectives, Scope and 

Methodology 
Appendix I: Objectives, Scope and 

Methodology

Page 41 GAO-13-23 DOE Recovery Act Cleanup Projects

Project Management officials. We reviewed data for both original 

Recovery Act projects and additional projects, known as buy-back 

projects, which were started later when some original projects finished 

with unused funds.2 We selected a nonprobability sample of two EM 

cleanup sites to visit in order to better understand how sites manage their 

Recovery Act projects.3

To assess project performance, we evaluated Recovery Act fundedprojects that were complete. Specifically, we obtained EM’s performance 

analysis and its approved project closure packages for projects that were 

administratively complete by April 30, 2012—that is, projects complete 

both in terms of cleanup work and closure paperwork. Using the 

assessment procedures that EM’s Recovery Act Program Office stated it 

would apply to Recovery Act projects, we compared the scope, cost, and 

schedule targets in performance baselines with actual scope, cost, and 

schedule when the project was complete. We used DOE criteria to 

measure project performance. Specifically, projects should be completed 

within the planned scope, and within 110 percent of the cost target at 

project completion, unless otherwise impacted by a directed change.

These sites—the Hanford Site and the Oak Ridge 

Reservation—together were allotted about $2.7 billion of the total $6 

billion in Recovery Act funding for environmental cleanup. At each site 

visited, we reviewed project documentation, interviewed officials, and 

observed Recovery Act work under way.

4

 

2

We did not count as projects any of three project codes that EM identified as payment 

activities, such as for Recovery Act administrative purposes, or “embedded buyback 

activities” that involved using a project’s excess funds to do additional scope managed 

under its existing project code.

We 

discussed projects with EM Recovery Act officials when our assessment 

of project performance differed from EM’s to identify the reasons for the 

differences. Because we found that the schedule targets for Recovery Act 

projects were generally not specific to the projects, which is necessary for 

a meaningful assessment, we chose to discuss this issue in the report but 

do not draw conclusions about the extent to which projects met schedule 

3

Because this was a nonprobability sample, the information derived from our site visits is 

not generalizeable to all EM cleanup sites but provides illustrative examples of how sites 

manage their Recovery Act projects.

4

According to DOE Order 413.3B, a directed change is a change caused by some DOE 

policy directives (such as those that have force and effect of law and regulation), 

regulatory, or statutory action and is initiated by entities external to the Department, to 

include external funding reductions.
Appendix I: Objectives, Scope and 

Methodology

Page 42 GAO-13-23 DOE Recovery Act Cleanup Projects

targets. We also interviewed EM officials about the reliability of the IPABS 

database because of its use to document performance baselines for 

operation activity projects. We believe the data are insufficiently reliable 

for the purposes of drawing conclusions about the extent to which 

projects met schedule targets, but are otherwise sufficiently reliable for 

assessing overall project performance in conjunction with other data we 

obtained.

To identify management issues, if any, that arose during EM’s Recovery 

Act projects and any lessons EM has learned that it could apply to other 

cleanup efforts, we reviewed GAO reports, including our High-Risk 

series,5

 

5

See 

which discuss EM project management issues; DOE reports and 

other documents, including DOE’s root cause analysis and corrective 

action plan; and other recent reports and documents addressing 

previously identified EM project management issues. We also reviewed 

EM Recovery Act Program Portfolio Management Framework (2009), its 

2010 and 2012 operations protocols, and other documents to understand 

the management issues that the initiative was intended to address. To 

identify any management issues that arose during EM’s Recovery Act 

program, we examined project closure documents and interviewed EM

and Office of Project Management officials. With regard to lessons 

learned, because EM was still in the process of gathering and assessing 

lessons learned for inclusion in a report to be issued in August 2012, we 

were unable to determine what EM considered the lessons learned from 

its Recovery Act program. To understand EM’s potential lessons learned, 

we reviewed the materials that sites submitted about Recovery Act 

projects. Specifically, we reviewed lessons learned captured in EM’s 

lessons learned database. We also attended EM’s lessons learned 

“information exchange” conference held on March 1, 2012, and reviewed 

presentations given. All 17 sites receiving Recovery Act funding 

submitted lessons to the database or at the conference. We analyzed the 

lessons learned to see if each addressed one or more of areas of 

possible improvement identified by EM or others. In addition, we reviewed 

the lessons learned to evaluate the potential for applying them to other 

EM cleanup projects and discussed this issue with EM officials. We also 

determined if any of the lessons addressed the effectiveness or other 

aspects of the initiative for EM’s Recovery Act projects, such as 

implementing smaller, shorter-term projects, breaking larger EM projects 

GAO-11-278. 
Appendix I: Objectives, Scope and 

Methodology

Page 43 GAO-13-23 DOE Recovery Act Cleanup Projects

into capital asset and operation activity projects, increasing project 

oversight and reporting, and for disbursing Recovery Act funding in 

phases.

We conducted this performance audit from May 2011 to October 2012 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Administratively Completed 

Recovery Act Projects Available for GAO 

Analysis as of April 30, 2012

Page 44 GAO-13-23 DOE Recovery Act Cleanup Projects

Project number Project description

Argonne National Laboratory (IL)

1. CH-ANLE-0040.NEW.R1.1 Building 310

2. CH-ANLE-0040.NEW.R1.2 Building 330

3. CH-ANLE-0040.NEW.R1.3 AGHCF waste & materials disposition

4. CH-ANLE-0040.NEW.R1.4 TRU Waste Disposition

Brookhaven National Laboratory (NY)

5. BRNL-0040.R1 Graphite Research Reactor D&D

6. BRNL-0041.R1 High Flux Beam Reactor

7. BRNL-0041.NEW.R1 High Flux Beam Reactor

Energy Technical Engineering Center (CA)

8. CBC-ETEC-0040.R1.2 Area IV Soil and Groundwater Remediation

Hanford Site – Office of River Protection (WA)

9. ORP-0014.R1.1 Tank Farm Infrastructure Upgrades

10. ORP-0014.R1.2 Other Infrastructure Upgrades

11. ORP-0014.R1.3 Facility Upgrades

12. ORP-0014.R1.4 Waste Feed Infrastructure Upgrades

13. ORP-0014.R1.5 SY Transfer Line Upgrade

Hanford Site – Richland Office (WA)

14. RL-0013C.R1.1 MLLW Treatment

15. RL-0013C.R1.2 TRU Waste

16. RL-0030.R1.1 Soil & Groundwater Treatment

17. RL-0030.R1.2a Soil & Groundwater Operation Activities

18. RL-0040.R1.2 Outer Zone D&D

19. RL-0041.R1.1 100 K Area Remediation

20. RL-0041.R1.2 ERDF Cell Expansion

21. RL-0041.R1.3 Accelerated Remediation & Disposal

22. RL-0041.R1.4 Super Cell 10

23. RL-0041.R2 618-10 Trench Remediation

Idaho National Laboratory (ID)

24. ID-0013.R1 TRU Waste

25. ID-0030B.R1.1 Buried Waste

26. ID-0030B.R1.2 In Situ Grouting

27. ID-0030B.R1.3 Soil & Groundwater Operations

28. ID-0030B.R1.4 Soil & Groundwater Buy-Back

29. ID-0040B.R1.1 D&D (NTB)

Appendix II: Administratively Completed 

Recovery Act Projects Available for GAO 

Analysis as of April 30, 2012
Appendix II: Administratively Completed 

Recovery Act Projects Available for GAO 

Analysis as of April 30, 2012

Page 45 GAO-13-23 DOE Recovery Act Cleanup Projects

Project number Project description

Los Alamos National Laboratory (NM)

30. VL-LANL-0030.R1.2 Monitory Well Installation Program

31. VL-LANL-0040-D.R1.1 D&D - TA-21

32. VL-LANL-0040-N.R1.1 D&D-TSTA

33. VL-LANL-0040-N.R1.2 D&D-Non Def Buy-Back

Moab UMTRA Site (UT)

34. CBC-MOAB-0031.R1 Moab Recovery Act Project

Mound Site (OH)

35. OH-MB-0031.NEW.R1 Mound Operable Unit 1 

Nevada National Security Site (NV) 

36. VL-NV-0030.R1 Soil and Water Remediation

37. VL-NV-0030.R2 NNSS ARRA Buy-Back 

Oak Ridge National Laboratory (TN)

38. OR-0040.R1.1 K-27 Demolition Preparation

39. OR-0040.R1.2 K-33 Demolition

40. OR-0041.NEW.R1.1 Y-12 Excess Material Disposition

41. OR-0041.NEW.R1.2 Y-12 Biology Complex

42. OR-0041.NEW.R1.3 Y-12 9206 Filter House D&D 

43. OR-0041.R1.1 Y-12 Facility D&D

44. OR-0041.R1.3 Disposal Facility Expansion - EMWMF 

Expansion

45. OR-0041.R1.4 Disposal Facility Expansion-Sanitary Landfill 

Expansion

46. OR-0042.R1.2 Facility Demolition - Building 3026/Wooden 

Facilities

47. OR-0042.R1.3 Defense Remedial Actions

48. OR-0042.R1.5 ORNL Bethel Valley Burial Grounds

49 OR-0042.R1.10 ORNL Waste Operations

50. OR-0042.NEW.R2.2 ORNL Non-Defense Misc. Facility Demolition 

– 2000 Complex

Paducah Site (KY)

51. PA-0040.R1.1 C-410 D&D

52. PA-0040.R1.2 C-340 D&D

53. PA-0040.R1.3 C-746-A D&D

54. PA-0040.R1.4 Paducah Buy-Back

Portsmouth Site (OH)

55. PO-0013.R1.1 UMC Disposition

56. PO-0040.R1.1 X-701B Plume Remediation
Appendix II: Administratively Completed 

Recovery Act Projects Available for GAO 

Analysis as of April 30, 2012

Page 46 GAO-13-23 DOE Recovery Act Cleanup Projects

Project number Project description

57. PO-0040.R1.2 X-533 D&D

58. PO-0040.R1.3 X-633 D&D

59. PO-0040.R1.4 X-760 D&D

60. PO-0040.R1.5 D&D Buy-Back 

61. PO-0040.R1.6 Waste Disposal Buy-Back

Savannah River Site (SC)

62. SR-0013.R1.1 Solid Waste Disposition

63. SR-0014C.R1.1 Liquid Waste Systems Recapitalization

64. SR-0014C.R1.2 Saltstone Disposal Unit #2

65. SR-0030.R1.2 P Reactor Decommissioning Project

66. SR-0030.R1.3 P Ash Basin Remediation Project

67. SR-0030.R1.4 R Reactor Decommissioning Project

68. SR-0030.R1.5 R Ash Basin Remedial Action Project

69. SR-0030.R2.1 M and D Area Completion GPP and 

Operations

70. SR-0030.R3.1 Site Wide Completion GPPs and Operations

71. SR-0030.R3.2 Heavy Water Components Test Reactor 

Decommissioning Project

72. SR-0040.R1 Inactive facility S&M

SLAC National Accelerator Laboratory (CA)

73. CBC-SLAC-0030.R1 SLAC Recovery Act Project

Separations Process Research Unit (NY)

74. VL-SPRU-0040.R1.1 Building G2 and H2 D&D

75. VL-SPRU-0040.R1.2 Contaminated Soil Removal - North Field

West Valley Demonstration Project (NY)

76. OH-WV-0013.R1 TRU and Solid Waste 

77. OH-WV-0040.R1.1 Main Plant D&D

78. OH-WV-0040.R1.2 Other D&D

Source: GAO analysis of DOE data.

a

In a closure document, EM designated a portion of the scope of RL-0030.R1.2 as RL-0030.R1.3, We 

are referring to both projects as the single project RL-0030.R1.2 because an EM official explained 

that they were managed as a single project with a single baseline.
Appendix III: Comments from the Department 

of Energy

Page 47 GAO-13-23 DOE Recovery Act Cleanup Projects

Appendix III: Comments from the 

Department of Energy
Appendix III: Comments from the Department 

of Energy

Page 48 GAO-13-23 DOE Recovery Act Cleanup Projects
Appendix III: Comments from the Department 

of Energy

Page 49 GAO-13-23 DOE Recovery Act Cleanup Projects
Appendix III: Comments from the Department 

of Energy

Page 50 GAO-13-23 DOE Recovery Act Cleanup Projects
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 51 GAO-13-23 DOE Recovery Act Cleanup Projects

Mark Gaffigan (202) 512-3841, or gaffiganm@gao.gov

In addition to the individual named above, the following staff members 

made key contributions to this report: Janet Frisch, Assistant Director; 

Thomas Beall; Antoinette Capaccio; Ellen W. Chu; Eli DeVan; James 

Espinoza; Terry Hanford; Yvonne Jones; Eli Lewine; Mehrzad Nadji; 

Josie Ostrander; Carol Patey, Anne Rhodes-Kline; Beverly Ross; Carol 

Herrnstadt Shulman; Jonathan Stehle; and Kiki Theodoropoulos.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(361286)
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