Nuclear Cleanup: Actions Needed to Improve Cleanup Efforts at DOE's Three Former Gaseous Diffusion Plants

Cleaning up DOE's former uranium enrichment sites will cost billions of dollars and span decades. These sites, near Oak Ridge, Tennessee; Paducah, Kentucky; and Portsmouth, Ohio, are contaminated with radioactive and hazardous materials. EM is responsible for their cleanup.

This report examines (1) the extent to which EM has managed cleanup of the GDPs compared with relevant program management leading practices and the status of the cleanup effort; (2) what EM has spent on cleanup at the GDPs, and the extent to which EM's cost estimates for completing GDP cleanup are reliable; and (3) the extent to which the D&D Fund is sufficient to cover EM's estimated cleanup costs of the GDPs and challenges, if any, that could affect the sufficiency of the fund. GAO reviewed relevant legislation and DOE reports to Congress on GDP cleanup; compared program management to relevant leading practices; assessed EM expenditure and cost estimation documents; and interviewed EM and state regulatory officials at the three GDPs.

Since 2007, the Department of Energy (DOE) has stated in reports to Congress that it intends to manage its three former gaseous diffusion plants (GDP) in an integrated manner. Also, a Decontamination and Decommissioning (D&D) Fund was established by law to pay for the cleanup costs of the GDP sites, so that DOE's Office of Environmental Management (EM) must coordinate and make trade-offs in its use of resources among the three GDPs. However, EM has managed the cleanup of the three GDPs as three individual sites. In addition, EM is not following relevant leading practices GAO reviewed for managing the cleanup as a program (having a program management plan; a reliable integrated master schedule; and a reliable, integrated, comprehensive life-cycle cost estimate. By managing the three GDPs as an integrated program and following these program management leading practices, EM would have more reasonable assurance that it is taking every opportunity to increase the efficiency and effectiveness of its management activities.

EM has reported spending a total of about $15.5 billion on GDP cleanup as of fiscal year 2018. However, EM's cost estimates for completing cleanup at the three sites are not reliable. GAO assessed EM's cost estimates for the GDPs individually by comparing them with best practices for developing high-quality, reliable cost estimates. EM's cost estimates for completing cleanup of the GDPs do not fully or substantially meet all of the characteristics of a reliable cost estimate Until EM ensures that its site-specific cost estimates fully incorporate best practices for cost estimation, EM, DOE, regulators, and Congress will not have the information needed to understand the level of resources required to achieve cleanup of the three GDPs.

Under EM's current cost estimates, remaining GDP cleanup costs exceed the balance of the D&D Fund by at least $25 billion and EM faces challenges that could affect cleanup progress and the sufficiency of the fund. For example, DOE's reporting to Congress on the sufficiency of the D&D Fund is based on old financial data, incomplete information, and unclear scope. These limitations reduce the quality of the information Congress receives for making decisions about the sufficiency of the fund and allocating resources to the fund. For example, DOE reported to Congress on the status of the D&D fund and GDP cleanup in May 2019. The report was based on financial data as of September 2016 and on cost estimates prepared in 2013 for one GDP and in 2014 for the other two. Given that DOE estimates the fund will be exhausted in 2020, there is urgency for DOE to communicate current information on the fund on a timely basis to Congress. By regularly reporting on the status of the D&D Fund and cleanup efforts at the three GDPs with current information that contains details on challenges in reaching agreement with regulators and a clear scope of work, DOE will be able to provide better information for congressional decision-making on the sufficiency of the fund.

GAO is making five recommendations, including that DOE (1) manage the cleanup of the three GDPs as an integrated program and follow program management leading practices, (2) ensure cost estimates fully incorporate cost estimating best practices, and (3) report regularly on the status of the D&D Fund and cleanup efforts at the three GDPs. DOE agreed with four of them and partially agreed with one. GAO believes all of the recommendations should be implemented at all three sites.

Completing cleanup at the Department of Energy’s (DOE) three former  uranium enrichment sites will cost billions of dollars and span decades.  Located near Oak Ridge, Tennessee; Paducah, Kentucky; and  Portsmouth, Ohio, these former uranium enrichment sites—referred to as  gaseous diffusion plants (GDP) because they relied on gaseous diffusion  technology to enrich uranium—were built starting in the 1940s.  Contaminated with radioactive and hazardous materials, the three GDPs  encompass more than 30 million square feet of floor space, use miles of  interconnecting pipes, and thousands of acres of land. All three GDPs  ceased operations by 2013, and DOE’s Office of Environmental  Management (EM) is responsible for their cleanup. Cleanup activities  include assessing, treating, and disposing of contamination;  decontaminating and decommissioning (D&D) buildings and facilities; and  cleaning up soil, surface water, and groundwater, which are considered  remediation activities. EM conducts GDP cleanup activities under the  requirements of several federal environmental laws as well as site- specific agreements with the Environmental Protection Agency (EPA) and  state regulatory agencies.

The Energy Policy Act of 1992, as amended, established the Uranium  Enrichment Decontamination and Decommissioning Fund (D&D Fund) to  pay for cleanup at the three GDP sites. In its 2019 Triennial Report to  Congress (hereafter referred to as the 2019 triennial report), DOE stated  that as of September 2016—the financial reporting period end date of the  report—the D&D Fund had a projected shortfall of $26.6 billion and was  predicted to be exhausted by 2020. EM’s GDP cleanup costs represent  one aspect of the federal government’s overall environmental liabilities,  which are the costs the federal government bears for cleaning up legacy  contamination for which it is responsible.

In February 2017, we placed the federal government’s environmental  liabilities on our high-risk list of agencies and program areas vulnerable to  fraud, waste, abuse, and mismanagement or most in need of  transformation. In fiscal year 2018, DOE reported that its total  environmental liabilities were $494 billion (in constant fiscal year 2018  dollars), representing more than 85 percent of the U.S. government’s  overall environmental liability. The GDP cleanup accounts for a portion of  this overall liability.

You asked us to review the D&D Fund and the status of cleanup at the  three GDPs. This report examines (1) the extent to which DOE’s EM has  managed the cleanup of the three GDPs compared with relevant program  management leading practices and the status of the cleanup effort; (2)  what EM has spent on cleanup at the three GDPs and the extent to which  EM’s cost estimates for completing GDP cleanup are reliable; and (3) the  extent to which the D&D Fund is sufficient to cover EM’s estimated  cleanup costs of the GDPs and challenges, if any, that could affect the  sufficiency of the fund.

To inform all three objectives, we reviewed the Energy Policy Act of 1992,  as amended; DOE triennial reports to Congress on GDP cleanup efforts;  and prior reports issued by us, DOE’s Office of Inspector General (both  performance audits and financial statement audits on the D&D Fund), and  the National Academies of Sciences, Engineering, and Medicine (National  Academies). We also interviewed officials from DOE’s Office of Inspector  General, EPA, and representatives of the National Academies, regarding  their knowledge of EM’s cleanup progress at the GDPs and any past,  ongoing, or future work they have conducted or are planning on the GDP  cleanup. We visited all three GDP sites to observe the cleanup work and  interviewed EM officials responsible for the cleanup, representatives of  the DOE contractor responsible for D&D activities, state regulators  working with EM on environmental compliance activities (from Kentucky,  Ohio, and Tennessee), members of GDP site-specific advisory boards,  and representatives of community reuse organizations. Following these  interviews, we conducted a content analysis of all responses to our  interview questions to determine any key challenges EM faces in  completing cleanup of the GDPs.

To examine the extent to which EM has managed the cleanup of the  GDPs compared with program management leading practices and the  status of the cleanup effort, we reviewed documents, including site- specific GDP cleanup plans and GDP cleanup progress briefings, as well  as reports issued by the National Academies, us, and DOE. We  interviewed EM officials and contractor representatives on their past,  present, and future plans for cleanup. We also interviewed EPA and state  regulatory agency representatives at each of the GDPs regarding their  role in the cleanup and interactions with EM. We assessed the  information from our document reviews and all interviews (content  analysis from interview responses) and aligned the assessed information  with relevant program management leading practices. We identified the  three program management leading practices by reviewing our prior work  and the Project Management Institute’s (PMI) The Standard for Program  Management—Fourth Edition. The three leading practices were having  (1) a program management plan, (2) an integrated master schedule, and  (3) a reliable, integrated, comprehensive life-cycle cost estimate. We  compared EM’s management of the GDPs with these leading practices.  To examine the status of cleanup at the GDPs, we reviewed EM’s  documentation of the cleanup work completed and the work remaining at  each GDP.

To examine what EM has spent on cleanup at the three GDP sites, and  the extent to which EM’s cost estimates for completing GDP cleanup are  reliable, we reviewed historical funding and cleanup expenditure data for  all three sites for fiscal years 1994 through 2018 and analyzed EM  documentation supporting cost estimates for each of the three GDPs. We  reviewed financial statement audit reports issued on the D&D Fund for  fiscal years 2005 to 2012. We also met with relevant headquarters and  field financial management, budget, and planning staff. In addition, we  assessed the reliability of the historical funding and expenditure data  provided by EM by obtaining, from EM officials familiar with DOE’s  financial management system, responses to a series of data reliability  questions on data entry access, quality control procedures, and the  accuracy and completeness of the data. Based on these responses, we  found the data to be sufficiently reliable for purposes of our reporting  objective. To examine the reliability of EM’s cost estimates for completing  cleanup at the three GDPs, we reviewed EM’s cost estimate  documentation, interviewed EM site officials, and compared GDP cost  estimates against characteristics of reliable cost estimates contained in  our Cost Estimating Guide. We reviewed agency documents that  established the basis and assumptions for site contractors’ contributions  to the cost estimates; the contractors’ work breakdown structures; and  presentations on the contractors’ cost estimating models. We shared our  draft assessment for each GDP cost estimate with EM officials and then  revised those assessments based on EM’s written comments and the  additional documentation they provided, as appropriate.

To examine the extent to which the D&D Fund is sufficient to cover EM’s  estimated cleanup costs of the GDPs and challenges, if any, that could  affect the sufficiency of the fund, we reviewed information on the balance  of the D&D Fund and compared it to EM cost estimate information, past  reports that describe the balance of the fund, and our prior report on the  fund. We reviewed DOE’s triennial reports from 1996 to 2019 to  determine the extent to which the information provided was presented  consistently across reports. In addition, we interviewed key stakeholders,  including EM and EPA officials; Kentucky, Ohio, and Tennessee  regulators; members of GDP site-specific advisory boards; and  representatives of community reuse organizations as discussed above  regarding challenges that could affect the sufficiency of the D&D Fund.

We conducted this performance audit from April 2018 to December 2019,  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.

The GDPs were constructed in the 1940s and 1950s and were used to  enrich uranium for the U.S. military as well as the nation’s domestic  nuclear power industry. The GDPs are located near Oak Ridge,  Tennessee; Paducah, Kentucky; and Portsmouth, Ohio (see fig. 1). The  GDPs were rendered obsolete due to the emergence of newer, more  efficient technologies and the globalization of the uranium enrichment market. All three GDPs eventually ceased uranium enrichment activities,  with Paducah being the last to stop enriching by 2013.

The GDP sites are similar in many ways. For example, the primary  structures at each GDP are large buildings for uranium enrichment  processing using the same gaseous diffusion technology. In addition, at  each of the sites, these large buildings all housed similar equipment, such  as compressors, converters, and other equipment necessary for enriching  uranium. EM measures these buildings in acres rather than square feet  (see fig. 2). For example, the five uranium enrichment processing  buildings that once stood at Oak Ridge measured a total of 114 acres.  Each GDP site also consists of hundreds of other similar buildings and  facilities used to fabricate, service, repair, and clean machinery as well as  additional infrastructure, such as electrical switchyards and cooling  towers.

Rescission of the USEC Fund   The Energy Policy Act of 1992 created the  United States Enrichment Corporation  (USEC) as a government corporation  authorized to, among other things, acquire,  market, and enrich uranium. The 1992 Act  also established a revolving fund in the U.S.  Treasury—the USEC Fund—for carrying out  USEC’s purposes. In 1996, Congress enacted  the USEC Privatization Act authorizing  establishment of a private, for-profit  corporation. The act provided that “expenses  of privatization” were to be paid from certain  accounts, including the USEC Fund. One  week before privatization, Congress enacted  the “McConnell Act,” which reserved  approximately $373 million from certain  accounts, including the USEC Fund, for the  disposition of depleted uranium stored at  government-owned enrichment plants  operated by USEC. USEC was privatized on  July 28, 1998. After privatization, the USEC  Fund balance of $1.2 billion was retained on  the books of the Treasury. Since then, the  balance of the USEC Fund has grown to an  estimated $1.695 billion as of fiscal year 2020.  In 2015, we found that the entire balance of  the USEC Fund is available for permanent  rescission since the two statutorily authorized  uses for the USEC Fund have been fulfilled:  (1) environmental clean-up expenses  pursuant to the “McConnell Act,” and (2)  expenses of privatization. In the fiscal year  2017 federal budget, the Administration  proposed using the balances of the USEC  Fund to carry out purposes authorized to be  funded by the Uranium Enrichment  Decontamination and Decommissioning Fund.  This is not one of the authorized purposes of  the USEC Fund. We have previously found  that DOE’s effort to utilize USEC Fund monies  instead of general fund appropriations to  support efforts other than the authorized  purpose of the USEC Fund would diminish  transparency in budgeting. In May 2019, we  highlighted this issue in our annual report on  fragmentation, overlap, and duplication.  As of September 2019, Congress had not  passed legislation to permanently rescind the  balance of the USEC Fund, as we suggested  in April 2015. Rescission may increase the  transparency of federal agencies' budget  presentations and help Congress have a clear  understanding of how new funding requests  relate to funding decisions for existing projects  with continuing resource needs. nuclear power reactors and enrichment continued until 1985. The Oak  Ridge GDP permanently closed in 1987.

Portsmouth. The Portsmouth GDP, a 3,778-acre site located north of  Portsmouth, Ohio, operated from 1954 until 2001. The GDP enriched  uranium for both commercial reactor fuel and military applications.  The Portsmouth GDP includes three uranium enrichment processing  buildings, as well as over 300 other buildings and facilities.  Management of both Portsmouth and Paducah has changed over  time. Specifically, the Energy Policy Act, as amended, established the  United States Enrichment Corporation (USEC) as a government  corporation to, among other things, provide uranium enrichment  services and take over operations of the GDPs in Portsmouth and  Paducah beginning in 1993 (see sidebar). By 1998, USEC was  privatized under the USEC Privatization Act and became a subsidiary  of the newly created USEC, Inc. USEC produced low-enriched  uranium for commercial power plants until 2001, when it ceased  operations at the Portsmouth GDP. Later that year, the plant was  placed on cold standby—a dormant condition that would allow  operations to be resumed within 18 to 24 months if needed—and  USEC, under contract with DOE, maintained the site. In 2011,  USEC returned the Portsmouth GDP to DOE and EM’s contractor  initiated deactivation activities of the uranium enrichment processing  buildings.

Paducah. The Paducah GDP, located on 3,556 acres of land west of  Paducah, Kentucky, initially produced enriched uranium for nuclear  weapons from 1952 until 1993. From 1993 through 2013, USEC  leased and operated the facilities to produce enriched uranium for the  commercial nuclear power sector. Similar to the Portsmouth GDP site,  management of the Paducah site has changed over time. The  Paducah GDP has four uranium enrichment processing buildings as  well as more than 500 other buildings and facilities. After shutting  down operations in 2013, USEC returned the Paducah GDP to DOE  in 2014.

Table 1 provides additional detail on the GDPs, including the date when  cleanup began, the site size, and the size of the contractor workforce  performing the cleanup activities.

Cleanup of the GDPs is a complex process that involves multiple,  coordinated activities: surveillance and maintenance, D&D, and site  remediation. Throughout the cleanup process, EM must conduct  surveillance and maintenance activities at the GDPs to ensure public and  worker safety. This includes maintaining and repairing site infrastructure,  such as buildings and facilities and electrical and water supplies.

The D&D process involves the following activities: deactivation,  decontamination, decommissioning, and demolition. According to the  National Academies and DOE, these cleanup activities are encompassed  within the detailed processes described below:

Characterization and measurement of the contaminants present.

During this process, cleanup workers determine the identities, forms,  amounts, and locations of hazardous and radioactive substances.  According to DOE, common contaminants found at the GDPs include  radioisotopes stemming from the historical enrichment process (e.g.,  uranium and technetium-99); hazardous chemicals (e.g.,  trichloroethylene, polychlorinated biphenyls, and beryllium); asbestos,  and other hazardous materials typical of industrial facilities. When the  GDPs were in operation, workers used volatile organic compounds in  large quantities to clean and degrease equipment, which resulted in  the release of such compounds, specifically trichloroethylene, into the  environment. These compounds contaminated soil, surface water,  and groundwater when they were spilled, burned in pits, discharged in  holding ponds, or placed in trenches for disposal.

Removal of large uranium deposits. During this process cleanup  workers remove large deposits of enriched uranium from the process  equipment and piping. This step is necessary at some of the uranium  processing buildings to reduce the possibility of nuclear criticality—an  event in which an assemblage of enriched uranium produces a short- duration (millisecond) burst of heat and radiation. This step is also  necessary to resolve security concerns regarding the protection and  handling of special nuclear materials.

Disassembly and decontamination of equipment and building  structural components. Hundreds of large process equipment  components, such as converters, compressors, and motors may need  to be disassembled and decontaminated. In addition, the floors, walls,  and other structural components of buildings that housed such  equipment must be decontaminated.

Demolition of buildings and facilities. Hundreds of structures— including analytical laboratories, electrical switch yards, and uranium  enrichment processing buildings that are many acres in size—must be  demolished at the GDP sites.

Management or disposal of waste. The D&D process generates  significant amounts of waste, including building materials and  hazardous and radioactive waste removed from equipment and  piping. Waste management activities include treatment, storage,  transportation, and disposal of low-level radioactive waste, hazardous  waste, mixed radioactive and hazardous waste, and sanitary waste.

In addition to surveillance and maintenance activities and the D&D of  buildings and facilities, remediation of contaminated soils, surface water,  and groundwater is a part of GDP cleanup and is an important aspect of  protecting human health and the environment. According to DOE,  remediation of contaminated soils, surface water, and groundwater  involves assessing the site, including subsurface soils and groundwater  contaminated by past GDP operation, and addressing the sources of  contamination. According to EM, the Paducah GDP has the most  groundwater and soil contamination of the three GDPs, and the  Portsmouth GDP has the least amount of contamination.

EPA and State Regulators’ Roles in GDP Cleanup

At each GDP site, EM is required to consult and reach agreement with  federal and state regulatory agencies in determining cleanup  requirements, strategies, and priorities. Federal laws, including the  Resource Conservation and Recovery Act of 1976 (RCRA), as amended;  the Comprehensive Environmental Response, Compensation, and  Liability Act of 1980 (CERCLA), as amended; and cleanup agreements  with state regulatory agencies in Kentucky, Ohio, and Tennessee govern  cleanup at the three GDPs. RCRA establishes the framework for the  management of hazardous and non-hazardous solid waste. CERCLA  authorizes the federal government to respond directly to releases or  threatened releases of hazardous substances, pollutants, or  contaminants that may endanger public health or the environment.  CERCLA requires that EPA maintain a National Priorities List that  includes some of the most seriously contaminated sites that EPA  identifies for long-term cleanup of hazardous substances, pollutants, or  contaminants throughout the United States and its territories. Federal  sites on this list are required to have an interagency agreement for  expeditious completion of all remedial action at the facility. The  interagency agreement, termed a Federal Facility Agreement, guides the  cleanup process and sets enforceable milestones for priority cleanup  activities as agreed to by all the parties to the agreement.

The Oak Ridge and Paducah GDPs are both included on EPA’s National  Priorities List under CERCLA. As a result, both sites have negotiated tri- party Federal Facility Agreements signed by DOE, EPA, and the relevant  state regulator. Under the terms of these agreements, DOE must reach  agreement with EPA and Tennessee and Kentucky state regulators to  establish cleanup priorities and schedules for work with enforceable  milestones subject to the agreements’ dispute resolution procedures. In  addition, the agreements state that DOE must consult with these  regulators in making budget requests to Congress for the GDPs.

The Portsmouth GDP is not listed on EPA’s National Priorities List due to  an agreement among regulators and, therefore, does not have a Federal  Facility Agreement. Instead, the Ohio regulator is responsible for  overseeing cleanup under a State of Ohio Consent Decree under RCRA  and an Ohio Environmental Protection Agency Directors Final Findings  and Orders for Decontamination and Decommissioning, which guide the  cleanup process at Portsmouth. Under Presidential Executive Order  12580, DOE is the lead federal agency for implementation of CERCLA at  Portsmouth. According to DOE’s Fiscal Year 2020 Congressional Budget  Justification, the Ohio regulator used the CERCLA framework in  developing the Orders. According to EPA officials we interviewed, EPA is  not involved in regulating the CERCLA or RCRA components of the  cleanup at the Portsmouth GDP.

Decontamination and Decommissioning   Fund: Uranium and Thorium  Reimbursements  Title X of the Energy Policy Act, as amended,  authorizes the Decontamination and  Decommissioning (D&D) Fund to reimburse  licensees of uranium and thorium processing  sites for their portion of D&D activities,  reclamation efforts, and other cleanup costs  attributable to the uranium and thorium  materials they sold to the federal government.  These sites became contaminated with radon  and other decay products of uranium over  time. According to a DOE report, as of 2017,  there were ten sites that were continuing  remedial activities and where DOE was  continuing to provide reimbursements.  According to the 2017 DOE report, DOE had  at the time issued about $716 million in  reimbursement payments since inception of  the D&D Fund. The largest recipient is West  Chicago Environmental Response Trust, with  over $380 million in reimbursement payments  through fiscal year 2017. As of fiscal year  2016, DOE estimates that the total remaining  payouts to uranium and thorium producers will  be approximately $164 million.

In 1992, the Energy Policy Act established the D&D Fund to pay for the  cleanup of the three GDPs. The act authorized $480 million in annual  contributions to the D&D Fund (annually adjusted for inflation) for a period  of 15 years—from fiscal years 1993 through 2007. According to the act, of  the $480 million in annual contributions originally authorized, up to $150  million was to come from a special assessment collected from domestic  utility companies that used the enriched uranium produced by the GDPs  for nuclear power generation, and the remainder was authorized to be  appropriated by the federal government for a period of 15 years. While  domestic utility payments were discontinued in 2007, as prescribed by the  1992 Energy Policy Act, additional sums have continued to be  appropriated for the D&D Fund.

The act specified that any unused balances in the D&D Fund be invested  in Treasury securities and any interest earned be made available to pay  for activities covered under the D&D Fund. The act also authorizes  reimbursements to uranium and thorium processing site licensees who  provided raw materials to the GDPs for their cleanup costs (see sidebar).

The Energy Policy Act, as amended, authorizes the D&D Fund to pay for  the costs of all D&D and remediation activities at the GDPs. Specifically,  according to EM officials, the D&D Fund is used to pay for the following  cleanup activities: (1) D&D of inactive facilities either by cleaning up the  facilities so they could be reused or by demolishing them; (2) remedial  actions such as assessing and treating groundwater or soil  contamination; (3) waste management, such as the transport and  disposal of hazardous waste; (4) the surveillance and maintenance of the  GDPs, such as general repairs to keep the buildings and facilities in a  safe condition; (5) uranium and thorium licensee reimbursements; (6) training for contractor personnel who work on D&D activities; and (7)  other activities, such as legal costs associated with the GDPs, funding to  support site-specific advisory boards at Portsmouth and Paducah, and  pension costs of workers involved in uranium enrichment or D&D.

According to EM officials, there are additional cleanup-related activities  taking place at the GDPs that are not covered by the D&D Fund, which  include: (1) security—which provides services to protect nuclear  materials, sensitive uranium enrichment technology, equipment, and  facilities; (2) operation of the onsite waste disposal facility at Oak Ridge;  and (3) conversion of depleted uranium hexafluoride—a byproduct of the  enrichment process—into a more stable form, such as uranium oxide,  that will require eventual disposal (see sidebar).

Depleted uranium hexafluoride—referred to  as depleted uranium “tails”—is a byproduct of  the uranium enrichment process. The uranium  enrichment process involves concentrating  uranium-235, which is the isotope of uranium  that undergoes fission to release enormous  amounts of energy. Natural uranium contains  0.7 percent of the uranium-235 isotope, and  tails contain less uranium-235 than natural  uranium (i.e., less than 0.7 percent of  uranium-235). Tails have historically been  considered waste because the enrichment  process required to extract the remaining  useful quantities of uranium-235 is significant  and can be costly. In addition, tails may be  dangerous to human health and the  environment and can form extremely  corrosive and potentially lethal compounds  when in contact with water. Therefore, the  Department of Energy (DOE) has opted to  convert its inventory of tails into a more stable  chemical form, such as uranium oxide, that  would allow for long-term storage and  minimize environmental impacts and costs.   The Portsmouth and Paducah gaseous  diffusion plants (GDP) each store their  inventories of tails in thousands of cylinders,  and both GDPs have an onsite conversion  facility. As of March 2018, DOE estimated that  the combined tails stockpile at the Portsmouth  and Paducah GDPs was estimated at 62,000  cylinders. DOE estimates the Portsmouth  GDP will complete conversion of its tails  inventory by 2034 and Paducah by 2047.  Most of the tails inventory at the Oak Ridge  GDP (approximately 7,200 cylinders) has  been shipped to Portsmouth for conversion.   According to DOE officials, the D&D Fund is  not used to pay for conversion of the tails.

To pay for these additional cleanup-related activities, EM officials  reported that EM has used the Defense Environmental Cleanup and the  Non-Defense Environmental Cleanup Appropriation Accounts.

At Portsmouth, EM has also transferred natural uranium to site  contractors in exchange for cleanup services—a practice EM refers to as  “barter.” Additional details on this practice are discussed later in the  report.

As we reported in February 2019, effective program and project  management are important to the success of efforts like the EM  program. According to PMI, a program is defined as “related projects,  subsidiary programs, and program activities managed in a coordinated  way to obtain benefits not available from managing them individually.”  According to a PMI conference paper, to reach the ultimate goal from a  program—to obtain benefits not available from managing the related  projects and program activities individually—a structured way of working  has to be established.

The Program Management Improvement Accountability Act requires the  Office of Management and Budget (OMB) to adopt and oversee  implementation of government-wide standards, policies, and guidelines  for program and project management in executive branch agencies. In  June 2018, OMB issued a memorandum on the implementation of this  law that includes initial implementation guidance and calls for agencies to  generally align their own program management standards to the  management practices and principles found in the memorandum. The  memorandum states that the act aims to improve program and project  management practices within the federal government. The OMB  memorandum also states that agencies may use program management  leading practices developed by us, other agencies, and external voluntary  consensus standard-setting bodies, such as PMI.

EM Has Managed Cleanup of the GDPs as Three Individual Sites and Estimates That Cleanup at All Sites Will Not Be Completed Until 2070 at the Latest

EM has managed cleanup of the GDPs as three individual sites, rather  than as an integrated program, and has not managed the cleanup of the  GDPs consistent with relevant program management leading practices.  For over a decade, DOE has reported to Congress in its triennial reports  that its intent is to manage the GDPs in an integrated manner but has not  developed an integrated program management plan, integrated master  schedule, and a reliable, integrated, comprehensive life-cycle cost  estimate. In addition, EM estimates that cleanup of the Oak Ridge GDP is  nearing completion, that Portsmouth will be completed by 2041, and that  Paducah will be completed between 2065 and 2070.

EM Has Managed Cleanup of the GDPs as Three Individual Sites

The Energy Policy Act, as amended, establishes a single, shared D&D  Fund to pay for the D&D costs of the GDP sites, such that EM must  coordinate and make trade-offs in its use of limited resources among the  three GDPs. In addition, since 2007, DOE has stated in its triennial  reports to Congress that its intent is to manage the GDPs in an integrated  manner. While neither EM nor DOE explicitly refers to the management of  the GDP cleanup as a program, DOE’s stated intent is consistent with  PMI’s definition of a program—”related projects, subsidiary programs, and  program activities managed in a coordinated way to obtain benefits not  available from managing them individually.”

However, we compared EM’s management of the cleanup of the three  GDPs to the three relevant PMI program management leading practices  that we examined—those addressing planning, scheduling, and cost  estimating—and found that EM is not managing the cleanup of the GDPs  consistent with these practices:

Planning—Having a program management plan. We found that EM  does not have a GDP-wide program management plan. According to  PMI, a program management plan formally expresses an  organization’s concept, vision, mission, and expected benefits  produced by the program; it also defines program-specific goals and  objectives. In a 1996 report, the National Academies recommended  that DOE develop a GDP-wide program management plan for cleanup  of the three GDPs that would help coordinate decisions across the  three GDPs. Representatives from the National Academies told us  in December 2018 that they continue to believe this recommendation  is valid. Furthermore, EPA and state regulators have criticized EM for  not having a long-term vision for GDP cleanup.

According to EM officials, EM developed site-level plans for each of  the three GDPs over time as the GDPs ceased operating and became  available for cleanup at different times—Oak Ridge ceased operating  in 1987, Portsmouth in 2011, and Paducah in 2013. However, in  reviewing what EM officials refer to as GDP program management  plans, we found that the documents were created for different  purposes and do not contain comparable information. For example,

The Oak Ridge plan was created in 2017 as an update of a fiscal  year 2014 through 2024 site-level plan for the three EM cleanup  sites located at Oak Ridge reservation—the GDP, the Oak Ridge  National Laboratory, and the Y-12 National Security Complex.  This document presents a high-level picture of cleanup activities.  EM officials told us that the Oak Ridge plan is intended to be high- level because cleanup of the Oak Ridge GDP is further along than  cleanup of the Portsmouth and Paducah GDPs and because the  Oak Ridge plan covers all three cleanup efforts at the Oak Ridge  Reservation. EM officials also noted that other specific planning  materials on the Oak Ridge GDP could be found in other  documentation, but such documentation was not in the plan or in a  usable form.

The document EM provided as the Portsmouth plan contains a  series of PowerPoint presentations for a March 2018 symposium  on waste management. The PowerPoint slides were presented by  both DOE officials and contractor representatives about different  projects at the Paducah and Portsmouth sites. However, the  slides contain contradictory information on when the Paducah  GDP began deactivation—one slide indicates that deactivation  began in 2014, but another shows deactivation will begin in 2035.

EM officials at the Paducah GDP provided the 2015 site  management plan for the Paducah GDP, which was signed by  DOE and the contractor. This plan includes actions taken to date,  site prioritization information (i.e., risk prioritization criteria), and  key planning assumptions. The Paducah plan is the most  comprehensive and detailed.

The individual GDP plans differ in their level of detail; do not present  comparable information, such as milestones that each GDP is to  meet; and do not reference past, ongoing, or planned work at the  other GDPs. As a result, they are not useful as plans for decision- making on the three GDPs in an integrated manner. Further, EM does  not have a document that contains a concept, vision, mission, and  expected benefits from GDP cleanup or that defines program-specific  goals and objectives. By developing a GDP-wide program  management plan, EM would have a comprehensive and consistent  roadmap to achieve GDP cleanup and would be in a better position to  leverage resources among the three GDPs.

Scheduling—Having a reliable, integrated master schedule. We  found that EM does not have an integrated master schedule for  cleanup of the GDPs. According to PMI’s Program Management  Standard, a program master schedule is the top-level program  planning document that defines the individual component schedules  and dependencies among program components (individual  components and program-level activities) required to achieve the  program goals. It should include those component milestones that  represent an output to the program or share interdependency with  other components. The program master schedule should also include  activities that are unique to the program including, but not limited to,  activities related to stakeholder engagement, program-level risk  mitigation, and program-level reviews. The program master schedule  determines the timing of individual components, enables the program  manager to determine when benefits will be delivered by the program,  and identifies external dependencies of the program.

EM officials told us that the agency’s corporate database—the  Integrated Planning, Accountability, and Budgeting System (IPABS)— contains the integrated master schedule for all of EM’s cleanup work,  including the GDPs. The purpose of IPABS is to provide information  on (1) changes to the life-cycle scope, cost, and schedule and (2)  performance data such as earned value, performance metrics, and  cleanup milestones. While IPABS provides a top-line planned  completion date as well as other information, including cleanup  milestones negotiated with regulators and performance metrics, it  does not provide all of the information needed to build up to that  date, including sequences clearly showing how related portions of  work depend on one another. Without information such as sequences,  it will not be possible for EM to identify the consequences of changes  or possible managerial action to respond to them. An integrated  master schedule makes it possible to help coordinate cleanup across  the GDPs by establishing each GDP site’s schedule and identifying  how related portions of work, such as funding profiles and workforce  and equipment requirements that tie the sites together, depend on  one another. For example, EM officials stated that certain demolition  equipment, such as high-reach excavators, are in limited supply and  may be shared among the three GDPs. By creating an integrated  master schedule, EM would be in a better position to coordinate  individual project activities across the three GDPs and thus help  achieve program goals.

Cost Estimating—Having a reliable, integrated, comprehensive  life-cycle cost estimate. We found that EM does not have a reliable,  integrated, comprehensive life-cycle cost estimate for cleanup of the  GDPs consistent with PMI’s Program Management Standard, which  calls for estimating a program’s full life-cycle costs. According to PMI,  calculating full life-cycle costs and including transition and  sustainment costs results in total cost of ownership. Total cost of  ownership is considered to be relative to the expected benefit of one  program against another to derive a funding decision. There are  numerous estimating techniques to derive program cost estimates.  Program cost estimates should also identify any critical assumptions  upon which the estimates are made, as these assumptions may prove  unfounded in the course of program delivery and require  reconsideration of the program business case or revision of the  program management plan. Finally, program cost estimation can  support or guide cost estimation at the component level. Any  prevailing program level cost estimation guidance intended for use at  the component level should be documented and communicated to  component managers.

Instead, EM has, over time, developed separate cost estimates for  each of the three GDPs that do not reference historic costs at the  other GDPs. EM officials stated that IPABS contains the life-cycle cost  estimate for EM’s cleanup work, including the GDPs. However, IPABS  only provides a top-line cost estimate. It does not provide details on  what information is included in developing that estimate, such as any  critical assumptions upon which the estimates are made. Moreover, in  February 2019 we reported that certain IPABS data, including  expenditure data, were not reliable. By developing an integrated,  comprehensive life-cycle cost estimate, EM management, Congress,  and stakeholders would have information on total cleanup costs,  including underlying costs, enabling more informed decision-making  on funding and resource allocations from the shared D&D Fund  across the three GDPs.

EM officials acknowledged that cleanup work at the GDPs is managed  independently by the three sites and not as an integrated program.  However, the officials noted that the GDP cleanup work is managed as  part of EM’s overall work to clean up radioactive and other hazardous  waste that remains at 16 different sites across the nation, which they  explained was all managed as one program. Further, according to EM  officials, since the cleanup work is part of EM’s overall cleanup program it  is able to make decisions at a high-level to support overall funding  priorities, reduce the greatest risks, and effectively use taxpayer dollars.  However, in February 2019, we reported on EM’s cleanup program and  found that EM’s cleanup policy—which governs its cleanup work—does  not follow any of the relevant program management leading practices  related to a program’s management of scope, cost, schedule  performance, and independent review of performance.

The benefits of managing the work at the GDPs as a program have long  been recognized. In 1996, the National Academies in its report to  Congress recognized GDP cleanup as having the characteristics of a  program noting that the repetitive and common design of the GDPs would  allow for economies of scale in performing D&D. The report  recommended that DOE develop a GDP-wide program management plan  that integrates the D&D of the facilities and environmental remediation  activities, as previously mentioned. According to the National Academies  report, coordinating efforts across the GDPs at the complex level would  help to ensure that D&D is integrated at the three sites and that  resources, including disbursements from the shared D&D Fund, would be  used effectively. Moreover, the report noted that delays would lead to  substantial expenditures for surveillance and maintenance; deterioration  of the facilities would exacerbate these costs; risks to individuals would  increase; and the costs for safeguards and security for the sites would  continue. In December 2018, representatives from the National  Academies told us that they continue to believe that managing the GDPs  as an integrated program would benefit cleanup efforts.

By taking steps to manage the three GDPs as an integrated program and  following relevant program management leading practices (developing a  program management plan; an integrated master schedule; and a  reliable, integrated, comprehensive life-cycle cost estimate), EM would  have more reasonable assurance that it is taking every opportunity to  increase the efficiency and effectiveness of its management activities.

EM Estimates That Cleanup of All Three GDPs Will Not Be Completed Until 2070 at the Latest

EM estimates that cleanup of the Oak Ridge GDP is nearing completion,  that Portsmouth will be completed by 2041, and that Paducah will be  completed between 2065 and 2070. Cleanup of the three GDPs— primarily remediation efforts—began in the late 1980s, and EM estimates  that cleanup of the last GDP, Paducah, will be completed by 2070 at the  latest. As figure 3 shows, based on DOE’s estimates, cleanup from start  to completion will take 33 years at Oak Ridge, 52 years at Portsmouth,  and 77 to 82 years at Paducah.

Each GDP site still has varying levels of cleanup work remaining, mainly  relating to when the site was closed. For example, the majority of cleanup  work began at Portsmouth and Paducah after the contractor operating the  GDPs—USEC—returned the site to DOE (in 2011 and 2014,  respectively). The following provides a brief overview of the work  remaining and estimated cleanup completion dates for each of the GDPs.  See appendix II for a summary of the cleanup work completed as of June  2019.

Oak Ridge. At Oak Ridge, the work remaining includes cleaning up  surface and groundwater contamination, remediating soils on  approximately 800 acres, and conducting D&D on more than 130  remaining facilities. DOE reported in its 2019 triennial report that it  intends to complete cleanup of the Oak Ridge GDP by fiscal year  2022. However, according to EM documentation and officials, EPA  officials, and state regulators, EM is unlikely to complete the cleanup  by this date. In information provided to us in 2018 and in  documentation supporting its cost estimate, EM cited fiscal year 2024  as the completion date for the Oak Ridge cleanup. In addition, in  March 2019, EM officials said that all facilities at the Oak Ridge GDP  will be demolished by fiscal year 2020 and remediation activities will  be completed by fiscal year 2024, stating that the fiscal year 2022  date in the 2019 triennial report is based on outdated data. EPA and  Tennessee regulators also told us they do not believe that EM’s  current estimated completion date is realistic for the Oak Ridge GDP  cleanup based on their understanding of the scope of remaining work,  particularly cleanup of groundwater contamination. They said it is  more realistic that cleanup of the Oak Ridge GDP will not be  completed until the late 2020s and EPA believes cleanup completion  could go out as far out as the 2040s, due to the lack of an agreed  approach to address contaminated groundwater. The completion date  for the Oak Ridge GDP has slipped in the past. Oak Ridge was  previously scheduled to be completed in fiscal year 2009 and then in  fiscal year 2012.

Portsmouth. At Portsmouth, EM must complete D&D for three  uranium enrichment processing buildings. Specifically, the first of  three processing buildings is undergoing the final stages of  deactivation, and the contractor is scheduled to begin demolition in  fiscal year 2020. EM has started deactivation procedures at the  second of the processing buildings, where EM is scheduled to start  demolition in fiscal year 2024. At the third processing building,  deactivation has yet to begin, and EM estimates the building will be  ready for demolition in fiscal year 2031. In addition, EM must conduct  D&D on hundreds of other support buildings and facilities. EM also  plans to continue to remediate groundwater plumes at Portsmouth  and to complete construction of an onsite waste disposal facility,  which is scheduled to be operational by fiscal year 2020. According to  the 2019 triennial report, cleanup of the Portsmouth GDP will be  completed in 2041 based on scope and funding projections. However,  in June 2019, EM officials told us that the Portsmouth cleanup will  more likely be completed in 2043.

Paducah. At Paducah, EM is focusing its near-term cleanup efforts on  D&D of the C-400 building—a building that was used to clean  machinery parts and test equipment and has been identified as the  primary source of groundwater contamination at the site. After the  demolition of this building, EM plans to dig up the slabs underneath  the building to remove contaminants that EM believes are the source  of the contamination, according to EM officials. According to EPA, EM  is also focusing its near-term cleanup efforts on other activities, such  as stabilization and deactivation of uranium enrichment and support  buildings across the GDP, infrastructure optimization activities  (including railroad upgrades for safe waste transport and downsizing  the electrical power grid network), and new facility construction.  According to an EM document and officials, deactivation of the  processing buildings began in 2014, after USEC returned the site to  DOE. In addition to the process buildings, EM will also need to  conduct D&D on hundreds of other buildings and facilities. In addition,  according to EM officials, EM has yet to decide on whether the waste  produced from the GDP cleanup will be shipped offsite or if it will  construct an onsite waste facility. EM estimates the cleanup of the  Paducah GDP will be completed between fiscal years 2065 and 2070.  The completion date for the Paducah GDP has slipped in the past.  Paducah was previously scheduled to be completed in fiscal year  2040, and then in fiscal year 2047.

EM’s Past Expenditure Data Are Limited, and Its Future Cost Estimates Are Unreliable

EM reported it has spent at least $15.5 billion on GDP cleanup as of  2018, including approximately $5.1 billion on the Oak Ridge cleanup,  approximately $6.7 billion on the Portsmouth cleanup, and approximately  $3.7 billion on the Paducah cleanup. However, EM has limited detailed  expenditure information on the cleanup activities carried out at the GDPs.  Moreover, EM’s cost estimates for completing cleanup at the three GDPs  are not reliable because they do not fully or substantially meet all of the  characteristics of a high-quality, reliable cost estimate as described in our  Cost Estimating Guide.

EM Reported It Has Spent at Least $15.5 Billion on Cleanup of the Three GDPs as of Fiscal Year 2018 but Has Limited Detailed Expenditure Data

Efforts to Supplement the  Decontamination and Decommissioning  Fund: Transfer of Natural Uranium for  Cleanup   As we reported in September 2011, from 2009  through 2011, the Department of Energy  (DOE) used 1,473 metric tons of natural  uranium to pay for $194 million in cleanup  services performed by a contractor—the  United States Enrichment Corporation  (USEC)—at the Portsmouth gaseous diffusion  plant (GDP). USEC then sold the natural  uranium and retained the proceeds. The  cleanup services provided by USEC included  removing chemical and hazardous material  from the GDP. DOE has in the past referred to  this practice as “barter.”  We found in our September 2011 report that  DOE mischaracterized certain transactions  with USEC as barters. From December 2009  through March 2011 DOE’s uranium  transactions with USEC were sales authorized  by the USEC Privatization Act, but they did  not comply with federal fiscal law. The USEC  Privatization Act requires that before a  uranium sale, DOE must determine: the  materials are surplus to national security  needs; the department is receiving fair market  value; and the sales will not adversely affect  the domestic uranium mining, conversion, and  enrichment industries. We found that DOE  met these requirements. Nevertheless, by not  depositing the value of the net proceeds from  the sales of uranium into the Treasury, we  found that DOE violated the miscellaneous  receipts statute. This statute requires an  official or agent of the government receiving  money from any source on the government's  behalf to deposit the money into the Treasury.  By not depositing an amount equal to the  value of the uranium into the Treasury, DOE  inappropriately circumvented the power of the  purse granted to Congress under the  Constitution.  DOE disagreed that its actions did not comply  with federal fiscal law. We suggested that  Congress consider authorizing DOE to,  among other things, retain the proceeds of  future uranium transactions. Pursuant to  direction from Congress, in March 2018, DOE  suspended this practice through fiscal year  2019. In its fiscal year 2020 budget request,  DOE indicated that it would resume this  practice to help pay for cleanup at  Portsmouth. a practice EM refers to as “barter.” According to data provided by EM  officials in 2018, from December 2009 through March 2018, EM  transferred uranium valued at about $1.4 billion. According to an EM  official, EM has used this transfer process exclusively at Portsmouth  (see sidebar). Among other sources, the Non-Defense Environmental  Cleanup Appropriation Account supplied over $1.2 billion in cleanup  funding at Portsmouth for activities such as the operation of the  depleted uranium hexafluoride conversion facility.

Paducah. EM also reports that it has spent about $3.7 billion on the  Paducah cleanup as of 2018. Similar to the Oak Ridge and  Portsmouth GDPs, the D&D Fund paid for the majority of the cleanup  costs at the Paducah GDP—approximately $2.7 billion. The remaining  $1 billion in cleanup expenditures were funded by aforementioned  appropriation accounts, including $138 million from the Defense  Environmental Cleanup Appropriation Account on activities such as  security and safeguards.

EM tracks annual expenditures for cleanup activities at each GDP site in  STARS, according to EM officials. However, EM does not track detailed  expenditure information by GDP site on specific cleanup activities—such  as remediation, waste management, or surveillance and maintenance—in  that system. For example, EM officials provided data from STARS  indicating that EM spent about $262 million on D&D at the Oak Ridge  GDP in fiscal year 2007, but officials could not provide a breakdown of  what specific cleanup activities the funds were used for, such as  remediation or waste management. EM headquarters and site officials  explained that they do not track detailed expenditure information of GDP  cleanup activities in STARS because they are not required to do so.

EM has previously provided a detailed breakdown of expenditures. For  example, in our July 2004 report, in addition to expenditures on D&D, EM  provided expenditures for the following categories: remedial actions,  surveillance and maintenance, uranium and thorium reimbursements,  waste management, and other activities. In addition, DOE’s 2007 triennial  report has an appendix on GDP future costs that provided a similar  breakout. However, EM officials could not provide current expenditure  information similar to these prior reports. EM site officials told us that EM  tracks more detailed expenditure data on certain categories by project,  including demolition activities, and that these data were available in  various project management systems maintained across the three sites.  However, according to these officials, the various project management  systems do not consistently track expenditures across the three GDP  sites. EM headquarters officials stated that EM tracks more detailed  expenditure data centrally in IPABS. However, in February 2019, we  reported that the earned value management data in IPABS, which contain  the expenditure data, were unreliable.

Detailed expenditure data are important for developing reliable cost  estimates, according to our Cost Estimating Guide. The Cost Estimating  Guide states that it is always better to use actual costs rather than  estimates as data sources, since actual costs represent the most  accurate data available. EM officials told us that they used expenditure  data at Oak Ridge, supplemented by other information, to help develop  cost estimates at Portsmouth and Paducah. However, according to EM  officials, EM does not track detailed expenditure data consistently across  the three GDPs, therefore its ability to develop accurate and informed  cost estimates for future work at the three GDP sites is limited. By  tracking consistent and detailed expenditure information on cleanup  activities across the GDPs, EM management would be better able to  develop reliable cost estimates to plan for future work.

EM’s Cost Estimates for Completing Cleanup of the Three GDPs Are Not Reliable

EM’s cost estimates for cleanup of the three GDPs (about $28-$30 billion,  according to DOE’s 2019 triennial report to Congress) are not reliable and  likely underestimate the future cleanup costs. EM has developed  individual cost estimates for each of the three GDPs over time and has  presented those cost estimates in the triennial reports to Congress. EM  prepared the latest cost estimate for Oak Ridge in 2013, for Portsmouth in  2014, and for Paducah in 2017.

We assessed EM’s cost estimates for the three GDPs individually by  comparing them with the best practices identified in our Cost Estimating  Guide. The guide outlines best practices for developing a high-quality,  reliable cost estimate and identifies four characteristics of such an  estimate: comprehensive, well-documented, accurate, and credible (see  fig. 5 for a depiction of the four characteristics and some of the best  practices that underlie them). A cost estimate is considered reliable if  the assessment for each of the four characteristics are substantially or  fully met. If any of the characteristics are not met, minimally met, or  partially met, then the cost estimate does not fully reflect the  characteristics of a high-quality estimate and cannot be considered  reliable.

We found that the Portsmouth and Paducah cost estimates fully or  substantially met some of the characteristics of a reliable cost estimate,  but none of the three cost estimates fully or substantially met all of the  characteristics, so EM’s cost estimates for completing cleanup of the  three GDPs are not reliable. Specifically, EM’s cost estimate for  Portsmouth fully met the comprehensive characteristic and substantially  met the well-documented and accurate characteristics. EM’s cost  estimate for Paducah fully met the accurate characteristic and  substantially met the comprehensive characteristic. However, in all other  instances, the cost estimates partially or minimally met the  characteristics, with Oak Ridge obtaining the lowest scores. Figure 6  provides a summary of our assessment of the cost estimates for Oak  Ridge, Portsmouth, and Paducah for each characteristic. Appendix III  provides additional information on our assessment. We also found that  the cost estimates likely underestimate the cleanup costs because of  challenges in reaching consensus on cleanup decisions with regulators  that we discuss later in this report.

In commenting on our assessment of the GDPs’ cost estimates, EM  officials stated that they disagreed with our findings. According to EM  officials, the cost estimates for the three GDPs have been audited  numerous times and contain thousands of pages of support. Officials  also questioned how the cost estimate for Oak Ridge scored the lowest of  the three sites, when the documentation supporting that cost estimate  was prepared by the same contractor that prepared the Paducah cost  estimate using the same processes, practices, and procedures. We use  the same criteria—our Cost Estimating Guide—to assess cost estimates  throughout the federal government, and we follow the same process for  assessing cost estimates. As we do for all agencies, we provided EM the  opportunity to review the detailed analysis that we prepared as part of our  assessment and the opportunity to provide additional documentation that  may fill gaps identified in that assessment.

While EM had documentation for the Paducah GDP cost estimate, which  included a project life-cycle summary schedule and life-cycle baseline  work breakdown structure, EM did not include such documentation for the  Oak Ridge GDP cost estimate. In addition, many of the documents EM  officials provided to support the Oak Ridge cost estimate were more than  5 years older than the cost estimate itself, a point by which EM should  have had actual expenditure data rather than proposed data to inform the  estimate. Because these documents did not contain actual expenditure  data, we determined they were out of date for Oak Ridge’s 2013 cost  estimate. We met with EM officials a second time to discuss our  assessment of the Oak Ridge GDP cost estimate and reviewed additional  documents provided by officials and modified the assessment to reflect  that additional information. However, this information did not change our  overall assessment. Until EM ensures the site-specific life-cycle cost  estimates for the cleanup of each of the GDPs fully incorporate best  practices for cost estimation, EM, DOE, regulators, and Congress will not  have the information needed to understand the level of resources  required to achieve cleanup of the GDPs.

EM Faces Estimated Cleanup Costs Exceeding the 2018 D&D Fund Balance by at Least $25 Billion and Challenges to the Sufficiency of the D&D Fund

Under EM’s current cost estimates, remaining GDP cleanup costs exceed  the balance of the D&D Fund by at least $25 billion, and EM faces  challenges that could affect cleanup progress and the sufficiency of the  fund. According to EPA and state regulatory officials from Kentucky and  Tennessee, negotiations with EM regarding various cleanup decisions  have strained relations between EM and the regulators and present  challenges to the GDP cleanup progress that could affect cleanup  progress and put additional demands on the D&D Fund. Finally, EM’s  reporting to Congress on the sufficiency of the D&D Fund is based on old  data and is not always complete or clear, which presents challenges to  Congress’s ability to be fully informed in taking actions to address the  sufficiency of the Fund.

EM’s Estimated Costs to Complete Cleanup of the GDPs Exceed the 2018 Balance of the D&D Fund by at Least $25 Billion

EM’s estimated costs of about $28 billion to $30 billion to complete  cleanup of the GDPs—cited in DOE’s 2019 triennial report—exceed the  $2.7 billion balance of the D&D Fund cited in a 2018 document agency  officials provided. Most recently, in its 2019 triennial report, DOE stated  that, as of September 2016, estimated cleanup costs exceeded the  balance of the D&D Fund by $26.6 billion. DOE has therefore estimated  that the D&D Fund would be exhausted by fiscal year 2020. Prior triennial  reports have made similar estimations. However, according to EM data,  this shortage is likely to be billions more. In 2017, EM prepared a revised  cost estimate for Paducah, revising Paducah’s life-cycle cost estimate for  completing cleanup to $34 billion from $15 to $16 billion in 2016 data. EM  did not include this revision or note it in any way in the final 2019 triennial  report provided to Congress. Based on this revision, EM’s estimated  costs would be about $47 billion to $48 billion to complete cleanup of the  GDPs.

The sufficiency of the D&D Fund has been a long-standing issue. In July  2004, we reported that based on projected costs and revenues at the  time, the D&D Fund would be insufficient to cover the cleanup activities at  the three GDPs. To better ensure that the fund would be sufficient to  cover the projected costs for authorized activities, we recommended that  Congress consider reauthorizing the fund for an additional 3 years—to  2010—and require DOE to reassess the fund’s sufficiency before it  expired in 2007 to determine if further extensions would be necessary  beyond 2010. In November 2007, the U.S. Senate Committee on Energy  and Natural Resources held a hearing on a bill which would have  reauthorized the fund and required DOE to continue to assess the fund’s  sufficiency. Although the committee did not take further action on that  bill, Congress has continued providing appropriations to the D&D Fund.

Negotiations with EPA and Regulators from Two States over Key Cleanup Decisions Present Challenges that Could Affect Cleanup Progress and Further Strain the Fund

According to EPA and state regulatory officials from Kentucky and  Tennessee, negotiations with EM regarding key cleanup decisions have  strained relations between EM and the regulators and present challenges  to the GDP cleanup progress. If EM is unable to reach agreement with  the regulators on its preferred outcomes, there will likely be further delays  and increases in GDP cleanup costs. The EPA and state regulatory  officials said that their negotiations over pending cleanup decisions have  raised concerns regarding EM’s priorities, cleanup remedies, and cost  estimates. Because both the Oak Ridge and Paducah GDPs are included  on EPA’s National Priorities List, both sites are required to have a Federal  Facility Agreement—an agreement that guides the cleanup process and  establishes cleanup priorities and schedules with enforceable milestones  as agreed to by EM, EPA, and state regulators. Disagreements among  the parties at both the Oak Ridge and Paducah GDPs present challenges  to EM’s assumptions regarding the acceptance of its preferred cleanup  strategy and will likely lead to delays and increases in EM’s estimated  cleanup costs if that strategy is not followed.

Disagreements over cleanup priorities. EPA and state regulatory  officials disagree with EM’s cleanup priorities at Oak Ridge and  Paducah. EM officials we interviewed told us their priority is  characterizing, decontaminating, and demolishing buildings and  facilities. EPA and state regulatory officials said that their priority is  soil and groundwater remediation to address contamination. The  Tennessee regulatory official said that the state agrees that the D&D  of buildings is valuable and beneficial but that those operations must  be followed by management and mitigation of soil and groundwater  impacts. EPA officials also told us that EM needs to better balance  D&D and remediation efforts by conducting more remediation  activities. EM officials stated that at the Oak Ridge GDP, EM balances  D&D with remediation activities, but they did not provide  documentation about these efforts. The Tennessee regulatory officials  added that EM has been reluctant to commit to milestones that  regulators identify as a priority. In addition, EPA officials and the  Kentucky state regulatory official said that EM reprioritizes the  cleanup effort every few years. The Kentucky regulator added that this  has led to delays in approving the site management plan. These  issues have led to disputes, and strained relations at the Paducah  GDP. Specifically, per the terms of their Federal Facility Agreement,  EM, EPA, and the Kentucky regulator must annually agree to a site  management plan that establishes enforceable milestones. However,  the parties have not agreed to such a plan since 2015, and in its draft  2018 plan, EM changed its priorities from the 2015 plan by moving a  number of enforceable milestones to non-enforceable planning  dates. As of February 2019, these and other technical disputes  between EM and EPA and state regulatory officials had delayed  demolition of the C-400 building—the primary source of groundwater  contamination at the Paducah site—by a year and led to cost  increases. In commenting on a draft of this report, both DOE and EPA  officials stated that disputes associated with the C-400 building  demolition were resolved in a memorandum of agreement signed in  August 2019.

Differences in preferred cleanup remedies at Oak Ridge. The Oak  Ridge Federal Facility Agreement requires EM to reach agreement  with the regulators on cleanup remedies. According to EM, EPA, and  Tennessee regulatory officials we interviewed, EM and the regulators  differ in their choice of preferred cleanup remedies at the Oak Ridge  GDP, an issue subject to dispute under the Federal Facility  Agreement. At Oak Ridge, EM officials we interviewed said that their  cost estimate for all of the groundwater cleanup assumes that  regulators will agree to a waiver for active cleanup across the site,  relying on a cleanup remedy called monitored natural attenuation— allowing natural processes to decrease or “attenuate” concentrations  of contaminants in the groundwater and monitoring that progress over  time. EM officials acknowledged that they have not reached  agreement with regulators on groundwater cleanup remedies. The  officials noted that their proposed approach is based on their analysis  of what remedies are cost effective, technically practicable, technically  feasible, fully protective, and likely to be agreed upon by the state. EM  officials also noted that their cost estimates are developed following  federal standards that require EM to assume the lowest cost remedy if  no remedy is more likely than another. However, DOE’s preferred  cleanup remedy may not be accepted by regulators. EPA and  Tennessee regulators told us that while they may agree to a waiver  for specific areas at Oak Ridge, they would not agree to a “blanket”  waiver covering the entire site. They added that they would prefer  that EM more actively address contamination, for example, by  installing a pump-and-treat system at Oak Ridge. Without the  blanket waiver included in their cost estimate, EM officials said that  cleanup would likely be delayed by several years, and costs would  likely increase by as much as hundreds of millions of dollars. EM  officials later said that they are not seeking a blanket waiver and do  not believe a blanket waiver will be required for all groundwater  remediation requirements, but rather that focused waivers may be  necessary for certain areas that cannot be restored by available  technology. Notably, in reviewing EM’s most recent cost estimate, we  found that the estimate continues to assume a waiver for the entire  site.

Concerns about EM’s cost estimation assumptions. EPA and the  Kentucky and Tennessee state regulatory officials we interviewed told  us that EM generally shares information under the terms of the  Federal Facility Agreement. However, the officials said they were  concerned that the assumptions behind EM’s cost estimates for GDP  cleanup are not transparent and that EM has not worked with them to  develop the estimates. EPA officials told us that EM does not  adequately or transparently include EPA on technical scope and  cleanup schedule considerations that underlie EM’s cost estimates.  Tennessee regulatory officials added that EM’s cost estimates do not  reflect the state’s assumptions about the technical scope and  schedules for the remedies for soil and groundwater remediation. In  commenting on a draft of this report, DOE officials stated that  estimates for the Oak Ridge GDP reflect the technical scope and  schedules to accomplish the end state remedies that the Tennessee  regulator has agreed to for soil remediation. The officials added that  they are working with the regulator on the remedy for groundwater  remediation. Similarly, at the Paducah GDP, the Kentucky state  regulatory official expressed concern that EM’s cost estimates were  unrealistic—especially EM’s assumption that Paducah would receive  over $1 billion in funding (in escalated dollars) for most years starting  in 2036 and ending in 2050. Total enacted appropriations for Paducah  in fiscal year 2019 were about $274 million; EM’s assumption would  constitute a significant increase in Paducah’s funding. Without these  increased funding levels, Paducah’s cleanup would likely extend  beyond the 2065 to 2070 time frame, and EM’s estimates for  completion and cleanup costs would likely increase. EM site officials  at Oak Ridge disagreed that they have not been transparent with EPA  and Tennessee state regulators, emphasizing that they have complied  with all Federal Facility Agreement requirements regarding regulator  participation in the budget process.

At Paducah, the challenges between EM, EPA, and the Kentucky  regulator are not new. In April 2004, we reported that EM, EPA, and the  Kentucky regulator had difficulty agreeing on an overall cleanup approach  as well as on the details of specific projects. Further, we found that over  time, these disagreements had undermined trust and damaged the  parties’ working relationship. We recommended that EM involve EPA and  the Kentucky regulator early in the development of the annual site  management plan and specific projects—before submitting formal  cleanup proposals for regulatory approval—so that the parties can identify  and resolve their concerns and reach consensus on cleanup decisions in  a more timely manner. EM stated it believed at the time that it had been  successful in fostering constructive relationships with its regulators and  through its intent to involve regulators early in the decision-making  process. In commenting on a draft of this report, DOE officials stated that  every year DOE conducts scoping meetings with EPA and the Kentucky  regulator to establish the strategy, planning schedules, and milestones for  the annual site management plan prior to it being transmitted to the  regulators in November.

According to a September 2012 Memorandum on Environmental  Collaboration and Conflict Resolution issued by OMB and the Council on  Environmental Quality, departments and agencies should “increase the  appropriate and effective use of third-party assisted environmental  collaboration as well as environmental conflict resolution to resolve  problems and conflicts that arise in the context of environmental, public  lands, or natural resource issues, including matters related to energy,  transportation, and water and land management.”

Pursuant to the memorandum’s annual reporting requirement, DOE’s  draft annual report from March 2018 presents information on the  department’s use of third parties and other collaborative problem-solving  approaches in fiscal year 2017. In that report, DOE cites the benefits of  integrating third-party facilitation into DOE site and program office  projects, including expanded and clearer communication that leads to  smoother relationships with the regulators and the public. EM officials told  us that they, in conjunction with the regulators, have used outside  facilitators to help scope site management plans, work plans, and other  project documents over the past few years. They said that they have  engaged the services of a facilitator at Paducah on two significant efforts,  and in both cases the facilitator added value and was effective. In  addition, Tennessee state regulatory officials told us that they have used  a mediator with EM at the Oak Ridge GDP site in the past, and they  believe the process had a positive result. However, EM is currently not  engaging the services of a facilitator at the three GDP sites to help the  parties address differences in setting priorities, agreeing on remedies,  and ensuring the cost estimates reflect regulator assumptions. By  working with an independent, third-party facilitator to help resolve  disagreements over cleanup priorities, cleanup remedies, and cost  estimation assumptions, EM would be in a better position to achieve  stakeholder concurrence on these issues and avoid future cleanup  delays.

Limitations in EM’s Reporting to Congress Present Challenges to Congress’s Ability to Take Actions to Address the Sufficiency of the D&D Fund

EM’s reporting to Congress on the sufficiency of the D&D Fund is based  on old data, incomplete information, and unclear scope, presenting  challenges to Congress’s ability to be fully informed in taking actions to  address the sufficiency of the fund. The Energy Policy Act, as amended,  required the Secretary of Energy to report within 3 years of enactment,  and at least once every 3 years thereafter, on the progress of the GDP  cleanup effort. DOE has continued to prepare triennial reports on the  status of the D&D Fund and GDP cleanup for Congress. However, DOE’s  2019 triennial report is based on outdated information, provides limited  information on the challenges EM faces in reaching agreement with EPA  and state regulators, and is not clear on the scope of work. These  limitations reduce the quality of the information Congress receives for  making decisions about allocating resources to the D&D Fund at the  same time that Congress will have to address a continued need for  resources for GDP cleanup given the fund is estimated to be exhausted  by 2020.

The 2019 triennial report is based on outdated information. The  latest triennial report, issued in May 2019, is based on financial  information as of September 2016 and on cost estimates prepared in  2013 (Oak Ridge) and 2014 (Portsmouth and Paducah). In addition,  the report does not contain information on an updated cost estimate  for the Paducah site. Specifically, for Paducah, the report cites a cost  estimate—prepared in 2014—of $15 billion to $16 billion and a  completion date of 2047. However, EM prepared a revised cost  estimate in 2018 that estimated costs to be $34 billion and estimated  completion dates ranging from 2065 to 2070. EM had initially included  information from this 2018 estimate in a draft of the 2019 triennial  report, but ultimately did not include this information or note it in any  way in the final report provided to Congress. EM headquarters  officials told us that they did not include the updated 2018 Paducah  cost estimate in the final 2019 report because they had already  completed an extensive field and headquarters review process of the  2019 triennial report and did not want to repeat that process.

The 2019 triennial report does not discuss the challenges EM  faces in reaching agreement with EPA and state regulators. The  2019 triennial report has a section on challenges and uncertainties for  each GDP. For the Oak Ridge and Paducah GDPs, this section does  not discuss the challenges EM faces in reaching agreement with  regulators on cleanup remediation decisions. For example, the Oak  Ridge challenges and uncertainties section of the 2019 triennial report  mentions that some groundwater treatment may be required, but the  report does not disclose EM’s assumption in its cost estimate that it  will receive a waiver allowing it to avoid active groundwater  remediation activities or that this is an area of disagreement with the  regulators. Similarly, the report’s discussion of challenges and  uncertainties at Paducah mentions that several CERCLA decisions  regarding groundwater need to be made, but does not discuss  disagreements with the regulators over priorities or the implications of  those decisions on cost or schedule.

Information in triennial reports is not always clear on scope of  work. Some information in the triennial reports has not always been  clear. For example, when reporting its cost estimates in its three most  recent triennial reports (2010, 2016, and 2019), DOE reports only  future costs for Oak Ridge; whereas for Portsmouth and Paducah it  reports either total costs (past plus future estimated costs), or future  costs, or does not clearly indicate if the cost estimate represents total  or future costs. These differences make it difficult to make  comparisons among the three GDPs. In addition, in six triennial  reports, DOE reported similar estimated future costs for completing  the Oak Ridge GDP cleanup—$1.2 billion in the 1998 report; $1.3  billion in 2001; $1.6 billion in 2007; $2.1 billion in 2010; $1.4 billion in  2016; and $950 million in 2019. Estimated costs to complete cleanup  would likely be reduced over time as work scope is completed, unless  the scope of work is increasing, costs for materials are increasing, or  prior estimates were incorrect; however, DOE has not clearly  explained the factors contributing to these similar future cost  estimates in any of its reports since 2007 (2007, 2010, 2016, 2019).

Standards for Internal Control in the Federal Government state that  management should externally communicate the necessary quality  information to achieve the entity’s objectives. Quality information is  appropriate, current, complete, accurate, accessible, and provided on a  timely basis. Given that DOE estimates the D&D Fund will be exhausted  in 2020, there is an urgency for DOE to communicate current and  accurate information on the fund on a timely basis to Congress. By  regularly reporting on the status of the D&D Fund and cleanup efforts at  the three GDPs with current information that contains details on  challenges in reaching agreement with regulators and a clear scope of  work, DOE will be able to provide better information for congressional  decision-making on the sufficiency of the fund.

EM has made progress in cleaning up DOE’s three former GDPs— particularly at Oak Ridge where contractors have demolished all five  uranium enrichment processing buildings measuring a combined 114  acres as well as most other supporting buildings and facilities—but future  work remains. Although DOE has stated its intent to manage cleanup of  the GDPs in an integrated manner, EM is not managing the cleanup as  an integrated program, even though cleanup of the GDPs meets the  definition of a program as defined by PMI and Congress established a  single, shared D&D Fund to pay for the cleanup. By taking steps to  manage the three GDPs as an integrated program and following relevant  program management leading practices we examined (developing a  program management plan, an integrated master schedule, and a  reliable, integrated, comprehensive life-cycle cost estimate), EM would  have more reasonable assurance that it is taking every opportunity to  increase the efficiency and effectiveness of its management activities.

Further, EM has limited expenditure data and its cost estimates for  completing cleanup are not reliable. Detailed expenditure data are  important for developing reliable cost estimates. However, according to  EM officials, EM does not track detailed expenditure data consistently  across the three GDPs. As a result, EM’s ability to develop accurate and  informed cost estimates for future work at the three GDP sites is limited.  By tracking consistent and detailed expenditure information on cleanup  activities across the three GDPs, EM management will be better able to  develop reliable cost estimates to plan for future work. Moreover, EM  does not have reliable cost estimates for completing cleanup of the three  GDPs. Until EM ensures the site-specific life-cycle cost estimates for the  cleanup of each of the GDPs fully incorporate best practices for cost  estimation, EM, DOE, regulators, and Congress will not have the  information needed to understand the level of resources required to  achieve cleanup of the GDPs.

According to EPA and state regulatory officials from Kentucky and  Tennessee, negotiations with EM regarding various cleanup decisions  have strained relations between EM and regulators and present  challenges to the GDP cleanup progress that will likely cause further  delays and increase GDP cleanup costs if EM is unable to reach  agreement on its preferred outcomes. EM officials said they have used  third-party facilitators with the regulators in the past but are not currently  engaging the services of a facilitator at the three GDP sites. By working  with an independent, third-party facilitator to help resolve disagreements  over cleanup priorities, cleanup remedies, and cost estimation  assumptions, EM would be in a better position to achieve stakeholder  concurrence on these issues and avoid future cleanup delays.

Finally, DOE’s 2019 triennial report is based on outdated information,  provides limited information on the challenges EM faces in reaching  agreement with EPA and state regulators, and is not clear on the scope of  work, thereby reducing the quality of the information Congress receives  about the sufficiency of the fund. Given that DOE estimates the fund will  be exhausted in 2020, there is an urgency for the department to  communicate current information on the fund on a timely basis to  Congress. By regularly reporting on the status of the D&D Fund and  cleanup efforts at the three GDPs with current information that contains  details on challenges in reaching agreement with regulators and a clear  scope of work, DOE will be able to provide better information for  congressional decision-making on the sufficiency of the fund.

We are making five recommendations to DOE:

The Secretary of Energy should direct the Assistant Secretary of the  Office of Environmental Management to take steps to manage the  three GDPs as an integrated program and follow relevant program  management leading practices (developing a GDP-wide program  management plan; an integrated master schedule; and a reliable,  integrated, comprehensive life-cycle cost estimate.)  (Recommendation 1)

The Secretary of Energy should direct the Assistant Secretary of the  Office of Environmental Management to track consistent and detailed  expenditure information on cleanup activities across the three GDPs.  (Recommendation 2)

The Secretary of Energy should direct the Assistant Secretary of the  Office of Environmental Management to ensure the site-specific life- cycle cost estimates for the cleanup of each of the GDPs fully  incorporate best practices for cost estimation. (Recommendation 3)

The Secretary of Energy should direct the Assistant Secretary of the  Office of Environmental Management to work—in conjunction with  EPA and Kentucky and Tennessee state regulators—with an  independent, third-party facilitator to help resolve disagreements over  cleanup priorities, cleanup remedies, and cost estimation  assumptions. (Recommendation 4)

The Secretary of Energy should regularly report on the status of the  D&D Fund and cleanup efforts at the three GDPs with current  information that contains details on challenges in reaching agreement  with regulators and a clear scope of work. (Recommendation 5)

We provided a draft of this report to DOE and EPA for comment. In  DOE’s comments, reproduced in appendix IV, the agency generally  agreed with our findings and recommendations, and described actions  that DOE intends to take in response to our recommendations.  Specifically, of our five recommendations, DOE concurred with four and  partially concurred with one. DOE also provided technical comments,  which we incorporated as appropriate. EPA did not provide written  comments but provided technical comments, which we incorporated as  appropriate.

DOE concurred with our first and second recommendations that the  Secretary of Energy should direct the Assistant Secretary of the Office of  Environmental Management to (1) take steps to manage the three GDPs  as an integrated program and follow relevant program management  leading practices and (2) track consistent and detailed expenditure  information on cleanup activities across the three GDPs. In its response  to the first recommendation, DOE stated that EM will develop a program  management master plan, to include site integrated master schedules  and life cycle costs for the remaining cleanup at the Portsmouth and  Paducah GDPs, and that the plan will incorporate program management  leading practices as appropriate. In response to the second  recommendation, DOE stated that EM will assess and identify an  appropriate mechanism for tracking expenditures for both the Portsmouth  and Paducah GDPs, using a standardized approach with an Earned  Value Management System reporting on, at a minimum, an annual basis.  We appreciate DOE’s commitment to improve cleanup at the Portsmouth  and Paducah sites; however, we emphasize that these two  recommendations are directed at all three GDPs, including the Oak Ridge  GDP. We reported that DOE intends to complete cleanup of the Oak  Ridge GDP by fiscal year 2022, but according to EM documentation we  reviewed and EM officials we interviewed, as well as EPA officials and  state regulators we interviewed, EM is unlikely to complete the cleanup by  this date. EPA officials and Tennessee regulators stated that it is more  realistic that cleanup of the Oak Ridge GDP will not be completed until  the late 2020s, and EPA officials told us that cleanup may not be  completed until the 2040s. Given the potential for Oak Ridge cleanup to  continue for at least another decade, we continue to believe it is important  that DOE include Oak Ridge in its implementation of these two  recommendations.

DOE partially concurred with our third recommendation that the Secretary  of Energy should direct the Assistant Secretary of the Office of  Environmental Management to ensure the site-specific life-cycle cost  estimates for the cleanup of each of the GDPs fully incorporate best  practices for cost estimation. DOE stated that EM will direct the  Portsmouth and Paducah sites to review and incorporate practices from  our Cost Estimating Guide, as appropriate, into the next revisions of each  site’s life-cycle cost baselines. DOE also stated that the remaining scope  for the Oak Ridge GDP will become part of the performance baseline for  the next Oak Ridge contractor. We appreciate DOE’s commitment to  improve cost estimation for the Portsmouth and Paducah GDPs.  However, we continue to believe that improving cost estimation for the  Oak Ridge GDP is also important, given that cleanup of Oak Ridge may  continue for at least another decade, as described above. As such, we  continue to believe it is important that DOE include Oak Ridge in  implementing this recommendation.

DOE concurred with our fourth recommendation that the Secretary of  Energy should direct the Assistant Secretary of the Office of  Environmental Management to work—in conjunction with EPA, and  Kentucky and Tennessee state regulators—with an independent, third-  party facilitator to help resolve disagreements over cleanup priorities,  cleanup remedies, and cost estimation assumptions. DOE stated that as  disagreements over cleanup priorities, remedies, and cost estimation  assumptions arise, EM will work with all parties to determine the feasibility  and benefits of using a facilitator on a case by case basis to help resolve  issues. DOE also concurred with our fifth recommendation that the  Secretary of Energy should regularly report on the status of the D&D  Fund and cleanup efforts at the three GDPs with current information that  contains details on challenges in reaching agreement with regulators and  a clear scope of work. DOE management stated that EM will produce its  next triennial Uranium Enrichment Decontamination and  Decommissioning Fund Report following closeout of fiscal year 2019, and  release of the most recent environmental liability estimate associated with  the remaining challenges and scope of cleanup at the GDPs.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of Energy, the Administrator of EPA, and other  interested parties. In addition, this report is available at no charge on the  GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-3841 or trimbled@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 significant contributions to the  report are listed in appendix VI.

Appendix I: Objectives, Scope, and Methodology

Our report examined: (1) the extent to which the Department of Energy’s  (DOE) Office of Environmental Management (EM) has managed cleanup  of the three gaseous diffusion plants (GDP) compared with relevant  program management leading practices and the status of the cleanup  effort; (2) what EM has spent on cleanup at the three GDPs and the  extent to which EM’s cost estimates for completing GDP cleanup are  reliable; and (3) the extent to which the Decontamination and  Decommissioning (D&D) Fund is sufficient to cover EM’s estimated  cleanup costs of the GDPs and challenges, if any, that could affect the  sufficiency of the D&D Fund.

To inform all three objectives, we reviewed the Energy Policy Act of 1992,  as amended; DOE triennial reports to Congress on GDP cleanup efforts;  and prior reports issued by us, DOE’s Office of Inspector General (both  performance audits and financial statement audits on the D&D Fund), and  the National Academies of Sciences, Engineering, and Medicine (National  Academies). We also interviewed officials from DOE’s Office of Inspector  General, the Environmental Protection Agency (EPA), and  representatives from of the National Academies, regarding their  knowledge of EM’s cleanup progress at the GDPs and any past, ongoing,  or future work they have conducted or are planning on the GDP cleanup.  We visited all three GDP sites to observe the cleanup work and meet with  EM officials responsible for the cleanup, representatives of the DOE  contractor responsible for D&D activities, state regulators working with  EM on environmental compliance activities (from Kentucky, Ohio, and  Tennessee), members of GDP site-specific advisory boards, and  representatives of community reuse organizations. During our interviews,  we discussed topics including funding for the GDP cleanup, cleanup  progress to date, and any challenges facing the cleanup effort. We  selected these interviewees because we determined, based on input from  EM officials, that they would be the most knowledgeable about GDP  cleanup status, funding, and challenges. Following these interviews, we  conducted a content analysis of all responses to our interview questions  to determine any key challenges that EM faces in completing cleanup of  the GDPs. We then grouped, coded, and verified the content in our  analysis and performed second-rater review. Through our content  analysis, we found that stakeholders primarily cited three key challenges  related to EM’s program management; relations between EM, EPA, and  state regulators; and transitioning the local communities to cleanup  completion.

To examine the extent to which EM has managed the cleanup of the  GDPs compared with relevant leading practices for program  management, and the status of the cleanup effort, we reviewed  documents, including site-specific GDP cleanup plans and GDP cleanup  progress briefings, as well as reports issued by the National Academies,  us, and DOE. We interviewed EM officials and contractor representatives  on their past, present, and future plans for cleanup. We also interviewed  EPA and state regulatory agency representatives at each of the GDPs  regarding their role in the cleanup and interactions with EM. We assessed  the information from these reviews and all interviews (content analysis  from interview responses) and identified the relevant program  management leading practices that aligned with the assessed  information. We identified the three program management leading  practices by reviewing our prior work and the Project Management  Institute’s (PMI) The Standard for Program Management—Fourth  Edition. The three leading practices were having (1) a program  management plan, (2) an integrated master schedule, and (3) a reliable,  integrated, comprehensive life-cycle cost estimate. We compared EM’s  management of the GDPs with these leading practices.

Specifically, during our interviews with EM, the DOE Office of Inspector  General, and EPA officials; Kentucky, Ohio, and Tennessee regulators;  representatives of the National Academies; and members of the site- specific advisory board from all three sites, we asked about challenges  EM faces in completing cleanup of the three GDP sites. As discussed  above, we conducted a content analysis of their responses to our  interviews and found that stakeholders primarily cited three key  challenges, including EM’s poor program management. Under poor  program management, stakeholders cited three sub-challenges: (1)  frequent changes in EM’s cleanup priorities and staff turnover, which  most closely aligns with the program planning leading practice; (2) lack of  integrated schedules across the GDPs, which most closely aligns with the  scheduling leading practice; and (3) lack of transparency in EM’s cost  estimation processes, which most closely aligns with the program cost  estimating leading practice. As a result, we assessed the three leading  practices that aligned with those issues: (1) program management plan,  (2) integrated master schedule, and (3) integrated comprehensive life- cycle cost estimate. To examine the status of cleanup at the GDPs, we  reviewed EM’s documentation of the work completed and the work  remaining at each GDP.

To examine what EM has spent on cleanup at the three GDP sites, and  the extent to which EM’s cost estimates for completing GDP cleanup are  reliable, we reviewed historical funding and cleanup expenditure data for  all three sites for the period from fiscal year 1994 through 2018 and  analyzed EM documentation supporting its cost estimates for each of the  three GDPs. The data the sites provided include expenditures from the  D&D Fund as well as from other funding sources including: the American  Recovery and Reinvestment Act, Uranium Facilities Maintenance and  Remediation funds, Environmental Management Waste Management  Facility funds, and Technetium-99 cleanup funds. We reviewed financial  statement audit reports issued on the D&D Fund for fiscal years 2005 to  2012 and met with relevant headquarters and field staff in financial  management, budget, and planning. In addition, we assessed the  reliability of the historical funding and expenditure data provided by EM.  Specifically, we obtained from EM officials familiar with DOE’s financial  management system responses to a series of data reliability questions  such as data entry access, quality control procedures, and the accuracy  and completeness of the data. During our review of the GDP expenditure  data, we identified a number of inconsistencies between the data  received from EM site officials and the data reported in DOE’s 2019  triennial report to Congress. EM officials were able to provide satisfactory  responses and documentation to address the identified inconsistencies.  We therefore found the data to be reliable for our purposes.

To examine the reliability of EM’s cost estimates for completing cleanup  at the three GDPs, we reviewed EM’s cost estimate documentation,  interviewed EM site officials, and compared GDP cost estimates against  characteristics of reliable cost estimates contained in our Cost Estimating  Guide. Our review included documents that established the basis and  assumptions for site contractors’ contributions to the cost estimate,  documents that established the contractors’ work breakdown structures,  and presentations on contractors’ cost estimating models. We interviewed  EM site officials and contractor staff responsible for producing the cost  estimates to understand the methods, assumptions, information, and data  EM used to produce the estimates. Our cost estimation specialists  assessed this information against the best practices for cost estimating  found in our Cost Estimating Guide that we developed to establish a  consistent methodology that can be used across the federal government  to develop, manage, and evaluate capital program cost estimates. We  shared our draft assessment for each GDP cost estimate with EM officials  and then revised those assessments based on EM’s written comments  and additional documentation they provided as appropriate. At EM’s  request, we met with Oak Ridge officials a second time to discuss our  assessment of the Oak Ridge GDP cost estimate and reviewed additional  documents provided by officials, and we reflected that additional  information into our assessment of the Oak Ridge cost estimate.

To examine the extent to which the D&D Fund is sufficient to cover EM’s  estimated cleanup costs of the GDPs and challenges, if any, that could  affect the sufficiency of the D&D Fund, we reviewed information on the  balance of the D&D Fund and compared it to EM cost estimate  information, past reports that describe the balance of the fund, and our  prior report on the fund. Despite our findings that the three cost  estimates were unreliable, we were able to report on the cost estimates  provided in DOE’s 2019 Triennial Report by presenting an “at least” cost  estimate. In addition, we interviewed key stakeholders, including officials  from EM, the DOE Office of Inspector General, and EPA; regulators from  the states of Kentucky, Ohio, and Tennessee; representatives of the  National Academies; and members of the site-specific advisory boards  and representatives of the community reuse organizations from all three  sites, regarding challenges EM faces in completing cleanup of the three  GDP sites and challenges that could affect the sufficiency of the D&D  Fund. As noted above, we conducted a content analysis of their response  and found that stakeholders primarily cited three challenges that could  affect cleanup progress and further strain the D&D Fund, including  challenges with negotiations with EPA and state regulators. We also  reviewed DOE’s triennial reports from 1996 to 2019 and compared  information included in each of these triennial reports to determine the  extent to which the information provided was presented consistently  across reports and consistent with other documentation provided, such as  site-specific plans and DOE’s cost estimates. We also interviewed DOE  officials about the sufficiency of the D&D Fund and factors affecting the  sufficiency of the fund.

We conducted this performance audit from April 2018 to December 2019,  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: Information on Cleanup Work Completed at the Department of Energy’s Former Gaseous Diffusion Plants as of June 2019

This appendix provides information on cleanup work completed at the  Department of Energy’s (DOE) former gaseous diffusion plants (GDP) as  of June 2019. DOE’s Office of Environmental Management (EM) is  responsible for their cleanup.

EM began cleanup at Oak Ridge in 1989 and Decontamination and  Decommissioning (D&D) of the uranium enrichment process buildings in  1998. Since that time, EM has characterized the levels and types of  contamination for most of the site and conducted D&D on all five uranium  enrichment process buildings. EM has also demolished over 390  additional buildings and facilities, including a fire water tower and the  Central Neutralization Facility that was used to treat the site’s industrial  wastewater. In addition, EM has remediated nearly 1,400 acres of  contaminated soils and has used an onsite waste disposal facility to  dispose of much of the waste generated from cleanup. Some specific  cleanup work EM has completed at Oak Ridge includes:

Removed slabs from two uranium enrichment process buildings and  completed cleanup of contaminated soils beneath the slab, clearing  the way for transition to industrial reuse.

Excavated and disposed of approximately 100,000 cubic yards of  contaminated materials from a burial ground.

Remediated an area considered to be a primary source of organic  contamination in area soils and groundwater and treated the resulting  approximately 175 cubic meters of contaminated soil.

Removed more than 48,000 tons of scrap metal from two scrap yards.

EPA and Tennessee state regulators agree that the end use for the site  will be a commercial industrial park, and several businesses are already  leasing portions of former GDP lands. In addition, more than 3,000 acres  of the former GDP lands have been cleared for conservation and  recreational use. EM has partnered with the Community Reuse  Organization of East Tennessee to attract businesses to operate on the  available lands. According to a representative of the Community Reuse  Organization of East Tennessee, EM has transferred over 1,000 acres of  land and 14 buildings to the reuse organization, who has in turn sold over  300,000 square feet to the private sector. There are 20 private companies  operating at the site.

EM began cleanup at the Portsmouth GDP in 1989 and D&D of the  uranium enrichment process buildings in 2011, after the contractor that  operated the site—the Unites States Enrichment Corporation (USEC)  returned the buildings to DOE in 2010. As of May 2019, EM is preparing  the first of three uranium enrichment process buildings for demolition and  is starting to characterize contamination in the second. EM is also  conducting ongoing remediation activities and constructing an on-site  waste disposal facility, where EM intends to dispose of D&D waste that  meets the approved acceptance criteria of the disposal facility. Several  site support facilities, including a large electric switchyard, have been  demolished. Some specific cleanup work EM has completed at  Portsmouth includes:

Completed sampling and removal for off-site disposal of all 7,020  uranium enrichment components (converters, compressors, and  coolers) from one of the uranium enrichment process buildings.

Closed five on-site landfills covering 60 acres.

Removed more than 37,000 pounds of trichloroethylene—a solvent  for degreasing metal that contaminated the groundwater at the site— through groundwater remediation.

EM contractors at Portsmouth told us that they are cleaning up the site for  future industrial use.

EM began cleanup at the Paducah site in 1988. USEC officially returned  the GDP to DOE in 2014 and according to an EM document and officials,  deactivation of the uranium processing buildings began that same year. In  January 2019, EM reached a milestone—deactivation of the C-400  building—by completing the cleanup of legacy materials in the building.  C-400 was a cleaning facility used to clean machinery parts and test  equipment and has been identified as the primary source of groundwater  contamination at the site. According to EM officials, EM has primarily  been using a pump-and-treat method to control the high concentration  portion of the groundwater plumes at Paducah. EM officials stated that  EM is focusing its cleanup efforts on D&D of the C-400 building and  remediation from now until the early 2030’s. According to EM officials, EM  is continuing to treat large contamination plumes and demolish inactive  facilities. Some specific cleanup work EM has completed at Paducah  includes:

Demolished and removed 43 inactive facilities including a 210,000  square foot uranium hexafluoride feed plant and a 60,000 square foot  metals plant.

Treated over four billion gallons of contaminated groundwater from  two operating pump-and-treat facilities and, as part of this treatment,  removed approximately 3,700 gallons of trichloroethylene.

Removed more than 850,000 cubic feet of low-level and mixed low- level legacy wastes and material storage area waste.

Resurfaced 74 acres of roofs at the site and rerouted roof drains in  order to reduce infiltration of water into the facilities.

Officials at Paducah told us that they are cleaning up the site for future  industrial use.

Appendix III: Summary of GAO’s Assessment of DOE’s Cost Estimates for Cleanup of the GDPs Compared with Best Practices

Appendix IV: Comments from the Department of Energy

Appendix V: GAO Staff and Acknowledgements

In addition to the individual named above, Amanda K. Kolling, Assistant  Director; Luqman Abdullah; Mark Braza; Jennifer Echard; Emile Ettedgui;  Juan C. Garay; Mark Keenan; Jennifer Leotta; Gregory Marchand; Kiki  Theodoropoulos; and Lauren Woodard made key contributions to this  report. Also contributing to this report were Alexandra Edwards; Keegan  Maguigan; Anne Stevens; and Doris Yanger.

Cleaning up 3 plants where uranium was enriched will cost billions of dollars and span decades. These sites—near Oak Ridge, Tennessee; Paducah, Kentucky; and Portsmouth, Ohio—are contaminated with radioactive and hazardous materials.

DOE reported spending about $15.5 billion to clean these areas up, as of 2018. The Department of Energy’s current estimate of remaining cleanup costs—more than $28 billion—is not reliable and is likely low. Even using this estimate, costs exceed the amount in DOE’s cleanup fund by at least $25 billion.

We made 5 recommendations, including that DOE take actions that will produce more accurate cost estimates.