At EM’s 16 Cleanup Sites, Cleanup Is Governed by 72 Agreements, but EM Headquarters and Sites Do Not Consistently Define or Track Milestones

At EM’s 16 cleanup sites, cleanup is governed by 72 agreements and  hundreds of cleanup milestones. Within the agreements, hundreds of milestones outline deadlines for  specific actions to be taken by EM as it carries out its cleanup work. EM Headquarters and Selected Cleanup Sites Do Not Consistently Define or Track Milestones

EM headquarters and cleanup site officials provided us with different  totals on the number of milestones in place at the four sites we selected  for further review. These discrepancies result from how headquarters and selected sites  define and track milestones. However, not all sites make the same distinction  between major and non-major milestones and, as a result, are not  consistently reporting the same types of milestones to EM  headquarters. Sites do not consistently  provide EM headquarters with the most up-to-date information on the  status of milestones at each site. Similarly, officials at the Hanford Site said that some milestones  governing Hanford’s cleanup are part of the site wide RCRA permit  issued by the state, which is separate from its federal facility agreement,  and, as a result, officials do not track this information in the same Hanford  milestone tracking system and do not report it to EM headquarters. EM’s lack of a standard  definition of milestones limits management’s ability to use milestones to  manage EM’s cleanup mission and monitor its progress. However, sites regularly  renegotiate milestones they are at risk of missing, and EM does not track  data on the history of postponed milestones. For example, in its report to Congress on the status of the  enforceable milestones, EM includes the latest (meaning the most  recently renegotiated) milestone dates with no indication of whether or  how often those milestones have been missed or postponed. This is because once  milestones are changed, sites are not required to maintain or track the  original milestones. Because EM does not track the original baseline schedule for  renegotiated milestone dates, milestones do not provide a reliable  measure of program performance. However, since neither EM headquarters  nor the sites track renegotiated milestones and their baseline dates at the  sites, EM cannot accurately use milestones for managing and measuring  the performance of its cleanup program. EM Has Not Consistently Reported Required Information to Congress, and the Information It Has Reported Is Incomplete

EM has not consistently reported required information to Congress on the  status of its milestones. EM Does Not Analyze the Root Causes of Missed or Postponed Milestones and Does Not Have Guidelines for Considering Root Causes When Renegotiating New Milestones

Best practices and DOE requirements for project management call for a  root cause analysis when problems lead to schedule delays, but EM  officials at both headquarters and selected sites have not analyzed  reasons why milestones are missed or postponed. According to best  practices identified in GAO’s cost estimating guide, agencies should  identify root causes of problems that lead to schedule delays and  renegotiated milestones. However, EM has not done a complex-wide analysis of the reasons for  missed or postponed milestones. Similarly, officials we interviewed at the  four selected sites said that they were not aware of any site-wide review  of why milestones were missed or postponed. Because EM has not analyzed why it  has missed or postponed milestones, EM cannot address these systemic  problems and consider those problems when renegotiating milestones  with regulators. Without such analysis, EM and its cleanup regulators  lack information to set more realistic and achievable milestones and, as a  result, future milestones are likely to continue to be pushed back, further  delaying the cleanup work. As we have reported previously, these delays  lead to increases in the overall cost of the cleanup. Conclusions

The federal government faces a large and growing future environmental  liability, the vast majority of which is related to the cleanup of radioactive  and hazardous waste at DOE’s 16 sites around the country. (Recommendation 3)
The Assistant Secretary of DOE’s Office of Environmental Management  should conduct root cause analyses of missed or postponed milestones. (Recommendation 4)

	Agency Comments and Our Evaluation

We provided a draft of this report to DOE for review and comment. Of the four recommendations in the report, DOE  agreed with three, and partially agreed with one. We have  found that, without a documented and consistently-applied schedule  change control process, program staff may continually revise the  schedule to match performance, hindering management's insight into  the true performance of the project.
Why GAO Did This Study

EM manages DOE's radioactive and hazardous waste cleanup program using compliance agreements negotiated between DOE and other federal and state agencies. Within the agreements, milestones outline cleanup work to be accomplished by specific deadlines. EM's cleanup program faces nearly $500 billion in future environmental liability, which has grown substantially.
GAO was asked to review DOE's cleanup agreements. This report examines the extent to which EM (1) tracks the milestones in cleanup agreements for EM's cleanup sites; (2) has met, missed, or postponed cleanup-related milestones at selected sites and how EM reports information; and (3) has analyzed why milestones are missed or postponed and how EM considers those reasons when renegotiating milestones.
GAO reviewed agreements and milestones at EM's 16 cleanup sites and compared information tracked by EM headquarters and these sites; interviewed officials from four selected sites (chosen for variation in location and scope of cleanup, among other factors); and reviewed EM guidance related to milestone negotiations.

What GAO Found

The cleanup process at the 16 sites overseen by the Department of Energy's (DOE) Office of Environmental Management (EM) is governed by 72 agreements and hundreds of milestones specifying actions EM is to take as it carries out its cleanup work. However, EM headquarters and site officials do not consistently track data on the milestones. EM headquarters and site officials provided GAO with different totals on the number of milestones in place at the four sites GAO selected for review. These discrepancies result from how headquarters and selected sites define and track milestones. First, not all sites make the same distinction between major (i.e., related to on-the-ground cleanup) and non-major milestones and, as a result, are not consistently reporting the same milestones to EM headquarters. Second, sites do not consistently provide EM headquarters with the most up-to-date information on the status of milestones at each site. These inconsistencies limit EM's ability to use milestones to manage the cleanup mission and monitor its progress.
EM does not accurately track met, missed, or postponed cleanup-related milestones at the four selected sites, and EM's milestone reporting to Congress is incomplete. EM sites renegotiate milestone dates before they are missed, and EM does not track the history of these changes. This is because once milestones change, sites are not required to maintain or track the original milestone dates. GAO has previously found that without a documented and consistently-applied schedule change control process, program staff may continually revise the schedule to match performance, hindering management's insight into the true performance of the project. Further, since 2011, EM has not consistently reported to Congress on the status of the milestones each year, as required, and the information it has reported is incomplete. EM reports the most recently renegotiated milestone dates with no indication of whether or how often those milestones have been missed or postponed. Since neither EM headquarters nor the sites track renegotiated milestones and their baseline dates at the sites, milestones do not provide a reliable measure of program performance.
EM officials at headquarters and selected sites have not conducted root cause analyses on missed or postponed milestones; thus, such analyses are not part of milestone negotiations. Specifically, EM has not done a complex-wide analysis of the reasons for missed or postponed milestones. Similarly, officials GAO interviewed at the four selected sites said that they were not aware of any site-wide review of why milestones were missed or postponed. Best practices for project and program management outlined in GAO's Cost Estimating and Assessment Guide note the importance of identifying root causes of problems that lead to schedule delays. Additionally, in a 2015 directive, DOE emphasized the importance of conducting such analysis. Analyzing the root causes of missed or postponed milestones would better position EM to address systemic problems and consider those problems when renegotiating milestones with regulators. Without such analysis, EM and its cleanup regulators lack information to set more realistic and achievable milestones and, as a result, future milestones are likely to continue to be pushed back, further delaying the cleanup work. As GAO has reported previously, these delays lead to increases in the overall cost of the cleanup.

What GAO Recommends

GAO is making four recommendations, including that EM establish a standard definition of milestones across the cleanup sites, track and report original and renegotiated milestone dates, and identify the root causes of why milestones are missed or postponed. In commenting on a draft of this report, DOE agreed with three of the recommendations and partially agreed with a fourth.