Summary
In 2004, the Department of Energy (DOE) disposed of more than 378,000 cubic meters of low-level radioactive waste (LLRW)--contaminated building rubble, soil, and debris. In 2002, DOE directed its sites to use life-cycle cost analysis to manage LLRW. Life-cycle cost analysis examines the total cost of various options to manage LLRW over its life, including its packaging, treatment, transport, and disposal, to identify the lowest-cost alternative. GAO determined whether (1) DOE sites use life-cycle cost analysis to evaluate LLRW management alternatives and (2) DOE has a strategy for cost-effectively managing LLRW departmentwide, including state actions that may affect this strategy.
The six DOE sites we visited, representing more than 70 percent of the LLRW disposed of by DOE during 2003 and 2004, did not consistently use life-cycle cost analysis because of weak DOE guidance and a lack of oversight of contractors' implementation of this guidance. As a result, DOE cannot ensure that lowest-cost LLRW management alternatives are identified, so that managers make decisions that fully weigh costs against noncost factors, such as safety and schedule. For example, DOE contractors at two sites did not consistently consider alternative transportation modes or postclosure maintenance and surveillance costs of disposal sites in their analyses for fiscal year 2004 disposal decisions. GAO also could not always determine how contractors used cost analyses in disposal decisions because of incomplete documentation. While DOE's guidance requires each site to develop the mechanisms necessary to ensure use of life-cycle cost analysis, it does not specify, for example, (1) a systematic, consistent method of analyzing all cost elements to determine the lowest cost, or (2) when analyses should be performed. Also, no such guidance was incorporated into site contracts, and DOE site offices had not evaluated contractors' use of life-cycle cost analysis. DOE has recognized that its current approach--having each site responsible for developing mechanisms necessary to control costs--may result in cost inefficiencies and may limit its ability to meet departmentwide strategic objectives. As a result, DOE plans to begin implementing a national LLRW disposition strategy by March 2006 to better coordinate disposal efforts--specific schedules have not yet been established for when the strategy will be fully in place. However, DOE faces challenges in developing and implementing this strategy. First, it needs to gather complete data on the amount of LLRW needing disposal. Second, the fact that DOE's multiple program and site offices have differing missions and oversee many contractors presents coordination challenges. For example, one program office dismantled and disposed of a supercompactor used to reduce the volume of large LLRW items without a DOE-wide assessment of LLRW compacting needs and without considering other potential cost-effective uses for the supercompactor that might benefit other DOE sites. Third, DOE faces state actions that have restricted access to disposal facilities, making it more difficult to coordinate and integrate disposal departmentwide.
Recommendations
Our recommendations from this work are listed below with a Contact for more information. Status will change
from "In process" to "Implemented" or "Not implemented" based on our follow up work.
Director:
Team:
Phone:
Eugene E. Aloise
Government Accountability Office: Natural Resources and Environment
(202) 512-6870
Recommendations for Executive Action
Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should prepare comprehensive guidance on life-cycle cost analysis that, at a minimum, specifies (1) a systematic, consistent method of analyzing all cost elements or of comparing key alternatives within these cost elements to determine the lowest cost; (2) when and under what circumstances sites should prepare cost analyses; (3) relevant DOE orders, manuals, or other reference materials that should be consulted to provide consistent direction on how and when to perform the analysis; and (4) how final LLRW management decisions should be documented to demonstrate that life-cycle cost factors were adequately weighed against noncost factors, such as safety, health, or schedule.
Agency Affected: Department of Energy
Status: In process
Comments: According to DOE's DARTS Status Report dated October 10, 2006, recommendation 1 remains open. According to the report, DOE submitted the required report to Congress on February 14, 2006, which described the steps DOE is taking to implement the recommendation. Recently proposed changes and circumstances related to Low-Level Radioactive Waste (LLRW) will be incorporated into a path forward. Following EM review, the proposed guidance will be shared with other DOE programs later this year.
Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should incorporate the revised life-cycle cost guidance into new or existing site contracts or into the departmental orders cited in those contracts.
Agency Affected: Department of Energy
Status: In process
Comments: According to DOE's DARTS Status Report dated October 10, 2006, recommendation 2 remains open. According to the report, existing cleanup contracts were reviewed and EM's Office of Procurement and Planning will consider adopting this recommendation in the upcoming Hanford and Savannah River contracts.
Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should direct DOE to oversee contractors to ensure that site contractor officials properly use life-cycle cost analyses in evaluating LLRW management alternatives.
Agency Affected: Department of Energy
Status: In process
Comments: According to DOE's DARTS Status Report dated October 10, 2006, recommendation 3 remains open. According to the report, this recommendation is integrally tied to those related to recommendations 1 and 2. Following completion of activities related to recommendations 1 and 2, DOE will provide appropriate direction to DOE staff to implement this recommendation.
Recommendation: To promote cost-effective LLRW management, the Secretary of Energy should actively promote and monitor the development of a timely, national LLRW management strategy that is based on departmentwide data on LLRW needing disposal, and ensure that the implementation of the strategy is fully carried out.
Agency Affected: Department of Energy
Status: In process
Comments: According to DOE's DARTS Status Report dated October 10, 2006, recommendation 4 remains open. According to the report, DOE completed collection of updated low level waste (LLW) and MLLW data in February 2006, and the information is available to users on the Waste Information Management System. The National Low-Level Radioactive Waste (LLRW) management strategy is documented in the National Disposition Strategy for LLW and MLLW, Rev 0, which was completed in September 2006.
