DOE Project Management: NNSA Needs to Clarify Requirements for Its Plutonium Analysis Project at Los Alamos
Highlights
What GAO Found
The Department of Energy's (DOE) National Nuclear Security Administration (NNSA) defined requirements for the revised Chemistry and Metallurgy Research Replacement (CMRR) project to provide plutonium analysis equipment at its Los Alamos site but did not specify the capacity for analyzing plutonium that the project should provide, making it possible that the project would not meet plutonium analysis needs. NNSA policy states that project requirements should include key performance parameters, which describe how well a project will perform its functions, expressed in terms such as processing rate or capacity. However, NNSA did not identify a key parameter that addresses a primary function of the project's analysis equipment—to analyze plutonium in support of producing an essential part of a nuclear weapon, known as a pit. NNSA has determined that it needs sufficient analysis capacity to support producing pits, including at planned rates of 10 pits per year in 2024 and 50 to 80 pits per year by 2030, but an NNSA analysis shows that the revised CMRR project may not support these rates. NNSA officials said the project's requirements do not include a pit production-related parameter because NNSA only tasked the CMRR project with replacing analysis equipment used in an aging facility, regardless of analysis capacity. Not identifying this parameter likely contributed to the project potentially not providing sufficient analysis capacity to support planned pit production and may have contributed to different understandings among senior agency officials about how well the project will support pit production. By identifying a pit production-related parameter that describes the analysis capacity that the revised CMRR project is to provide, NNSA could clarify the extent to which the project will support such pit production.
NNSA's total estimated cost for the revised CMRR project is lower than the cost of the previously approved CMRR project, which included a large nuclear facility, but NNSA may have overstated its cost savings. NNSA's estimated savings from cancelling the previously approved nuclear facility did not account for work that the agency deferred to future projects, including a storage vault and tunnel. NNSA's approach for the revised CMRR project allows costs to be spread out over time, improving NNSA's ability to concurrently fund other work. However, the revised CMRR project includes less scope and is likely to provide less plutonium analysis capacity than the previously approved nuclear facility.
The revised CMRR project schedule and cost estimates only partially met best practices. For example, the schedule did not include most of the work needed to complete the project. According to best practices, agencies should develop and maintain a schedule that contains all necessary work activities, but the revised project's schedule was limited to near-term work ending in 2017. When NNSA created the revised CMRR schedule, DOE did not specifically require projects to maintain complete schedules after project approval. Since then, DOE has issued a memorandum directing that all schedules contain the entire scope of work, but NNSA does not plan to develop a complete schedule for the entire CMRR project until mid-2017. Continuing to rely on a partial schedule limits managers' insight into how current activities might affect future completion dates, including NNSA's goal to end plutonium work in an aging facility at Los Alamos.
Why GAO Did This Study
In recent years, NNSA has spent billions of dollars designing large construction projects, only to revisit options after cost increases and schedule delays. At Los Alamos, NNSA reversed its prior decision to build a nuclear facility as part of the CMRR project after spending $450 million. The facility was to provide analysis equipment needed to support the production of pits as part of nuclear weapons life extension programs. Instead, NNSA approved a revised CMRR project to install plutonium analysis equipment in existing facilities.
Senate report 113-44 includes a provision for GAO to review NNSA's revised CMRR project. GAO's report assesses (1) the extent to which the revised CMRR project is expected to meet plutonium analysis needs, (2) how its cost and scope compare to the previously approved project, and (3) the extent to which its schedule and cost estimates reflect best practices, among other objectives. GAO reviewed project documentation, assessed cost and schedule estimates against GAO-identified best practices, and interviewed NNSA and DOE officials and CMRR contractor representatives.
Recommendations
GAO is making seven recommendations to NNSA, including that it identify a pit production-related parameter for the revised CMRR project and develop a CMRR project schedule that includes all necessary work activities. NNSA generally neither agreed nor disagreed with the recommendations but described some actions it was taking. GAO continues to believe that the recommendations are valid, as discussed in this report.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Energy | To ensure that NNSA will acquire sufficient plutonium analysis equipment and space to meet its needs, including pit production to support critical life extension programs, the Secretary should direct that the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, update the program requirements document for the revised CMRR project to identify a key performance parameter that describes the plutonium analysis capacity the CMRR project is required to provide to support specific pit production rates. |
NNSA officials confirmed that Los Alamos National Laboratory (LANL) has updated the program requirements document (PRD) for the Chemistry and Metallurgy Research Replacement (CMRR) project, and this update identifies the plutonium analysis capacity that CMRR is required to provide and reflects NNSA's Pit Production Strategy at LANL, a document that NNSA delivered to Congress in May 2020 and that we have reviewed. As of August 2020, NNSA officials have plans to review and finalize the PRD. Based on the information provided to us by NNSA officials, we will close this recommendation as implemented and review the PRD once finalized to determine how it addresses others of our recommendations.
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| Department of Energy | To ensure that NNSA will acquire sufficient plutonium analysis equipment and space to meet its needs, including pit production to support critical life extension programs, the Secretary should direct that the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, specify plans for how the agency will obtain additional plutonium analysis capacity if the revised CMRR project will not provide sufficient plutonium analysis capacity to support NNSA's pit production plans. |
In May 2020, NNSA update its LANL plutonium strategy document. The document describes that when all four CMRR subprojects are complete, and integrated with other planned upgrades in TA-55, there will be sufficient Materials Characterization (MC) and Analytical Chemistry (AC) to facilitate the cessation of the (1) old CMR building, (2) support production of up to 30 pits per year, and (3) support PF-4's other plutonium missions. No other MC or other AC chemistry efforts are included in the LANL strategy. The report notes that if LANL is required to produce 80 pits per year, additional investments in all aspects of PF-4 will need to be made. The strategy is also silent on LANL's ability to provide MC/AC capabilities to the planned Savannah River Pit Production Facility which will eventually produce 50 pits per year. Because this facility is in design, it is unclear if it will have its own MC/AC capability or if it will rely on existing capabilities at LANL and small scale capabilities at LLNL. Narrowly interpreted, we believe that there is sufficient evidence to close this recommendation as implemented. However, NNSA must soon address MC/AC capabilities for Savannah River pit production.
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| Department of Energy | To ensure that NNSA will provide clear information to stakeholders about the program needs that the revised CMRR project will satisfy, the Secretary should direct the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, to update the program requirements document for the revised CMRR project to clarify whether the project will provide plutonium analysis equipment to meet the needs of DOE and NNSA programs other than those in the Office of Defense Programs. |
In January 2021, NNSA approved an updated program requirements document for the CMRR project. The document includes a new requirement that states that the CMRR project will not provide plutonium analysis equipment that is only needed by non-defense related programs or activities. The requirements document notes that all capabilities to be installed as part of CMRR are needed by the Office of Defense Programs, but that the analysis equipment may also be available to meet the needs of other DOE and NNSA programs. In light of this revision to the program requirements document, we believe that NNSA's actions meet the intent of our recommendation.
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| Department of Energy | To ensure that NNSA's future schedule estimates for the revised CMRR project provide the agency with reasonable assurance regarding meeting the project's completion dates, the Secretary should direct the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, to develop future schedules for the revised CMRR project that are consistent with current DOE project management policy and scheduling best practices. Specifically, the Under Secretary should develop and maintain an integrated master schedule that includes all project activities under all subprojects prior to approving the project's first CD-2 decision. |
NNSA has identified the key milestone dates for two of four CMRR's subprojects, including critical decisions and completion, but the agency had not created a detailed integrated master schedule that includes all project activities for all four CMRR subprojects. Although the number of subprojects included in CMRR was in flux in 2019, as of April 2020, CMRR is expected to again include four subprojects pending expected Congressional Action. In August 2020, NNSA's Director of its Acquisition and Project Management Office reported that NNSA would not develop an integrated master schedule for the entire project and argued that the subprojects are distinct, severable, deliverable efforts with their own funding streams and federal project directors . He added that combining all four detailed integrated master schedules was incompatible with the way the work is performed and that combining them would be a compliance issue with no practical purpose. He did note that there is a high level, less detailed schedule showing all the CMRR work used for resourcing as part of execution planning. If this is what NNSA's project management policy intends, it should revise its policy to reflect this.
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| Department of Energy | To ensure that NNSA's future schedule estimates for the revised CMRR project provide the agency with reasonable assurance regarding meeting the project's completion dates, the Secretary should direct the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, to develop future schedules for the revised CMRR project that are consistent with current DOE project management policy and scheduling best practices. Specifically, the Under Secretary should conduct a comprehensive schedule risk analysis that applies to the integrated master schedule to identify the likelihood the project can meet its completion dates. |
As of April 2020, NNSA said that it had completed risk analyses for two of CMRR's four subprojects, but it had not completed a schedule risk analysis that applies to an integrated master schedule for the entire CMRR project. In August 2020, NNSA's Director of its Acquisition and Project Management Office reported that NNSA would not develop an integrated master schedule for the entire project and argued that the subprojects are distinct, severable, deliverable efforts with their own funding streams and federal project directors . He added that combining all four detailed integrated master schedules was incompatible with the way the work is performed and that combining them would be a compliance issue with no practical purpose. As a result of this approach of managing by subproject, NNSA will not complete a comprehensive schedule risk analysis to the entire CMRR project, even though NNSA's pit production plans rely on the completion of all CMRR subprojects to provide adequate materials characterization and analytic chemistry to support the resumption of of pit manufacturing at LANL by 2026.
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| Department of Energy | To ensure that NNSA is better positioned to objectively consider alternatives before making its selection of an alternative for the Plutonium Modular Approach, the Secretary should direct the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, before completing the analysis of alternatives, to rephrase the statement of mission need and requirements for the Plutonium Modular Approach so that they are independent of a particular solution. |
NNSA initially did not agree to implement the recommendation as stated in the report. However, in June 2017, as part of conducting the Analysis of Alternatives (AOA), NNSA revised the Mission Need Statement and Program Requirements Document for the project. The 2017 revision of the Mission Need Statement no longer included a specific mention of building modular facilities or extending the life of PF-4 at Los Alamos and was therefore independent of a particular solution. In addition, the 2017 revised program requirements focused on meeting pit production requirements rather than constructing modular facilities at Los Alamos. In light of these revised documents, we believe that NNSA's actions meet the intent of our recommendation.
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| Department of Energy | To ensure that NNSA has information about program-specific needs to inform its analysis of alternatives for the Plutonium Modular Approach and to provide a clearer basis for selecting a project alternative, the Secretary should direct the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, before completing the analysis of alternatives, to identify key performance parameters and program-specific requirements for the Plutonium Modular Approach. |
NNSA initially did not agree to implement the recommendation as written in the report. However, NNSA stated that it would develop key parameters and project requirements as part of the analysis of alternatives (AOA). In October 2017, NNSA completed the AOA. The final report describing the AOA includes information about program-specific requirements and production capacity requirements that NNSA developed for the project. We believe NNSA's actions meet the intent of our recommendation.
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