To modernize and maintain our nation’s nuclear weapons stockpile, the National Nuclear Security Administration (NNSA) will need a comprehensive strategy to address the generation of new waste that such activities will produce in the coming years.
However, in a recently published report by the Government
Accountability Office (GAO): NNSA Should Improve Its Strategy for Managing Anticipated Waste from Defense Activities, the GAO demonstrated that NNSA's February 2024 strategy for
treating, storing, and disposing of novel waste is not comprehensive and does not fully address all the legal requirements necessary to ensure adequate management of that waste.
When comparing the strategy to the seven key components of a comprehensive strategic plan, GAO found that the strategy only substantially meets one key component, that being the strategy’s Mission statement.
GAO stated that the NNSA’s comprehensive strategy does not define the problem it is intended to address. It does not identify the problems DOE may face with storing, treating, and disposing of novel waste nor does it explain how the
strategy will address problems associated with those activities. Furthermore, the strategy does not include goals and objectives, nor does it include activities, milestones, or performance measures to meet those goals and objectives.
When assessing the strategy’s planning of organizational roles, responsibilities, and coordination, GAO found that the strategy did successfully identify sources of waste generation
within NNSA. The strategy states that the waste management process is decentralized, with each NNSA waste generator site and contractor directing its own waste generation, management, transportation, disposal activities, and coordination with EM disposal site operators. Yet crucially, the strategy does not discuss the roles and responsibilities of NNSA offices in charge of the various tasks that would be required to implement the strategy, fulfilling the component only partially.
The strategy notes certain external factors that could affect disposal, and discusses relevant mitigation factors, but not others. For example:
- The strategy identifies how operations at WIPP, or the Nevada National Security Site have the potential to adversely impact NNSA’s mission. As mitigation, the strategy discusses exploring options for temporary storage at the generator sites or identifying other locations to
dispose of the waste.
- The strategy also emphasizes improving NNSA’s focus on positive regulatory relationships, which could help minimizing disruptions to missions from interruptions to waste management activities and flows.
However, GAO faulted the strategy for failing to discuss how the regulatory process impacts the waste management process or how NNSA plans to work with the regulators to ensure a
smooth waste management process.
As a key point, GAO stressed that the strategy does fully address all legal requirements included in the Senate statute that mandates the NNSA develop a comprehensive strategy. These include:
- Generated waste amounts. NNSA has not identified all sources and amounts of waste that may be generated in the next 25 years, for a strategy that has a 25-year scope.
This includes reestablishing plutonium pit production capability or surplus plutonium disposition, because these activities will not generate waste in the next 5 fiscal years.
- Coordination with the Office of Environmental Management (EM). The strategy recommends establishing formal coordination mechanisms with EM, but it does not define formal coordination or describe NNSA's plans to create this mechanism.
- Cost estimates. NNSA estimated
costs of about $2.5 billion over the next 5 years, but the estimate may not be reasonable, in part because NNSA used inconsistent and unclear information and did not perform risk and uncertainty analyses.
- Disposal options. The strategy did not identify disposal facilities, including any needed modifications.
GAO recommended that NNSA should incorporate all the key components of a
comprehensive strategy and fully address statutory requirements in its next strategy update. Following this recommendation will place NNSA in the best position to ensure the strategy's success and avoid the challenges that have affected efforts to dispose of waste generated by previous atomic weapons production activities. NNSA concurred with the GAO’s recommendation.
Read the GAO’s summary of the report here.
Read the full report here.
ECA will continue to provide summaries on GAO reports on key EM and NNSA programs. To learn more, visit ECA’s website.