Costs increase for clean-up of US Cold War legacy sites

19 October 2023

The estimated future cost to clean up 19 sites contaminated by nuclear waste from the Cold War nuclear arms race has risen by nearly $1bn over the past seven years, according to a new 77-page report from the US Government Accountability Office (GAO).

Nuclear weapons production and energy research activities from the 1940s to the 1970s generated large amounts of radioactive contamination and hazardous waste at commercial enterprises that were under contract to the federal government. As a result, contamination of soil, groundwater, and structures occurred at sites across the country, posing potential risks to human health and the environment. 

The Formerly Utilised Sites Remedial Action Program (FUSRAP) aims to identify; investigate; and, if necessary, clean up or control that contamination with the goal of returning the sites to beneficial use for the surrounding communities. The US Army Corps of Engineers (USACE) manages the response actions, including investigation and clean-up. There are 19 active sites across eight states in the Midwest and Northeast. 

FUSRAP was established in 1974 by a predecessor of the Department of Energy (DOE). In 1997, Congress transferred the FUSRAP from DOE to USACE for programme execution. GAO was asked to provide information about USACE’s efforts to clean up contamination under FUSRAP. Its report describes the reported environmental liabilities associated with active FUSRAP sites and uncertainties around those estimates. It also examines the extent to which FUSRAP meets leading practices for programme management.

GAO reviewed legal requirements, federal accounting standards, agency documents, and leading programme management practices; analysed data on the USACE cleanup expenditures and total cost estimates; and interviewed agency officials.

 GAO found that USACE reported $2.6bn in environmental liabilities in fiscal year 2022 for the estimated future costs to investigate and clean up contamination under FUSRAP. 

Of the 19 active sites in the programme, four with complicated clean-up remedies or large amounts of contamination make up about three-quarters of this estimate. Two of those sites are in New York state (one near Niagara Falls and one in Lockport). The others are in Armstrong County, Pennsylvania, and in the St Louis area. 

The government’s financial liability at the sites ballooned from $177m in 2016 to $406m in 2022, primarily because of additional contamination that forced USACE to expand the investigation and cleanup to include a 10-year floodplain at Coldwater Creek in St Louis.

USACE officials said that FUSRAP's environmental liability has the potential to be affected by uncertainties, such as the discovery of additional contamination after completing a cost estimate for remediation. Since 2016, FUSRAP's environmental liability has risen by nearly $1bn, which officials attribute to uncertainties and inflation.

GAO's review of FUSRAP documents found that USACE minimally met selected leading practices for programme management related to risk management and cost estimating, among other things. For example:

Programmes should identify risks and opportunities, document their characteristics, and prepare to manage them. The Corps does not have a documented programme-level risk management process for FUSRAP. A programme-level risk management process could help officials identify and manage risks that can affect multiple projects, such as limited staffing in areas like procurement, which officials said can extend some projects' timelines.

Programmes should have an integrated life cycle cost estimate that is comprehensive. Corps officials said that they consider FUSRAP's environmental liability estimate to be the program's life cycle cost estimate. However, the environmental liability estimate does not include all costs and does not track costs from previous years. Having an integrated life cycle cost estimate that includes all programme costs could enhance FUSRAP management's ability to make risk-informed decisions on how to manage and allocate its resources.

USACE officials said that the agency's standard business practices do not require FUSRAP to adhere to some of the leading practices at the program level. Although not required, following these and other leading practices would better position USACE to oversee and manage FUSRAP.

GAO concluded that environmental liabilities continued to be on its HighRisk List, due to their growth government wide, despite federal agencies spending billions each year on cleanup efforts. It said USACE decentralises its programme management and community outreach for FUSRAP across its sites, districts, and divisions, and there is limited integration at the programme level. FUSRAP could benefit from a centralised strategy to ensure that USACE is making risk-informed decisions. Specifically, opportunities exist for the USACE to improve its overall programme management by implementing some activities identified in selected GAO leading practices related to planning, cost estimating, and managing risk. These include:

  • By developing a more comprehensive programme management plan, including details on shared staffing resources in areas like procurement, FUSRAP management would be more efficient at using shared resources to achieve cleanups. 
  • If FUSRAP had a roadmap for the programme, management would be better able to assess progress and communicate progress to stakeholders. 
  • By having a comprehensive cost estimate that aligns estimates from all programme components and includes expenditures from previous years, FUSRAP would have greater insight as to a full life cycle cost for the programme and, therefore, be better positioned to make risk-informed decisions to manage and allocate its resources. 
  • Improved risk management activities at the programme level as a whole, not just at the project level, would help USACE plan for uncertainties that may affect future environmental liability estimates and identify opportunities to efficiently allocate resources across projects. 
  • Opportunities also exist for USACE to improve outreach and build better relationships with tribal, state, and local government officials, and community leaders around FUSRAP sites.

 GAO made five recommendations, The Secretary of the Army should ensure that the Chief of Engineers and Commanding General of USACE:

  • Update the FUSRAP Program Management Plan to follow leading practices for programme management, for example, by including details in on how to allocate staffing resources shared among project sites. 
  • Create programme roadmap for FUSRAP that follows leading practices for programme management, for example, by projecting when sites would need contracting support or technical expertise. 
  • Develop a comprehensive, integrated life cycle cost estimate for FUSRAP that follows leading practices for programme management, for example, by including both past and future programme costs. 
  • Conduct risk management for FUSRAP at the programme level that follows leading practices for programme management, for example, by developing a risk register. 
  • Include the specific needs of FUSRAP communities in district level outreach strategies under President Biden’s Justice40 Initiative that aims to ensure that 40% of the overall benefits of certain Federal investments positively impact marginalised by underinvestment and overburdened by pollution.    

The Department of Defence has said it would work to implement the GAO's recommendations, the report stated. USACE “remains committed to cleaning up and completing projects” being executed under FUSRAP to “protect the health and well-being of communities and the environment”, a statement said. "We have received the Government Accountability Office's report and we are currently working to address their recommendations."

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