Title page 1

Contents 3

Highlights 2

Letter 5

Background 8

EM Cleanup Sites 8

DOE Project Management Standards 10

Regulatory Framework Governing EM Cleanup 13

A Majority of Mission Need Statements for Large Projects Do Not Fully Align with DOE Project Management Standards 14

The Majority of EM's Mission Need Statements for Large Projects Identify a Particular Solution Too Early 14

EM Officials Gave Various Reasons for Submitting and Approving Mission Need Statements That Did Not Fully Meet DOE Standards 16

Several Factors Limited the Range of Solutions EM Has Considered for Some Large Projects and This Planning Stage Lacks Independent Review 19

Legal and Regulatory Constraints, Contractor Involvement, and Existing Projects Limited the Range of Solutions EM Considered for Some Large Projects 19

Some Perceived Legal and Regulatory Constraints on Selected Projects May Be Flexible 27

EM Does Not Incorporate Independent Review in the Planning Stage for Large Projects 29

Conclusions 30

Recommendations for Executive Action 30

Agency Comments 31

Appendix I: Objectives, Scope, and Methodology 33

Appendix II: Comments from the Department of Energy 41

Appendix III: GAO Contact and Staff Acknowledgments 43

Table 1. Summary of Activities in DOE's Project Management Directives That May Occur Prior to Critical Decision (CD) 0, Approval of Mission Need 12

Table 2. Experts Participating in GAO's January 2026 Virtual Discussion Groups 38

Figure 1. Department of Energy (DOE) Office of Environmental Management (EM) Cleanup Sites with Active and Future Large Projects as of March 2026 9

Figure 2. Project Management Phases for Office of Environmental Management Capital Asset Projects 10

Figure 3. Selected Legal and Regulatory Changes Related to the Department of Energy's (DOE) Treatment of Low-Activity Waste (LAW) at the... 28

Figure 4. Scope of Documents Received from Department of Energy's Office of Environmental Management Related to Mission Need Approval 35