The Government Accountability Office reported that the Department of Energy's Office of Environmental Management routinely violates its own project management standards by embedding predetermined solutions into mission need statements for large nuclear cleanup projects. Of 21 mission need statements reviewed for projects estimated at $100 million or more, the majority specified a particular facility or technology upfront — such as the Outfall 200 Mercury Treatment Facility at the Oak Ridge Reservation, which proposed "a new mercury treatment facility" before alternatives were analyzed.

This practice has tangible cost consequences. At Idaho National Laboratory, EM pursued a suboptimal radioactive waste treatment for years due to an existing regulatory agreement, bypassing a cheaper technically sound alternative before ultimately suspending the project. Since 2022, total costs for EM's most expensive capital asset projects have grown by more than $2 billion, with at least five sites anticipating future projects exceeding $100 million each.

Root causes include legal and regulatory constraints that narrow solution sets before analysis begins, contractor influence during early planning, and an internal review process that lacks independent technical experts. EM officials argued alternatives are explored in later stages, but GAO found the early commitment to a specific solution effectively foreclosed cost-saving options.

GAO recommended two corrective actions: revise mission need statements that pre-select solutions before approval, and incorporate independent experts outside DOE into the mission need review stage — particularly before agreeing to solutions with regulators under CERCLA cleanup frameworks. DOE concurred with both recommendations, which remain open pending implementation verification.