Unless I'm missing something, footnote #20 at the end of the 43 page report significantly undercuts their argument. It is easy to make a clear and succinct report that comes to the conclusion you want.
I don't see how it undercuts their argument. At best it means the DOE was following the spirit of their standards and the mission need statement was simply created later in the process than it should have been. It's still questionable though whether that prior planning actually considered and evaluated options as open-mindedly as if it had been done by the appropriate process.