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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program SYMPTOMS The Committee has identified several general symptoms of the problem: Planning that is driven by existing organizational structures rather than problems to be solved. Commitments that are made without adequately considering technical feasibility, cost, and schedule. An inability to look at more than one alternative at a time. Priorities that are driven by narrow interpretations of regulations rather than the regulations’ purpose of protecting public health and the environment. The production of documents as an end in itself, rather than as a means to achieve a goal. A lack of organizational coordination. A “not-invented-here” syndrome at individual sites. Under each general symptom are listed a few recent examples of the symptom with a description of how the underlying deficiencies have obstructed or vitiated relevant scientific and engineering progress. It is evident that some of the examples given cut across several general symptoms. General Symptom 1: Planning that is driven by existing organizational structures rather than problems to be solved. Example Both the Niagara Falls Storage Site (NFSS) in Lewiston, NY, and Fernald Environmental Management Project (FEMP) Site in Fernald, OH, have residues from the recovery of uranium during World War II from very rich ores from the former Belgian Congo (now Zaire) that contain very high concentrations of radium and thorium. Although there are differences in detail, the residues and the geochemical factors at the two sites are similar, yet the proposed management approaches at the two sites are quite different. At NFSS, the plan is to leave the residues in the near-surface storage facility, with an improved cap and continuing site maintenance and monitoring under government control for a period of 200 years or longer. At FEMP, the plan is to remove the residues from the silos where they are now stored, vitrify them, and ship them to the Nevada Test Site, Mercury, NV, for final disposal.
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program In its April 1986 Final Environmental Impact Statement for the NFSS (U.S. Department of Energy, 1986), DOE selected near-surface containment on site as the preferred alternative for disposal of the adopted NFSS residues. Although planning for disposal of FEMP residues was then only beginning, DOE adopted the position that disposal decisions for FEMP would be conducted independently from those at NFSS. This was done despite a previous request from the New York State Department of Health (letter from D. Axelrod, Commissioner of Health, to J.S.Herrington, Secretary, DOE, dated September 24, 1986) and from the New York State Department of Environmental Conservation (letter from T.C.Jorling, Commissioner of Environmental Conservation, to H.O’Leary, Secretary, DOE, dated September 28, 1993) that DOE refrain from using NFSS as a long-term disposal site for the high-radioactivity uranium ore residues. The later letter endorsed a similar position taken by Region II of the EPA (letter from W.J.Muszynski, Acting Regional Administrator, to P.D.Grimm, Acting Assistant Secretary for Environmental Restoration and Waste Management, DOE, dated June 4, 1993). Although the two sites are very similar with regard to quantities and types of residues, Fernald is classified administratively as a former weapons production site, whereas NFSS is considered to be a formerly used site remedial action program (FUSRAP) site. This puts them under different DOE organizational structures and subjects them to different legislative requirements and management approaches. The DOE is now reviewing its plans for permanent emplacement of the residues at the NFSS. The plan for vitrifying the FEMP residues and their shipment off-site for disposal is being carried forward (U.S. Department of Energy, 1995a, pp. OH 14 to 15). DOE appears to have given little, if any, consideration to the similarity of the technical and health issues related to the residues. Indeed, disposal planning at the two sites appears to have been carried out with little consideration given to applying information or approaches developed at one site to the problems at the other. This is apparently attributable to the initial decision to consider the two sites independently, largely because of the different management organizations now responsible for them. The committee recently completed a report (requested by DOE/EM-40) on the safety of the high-level uranium ore residues at NFSS (National Research Council, 1995). Example The committee has analyzed in some detail the use of systems engineering to address the Hanford Reservation, Richland, WA, tank wastes and has found that Hanford’s system engineering plans are repeatedly derived from organizational structures rather than the actual physical remediation tasks. The top level breakdown consists of one system function—“Remedy Unsafe and Unacceptable Conditions”—and four program management functions such as “Manage Program” and “Obtain Public Acceptance.” At the next planning level, the system function was broken into seven elements which seemed to correspond more to organizational subunits than to logical system functional boundaries. For example, the waste materials still in the tanks were placed in a different element than the wastes that had leaked out of the tanks, reflecting an organizational division of tasks between DOE Office of Waste Management (EM-30) and DOE/EM-40. Systems engineering at
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program Hanford was discussed in a committee letter report (National Research Council, 1994) and will be analyzed in more detail in a committee report that is currently being completed. General Symptom 2: Commitments that are made without adequately considering technical feasibility, cost or schedule. The reward for solving “political” problems in the short term is perceived to be greater than the penalty for eventual delays, cost overruns, or technical failures. Example In the Record of Decision in 1987 associated with the Hanford Site final environmental impact statement (U.S. Department of Energy, 1987; see also Johnson et al, 1993), DOE deferred final decisions regarding disposal of single-shell tank wastes at Hanford until additional development and evaluation were completed. The interim “reference option” was stated to be stabilization in place. However, in 1991, DOE changed the planning basis from stabilization in place to one of removal; i.e., the presumption was that the waste would be removed, treated, and sent elsewhere for disposal unless it was shown to be safe to leave it in place (S.Cowan, DOE/EM-30, presentation to the committee, November 8, 1993, Washington, DC). An NRC panel, predecessor to the present committee, reviewed this issue in 1992, emphasizing the need to keep options open (National Research Council, 1992): Do not reduce the number of technology options or alternatives at this early stage in the study [for closure of the Hanford single-shell tanks]. It is unsuitable to foreclose any technology or alternative before the various benefits, risks, and costs have been thoroughly delineated and carefully reviewed. Yet, in the 1993 renegotiation of the Hanford Federal Facility Agreement and Consent Order (Hanford Triparty Agreement or TPA) (Washington State Department of Ecology, United States Environmental Protection Agency, and United States Department of Energy, 1994), the new planning basis became a legal commitment. The revised agreement dropped a previous reference to a supplemental environmental impact statement and added the requirement for essentially complete retrieval of the waste (amounting to 99 percent or more of the inventory of the tanks containing most of the waste) as a formal requirement for tank closure. This requirement can be waived on a tank-by-tank basis, but only on the basis of technical necessity. Under the TPA, other criteria such as cost and radiation exposure are relevant only to the evaluation of closure options for the tanks after retrieval of their contents, and not to the determination of how much of the contents to remove in the first place. The committee has seen no analysis demonstrating that essentially complete waste removal is technically achievable or even advisable for all or many of the tanks. Neither has the committee seen any analysis of the full range of costs and impacts of such retrieval, even for a case in which it may be technically achievable. On the contrary, in the Tank Waste Technical Options Report (Boomer et al., 1993), published prior to renegotiation of the agreement, the authors examined a range of potential retrieval technologies and concluded that “Little is known about actual retrieval performance with SST [single-shell tanks] tank
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program wastes” (p. 6–44). This statement remains true today. Consequently it appears that the decision to make legally binding the commitment to retrieve essentially all of the contents of the single-shell tanks on an enforceable schedule, subject only to considerations of technical feasibility, was made without a technical basis. Example After detailed studies, DOE determined that grouting was a satisfactory treatment method for the low-level fraction of the Hanford tank wastes (Boomer et al., 1991). However, stakeholders objected. The objections appear to have been based in part on the need for a substantial land area to store grouted wastes and on a concern that grouting would lessen the likelihood that the wastes will eventually be removed from the Hanford site. In response to these objections, the 1993 renegotiation of the Hanford TPA committed DOE to vitrification of the low-level tank waste fraction using technology that, it was thought, was close to being available. In fact, the decision to vitrify was made without experimental evidence that vitrification of this fraction would produce a satisfactory waste form, without any serious cost analysis of vitrification, and without knowing what preliminary processing steps would be needed to produce a material that could be vitrified into an acceptable waste form. Example DOE agreed to classify all Hanford in-tank waste as being governed by the Resource Conservation and Recovery Act (RCRA) hazardous waste rules, although a good argument can be made that underground storage tanks taken out of operation before July 26, 1980, are not subject to RCRA closure requirements. The Hanford TPA by fiat applies both RCRA closure and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to all tank wastes. This provision has the dual effects of introducing state RCRA requirements for tank wastes and of greatly complicating the remediation process. This is so because (1) the Washington State Department of Ecology rules concerning wastes classified as hazardous under RCRA are sometimes more restrictive than the federal rules, (2) RCRA prohibits leaving hazardous wastes in place, and (3) DOE must simultaneously comply with RCRA and CERCLA, whereas private sector sites subject to RCRA hazardous wastes rules are not subject to CERCLA requirements except in special cases. DOE consent to this classification of tank wastes foreclosed significant technological options in the cleanup of the Hanford tanks and created the possibility of a potential cost increase in the range of billions of dollars. As far as the committee has been able to determine, this commitment was made with little or no examination of the technical or financial ramifications of the decision. In addition, apparently no consideration was given to possible negotiation of the relevant work milestones in the Hanford TPA with the co-signing regulatory agencies. Example Storage silos at the FEMP Site, Fernald, OH, contain the radium and thorium residues associated with recovery of uranium from very rich ores during the early
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program years of World War II. The present waste management plan calls for removing these radioactive residues from the storage silos, vitrifying them, and shipping them to the Nevada Test Site in Mercury, NV (U.S. Department of Energy, 1994, p. 57). A range of waste management options, including that of leaving the residues on site, was considered. The choice of vitrification and shipment off site appears to have been driven in large part by the preferences of local stakeholders and the state of Ohio. Vitrification was apparently chosen as the means of immobilizing the residues with only limited knowledge of how the vitrification process would actually be carried out. A pilot plant is under construction that will be used to vitrify some of the residues. If the pilot runs are satisfactory, those parts of the plant that are not already at full size will be enlarged. However, it appears that preliminary small-scale testing was carried out at substantially lower temperatures than those at which the plant will actually operate. There is therefore reason for concern about the success of the vitrification operation. Several of the above examples involve the Hanford TPA. The committee has discussed the DOE negotiation strategy for the 1989 Hanford TPA with numerous individuals both within and outside of DOE. The clear consensus is that at the time of negotiation, DOE delegated significant authority from headquarters to field personnel. Headquarters provided little guidance on the substance of the negotiation beyond giving the operations office a strong signal to reach an agreement with the state and EPA as soon as possible. In achieving this agreement, DOE appears to have given up significant legal rights and imposed extremely complicated and costly requirements upon itself for cleaning up the Hanford tank wastes. General Symptom 3: An inability to look at more than one alternative at a time. In these cases, the selected alternative becomes the organizational goal, rather than the purpose for which the alternative was chosen. Example Protection of buried waste against infiltrating rain water has great importance for Hanford and for other DOE defense nuclear waste sites located in the arid western United States. The Committee feels that achieving this protection is especially important, given the staggering costs associated with removal and disposal of contaminated soils and waste materials, the need for interim isolation of portions of the subsurface environment, and the inevitability of leaving some contamination in the ground. Teams at Hanford have developed approaches and designs both for surface barriers, which would prevent rainfall infiltration and mammal intrusion for very long periods of time, and for subsurface barriers, which would isolate Hanford’s underground storage tanks and prevent migration of wastes from leaking tanks. In the latter instance, the committee’s concern is that the tank contents be removed without additional migration of waste constituents.
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program Work on the surface barriers has progressed to a point where a prototype of one particular design, the “Hanford Barrier,” has actually been installed over a crib for which subsurface characterization data were available. The committee views this well-instrumented prototype as an important project which will yield data of great value and interest, not only to Hanford, but to all DOE sites in the arid West, as well as other parties working in the environmental remediation arena. Notwithstanding the pressing need for this barrier technology, it is the committee’s understanding that funding for the data collection and evaluation of the barrier has been terminated. Historically, much of the support for the Hanford Barrier project came from the tank waste management program. With the decision to remove tank wastes, the tank waste management program no longer considers barriers to be a priority—in spite of the substantial technical and budgetary questions about whether removal of the wastes is possible and about the possibility of additional leakage during removal. Although the committee understands the occasional need to shift priorities and resources, it does not understand the cessation of monitoring of this prototype barrier experiment, especially because much of the investment has already been made and the barrier has many potential applications other than to the tanks including development of barriers associated with other remediation activities. Example From 1979 to 1981, the Office of Nuclear Waste Management of the Department of Energy established an “Alternative Waste Form Review Panel” chaired by Professor Larry Hench (Hench et al, 1979, 1980, and 1981). The panel met three times, conducting an extensive review of waste forms that included borosilicate glass, synroc, high silica glass, concrete, metal matrices and a wide variety of coated particles. Borosilicate glass was evaluated as the reference waste form for comparison to the alternatives. In the final ranking, borosilicate glass was recommended for vitrification of the Savannah River waste, and synroc, a crystalline ceramic, was selected as the top alternative—“the best characterized and understood of the non-borosilicate glass waste forms” (Hench et al, 1981). The panel recommended further work on alternatives, particularly synroc. With the decision to vitrify Savannah River waste, the alternative waste form program ended, however. Fifteen years later, a number of DOE laboratories are beginning the investigation of crystalline waste forms for defense waste, mixed waste, special waste streams, and new applications (e.g., disposition of excess weapons plutonium). As a result, nearly a decade of research and development has been lost with no substantive change in waste form technology for the past 15 years. Example When DOE agreed in the Hanford TPA to vitrify the low-level fraction of the Hanford tank wastes, it discontinued funding of grout waste forms, even though a pilot plant had been built, test runs had been conducted, and the facility was ready to go into operation. Given the technical and budget uncertainties about vitrification of this waste fraction, this decision raises significant questions about risk.
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program General Symptom 4: Priorities that are driven by narrow interpretation of regulations rather than the regulations’ purpose of protecting public health and the environment. DOE considers a regulatory requirement to be a virtually unchallengeable justification for expenditure, whereas technically based assertions about risk can be questioned. Example The Rocky Flats (CO) plant contains one of the larger inventories of plutonium in the DOE complex. Much of this material has been stored in temporary packaging since production at the plant shut down suddenly in 1989. Plastic packaging has deteriorated, producing hydrogen gas that could contribute to pyrophoric conditions. Solutions containing high concentrations of plutonium have been left in process tanks and pipes, and remain there as seals and flanges have begun to deteriorate and leak. Budget priorities at Rocky Flats have focused heavily on restoration of contaminated soil and ground water at the site as required by RCRA and CERCLA. Remedial investigations have been completed for two operable units, and field work is currently under way for seven others. Although the environmental contamination at Rocky Flats is a very real problem, the threat it poses is not of the same severity as the plutonium storage problems (Consortium for Environmental Risk Evaluation, 1995). Only after the Defense Nuclear Facilities Safety Board sharply criticized DOE’s priorities at Rocky Flats in its recommendation 94–1 (Defense Nuclear Facilities Safety Board, 1994), and a variety of stakeholders—including plant employees and State of Colorado regulators—called for a greater emphasis on stored plutonium, did DOE Office of Environmental Management (EM) announce a reorientation of priorities in the proposed 1996 budget. Example The first version of the Hanford TPA required detailed characterization of each of the 177 large waste tanks for all parameters listed for waste analysis under RCRA, including even pesticides. This requirement was driven by a perception that the RCRA rules must be followed to the letter, rather than by program needs for specific information. Only after it became clear that this approach to characterization was too slow and unreasonably costly and risky, was a more rational characterization plan—one keyed to the information actually needed—developed. General Symptom 5: The production of documents as an end in itself, rather than as a means to achieve a goal. A document is a bureaucratically measurable achievement, whereas cleanup is often a distant goal. Example The Hanford Site-Wide Document Hierarchy (reproduced as Figure 1 from Westinghouse Hanford Company, 1994) contains a mix of program directives and policies, work breakdown structures, costs and schedules, and system technical descriptions. This hierarchy clones itself for site, program, and project levels. The multiplication of documents results in unnecessary repetition of content and over-complication.
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program FIGURE 1. Hanford Site Information and Document Hierarchy (Westinghouse Hanford Company, 1994, Figure 1.1).
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program Example In 1993, a Congressional conference committee directed DOE to submit a report “evaluating the risk to public health and safety posed by the conditions at weapons complex facilities that are addressed by compliance agreement requirement” (from 103d Congress House of Representatives Report 103–305, copied in U.S. Department of Energy, 1995b, p. A-4). The report was to be used to help establish priorities. In response to this mandate, DOE involved many contractor and government employees in a multi-million-dollar report-writing effort. In producing a document whose size was commensurate with the expenditure, large amounts of detailed information had to be collected from the individual sites. As a result, DOE Headquarters found itself relying on the sites’ own evaluations of the degree of risk which each activity addressed. Given the natural tendency of organizations to justify their own budgets, this reliance greatly reduced the usefulness of the report for its original purpose. This sequence of events must be viewed in the context of the numerous and uncoordinated reporting requirements that Congress places on DOE. The clear intent of the conference committee—to force the agency’s top management to confront priority decisions—is undercut by a stream of demands that eat away at managers’ time. The treatment of reports as ends in themselves rather than occasions for thinking is, in part, a consequence of the demand for too many reports. Example The Hanford Site-Specific Science and Technology Plan (Pacific Northwest Laboratory, 1993) laid out a systematic methodology for ranking needs for development of new science and technology based on inputs from stakeholders. But when the methodology was applied, the only stakeholders consulted were the “problem owners”—the DOE managers. Furthermore, the methodology used to rank needs was ignored when the results did not support existing priorities. For example, the report attempts to explain away the significance of the highest ranked problem (pre-1970 buried waste) on the grounds that the “wrong group” was doing the ranking. Retrieval of contaminated soils, on the other hand, was ranked low, but was nevertheless kept in the plan. Like many other DOE “planning” documents, this plan was never used to direct research and development activities. The committee finds this unfortunate and believes this is characteristic of how DOE has treated other studies that have provided guidance for technology selection and assessment.
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program Example A technology needs assessment conducted for DOE Office of Environmental Restoration (EM-40) by Chem-Nuclear Geotech, Inc. (1991) found a lack of communication among the DOE/EM-40, DOE Office of Technology Development, and field offices. The “Crosswalk Project” was initiated as an effort to improve communication among these groups and to provide a mechanism to link environmental restoration problems with potentially applicable technologies that are currently under development. The Technology Needs Crosswalk Report was published in 1993, presenting the results of the Crosswalk Project (Chem-Nuclear Geotech, Inc., 1993). The Crosswalk Project employed specially developed worksheets to collect information. It then generated keywords to facilitate matching problems and technologies. Although there is no doubt that the exercise did result in a compilation of information, the linkage that was developed was based entirely on information collected by contractors during a limited time period. The resulting data base, the development of which became the goal of the Crosswalk Project, is not being used. It appears that the report did nothing toward its original objective of enhancing continuing communication between technology developers and users. Too often, DOE undertakes elaborate paper studies without any effort or intention to develop new or substantive results. Repeatedly, studies are structured so as to justify existing spending patterns rather than critically analyzing needs and priorities. In the 2–1/2 years of the committee’s existence, its Technology Development Subcommittee has been briefed several times on DOE methods for identifying technology needs and prioritizing research efforts. Before being able to complete an evaluation of any one of these methodologies, the subcommittee was advised that it had been replaced with yet a different approach. General Symptom 6: A lack of organizational coordination. Organizational subunits lack motivation to help solve each others’ problems. Example Lack of coordination between DOE’s Offices of Waste Management (EM-30) and Environmental Restoration (EM-40) organizations appeared to be impeding meeting milestones established by interagency agreements related to various DOE facilities between DOE and federal and state regulatory agencies (often called triparty agreements). In an effort to ensure adequate coordination, these two organizations issued a Memorandum of Understanding (MOU) on September 15, 1992, establishing a Facilities Planning Board at DOE Headquarters “to review all recommendations for new facilities and to determine the need, scope, management, and funding strategy for each recommendation” (cover letter of MOU). However, the MOU does not address underlying factors which drive decisions under the agreements, such as the unknown future land use at Hanford. Furthermore, the MOU contains no mechanism to influence the DOE-state-EPA negotiations that directly affect the mission of both organizations.
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Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program Example Two years after the MOU between EM-30 and EM-40, DOE created an Office of Facility Transition and Management (EM-60) and issued a memorandum to improve coordination of its subunits (memorandum from J.J.Fiore and L.A.Weiner, dated September 8, 1994, entitled “Facility Transition Processes and Procedures”). This memorandum requires EM-60 to take responsibility for those “orphan” facilities no longer needed by EM-30, that EM-40 was not ready to accept. The memorandum also orders EM-40 and EM-60 to coordinate their activities by establishing formal points of contact that are required to meet at least every other month. The MOU explicitly requires that these individuals meet and communicate among themselves. Further, the cover letter to this MOU contained an extraordinary admonition to “…not wait for this or any other meetings to continue or initiate frequent and routine communication between your headquarters and field POCs [points of contact]”. Facility transition, deactivation, and decommissioning cannot be done in a vacuum, but must be done in light of standards for cleanup and future land uses agreed to by DOE. Surprisingly, the MOU between EM-40 and EM-60 fails to require that either subunit be part of the negotiations to establish the standards by which facilities are transferred. The committee notes that DOE/EM-60 has recently been reorganized. It is not yet clear, however, whether this represents a fundamental change in its mission. The fact that the DOE Office of Environmental Management (EM) has been compelled to rely upon MOUs between its own subunits reflects deep organizational problems. Rather than being directed by their top management to respond together to the realities of the remediation agreements and the physical characteristics of the individual sites, the subunits of DOE/EM have created additional bureaucratic mechanisms for coordination. General Symptom 7: A “not-invented-here” syndrome at individual sites. Technical problems are often treated as excuses to seek funding for a new program, rather than as obstacles to be overcome. Example As discussed above, the committee found that work of great importance concerning barrier technologies is being done at Hanford. The committee also observed similar barrier activities at Idaho National Engineering Laboratory (INEL) near Idaho Falls, ID. It is not clear, however, that the separate teams doing the investigations have had the full benefit of each other’s work. In fact, while the objectives of the surface barriers are clearly the same at both facilities, and the general climate and geology are similar, different approaches are being taken to their designs. This, in itself, may be a good thing. But the concern remains that the work is not being coordinated as well as it could be. Rather, the impression is that the two facilities are making independent efforts to solve a common problem without adequate communication.
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