In November 1989, the Department of Energy (DOE) established the Office of Environmental Management (EM) to manage the cleanup of waste and environmental contamination from the Manhattan Project and Cold War-era production of nuclear materials at more than 100 sites around the country. The EM cleanup mission is to reduce health and safety risks from legacy1 radioactive waste and environmental contamination to meet applicable regulations and agreements (DOE, 1996). The cleanup is not intended to remediate the sites to the point of unrestricted reuse (“greenfield”).
At one time, DOE estimated that completing the cleanup would cost $300 billion and require 70 years. In early 2002, DOE completed a top-to-bottom review of EM’s programs and accomplishments (DOE, 2002a). As a result of the review, EM, working with federal and state regulators and local governments, developed an accelerated program with the goal of completing its cleanup mission by the year 2035 at a total life-cycle cost of about $142 billion (DOE, 2003, 2004). Currently, EM is considering how the schedule and costs might be reduced further, without compromising health and safety.
EM commissioned this study by the National Academies’ Board on Radioactive Waste Management (BRWM) to provide technical advice for its accelerated cleanup program (see Sidebar 1.1).
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Improving the Characterization and Treatment of Radioactive Wastes for the Department of Energy’s Accelerated Site Cleanup Program 1 Introduction In November 1989, the Department of Energy (DOE) established the Office of Environmental Management (EM) to manage the cleanup of waste and environmental contamination from the Manhattan Project and Cold War-era production of nuclear materials at more than 100 sites around the country. The EM cleanup mission is to reduce health and safety risks from legacy1 radioactive waste and environmental contamination to meet applicable regulations and agreements (DOE, 1996). The cleanup is not intended to remediate the sites to the point of unrestricted reuse (“greenfield”). At one time, DOE estimated that completing the cleanup would cost $300 billion and require 70 years. In early 2002, DOE completed a top-to-bottom review of EM’s programs and accomplishments (DOE, 2002a). As a result of the review, EM, working with federal and state regulators and local governments, developed an accelerated program with the goal of completing its cleanup mission by the year 2035 at a total life-cycle cost of about $142 billion (DOE, 2003, 2004). Currently, EM is considering how the schedule and costs might be reduced further, without compromising health and safety. PROSPECTUS AND STATEMENT OF TASK EM commissioned this study by the National Academies’ Board on Radioactive Waste Management (BRWM) to provide technical advice for its accelerated cleanup program (see Sidebar 1.1). 1 DOE uses the term “legacy” in reference to sites, facilities, and materials (including waste and environmental contamination) associated with its former research and production activities. See Linking Legacies (DOE, 1997).
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Improving the Characterization and Treatment of Radioactive Wastes for the Department of Energy’s Accelerated Site Cleanup Program Sidebar 1.1 KEY EXCERPTS FROM THE STUDY PROSPECTUS Opportunities for Accelerating Characterization and Treatment of Waste at DOE Nuclear Weapons Sites In 2001, EM announced that it was changing the paradigm for its cleanup program, focusing on reducing the large risks at its sites to residual levels and managing remaining hazards through long-term stewardship… EM recognizes that, to achieve these “accelerated cleanup” schedule and cost goals, it must make more effective use of its existing cleanup capabilities and wiser investments in cleanup technology R&D. To this end, EM is asking the National Academies to identify opportunities for improving waste characterization and treatment approaches at its sites, and also to identify opportunities for technology R&D to provide for future improvements in characterization, treatment, and disposal capabilities. … EM is responsible for characterizing, treating, and disposing of thousands of physically and chemically distinct waste streams that are currently in storage or will be generated during site cleanup… Characterizing and treating these waste streams to make them suitable for disposal may be difficult and/or expensive because of their large volumes, physical and chemical complexity and heterogeneity, and radioactivity or toxicity. Because many similar waste streams exist at multiple sites, EM also is faced with the choice of constructing duplicate characterization, treatment, and (in some cases) disposal facilities, or else transporting waste between sites. There are likely to be many opportunities for optimizing the characterization and treatment programs across EM sites to more effectively utilize existing capabilities and to develop new capabilities that can serve multiple sites or purposes. In its statement of task (see Sidebar 1.2), the committee was asked to identify opportunities for EM to make more effective use of its existing facilities and capabilities for waste characterization and treatment, including eliminating self-imposed requirements that have no clear safety or technical basis; for EM to improve its characterization and treatment capabilities especially for “orphan” wastes;2 and for EM to invest in new technologies to achieve these improvements. APPROACH TO THE STATEMENT OF TASK To help ensure that its accelerated cleanup schedule could be achieved, EM instructed each site to develop a Performance Management Plan (PMP) 2 Orphan wastes have no generally agreed-upon path for their disposition. Often, but not always, they exist in small quantities, which make them unattractive for inclusion in cleanup contracts. Nonetheless, their presence at a site can interfere with that site’s closure.
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Improving the Characterization and Treatment of Radioactive Wastes for the Department of Energy’s Accelerated Site Cleanup Program Sidebar 1.2 STATEMENT OF TASK The National Academies will identify opportunities for improving the DOE Office of Environmental Management’s waste characterization and treatment capabilities, particularly with respect to the following: Making more effective use of existing capabilities and facilities for waste characterization, treatment, or disposal and eliminating self-imposed requirements that have no clear technical or safety basis. Improving characterization and treatment capabilities to achieve step efficiency improvements or to treat orphan waste streams. Recommendations on technology development and demonstration investments that EM should make over the near term to achieve these improvements. The study will focus on waste streams for which current characterization, treatment, or disposition pathways are difficult and (or) expensive, and for which improvements would help reduce costs, schedules, and hazards to workers, public, or the environment. that laid out the schedules and strategies (“baselines”) for that site’s accelerated cleanup. The committee used these as frameworks for information-gathering visits that included EM’s four largest sites: the Oak Ridge Reservation, Tennessee; the Savannah River Site, South Carolina; the Idaho National Engineering and Environmental Laboratory; and the Hanford Site, Washington. Presentations to the committee included an overview of the site’s cleanup objectives and its initiatives for accelerated cleanup, as described in the PMP. Site personnel gave details of the initiatives for which they felt the committee’s advice would be most useful, including the assumptions and criteria for success underlying each initiative. The committee used these site-specific overviews along with its own collective expertise to identify opportunities for accelerating characterization and treatment that would be practical to implement in the near term (see Sidebar 1.3). In the course of its information gathering, the committee decided it could best address the statement of task by interpreting “characterization” and “treatment” in the broad context of the sites’ cleanup needs. Characterization as discussed in this report includes determining the nature of wastes at DOE sites, (e.g., physical form, and chemical and radioisotopic contents) as well as environmental factors that might change the nature of the waste over time. Similarly, treatment includes actions necessary to prepare waste for shipment, storage or disposal or, more simply, to stabilize waste in place.
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Improving the Characterization and Treatment of Radioactive Wastes for the Department of Energy’s Accelerated Site Cleanup Program Sidebar 1.3 SCOPE OF THIS STUDY According to the study prospectus and statement of task, the committee restricted its deliberations to the following: Technical issues associated with waste characterization and treatment to support EM’s accelerated cleanup program. The committee focused on providing EM with technical advice while recognizing that non-technical factors will clearly affect the degree to which EM can implement this advice (see the final section in this chapter). The committee did not attempt to assess non-technical factors or examine EM’s “risk-based end state” concept for accelerating cleanup (Roberson, 2004).a Legacy wastes and contamination under the responsibility of EM at the time of this study. This includes wastes and contamination that EM will remove and dispose as well as wastes and contamination that EM will leave in place. Current and future wastes from non-EM programs are not considered. Major needs and challenges at the four largest EM cleanup sites according to the sites’ presentations and PMPs (see main text). The magnitude of the EM program as well as the limited time and resources for this study precluded a more comprehensive study. a A separate BRWM study commissioned by EM on the development of risk-based approaches for disposition of transuranic and high-level radioactive wastes was conducted in parallel with this study. In reviewing existing capabilities and facilities for possibly more effective use or retention, the committee paid special attention to those with applicability to problem or orphan wastes for which an effective disposition path will be needed to achieve accelerated cleanup. NON-TECHNICAL FACTORS BEARING ON THE COMMITTEE’S RECOMMENDATIONS In this report the committee identifies opportunities for EM that are technically feasible and aligned with the near-term goals of accelerated cleanup. The committee is aware that many non-technical factors will bear on EM’s ability to implement its recommendations. The committee did not attempt to pre-judge how non-technical issues might limit or foreclose valid technical opportunities. Nevertheless it is clear that for accelerated cleanup to succeed, EM must collaborate with the Environmental Protection Agency (EPA), state regulators, local governments, and other involved stakeholders. All of EM’s proposed cleanup activities require the support of regulators and other stakeholders outside of EM and the field offices.
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Improving the Characterization and Treatment of Radioactive Wastes for the Department of Energy’s Accelerated Site Cleanup Program Public Concerns Each of the committee’s site visits included opportunities for public participation. During these sessions, citizens and representatives of citizens’ groups remarked on generally deteriorating relations with DOE. Public concerns and opposition, which, for example, have led to significant legal challenges to DOE’s plans for some of its high-level tank wastes and buried transuranic wastes (NRDC, 2003; PSCC, 2003), can potentially derail EM’s accelerated cleanup program. The committee did not examine the impact of public concerns on EM’s cleanup plans. The committee recognizes that public concerns could be significant barriers to EM’s implementing the recommendations in Chapter 3, which describes opportunities for maintaining or extending the use of a few existing characterization and treatment facilities at DOE sites. Public concerns would include security, safety, and equity issues. As noted in the study prospectus, optimizing the use of a few centralized facilities may require transporting wastes among sites—although the volumes of the problematic and orphan wastes primarily addressed in this report would be small compared to the ongoing shipments to the Waste Isolation Pilot Plant in New Mexico and those planned for the Yucca Mountain repository in Nevada. The committee did not address public concerns regarding the safety of waste transportation or shipping wastes into their states for treatment. At the committee’s public sessions, several citizens and representatives of citizens’ groups suggested that improved communication about site planning, additional stakeholder meetings, and funding of liaison positions would benefit EM’s accelerated cleanup efforts at little financial cost to EM. The committee agrees that good public communication and transparency are essential. In Chapter 2 the committee recommends greater use of DOE’s removal action authority to expedite cleanup, which formally reduces the public comment period for these actions. The committee did not address how citizens might perceive the shortened comment period, but it would seem that proceeding with actions to reduce risks might be viewed more favorably than protracted discussions. Chapter 4 introduces a concept for managing wastes that EM will leave on DOE sites that the committee believes has technical advantages and may help mitigate public concerns about these residual wastes. Regulatory Constraints EM’s ability to implement the technical opportunities identified by the committee will be subject to present and future agreements, permits, and regulations among the sites, their host states, and the EPA. In reviewing the
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Improving the Characterization and Treatment of Radioactive Wastes for the Department of Energy’s Accelerated Site Cleanup Program sites’ PMPs, the committee noted that many of the basic assumptions for achieving accelerated cleanup hinge on regulatory issues that are outside of EM’s control; and in addition there are legal challenges such as the recent court rulings in Idaho (NRDC, 2003; PSCC, 2003). The committee also noted that each site has specific agreements with its state and their EPA regions and that these agreements account for some of the variations in the DOE field offices’ approaches to site cleanup. In identifying opportunities for accelerating waste characterization and treatment, the committee was mindful of the main agreements and regulations under which EM and the sites operate, and none of this report’s recommendations are intended to circumvent them. However, the committee did not make a detailed examination of laws, agreements, and regulations that might constrain its recommendations. The committee recognizes that the “DOE self-imposed restrictions” discussed in Chapter 2 have in some cases been incorporated into agreements with regulatory or permitting agencies so that the recommended opportunities might not be implementable at all sites. EM’s ability to implement recommendations in Chapter 3 on maintaining characterization and treatment facilities, and transporting waste among sites to optimize their use, will be constrained by applicable agreements and regulations, as will its options for leaving wastes in place discussed in Chapter 4. Economic Factors As noted at the beginning of this chapter, EM’s accelerated cleanup program is directed at reducing cost and schedule to the greatest extent possible without compromising health and safety. For perspective, the committee used estimates provided by EM headquarters and the sites in their presentations and in their PMPs. However, the committee did not attempt to quantify costs or savings that might be associated with the technical opportunities it identified. Taking advantage of the administrative opportunities to expedite or simplify characterization and treatment described in Chapter 2 and the approaches for managing waste in place identified in Chapter 4 should result in substantial cost savings. Maintaining the facilities identified in Chapter 3 will be very expensive—restarting the INEEL incinerator could cost several hundred million dollars—however, the committee believes that the options it has identified may be less expensive than the alternatives. Interactions with other DOE Offices, the Sites, and Site Contractors The DOE Assistant Secretary for Environmental Management commissioned this study, and the committee’s recommendations are directed pri-
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Improving the Characterization and Treatment of Radioactive Wastes for the Department of Energy’s Accelerated Site Cleanup Program marily to EM headquarters. In this sense the committee’s recommendations are directed “top down.” The committee did not attempt to assess the interactions among EM, other DOE offices (Legacy Management, National Nuclear Security Administration), the sites, or site contractors3 that would ultimately be necessary to implement the recommendations. These relationships may inhibit or possibly help implement the recommendations. The committee intends and hopes that the opportunities it has identified are useful to the broader audience that is involved with site cleanup, including congressional staff, DOE, the sites, regulators, contractors, and concerned citizens. Changes in the DOE organization that occurred as this report was being completed serve as reminders of the need for a solid scientific and technical basis for site cleanup even as non-technical factors remain in flux.4 3 Site contractors, through the bidding process, will ultimately determine how technical enhancements recommended in this report might be implemented. 4 EM Assistant Secretary Roberson resigned, EM reorganized, and the Office of Legacy Management was established.