VII
Monitoring

The committee has been charged by Congress in Section 3146 of the National Defense Authorization Act (NDAA) of Fiscal Year 2005 to evaluate “the adequacy of the Department’s plans for monitoring disposal sites and the surrounding environment to verify compliance with [the 10 CFR 61] performance objectives” and has been asked to recommend “the best means of monitoring any on-site disposal sites from the waste streams referred to above to include soil, groundwater, and surface water monitoring.”1 This chapter is one of the shortest in the report because the Department of Energy (DOE) has not yet, for the most part, developed plans for post-closure monitoring of the tanks, so the committee could not evaluate the adequacy of such plans. At the Idaho National Laboratory, long-term monitoring plans have been (and will continue to be) developed in compliance with records of decision for radioactive waste that spilled, leaked, or was injected into the ground at the Idaho Nuclear Technology Engineering Center, where the tank farm is located. These plans are discussed specifically, but in the rest of its evaluation, the committee has focused on the overall approach and structure used in DOE’s current monitoring programs at the sites. The committee’s findings and recommendations are consistent with this high-level review and do not focus on specific methods or on small details such as the placement of a particular monitoring well. Further, this chapter is devoted to technical issues, not to legal or regulatory issues, which are discussed in Chapter VIII.

As defined in 10 CFR 61, “monitoring means observing and making measurements to provide data to evaluate the performance and characteristics of the disposal site.” DOE conducts monitoring in different stages, which can be related to the different stages of activity at the disposal sites: site characterization, operations, closure, observation or surveillance, and active institutional control (see, e.g., USNRC, 1997b). Each stage of monitoring may require different types of data. In addition, regulatory programs (under the Resource Conservation and Recovery Act [RCRA], the Comprehensive Environmental Restoration, Compensation, and Liability Act [CERCLA], and so forth) have specific data needs. Although monitoring at different stages and for different purposes has different goals and may try to answer different questions, it is desirable to coordinate all monitoring at a site. In addition to these different programmatic stages or time frames, monitoring takes place at different spatial scales, namely facility or disposal site monitoring and overall or site-wide monitoring (e.g., monitoring of the Saltstone Disposal Facility and site-wide monitoring for the Savannah River Site). Similarly, monitoring for conditions at these different spatial scales may have different objectives. For example, monitoring to confirm the expected performance behavior of a particular disposal facility would seek to encounter any contaminant plume from the facility, while monitoring at a site-wide level might gather data on the hydrologic budget at the site.

The committee has identified seven features of a good monitoring program. A good monitoring program: (1) is goal oriented; (2) has an integrated vision of monitoring for the overall site; (3) seeks relevant information in the right places; (4) observes the environment (both natural and constructed) and the dynamics that affect processes of interest; (5) provides early warning to enable intervention, if necessary; (6) is subjected to review on a regular basis and adapts to changing circumstances; and (7) archives data in a durable and accessible form. Each of these features is described in Appendix H. The committee used these features as metrics for evaluating the DOE monitoring programs. Because data

1

Section 3116 of the 2005 National Defense Authorization Act charges the U.S. Nuclear Regulatory Commission, in coordination with the host state, to monitor “disposal actions” to assess compliance with the provisions of that section of the law. There has been some debate (e.g., the U.S. Nuclear Regulatory Commission’s public meeting on November 10, 2005) as to what monitoring compliance comprises. Unless otherwise indicated, theterm monitoring in this report means monitoring the disposal facility, the environment of the disposal sites, and the surrounding areas, not monitoring waste processing activities or construction of the disposal facilities.



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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report VII Monitoring The committee has been charged by Congress in Section 3146 of the National Defense Authorization Act (NDAA) of Fiscal Year 2005 to evaluate “the adequacy of the Department’s plans for monitoring disposal sites and the surrounding environment to verify compliance with [the 10 CFR 61] performance objectives” and has been asked to recommend “the best means of monitoring any on-site disposal sites from the waste streams referred to above to include soil, groundwater, and surface water monitoring.”1 This chapter is one of the shortest in the report because the Department of Energy (DOE) has not yet, for the most part, developed plans for post-closure monitoring of the tanks, so the committee could not evaluate the adequacy of such plans. At the Idaho National Laboratory, long-term monitoring plans have been (and will continue to be) developed in compliance with records of decision for radioactive waste that spilled, leaked, or was injected into the ground at the Idaho Nuclear Technology Engineering Center, where the tank farm is located. These plans are discussed specifically, but in the rest of its evaluation, the committee has focused on the overall approach and structure used in DOE’s current monitoring programs at the sites. The committee’s findings and recommendations are consistent with this high-level review and do not focus on specific methods or on small details such as the placement of a particular monitoring well. Further, this chapter is devoted to technical issues, not to legal or regulatory issues, which are discussed in Chapter VIII. As defined in 10 CFR 61, “monitoring means observing and making measurements to provide data to evaluate the performance and characteristics of the disposal site.” DOE conducts monitoring in different stages, which can be related to the different stages of activity at the disposal sites: site characterization, operations, closure, observation or surveillance, and active institutional control (see, e.g., USNRC, 1997b). Each stage of monitoring may require different types of data. In addition, regulatory programs (under the Resource Conservation and Recovery Act [RCRA], the Comprehensive Environmental Restoration, Compensation, and Liability Act [CERCLA], and so forth) have specific data needs. Although monitoring at different stages and for different purposes has different goals and may try to answer different questions, it is desirable to coordinate all monitoring at a site. In addition to these different programmatic stages or time frames, monitoring takes place at different spatial scales, namely facility or disposal site monitoring and overall or site-wide monitoring (e.g., monitoring of the Saltstone Disposal Facility and site-wide monitoring for the Savannah River Site). Similarly, monitoring for conditions at these different spatial scales may have different objectives. For example, monitoring to confirm the expected performance behavior of a particular disposal facility would seek to encounter any contaminant plume from the facility, while monitoring at a site-wide level might gather data on the hydrologic budget at the site. The committee has identified seven features of a good monitoring program. A good monitoring program: (1) is goal oriented; (2) has an integrated vision of monitoring for the overall site; (3) seeks relevant information in the right places; (4) observes the environment (both natural and constructed) and the dynamics that affect processes of interest; (5) provides early warning to enable intervention, if necessary; (6) is subjected to review on a regular basis and adapts to changing circumstances; and (7) archives data in a durable and accessible form. Each of these features is described in Appendix H. The committee used these features as metrics for evaluating the DOE monitoring programs. Because data 1 Section 3116 of the 2005 National Defense Authorization Act charges the U.S. Nuclear Regulatory Commission, in coordination with the host state, to monitor “disposal actions” to assess compliance with the provisions of that section of the law. There has been some debate (e.g., the U.S. Nuclear Regulatory Commission’s public meeting on November 10, 2005) as to what monitoring compliance comprises. Unless otherwise indicated, theterm monitoring in this report means monitoring the disposal facility, the environment of the disposal sites, and the surrounding areas, not monitoring waste processing activities or construction of the disposal facilities.

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report from environmental monitoring play a key role in performance assessments (see Chapter VI), the committee has also evaluated the connection or integration of the long-term monitoring programs to the performance assessment programs. To evaluate DOE monitoring programs with respect to these features, the committee visited the sites, received input during public meetings, and reviewed documents. Several committee members followed up those information-gathering activities with conference calls with site personnel, which allowed detailed questioning on specific topics. In preparation for these discussions, the committee provided Hanford, Idaho National Laboratory, and Savannah River Site personnel with a list of questions that served as the bases for the discussions. In what follows, the evaluation of DOE’s monitoring programs is organized using the features cited above. Monitoring requirements at sites will shift based on the stage of site development and the evolving state and understanding of the biological, hydrological, and geological features of these complex sites. The committee recognizes that no single monitoring program is suitable for all sites or all stages of site development; rather, monitoring requires careful, site-specific and time-specific planning to ensure that “data of the type and quality needed, and expected for their intended use, are provided, and that decisions involving the design, construction, and operation of environmental technology are supported by appropriate quality-assured engineering standards and practices” (IDQTF, 2005). DOE’S MONITORING PROGRAMS Monitoring the Aquifer and Perched Water at the Idaho National Laboratory DOE has developed long-term monitoring plans under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) for waste releases (spills, infiltration, and injection) at the Idaho National Laboratory (INL), including the area in the vicinity of the tank farms (DOE-ID, 2003c, 2004a). This monitoring program for the aquifer and perched water at the Idaho facility, with the associated quality assurance project plan (DOE-ID, 2004b), provides an excellent example of the level of effort and institutional commitment required for site-level monitoring. It illustrates well the linkage that must exist between monitoring and the decision support system for site management. To address the long term, the plan establishes an adaptive process that could extend to 2095. CERCLA monitoring plans emphasize the groundwater pathway; this plan was not integrated with a more broadly based environmental effects element that would include an ecological monitoring plan, although the site has indicated that an ecological monitoring plan may be required when a final cleanup alternative is selected for the tank farm soils. For closure of the tank farms at each of the three sites, it is desirable to have a monitoring plan such as the one in place at the Idaho National Laboratory, but that extends beyond 100 years and explicitly considers the integration with monitoring of other media and the biosphere. Evaluating Current Monitoring Programs Goal Oriented Monitoring at Hanford, the Idaho National Laboratory, and the Savannah River Site is complex, highly variable, and site specific. As the sites’ processing and disposal operations have evolved, so has monitoring. Monitoring programs have been developed under CERCLA or RCRA requirements with state and, in some cases, U.S. Environmental Protection Agency (EPA) oversight. Monitoring requirements under these regulations are used widely at sites across the nation and, thus, have been field tested in many different situations. However, it was difficult to evaluate fully what monitoring would be adequate at any of the sites because the interpretation of monitoring program goals varies based on the intricate histories of interactions between each site and its regulators. Nonetheless, the committee’s overall impressions are that the sites’ monitoring programs are good at fulfilling their current goals, which in most cases are site characterization, operations monitoring, and provision of data to assess compliance with RCRA, CERCLA, and, or state groundwater quality requirements. The programs have been developed recognizing the importance of good data. There is an evolving understanding of the dynamics of contaminant movement on the sites. Investigators continue to be surprised as monitoring finds the unexpected, but these “surprises” are leading to improved understanding of the dynamics and drivers of fluid and contaminant movement (see examples in the section “Provides Early Warning”). As noted at the beginning of this chapter, DOE’s plans for post-closure monitoring (including monitoring for compliance with performance objectives) have not, for the most part, been developed at the sites. “DOE Order 435.1 requires that high-level waste facilities “be closed in accordance with an approved closure plan … [which] shall include … relevant closure controls including a monitoring plan, institutional controls and land use limitations to be maintained in the closure activity” (DOE, 2001a). It is understandable that post-closure monitoring is not DOE’s highest priority right now, considering that closure of the tank farms is still decades away. Plans are needed however before closure, because the monitoring systems will have to be built into the closure system as required for low-level waste treatment and storage facilities.2 DOE Order 435.1 further requires a pre- 2 DOE’s radioactive waste management manual for Order 435.1 states, “Monitoring and/or leak detection capabilities shall be incorporated in the design and engineering of low-level waste treatment and storage facilities to provide rapid identification of failed confinement and/or other abnormal conditions” (DOE, 2001a).

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report liminary monitoring plan prior to disposal authorization for low-level waste. Before monitoring systems, or even the monitoring program, can be designed, DOE must know the goals and requirements. The complex regulatory environment for post-closure monitoring at DOE sites results in competing requirements and overlapping jurisdictions.3 At Hanford, DOE worked with the Environmental Protection Agency and the Washington Department of Ecology to develop a framework that fits together the regulatory goals and strategies for groundwater protection, monitoring, and remediation (DOE-RL, 2004b). When the parties expand this document to address the topics of vadose zone monitoring and long-term stewardship, the pieces will be in place to develop a long-term monitoring plan for all groundwater at Hanford. The Savannah River Site provided the committee with documents (e.g., WSRC, 2004b) that do not document well the site’s strategies and goals. Such goals have to be stated explicitly. Faced with the complex web of regulatory requirements described above, the Savannah River Site has asked the State of South Carolina, the Environmental Protection Agency, and the U.S. Nuclear Regulatory Commission to participate in a meeting to clarify the goals of post-closure monitoring and reach agreement on a single plan for monitoring that will meet the needs of all parties. Although no such meeting had taken place as of January 2006, agreeing on a common set of goals and parameters for the monitoring plans is a sensible first step, in the committee’s opinion. Has an Integrated Vision of Monitoring for the Site Although there have been efforts to do so, DOE has not yet fully articulated an integrated vision of monitoring for each site. Such an integrated vision would fit together the various monitoring goals for each site and establish an overarching strategy that provides a comprehensive view of the site beyond what is seen as necessary under one or another specific regulatory requirement. Each overall site has many disposal sites, classes of wastes, and contaminated areas that require monitoring, some with different requirements and different people overseeing the monitoring. For example, at Hanford the responsibility for monitoring tank leaks resides with a different contractor than monitoring for contaminants in the saturated zone. One manager is, however, responsible for all monitoring at each site and Hanford has a mechanism for integrating its efforts. The Hanford groundwater monitoring report for fiscal year 2004 (PNNL, 2005a) shows that Hanford has established a firm foundation and is making good progress in integrating both its various groundwater monitoring efforts and its modeling and monitoring efforts with each other. Hanford is continually updating its monitoring networks, making use of nontraditional well sampling techniques, and using monitoring data to develop a site-wide model of groundwater flow and contaminant movement. Results from the site-wide model provide feedback into the monitoring program. The committee encourages Hanford to continue this progress and to do more to integrate groundwater monitoring with other monitoring activities on the site. Hanford, the Savannah River Site, and the Idaho National Laboratory each issue annual environmental reports that describe results of monitoring in different media across the overall site (see, e.g., DOE-ID, 2004a; PNNL, 2005b; WSRC, 2005), and these are part of the picture needed for an integrated vision and monitoring plan. The sites described monitoring databases they are developing (the Idaho National Laboratory, at least, has this operational) to make all of the current and historical monitoring data available to scientists and technicians on the sites (see “Archives Information,” below). Another piece of an integrated vision is connected to the comprehensive performance assessment for all wastes and contamination on the overall site. Hanford’s effort to carry out this assessment is called the System Assessment Capability. Other sites have a composite analysis. The most recent composite analysis for the Savannah River Site, however, does not reflect any recent decisions or proposals for waste disposition and does not cover the overall site, although this concern is important only to the extent that potential impacts from radioactive materials at various locations on the site would overlap in space and time. It is not necessarily a concern in all cases. Seeks Relevant Information in the Right Places The sites are currently monitored extensively for both radioactive and nonradioactive constituents. Much of the programs’ focus is on groundwater, which is appropriate. The monitoring programs use geostatistical methods (e.g., kriging) to help make decisions about new monitoring well locations and what wells to discontinue using. Observes the Environment (both Natural and Constructed) and the Dynamics That Affect Processes of Interest Environmental monitoring at the sites has resulted in widespread site characterization. Each site has operated for periods that have allowed the acquisition of extensive datasets that can serve as baselines to compare against future monitoring data. Characterization data that precede DOE operations (i.e., data obtained during Atomic Energy Commission operations) vary, but in general each site has 3 The overlapping jurisdictions and regulatory requirements include federal CERCLA requirements for post-closure monitoring, state requirements under RCRA, state and U.S. Nuclear Regulatory Commission (USNRC) needs under Section 3116 (in Idaho and South Carolina) of the 2005 NDAA, and any other requirements agreed to under the federal facility agreements. Also, it should be noted that EPA and state environmental regulatory agencies show great interest in protection of groundwater as a resource (see Appendix C, Table C-3 for a list of requirements DOE considers applicable).

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report sufficient monitoring to support most site characterization activities. Vadose zone monitoring and investigations of geochemical behavior in the environment may be the exceptions to this observation. Further, each of the sites is supporting long-term ecological monitoring; indeed nationally recognized ecological monitoring programs exist at each site. Knowledge gained mostly through investigations of past releases has yielded a reasonably good understanding of the hydrology at the Savannah River Site, confirmed by following the progress of actual contaminant plumes. Monitoring and analysis of similar releases at Hanford and the Idaho National Laboratory have contributed to the understanding of contaminant transport at those sites, although transport in the subsurface at these sites, particularly the vadose zone, is more complex and not as well understood. At each of the sites, it appears that there is information adequate to characterize the present environment around the waste tank facilities and to guide the development of the performance assessments. However, as noted in Appendix H, monitoring must not be seen as a static process that is complete and finished at some point. For example, at Hanford, the groundwater flow is changing radically, with indications that the flow may actually reverse direction in some locations because DOE no longer discharges large quantities of contaminated water into the subsurface. To evaluate such events, an adequate long-term monitoring program needs to include a continuing performance assessment to confirm that the site is performing as expected and to point out where additional investigation or explanation is needed. Questions have been raised about DOE’s knowledge of the subsurface flow system beneath Hanford, particularly the locations and extents of clastic dikes and their effect on contaminant migration. It would be difficult to gain detailed knowledge of the subsurface beneath the tanks from the 60 groundwater wells around the tanks and the two slant boreholes that collected high-quality sediment samples and associated contaminants from under the tanks. Site personnel note that the dikes are relatively narrow and, thus, do not have a major effect on contaminant transport, and that there has been no specific case in which the dikes have been cited as the cause of anomalous transport. However, structural discontinuities can have a major impact on both flow direction and sorptive behavior at a local scale, such as beneath an individual tank farm. At the Idaho National Laboratory, the subsurface has proven to be much more complicated than initially thought because of perched aquifers and fracture flow. In recent years, Idaho National Laboratory personnel have created detailed maps of the perched water and interbedded layers to better understand the transport of contaminants from spills at the tank farm. DOE monitors existing engineered structures (caps and liners for disposal facilities) less consistently than it monitors the environment. At the Savannah River Site, the tank annuli are monitored with resistivity sensors and there are annual visual inspections to the extent that access allows, but fear of damaging piping has prevented the Savannah River Site from monitoring groundwater below the tank farms. Complicating this picture is the fact that the conditions expected after the tanks and disposal sites are closed may be somewhat different, with large capped mounds redirecting precipitation recharge away from areas containing the waste and facilities left on-site. Some monitoring personnel at the site speculate that even now, with the asphalt ground cover currently in place, the top aquifer may have a local depression under the tank farms caused by reduced surface infiltration and continued vertical flow through the aquitard. Current data are insufficient to confirm this idea. Several noninvasive geophysical options exist for locating buried pipes where exact locations are unknown. In areas where the surface soils are electrically resistive (i.e., low clay content), ground penetrating radar (GPR) provides a cost-effective solution for horizontal location of metal and plastic structures (i.e., pipes) to within a few centimeters and an estimate of vertical location that is typically accurate to within a few tens of centimeters. Ground penetrating radar has been shown to work well at Hanford to depths approaching 10 m (Last and Horton, 2000; Murray, et al., 2005). Ground penetrating radar would also work reasonably well at the Idaho National Laboratory but would likely provide good results to depths of only a few meters at the Savannah River Site because of the partially saturated clayrich soils. Alternative geophysical methods include magnetic gradiometry surveys and electrical resistivity surveys. Provides Early Warning to Enable Intervention if Necessary The committee believes that monitoring within the disposal facilities is the most desirable approach for the early detection of problems, followed by detection in the vadose zone, and finally detection in the nearest aquifer. Hanford has 800 dry wells around its tanks. Detectors in these wells were able to observe some of the leaks from the single-shell tanks. During retrieval operations, the dry wells are checked weekly because retrieval operations are the activities most likely to mobilize waste from the tanks. At other times, the wells are checked at a longer interval. Hanford has tested a capability to detect tank leaks within 24 hours of their occurrence using resistivity sensors (see Sidebar VII-1). The Savannah River Site has not yet formulated plans for monitoring the covers for its tank farm and Saltstone Vault disposal facilities. Hanford, by contrast, has a prototype barrier system that is outfitted extensively with sensors. DOE indicated that it is premature to decide on the details of the cover system for its tank closures and low-activity waste disposal facility (the Integrated Disposal Facility, or IDF), but Hanford is building lysimeters into multiple layers of the IDF bottom liner. The Idaho National Laboratory has a network of monitoring sites to determine contaminant movement in the vadose zone and the aquifer and is following the

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report SIDEBAR VII-1 Tank Leak Detection Early detection of leaks is desirable to stop leaks at the earliest possible time limit the volume of contaminated earth. Geophysical methods have the advantage of integrating the signal from a three-dimensional volume, as opposed to a one-dimensional sample obtainable from individual observationwells. While several geophysical and geological methods can help in hydrological and geological characterization of possible contaminant flow paths, the electrical resistivity method of geophysical monitoring is most likely to be successful in early detection of tank leaks. In 2002, a 110-day blind test was staged at the Hanford Mock Tank Site (Barnett et al., 2003). The test evaluated electrical resistivity tomography (ERT) with variations using point electrode techniques and the long-electrode technique. These tests resulted in 10 of 12 leaks being detected on the first day. Another test in the series involved the high-resolution steel casing resistivity technique, which provided leak volume estimates with accuracy within about 30 percent, while detecting 9 of 13 leaks. The other four leaks that were not detected could be associated with identifiable technical problems such as disconnected electrodes or major electrical interference. Barnett et al. (2003), who compared detection through electrical resistance to other methods, found that these results suggested that electrical methods have one to two orders of magnitude advantage over neutron or gamma logging. They also have the advantage of continuous measurement versus the periodic measurements done with logging methods. Although these results at Hanford are promising, they were made in an environment with little natural near-surface moisture and relatively low clay content. The geological and hydrological conditions at the Savannah River Site are less favorable for the use of resistivity changes to detect leaks because of higher clay content in the soils and greater interstitial moisture content. With respect to electrical resistivity monitoring, the geological and hydrological conditions at the Idaho National Laboratory are closer to those at Hanford than the Savannah River Site. Resistivity signatures have temporal variations on seasonal as well as other scales. Consequently, any monitoring using resistivity would have to be done in a way to avoid temporal aliasing (mistaking signals from leaks for the natural temporal fluctuations because they occur with the same frequency or with simple multiples or fractions of the same frequency). SOURCE: Barnett et al., 2003. movement of spilled materials as a means of updating knowledge of site dynamics. Figure VII-1 illustrates the different types of monitoring and where they fit into the physical and regulatory environment. It shows the disposal facility with monitoring ports or access into or near the waste cell that allow monitoring of the engineered facility and early detection of releases, before extensive spread of contamination occurs. The figure illustrates the area for monitoring of releases inside the buffer zone that allows time to correct the problem before it reaches the areas to which the general public would have access and could be impacted. The point of compliance is shown as the line of demarcation for public areas versus the areas inside, in which any person is considered an intruder. The water table is illustrated because it is the entry surface to the saturated zone that is the pathway of most concern for transmission of the waste to a publicly accessible point either by well water or by surface streams to which the groundwater seeps out or gets discharged. Each site has encountered surprises found by monitoring efforts, such as a discovery of unexpectedly high concentrations of technetium-99, nitrate, and other contaminants at the bottom of the unconfined aquifer downgradient from the T Tank Tarm at Hanford in 2004. Such surprises should be regarded as successes for the monitoring programs, even as they raise concerns about contaminants, including potential undetected releases. However, they also indicate the need for an early warning system to enable decision makers to intervene if appropriate. For example, at the Idaho National Laboratory, site monitoring contributed to a decision to relocate the percolation ponds and to the eventual revision of the site hydrogeological conceptual model (DOE-ID, 2004a). The Savannah River Site provided examples of cases in which contaminants discovered by monitoring led to remediation efforts. Is Subjected to Review on a Regular Basis and Adapts to Changing Circumstances The monitoring programs have grown and adapted to changing needs. A certain amount of review is built into the programs as a result of operating under CERCLA or RCRA. CERCLA five-year reviews are required to ensure protectiveness for any remedial action that leaves hazardous sub-

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report FIGURE VII-1 Different types of monitoring and where they fit into the physical and regulatory environment at a hypothetical site. stances on a site above levels that allow for unrestricted use by the public.4 Personnel at each site stated that they conduct regular reviews of site monitoring programs, although the committee did not examine the details of those reviews. As noted in footnote 1 of this chapter, Section 3116 of the 2005 National Defense Authorization Act requires the Nuclear Regulatory Commission, in coordination with the host state, to monitor “disposal actions” to assess compliance with the provisions of that section of the law. The South Carolina Department of Health and Environmental Control requested that DOE provide the state with a long-term monitoring plan for the tank farms at the Savannah River Site. This request prompted DOE to call for the meeting mentioned earlier in the discussion of goals. Archives Data in a Durable and Accessible Form Recognizing that DOE might not solve the problem of creating archives that will last and be accessible for centuries, which is a challenge confronting many parts of our society, DOE can at least assemble the information it has so that it is accessible now. The sites have created central databases for accessing monitoring data and have populated the databases with much of the information available, although there is not yet a comprehensive set for any of the sites.5 The extensive monitoring history provides the sites with an opportunity to create functional archives that provide both data and metadata from each monitoring effort. Unfortunately, none of the sites has a functional, site-level monitoring archive that fully integrates environmental data management. The committee has observed the separation of monitoring procedures and data management by program or project boundaries at each site. Particularly important “data divides” at the sites include divides that exist between process data collection and site characterization, long-term ecological analyses and regulatory compliance monitoring, and a program data focus that fails to integrate media-specific monitoring results (air, surface water, and groundwater). Except in the case of the Idaho National Laboratory plan for groundwater monitoring described earlier, none of the people to whom the committee talked said that the sites explicitly follow the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP; IDQTF, 2005), which is designed to ensure that a monitoring program is well designed and implemented. It is, of course, possible to have a good monitoring program without explicitly following the policy, but the programs could be improved in terms of interoperability, meeting the needs of the performance assessment for tank wastes, and coordinating not just within the site but at the margins between sites. Perhaps more 4 A 1999 examination of CERCLA five-year reviews (not specific to DOE sites) found that EPA’s backlog of reviews that were past due was increasing (EPA-OIG, 1999). EPA instituted measures to clear the backlog by the end of 2002. A recent Government Accountability Office report found that the five-year interval may be too long for sites that rely on institutional controls as part of their remedies, and the five-year reviews did not consistently review the effectiveness of the institutional controls (GAO, 2005a). 5 The most complete may be Idaho National Laboratory’s Environmental Data Warehouse, a site-wide database for groundwater and perched water data available to site personnel from their desktops.

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report important is that following the policy may make it more likely that the organizations carrying out monitoring at the sites will coordinate better and continue to do the job well as responsibility is passed from one generation of managers and technicians to the next or from one contractor to the next. FINDINGS AND RECOMMENDATIONS Finding VII-1a: The committee’s overall impressions are that the sites’ monitoring programs are effective at fulfilling their current goals, which in most cases are site characterization and operations monitoring to assess regulatory compliance. Finding VII-1b: For the most part, the sites have not yet developed plans for post-closure monitoring, including continuing post-closure performance assessment to confirm the performance of on-site waste disposal. Finding VII-1c: The existing monitoring programs can be improved, and both planning and action are needed to ensure that the programs continue to address the multigenerational challenge posed by long-term monitoring. Considering the importance of monitoring data in the evaluation activities that support decision making in verifying compliance with performance objectives and in overall protection of human health and the environment, DOE needs to take actions to ensure that the post-closure and long-term monitoring efforts perform well for generations. Recommendation VII-1: DOE should start planning its post-closure monitoring programs so that provision for monitoring can be built into closure plans and designs. In doing this, each site should implement a process to ensure a high-quality, comprehensive, coordinated, and site-wide monitoring program that meets current and ongoing needs for site evaluation and compliance and is revised as needed to provide long-term monitoring data for continuing evaluation of the site’s ability to meet performance objectives. In addition to site-wide quality assurance, this process should also provide guidance for disposal site monitoring and related performance assessments. DOE has guidance presently available in its UFP-QAPP that can assist with this.