Click for next page ( 35


The National Academies | 500 Fifth St. N.W. | Washington, D.C. 20001
Copyright © National Academy of Sciences. All rights reserved.
Terms of Use and Privacy Statement



Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.

OCR for page 34
Environment INTRODUCTION In no other area has DOE been subject to a greater degree of scrutiny and criticism regarding its management of the weapons complex than in its activities related to the environment. Environmental issues in the complex have been the subject of numerous congressional inquires, lawsuits, federal investigations, and a variety of activities by interest groups. The level of attention reflects intense concerns about environmental hazards associated with the facilities and a strong distrust of DOE in this regard based on past performance. Background From the time of the establishment of the Atomic Energy Commission (AEC) in 1947 until the legal ruling in LEAF v. Hodel in 1984 (586 F. Supp. 1163, E.D. Tenn. 1984), the operating agencies (AEC, then Energy Research and Development Administration, and now DOE) were perceived to have had sole responsibility to define programs to protect human health and the environment within the weapons complex. The waste management and environmental practices of the complex were born in the wartime atmosphere of urgency that understandably put a high priority on production but with little attention to the environment Initially practices relating to the disposal of chemical wastes were similar to those of other industries at the dine. Wastes were placed in unlined and unprotected trenches; oils and organic solvents were poured into open standpipes in the soil; contaminated cooling water was deposited directly on the ground; unlined ponds 34

OCR for page 34
ENKIRONME~ 35 that served as infiltration basins were used for the disposal of various liquid waste streams. Over the years, however, as other industries improved their waste management practices with the advent of environmental regulations, practices at weapons facilities changed comparatively slowly. Moreover, the environmental practices at the facilities were kept from public view under the shroud of secrecy that cloaked the complex from the early days of operations. In 1984, DOE's self-regulated role was challenged by the lawsuit l EAR v. Hodel. The court found DOE to be in violation of the Clean Water Act (CWA) and the Resource Conservation and Recovery Act (RCRA) at the Y-12 Plant in Oak Ridge, Tennessee. With this legal nailing, the Deparunent acknowledged the applicability of federal environmental laws, as well as certain state and local laws, to its weapons production activities. These Lows generally provide for the regulation of air and water pollution and of the disposal of hazardous wastes, and they require the remediation of uncontained hazardous waste dumps. The radioactive component of wastes is not governed by RCRA, although the hazardous component of mixed wastes is. Management and disposal of the radioactive component of wastes is the responsibility of DOE under the Atomic Energy Act. (Final disposal of both commercial and high-level wastes is also regulated by the Nuclear Regulatory Commission.) Table 3.1 provides a list of major federal legislation affecting DOE's environmental programs. The establishment of environmental standards for the weapons complex in principle requires the determination of the appropriate balance of risks and benefits arising from the operation of the facilities. It is by no means obvious that the balance for the weapons facilities is necessarily the same as that for industrial activities. Thus, at least in principle, a set of standards different from those applied to the commercial sector (perhaps more stringent, perhaps less) might be justified for application to the weapons complex. However, in the Five-Year Plan (see Recent Initiatives below), DOE, with the encouragement of Congress, has stated that the complex should operate in compliance with the environmental laws and standards that are generally applicable to industrial operations. This decision no doubt reflects a political judgment in which the Department, other federal agencies, Congress, the states, Indian tribes, and local communities have interests. The committee has not evaluated this judgment. We recognize, however, that the decision defines the agenda for DOE's activities related to the environment, and we have approached our task under the assumption that it will continue to do so. With the Department's acknowledgment of the applicability of environmental laws, DOE set about performing the daunting task of bringing its facilities into compliance. Today, many former practices for disposing of wastes have been replaced with more modern and environmentally sound technologies. But the Department's initial efforts lacked an integrated plan and strong commitment from upper levels of management. More than five years after the LEAF v. Hodel decision and after many different planning exercises, the Department continues to be out of compliance in management of some of its current wash streams and is

OCR for page 34
36 THE NUCl~AR WEAPONS COMPI~X TABLE 3.1 Mapr Federal Legislation Affecting Environmental Protection Protons Atomic Energy Act Federal Insecticide, Fungicide, and Rodenticide Act Fish and Wildlife Coordination Act National Enviromental Policy Act Clean Air Act Clean Water Act Safe Wining Water Act Endangered Species Act Resource Conservation and Recovery Act Hazardous and Solid Waste Amendments Toxic Substance Control Act Comprehensive Environmental Response, Compensaiioql, and Liability Act Superfund Amendments am Reorganization Act Emergency Planning and Community Right-To-Know Act Source: SRS 1989. lagging in its efforts to clean up previously contaminated sites. Dissatisfaction with its progress led several state environmental agencies, as well as EPA, to seek enforceable compliance agreements with DOE. Recent Initiatives The current Secretary of Energy has stand that the Deparunent will reorder its priorities to put health, safety, and environmental issues on an even footing with production. With respect to environmental issues, this shift in emphasis has included a commitment to environmental restoration, compliance with applicable environmental regulations, and more cooperative relations with host states and regulatory agencies. The cornerstone of DOE's recent initiative in this area is its Environmental Restoration and Waste Management: Five-Year Plan, issued in August (DOE 1989a), which is intended as a dynamic plan that will be updated annually. The document sets out the Department's plans for the next five years for coming into compliance and cleaning up contaminated sites. It describes how the Department intends to set priorities and establishes a goal to have completed the restoration of contaminated sites in 30 years. It anticipates spending $6.8 billion on environmental restoration activities over the next five years. The Five-Year Plan makes an appropriate and useful distinction between environmental restoration required to remediate past practices and waste management operations stemming from current and fume operations. These Do

OCR for page 34
EN17MONME~ 37 aspects are reasonably dissect from one another and will require a balance in the efforts and resources of DOE. Additionally, He plan address the corrective actions that are required to bring facilities into compliance with existing environmental regulations and calls for applied research and development that is needed in support of restoration and waste management. This aggressive commitment to change, along with the comprehensive plan for action, is welcome and deserving of considerable praise. ENVIRONMENTAL CONTAMINATION Conclusion Environmental contamination exists throughout the weapons complex. Addressing these contaminated sites is an immense task that will be costly and iime-consurrung. Virtually every facility in the weapons complex has some amount of environmental contamination within its boundaries, while many also have some contamination outside the boundaries. The severity of contamination is highly variable, with some sites containing very high concentrations of one or more contaminants and others containing rather small amounts. To date, more than 3,200 sites have been identified as having some soil contamination, or groundwater contamination, or both. Examples include the presence of cesium-137 in streams and wetlands at the Savannah River Site, plutonium-239 in soil at the Rocky Flats Plant, fission products in shrublands at the Hanford Reservation, and mercury in freshwater ecosystems at the Oak Ridge Y-12 Plant. Measurable groundwater contamination, usually involving organic solvents such as trichloroethylene, has been identified at several facilities including the Lawrence Liverrnore National Laboratory, the Idaho National Engineering Laboratory, the Rocky Flats Plant, the Hanford Reservation, and the Savannah River Site. Although this contamination is not likely to cause measurable disruption of ecological systems, there is concern that off-site groundwater movement could result in the ingestion of contaminants by people through drinking of well water or consumption of crops irrigated with well water. There is no doubt that the contamination is pervasive. Our work did not include the review of risk assessments associated with the contamination. We therefore are unable to comment on the magnitude of the impact of contamination at the nuclear weapons facilities. It is the responsibility of DOE and the regulators to conduct such assessments. We note, however, that where contaminants are isolated from population centers by distance and natural barriers, there is reason to believe that the immediate threats to health are slight. Furthermore, we believe in general that ecological impacts of contamination that is, the effects on systems of native plants and animals have been less than the impacts resulting from construction of roads, buildings, and many other human activities at the sites. Nonetheless, the potential long-term risks to huma health and the environment associated with environmental contamination at the

OCR for page 34
38 THE NUC~AR WEAPONS COMPLEX sites pose difficult problems. The long-lived nature of some of the contaminants coupled with uncertainties surrounding the response of humans to low levels of chronic exposure to a variety of contaminants limit our ability to determine the effects. It is clear that the cleanup at the weapons facilities will be extensive. Recommendation In the Five-Year Plan released in August 1989, DOE outlines plansfor an approach to environmental cleanup and,for thefirst time, commits to cleaning up sites in accordance with applicable laws and regulations. It is imperative that DOE proceed apace with remedial actions and that the Department, Congress, and the nation standf rmly by the commitment to clean up. SETTING STANDARDS AND PRIORITIES ACROSS THE COMPLEX Conclusion There is need to develop and apply a scientifically credible scheme to aid in making decisions about appropriate cleanup standards and prioritiesfor performing remediation in the face of resource limitations. Implementing plans for environmental restoration will require DOE to resolve many complex questions with scientific as well as policy or social components. Among these, the most important at this time are those relating to acceptable levels of cleanup (or, conversely, what level of contamination may remain at a site after cleanup), how to clean up different sites, and which cleanup activities to undertake first. Not only are these difficult questions in themselves, but the answer to one will bear upon the answers to the others. Moreover, since cleanup activities are to be funded by public money, it rests with DOE to assure that its response and approach to these questions expend the public resources efficiently and cost effectively. In the Five-Year Plan, DOE has identified two priority schemes it intends to use to guide decisionmaking regarding cleanup and allocation of resources across the complex. The first, the National Priority System (NPS) to be developed in consultation with EPA and other federal agencies, affected state and tribal governments, and other bodies, will be used to determine how resources should be allocated within and among corrective action, environmental restoration, and waste management operations projects. The second entails a plan to work with these same organizations to develop consensus-based, consistent regulatory standards for cleanup. Risk-Based Cleanup Standards In recent years, risk assessment has been used increasingly by regulators and other decisionmakers as a tool to bring scientific information into the decisionmaking process. One method for establishing standards is ~ determine

OCR for page 34
ENVIRONM~ 39 the probability that an individual or population exposed to a given level of a contaminant will develop a fatal affliction because of the exposure over a lifetime and then set a standard based on what is considered an acceptable level of risk. This probability, or risk, depends on knowledge about the dose-response relationship for contaminants and about He transport, dispersion, dilution, and decay of contaminants In the natural environment. It also depends on assumptions about pathways of exposure to human populations, for example, the amount of water consumed from a contaminated well or the ingestion of fish that have accumulated contaminants. The dose to different individuals in a population will differ depending on where they live and on other kinds of lifetime experiences. One indicator of risk is the risk to a "maximally exposed individual," a hypothetical nearby resident who is assumed to be exposed to the largest possible amount of contamination through use of water from a contaminated aquifer or body of surface water, consumption of plants grown in contaminated soil, breathing air carrying contaminants, and so forth. Such an individual is assumed to dwell at the site for a lifetime. Another measure of risk is risk to a population. Population risk involves combining estimated rislcs to individuals with probabilities that a certain number of individuals will live within various distances from a site and be exposed to various amounts of contaminants. Risk assessments can incorporate different measures of risk. In making a decision regarding how to manage risk (i.e., setting cleanup levels and pnonties), however, many other important factors (e.g., economic costs, benefits, feasibility) will and should be involved. We use the term "risk-based analyses" below in a generic sense. We do not advocate any particular calculus; rather, we suggest that some consistent fonn or fonns of risk analysis should play a role in determining standards and setting priorities. Our recommendations on the use of risk assessment presented below should not be read as a suggestion that risk assumes a role as a single determinant. We merely advocate the use of such analyses as a way to be consistent in using scientific knowledge to inform the decisionmaking process. In a draft Five-Year Plan, DOE stated its commitment to "seek the establishment of technically sound, nsk-based standards, which all can accept, to yield the greatest national progress toward DOE's compliance and cleanup commitments" (DOE 1989d). We encourage DOE in its effort to establish cleanup criteria on a risk basis. There are, however, certain obligations that arise from a commitment to adopt risk-based standards. As the National Research Council's Board on Radioactive Waste Management (BROOM) commend in its review of the draft Five-Year Plan (NRC 1989a), as DOE moves through the transition from a self-regulated entity to an externally regulated one, it takes on the "obligation to participate, as an affected party, in rule-making and legislative initiatives that affect its mission." In this connection, there is a fundamental issue relating to the development of risk-based standards that requires DOE's immediate attention. Any risk assessment involves (1) the evaluation of the toxic potential of the

OCR for page 34
40 THE NUClAR WEAPONS COMPLEX harmful magentas) and (2) the estimation of the level of human exposure (or dose) to such agents. In the environmental setting, exposure to a hazardous contaminant will depend upon the ability of the agent to migrate in air, soil, or water, as well as on the proximity of an individual who may receive the dose. The exposure potential of an environmental contaminant will vary with site characteristics, including, but not limited to, soil type, precipitation, groundwater flow rates, and types of vegetative cover. A pathway analysis can be used to estimate how exposure will differ based on environmental setting and population parameters. In general when risk-based standards are promulgated by EPA, a conservative or worst-case hypothesis exposure is assumed. Then a concentration of the contaminant in soil or water corresponding to what is considered to be an acceptable level of risk is determined for this case. Such determinations are considered risk management. This type of risk-based standard attains an acceptable risk level for the worst-case exposure, but it is overly protective in other circumstances. A standard that specifies a concentration in environmental media, for example, would actually result in disparate reductions in risk if applied at all sites without regard to issues such as the proximity of human populations to the source. In many situations, achievement of such a concentration standard is not necessary to assure the desired reduction in risk. Another approachthe one favored by us would be to establish an acceptable level of risk that contaminated sites should meet. The acceptability of risk is a value judgment, not a scientific one. DOE therefore must seek to establish an acceptable level of risk through a political process, although achieving consensus may be difficult. The specific cleanup level for a given situation would then be determined through the use of consistent risk assessment methodologies. We recognize that there are difficulties in this approach. Credible risk assessment methodologies can result in risk assessments that differ by orders of magnitude. Additionally, confidence in the assessment of the risks diminishes as projections are made further into the future. Nonetheless, tailoring cleanup requirements to specific sites seems to us to be the optimal approach, taking into account constraints In resources. In the Five-Year Plan, DOE lays out the basic steps of the environmental restoration process required under RCRA and the Comprehensive Environmental Responses Compensation, and Liability Act (CERCLA or "Superfund"~. These steps include preliminary assessment, inspection, characterization, evaluation of cleanup alternatives, cleanup action, and compliance. To the extent permissible by law, DOE should use risk-based methodologies to guide the Department through these phases and in setting priorities. In particular, it is imperative that risk assessment be used as a mechanism to bring scientific information into the decisionmaking, or risk management, process in the evaluation of cleanup alternatives. The application of risk assessment methods in this context should take place on a site-by-site basis. In each case, characterization data should be used to estimate

OCR for page 34
E~VIRONME~ 41 the risk to public health under several different courses of remediation ranging from no action to complete cleanup and employing different technologies, if alternative appropriate technologies are available. Risk assessments would be done using pathway analyses that model the fate and transport of contaminants in the environment and estimate the potential for exposure. Although different sites will require different model parameters because of site-specific features, the methods used should be as uniform as possible. For example, the movement of chemicals through He environment should be analyzed in a manner consistent with the movement of radionuclides. The use of consistent risk assessment methods will not only ensure Cat Be various alternatives for remediating a particular site are comparable, but they will also enable DOE to make intensive comparisons for priority setting with greater confidence. In some cases, it may be found that the existing contamination does not warrant full-scale cleanup activities or that cleanup activities themselves may create greater risks. In such cases the prudent decision may be to institute only long-tenn-monitonng to assure that the risk remains low or, if the risk is not acceptably low, to monitor until feasible remedia~on technology becomes available. In other cases, it may be found that the environmental impact of existing contamination is less than that normally associated with the construction of buildings and roads, and that to mount an engineered cleanup would cause greater environmental damage than leaving the waste in place. Execution of the risk-based approach will be a demanding task. Ultimately, remedianon decisions will have to be made in conjunction with the appropriate regulatory agencies. To come into compliance with legal requirements, DOE may be required to clean up to levels that are more than adequately protective of human health. It will, however, be to the Deparunent's benefit to be aware of the risks and costs associated with its efforts so Mat it can defend a sensible, scientifically credible, and fiscally responsible approach. Recommendation The Department should seek to achieve site-specific cleanup standards. Consistent risk assessment methodologies should be used to bring scientific information into decisions regarding extent of cleanup, cleanup methodologies, and prioritiesfor environmental restoration. National Priority System As BROOM pointed out in its review of a preliminary draft of the Five-Year Plan (NRC 1989a), the development of DOE's NPS with the involvement of all affected parties is of crucial impedance. The need for such a system is born out of the immensity of the cleanup task and recognition that it cannot be completed all at once. The NPS will guide DOE in approaching its task and in allocating resources. Although a final NPS has yet to be developed, DOE has proposed a four-tiered system to be used in the intenm. The proposed system is as follows:

OCR for page 34
42 THE NUCLEAR WEAPONS COMPl~X Priority 1: "Aciivi~aes necessary to prevent near-term adverse impacts to workers, the public, or the environment," and `'ongoing a`:tivi~aes that, if terminated, could result in significant program and/or resource impacts." Priority 2: "Activities required to meet the terms of agreements (in place or in negotiation) between DOE and local, State, and Federal agencies." Priority 3: "Activities required for compliance win external environmental regulations that were not captured by Prionty 1 or 2." Priority 4: "Activities that are not required by regulation but would be desirable to do." The distinction between priorities 2 and 3 appears to be based solely on the existence of compliance agreements and' as such, endows such agreements with an ex~ordinanly important role. DOE should view its responsibility to comply with all applicable environmental regulations as a single responsibility. DOE should acknowledge that it cannot come into compliance everywhere immediately and should place its initial efforts in areas where it can achieve the greatest reduction in risk with the available resources. The approach may require the renegotiation of some agreements already in place. Recommendation To the greatest extent practicable, DOE should incorporate risk assessment as a guiding principle in developing an UPS. Characterization of Contaminated Sites Conclusion Intensified sampling to describe the extent and nature of contamination, as well as hydrogeology and ecology, is necessary to guide cleanup, isolation, or restoration activities in a timely manner. Improved data management will assist in the retrieval and analysis of the massive amount of information collected. Characterization of the extent and nature of chemical and radioactive contarninaiaon at DOE sites is a prodigious task, but such characterization is essential before the nature and extent of any necessary cleanup activity can be determined. Identification and characterization of source terms, both past and present, and of contamination in soils, groundwater, surface water, and biota have already resulted in the collection of many thousands of samples. Sampling can be as simple as collecting vegetation or soil, as complex as setting up an air monitoring station, or as costly as drilling monitoring wells. Each sample may be analyzed for a host of constituents. For the results to be meaningful and useful, the samples must be collected and analyzed carefully, under strict quality assurance and quality control guidelines. As with any undertaking, it is important to assess the costs of the effort relative

OCR for page 34
E~MONhIE' 43 to the anticipated benefits. Environmental sampling can be very costly, but the knowledge it supplies can lead to lower overall remediation costs. The extent of sampling should be tailored to the degree of risk presented by to site. The problem of data management is obviously challenging, and it is made more complex because a large effort to collect data has been mounted over a relatively few years. As a result, the responsibility for collecting data has been fragmented at many, if not all, of the facilities. Maintaining consistent data bases in such circumstances can be difficult, but it must be done if the data base is to serve as a guide to decisionmaking regarding cleanup and further data collection. The migration of contaminants in surface and subsurface media is complex. An understanding of the overall geology, hydrogeology, and land use at an installation, not merely the required measurements of concentrations of contaminants at each contaminated site, is required if informed risk assessments are to be performed. Indeed, analysis of the potential for migration of contaminants outside the boundaries of federal property demands such understanding. Most work to date at the DOE installations has focused on thorough characterization of a relatively small number of contaminated sites. Nevertheless, an overall evaluation of environmental impact requires adoption of a broader, more consistent view applied across the complex. Recommendation Each installation should develop a comprehensive data base of environmental information, one that will allow the data to be accessed and usedfor a variety of purposes related to remediation of contaminated sites within the installation. The structure and content of the data base should be consistent across the complex. DOE should also insist that each installation develop a plan to acquire the data necessary to improve understanding of the installationwide geology, hydrogeology, and land use. WASTE MANAGEMENT The Deparunent's past production and waste management practices are easily identifiable as the source of the extraordinarily large cleanup and restoration projects facing the Department today. In looking to the future, it is important for the Department to learn from its past mistakes to prevent the occurrence of an analogous situation 40 years hence. A strong emphasis should be placed on improving current waste management practices and developing innovative waste management technologies for the future. At each production site and research laboratory there are already in place waste management facilities providing some treatment and storage. These facilities provide for handing and movement of chemicals and radioactive materials followed by treatment to reduce toxicity, amount, or potential for exposure on dispersement. This general sequence of waste management occurs for radioactive wastes,

OCR for page 34
44 THE NUCLEAR WEAPONS COMPLEX _~ W,t~ tt ~V'" - S o R A G T E A T M E N D 1 S P S A L High-Level Waste {HLW) | Low-Level Waste (LLW) 5~ And C~ Spant Fuel In 5ing~-SII C~u~o Retr~eweb~ tat~~ TS--c`~' i 1 1~ ~ I -~_~ i 1 ~ D~ u~ta ~_> A.. 0~ ~ 1 1 . HtW in I ~ ~ W~te D~We Shell Yitriticat#'l, Tenhe 1 1 Pl~t F~d 11 ~,', . 1 j 1 1 $ 1 ~ 1 1 1 1 ~ - 1 ~ Ev~tm ~1 ~ 1 ~ u J1 ~J 7_~1 _ t~iV ___+ 7___t ~_~ __~ T_~ 0~ - . _ j ~J kLW Doldb - S~ i) ~1 Ib~_ 1 L:o_^t_i 44ued W.te (MOO\ W - t. a~ ~ _.~ ,'__ _. ~ "W Sto~e F~ . , 31 1 - ~ ~__ ~ ___~_~- ~ ~ l_ : ~ U 1 _P - ' - _~ _~ ~e,1 ~ V_ __ e_~_ FIGURE 3.1 Hanford waste management plan.

OCR for page 34
E7WIRONAfENT A_ Transuranic Waste (TRIG I Hazardous Waste LLW EM tt i t _I __ em_ _ 4~ ~ - i ~7 He_ Ed 45 T$1U In DoubIS T~e 1 : 1. : 1 ; ~ em_ ; 1 T P__ ~~ _ i_ ~' MAY Conorated Contact Hendled TRU Sad Wast* I , ala,,,_ , ~ TRU ~itoraga Had AN TV Faculty 1 Storage ~ _ l . Pt-e lq70 Urt~tr.~.u~d Seed Wastr And Cont*mir - ~.d SO ~ S'te~ D4~t t>~~V~6~ ~ Ie~ Q.. 1 F ~~ 0~ A. - ~ `,,,~,,~,,t,,. ^,, ( `~ - rr~a Rerr'~t. Ha~4dIed TRU In C.r.eon ' 1 1 . Ca~ 504 To Oah _ `o~ t~.t Fc4r T~~~t _~ ~ ~~ 4*___3 T~ taposJ l~t W4~*t. _ ~ | b~t~n Pr~ct ~,~ I Pb~ttVVIPPI Ner red~o~ct~v~ He,.,dc~u~ We~to 4 ~ ?io,`~d'~'ttwe t)~grrr~u$, ^,*ar~ StOr4,9 9~1~ry G. ~_, ~ r=~ Tr~n~portat~r~n B~4ri*1 Oft - ~. F<'r t R.s<~"r~ ~ O~.l Cvn~.t'4n R ~ rn Art

OCR for page 34
46 THE NUCl~AR WEAPONS COMPLY hazardous and nonhazardous wastes, gaseous discharges, solid wastes, etc. These waste management sequences differ from facility to facility. An illustration of the current waste management strategy at Hanford, which addresses radioactive and other hazardous wastes, is shown in Figure 3.1. The ability of these waste management facilities to comply with evolving state and federal regulations for the various wastes that are produced is not uniform across the complex. Conclusion The Department needs an integrated long-range plan for waste management. The Deparunent's Five-Year Plan is its first effort to develop an integrated plan that addresses waste management operations throughout the complex. The plan encompasses high-level, low-level, ~nsusnic, and minced radioactive wastes, as well as hazardous and sanitary wastes. The plan reflects the Department's priorities in this area, first, to comply with all applicable laws and, second, to reduce risks and minimize the generation of wastes. We commend the Department for its intentions in this area. The strategy should be extended, however, to include nonhazardous liquid discharges, gaseous discharges, and thermal discharges, thus encompassing all process wastes and residuals. In addition, DOE should include wastes from decommissioning and decontamination activities in its planning. These wastes are expected to be substantial as the Department proceeds with the decontamination and dismantling of retired facilities. Further, the Deparunent needs to develop guidance as to how the Five-Year Plan will be implemented. In the course of this study, we observed that individual facilities often act independently of others that face similar problems. It behooves the Department to look at the entirety of its waste management operations to identify the more successful approaches. Although ultimately waste management options are likely to be assessed, adopted, and implemented locally, the establishment of an overall Department strategy would provide a useful framework for selection of alternatives. Recommendation The Department of Energy should build on its FiYe-Year Plan for waste management operations to include all production wastes anal residuals, as well as wastes resulting from decommissioning and decontamination efforts. Additionally, the Five-Year Plan should be developedfurther to include plansfor implementing the policies it set forth. Waste Minimization Conclusion The waste streams from different operations in the complex are diverse, can produce significant volumes, and may contain high concentrations of chemicals of concern. Reduction of wastes in the complex is essential.

OCR for page 34
ENVIROlVME' 47 The management of industrial wastes presents an integrated or interconnected aggregation of choices, involving often conflicting technical and economic factors. Increasingly, industries in the United States are finding that principles of waste minimization provide a sound approach to these problems. The consideration of waste minimization vanes now considerably from facility to facility within the complex. Most waste management programs place heavy emphasis on treatment and containment technologies, rather than on the often more cost-effective minimization at the source. Waste minimization principles could be applied profitably throughout the complex, not only in ongoing operations, but also to decommissioning and decontamination activities and to new initiatives as modernization proceeds. The application of an analytical framework based on waste minimization would give the Department an overall perspective on how the many residuals from its operations affect both the cost of operations and the environment. Implementation of process modifications that result in less pollution per unit of production output often requires significant capital investment. Indeed, the restriction of capital outlays was frequently cited as a serious limitation for implementing change. Waste minimization programs at the facilities typically lack an economic framework or policy to provide a rationale for implementing cost-effective changes to reduce waste generation. Such a framework is necessary to determine whether, in fact, the heavy front-end costs offer significant long- term savings. A potentially important, effective waste minimization effort is under way in the Office of Defense Waste Transpmation and Management at DOE headquarters, and it involves representatives of most production facilities. The inclusion of source reduction goals in this program is relatively new to DOE. At this stage, we could not evaluate the effectiveness of this office. However, we view this effort as a hopeful sign that the Department is embarking on the right track. As the Department begins to modernize the nuclear weapons complex, it should incorporate waste minimization concepts into the planning process at the outset. The economic, technical, environmental, safety, and health benefits of reduction in process losses and waste generation are far-reaching. The planning for the New Production Reactors REPRO, currently in progress, represents DOE's most significant effort in this area. The NPR program has already adopted a waste minimization approach with respect to radioactive wastes. Missing from these plans, however, are analyses related to minimizing hazardous and nonhazardous chemical wastes, solid wastes, low-level radioactive wastes, and other process residuals. For a wash management policy that embraces waste minimization to be implemented successfully, a commitment to the effort must be made at all levels, from the operations personnel to the highest levels of management. Furthermore, because current environmental regulations focus on wastes that have already been generated, and not on source reduction, a commitment to waste minimization goes beyond a goal of compliance with state and federal regulations. Nonetheless, such a strategy offers significant long-term advantages.

OCR for page 34
48 TlIENUC1~AR WEAPONS COMPLEX Recommendation The Department should develop and implement a framework for the Affective and efficient application of waste rrunirruzation principles in all process and waste management contexts. DOE should make use of work done in large industries and academic institutions to develop an analyncalframeworkfor evaluating process and waste management alternatives arm setting priorities. Process Development Conclusion Upgrading waste management operations to keep pace with future regulatory developments and to achieve waste nunirruzation will require a sustained applied effort toward research and technology development and demonstration. We strongly support DOE's plans to improve available technologies and develop new ones with He aim of reducing costs and risk to workers and the public. DOE should also look outside the agency for nonradioactive waste treatment and disposal technologies. The commercial sector and other agencies of the federal government have supported research and development along these lines. For wastes that are unique to the DOE mission, however, DOE will have to support research and development activities. Recommendation The Department of Energy should' sustain an applied research and technology development and demonstration effort in support of waste rrunim~zaiion and waste management activities. For wastes that are unique to the DOE mission, the Department must undertake wholly to support such efforts. In other areas, the Department should make use of technologies developed elsewhere and take advantage of research An development conducted under other Apices. ENVIRONMENTAL RESEARCH An essential component of DOE's mission is the support of research on environmental and health effects of energy technologies Over the years, DOE's commitment in these areas has waxed and waned. Today, when faced with the enormous task of addressing its extensive environmental contamination, upgrading waste management operations, and modernizing the complex, the need for more information on environmental effects and for the development of technologies to address these problems is great The Five-Year Plan recognizes the need for applied research and technology research and development to be conducted in support of environmental restoration goals. The BROOM has commented on how DOE could improve its proposed plan (NRC 1989a). In addition to applied research, however, it is imperative that DOE also support basic research directed toward the support of its cleanup goals and . . researc ~ mission.

OCR for page 34
ENVIRONMENT 49 Types of Research Needed Conclusion An increase in DOE-funded research will be required in order to meet needs in the areas of cleanup of contaminated soils and sediments and environmental restoration of damaged ecosystems. There is enormous diversity in the contaminated sites of the weapons complex in terms of area and depth of contamination, the type and chemical form of contamination, soil and biological characteristics, and other attributes. Current knowledge as to whether and how to remediate such contamination is growing, but limited. Because of these uncertainties, decisions concerning cleanup and restoration must be conservative and therefore may not be cost-effective. If the risk-based approach we advocate is applied, the decision about whether to clean up a contaminated site must be guided by scientific knowledge concerning transport through environmental pathways and biological effects of the contaminants of concern. The mechanisms, pathways, and rates of contaminant movement from one medium to another must be understood. Moreover, it is necessary to determine how these processes and rates vary temporally, spanally, and with other factors such as soil characteristics. The more complete the information, the less the uncertainty with which risk estimates can be made. A good deal of information is currently available in this area, but site-specific, credible applications demand much additional information if large uncertainties are to be avoided. Better understanding and quantification of the dose-response relationships are also needed to assess biological effects. For the weapons complex, determinations are complicated because, in many cases, two or more contaminants may be contributing simultaneously to biological stress. It thus would be helpful to understand the nature of the combined (possibly synergistic, possibly antagonistic) effects (NRC l989c). Moreover, in addition to better knowledge of human toxicity, greater understanding of how chemicals and radionuclides affect critical species of plants and animals is required DOE's Office of Health and Environmental Research (OHER) now supports programs that deal with some of these needs. In our opinion, however, the magnitude and direction of current funding within OHER is neither sufficient nor properly focused. While environmental restoration technologies should be vigorously pursued, an equal effort should be placed on research to guide the need for and extent of cleanup. It does not make economic sense ~ spend massively to clean up contamination that currently is at levels that pose low levels of risk humans and the environment. In a similar vein, adequate funding now of waste minimization research, improved waste treatment and storage technologies, and environmental cleanup will also pay off in the long run by reducing the likelihood and magnitude of future contamination and necessary cleanup.

OCR for page 34
so THE NUCLEAR WEAPONS COMPLEX Recommendation The Department of Energy should give high priority to research focused on the types of contaminated ecosystems in the DOE nuclear weapons complex and on the primary radioactive and chemical constituents that may require cleanup. The research should be clearly applicable to the development of models and risk-based stand~rdsfor the cleanup and restoration of contaminated sites. The Role of DOE Measurement Laboratories Conclusion There is a serious erosion of technical expertise at the DOE measurement laboratories that could eventually have an adverse effect on the Department's interlaboratory comparison program and traceability of measurements to standards. Three DOE laboratories that specialize in the detection and measurement of radionuclides and internal and external exposures are a rich and unique source of technical expertise for the DOE weapons complex. They include the Radiological and Environmental Sciences Laboratory (RESL) at Idaho Falls, Idaho, the Environmental Measurements Laboratory (EML) in New York City, and the New Brunswick Laboratory at New Brunswick, Illinois. EML focuses on environmental measurements, the New Brunswick Laboratory is recognized as a standards facility, and RESL specializes in dosimetry. These facilities have contributed significantly to the DOE system in the research and development of new techniques for environmental measurement and dosimetry, in forming a central focus for interlaboratory comparison of measurement data, and in ensuring the traceability of standards for measurements made at DOE sites. The use of these facilities for the traceability of standards and interlaboratory comparisons of environmental and dosimetry measurements is crucial to the credibility of the Department's environmental and personal monitoring program. Each laboratory now employs experienced and highly qualified technical personnel, but difficulties in attracting and retaining young staff coupled with a lack of adequate support for the laboratories make the future of these facilities uncertain. Recommendation The role of the three DOE rneasurernent laboratories should be carefully reviewed to ensure their optimal use and continuing quality. DOE'S ENVIRONMENTAL RESPONSIBILITY In its relatively new role as an externally regulated entity, DOE must take on responsibilities in addition to legal compliance. Central to this role is the responsibility to communicate effectively with the regulators and the public about the risks associated with the Deparunent's operations and how it plans to reduce

OCR for page 34
ENVIRONMENT 51 them. The transition is extremely challenging in that it is taking place at a time when public confidence in the Department is low and concern about the environment is high. Mote than any other factors, public perception and satisfaction of the regulators will determine priorioes for environmental issues for the future. It would strengthen the Depar~nent's credibility if it were to act as an active, open, and willing participant in this process. Participation by the Public and by Local and State Officials in Environmental Programs Conclusion There is insufficient public and state and local government participation in the design and implementation of key environmental objectives. such as restoration of DOE sites and the assessment of risk to the public. The Five-Year Plan establishes DOE's commitment to working with regulators, the public, and others in establishing its priorities for environmental restoration and waste management. As pointed out by BROOM ARC 1989a), however, DOE should be more explicit about its intentions. The National Research Council report, Improving Risk Communication, provides insight into how this can be done effectively (NRC 1989d). Inadequate attempts to bring the public into the Department's decisionmaking process are often not the result of a lack of emphasis being given to environmental matters; rather, the cause is the extension of early philosophies of the weapons complex related to classification of operations and the serious lack of expertise and commitment to informing the public. At many sites, effective and comprehensive environmental monitoring and research programs are being carried out, but because of poor communication of results and the absence of public involvement, public understanding has not improved. At some of the sites, progress is being made through regular public meetings with technical personnel responsible for environmental programs, but little effort is made by key department and contractor management to participate in public meetings or to understand and address the concerns of the local public. One example that may become a model for involving independent technicians and public officials is the Hanford Environmental Dose Reconstruction Project (Till, in press). This study is intended to reconstruct doses that individuals living in the vicinity of the reservation may have received from releases of radionuclides to the environment during the early years of operations. It is being directed by an independent steering panel, the Technical Steering Panel, while the study itself is being carried out by a major DOE contractor. DOE has clearly given the panel the authority to set objectives, establish priorities, and control the scientific quality of the research. The Technical Steering Panel sees it's role as not only to approve and verify the data and models being used in the dose assessment but also to convey

OCR for page 34
52 THE NUCLEAR WEAPONS COMPLEX the results of the study to the public in a credible form once the work is completed. The second objective is likely to be the more difficult of the two taslcs, and the panel is testing new ground in public involvement in a scientific study. Although cooperation between host states and the Department seems to be improving at some sites, there continue to be serious differences regarding environmental quality, access to the sites, and what constitutes acceptable residual risk following cleanup. States must play a role in key environmental programs, including the design and implementation of monitoring programs for routine and accidental releases, and in establishing priorities for cleanup and restoration. Involvement of the public and state officials in environmental issues at the weapons complex facilities necessarily implies the responsibility of all parties to investigate and implement decisions from a sound base of scientific and technical information. Recommendation The Department and its contractors must significantly improve the involvement of the public and state officials in-activities related to environmental issues at its sites. This participation must be actively and frequently sought in coming to terms with environmental issues. Ecological Value of DOE Lands Conclusion In general, DOE management does not appear to appreciate or understand the ecological value of the lands under its care. Several of the DOE installations, including the SRS, the Hanford Reservation, the INEL, the ORAL, and the Los Albinos National Laboratory (LANL), encompass large land holdings. All these installations have large and diverse natural areas that have been designated as National Environmental Research Parks (DOE 1985~. In addition, smaller sites such as Rocky Flats and Site 300 at LLNL, although more heavily affected by operations, cover relatively pristine landscapes that are also significant in area The DOE sites were acquired 30 or more years ago when the lands were sparsely populated and were either unspoiled or in a condition to undergo natural ecological succession from old farmland. Protection from human disturbances and from intense development produced a diverse mosaic of natural ecosystems between the access roads, buildings, and waste disposal areas. In most cases today, the DOE land areas in pristine condition are far larger than the areas devoted to buildings, asphalt, concrete, gravel, or periodic disturbances. The natural areas include coniferous and hardwood forests, shrublands, grasslands, meadows, riparian thickets, cypress swamps, lakes, ponds, reservoirs, and streams. These ecosystems harbor a large diversity of native plants, fish, and wildlife, including several species classified as rare or endangered.

OCR for page 34
ENVIRONMENT 53 Much could be written about the ecological value of these sites, but in brief and among other things, they (1) serve as buffer zones for DOE activities within them; (2) naturally decontaminate air, water, and soil through geocycling processes over time and distance; (3) serve as breeding grounds and nurseries that help to replenish populations both on and off site; (4) act to prevent soil erosion and to recharge watersheds and aquifers; (5) provide harvestable natural renewable resources like amber; and (6) act as corridors for fish and wildlife migrations, as well as seed dispersal. By reason of their status under DOE's protection, these lands preclude urbanization, agricultural development, and destruction of historic archeological sites. Many DOE sites are excellent and unique places in which to conduct ecological research Hat could not be done on lands accessible to the public. While these attributes are often not appre~cia~ by DOE and contractor management, there are a few exceptions. The SRS is a model example of a DOE facility where an ecological culture has been adopted by many managers. Basic ecological research by the Savannah River Ecology Laboratory (SREL), as well as the Savannah River Laboratory, seems well appreciated by DOE and the site contractor management Long-term, high-quality research along with popular writing and public ledges on the SRS wildlife and environment have obviously had a positive effect not only on plant management but also on public opinion. These activities thus have not only advanced science but they have also enhanced the independence and public credibility of DOE's environmental work. Recommendation Department of Energy and site contractor management should develop better awareness and appreciation for the ecological value of the lands under-their stewardship. The on-site expertise in ecology and related environmental sciences should be maintained and strengthened. As a part of DOE's basic research program related to environmental remediation, the ecological resources of weapons complex installations should be made accessible to qualified researchers under the minimum constraints required to meet specific security interests.