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--> 5 Planning the D&D Program The D&D of the three GDPs presents an interesting dichotomy. On the one hand, this D&D is a relatively simple operation, consisting of the demolition of large buildings and the removal and disposal of their contents; on the other hand, it is very complex, owing to the number of parties involved, the presence of hazardous substances, the complex regulatory environment, the long time frames for budgets and management, and the large scale of the project. Cost-effective management will require a management structure that is streamlined, orderly, responsive, focused on safety and cost containment, shares information, and is open to scrutiny by others throughout the D&D process. Careful planning is therefore required to ensure program integration, effective stakeholder involvement facilitating trust and confidence, and a responsive management that has the authority and responsibility to move the project to closure in an expeditious manner while protecting workers, the public, and the environment and complying with a large set of current and as-yet undefined regulations. It is a formidable task, but it can be completed successfully if able leaders on site are given the freedom and authority to get on with the task. It will require some changes in current management practices applied to D&D and the definition and implementation of a coordinated set of regulatory requirements. Public And Stakeholder Involvement Although the U.S. Department of Energy (DOE) and its project management are ultimately responsible for the project and cannot delegate that responsibility, the committee believes that involvement of the public and other stakeholders in the D&D process is an important factor in attaining cost-effective D&D (see, for example, Colorado Center for Environmental Management, 1993, and Confederated Tribes of the Umatilla Indian Reservation, 1995). There are several key constituencies that must be included in each site stakeholder group: the local and broader public, state and local officials, members of Congress, state and national regulators, and the workers. Other affected parties may be included as needed. These groups must not only be represented, but their active participation in providing input into all stages of the decision-making process, providing oversight, and representing the spectrum of views must be integrated. Local public and stakeholder involvement and its integration at the sites should be initiated early in D&D planning. Public involvement must be tied to planning and programmatic decision making early so that the views of the stakeholders can be considered in defining the basic direction of the program.
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--> While DOE and its project management are ultimately responsible for the project, a stakeholder involvement group should serve as a sounding board, consensus builder, and advisor. It is essential that stakeholders be provided with information on costs and technical limitations of the various alternatives to help them develop their recommendations. This arrangement will help to illuminate the positions of the various stakeholders and bring to bear the many positions. Further, it should be the advisory body in which compromises are developed in light of the widely varying and sometimes conflicting interests. The advisory body should also provide a constant view into the project, so that public input is represented in the work as it progresses from planning to implementation to completion. Such a public involvement process is very different from a public information program. Integrating the public and stakeholders into the D&D decision-making process poses challenges. DOE has shown an increasing understanding of the importance of public participation for the success of its new mission and has charged its Environmental Management Program with developing an integrated public involvement program. This programmatic responsibility is lodged in the Office of Public Accountability (DOE, 1994a). The D&D of the nation's GDPs are a part of the larger Environmental Management Program efforts and will therefore be expected to conform to, and benefit from, the evolving importance of its public participation program. Site Specific Advisory Boards (SSABs) are a recently developed mechanism to integrate stakeholder concerns. The SSAB provides a representative forum for affected groups at a site. DOE is forming an SSAB at the Oak Ridge Reservation; however, the board's intended relationship with existing public involvement groups is unclear. Funding for SSABs averages $200,000 per year; one (at Hanford) costs $900,000 (Beck, 1994). However, the costs of delay and lost opportunities resulting from failure to work together with these groups can be far higher. Establishing a cooperative relationship early should foster a functional and beneficial role that will enhance D&D, but DOE faces challenges in both integrating of existing groups and staking out a meaningful place in the D&D program for SSABs. One problem for the SSABs appears to arise out of the interpretation of the Federal Advisory Committee Act. While intended to ensure that the federal bureaucracy actively addresses stakeholder issues, the act's requirements may also interfere with the ability of the SSABs to set their own agenda and provide independent advice. This problem needs to be addressed and rectified by DOE to preserve the perceived legitimacy of the SSABs in their communities and to ensure that DOE does not exert too much control over SSAB activities. Because the public may not readily distinguish D&D from other environmental restoration activities at the sites, D&D stakeholder involvement must be a part of an integrated site stakeholder involvement program that considers the whole site. While each site has unique perspectives and concerns, experience with effective stakeholder involvement mechanisms should be shared among GDP sites. The committee believes that the SSAB can provide important input to DOE project management at each site during the course of the D&D project cycle. The exact format for stakeholder involvement may vary depending on the site and the individuals involved. An existing group that is functioning well and has broad representation may serve as the basis for an SSAB. The SSAB could include affected public(s), regulators, worker representatives, and
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--> others and would be formed at the beginning of the D&D process and operate throughout the D&D project cycle. Although the level of participation of the member groups may vary during the process, all should be actively involved during the planning phase and remain in an oversight role during the implementation phase. Although an SSAB is not charged with decision-making authority per se, meaningful participation implies that the SSABs, or their equivalent, would have an active role throughout the D&D process. For example, they should periodically review the work in progress, particularly when there are major changes to the work plan, significant schedule delays, or major cost overruns. For each site, stakeholder involvement could be managed through an SSAB or similar format; for the complex as a whole, a steering panel should be formed. The steering panel would provide program-level advice to DOE management on the conduct of the D&D efforts at the three GDP sites. The steering panel would provide input on such issues as focus, timing, priorities, budget, and end states on a GDP complex-wide basis. The panel would also serve the important function of addressing differences that may occur among sites. The panel should include representatives of the SSABs from each site to reflect concerns from the different localities. The Oak Ridge GDP site requires additional coordination with other activities at the Oak Ridge Reservation. End-State Alternatives Past D&D planning by DOE has been predicated on defining certain end states for the GDPs at the beginning of the planning and execution process. It has been assumed that the end state was the primary cost driver and that the same end state was to be obtained at all three sites. The Nuclear Regulatory Commission has a standard list of possible end points for D&D of nuclear power plants.1 However, these alternatives were developed for facilities and sites containing short-lived radionuclides, namely, cobalt-60. This is not the case at the GDPs, where 238U is the dominant radionuclide. The Ebasco and TLG D&D cost estimates assumed removal, rather than safe storage, of the equipment and hazardous and radioactive substances such that a future occupant would not be exposed to harmful levels of these substances. This approach is termed "prompt dismantlement." However, other end states are possible, and those considered by the committee are given in Table 5-1. This list is meant to be illustrative and is not intended to be complete. The end states are arranged in the order of increasing cleanup activity as follows: 1 These end points are referred to as ENTOMB, SAFSTOR, and DECON. The ENTOMB end point entails encasing the radioactive contaminants in structurally long-lived material that is maintained until the contaminants decay to a level permitting unrestricted release of the site. The SAFSTOR option involves maintaining the facility in a safe storage condition, with decontamination to an unrestricted release level deferred until a later date. Under the DECON option, the radioactive contaminants are removed from the equipment, structures, and site to a level permitting unrestricted release of the site shortly after cessation of facility operations.
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--> TABLE 5-1 End-State Alternatives for the D&D of the GDPs End State Description No action Buildings and facilities left in current state; Enriched uranium removed to eliminate criticality and safeguards concerns; Remedial actions halted except for significant, near-term risks; Limited access controls maintained and areas posted to indicate hazardous and radioactive materials present; Surveillance and maintenance continue in perpetuity Entombment, in place Stabilization of structure; Engineered barrier to minimize contaminant migration; Asbestos and materials contaminated with PCBs left in place; PCB-contaminated bulk fluids removed Entombment, surface burial Equipment and buildings dismantled and demolished; Contaminated equipment and structures buried in an on-site facility Decontamination, restricted use Contaminated equipment removed and buildings remain; Loose contamination removed or fixed in place; Buildings reused for alternative activities, such as waste storage Decontamination, unrestricted use, and release to commercial sector Contaminated equipment removed and buildings remain; Buildings decontaminated; Buildings released to the public for unrestricted use or abandoned and allowed to degrade over time Decontamination, greenfield Same as for unrestricted use and release, except that the buildings are removed and the site is covered with clean soil and released to the public
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--> No Action (long-term surveillance and maintenance). The present state of the retired facilities is maintained in perpetuity; access to those facilities is closely controlled, and significant near-term risks, such as highly enriched uranium, are mitigated. Entombment. The potentially mobile contamination in the structures is removed or fixed in place. The contaminated equipment remains in place, and the structures are sealed within an engineered enclosure to confine contaminants. An alternative entombment approach is to disassemble, demolish, and bury the structure and its contents in an on-site facility. Decontamination. Three variations of an option are considered in which the contaminated equipment is first removed and the remaining structures are subjected to one of the following: – partial decontamination and retention of the buildings for restricted reuse; – decontamination, retention, and release of the buildings for unrestricted, alternative reuse (this variation corresponds to the "prompt dismantlement" assumed in the cost estimates); or – demolition and complete removal of the buildings, with the site restored to greenfield conditions. In the no action and entombment alternatives, the contaminated equipment and structures remain on site for extended periods. Contaminant releases are limited by surveillance and maintenance of the structures in the first case and engineered enclosure limits releases in the second case. Because of the very long half-lives of the uranium radionuclides present at the sites, the contamination levels will be essentially unchanged when the existing buildings or the entombment enclosure collapses. The other hazardous substances also do not decay. Thus, no reduction of the risk associated with the structures and their equipment will have been achieved during the delay period. The three decontamination alternatives all presume removal of the contaminated equipment from the structures and either complete or partial decontamination of the empty structures. If decontamination is achieved, the clean structures may be demolished and the site restored to the greenfield condition, for example, for possible residential use. Alternatively, the structures may be left in place and released for unrestricted reuse. In these situations, the radiological and toxicological risks from the site have been reduced to an acceptable level. If the structures are only partially decontaminated, that is, loose contamination is removed or fixed in place, they may be retained for restricted use, such as storage for low-level radioactive or hazardous wastes, and a small but finite risk from hazardous or radioactive materials remains for the site. These end states are not mutually exclusive in the sense that at a particular site different buildings may be targeted for different levels of cleanup. For example, some buildings might be cleaned up for reuse, some demolished, and some might be put into a surveillance and maintenance program for cleanup in the future. Perhaps not all the sites would be cleaned up to achieve the same end state. Additionally, the goal of greenfield status, or taking a site back
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--> to a pristine condition for future unrestricted use, may not be appropriate if the remainder of the site has contaminated areas. In such a situation, the cleaned-up areas where the buildings once stood would be clean islands within a broader area that would most likely remain restricted because of residual contamination. Prioritized Cost- and Risk-Reduction Approach Choosing an end state as the starting point of D&D is not the only way to begin planning and conducting D&D Because of regulatory and budgetary uncertainty and the often lengthy process of developing consensus of the various groups affected by D&D operations, deciding on an end state could be a time-consuming process. Another approach is to prioritize the costs and risks presented by the site and schedule cleanup activities incrementally, focusing first on those activities that must be performed regardless of the final end state, on those areas where risk is highest, and on those actions that would reduce total costs over the entire D&D effort. Using this incremental approach, an end state need not be determined immediately; site release criteria would not be immediately necessary; and additional opportunities would be available to involve the public and other affected stakeholders. Furthermore, each of the end-state alternatives has its particular funding requirements and activity schedules and would require significant, sustained levels of funding over the time period specified to achieve the desired end state. Because of the uncertainties of budgetary and appropriations processes and the complex planning required, an incremental approach to D&D may be more appropriate, and work could proceed promptly within available annual budgets. The following example of the prioritized cost- and risk-reduction approach is provided as an illustration. If this approach were implemented, a complete and thorough determination of the costs and risks would be required. Starting from the baseline of "no action," the first activity would be the abatement of any potential for a nuclear criticality event. This could be accomplished by removal of those deposits of highly enriched uranium large enough to initiate a criticality event under appropriate conditions. This action would not only eliminate a significant risk to site workers, it might also eliminate the special security and accountability functions required by large inventories of special nuclear materials, thereby reducing the ongoing costs of surveillance and maintenance, such as by reducing the size of the security perimeter to reduce security costs. In the absence of a quantitative risk assessment, the committee believes that at this point, the only high-consequence, significant-probability risks associated with the facilities appear to be fire or high winds causing release and transport of friable asbestos, PCBs and/or their combustion products, and loose radioactive surface contamination. 2 Efforts to remove or fix asbestos contamination would mitigate this risk, and effective fire protection measures would substantially reduce the chance of fire borne dispersal of PCBs or loose surface contamination. Draining and replacing PCB fluids in electrical equipment would reduce the hazards associated with a fire in PCB-containing electrical equipment. 2 The risk of other natural hazard events, such as earthquakes, should be evaluated.
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--> After these risks have been mitigated, measures to remove potential long-term hazards would be carried out in a prioritized fashion by considering marginal risk reduction versus cost. If carried to completion, this strategy could eventually result in the removal and disposal of all contaminated materials and release of the site for unrestricted use or in permanent restriction of those areas of the sites unsuitable for remediation. Development Of An Integrated Regulatory Program The D&D of the uranium enrichment facilities will be conducted under the regulatory oversight of several agencies. While large quantities of radioactive and/or toxic materials are found in the GDPs, three predominate: uranium compounds including large amounts of UF6 (uranium hexafluoride), PCBs, and asbestos. Regulations promulgated by states, federal agencies, and internal DOE orders are intended to protect workers, the environment, and the public from toxic and/or radioactive releases into the air or water and to ensure that hazardous, radioactive, and mixed wastes are reduced and treated appropriately. During D&D operations, similar protections will be required. However, regulations can drive up the cost unnecessarily if they conflict with one another or are redundant. Regulatory mandates can also alter the D&D schedule. Similarly, some regulations need to be promulgated to facilitate D&D planning, particularly standards addressing numerical limits for recycled materials and site release criteria. Such standards will enable DOE to target cleanup end states, although planning and initial cleanup must and can proceed in their absence.3 Costs will be reduced if regulations can be applied in a coordinated fashion to the entire D&D effort. Federal Regulations Together with the DOE, a number of federal regulatory agencies such as the EPA, Nuclear Regulatory Commission, Occupational Safety and Health Administration (OSHA), and Department of Transportation (DOT) have authority over aspects of the D&D program. EPACT provides the broad structure for health, safety, and environmental oversight during D&D of the uranium enrichment facilities. In addition, numerous environmental laws will bear on D&D. Each of these laws has a major impact on planning and eventual conduct of D&D (DOE, 1991). However, the Comprehensive Emergency Response, Compensation, and Liability Act of 1980 (CERCLA, or "Superfund"), in concert with the Resource Conservation and Recovery Act (RCRA), is the overarching law regulating D&D. DOE DOE has an unusual role in D&D in that it is both a regulated entity and a regulator. In one role, DOE will be responsible for planning and implementing D&D activities and for this reason will be subject to EPA, Nuclear Regulatory Commission, and OSHA regulations. In its 3 Because radionuclides at the GDPs are limited and uranium predominates, the Environmental Protection Agency and the Nuclear Regulatory Commission could accelerate promulgation of regulations for uranium, technetium (99Tc), plutonium (234Pu), and neptunium 237Np), which would clarify DOE D&D goals.
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--> other role, DOE will apply a number of internal DOE orders to regulate D&D activities. These orders are designed to protect workers, the public, and the environment, through prescriptive rules on such issues as nuclear criticality safety. EPA EPA has primary regulatory authority over D&D of the three sites under CERCLA. It already has oversight of the Paducah GDP and the Oak Ridge Reservation because they are listed on the CERCLA National Priorities List; the Portsmouth GDP site may be added to the list in the near future, based on its hazard risk ranking score. Other laws and regulations that apply include RCRA, TSCA (Toxic Substances Control Act), the Clean Water Act, Clean Air Act, and Federal Facilities Compliance Act of 1992 (FFCA). Nuclear Regulatory Commission Normally, the Atomic Energy Act exempts DOE facilities from regulation by the Nuclear Regulatory Commission. However, EPACT, which established the USEC, mandated that the Commission certify Portsmouth and Paducah for continued safe operation; the Commission does not have jurisdiction over the Oak Ridge GDP site itself, since it is not an operating or commercial GDP. In contrast to the practice for most facilities under Nuclear Regulatory Commission jurisdiction, the Commission will issue a certificate, rather than a license, for Portsmouth and Paducah. The Nuclear Regulatory Commission has issued a proposed rule, "Certification of Gaseous Diffusion Plants," specific to these facilities and assumed regulatory authority from DOE on October 1, 1995. Although the Commission's role in overseeing the operating facilities is delineated by the EPACT, its role is less clear for D&D operations. An orderly transition plan to move from Nuclear Regulatory Commission regulation of the operating facilities to EPA regulation of the D&D effort could serve to minimize regulatory confusion and cost. OSHA Traditionally DOE facilities have also been exempt from the Occupational Safety and Health Act and OSHA regulation under the Atomic Energy Act. However, under a recently enacted memorandum of understanding with DOE (OSHA, 1994), OSHA will have oversight over DOE facilities, such as those undergoing D&D. Furthermore, the legislation establishing the USEC mandated OSHA oversight of the two leased GDPs during enrichment operations. OSHA currently provides training for the GDP staffs on hazard identification during enrichment operations. Plans for ongoing worker safety have not made a clear distinction between the different requirements of enrichment operations and D&D. However, routine maintenance activities can involve some decontamination, thus blurring the distinction between operations and D&D. OSHA has not identified its staffing and budgeting requirements to support DOE in its D&D program. In part, this is because OSHA, like the Nuclear Regulatory Commission, does not have a clearly defined role in D&D. Once OSHA's role is delineated, it could impose an additional cost not reflected in the Ebasco or TLG cost estimates. Because the greatest risk
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--> during D&D will likely be to on-site workers, expenditures to reduce these risks will be justified. DOT DOT has served as the regulatory authority for transport of enriched uranium product among the three GDP sites for a number of years. During D&D, it will regulate the safe transport of all waste materials from the sites under Hazardous Materials Transportation Regulations. Under the Hazardous Materials Transportation Act of 1974, DOT has regulatory responsibility for safety in the transportation of all hazardous materials and radioactive materials (DOT, 1983). This responsibility covers shipments by all modes of transportation in interstate and international commerce and by all means of conveyance, including truck, barge, rail car, vessel, and airplane. DOT and the Nuclear Regulatory Commission operate under a memorandum of understanding, revised June 8, 1979. Under this memorandum, DOT's role includes development of overall safety standards governing all radioactive materials packaging, their clarification, marking, and labeling. DOT has responsibility for packaging requirements for all waste materials expected to be generated from the three GDPs. USEC Effects on Regulatory Oversight The privatization of the two operating GDPs presents legal differences in regulatory oversight. For instance, Nuclear Regulatory Commission and OSHA regulations are not applicable to the Oak Ridge GDP, but are applicable to enrichment operations at the Paducah and Portsmouth GDPs through the USEC under Section 1312(c) of EPACT. It is unclear whether this regulatory oversight will change or cease upon closure of these GDPs. As part of the regulatory requirements scheduling, DOE should begin to develop regulatory plans for transfer of control of the two operating plants leased by the USEC back to DOE for D&D. 4 EPA and Nuclear Regulatory Commission Development of Radiation Site Cleanup Regulation Both the EPA and Nuclear Regulatory Commission, in coordination with DOE and the U.S. Department of Defense, are developing revised risk-based radiation site cleanup regulations. EPA is drafting applicable regulations for federal facilities, with a final rule due to be published in 1996. The Nuclear Regulatory Commission is also developing risk-based radiation site cleanup standards for its licensees,5 based on a proposed limit of 15 mrem/yr of total effective dose equivalent, including a 4 mrem/yr water quality requirement, for unrestricted 4 DOE is developing a plan of action to develop a regulatory strategy for the turnover of the GDPs to DOE after plant shutdown (DOE, 1995). 5 Existing cost estimates have used Nuclear Regulatory Commission Regulatory Guide 1.86 and DOE Order 5400.5 for site release criteria.
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--> site release.6 A total effective dose equivalent of 15 mrem/r is approximately a 4 × 10-4 lifetime fatal cancer probability. Congressional pressure has been exerted recently on these agencies to reconcile their radiation protection standards and risk assessment methodologies (GAO, 1994a; Lobsenz, 1994), and EPA has been asked to lead this effort (Lobsenz, 1995). DOE should continue to participate in and support these efforts. The issue of acceptable risk levels is politically sensitive, and delays in development of criteria are possible. However, once risk-based cleanup regulations are developed, appropriate future use scenarios should be used to determine site-specific exposure limits appropriate to the GDP sites. State Regulation Each of the GDPs is located in a different state and each state has a different set of laws and regulatory agencies that oversee the GDPs. There may be economic merit in developing uniformity across state lines: if DOE can create one master plan for cleanup for all three plants that is acceptable to all three state regulators, and state regulations are consistent, costs could be reduced. The state agencies differ in structure and in the history of their dealings with federal agencies.7 For example, the Ohio Environmental Protection Agency has sued DOE to dispose of the DUF6 (depleted uranium hexafluoride) inventory as waste (Van Kley, 1994). DOE characterizes this material as a national asset, rather than a waste. Moreover, DOE and the Ohio agency have different positions about whether, even if this material were deemed a waste, it would be regulated under RCRA and thereby subject to strict state monitoring and enforcement. (See Chapter 7 for a more complete discussion of DUF6.) For such reasons, establishment and development of a new working relationship among all the regulatory agencies, including those at the state level, will be required. State law suits and inspections and efforts by agency and contractor personnel to correct violations can increase the costs of D&D. The committee believes that if facility personnel and regulators work together and carry on an open dialogue, the emergence of major problems and violations can be better anticipated and avoided to a great extent. DOE involvement in the continuing deliberations of one of the national-level stakeholder groups, the State and Tribal Government Working Group, as well as its efforts with the National Governors Association, is a good start in establishing a smooth working relationship. Direct involvement of the state regulators at the sites is essential in the planning stages to minimize conflicts during D&D. 6 Restricted release scenarios may also be allowed, with adequate institutional controls in place. The standards would then be set such that if all institutional controls failed, the public would not be exposed to doses in excess of 100 mrem/yr. 7 Some state agencies are funded solely through the state, others through DOE funds transferred through other agencies.
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--> Challenges and Current Developments Some aspects of the regulatory arena contribute to uncertainty in planning work and developing cost estimates for cleanup of the three GDPs. One of the most significant, as the discussion above has indicated, is the fact that there are many agencies with jurisdiction over D&D, with insufficient coordination among agencies to integrate laws and resulting regulations. A prime example of this is regulation of mixed waste, that is, waste that is classified as both hazardous and radioactive. Significant quantities of mixed waste could be generated during D&D, although no quantitative estimates appear to be available. The Nuclear Regulatory Commission and DOE regulate mixed waste under the Atomic Energy Act, and EPA regulates it under the RCRA. These two regulatory programs prescribe different solutions to the mixed waste disposal problem. For example, radioactive wastes must be buried, while hazardous wastes are not allowed to be buried. This regulatory quandary has resulted in complex disposal systems (Thompson and Goo, 1993). Few of the environmental protection laws were legislated mindful of D&D requirements of the federal facilities, much less the GDPs. The FFCA is an exception in that it was specifically drafted to require federal facilities to comply with environmental laws. Its implementation clearly reflects the difficulties in obtaining the necessary coordination and cooperation of states, Indian tribes, and other key stakeholder groups. The multiple federal agencies involved in D&D, however, must compete for dollars allocated by Congress, while producing regulatory redundancies that do not provide additional checks and balances but create inconsistencies (Thompson and Goo, 1993). A General Accounting Office report, citing the various EPA, Nuclear Regulatory Commission, and DOE regulations, suggests that there has been a "historical lack of a unified federal framework for protecting the public from radiation exposure" (GAO, 1994a). Although it may be tempting to avoid compliance if regulations appear to conflict with one another, it is incumbent on decision makers to find creative integrating mechanisms that enhance environmental protection rather than avoid it. Under the FFCA, DOE is required to submit mixed-waste treatment plans either to host states that are authorized to regulate hazardous materials or to EPA (GAO, 1994b). The three states within which the GDPs are located are at various stages in negotiating mixed-waste plans with DOE. Waste management issues are illustrative of the difficulties of integrating state and federal oversight, conflicting regulations, and predicting the cost and schedule impact of future regulations. For materials that have surface contamination, standards exist that allow free-release if sufficient decontamination is achieved. These surface standards are currently under review by EPA and the Nuclear Regulatory Commission. There are no volumetric free-release standards for materials recycling in the United States. Waste regulations that have yet to be promulgated are those for recycling of materials, particularly metals and other materials that have been exposed to radioactive contamination. While most of the GDP materials only have surface contamination, some, such as the nickel barrier materials, have geometries that make decontamination difficult. Recycling potential would be enhanced with a volumetric standard. Both the Nuclear Regulatory Commission and EPA have begun preliminary work on surface and
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--> also incorporate the results of sensitivity analyses and assessment of the impact of design alternatives on project objectives (costs, risks, and social values). One useful method is to use decision and systems analysis. This method will be useful at this level to frame the alternatives and explore and communicate the consequences of potential decisions, as well as the uncertainties in these consequences. Early analysis allows identification of significant constraints (e.g., funding, public acceptance, or technological limitations) and minimizes the likelihood that infeasible solutions will be pursued. D&D Organization and Staffing Once the scope of work has been defined, the project organization and staffing should be planned by DOE. Prior D&D experience indicates that operation and maintenance personnel have valuable experience that should be used in developing the D&D plan and that continuity of key personnel enhances productivity. The requirements of labor laws and existing site labor agreements need to be integrated with the overall contracting strategy to strive for the optimal number and type of D&D workers. Plant Characterization Program A cost-effective characterization program is essential to identify and quantify radiological and other hazardous contaminants, and it is critical to project success. However, complete characterization of the GDPs is not necessary at the planning stage. The implementation of a data quality objectives approach to characterization will help in tailoring the characterization plan to support achievement of the desired end state. A data quality objectives approach identifies the level of data needed to support a given decision (e.g., to release the sites for unrestricted use), and the characterization plan is designed to provide data to within a desired level of accuracy. Such an approach will help avoid over design of characterization plans. Regulatory Plan An integrated plan should cover regulations and regulators governing the conduct of D&D at all three GDPs. The plan should also cover interface points with the appropriate government regulatory agencies and identify different standards that may apply to the sites in different states. Waste Management Plan Large quantities of waste materials will be generated during D&D. Management of this waste will entail either construction of new on-site treatment or storage and disposal facilities or transportation of these materials off site to new or existing facilities. Selection of a waste management approach will be influenced by costs, regulations, end-state decisions, availability of waste facilities, and the public's views. The costs and risks of packaging, transport, and off-site disposal must be weighed against the costs and regulatory hurdles inherent in constructing on-site facilities. For example, some waste is already being stored at the Oak Ridge GDP, which could affect D&D. Even if low-cost waste storage and disposal capacity is readily available off site, the political climate may not allow transportation
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--> to out-of-state facilities. There are also long-term uncertainties about the local acceptance of storage of low-level radioactive or mixed wastes. Because of the large volumes of radioactive, mixed, and hazardous wastes likely to be generated during D&D, DOE needs to start now to develop a waste disposal plan. The plan should consider low-level radioactive, mixed, and hazardous wastes and should address the issues of on- versus off-site waste treatment and disposal and expected disposal costs. The plan's goal should be to minimize secondary and mixed wastes and to maximize recycling where it is economical and safe to do so. Three sets of factors to be considered are scheduling and sequencing of D&D operations, end-state alternatives, and waste management. These factors are illustrative of the many issues that DOE must address in its planning. The complex-level plan should provide for coordination at and across the three facilities within the complex. This major planning document should be flexible enough that site-level planning can adopt and modify it to meet the specific needs of each of the three sites. The complex-level D&D plan will serve as the planning interface with the other activities required to manage the sites, including remediation of soils and groundwater and the management of the DUF6 stockpile. Site-Level Planning A detailed decommissioning plan, which does not currently exist, is essential to define the project baseline, cost estimate, D&D operations sequence, and schedule. The Ebasco cost estimate was performed in a short period of time without the benefit of a detailed decommissioning plan and a well-defined technical baseline. Ebasco did not have enough time to conduct a thorough evaluation of alternative D&D technologies, waste disposal options, or optimizing D&D operations sequence and schedule. The lack of technical, cost, and schedule baselines for the current cost estimate undermines its credibility. When a new cost estimate is prepared, it should be structured to allow determining the cost impact of changes in the principal variables, such as period of performance, inflationary increases in labor, materials and disposal costs, funding assumptions, and introduction of new D&D technology. The work plan should be prepared after discussion with the stakeholders about the D&D priorities. Planning should proceed expeditiously without waiting for all regulations to be issued and for other uncertainties to be resolved. Planning at the site level will consist of two parts. The first is application of the complex-level plan to the site by making necessary modifications so that the plan is site-specific. This plan may include such elements as specific time schedules, regulatory scenarios particular to the site, and detailed stakeholder identification. This plan should also detail the goals and objectives for the site and the broad outlines for the scope of work. The second part of planning should include a detailed work breakdown structure for D&D and sufficient detail to develop a budget-level cost estimate and bid solicitation for the work to be performed.
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--> Execution of the Planning Planning should be a continuing effort allowing modifications to reflect regulatory changes, funding constraints, obstacles encountered, and alterations made. Although site planning should be done almost in parallel at the three sites to form the basis for a new cost estimate, the plans for the sites should be modified and updated to incorporate lessons learned from ongoing D&D. Thus, if Oak Ridge undergoes D&D first, experience from this activity should be reflected in modifications of the D&D plans for the other two sites. Plans should be subject to change to take advantage, for example, of changes in regulations or stakeholder input. Plans will also be affected by other factors, such as the schedule for D&D. Based on the experience and knowledge base for the D&D of the GDPs, the committee judges that the first part of the site-level plan should be completed within 12 months and the second part of the site-level plan should take no more than another 6 to 12 months to complete. The plan should begin well in advance of the need for a detailed cost estimate and certainly while personnel knowledgeable of current operations are available. Planning should be performed by an independent contractor who is not currently managing the D&D planning or execution at the three GDP sites. There would be a learning period for such an independent contractor, but the committee believes that a fresh approach could be brought to D&D planning that is not tied to existing site practices and procedures relevant to an operating facility. This contractor could draw on the knowledge of experienced personnel at the sites and at the same time would not be constrained by preconceived notions of how to accomplish the D&D. Scheduling and Sequencing The current D&D program schedule envisions the D&D of the Oak Ridge GDP first, followed by that of the Portsmouth and Paducah GDPs. The Ebasco cost estimate assumed Oak Ridge followed by Paducah with Portsmouth last (DOE, 1991). The schedule and sequence of D&D activities will impact project cost and funding requirements. For example, the D&D of the three sites could be conducted in series to minimize annual funding requirements. Alternatively, the activities could be conducted in parallel. This strategy could reduce the total program schedule and cost, for example, by reducing the annual expenditures for surveillance and maintenance. Shortening the time period would also reduce overhead and program management costs. The D&D program could also be conducted using a staggered schedule that maximized the transfer of experience among the sites and might limit the number of subcontractors required. The annual contributions to the D&D Fund and the accumulations that accrue will constrain the rate at which D&D can be accomplished. Similarly, the sequence of activities among the three GDPs can be varied. For example, processing of the DUF6 could begin at Paducah first because it has the largest inventory and the greatest amount of the lowest 235U assay material, which is the least attractive for possible alternative uses (see Chapter 7). However, there are reasonable arguments for processing the DUF6 at Portsmouth first; the Ohio Attorney General has pressed for extensive monitoring, if not near-term disposition, of the DUF6 inventory. Different factors may influence the choice of a given schedule, in some cases accelerating and in others slowing down D&D operations. For example, delayed D&D or an extended
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--> program allow some technology demonstration efforts to reduce uncertainties and more detailed D&D planning, workforce planning and restructuring, and public involvement. Delayed D&D also allows DOE to address more immediate, high-risk concerns in its weapons complex. However, extending the schedule increases the cost of annual surveillance and maintenance, neglects those site risks that will increase over time, and increases the chances that D&D Fund resources are spent on activities other than D&D. Of course, accelerating the cleanup schedule too drastically introduces the possibility of wasted efforts and resources if some tasks must be redone. Effects of Early Plant Shutdown The current surplus in worldwide uranium enrichment capacity and the inherent high cost of the inefficient gaseous diffusion technology compared with modern gas centrifuge enrichment plants may lead the USEC to cease operations of one or both of the operating facilities prematurely. Such action might affect the order of planned site cleanup. For example, it might be prudent to begin full-scale D&D with a newly closed plant. Because its process piping would still be intact and support services would be readily available, it might be easier to reduce near term concerns as well as facilitate subsequent D&D. Furthermore, because of the personnel safety requirements of an operating plant, a newly closed plant would represent a less contaminated starting point and might be more useful for technology demonstration efforts. DOE needs to plan now for this possibility, including how an early plant shutdown might affect D&D scheduling, planning, and resource requirements.11 Effects of D&D Program Delay Increasing Future Risks. Lacking a quantitative site risk assessment, it appears to the committee that the risks to the public of the sites are low at present, based on the limited amount of contaminant exposure. However, these risks will likely increase in the future because of degradation of the existing facilities and DUF6 cylinders. These increasing risks will be borne both by the local public and, more immediately, by the D&D workers. Increased requirements for plant personnel protection could increase D&D costs and will certainly increase surveillance and maintenance costs. Intergenerational Equity. Cleanup delays would also postpone the potential benefits to the public (economic, environmental, and political) of a "clean" site. Extended delays have the effect of transferring the problem to future generations if funds are not set aside for eventual D&D. If the D&D inflation rate is less than the national discount rate, economic discounting of future D&D costs would imply an economic benefit in delaying the D&D operations but would place a burden on future generations. Long-Term Program Support. Planning a coherent D&D program is difficult because the time span projected for cleanup is great—one of many years and many political administrations. Program delays could hamper managerial focus, increase congressional criticism, and reduce program funding support. 11 DOE has initiated contingency planning for the turnover of a GDP from the USEC (DOE, 1994b).
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--> Competition for D&D Fund Resources. Compared to the existing cost estimates, the planned resources of the D&D Fund appear to be insufficient to complete the cleanup of the three GDPs. Other environmental restoration activities that are being conducted at the three sites include the remediation of contaminated soils and groundwater and management activities associated with potential DUF6 cylinder disposition. Although some of these efforts may respond to more immediate health, safety, or environmental risks, they are nonetheless competing for D&D Fund resources. Program delays increase the probability that these resources will be exhausted before the D&D of the GDP facilities is completed. Regulatory Uncertainty. The regulatory and political arena has changed considerably in the past 20 years and will continue to change over the next decades. These changes have ramifications for cost and program support of the cleanup effort, particularly for planning and management. In addition, agencies such as OSHA have not yet been included in D&D planning, even though OSHA regulations could be a major factor in the organization, cost, and potential litigation over D&D. Management Issues The discussion above has shown how management of D&D is influenced by many activities both within and outside of DOE. Management must be sensitive to these influences and activities and integrate and coordinate them at both the complex and site levels. A management structure needs to be developed that ties integrated planning, management, and stakeholder involvement to the D&D project cycle, for example, see that shown in Figure 5-1. It FIGURE 5-1 Organizational framework for D&D of the GDPs.
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--> is particularly important at the complex level that attention be paid to complex-wide resource allocation as well as regulatory, waste management, and disposal issues. It is also important that integration of the D&D, DUF6, and remediation programs is managed at the complex level. At the site level, management will be more concerned with detail. While DOE personnel will provide oversight and coordination, day-to-day management will rest with a contractor, as discussed below. Coordination at the site level, including SSAB involvement, will be required to ensure that site and local needs are considered and met. Coordination with other site activities, such as environmental restoration and waste management, will be required to ensure success. The management structure across the entire complex must be evaluated to ensure that there is the proper level of coordination and oversight. Layers of management should be reduced wherever possible. Increasing the direct labor to management labor ratio across the complex should be an early goal of management during planning. DOE should use as a benchmark the resource allocations that were effective in similar programs, such as in the D&D of the Shippingport facility. A detailed discussion of the management structure and contracting approach is presented in Chapter 6. Recommendations This chapter's findings and recommendations are summarized in Table 5-2 and are discussed in more detail below. Public and Stakeholder Involvement DOE needs to integrate the involvement of the various stakeholder groups at the sites. Use of an SSAB-type group may be a way to coordinate the involvement of these various groups, although SSABs are not without problems. Because the public may not readily distinguish D&D from other environmental activities at the sites, D&D stakeholder involvement must be integrated with other site stakeholder involvement programs at the sites. Although each site is unique, lessons learned should be shared among sites. Public involvement must start early in the D&D planning process. DOE should move expeditiously to achieve public involvement in setting D&D priorities, examining of future uses of sites and facilities, and waste disposal decision making. Stakeholders should provide advice and consultation to DOE and its contractors during project planning for each site. Regulatory Issues DOE needs to work with regulators early in D&D planning to couple regulatory requirements to the D&D schedule. A mechanism for coordination between DOE and appropriate federal and state regulators should be developed to enhance D&D planning.
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--> TABLE 5-2 Suggested Approach for Managing the D&D Process Areas Current Approach Recommended Approach Public and stakeholder involvement Historical context implies lack of trust between DOE and the public. Build on new DOE goal of meaningful citizen participation, possibly along the model of an SSAB. Multiple stakeholder groups are involved, and there is a lack of integration. Examine existing citizen participation programs for applicability to D&D, with the goal of establishing a site-level stakeholder involvement group. Use D&D steering group to provide stakeholder involvement at the GDP-complex level. Begin interaction with stakeholders immediately to solicit input early in the D&D planning. Regulatory issues Multiple regulators have jurisdiction over GDP sites. There is lack of coordination among regulators, including state regulators. Develop creative mechanisms and models for regulatory coordination between DOE and appropriate federal and state regulators. Regulatory issues have not been integrated into the D&D schedule. Work with regulators to couple regulatory requirements to the D&D schedule. Currently, there is no plan for regulatory hand-off of operating GDPs from the USEC to DOE. Plan for return of leased USEC assets back to DOE control for D&D. There are no standards for site cleanup or recycling of volume-contaminated materials. Continue DOE participation and support in the interagency working group on radiation standards. Use projected future use of the sites to guide release criteria.
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--> TABLE 5-2 Suggested Approach for Managing the D&D Process Areas Current Approach Recommended Approach Planning Each GDP is treated as a separate unit in planning D&D. Develop a complex-wide, detailed decommissioning plan for the three sites that provides a technical baseline; plans for uniform site characterization; a schedule of tasks based on cost and risk priorities; personnel and funding requirements; management, contracting and integrated regulatory approaches; and waste management and stakeholder involvement. Oak Ridge GDP was operated and shut down without preparation for D&D. For the Portsmouth and Paducah plants, operations are planned for many more years before D&D, although a contingency planning effort was begun in 1995 for possible shutdown. Develop plan for possible early closure of Portsmouth and Paducah, so that shutdown operations do not hinder, and perhaps will enhance, D&D. End states are expected to be chosen before D&D planning and execution can begin. Begin prioritized cost- and risk-reduction process, while engaging all stakeholders and regulators in priority setting for D&D. Make decommissioning plans modular to accommodate prioritized cost- and risk-reduction approach. Develop waste management plan to minimize secondary and mixed waste and maximize recycling where economical. Management issues There are multiple layers of DOE and contractor oversight, as well as outside committee oversight. Simplify management structure. Restructure workforce to increase the ratio of direct to indirect D&D personnel. There is a lack of inter- and intrasite coordination; different DOE entities administer D&D, environmental remediation, DUF6 management, waste management, and site landlord functions. Develop complex-wide and site-specific integration of environmental restoration functions (D&D, DUF6 management, environmental remediation, and waste management).
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--> At the state-level, DOE needs to emphasize a new cooperative approach with the states to minimize conflicts. The Interagency Working Group on Radiation Site Cleanup Standards should proceed expeditiously to develop a consistent set of regulations that can be applied to D&D. Application of these new standards should use site-specific exposure scenarios appropriate to these sites. To minimize costs and contamination, DOE needs to start now to develop regulatory plans for transfer of control of the GDP assets from the USEC back to DOE for D&D. Planning DOE should develop a complex-level plan that covers a number of areas: technical baseline; schedule of tasks, such as GDP characterization; personnel and funding requirements over time; management and contracting approach; applicable regulations, such as site release criteria; waste management; and public and stakeholder involvement. Because of the possibility of early plant shutdown, DOE needs to prepare now by examining how early shutdown would affect scheduling options, costs, and planning. DOE should use a prioritized cost- and risk-reduction approach to proceed with D&D in the face of the many uncertainties about D&D. This strategy allows work to begin from the start of planning, which integrates annual surveillance and maintenance costs and slowly increasing risks, does not foreclose end-state options, and demonstrates commitment to cleanup. Management Issues For the GDP complex as a whole, DOE should coordinate D&D, environmental remediation, management of DUF6, and waste management activities. At each site, DOE should coordinate D&D, landlord functions (such as maintaining buildings and infrastructure services, such as water, electricity, and security), environmental restoration, DUF6 management, and waste management to minimize annual surveillance and maintenance costs and to avoid actions that could hamper or delay D&D. A management approach should be taken that is streamlined, efficient, and increases the ratio of direct to indirect labor required.
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--> References Beck, D. 1994. DOE Stakeholders Involvement Program. Presented to the Committee on Decontamination and Decommissioning of Uranium Enrichment Facilities, Radisson Hotel, Columbus, Ohio, August 23, 1994. Colorado Center for Environmental Management. 1993. Environmental Decision Making: Conflict and Consensus. Golden, Colorado: Colorado Center for Environmental Management. Confederated Tribes of the Umatilla Indian Reservation. 1995. Scoping Report: Nuclear Risks in Tribal Communities, A Report by the Confederated Tribes of the Umatilla Indian Reservation Outlining Concerns About Risk-Based Approaches to Environmental Management Decision-Making. Pendleton, Oregon: Confederated Tribes of the Umatilla Indian Reservation. March. DOE (U.S. Department of Energy). 1991. Environmental Restoration of the Gaseous Diffusion Plants. Technical Summary Document, vol. 1. Washington, D.C.: Ebasco Environmental and Main-1893 for the DOE. October. DOE. 1994a. Public Participation Desk Reference (draft). Washington, D.C.: Office of Environmental Management. July. DOE. 1994b. The Department of Energy Contingency Plan for Turnover of a Gaseous Diffusion Plant from the United States Enrichment Corporation (pre-decision draft). Oak Ridge, Tennessee: DOE. August 31. DOE. 1995. GDP Turnover Contingency Plan. EFSD-95-007. Oak Ridge, Tennessee: DOE. October 2. DOT (U.S. Department of Transportation). 1983. A Review of the Department of Transportation Regulations of Transportation of Radioactive Materials. Washington, D.C.: DOT. Federal Register. 1986. Below Regulatory Concern (BRC), 51 FR 30839. Volume 51. August 29. GAO (U.S. General Accounting Office). 1994a. Nuclear Health and Safety: Consensus on Acceptable Radiation Risk to the Public is Lacking. GAO/RCED-94-190. Washington, D.C.: U.S. Government Printing Office. GAO. 1994b. Nuclear Waste: Much Effort Needed to Meet Federal Facility Compliance Act's Requirements. GAO/RCED-94-179. Washington, D.C.: U.S. Government Printing Office.
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--> Lobsenz, G. 1994. Glenn seeks to harmonize radiation standards. The Energy Daily. October 31. 22(208): 1–2. Lobsenz, G. 1995. Its official: EPA leading radiation standards review. The Energy Daily. April 13. 23(81): 4. OSHA (Occupational Safety and Health Administration). 1994. Memorandum of Understanding between the U.S. Department of Labor—OSHA and the U.S. Department of Energy Office of Environment, Safety and Health. December 21. Thompson, A. and M. Goo. 1993. Mixed Waste: A way to solve the quandary. Environmental Law Reporter, News and Analysis. December. 23 (ELR): 10705. Van Kley, J. 1994. Presentation by Jack Van Kley, Ohio Attorney General's Office, to the Decision and Process Analysis Panel of the Committee on Decontamination and Decommissioning of Uranium Enrichment Facilities, National Academy of Sciences, Columbus, Ohio, August 24, 1994.
Representative terms from entire chapter: