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Appendix A Summary of Past NRC Reports on Decision Making in DOE-EM and OST Several previous NRC reports have noted issues in the DOE-EM program that are relevant to OST decision making. The principal findings, conclusions, and recommendations of nine such reports are summarized below. NRC REPORTS PERTINENT TO DOE-EM BUT NOT ADDRESSED TO OST IN PARTICULAR I. The report Nuclear Weapons Complex: Management for Health, Safety, and the Environment (NRC, 1989), written at the beginning of the DOE-EM program, made several observations, recommendations, and conclusions reproduced here because of their relevance to decision making. On the Decision-Making Process Observations: be achieved. Decisions need to be pushed downward in the hierarchy of DOE, There is a tendency to push things upward, especially during budget deliberations, Lines of authority should be clear, simple, and unambiguous, Headquarters must provide clear guidance to the field offices and contractors if objectives are to "Conclusion: Many decisions are now unnecessarily deferred by staff to higher management levels, sometimes creating delay and paralysis in decision making" (NRC, 1989, p. 22~. "Recommendation: The Department should strengthen its management structure by delegating authority and responsibility for the initial resolution of issues to the lowest possible management levels, subject to clear guidance and support from upper management" (NRC, 1989, p. 22~. On Exchange of Information Within the Complex "Conclusion: Communications among organizations that confront common problems and efforts to focus the resources of the complex on finding solutions are inadequate" (NRC, ~ 989, p. 27~. 99
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100 Decision Making in the DOE-OST "Recommendation: The Department should work harder to overcome the natural impediments to the flow of information among contractors and to facilitate communication among the contractors and among DOE staff'' (NRC, 1989, p. 29~. On :Independent Technical Advice "Conclusion: The Deparunent is not aggressive enough in seeking the advice and counsel of experts from outside the weapons complex" (NRC, 1989, p. 29~. "Recommendation: The Department should aggressively seek outside advice, from the ACNFS [Advisory Committee on Nuclear Facility Safety] and other sources, with regard to the many technical issues that it confronts in the operation of the weapons complex" (NRC, ~ 989, p. 30~. On Setting Standards and Priorities Across the Complex "Conclusion: There is a need to develop and apply a scientifically credible scheme to aid in making decisions about appropriate cleanup standards and priorities for performing remediation in the face of resource limitations" (NRC, 1989, p. 38~. "Recommendation: The Deparanent should seek to achieve site-specif~c cleanup standards. Consistent risk assessment methodologies should be used to bring scientific information into decisions regarding extent of cleanup, cleanup methodologies, and priorities for environmental restoration" (NRC, 1989, p. 41). "Recommendation: To the greatest extent practicable, DOE should incorporate risk assessment as a guiding principle in developing an NPS [National Priority System]" (NRC, 1989, p. 42~. On Characterization of Contaminated Sites "Conclusion: Tntensif~ed 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" (NRC, 1989, p. 421. "Recommendation: Each installation should develop a comprehensive data base of environmental information, one that will allow the data to be accessed and used for a variety of purposes related to remediation of contaminated sites within the installation. The structure and content of the database 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 instalIation-wide geology, hydrogeology, and land use" (NRC, 1989, p. 43~. 2. The report Building Consensus Through Risk Assessment and Management of the Department of Energy's Environmental Remediation Program (NRC, 1994) noted that · the lack of trust in DOE and site operators is an impediment to the consensus and decision process;
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Appendix A Past NRC Reports on Decision Making in DOE-KM ant! OST · many interested parties (e.g., stakeholders) need to be involved from the beginning (i.e., at planning stages); · any such process to solicit their involvement should be open, clear, equitable, and inclusive; and · the absence of complete information should not be an excuse for lack of progress in site remediation. 101 The report commended risk assessment as "a highly desirable component of the remediation decision- making process" (NRC, 1994, p. 3), and said it was "one of a number of elements in the decision-making process and should not be treated as the only one" (NRC, 1994, p. 41. A comprehensive risk assessment process is feasible, desirable, and essential in consensus building for key decisions (NRC, 1994, p. 4~. 3. The report Improving the Environment: An Evaluation of DOE's Environmental Management Program (NRC, 199Sa) noted that the DOE-EM program had the following needs: · more specific goals; · a process for prioritizing tasks that would include risk assessment and cost-benefit analysis; · a peer-reviewed process for technology selection and development that is responsive to the needs of those implementing the remediation, and · incentives for successful implementation. These needs are contained in the report's principal recommendation: This committee believes getting on with the task, whichever definition one uses, will be accomplished most effectively by implementing a process for decision-making and accountability that includes · Having a more specific set of goals for the program · A process for prioritizing tasks which includes among its tools risk assessment (which should consider the perspectives and values of stakeholders as recommended in Building Consensus (NRC, 1994) and cost-benefit analysis. · A peer-reviewed remediation and waste-minimization technology selection and development process that is responsive to the needs of those implementing the remediation . An overall organizational and management structure which both provides an opportunity for stakeholder input in each of the above activities and provides incentives for stakeholders and federal and contract workers to implement these activities of the Environmental Management Program successfully. (NRC, 199Sa, pp. 10-! I) 4. The report Barriers to Science: Technical Management of the Department of Energy Environmental Remediation Program (NRC, 1996a) noted the following seven problems: I. planning that is driven by organizational structures rather than by problems to be solved; 2. commitments that are made without adequately considering technical feasibility, cost, and/or schedule; 3. an inability to look at more than one alternative at a time; 4. priorities that are driven by narrow interpretations of regulations rather than the regulatory purpose of protecting public health and the environment; S. the production of documents as an end in itself, rather than as a means to achieve a goal;
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102 Decision Making in the DOE-OST 6. a lack of organization coordination; and 7. a"not-invented-here" syndrome at sites. The report noted the following attributes ofthe DOE-EM program that were contributing concepts: lack of progress toward stated goals, a general inefficiency, goals that were not correctly formatted, and bad incentive programs. The report deduced the following problem with the DOE-EM program (NRC, 1996a, p. D: The committee observes a common pattern of behavior in these problems: What happens is driven too often by the internal needs of the organizational units charged with the remediation work rather than by the overall goal of environmental remediation. Efforts to remedy this situation must involve not only the Department of Energy, but also external stakeholders who have influenced its ways of doing business, including Congress, involved states, and the public. This problem is an organizational one, of technical management (NRC, 1996a, p. 191. External forces, as well as DOE culture, are contributing factors. An "aversion to decision-making" (NRC, 1996a, p. 19) is mentioned. 5. The report The Hanford Tanks: Environmental Impacts and Policy Choices (NRC, 1996c) reviewed alternative remediation approaches to the Hanford tanks, and noted that (~) significant uncertainties exist that limit current knowledge and that therefore (2) a phased decision strategy to consider multiple alternatives is called for. 6. Understanding Risk: Informing Decisions in a Democratic Society (NRC, 19966) emphasizes the role of risk characterization as a systematic analysis that includes participation by interested parties and as "a decision-d~riven activity, directed toward informing choices and solving problems" (NRC, 1996d, p. 21. The report noted the importance of early and total stakeholder-public involvement and the issue of public trust (or mistrust) in dealing with a government program. 7. The report Evaluating Federal Research Programs: Research and the Government Performance and Results Act (NRC, 1999b) examined research programs in federal institutions, including the DeparDnent of Energy, and offered recommendations as to how to assess the value of such programs. One recommendation was that expert review (an enhanced form of peer review that calls on individuals with sufficient expertise in the field to be considered to review the program) is the most effective method of reviewing federally funded research programs, concentrating on the following three indicators: I. quality of research programs Il. relevance to agency mission ant! IlI. international benchmarking
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Appendix A-Past NRC Reports on Decision Making in DOE-KM and OST NRC REPORTS PREPARED FOR OST 103 8. The Committee on Environmental Management Technologies Report for the Period Ending December 3l, 1994 (NRC, 1995b) noted, among others, the following characteristics of and advice to the OST program (as of December 1994~: · a lack of quantifiable end goals, cleanup levels, and criteria (to define technology development specifications and cleanup end points); · environmental remediation should be an expenment, with flexibility, integration of efforts, and feedback; · long-term work, particularly basic research, should continue, because the cleanup program will take more than 30 years; it is recommended that R&D focus on identified problems at particular sites; the final disposal destination of wastes should be considered in remediation decisions; the concept of waste minimization is praised as a criterion for technology development projects; the development of technology backups to the current baseline methods is lauded; vagueness is a noted characteristic of both I. numerical data and 2. the bases and assumptions underlying the derivation of calculated numbers; · the committee questions DOE's abilities to I. explore alternative technologies, after being locked into legal regulatory agreements for long term (multi-decade) cleanups, and 2. work with regulators in bringing new information to bear in renegotiating these agreements; · reasonable guidelines should be worked out between DOE and EPA on ground water cleanups for which it is unrealistic to expect to achieve drinking water standards; · the committee urged organizational continuity and stated that Focus Areas deserve a chance to see if they work well; and · redundant or duplicative technology development projects should be eliminated. The report noted three priority issues for OST: I. develop technologies that minimize secondary waste, 2. develop backup technologies, and 3. correct the vague criteria and apparent lack of justification that characterize the selection of site remediation measures, the desirable goals of remediation efforts, and the use of such information in technology development decisions. The report concludes (NRC, 1995b, p. 91: A culture change in technology development is needed at DOE-EM, where established programmatic and funding patterns are attuned to meeting the exigencies of site emergencies and external pressures. The committee hopes that the emphasis will turn to more systematic evaluation, including the use of risk assessment, to allow a more rational approach to technology development and site remediation.
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104 Decision Making in the DOE-OST 9. The report Environmental Management Technology-Development Program at the Department of Energy 1995 Review (NRC, 1996b), quoted below, gave recommendations that relate to the processes of goal setting, program planning, peer review, information gathering, and other activities that affect OST decision making. As expanded upon in the text, the Executive Summary noted (NRC, 1996b, p. 2~: Specific actions that DOE needs to take are . develop and implement quantitative criteria by which technology-development efforts can be prioritized and success can be measured; . carefully consider the waste streams (including those from remediation efforts to their eventual disposition) in determining adequate technology-development needs; . systematically assess and document previous and current efforts to develop and apply technologies using the quantitative criteria mentioned above; · apply effective, external peer review in the selection, evaluation, and prioritization of its projects; and . improve its system for information gathering and documentation on technologies that are available and under development by other relevant organizations in the United States and abroad. 10. Building an Effective Environmental Management Science Program: Final Assessment (NRC, 1997a) provided a recognition of the general value of scientific research in areas relevant to DOE-EM cleanup problems. The report recommends that the newly formed Environmental Management Science Program develop a "science plan." Other recommendations pertain to processes for proposal evaluation and program management strategies to enhance the long-term effectiveness and credibility of the EMSP. ~ I . Peer Review in the Department of Energy-Office of Science and Technology: Interim Report (NRC, 1997b) provided recommendations on the implementation of OST's peer review system to review projects that have been funded by the program and have reached sufficient maturity to show results of the technology development efforts. The report stressed that peer reviews should be conducted by technical experts external to (and independent of) the OST program office and highlighted the issues of I. defining the appropriate set of technical criteria to use in peer reviews and 2. defining the objectives of each peer review.
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