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5 Address Constraints to Technology Implementation The committees recognized that OST's ability to promote implementation of new technologies is constrained by legal and regulatory requirements and other non-OST factors, both within and external to DOE. Successful implementation of new and innovative technologies will require OST to identify these hindrances, evaluate their validity and importance, and in some cases, take a more proactive role in effecting change. Although some of these changes can be made by OST itself, most will require working with other elements in DOE, and some will require working with other federal and state agencies, Congress, and state legislatures. CONSTRAINTS WITHIN DOE OST operates in a complex, ever-changing environment. As pointed out by the Decision Making Committee, an important complication for OST is that the sites and EM offices responsible for overseeing waste management and cleanup activities (e.g., EM-30, EM-40) have a great deal of autonomy in selecting baseline remediation processes and technologies to deploy, consistent with current legally enforceable agreements. Furthermore, they are under no obligation to use OST-developed technologies and often pursue their own technology deployments (Decision Making report, p. 9~. In fact, contractors and managers at DOE installations have in some cases resisted efforts by DOE 35 The D&D Committee, as well as others, recognized the "not invented here" syndrome (i.e., whereby one site is reluctant to accept technologies developed by another site) at some DOE sites (D&D report, pg. 27~. 38

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ADDRESS CONSTRAINTS TO TECHNOLOGYIMPLEMENTATION 39 headquarters and OST to "push" use of innovative technologies (Subsurface report, p. 204~. One potential disincentive to the use of innovative technologies has been that rapid cleanup could lead to loss of revenue for the DOE site management contractor and loss of local jobs once the cleanup is completed and the site is closed (GAO, 1994~. Another barrier to deployment of innovative technologies is the potential liability to the user and embarrassment to DOE if the innovative technology were to fail (NRC, 1994, 1997b). Moreover, as new cleanup and waste management problems are found at the sites, new technology needs arise. This makes it difficult for OST to keep abreast of technology needs and to have its technologies accepted and deployed. Another problem relates to remediation contracts, which generally do not allow DOE to specify the technology to be used. In its review of OST's decontamination and decommissioning technology development program, the D&D Committee concluded that the Large Scale Demonstration Project (LSDP) was unable to overcome important institutional barriers to the deployment of new technologies (D&D report, p. 2~. OST and DOE-EM have initiated several efforts to address internal (to DOE) barriers to deployment. For example, in 1997 OST management initiated the Accelerated Site Technology Deployment (ASTD) program in which OST provides funding to a site for the first on-site deployment of a fully demonstrated technology if the site can show the potential for multiple uses of the technology in DOE-EM and an associated cost benefit. In 1997, OST received many more site proposals under these terms than could be funded (Decision Making report, p. 9~. Also in 1997, DOE-EM established an upper level management committee, the Technical Acceleration Committee (TAC), to help deploy technologies (Decision Making report, p. 26~. The Decision Making Committee found that the use of financial incentives such as those provided by the ASTD program were not desirable but appeared to be necessary at the time (Decision Making report, p. 74) The Decision Making Committee also recognized Cat the lack of strong incentives to deploy OST-developed technologies is largely out of OST's control, and recommended Cat DOE-EM seek ways to assist OST in getting its developed technologies deployed at We sites (Decision Making report, p. 74~. CONSTRAINTS EXTERNAL TO DOE Political Although other EM offices such as EM-30 and EM-40 are obvious users of OST technology developments, OST has other "customers" to satisfy. For example, the U.S. Congress must be satisfied that a reasonable fraction of OST

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40 TECHNOLOGIES FOR ENVIRONMENTAL MANAGEMENT products are useful and worth their cost. Furthermore, some OST expenditures are congressionally mandated. Consequently, the type and quality of the information provided to Congress (and to other interested review groups) is critically important to OST (Decision Making report, p. 3~. The Subsurface Contaminants Committee recognized that political pressures to meet federal and state groundwater and soil remediation requirements (e.g., at the Hanford Site) have created problems for DOE. In particular, DOE faces a major challenge in cleaning up large quantities of contaminated groundwater and soil with a suite of inadequate baseline technologies (Subsurface report, p. 248~. Regulatory The Subsurface Contaminants Committee noted that regulatory problems have interfered with deployment of innovative remediation technologies. The committee cited as especially problematic the slow, linear nature of the regulatory process and inconsistencies in the way the process has been applied from site to site. Such problems can delay selection of remediation technologies and can result in the use of outdated technologies chosen years before site cleanup begins. In addition, regulatory inconsistencies create uncertainties about whether a technology proven at one location will meet the regulatory requirements at another location, making contractors hesitant to take the risk of using an alternative technology (Subsurface report, p. 10~. For example, the committees identified differing approaches to waste management and disposal by the U.S. Environmental Protection Agency (EPA) for hazardous waste, the DOE for its own radioactive waste, and the U.S. Nuclear Regulatory Commission (USNRC) for commercial radioactive waste. EPA requires that all DOE mixed waste sites be designed to comply with RCRA. The Mixed Waste Committee criticized the approach recommended by EPA to determine toxicity, the Toxicity Characteristic Leaching Procedure (TCLP), because it requires grinding the material before a leach test, thereby destroying any protective coating put around the material by a treatment process. The report describes this test as bearing "little resemblance to the environmental conditions experienced by disposed waste" (Mixed Waste report, p. 72~. The committee reviewed the methods available to characterize the chemical and physical stability of waste forms for mixed waste and found that no test methods are accepted by the technical and regulatory authorities to demonstrate the long-term (greater than a few hundred years) behavior of a waste form in the disposal environment (Mixed Waste report, p. 80~. No waste form leachability criteria have been established for radioactive waste by either the DOE or the USNRC. As another example, EPA's facility design regulations are site independent

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ADDRESS CONSTRAINTS TO TECHNOLOGYIMPLEMENTATION 41 and hence cannot take into account the advantages one site may have over another. The EPA facility approval process does take into account site characteristics but not waste form. The USNRC performance objectives are for the entire disposal system and do include consideration of site and waste form characteristics (Mixed Waste report, p. 39~. In the area of containment, EPA requires containment for only 30 years after closure, whereas the USNRC recommends performance assessment for at least 1,000 years. Many hazardous components are either stable elements (e.g., Cd, Be, Ba, Pb, Sb) or very persistent organic constituents. The Mixed Waste Committee concluded that a major driver in technology selection and development by the MWFA has been EPA hazardous waste regulations, whereas other factors such as economics have received less attention (Mixed Waste report, p. 654. The committee recognized that technical issues pertaining to waste management are often overshadowed by nontechnical (e.g., political and social) issues (Mixed Waste report, p. 99~. Controlling regulations are complex, confusing, and subject to change and interpretations (Mixed Waste report, p. 4~. The OST's Technology Integration Systems Application (TISA) Domestic Program (formerly known as the Office of Technology Integration) is intended to facilitate knowledge, communication, and acceptance of new technology applied to DOE-EM problems among interested and affected parties (Decision Making report, p. 15~. OST investments in these activities show that attention to nontechnical barriers, such as regulatory acceptance of new technology ready for demonstration, has been a program priority, at least until the program's budget was cut in FY 1998 (Decision Making report, p. 150~. The Public Several of the reports observed that public concerns can be an obstacle to deployment of new technologies. For example, the Tanks Committee wrote that (Tanks report, pg. 5~: At present, many public stakeholders at Hanford apparently want DOE to follow the current compliance-driven Hanford baseline approach, and they view investment of significant resources in technology development for alternative scenarios as a diversion from that effort. Some stakeholders do apparently recognize that readjustments to the Hanford baseline may become necessary if a particular approach proves to be infeasible for whatever reason (whether technical, programmatic, economic, or political). However, stakeholders generally appear to prefer DOE to limit such

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42 TECHNOLOGIES FOR ENVIRONMENTAL MANAGEMENT ~nvestrnents. Nevertheless, more explicit consideration of alternatives as proposed herein and greater organizational commitment to a risk- based approach could make He overall DOE program more robust with respect to unexpected developments, as well as provide a more transparent rationale for a particular approach to eventually be adopted from among He candidate approaches. The Decision Making Committee also identified an unwillingness to jeopardize established agreements win interested and affected parties Concluding He public) as a barrier to innovative technology use (Decision Making report, p. 27~. CONCLUSION It is clear from the six reports reviewed for this synthesis, Hat merely identifying a promising technology will not lead to its implementation at DOE sites. Many over actions are necessary. Some can be done by OST itself, but most will require working with other elements in DOE. Some will also require DOE to work win over federal and state agencies. Because of the historical autonomy of DOE sites, there is no mechanusm to ensure implementation of successfully OST-developed technologies. As long as authority for technology deployment and responsibility for technology development continue to reside in different entities, centralized development of technologies to be deployed throughout He DOE complex will not, in the board's view, be effective. RECOMMENDATIONS Internal to DOE When contracts allow, agreements should be developed between the sites and OST that, if certain agreed-on conditions are met, then OST-sponsored technology will be implemented at the sisters). The sites and OST would agree on technical requirements (e.g., throughput and contamination reduction percentages of processing equipment), schedules (e.g., when testing of equipment or full scale operation will begin), and deployment costs. If these targets are met, then the sites would be required by DOE to deploy the technologies. If they are not met, the sites would be allowed to deploy any alternative that meets the targets, including those 36 Including economic as well as technological success.

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ADDRESS CONSTRAINTS TO TECHNOLOGYIMPLEMENTATION 43 developed independently of OST. (Some flexibility, however, would be necessary to accommodate changes in regulations or multiparty agreements.) If not allowed by current contracts, DOE should consider adding such provisions to future contracts. For current contracts, DOE should consider developing incentives to encourage use of OST-developed technologies, when these meet the above conditions. External to DOE . . . DOE-EM should work to promote consensus among EPA, USNRC, DOE, and the scientific community on waste form testing methods that will generally be acceptable for providing at least a qualitative evaluation of long-term waste performance in disposal environments (Mixed Waste report, p. 104~. DOE-EM should work with EPA and the USNRC to agree on clear guidelines that define acceptable waste forms for disposal of mixed waste in future near-surface disposal facilities (Mixed Waste report, p. 1051. The well-documented decisions and sound technical reviews recommended earlier in this report should be used by OST to earn the confidence of Congress and members of the public.