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2 Admistrative Opportunities
Pages 19-27

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From page 19...
... The committee believes that the ability to resolve these obstacles lies within the administrative authority of DOE and EM.i By identifying these barriers and self-imposed requirements, this report may provide impetus for positive changes that can significantly accelerate the cleanup program. Recommendation: EM headquarters and sites should aggressively pursue opportumt~es to simplify and expedite waste characterization, treatment, and disposal by · workmg with the responsible classification offices to declassify to the extent possible, classified materials declared as wastes, IThe committee did not teview DOE's legally binding commitments, e.g., Han old TtiPatty Ag cement, Waste isolation Pilot Plant permit.
From page 20...
... Classified equipment at the Paducah, Kentucky, and Portsmouth, Ohio, gaseous diffusion plants is likely to pose similar removal and disposal challenges in the future. While gaseous diffusion equipment appears to be a primary example of how security classification costs time and money in EM's cleanup activities, the committee expects that there are other examples that were not discussed in its open meetings.
From page 21...
... Photo courtesy of Oak Ridge Operations Office. edge and technology have evolved greatly since the Manhattan Project and the onset of the Cold War, which has likely rendered the bases for classifying these materials obsolete.
From page 22...
... Long-term remedial response actions that permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances that are serious, but not immediately life threatening. Currently most EM site cleanups are conducted as long-term remedial response actions, which require a much more extensive amount of planning and paperwork than removal actions.
From page 23...
... initiative on fast-track cleanup of its closure sites, which strives for expedited cleanup and reuse of property, closely parallels DOE's accelerated cleanup program. A fact sheet from DOD's Office of the Deputy Undersecretary for Environmental Security suggests the use of removal authority for DOD closure sites and gives a step-by-step description of how to conduct a removal action.3 The use of the removal actions option under CERCLA by DOE may be constrained by the agreements it has made with the EPA and /or the states.4 There are no clear lines as to what response actions should be removal or remedial.
From page 24...
... REMOVAL OF MUNITIONS AT INEEL During its visit to INEEL, the committee learned that EM resources are being used for clearing military munitions remaining on parts of the site used as a firing range for testing large naval guns and other weapons. While it is clear that some unexploded ordnance may present a danger to site cleanup operations and thus require the immediate attention of EM, it appears that EM has an opportunity to better engage DOD in removing these munitions.
From page 25...
... Site presentations and tours of waste characterization facilities at SRS, Hanford, and INEEL led the committee to the same conclusions presented in the previous study. Following the previous study's recommendations, the DOE Carlsbad Field Of rice applied to the New Mexico Environment Department (NMED)
From page 26...
... , so each site is making assumptions regarding how to characterize, treat, and package wastes and even which wastes will be accepted. Although the WAC will not be finalized until the site is licensed, the sites, EM, and the DOE Office of Civilian Radioactive Waste Management, which has overall responsibility for the proposed repository, and the Nuclear Regulatory Commission, which must approve DOE's license application, need to agree on a consistent approach to preparing wastes for disposal in that facility, with one of rice having oversight authority.
From page 27...
... Other examples include removing railroad track at Hanford, the unused cooling tower built for the K-Reactor at SRS, and numerous office buildings throughout the complex. The 1995 DOE-EPA policy on decommissioning (Herman et al., 1995)


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