Risk and Decisions About Disposition of Transuranic and High-Level Radioactive Waste (2005) / Chapter Skim
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Appendix B Summary of Previous Studies and Programs Aimed at Incorporating Risk into DOE Environmental Management Decision Making
Appendix B Summary of Previous Studies and Programs Aimed at Incorporating Risk into DOE Environmental Management Decision Making
Pages 171-198
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From page 171... ...
The POS suggestions for radical changes to the allocation of funds across the complex had little impact on fund allocations, but DOE headquarters supported the system because it provided them with detailed documentation regarding cleanup problems at the field offices (Jenni et al., 1995)
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. Creation of the Environmental Management Program The House Armed Services Committee's Subcommittee on Procurement and Military Nuclear Systems held a hearing in February 1989 on the priority-setting process used by DOE in conducting environmental restoration activities at its nuclear weapons facilities.
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The letter report states that DOE plans for a National Priority System to provide the basis for subsequent resource allocations could serve as a demonstration of DOE's new openness by involving stakeholders in its development. The letter report emphasizes that the National Priority System will be useful only if it is developed through a credible process and recommends that DOE put in place a broadly supported allocation system negotiated among DOE, regulators, the states, American Indian nations, local governments, and interest groups during the program start-up, rather than later, when it may no longer be possible.
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From page 174... ...
It also recommended that consistent risk assessment methodologies be used to bring scientific information into decisions regarding the extent of cleanup, cleanup methodologies, and priorities for environmental restoration. The committee noted that in order to ensure public acceptance of its cleanup decisions, DOE had to significantly increase public and state involvement in activities related to environmental issues at the sites (NRC, 1989b)
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From page 175... ...
The Steering Group determined that effective risk management requires both scientific risk assessment and responsive consideration to public risk perceptions. It also concluded that the following are areas for additional effort in risk analysis: developing methods to reduce uncertainties in risk analysis; determining how quantitative data collected are used in decision making, such as whether risk managers should consider cost-benefit analyses in their decisions; and most importantly, making sure that decision makers and the public are able to comprehend the meaning of risk information communicated to them (Hunter et al., 1994)
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From page 176... ...
and although there was not enough information to make a credible evaluation of the system as an objective ranking of sites for remediation, the committee noted that such a model would greatly assist in addressing conflicts by providing a more objective evaluation of the sites that should be cleaned up first and the degree of cleanup desired. The committee noted, as had others, that DOE had many preexisting compliance agreements that would override the relative evaluations of sites provided by the priority system.
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From page 177... ...
It noted that relative risks will have a bearing on the setting of priorities for cleanup activities but should not become the de facto priorities. The FFERDC supported the use of "risk plus other factors," in which risk to human health and the environment and other factors2 are carefully considered in advance of the need to make priority 2 Cultural, social, and economic factors, including environmental justice considerations; potential or future land use; ecological impacts of contamination and the proposed action to address it; regulator, American Indian nations, and other stakeholder acceptance of actions; statutory requirements and legal agreements; life-cycle costs; taking into consideration the ability to execute cleanup projects in a given year and the feasibility of carrying out the activity in relation to other
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From page 178... ...
In 1993, a report documenting the results of a pilot study involving the Savannah River Site, Fernald Environmental Management Project, and Nevada Test Site was released. The report focused on lessons learned in human health risk assessments and was meant to demonstrate realistic risk assessments; produce estimates for the problems studied; and provide suggestions for changing the way in which risk assessments were conducted at DOE facilities.
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From page 179... ...
a national stakeholder oversight board with representatives from various groups; and, (2) a national scientific board that could help to maintain consistently high standards in risk assessment by reviewing drafts of risk assessments, providing broad advice about methodological consistency, and helping to ensure national consistency in the plans (NRC, 1994c)
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interim report to DOE entitled Health and Ecological Risks at the U.S. Department of Energy's Nuclear Weapons Complex: A Qualita
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issued a report for DOE entitled Scoping Report: Nuclear Risks in Tribal Communities to "advocate reform of current risk assessment practice in order to make risk assessment a more effective tool for public policy and environmental management decision making" (CTUIR, 1995, p.
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Additionally, by not including meaningful involvement by American Indian nations or other members of the public throughout the evaluation process, there was an overdependence on risk experts and their values and judgments, rather than creating a balance by directly including affected communities (CTUIR, 1995)
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DOE found that it is difficult to integrate risk assessment methods and cultural and social values to produce meaningful priorities. The report stated that this is particularly true for American Indian nations and for minority and low-income populations affected by DOE activities.
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The Risk Committee stated that the CERE interim report provided an extensive baseline collection and summary of more than 1600 publicly available risk documents for 6 of the 17 DOE sites. However, the report did not provide answers -- nor did it claim to -- about the real issues that the EM program had to address in order to arrive at credible and cost-effective decision-making choices.
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. 1995-1997 RISK DATA SHEET SCORING SYSTEM The Risk Data Sheet scoring system was initially developed for the risk report to Congress as a priority-setting tool for using risk information in making management decisions.
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. NRC REPORT EVALUATING DOE'S ENVIRONMENTAL MANAGEMENT PROGRAM On January 11, 1995, Assistant Secretary Grumbly requested assistance from the NRC in addressing remedial action and waste management problems throughout the nuclear weapons complex.
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From page 187... ...
in setting priorities for environmental management activities, noting that the two criteria that would probably retain preeminence in any prioritysetting system are risk and regulatory considerations. The NRC committee stated that true priority-setting techniques provide enough information to assess whether to take action and what types of action to take.
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. 1997-1998 HUMAN HEALTH RISK COMPARISONS FOR ENVIRONMENTAL MANAGEMENT BASELINE PROGRAMS AND INTEGRATION OPPORTUNITIES In May 1997, a contractor team issued a report on its analysis of the complex-wide baseline programs and alternatives.
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. 1997 CRESP REVIEW OF DOE-EM RISK INFORMATION In 1997, Assistant Secretary Alm endorsed two meetings convened by CRESP to discuss how to improve the content and format of the risk elements in DOE's risk database.
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stated that the Project Baseline Summary program failed because DOE did not have a clear basis for understanding or classifying risks, there were inconsistencies in implementation, assessments were inadequate and not well documented, and the summaries were not accepted by field offices. As defined in the national 2006 cleanup plan, the risk assessments did not require adequate evaluation of the exposure receptors of concern or of the toxicity of constituents of concern, which are of fundamental importance to any risk characterization.
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From page 191... ...
. The CRESP review committee reported that the risk profiles were presented in a 1999 draft report entitled Results and Status of Environmental Management Site Risk Profiles: Public Hazard Management at Ten DOE Field Offices (CRE, 1999, cited in CRESP, 1999)
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. 1998 DOE GUIDELINES FOR RISK-BASED PRIORITIZATION OF DOE ACTIVITIES These guidelines were issued as a Defense Programs standard approved for use by all DOE "components" (offices and programs)
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. 1998 OUTCOME-ORIENTED RISK PLANNING Supported by the EM Office of Science and Risk Policy, the Joint Institute for Energy and Environment (JIEE)
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. 1999-2000 INTEGRATOR OPERABLE UNIT AND COMPOSITE ANALYSES The 1999 CRESP review committee observed a gap between DOE Environmental Management activities that are necessary to comply with various environmental statutes and regulations and those generated by a risk evaluation across the complex.
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cleanup work should be prioritized to achieve the greatest risk reduction at an accelerated rate; (2) realistic approaches to cleanup and waste management should be based on technical risk evaluation, with consideration given to anticipated future land uses, points of compliance, and points of evaluation; (3)
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; (3) risk balancing should occur among DOE facilities to address environmental management in a consistent pattern (understand risks before making budget decisions; consider sitewide tradeoffs, and include the participation of American Indian and local government officials, regulators, and other stakeholders)
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Use the end states as the basis for exposure scenarios developed in the baseline risk assessments that help establish acceptable exposure levels for developing remediation alternatives. Cleanup strategies and decision documents should include risk reduction measures, life-cycle costs, uncertainties, and other relevant policy factors.
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There appeared to be confusion and misinterpretation of the intent of the guidance. Therefore, the guidance clarification document explained that the RBES vision documents were intended as a means for sites to communicate to readers the current state of cleanup progress at the site and alternative end states.
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