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5 PLANNING THE D&D PROGRAM
Pages 103-126

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From page 103...
... 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, 19951. 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.
From page 104...
... 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.
From page 105...
... For each site, stakeholder involvement could be managed through an SSAB or similar format; for the complex as a whole, a steering pane} should be formed. The steering pane} would provide program-level advice to DOE management on the conduct of the D&D efforts at the three GDP sites.
From page 106...
... . migration Asbestos and materials contaminated with PCBs left in place PCB-contaminated bulk fluids removed Equipment and buildings dismantled and demolished Contaminated equipment and structures buried in an on-site facility Contaminated equipment removed and buildings remain Loose contamination removed or fixed in place Buildings reused for alternative activities, such as waste storage Contaminated equipment removed and buildings remain Buildings decontaminated Buildings released to the public for unrestricted use or abandoned and allowed to degrade over time 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
From page 107...
... 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)
From page 108...
... 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.
From page 109...
... 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.
From page 110...
... 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. OSLO Traditionally DOE facilities have also been exempt from the Occupational Safety and Health Act and OSHA regulation under the Atomic Energy Act.
From page 111...
... 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~.
From page 112...
... 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 fixture use scenarios should be used to determine site-specific exposure limits appropriate to the GDP sites.
From page 113...
... 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.
From page 114...
... (See Chapter 6 for further discussion of costs of safeguards and security.) COORDINATED PLANNING DOE has treated the three GDP sites separately for D&D planning, although the cost estimates all derive from a site planning exercise for the Oak Ridge GDP.
From page 115...
... the 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. The complex-level plan should be modular and flexible to facilitate changes and incorporation of experience during D&D and should be organized to readily permit changes In performance period, funding assumptions, and introduction of new D&D technology.
From page 116...
... 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, endstate decisions, availability of waste facilities, and the public's views.
From page 117...
... Site-Leve} 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.
From page 118...
... 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.
From page 119...
... Elects 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.
From page 120...
... 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.
From page 121...
... 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.
From page 122...
... Develop creative mechanisms and models for regulatory coordination between DOE and appropriate federal and state regulators. Work with regulators to couple regulatory requirements to the D&D schedule.
From page 123...
... 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 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.
From page 124...
... 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.
From page 125...
... Golden, Colorado: Colorado Center for Environmental Management. Confederated Tribes of the Umatilla Indian Reservation.
From page 126...
... 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.


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