Paul L. Aamodt
LANL/SNL

Keith Kristofferson and Roy Mathews
INEEL

Jerome Gnoose
Fernanld

Robert Johnson
SRS

Mike Peters and Patrick Ervin
Rocky Flats

Larry Maassen
LANL

Warren Cox
SNL

Robert Dodge
NTS

Roy Sheely and Linda Kaiser
ORNL

Brad Schilperoort
Hanford

John Ahlquist
DOE

Beginning in the summer 1996, operating contractors from nine Department of Energy (DOE) installations began working together to integrate their waste treatment, storage and disposal (TSD) plans in order to maximize operational efficiencies throughout the DOE complex. This initiative was sanctioned by the DOE and conducted in support of the new Ten Year Plan (now EM Focus 2006 Plan) for Environmental Management Programs. One part of the contractor environmental management integration (EMI) initiative was to examine Environmental Restoration (ER)-generated waste streams, which included updating estimated waste volumes by waste type and form, integrating ER waste streams with the total DOE waste TSD plans, and identifying other opportunities for accelerating ER projects across the DOE complex without compromising worker and public health or the environment. This paper discusses the outcomes of the ER Integration Team effort, with special emphasis on the recommendations made to accelerate ER work and/or enhance operational efficiencies. Many of the ER Integration Team recommendations have been incorporated into the latest draft of the DOE’s EM Focus 2006 Plan released for public comment early this year.

In June, 1996, the Department of Energy sanctioned a contractor-led initiative to integrate waste management treatment, storage and disposal (TSD) functions for nine major DOE installations and the Waste Isolation Pilot Plant (WIPP). This initial integration effort was done as a pilot project to determine if complex-wide integration was a practical method to address DOE’s waste TSD and to establish that the benefits, as cost savings and schedule enhancements, would be sufficient to continue and expand the integration effort. Teams were designated to examine integration opportunities by the major waste types (e.g., low level radiological, transuranic, mixed, hazardous, etc.) with members from contractor staffs at each of the installations having such waste. The initial outcomes were very promising, and in October, 1996, a team was formed to work on integrating ER-generated wastes with the other legacy and programmatic waste streams. The ER Integration Team met several times over the course of the next year to evaluate the ER projects across the complex and to develop enhancement recommendations.

The initial workouts focused on developing updated waste information including volume estimates by major waste category, treatment plans, disposal plans, institutional responsibilities, generation schedules, and the set of assumptions used by each installation’s ER Project. This information was then used to develop lifecycle flow diagrams (disposition maps) for each installation’s ER-generated waste streams, similar to that illustrated for Sandia National Laboratories (SNL) in Figure 1. During this process missing information about the ER waste streams, such as source, type, media, quantities, generation plans, etc. was identified and documented (it should be noted that because much of the ER waste has yet to be fully characterized and generated, a significant uncertainty factor exists in most of the ER waste estimates). Existing and planned treatment and disposal facilities throughout the DOE complex and the commercial sector were evaluated with respect to accommodating the ER wastes given the generation schedules, waste types and quantities, treatment needs, and costs. The disposition maps for both the ER and WM wastes were compared to the available and planned TSD facilities to verify that all of the DOE TSD requirements would (or would not) be met when needed. The end result was a set of recommendations to the DOE for optimizing waste TSD functions and facilities across the complex, and the ER/ WM disposition maps. These results were documented in "A Contractor Report to the Department of Energy on Environmental Management Baseline Programs and Integration Opportunities (Discussion Draft)", May 1997. The results and recommendations have also been incorporated into the most recent draft of the EM Focus 2006 Plan. Updates to the ER waste estimates and disposition maps will be reflected in annual revisions of the EM Focus 2006 Plan.

While the development of the waste data updates and disposition maps was a primary part of the ER Integration Team efforts, the Team also examined a number of other potential opportunities for accelerating ER Projects across the DOE complex, for improving efficiencies, and for cost savings or cost avoidance. The approach taken was to evaluate each of the represented installations with respect to accelerated or optimized ER activities, select the elements from the successfully implemented efforts that could apply to all (or most) DOE ER Projects and incorporate them into the other projects as part of the EM Focus 2006 Plan. Most of the "share and adapt" elements were relatively non-controversial (i.e., the local regulatory authority and stakeholders would have few concerns about the use of certain accelerated approaches, such as the greater use of presumptive remedies, more voluntary corrective actions, or using a proven technology for on site soil/waste segregation). The ER Integration Team conducted fairly extensive benefit evaluations on three acceleration and/or optimization prospects that appeared to have good payoff potential, but which will require DOE support to be fully adopted across the complex. The resulting recommendations to DOE are discussed below.

The ER Team recommended that the DOE adopt uniform radiological cleanup standards. In the past, the determination of appropriate cleanup levels has been made through negotiations with regulatory authorities and the public on a site-by-site basis. Often the result is a very conservative level that, if achievable at all, requires great expense to obtain. The site-to-site variability associated with negotiated cleanup levels makes cost estimates uncertain and leaves the DOE vulnerable to future legal liability if the cleanup levels used are ever challenged. For instance, if installation A used a negotiated cleanup level having a dose of 30 milliroentgen(mr)/yr for the public and 100 mr/yr for workers and installation B used 15 mr/yr and 50 mr/yr for public and workers, respectively, the more conservative dose levels at Installation B could be cited as a precedent to force DOE to do more cleanup at Installation A, even if doing so resulted in no significant additional risk reduction.

The ER Integration Team evaluated two proposed US regulations (40CFR196 and 10CFR834) and the international standards generally accepted outside the US. The adoption of the dose standards in 10CFR834, with some modification to the "as low as reasonably achievable" (ALARA) language to account for future land use restrictions, could yield a potential "savings" of hundreds of millions of dollars. As an example of potential "savings", the Rocky Flats Plant negotiated higher dose levels (equivalent to about 25mr/yr unrestricted release and 80mr/yr with land use restrictions) with the local regulators and stakeholders (documented in the Rocky Flats Cleanup Agreement or RCRA) that resulted in $300M in cost avoidance (reduction from earlier cleanup estimates) for soil and debris clean up. If the higher standard were used for all nine installations, the potential additional cost "savings" were roughly estimated to be in the billions of dollars. Consequently, the ER Integration Team strongly recommended that the DOE adopt the international dose standards of 30 mr/yr for unrestricted public use and 100 mr/yr for workers where land use restrictions would control access and potential exposure. At the same time, the Team recommended that DOE work aggressively with the Environmental Protection Agency (EPA) and the Nuclear Regulatory Commission (NRC) to codify these dose rates as national standards.

The ER Integration Team also recommended that the DOE support full incorporation of proven accelerated ER processes/approaches throughout the complex. Several of the installations had implemented various acceleration processes with the agreement of their regulators/stakeholders, but two, Sandia and Los Alamos National Laboratories, had made sweeping changes that incorporated the following common elements:

• A focus on the end state, not the process
• Aggressive early involvement of all interested stakeholders (regulators, Tribal and local governments and the general public)
• Early stakeholder agreement on the desired end states
• Use of presumptive remedies (i.e. similar site types usually have similar solutions)
• Extensive use of voluntary corrective actions where the solution is obvious
• Elimination of unnecessary plans, reports, and associated reviews/approvals
• One-pass assessment and remediation (i.e. assess and remediate at the same time)
• Acceptance of greater programmatic risk (by the DOE and installation operator)
• Maximize agility and flexibility in implementing ER work
• Use innovative and flexible contracting
• Moving authority, responsibility and accountability to the lowest level

At Sandia, incorporation of the accelerated process resulted in an estimated lifecycle cost reduction of about $250M (~50% of the earlier estimate to completion) and a schedule reduction of 13 years (from 2014 to 2001). At Los Alamos, the cost estimate to completion was reduced from $3.2 B to about $1.0B with a schedule reduction of 12 years (from 2018 to 2006). These two examples serve to indicate the magnitude of reductions that are possible with full implementation of the accelerated ER processes. During the initial Ten Year Plan development, the DOE installations incorporated many acceleration elements and reduced the complex-wide ER lifecycle costs by more than $12B. The ER Integration Team was able to identify another $150M in potential savings/avoidance with just a limited assessment of the participating ER projects.

Another Team recommendation to DOE was for the establishment of a means to share expertise and resources among the DOE installations. The DOE installations are (by design) dispersed across the US, and this has resulted in each site developing its own pools of expertise on ER issues as well as individual processes for purchasing and contracting for equipment and services. The value of these resources could often be increased if they were available to others in the DOE complex who have similar needs. For instance, a mobile treatment system purchased for use at Rocky Flats could later be moved to Hanford or another installation, thus saving the cost of purchasing or leasing another unit. This is especially significant for excavation and treatment equipment that becomes slightly contaminated but is still in good condition. Reuse at other sites, provided worker exposure is within acceptable levels, is a better option than purchasing another unit which itself might become too contaminated to return to the public sector. In the case of expertise, the sharing of knowledge, lessons-learned and technologies, if made more readily accessible, could help to reduce "learning curve" or "reinventing the wheel" kinds of costs. The ER Integration Team’s recommendation is for the DOE to establish a web-based clearinghouse for equipment and expertise that could be used by the installations to identify and access such resources. In addition, workshops to share experiences, successes, and lessons-learned are recommended on a once or twice-a-year basis. The regulatory nature of ER activities makes knowledge of successes and failures, as precedents, potentially very important for achieving higher efficiencies based on acceptability and reasonableness. The ultra-conservative approaches used previously to plan and implement ER work will simply not work to achieve the EM Focus 2006 Plan goals.

Finally, the EM Integration Team examined technology development needs with a view of practical attainment both within the year 2006 window, and for the longer term. Only two major near-term needs were identified:

• Large volume water treatment for radiological (tritium) and hazardous waste (TCE) contaminants
• A submersible, near-real-time tritium detector for monitoring surface or groundwater.

While other developing technologies could have a positive impact on the ER Program prior to 2006, the above are considered to be critical to the success of several ER Projects. Otherwise, it was agreed that existing technologies are adequate, though not necessarily optimal, for the achievement of the desired ER Project end states at the nine installations. Moreover, the ER Integration Team recommended that DOE consider reconfiguring the organizational responsibilities for technology development so that technologies needed by 2006 are developed directly by the DOE EM user organizations (Waste Management, Decommissioning, or ER) and that technologies needed in the longer term (post 2006) are developed by the EM Technology Development Organization (EM-50). The Team believes that such a change would help to ensure that the limited technology development resources are most effectively applied to near-term customer needs.

The ER Integration Team also examined barriers that would have to be overcome in order to achieve the benefits from using uniform radiological cleanup standards, implementing accelerated ER processes, and sharing more readily ER expertise and resources. In each case, the assessment was made relative to the current, or status quo, baseline conditions. The results are summarized in Fig. 2.

While the ER Integration Team agrees that these recommendations are both reasonable and responsible (i.e., their adoption will not compromise workers, the public or the environment, and will save significant taxpayer dollars), they are aware that implementation will be very difficult given existing agreements that would have to be changed, perceptions that would have to be overcome, and the culture of risk avoidance that exists throughout DOE and its contractors. Despite this, and to not eliminate any hope of achieving the goals in the EM Focus 2006 Plan, these and similar actions will need to be taken. The DOE, as the responsible federal agency, must take the lead role in overcoming barriers to a more efficient and effective ER Program.

The ER Integration Team, composed of contractor staff from nine DOE installations and DOE HQ, recommended the adoption of waste management integration of TSD functions for ER waste streams, as applicable. The team also recommended that DOE adopt uniform radiological cleanup standards, based on dose to workers and the public more consistent with the international standards (i.e., 30 mr/yr dose unrestricted land use and 100 mr/yr dose for land subject to use/access controls) and with reasonable application of ALARA principles. The Team recommended the complex-wide adoption of proven approaches to accelerate ER work by eliminating unnecessary plans, reports, reviews and approvals, and similar non-value added processes, using presumptive remedies and combining characterization and remediation, where appropriate, adopting complex-wide risk-based cleanup standards, and generally becoming less conservative or risk adverse while planning and implementing ER work. The ER Team recommended the establishment of a national data base (web site) to facilitate sharing of staff expertise and equipment resources. Finally, the Team recommended that DOE relocate technology development resources and responsibilities for near-term needs (to year 2006) to the DOE EM user organizations and keep only the long-term needs under the purview of the existing technology development organization (EM-50).

The evaluations of benefits to be derived if the ER Integration Team recommendations are fully adopted show that potentially hundreds of millions of dollars and many years could be eliminated from the current ER Planning base. However, there are significant barriers that will need to be overcome by DOE in order to achieve these benefits and to bring reasonableness and desired efficiencies to EM Programs.

This work was conducted as part of the contractor Environmental Management Integration initiative.

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