Improving the Environment An Evaluation of the DOE's Environmental Management Program (1995) / Chapter Skim
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Part 1: Synthesis Report
Part 1: Synthesis Report
Pages 1-26
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Part ~ Synthesis Report
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CAPUTO, Attorney, Natural Resources Defense Council EDWIN H CLARK, President, Clean Sites, Inc.
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In response to the request, the National Research Council of the Academy established the Committee to Evaluate the Science, Engineering, and Health Basis of the Department of Energy's Environmental Management Program. Four subcommittees were formed to address topics outlined in Mr.
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. According to the estimates of the total cost, 49% would go to waste management, 28% to environmental restoration, 10% to nuclear material and facility stabilization, and 5% to technology development with the remaining 8% for activities such as site security, transportation, and other landlord activities.
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The Environmental Management Program has six goals which have been established by Assistant Secretary Grumbly: · To eliminate and manage urgent risks in the system. · To emphasize the health and safety of workers and the public.
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Some contaminants have moved offsite (such as plutonium-contaminated soil at Rocky Flats) or are in the process of moving offsite (such as contaminated groundwater at Hanford moving toward the Columbia River)
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The Department spends more resources on its Environmental Management Program than on any other activity, and environmental management is often described as one of the Department's central missions. However, the Department should view its remedial activities as industry does, not as a central mission, but rather as a job that must be completed so that the Department can return to its more basic missions.
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The Congress has allocated $50 million of the Environmental Management Program funding for this effort. Such collaboration is the kind of integration recommended in all the subcommittees' reports.
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Current efforts to integrate options to reduce the cost of maintaining sites and facilities in a safe status while awaiting remediation, which will necessarily incorporate cost-benefit analysis, will further strengthen the analytical basis of Environmental Management' s budgeting process. Environmental Management has correctly recognized that without stakeholder acceptance and consensus on both the process and the outcomes, improved analytical techniques and better factual information will be of less value (although such techniques and information can serve to inform the stakeholders in those decisions)
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For some it is meeting milestones in compliance agreements and for others it means remediating contaminated soil, groundwater, and buildings, even when the process chosen may take decades and many billions of dollars to complete regardless of what compliance agreement milestones may require. This committee believes getting on with We task, whichever definition one uses, will be accomplished most effectively by implementing a process for decision-making and accountability that includes · Having a more specific set of goals for the program (see also pp.
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In the absence of permanent solutions, responsible stewardship allows progress to be made by providing adequate protection against environmental and human health risks that are serious and long-lived (see also pp.
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The record of decision selecting the remedy should incorporate specific commitments by the Department designed to maintain the necessary institutional controls over the lifetime of the contamination. Where contaminants are so long-lived that such commitments are impossible, the remedy should include specific procedures designed to reassess at regular intervals the adequacy of the institutional
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An effort to improve incentives, metrics and accountability for federal employees and contractors would be the most effective way to improve the performance of the Environmental Management Program in meeting its goals, lowering its costs, and improving its safety in the shortterm (see also pp.
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It is too early to tell who is correct and if the marketplace will finance private companies to undertake tasks such as the vitrification of wastes at Hanford. If the opposition to new approaches such as privatization is based on the pursuit of unstated goals like providing continued employment and funding for a site, mechanisms should be found to create incentives for states and other stakeholders to willingly participate in these new management approaches.
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1441. In industry, input by a multifunctional team consisting of a technical project leader, a lawyer, a finance manager, a corporate researcher, and government-relations, real-estate, and construction people starts at the beginning of a project and can continue through completion; the leadership of the team changes as needs change (see also p.
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Is Environmental Management going to have a comprehensive technology development program to reduce costs for waste management and environmental restoration activities? Goals are usually set after a dialogue between senior managers of an Agency who have helped formulate the vision and these within the agency who will have direct operational responsibility for accomplishing the goals.
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The presumption is that stakeholders will be receptive to such limitations and act on behalf of He national good. Need for More-Specific Goals The Environmental Management Program appears to understand its mission, and this is becoming apparent to the outside world.
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However, as further information is developed it may be that some of the goals are unattainable at a cost, risk, or social impact that society is willing to tolerate. Some goals of the Environmental Management Program are unstated and sometimes conflict with stated goals.
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· Coherence throughout the Department's complex. The priority-setting system must be coherent by being functional across the various Department sites and throughout the various elements of the Environmental Management Program.
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They help to determine priorities for site cleanup by providing a basis for sound risk assessments and provide the tools for reaching remediation goals and priorities and ensuring that actions of the Department are the best that can be done. For environmental management problems that lack good solutions, Environmental Management needs an effective way to bring Department and other scientific and technical resources to bear.
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National Laboratories constitute an extraordinary technical resource both in capability and in size. It must be recognized, however, that the Laboratories are unique in culture and expertise (especially with nuclear materials)
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Overcoming Regulatory "Obstacles"—Using Existing Flexibility In a number of instances in which the Department and its contractors cite regulatory restrictions as prohibiting common sense and safe solutions to their problems, there is usually some form of regulatory flexibility that has not been applied. The Department should increase the use of the flexibility that is available in the regulations (see also pp.
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47~. A number of potential problems are caused when the authorities of multiple regulators, such as states, the Defense Nuclear Facilities Safety Board, and the Environmental Protection Agency (and sometimes the Department)
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Whether the issue is the decision process for technology selection or the performance of a risk assessment for remedialaction options, involving stakeholders is crucial for creating workable consensus. The Department operates in a political environment in which citizen support is essential to avoid costly and protracted litigation or similar consequences.
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1995c. Environmental Management 1995: Progress and Plans of the Environmental Management Program.
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