2003 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: 17 Jan 2003 19:16:34 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] Risk-Based End State policy at Energy Department
The Office of Environmental Management at the U.S. Department of Energy
has been privately circulating drafts of two documents, a Policy and a
Guidance, designed to change the way the Department meets its cleanup
obligations. On the surface, some of the concepts in these documents
sound good. In practice, however, implementation could mean the
large-scale adoption of containment remedies at locations where
treatment or removal might better protect public health and the environment.

The Policy, "Cleanup Driven by Risk Based End States," explains, "The
single most significant change that we can make is to focus the program
on goals that are clearly articulated and technically defensible and
achievable. Those goals must be grounded in where we want to be at the
end of the cleanup effort, and not on interim milestones or conditions
that are continually subject to change."

The Policy continues, "When the drive to achieve risk-based end states
characterizes the Department's site assessment, remedy selection and
actions to assure long-term protectiveness, the cleanup program will
complete its work quicker, safer and more efficiently.... The approach
may cause a re-evaluation of, and changes to, current regulatory
agreements/documents (such as Federal Facility Agreements) and
compliance agreements."

The documents call for the development of a "risk-based end state
vision," in consultation with regulators, Tribal Nations, and other
stakeholders. Then site officials are to "redesign their cleanup
activities to achieve that vision." The Policy compares the new
initiative to other efforts such as Risk-Based Corrective Action,
Brownfields, and U.S. EPA's One Cleanup Program Initiative.


I have long believed that federal cleanup programs that move from
documentary milestone to documentary milestone fail to see the forest
for the trees. As some in the Air Force suggest, it makes sense to
"begin with the end in mind."

But massive, complex, and secretive nuclear weapons plants are not ideal
candidates for risk-based cleanup. They are not like gas stations,
plating shops, or drum collection sites.

Remedies that focus on interrupting pathways tend to be successful where
the risk is minor in the first place, migration is unlikely, or the
hazard can be expected to attenuate on its own. At major nuclear weapons
facilities, however, long-lived radionuclides, massive solvent plumes,
and unknown or unusual contaminants are likely to remain in place for a
very long time. Remedies that contain contaminants, stabilize them, or
interrupt pathways may in places be unavoidable, but in general they
will be continuously at risk of catastrophic breakdown.

The Energy Department Policy barely recognizes this challenge: "When
contaminants are expected to persist but can be isolated, risk concepts
should include effective and transparent institutional controls to
maintain isolation. Long term monitoring and surveillance methods must
be designed to assure that the contaminants remain sequestered and human
health and the environment are protected."

Long-term monitoring is essential, to be sure, but monitoring can only
predict or discover the breakdown of remedies. The Energy Department
must continue to explore better ways to treat and control contamination
to minimize the chance of failure. Over the life of its contaminants,
people and ecosystems are likely to be exposed, so remedies should deal
with the hazards, not just the pathways. Even in areas declared
"national sacrifice zones" because there is apparently no way to
eliminate the hazards, active cleanup should continue.

Developing cleanup strategies based upon an end-state vision is a good
idea, as long as that vision is not based upon ignoring serious,
persistent hazards because there is no significant immediate risk.


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918

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