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Appendix C

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BASELINE REPORT METHODOLOGY

Table of Contents

C.0 Introduction

C.1 Defining the Study

C.1.3 Developing Categories for Personnel Requirements

C.2 Gathering and Assembling Data

C.2.1 Gathering Data

C.2.1.1 Environmental Restoration Activities
C.2.1.2 Nuclear Material and Facility Stabilization Activities
C.2.1.3 Waste Management Activities
C.2.1.4 Science and Technology Activities
C.2.1.5 Landlord Activities
C.2.1.6 National Program Planning and Management Activities
C.2.1.7 Support Activities

C.2.2 Assembling the Data

C.2.3 Verifying and Documenting Data

C.3 Integration Analyses

C.3.1 Base Case Scenario

C.3.1.1 Performing the Integration
C.3.1.2 Documentation

C.3.2 Alternative Scenarios

C.3.2.1 General Approach
C.3.2.2 Land Use
C.3.2.3 Program and Project Scheduling
C.3.2.4 Minimal Action

C.3.3 Risk

C.4 Estimating Program Improvements

C.4.1 Technology Development
C.4.2 Pollution Prevention
C.4.3 Productivity

C.5 Developing Documentation

C.6 Stakeholder Involvement

C.7 Base Case Uncertainty Analysis

C.0 INTRODUCTION

This appendix presents the methodology used to develop the cost and schedule estimates for the 1996 Baseline Environment Management Report. The Department of Energy used a five-step process to build on and enhance the approaches and tools used to develop the 1995 Baseline Environment Management Report (Table C-1). The purpose was to improve the basis for the cost and schedule estimates, increase the involvement of personnel at the individual field sites in data analysis, increase stakeholder involvement, and improve the consistency between the 1996 Baseline Environment Management Report and other program planning initiatives. All of the Base Case data, including the final integrated cost and schedule estimates, were either provided directly from the individual sites or reviewed by the sites prior to inclusion in the 1996 report. This allowed the field personnel, who know their individual sites best and have experience with their respective regulators and stakeholders, to ensure that the cost and schedule data are complete and reflect the most current understanding of how the Environmental Management program is likely to unfold at each site. Each of the steps in the general methodology is described in a separate subsection below. This appendix concludes with the methodology for the uncertainty analysis for the Base Case.

Table C-1. Steps in the General Methodology

Define the Study - Establish the scope, framework, and general assumptions for the estimates; seek input from stakeholders

Gather and Assemble Data - Collect, verify, and document cost, waste volume, and schedule data

Perform Site-and Complex-Wide Integration - Ensure that costs remain within assumed funding limits and account for all waste transfers

Estimate Program Improvements - Evaluate the impacts of technology development, pollution prevention, and productivity improvements

Develop Documentation - Prepare the 1996 report

C.1 DEFINING THE STUDY

Assumptions are developed at three levels: general assumptions to guide the development of the 1996 report, national assumptions to be applied uniformly across all of the Department of Energy sites, and site-specific assumptions.

C.1.1 Setting Assumptions

General assumptions - Five overarching, general assumptions guide the development of the 1996 report (Table C-2). These assumptions are identical to those used to develop the 1995 Baseline Environmental Management Report. The primary assumption is that all Department of Energy activities will be in full compliance with all legal agreements (e.g., compliance agreements, consent orders) and all applicable federal, state, and local laws and regulations. For example, cost estimates must assume that remedial technologies will be designed to meet all applicable or relevant and appropriate regulations and will comply with all worker safety regulations.

Table C-2. General Assumptions for the Baseline Environmental Management Report

Legal Requirements - all Department of Energy actions will be consistent with existing legal agreements and will comply with existing laws and regulations.

Ongoing Decision Processes - all cost and schedule estimates will be as consistent as possible with the status of ongoing negotiations, decisionmaking processes, and related studies as of October 1995.

Funding Limits - all cost and schedule estimates will assume a minimum funding level consistent with meeting the milestones in existing compliance agreements. Assumed funding beyond the year 2000 will be "capped" at each site's FY 2000 estimate of compliance funding unless cost increases are dictated by existing compliance agreements.

Local Visions of the Future - all cost and schedule estimates will reflect, to the extent possible, each site's own views of its likely future.

Estimates, not Decisions - the cost and schedule figures are only estimates and not presumptions of future decisions the Department has yet to make.

The second general assumption is that all cost and schedule estimates will be as consistent as possible with the status of ongoing decisionmaking processes as of October 1995. The Department currently is engaged in a number of negotiations, discussions, and studies in support of key decisions such as:

  • Federal Facility Compliance Act negotiations to determine the locations of future mixed low-level waste management facilities;
  • The Future Use Project aimed at determining local stakeholders' preferred future land uses for Department of Energy sites; and
  • Studies leading to National Environmental Policy Act documentation such as the Waste Management Programmatic Environmental Impact Statement and site-specific environmental impact statements.

The Baseline Environmental Management Report should reflect the key policy decisions reached through these democratic processes. However, many of these processes will not achieve final decisions for several months or years, and their directions are expected to change any number of times as these processes evolve. As a consequence, the specific assumptions used to develop cost and schedule estimates for the 1996 report (e.g., future land use and missions at each site) reflect the state of these processes "frozen" as of October 1995. Therefore, it is likely that the 1996 report will rapidly become out of date with respect to the current state of these processes.

The third general assumption is that all cost and schedule estimates will assume a minimum funding level consistent with meeting the milestones in existing compliance agreements. Because the milestones in most compliance agreements do not extend beyond the year 2000, assumed funding beyond that year will be "capped" at each site's FY 2000 estimate of compliance funding. Annual site costs beyond FY 2000 will not be permitted to exceed the funding cap unless these cost increases are dictated by existing compliance agreements.

The fourth general assumption is that the assumptions used to develop cost and schedule estimates for the 1996 report will reflect each site's vision of the future. The inherent uncertainties associated with predicting activities several decades into the future make it difficult to estimate accurately the total life-cycle cost and schedule for the Environmental Management program. The best current understanding of potential future developments at each site is likely to be held by those individuals that live and work at or nearby these facilities.

The final general assumption is that the 1996 report is not a decision document. The Department recognized that the cost and schedule estimates in the 1996 report could be interpreted as final decisions. However, the assumptions used to develop the 1996 report, and the cost and schedule estimates resulting from implementing these assumptions, are developed solely to meet the Congressional mandates for the 1996 report, except where these assumptions, costs, and schedules reflect conditions set forth in Records of Decision, compliance agreements, and other legal agreements. Assumptions and cost and schedule estimates are expected to change in future reports as new information becomes available and ongoing decisionmaking processes evolve.

National assumptions - Certain assumptions were applied uniformly across all of the Department of Energy sites. These assumptions dealt with issues such as projected funding levels; where treatment, storage, and disposal of low-level mixed waste, low-level waste, and transuranic waste would occur; and when a geologic repository and the Waste Isolation Pilot Plant are expected to accept waste for disposal. Most of the national assumptions were developed at Headquarters based on the current status of ongoing decision processes (e.g., negotiations with states under the Federal Facility Compliance Act), current Environmental Management program plans, and discussions with the Office of Management and Budget. Each site reviewed the national assumptions and applied them as appropriate to their sites.

Site-specific assumptions - Personnel at each site provided specific assumptions regarding how the Environmental Management program is likely to unfold at the site. These assumptions dealt with issues such as expected future land use and the likely types of remedial technologies to be used for particular problems. Headquarters personnel reviewed the site-specific assumptions and modified them as necessary. Site-specific assumptions are listed in the individual site summaries presented in Volumes II and III of the 1996 report.

C.1.2 Defining Activities and Projects for Environmental Management Program Functional Elements

The FY 1995 National Defense Authorization Act requires the Department to provide a description of each project and activity to be performed by the Environmental Management program. The format used this year is similar to that used for the 1995 Baseline Environmental Management Report. Information is organized according to activities and projects for each Environmental Management program element. In this year's report, some terminology and categories differ and greater emphasis was placed on linking cost and schedule estimates to specific, discrete projects at each site.

C.1.2.1 GENERAL DEFINITIONS AND CRITERIA

Activities - Activities represent the general sets of actions required to remediate contaminated areas, disposition special nuclear material and contaminated facilities, manage waste, maintain federal lands and facilities, and manage the Environmental Management program. Table C-3 lists the general types of activities being conducted by the six functional elements of the Environmental Management program. The following subsections define and describe each of these activities. Each individual site has provided an estimate of the cost and schedule for, and a written description of the scope of work included in each activity. The individual site summaries presented in Volumes II and III of the 1996 report provide these estimates and descriptions.

Table C-3. Program Elements and Activities

Environmental Restoration
Assessment
Remedial Actions
Facility Decommissioning
Long-Term Surveillance and Monitoring
Nuclear Material and Facility Stabilization
Surveillance and Maintenance
Pre-Stabilization
Post-Stabilization
Post-Deactivation
Nuclear Material Stabilization
Facility Deactivation
Waste Management
Waste Treatment
Waste Storage
Waste Disposal
Science and Technology Development
Landlord
National Program Planning and Management

Projects - A primary goal for the 1996 Baseline Environmental Management Report is to provide more complete information about how the costs estimated for each activity are linked to specific projects. The Department used four general criteria for defining projects associated with environmental restoration, nuclear material and facility stabilization, and waste management activities (Table C-4). Projects had to be tangible entities linked to geographically identifiable problems or sites and large enough to address real problems and represent significant cost. To facilitate schedule estimates, projects had to have a definable beginning and end. To improve linkages with other program planning efforts, individual sites had to be able to crosswalk projects with existing budget breakdowns and planning tools.

Table C-4. Criteria for Defining Projects

  • Tangible entities linked to geographically identifiable problems or sites
  • Large enough to address real problems and represent significant cost
  • Definable beginning and end
  • Able to be linked to existing budget breakdowns and planning tools

Using the above criteria, each site identified its major projects, using those identified in the 1995 Baseline Environmental Management Report as a starting point. Environmental restoration projects generally represent discrete, identifiable geographical portions of sites (or entire small sites). For nuclear material and facility stabilization activities, large facilities are listed as discrete projects, while smaller facilities are grouped together by facility category and geography. Waste management projects are specific facilities used to treat, store, and/or dispose of high-level waste, spent nuclear fuel, low-level waste, low-level mixed waste, and transuranic waste at each site where the waste type is present.

Personnel at individual sites have provided an estimate of the cost and schedule for each major project. The individual site summaries presented in Volumes II and III of the 1996 report provide these estimates.

C.1.2.2 ENVIRONMENTAL RESTORATION ACTIVITIES

Environmental restoration is carried out to ensure that potential exposures to radionuclides and other contaminants in environmental media and surplus facilities are eliminated or reduced to levels prescribed through formal agreement with regulators. The major environmental restoration activities are assessment, remedial actions, facility decommissioning, and long-term surveillance and monitoring. To support these activities, related actions may be undertaken including treatment of contaminated soils or ground water onsite, packaging waste for commercial treatment and/or disposal, and disposing of consolidated contaminated materials such as soils or building rubble onsite.

Assessment involves all activities required to identify and characterize release sites or facilities and reach a formal agreement with regulators regarding appropriate further actions (e.g., Superfund Records of Decision). Specific tasks include reviewing historical records; physically assessing current conditions at the release site or facility; collecting and evaluating media samples to identify the nature and extent of contamination; assessing current and future risks to human health and the environment; developing and evaluating the feasibility of potential decommissioning or remedial options (including no action); conducting appropriate public involvement activities; and preparing, reviewing, and revising all reports and documents required by applicable regulations.

Remedial actions follow assessment and involve all activities required to implement further actions determined through formal agreement with regulators. There are three general types of remedial actions: active removal, containment, and "No Further Action" Active removal of most contaminants, including radionuclides, involves excavating or extracting contaminated media and one or more of the following: treatment to remove contaminants from the medium, placing the contaminated medium or byproducts in appropriate containers for shipment to treatment or disposal sites, and/or directly disposing of the contaminated medium or byproducts in an appropriate disposal facility. In-place destruction (e.g., bioremediation) may be possible for some organic contaminants. Containment involves leaving contaminants in place and constructing physical barriers (e.g., caps, slurry walls) or implementing interception strategies (e.g., pumping ground water) to prevent further migration of contaminants. No Further Action is taken where contaminants have been eliminated or are present in such low concentrations as to have no significant health consequences. This situation may result when contamination upon investigation is lower than suspected or limited expedited response actions were sufficient to address long-term risk concerns.

Facility decommissioning activities involve the safe decontamination and/or dismantlement of surplus facilities that have been deactivated. The contents of these facilities are primarily reactors, hot cells, processing plants, storage tanks, research equipment, and other structures. Related tasks include surveillance and maintenance, characterization, environmental documentation review, waste disposal, and closeout. There are three general types of facility decommissioning actions: full decontamination and dismantlement, decontamination and containment, and entombment. Full decontamination and dismantlement involves complete decontamination of facility contents, demolition of structural materials, and removal of demolition materials. Decontamination and containment involves decontamination and demolition, with capping demolition materials in place. Entombment involves partial decontamination, limited or no demolition, and encasing remaining materials in concrete.

Treatment, storage, and disposal are a small part (less than 10 percent) of environmental restoration activities. These activities are required at some sites (i.e., the Oak Ridge K-25 Site, the Paducah Gaseous Diffusion Plant, the Pinellas Plant, and the Portsmouth Gaseous Diffusion Plant) with large facility decommissioning projects and few or no established waste management facilities. At two other sites (the Hanford Site and the Savannah River Site), environmental restoration activities include construction and operation of large disposal cells for waste generated from remedial actions and facility decommissioning.

Long-term surveillance and monitoring is conducted to ensure that the selected remedies continue to provide the level of protection for human health and the environment that is specified in formal agreements with regulators. These activities are required for all remedies involving containment or No Further Action and may be required for long-term remediation strategies (e.g., ground-water pump-and-treat operations) and following completion of facility decommissioning actions. Specific tasks may include compliance monitoring to ensure that the remedial technologies remain effective as well as surveillance to ensure that physical access to restricted areas is prevented.

C.1.2.3 NUCLEAR MATERIAL AND FACILITY STABILIZATION ACTIVITIES

Nuclear material and facility stabilization involves stabilizing and storing special nuclear materials prior to their final disposition and deactivating facilities that the Department has declared surplus because they no longer are needed to meet mission objectives (e.g., research, waste management, nuclear weapons production or dismantlement). The major activities are nuclear material stabilization, facility deactivation, and surveillance and maintenance. Surveillance and maintenance is an integral component of both stabilization and deactivation.

Nuclear material stabilization activities are carried out to reduce the near-term risks associated with current storage configurations for special nuclear materials by placing these materials in a condition suitable for long-term storage. These activities include repackaging and consolidation of these materials.

Facility deactivation activities are carried out to ensure that surplus facilities are secure and in a safe shutdown condition pending their ultimate disposition, which could range from demolition to further cleanup and commercial reuse. These activities involve eliminating immediate safety and environmental hazards as well as removing most contaminants within the facility. Specific tasks include removing equipment and stock chemicals; cleaning out pipelines, holding tanks, and process vessels; and removing reactor cores.

Surveillance and maintenance activities involve all actions required to ensure adequate security of nuclear materials and surplus facilities, pending their ultimate disposition. Specific tasks include maintaining fences and other access barriers and providing onsite surveillance, environmental monitoring, repairs, and other routine maintenance. Surveillance and maintenance continues before, during, and after stabilization and deactivation until the final disposition has been completed. At some sites (e.g., the Rocky Flats Environmental Technology Site), surveillance and maintenance also includes storage of special nuclear materials after stabilization has been completed.

The scope of work associated with surveillance and maintenance differs markedly before stabilization, between stabilization and deactivation, and after deactivation. Consequently, at sites where data are available, separate estimates are provided for pre-stabilization, post-stabilization, and post-deactivation surveillance and maintenance. Surplus facilities may go directly to stabilization or deactivation, or they may go directly from stabilization to deactivation. Therefore, not all phases of surveillance and maintenance may occur. At the Hanford Site and Savannah River Site, data are reported by projects and phase. At the Idaho National Engineering Laboratory, Oak Ridge Reservation, and Rocky Flats Environmental Technology Site, data are reported by phase. At the remaining sites, data are reported as a single nuclear material and facility stabilization estimate.

C.1.2.4 WASTE MANAGEMENT ACTIVITIES

Waste management involves the safe and efficient treatment, storage, and disposal of waste and spent nuclear fuel. Most of this effort involves the design, permitting, construction, operation, maintenance, stabilization, and clean closure of treatment, storage, and disposal facilities. The waste comes from three primary sources: existing inventories; waste derived from environmental restoration activities; waste derived from nuclear material and facility stabilization activities; additonal wastes generated by waste management activities; and new waste generated by ongoing Departmental missions. The Environmental Management program manages eight types of waste: high-level, transuranic mixed, transuranic, low-level mixed, low-level, special case, hazardous, and sanitary. The program also manages the Department's inventory of spent nuclear fuel, which the Departments does not consider a waste material.

Treatment activities involve applying a wide variety of technologies such as incineration, vitrification, and grouting to transform waste into material suitable for disposal. In addition to constructing, operating, maintaining, and closing waste treatment facilities, specific tasks include characterizing waste to determine appropriate handling procedures and packaging and transporting waste to appropriate treatment or disposal facilities. The Department will use commercial vendors for high-level and transuranic waste at some sites. For purposes of this report, treatment also includes conditioning of spent nuclear fuel prior to disposal.

Storage activities are undertaken if no appropriate treatment or disposal facility is available for a given volume of waste. In addition to constructing, operating, maintaining, and closing storage facilities, specific tasks include characterizing waste to determine appropriate handling procedures, and packaging and transporting waste to appropriate treatment or disposal facilities.

Disposal activities involve placing post-treatment materials into appropriate landfills, repositories, or other engineered structures and providing adequate security, surveillance, and maintenance to ensure that contaminants are not released from these facilities into the environment. In addition to construction, operation, and maintenance of disposal facilities, specific tasks include providing onsite surveillance, environmental monitoring, repairs, and other routine maintenance.

C.1.2.5 SCIENCE AND TECHNOLOGY DEVELOPMENT ACTIVITIES

Science and technology development activities include managing and directing focused, problem/solution-oriented technology development programs to support environmental restoration, nuclear material and facility stabilization, and waste management activities. These activities include basic as well as applied science research. Technologies are designed to reduce risks, facilitate compliance, minimize waste generation, and decrease site cleanup costs. A major goal is to enhance the commercialization and implementation of new technologies to reduce costs and provide a world-wide leadership role for the United States in environmental remediation. Costs for technology development activities are shown in the 1996 report in two ways. In Volume I, costs are presented as part of National Program Planning and Management (see Chapter 4). In Volume II, costs are presented in the Maryland/Washington, D.C. site summary. Although costs for these activities are appropriated at Headquarters, approximately 91 percent of this funding is transferred to field operations.

C.1.2.6 LANDLORD ACTIVITIES

Landlord activities involve the physical operation and maintenance of Department of Energy sites. Specific tasks vary but generally include providing utilities, maintenance, and general infrastructure for the entire site.

C.1.2.7 NATIONAL PROGRAM PLANNING AND MANAGEMENT ACTIVITIES

National Program Planning and Management activities include planning, monitoring, and reporting ongoing activities, cost/schedule tracking, clerical, and other administrative support. Also included are grants to states and locations as well as Department-wide development and implementation of effective strategies, techniques, methods, and policy guidance for the safe, secure, efficient, and cost-effective transportation of Department of Energy materials. Costs for national program planning and management fall into two categories. Program management includes program support, which involves general technical contractor support services for all Environmental Management Headquarters elements, special projects of immediate concern, and other projects that arise during the fiscal year. Program direction includes salaries and benefits for all federal Full-Time Equivalent personnel at Headquarters.

Individual site summaries in Volumes II and III of the 1996 report also include separate cost estimates for program management/support activities. These represent program management, program direction, and other support activities associated with the site and/or particular functional elements (e.g., environmental restoration, waste management) at the site. Examples of support activities include furnishing government equipment, upgrading laboratories, and performing treatability and prevention of contamination dispersion studies.

C.1.3 Developing Categories for Personnel Requirements

The National Defense Authorization Act of 1995 required, for the first time, that the Baseline Environmental Management Report provide an estimate of the personnel required to perform the mission activities of the Environmental Management program. The Department selected the nine labor categories defined by the Common Occupational Classification System used for earlier work force planning projects (Table C-5). Using these categories, each site provided counts of their human resource needs for the years FY 1996 through FY 1998. These counts included both federal and contractor (direct and indirect) personnel. All data are presented in the site summaries in Volumes II and III of this report.

Table C-5. Labor Categories Used to Estimate Personnel Requirements

General Managers, Executives, First Line Supervisors, and Program/Project Managers - Persons who engage in activities related to planning, scheduling, monitoring, coaching, overseeing, and evaluating the work of others, and who control and distribute resources within their organizational units, programs, or projects.

General Administrative, Secretarial, and Clerical Support Staff - Persons who provide office support services to managerial, scientific, engineering, and professional staff through activities such as typing, word processing, making appointments, and answering telephones.

Administrative and Other Professional Occupations - Persons who provide services and professional advice, inspect operations and facilities, and/or maintain computer, communications, and financial systems.

Engineers - Persons who apply physical laws and principles for the development and use machines, materials, instruments, processes, and services and engage in activities such as research, design, construction, testing, procurement, production, operations, and sales.

Scientists - Persons who apply scientific methods to investigate the laws of natural, physical, and social phenomena and their application to problems in fields such as engineering, medicine, production, and the environment.

Technicians - Persons who apply scientific, technical, or engineering principles to solve basic problems; who repair, maintain, or provide basic operation of tools or equipment; or who collect and analyze data via field sampling and laboratory analysis.

Operators - Persons who control and operate vehicles, machines, systems, equipment, and plants to produce, destroy, move, and store materials and supplies.

Craftsmen - Persons who construct, destruct, alter, and/or maintain buildings, bridges, pipelines, and other structures and/or who fabricate materials and machinery.

Laborers and General Service Workers - Persons who engage in manual labor or general infrastructure support activities.

C.2 GATHERING AND ASSEMBLING DATA

The magnitude of the environmental problems associated with the nuclear weapons complex, the length and complexity of the cleanup effort, and the uncertain and changeable nature of the Environmental Management program make it difficult for site personnel to develop precise long-range cost and schedule estimates. The need to meet the Congressional mandate for a program baseline, coupled with the need to provide a basis for evaluating program alternatives (e.g., how total cost would change if annual funding went up or down), required the ability to isolate direct project costs from various indirect costs, including landlord activities. Numerous differences in cost estimating methodologies, planning methodologies, and accounting practices across the complex made this a difficult task.

Given the uncertainties and needs, the Department developed life-cycle cost estimates for two types of scenarios. The first is the Base Case scenario, which represents current views (as of October 1995) of the most likely set of activities and costs that will occur during the life cycle of the Environmental Management program. The second type is alternative scenarios, which examine the potential impacts of various policy decisions on total program cost and schedule. The 1996 report examines alternative scenarios for land use, program funding and schedule, and minimal action. The alternative scenarios were limited to the five Environmental Management sites with the highest life-cycle cost estimates: Hanford Site, Idaho National Engineering Laboratory, Oak Ridge Reservation, Rocky Flats Environmental Technology Site, and Savannah River Site. These five sites represent the majority (70 percent) of the total cost estimate in the 1996 report.

For the Base Case scenario, cost and schedule estimates are based primarily on site-specific (field) data, supplemented with parametric modeling by Headquarters only when necessary to fill data gaps. Headquarters developed the overall scope and the general assumptions to be used, as well as a framework and software application for reporting data. Personnel at each individual site developed their own, fully integrated cost and schedule estimates using their most current baselines and planning documents. Headquarters personnel provided assistance in cost estimation and data integration as needed, and worked closely with sites to ensure that support costs were included fully. Personnel at the individual sites verified all changes proposed by Headquarters prior to inclusion in the 1996 report.

For the alternative scenarios for land use and program funding and schedule, the personnel at individual field sites provided critical assumptions that would affect projects and described how these projects would change, and Headquarters used parametric modeling to estimate the cost consequences of these changes. For the minimal action scenario, site personnel provided both critical assumptions and alternative cost and schedule estimates for their individual site.

C.2.1 Gathering Data

Obtaining an integrated cost and schedule estimate required the following basic types of data for each Environmental Management activity:

  • Identity and location are used to identify the activity, track it through the Baseline Environmental Management Report data bases and analyses, and ensure that costs were accounted for at the appropriate site.
  • Annual cost, start date (year), and duration (years) are used to develop cost profiles over time for each site.
  • Data on waste type and annual volumes generated are used to coordinate planned waste management facilities with estimated waste generation and to estimate waste management costs.
  • Data on assumed technologies are used to evaluate the impact of technology development on cost and schedule estimates.

Because of the potential need to reschedule Environmental Management projects to accommodate funding and waste management constraints, it also was critical to understand which projects were governed by existing compliance agreements (to avoid creating a Base Case that was not in compliance with these agreements). Specific methods used to collect data for each of these types of projects are described in separate sections below.

To develop cost and schedule estimates for specific projects, it also was necessary to determine which activities were associated with each project and the sequence in which these activities would be performed. Environmental restoration projects generally consisted of three activities: assessment (e.g., remedial investigations, feasibility studies), remediation or decommissioning, and post-remediation surveillance and monitoring (e.g., ground-water monitoring, inspecting containment barriers such as caps). Nuclear material and facility stabilization projects could consist of as many as five activities: pre-stabilization surveillance and maintenance, nuclear material stabilization, post-stabilization surveillance and maintenance, deactivation, and post-deactivation surveillance and maintenance. Waste management projects could consist of four activities: pre-treatment storage, treatment, post-treatment storage, and disposal.

C.2.1.1 ENVIRONMENTAL RESTORATION ACTIVITIES

Data for environmental restoration activities were obtained by updating information in a core data base. To facilitate the updating of this information, the software application used to collect data was seeded with each site's 1995 Baseline Environmental Management Report data where possible. Field staff employed the software application for the entry of data at each site, aggregated the data at the Department of Energy Operations Office level, and transmitted the data to Headquarters. Headquarters staff performed an initial screening of the data to ensure that all needed data fields were completed in the correct format and that the data were referenced adequately. Headquarters staff then performed a detailed content review to determine whether all data elements required for Baseline Environmental Management Report analyses were provided. Examples of specific reviews included determining that:

  • All significant areas of contamination (or waste streams) were listed;
  • Waste type and volume were provided;
  • Each waste stream had at a minimum basic characterization of its radiological and hazardous chemical properties;
  • Remedial or decommissioning strategy was included; and
  • Contingency costs were provided for all relevant records.

Headquarters staff also coordinated the use of a parametric model (the Automated Remedial Assessment Methodology) in the few instances where sites could not estimate the cost of and waste volumes from decommissioning of surplus facilities.

C.2.1.2 NUCLEAR MATERIAL AND FACILITY STABILIZATION ACTIVITIES

The cost estimates for nuclear material and facility stabilization are, for the most part, order-of-magnitude estimates. Base Case estimates were field-developed at four sites: Hanford Site, Idaho National Engineering Laboratory, Rocky Flats Environmental Technology Site, and Savannah River Site. The remainder were developed using parametric cost-estimating techniques at Headquarters. In instances where parametric cost estimating techniques were used, the Department assumed a hypothetical "7-3-3-2-2" scheduling scenario (in this sequence): seven years of pre-stabilization surveillance and maintenance; three years of stabilization; three years of post-stabilization surveillance and maintenance; two years of deactivation; and two years of post-deactivation surveillance and maintenance. This represents a change in assumptions from the 1995 Baseline Environmental Management Report, which used a hypothetical "10-5-2" scheduling scenario: ten years of pre-stabilization surveillance and maintenance; five years of stabilization/deactivation; and two years of post-deactivation surveillance and maintenance. Facility decommissioning activities are assumed to begin after two years of post-deactivation surveillance and maintenance. Therefore, any surveillance and maintenance costs beyond that period are considered part of environmental restoration activities. Table C-6 presents the assumptions used to develop nuclear material and facility stabilization cost estimates.

Table C-6. Assumptions for Nuclear Material and Facility Stabilization Estimates

The "7-3-3-2-2" hypothetical scheduling scenario assumes seven years of pre-stabilization surveillance and maintenance, three years for nuclear material stabilization, three years of post-stabilization surveillance and maintenance, two years of facility deactivation, and two years of post-deactivation surveillance and maintenance. This scenario does not necessarily represent the way that current and future surplus facilities will be addressed.

Data for each facility represent the best information available from the Surplus Facility Inventory Assessment data base as of December 1994, as modified by the individual field sites during the 1996 data collection process.

Only surveillance and maintenance, nuclear material stabilization, and facility deactivation activities are included in this estimate.

Surveillance and maintenance are occurring during stabilization and deactivation activities and in some cases include storage costs for special nuclear material.

Data for nuclear material and facility stabilization activities were obtained by translating data from the 1995 Baseline Environmental Management Report format to the 1996 Baseline Environmental Management Report format and seeding the software application used to collect data with this information. The software application allowed the sites to define scheduling/transfer units (Table C-7), update specific facility data, add or remove facilities, modify the 1995 Baseline Environmental Management Report cost and waste volume estimates, and/or provide their own cost and waste volume estimates. Sites used the software application for data entry, aggregated the data at the Department of Energy Operations Office level, and transmitted the data to Headquarters.

Table C-7. Scheduling/Transfer Units

Each scheduling/transfer unit includes a site-specific grouping of facilities based on similarities such as geographical location and/or historical use. They typically consist of more than one separate building (e.g., a large chemical processing building and dozens of ancillary buildings may be included in a single unit). Scheduling/transfer units are used to define nuclear material and facility stabilization costs as well as to schedule projects moving from stabilization to decommissioning.

Two sites - the Hanford Site and Savannah River Site - provided cost and schedule estimates by phase for individual scheduling/transfer units. Three sites - the Idaho National Engineering Laboratory, Oak Ridge Reservation, and Rocky Flats Environmental Technology Site - provided cost and schedule estimates by phase for a single, site-wide scheduling/transfer unit. At the remainder of the sites, a single estimate was provided for all nuclear material and facility stabilization activities combined. In cases where a site was unable to provide any cost and schedule estimates, the 1996 Baseline Environmental Management Report used a modification of the four-step process originally defined for the 1995 report:

Modify List of Surplus Facilities Expected to Require Stabilization - For the 1995 report, the Department produced a unified list of approximately 3,500 facilities (as of December 1994) likely to require stabilization in the future. This list was based on a comparison of the Surplus Facilities and Inventory Assessment data base and a list of surplus facilities developed for the Waste Management Programmatic Environmental Impact Statement. Each site reviewed and updated this list for the 1996 report.

Define Cost Estimating Categories and Classify Facilities - For the 1996 report, the Department used the same 22 facility categories developed for the 1995 report based on physical characteristics and types of historical activity (Table C-8).

Modify and Execute Algorithms for Estimating Cost and Waste Volume - For the 1996 report, the Department modified the algorithms for estimating cost and waste volumes for each of the 22 facility categories. The 1995 algorithms, developed using a "10-5-2" scenario, were modified to reflect the "7-3-3-2-2" scenario used for the 1996 report. These algorithms are based on multiplying the facility's physical characteristics (square feet, linear feet, gallons of facility size) by a unit cost (per square foot, linear foot, or gallon).

Provide List of Facilities and Cost and Waste Estimates to Field for Review and Verification - Numerous discussions have taken place between Headquarters and site personnel regarding what facilities are on the list; how these have been classified for cost estimation purposes, size and other key physical characteristics; types of waste expected to be present; and waste volumes expected to be generated during stabilization. The lists and resulting cost estimates were modified based on the updated information provided by the field.

Table C-8. Categories for Nuclear Material and Facility Stabilization Cost Estimates

Category

Description

A. Large Production Reactors 14 large reactors used to generate uranium, plutonium, and tritium for nuclear weapons
B. Chemical Processing Buildings Eight large plants ("canyons") used to chemically separate uranium and plutonium from other fission products
C. Diffusion Cascade Buildings Three large facilities ("gaseous diffusion plants") used to remove and separate uranium-235 from uranium-238
D. Research Reactors Smaller reactors used for research and development
E. Radiologically Contaminated Facilities

E1 - size less than 1,000 ft2

E2 - size greater than 1,000 ft2 and less than 15,000 ft2

E3 - size greater than 15,000 ft2

Other facilities contaminated with radioactive materials but not hazardous substances
F. Radiologically Mixed Contaminated Facilities

F1 - size less than 1,000 ft2

F2 - size greater than 1,000 ft2 and less than 15,000 ft2

F3 - size greater than 15,000 ft2

Other facilities contaminated with radioactive materials and hazardous substances
G. Hazardous Materials Contaminated Facilities

G1 - size less than 1,000 ft2

G2 - size greater than 1,000 ft2 and less than 15,000 ft2

G3 - size greater than 15,000 ft2

Other facilities contaminated with hazardous materials but not radioactive materials substances
H. Radiologically Mixed Contaminated Facilities

H1 - size less than 1,000 ft2

H2 - size greater than 1,000 ft2 and less than 15,000 ft2

H3 - size greater than 15,000 ft2

Other facilities contaminated with special nuclear materials
I. Storage Tanks

I1 - tanks contaminated with radioactive materials

I2 - tanks contaminated with hazardous materials

Above-ground and underground tanks used to store waste and other materials
J. Stacks Facilities used as exhaust stacks for boilers and similar structures
K. Electrical Switchyards Facilities used to house temporary generators, transformers, and other electrical service components
L. Pipelines Pipelines used to transfer materials between facilities
M. Ponds/Retention Basins Earthen structures used to hold effluent liquids

C.2.1.3 WASTE MANAGEMENT ACTIVITIES

The Environmental Management program is responsible for managing eight types of waste and spent nuclear fuel, which the Department does not consider as a waste material. The approach for estimating life-cycle waste management costs depended considerably on the type of waste being managed. Life-cycle costs and schedules for managing high-level waste and spent nuclear fuel are fairly well defined. The Department currently has accurate estimates of the total volume of high-level waste and spent nuclear fuel for which the Environmental Management program is responsible. Plans for managing high-level waste are reasonably well advanced, and options for managing spent nuclear fuel were evaluated in accordance with the National Environmental Policy Act process, with a Record of Decision published in May 1995.

Most of the hazardous and sanitary waste being managed by Environmental Management is generated by ongoing Department of Energy operations. Life-cycle costs and schedules for managing these two waste types are based primarily on estimated generation rates from these ongoing operations.

Low-level, low-level mixed, transuranic, and transuranic mixed waste present a different challenge. A significant fraction of the volumes of these waste types requiring treatment, storage, and disposal will be generated by environmental restoration and nuclear material and facility stabilization activities. However, since numerous environmental restoration decisions have not yet been made, there are considerable uncertainties in the waste volumes that will eventually be generated, the types of facilities that will be required to manage them, and cost estimates. Site personnel estimated the volumes of these waste types to be generated by these activities and whether they required treatment prior to disposal.

Many of the waste management cost and schedule estimates for the 1995 Baseline Environmental Management Report were developed at Headquarters using program planning documents. To improve the estimates for the 1996 report, the Department focused on obtaining "bottom-up" data from the field. This allowed the field personnel, who are most familiar with their individual sites and have experience with their respective regulators and stakeholders, to ensure that the cost and schedule data are complete and reflect the most current understanding of how the Environmental Management program is likely to unfold at their sites. Program management costs for waste management activities are included in the treatment, storage, and disposal costs.

High-Level Waste - Site personnel provided all cost and schedule estimates for managing high-level waste. Planning estimates are available for the four sites with nearly all of this waste: the Hanford Site (including the Tank Waste Remediation System), the Savannah River Site (including the Defense Waste Processing Facility), the West Valley Demonstration Project, and the Idaho National Engineering Laboratory. Cost estimates for high-level waste include the treatment and disposal of low-level waste resulting from treatment processes such as the saltstone facility at the Savannah River Site and a vitrification facility at the Hanford Site. Decommissioning costs for high-level waste facilities are included in the site estimates.

Spent Nuclear Fuel - Site personnel provided all cost and schedule estimates for managing spent nuclear fuel. A Record of Decision (May 1995) for the "Spent Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental Restoration and Waste Management Programs Environmental Impact Statement" supports the preferred alternative of interim storage consolidation at three sites: the Hanford Site, the Savannah River Site, and the Idaho National Engineering Laboratory. Spent fuel clad with aluminum will be sent to the Savannah River Site for interim storage, and spent fuel clad with stainless steel will be sent to the Idaho National Engineering Laboratory. The Base Case estimate assumes consolidated storage, shipment to a geologic repository, and decommissioning of interim storage facilities.

Hazardous and Sanitary Waste - Site personnel provided all cost and schedule estimates for hazardous waste and sanitary waste generated and/or managed by the Environmental Management program. These estimates are based on current and estimated future generation rates from sources both within the Environmental Management program (e.g., environmental restoration activities) as well as other Department of Energy sources (e.g., facilities operated by Defense Programs). All hazardous and sanitary waste is assumed to be handled by the Environmental Management program. Sanitary waste is either disposed of onsite or in municipal landfills. Hazardous waste is sent to commercial vendors for treatment and disposal.

Low-Level, Low-Level Mixed, Transuranic, and Transuranic Mixed Waste - Site personnel provided all cost and schedule estimates for these waste types. This entailed a significant effort to integrate data on current waste inventories; the estimated volume and schedule for generating waste from environmental restoration, nuclear material and facility stabilization, and other Department of Energy activities; existing treatment, storage, and disposal capacity; and estimates of future capacity. Some waste will be shipped from one site to another for treatment and/or disposal; this required an additional effort to integrate information on waste generation at the source site and treatment or disposal capacity at the receiving site. The Baseline Environmental Management Report Integration Tool, developed for the 1995 report, was used to assist in this integration effort. Current Department of Energy plans call for disposal of transuranic waste at the Waste Isolation Pilot Plant in New Mexico. Generating sites will treat and package transuranic waste to meet the Waste Isolation Pilot Plant waste acceptance criteria. The life-cycle estimate for this facility includes the costs for transporting the packaged material, disposing it, and operations.

C.2.1.4 SCIENCE AND TECHNOLOGY ACTIVITIES

Current funding for science and technology activities is approximately six percent of the total Environmental Management program budget. The Department assumed that science and technology funding would continue at this percentage until 2030, when between 70 and 80 percent of the Environmental Management program is expected to be completed.

C.2.1.5 LANDLORD ACTIVITIES

The Environmental Management program has landlord responsibilities at nine Department of Energy sites (Table C-9). Personnel at these sites provided estimates of annual landlord costs for the life of the Environmental Management program at their site.

Table C-9. Sites at Which the Environmental Management Program Has Landlord Responsibilities

Energy Technology Engineering Center

Fernald Site

Grand Junction Projects Office

Hanford Site

Idaho National Engineering Laboratory

Oak Ridge K-25 Site

Pinellas Plant

Rocky Flats Environmental Technology Site

Savannah River Site

C.2.1.6 NATIONAL PROGRAM PLANNING AND MANAGEMENT ACTIVITIES

Current funding for national program planning and management activities is approximately four percent of the total Environmental Management program budget. The Department assumed that the program management component of this program element will be three percent of the total budget until FY 2000, two percent from FY 2001 to FY 2020, and one percent thereafter. The program direction component is assumed to be one percent throughout the life of the Environmental Management program.

C.2.1.7 SUPPORT ACTIVITIES

The Environmental Management program performs many activities to accomplish its varied missions, including remedial actions, decommissioning, constructing, and operating waste management facilities. However, these "direct mission" activities do not represent all of the Environmental Management program activities and costs. The Environmental Management program must conduct numerous "support" activities such as program management, infrastructure support, and human resources, which are necessary to manage the ongoing work associated with the program and maintain and operate the lands, facilities, and other resources for which the program is responsible.

Environmental management support activities are classified into six general categories and 29 specific categories for this analysis (Table C-10). To ensure that support costs are accounted for completely in the 1996 Baseline Environmental Management Report, the Department asked site personnel to estimate support costs based upon two factors: (1) current levels of support costs, and (2) how support costs are likely to change in the future as the Environment Management program matures.

Table C-10. Environmental Management Support Activity Categories

Management - Overall management activities, including executive direction, contractor oversight, management/award fees, program management, and quality assurance.

Finance and Administrative Services - General administrative activities, including administrative support, chief financial officer, human resources, information services, legal services, and training.

Environment, Safety, and Health - Activities associated with operating facilities and lands safely. Includes traditional activities such as emergency preparedness, fire protection, industrial safety, and occupational medicine services as well as environmental monitoring, analytical laboratory support, and pollution prevention.

Infrastructure - Activities associated with providing utilities, maintenance, and general infrastructure for a site. Includes facilities management/engineering and maintenance, logistics support, procurement, and utilities.

Safeguards and Security - Activities associated with protection of nuclear materials, nuclear weapons, classified information, and government property from acts such as theft, sabotage, and espionage.

Stakeholders and Regulatory Interactions, and Other - Other types of activities related to operating facilities and sites. Includes negotiating and implementing agreements with stakeholders, economic development, laboratory-directed research and development, media/communications, regulatory compliance, stakeholder-related outreach, taxes, technology development, and all other support activities.

Estimating current support costs - Most sites were asked to estimate their total FY 1996 support costs by general functional category. The five highest-cost sites were asked to provide rough estimates of funding levels for each of the 29 specific support cost categories identified above. This required examining all accounts and estimating what portion of those accounts are for each support cost activity, using allocations and best professional judgment as necessary. The objective was to understand the magnitude of support costs relative to "direct mission" activities in a base year.

Estimating changes in support costs - To estimate future support costs, and to support the alternate scenario analyses discussed below (Section C.3.2), most sites were asked to estimate how costs for each of the six general support cost categories would change in response to changes in "direct mission" activities. The five highest-cost sites were asked to make these evaluations for all 29 specific cost categories. Site personnel had the option of forecasting support costs directly or completing a survey instrument to provide input on these factors to a parametric model for estimating outyear support costs. The survey responses were used to develop algorithms specific to each site relating estimated costs for support activities to estimated costs for "direct mission" activities. The Baseline Environmental Management Report Integration Tool was modified to use these algorithms to project outyear costs. Site personnel reviewed these forecasts to ensure their quality.

The survey instrument contained three sets of questions to elicit input factors for the support cost algorithms:

(1) How would the costs for each support activity vary in response to a change in environmental restoration, nuclear material and facility stabilization, or waste management activities? Site personnel were asked to circle the appropriate response in each row of the following matrix:

Change in "Direct Mission" Cost Change in Support Activity Cost
+ 100% 0% +10% +20% +30% +40% +50% +60% +70% +80% +90% +100%
+ 75% 0% +10% +20% +30% +40% +50% +60% +70% +80% +90% +100%
+ 50% 0% +5% +10% +15% +20% +25% +30% +35% +40% +45% +50%
+ 25% 0% +2% +4% +6% +8% +10% +12% +15% +18% +20% +25%
- 25% 0% -2% -4% -6% -8% -10% -12% -15% -18% -20% -25%
- 50% 0% -5% -10% -15% -20% -25% -30% -35% -40% -45% -50%
- 75% 0% -10% -20% -30% -40% -50% -60% -70% -80% -90% -100%
- 100% 0% -10% -20% -30% -40% -50% -60% -70% -80% -90% -100%

(2) How would the costs for each support activity vary as the Environmental Management program matures? Site personnel were asked to circle the appropriate response in each row of the following matrix:

Maturity Change in Support Activity Cost
+ 5 years +100% +75% +50% +25% +10% +5% 0% -5% -10% -25% -50% -75% -100%
+ 10 years +100% +75% +50% +25% +10% +5% 0% -5% -10% -25% -50% -75% -100%
+ 20 years +100% +75% +50% +25% +10% +5% 0% -5% -10% -25% -50% -75% -100%
+ 30 years +100% +75% +50% +25% +10% +5% 0% -5% -10% -25% -50% -75% -100%
+ 40 years +100% +75% +50% +25% +10% +5% 0% -5% -10% -25% -50% -75% -100%

(3) How would the costs for each support activity vary in response to changes in any other factors? Site personnel were asked to provide a quantitative and narrative discussion of these effects.

All support cost estimates were incorporated into estimates of Adirect mission@ activities to ensure that all costs were accounted for in the total program cost estimate. Thus, support costs are not reported separately in the 1996 Baseline Environmental Management Report.

C.2.2 Assembling the Data

The Department used a nine-step process to assemble cost and schedule data prior to the integration analyses (Table C-11). Each step is described below.

Table C-11. Steps in Gathering and Assembling Data

1. Develop analytical units for integration analyses

2. Define linkages between analytical units and to external data sources

3. Develop data collection software

4. Modify data dictionary and data formats and develop software for input to Baseline Environmental Management Report Integration Tool

5. Perform initial quality assurance/quality control of data and identify missing data

6. Modify data and fill in missing data using parametric models

7. Assemble preliminary data set for input into Baseline Environmental Management Report Integration Tool

8. Perform final quality assurance/quality control on input data

9. Assemble final data set for input to Baseline Environmental Management Report Integration Tool

Step 1- Develop analytical units for integration analyses

Information obtained for Environmental Management program activities included anticipated starting dates and duration. The integration analyses for the Base Case and alternative scenarios required the ability to revise starting dates and durations in order to meet anticipated funding restrictions, allow for capital costs of new waste management facilities, and ensure that remediation and nuclear material and facility stabilization projects that would generate waste would be coordinated with waste management capacity. The Department therefore compiled information for each activity into analytical units for purposes of integration and scheduling.

With two exceptions, the analytical units corresponded directly to the Environmental Management activities defined earlier (see Section C.1.2). Analytical units for environmental restoration activities were defined at a lower level (the project level) to provide more flexibility in the integration and scheduling analysis. The 295 environmental restoration activities were subdivided into 936 projects. For waste management activities, the uncertainties associated with future generation of low-level, low-level mixed, transuranic, and transuranic mixed waste made it necessary during integration to define "new" (hypothetical) facilities to manage this waste, particularly later in the time period covered by this analysis.

Step 2 - Define linkages between analytical units and to external data sources

Building an integrated Base Case estimate requires an understanding of the interdependencies between Environmental Management activities or projects within, and in some cases, between sites. For example, the costs for managing waste generated by an environmental restoration activity may be reported in a waste management activity. In cases where this waste is generated at one site and managed at another, the two interrelated activities will be at different sites. In addition, some activities are sequentially related to one another. For example, facility deactivation precedes facility decommissioning. Cross linking efforts for the Base Case focused in two areas. (1) For all activities expected to generate waste volumes, an attempt was made to identify the specific waste management facility (project) at which that waste would be managed. (2) Facility decommissioning projects were linked to specific scheduling transfer units to ensure that deactivation and decommissioning activities were fully linked.

Providing data sets for the alternative scenarios examined in the 1996 report requires an understanding of the linkages between Baseline Environmental Management Report activities and data bases in two key parametric models. Environmental restoration core reporting levels were linked to a data base of release sites (source areas) used by the Automated Remedial Assessment Methodology to provide estimates of environmental restoration costs for alternative land-use scenarios (see Section C.3.2.2). Data on existing and planned waste management facilities (obtained from the field) were placed and updated in the System Cost Model data bases to estimate waste management costs for alternative scheduling analyses (see Section C.3.2.3).

Step 3 - Develop data collection software

    To streamline the data collection and review process, the Department developed software to collect and report Base Case data. These software applications were seeded with data from the 1995 Baseline Environmental Management Report. Site personnel modified and updated these data and provided missing data as necessary and submitted the completed data packages. Key data included duration, annual cost, annual waste volumes by type, anticipated start date, and whether any portion of the element was included in a compliance agreement. To improve overall efficiency, the software applications also were used to collect other Environmental Management programmatic data not required specifically for the 1996 Baseline Environmental Management Report but needed for other analytical requirements.

Step 4 - Modify data dictionary and data formats and develop software for input to Baseline Environmental Management Report Integration Tool

A set of specifications was developed for loading the Base Case data into the Baseline Environmental Management Report Integration Tool for performing the integration analyses (see Section C.3.1.1). The Department also developed software to translate data from the data collection applications to the Baseline Environmental Management Report Integration Tool. This software application also assisted in quality assurance/quality control efforts.

Step 5 - Perform initial quality assurance/quality control of data and identify missing data

Initial data submissions from the field were reviewed and evaluated. Headquarters staff performed an initial screening of the data to ensure that all needed data fields were completed in the correct format and that the data were referenced adequately. Headquarters staff then performed a detailed content review to determine whether all data elements required for the 1996 Baseline Environmental Management Report were provided and consistent with overall program plans. Missing and problematic data were identified.

Step 6 - Modify data and fill in missing data using parametric models

Based on the above data reviews, site personnel corrected data errors and omissions and re-submitted the completed data packages. Additional rounds of review and quality assurance/quality control were performed as necessary.

Step 7 - Assemble preliminary data set for input into Baseline Environmental Management Report Integration Tool

The Department translated data from the completed data packages into the Baseline Environmental Management Report Integration Tool data formats.

Step 8 - Perform final quality assurance/quality control on input data

The translated data were loaded into the Baseline Environmental Management Report Integration Tool. These data were used to provide a final quality assurance/quality control check on the input data. Missing or problematic data were provided or modified accordingly.

Step 9 -Assemble final data set for input to Baseline Environmental Management Report Integration Tool

Following extensive review and quality assurance/quality control checks, the final set of data representing the Base Case was assembled and loaded into the Integration Tool data bases.

C.2.3 Verifying and Documenting Data

Throughout the data assembly process, quality assurance reviews were performed to ensure that the data used for the integration and scheduling analysis were the most accurate and complete representation of the Environmental Management program that could be provided to date. Data from all available sources were checked to ensure completeness, avoid double-counting, and ensure smooth integration of data from all sources. Internal consistency checks included a mass balance accounting to ensure that all waste that the report assumed will be generated is also assumed to be treated, stored, and/or disposed, particularly when transfer from one site to another is anticipated.

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