2.0 The Environmental Management Program

The Department established the Environmental Management program in 1989 to address the environmental legacy of nuclear weapons production and other sources of potential pollutants such as nuclear research. The Environmental Management program encompasses six major functional areas: (1) environmental restoration, (2) waste management, (3) nuclear material and facility stabilization, (4) science and technology development (5) landlord, and (6) national program planning and management. These six areas are all interrelated. Figure 2.1 graphically depicts the scope of the Environmental Management program and the key interrelationships of the six major areas. Waste management involves the safe treatment, storage, and disposal of existing waste and waste yet to be generated. Environmental restoration activities address remediation of contaminated soil and water as well as decommissioning of contaminated surplus facilities. Nuclear material and facility stabilization involves stabilizing and consolidating special nuclear materials such as plutonium and highly enriched uranium and deactivating surplus facilities to a safe, low maintenance condition while awaiting final decommissioning. Science and technology development refers to a variety of basic and applied research activities that explore more effective and less expensive remedies to address the environmental and safety problems of the Environmental Management program. Landlord functions represent crosscutting site-wide support activities such as road maintenance and fire and ambulance services. National program planning and management encompasses Headquarters functions. The following subsections describe each major area.

The U.S. Department of Energy requires management of its sites and facilities in compliance with applicable federal, state, and local regulations. The Base Case described in this report is a "compliance case" (that is, based on compliance with all applicable provisions of laws, permits, regulations, orders, and agreements) in effect throughout the Department of Energy complex. The following box provides a list of the major federal laws that directly influence the functional area strategies outlined in this chapter.

Mission

The Environmental Restoration program's overall mission is to protect human health and the environment from risks posed by inactive, surplus facilities and contaminated areas. The program is accomplishing this mission by remediating sites and facilities in the most cost-efficient and responsible manner possible to provide for future beneficial use while complying with applicable environmental regulations. Environmental restoration activities are prioritized based upon various factors, including the goals of reducing risks at all sites and compliance with existing laws, regulations, and agreements. Most actions are designed to either clean up or contain contamination in the environment (including soil, ground water, and surface water) or to decommission contaminated buildings (including reactors and chemical processing buildings). Related activities conducted to support these actions may include immediate treatment of contaminated soils or ground water, packaging of waste for commercial treatment and/or disposal, and onsite disposal of consolidated contaminated media such as soils or building rubble.

Cleanup goals and remedies for each contaminated area are decided through processes established by federal and state laws and other legal agreements. These processes involve decisionmakers outside of the Department such as the states, the U.S. Environmental Protection Agency, and the U.S. Nuclear Regulatory Commission. The environmental restoration process described below is a generic approach based primarily on requirements of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended. Other statutes that influence the process include the Resource Conservation and Recovery Act, as amended, and the National Environmental Policy Act.

The Remediation Process

Initially, the Department characterizes a contaminated area to identify contaminants, determine the extent of contamination, and assess potential threats to public health and the environment. If a significant contamination problem is indicated, and a fast and limited cleanup or containment action could mitigate this problem, the Department may conduct an expedited response action or interim action. To date, the Department has completed over 500 such limited actions, avoiding larger contamination problems that could have resulted from delay.

Upon completion of characterization, the Department performs a detailed analysis to quantify existing risks and evaluate remedial alternatives. The analysis is followed by a formal decision process, including public meetings and a formal comment period. If the results of the analysis indicate that a contaminated area does not pose a threat to public health or the environment, or that a previously completed limited action adequately remediated the contamination, the Department makes a decision to take "No Further Action," in conjunction with the regulators, the U.S. Environmental Protection Agency, and the host state. If, however, a threat is deemed to be present, the Department identifies and implements the appropriate remedial action.

The Department of Energy reviews potential activities to determine how much waste will be generated in the cleanup and makes provisions for its storage, treatment, and/or disposal. If actual cleanup (for example, a removal action) is not practical, or not required because of decisions regarding future land use, the Department may take steps to stop or slow the spread of contamination by implementing containment technologies. Actions depend on the contaminants and the medium (for example, soil and ground water) in which they are found. Contaminants such as hazardous organic chemicals or fuel oil are often highly mobile but can be effectively removed from the media and destroyed. Heavy metals and radioactive materials are often less mobile but cannot be destroyed, even when it is possible to remove them from the media.

Radioactivity will decay naturally over time, but it can take from a few days to tens of thousands of years to become less harmful. During this time, heavy metal contaminated soils and radioactive waste that pose threats to public health and the environment must be contained, stabilized, or moved to a safer place. Containment structures associated with contamination that has not been fully remediated or that has been stabilized in place must be continuously monitored and maintained.

To date, the Department has completed 119 remedial action projects. Another 111 projects are under way. These projects have included cleanup of contaminated soils, construction of ground-water treatment facilities, and retrieval of buried waste. The Department is positioned to accomplish even more cleanup in the near term as many characterization activities are complete or nearing completion, and many formal cleanup decisions will be made over the next few years.

The Decommissioning Process

Decommissioning of surplus facilities involves a decisionmaking process similar to the process used for environmental remediation: characterization followed by detailed analysis of alternatives and formal remedy selection. Based on a joint policy between the Environmental Protection Agency and the Department of Energy, provisions of the Comprehensive Environmental Response, Compensation, and Liability Act generally govern decommissioning activities, which are conducted as "non-time critical removal actions."

Decommissioning activities, which occur after facilities have been stabilized and deactivated, address contamination that is already contained within buildings. Building deterioration, however, may pose a substantial hazard to surveillance and decommissioning workers, and the recurring costs associated with maintaining surplus facilities absorb resources that could be better spent on remediation. These issues raise important policy and planning questions.

Of the 3,500 contaminated facilities that are surplus, or projected to be surplus within the next ten years, the Department has decommissioned 100 facilities to date. In spite of its modest beginnings, the program has placed a priority on minimizing secondary waste and has recycled 7.24 million kilograms (16 million pounds) of scrap metal from dismantled facilities and equipment.

Mission

The Waste Management program's mission is to treat, store, and dispose of waste generated during past and future Department of Energy activities. This includes managing large volumes of "backlog" waste that currently exist at various facilities throughout the United States. For example, at the end of 1995, approximately 600,000 cubic meters (786,000 cubic yards) of radioactive waste were stored in facilities at various Department of Energy installations. Additional waste is expected from environmental restoration and nuclear material and facility stabilization activities and from other ongoing activities within the Department.

Based on definitions contained in regulations, waste is divided into categories that include high-level, transuranic, mixed transuranic, low-level, low-level mixed, uranium mill tailings, hazardous, sanitary, and special case waste. See the following box for a brief description of each waste type. Because they have specific requirements for treatment, storage, and disposal, each waste type requires a different management strategy.

Strategies

Even more than environmental restoration processes, waste management strategies depend on following detailed regulatory requirements. These include the Resource Conservation and Recovery Act, as implemented through permits, compliance agreements, and consent orders into which the Department has entered with host states and the U.S. Environmental Protection Agency. For example, the Federal Facility Compliance Act of 1992, which amended the Resource Conservation and Recovery Act, waives sovereign immunity for all federal agencies and specifically requires the Department to submit Site Treatment Plans and enter into compliance agreements with the states specifying treatment plans and schedules for mixed waste (including high-level, transuranic, and low-level mixed waste). As a result of this Act, the Department has entered into negotiated compliance orders between state regulators and/or the U.S. Environmental Protection Agency for 29 states and is currently negotiating orders for six sites.

High-Level Waste

Approximately 350,000 cubic meters (459,000 cubic yards) of high-level waste is currently stored at four sites: Hanford Site, Idaho National Engineering Laboratory, Savannah River Site, and West Valley Demonstration Project. The Department has ended production operations involving special nuclear materials and is phasing out chemical processing of spent nuclear fuel. As a result, the Department does not expect large volumes of high-level waste to be generated in the future. Small amounts, however, will be generated during nuclear material and facility stabilization activities.

Two statutes provide the principal regulatory basis for high-level waste. The Atomic Energy Act governs the radioactive constituents of high-level waste and Subtitle C of the Resource Conservation and Recovery Act governs the hazardous constituents. Based on regulatory requirements, liquid high-level waste must be converted to a durable, stable, solid form for disposal. The preferred treatment for most high-level waste is vitrification (that is, mixing liquid high-level waste with glass frit and heating it to create glass that is solidified inside steel canisters). A vitrification facility at the Savannah River Site in South Carolina recently began operations, and a facility at the West Valley Demonstration Project in western New York plans to begin operating in 1996.

Presently, no disposal facility for high-level waste is available. The Department will oversee the placement of high-level waste in a national geologic repository developed by the Department of Energy's Office of Civilian Radioactive Waste Management. This office currently plans to have a repository available for high-level waste shipments by 2015. However, based on site scheduling assumptions, this report assumes that a high-level waste repository will be available to accept Department of Energy waste in approximately 2016.

Transuranic and Mixed Transuranic Waste

Pending the availability of a geologic repository, many sites store transuranic waste, including the Hanford Site, Idaho National Engineering Laboratory, Los Alamos National Laboratory, Nevada Test Site, Oak Ridge Reservation, Rocky Flats Environmental Technology Site, and Savannah River Site. Storage facilities for transuranic waste are upgraded or built to comply with requirements under Subtitle C of the Resource Conservation and Recovery Act. Before 1970, this waste was buried in shallow trenches, mostly at the Idaho National Engineering Laboratory and the Hanford Site. Some burial site retrieval actions are now determined by the Environmental Restoration program through a process that is specified by the Comprehensive Environmental Response, Compensation, and Liability Act.

Treatment of mixed transuranic waste (radioactive and hazardous) to remove, or reduce to acceptable levels, the constituents in the waste restricted by land disposal restrictions, may be required under the Resource Conservation and Recovery Act. Mixed transuranic waste treatment requirements are being assessed as part of the Waste Isolation Pilot Plant test phase. The Waste Isolation Pilot Plant is a deep geologic repository that the Department excavated in the 1980s for disposal of transuranic waste. The Plant is located in a salt bed 640 meters (2,100 feet) below the surface in southern New Mexico. The Department plans to use this facility to dispose of transuranic waste beginning in 1998, pending completion of regulatory compliance demonstrations.

Low-Level Waste

Low-level waste ranges from low-activity waste that can be disposed of by shallow land disposal techniques to high-activity waste that requires disposal techniques providing greater confinement. Over 30 installations currently generate low-level waste. The Hanford Site, Idaho National Engineering Laboratory, Los Alamos National Laboratory, Nevada Test Site, Oak Ridge Reservation, and Savannah River Site store low-level waste on a long-term basis.

Low-level waste generally undergoes minimum treatment (that is, volume reduction, solidification of liquids, and packaging) before transportation and disposal. Low-level waste storage is kept to a minimum because disposal operations are ongoing at six installations. Waste radioactivity levels (low-level waste can have high or low levels of radioactivity) and geohydrological conditions influence disposal methods (for example, shallow land burial or engineered vaults).

In response to a recommendation from the Defense Facilities Nuclear Safety Board, the Department is taking steps to integrate low-level waste management and determine the future disposal configuration.

Low-Level Mixed Waste

Until the late 1980s, most low-level mixed waste was routinely disposed of by shallow land burial. However, enactment of the Resource Conservation and Recovery Act limited land disposal of low-level mixed waste, which is subject to land disposal restrictions, unless treatment standards are met or a variance is granted. As a result, the Department currently plans to treat most low-level mixed waste at Department of Energy sites.

Treatment strategies for low-level mixed waste have been developed through interactions between the Department, states, and stakeholders. Disposal locations will be determined in conjunction with the Waste Management Programmatic Environmental Impact Statement; site-specific Environmental Impact Statements; state regulators; and local stakeholders. For purposes of this analysis, the Department assumed that mixed low-level waste will be disposed of at the existing low-level waste sites: Hanford Site, Idaho National Engineering Laboratory, Los Alamos National Laboratory, Nevada Test Site, Oak Ridge Reservation, Savannah River Site, and commercial facilities.

Hazardous Waste

Hazardous waste includes materials identified as hazardous or requiring regulatory control as stipulated by Subtitle C of the Resource Conservation and Recovery Act. For purposes of this report, the definition of hazarious waste includes Toxic Substances Control Act-regulated material, such as asbestos and polychlorinated biphenyls. Land disposal restrictions under the Resource Conservation and Recovery Act require treatment of the hazardous constituents of waste to specific concentration levels before disposal. These regulations are implemented by the states and the Environmental Protection Agency regions and apply to local Department of Energy operations. All waste management facilities must meet stringent waste acceptance criteria.

In general, hazardous waste generated by the Environmental Management program is sent to commercial treatment and disposal facilities. Permitted commercial facilities manage approximately 10,000 cubic meters (13,100 cubic yards) of the Department's hazardous waste annually. Small amounts of hazardous waste await treatment and disposal, except for waste being accumulated for shipment to commercial facilities.

Sanitary Waste

Sanitary waste includes materials that are not hazardous or radioactive. There are essentially two types of sanitary waste: solid and liquid. Solid sanitary waste includes garbage, rubble, and other nonhazardous debris routinely generated by construction or other activities. It is regulated under Subtitle D of the Resource Conservation and Recovery Act and is typically disposed of in onsite sanitary landfills or shipped offsite to municipal landfills. Liquid sanitary waste includes sewage and industrial wastewater that is regulated by the Clean Water Act and the National Pollutant Discharge Elimination System. Treatment of liquid sanitary waste is usually accomplished at onsite or municipally-owned facilities. Industrial wastewater undergoes pretreatment processes before being discharged.

Special Case Waste

Special case waste is waste that is not high-level or transuranic, but requires greater confinement than shallow land burial. This waste is similar to Greater-Than-Class C waste regulated by the Nuclear Regulatory Commission. Only a few sites contain special case waste. These sites include the Hanford Site, Idaho National Engineering Laboratory and Grand Junction Projects Office. A decision has not been made regarding disposal of special case waste. However, the Department is considering several disposal options, including disposal onsite and in a national repository.

Spent Nuclear Fuel

Spent nuclear fuel is not regulated as a waste material. It consists of nuclear materials or heavy metals such as uranium, plutonium, or thorium withdrawn from a nuclear reactor or another neutron irradiation facility. Spent nuclear fuel exists primarily in solid form as metal-clad rods that require no treatment for near-term storage. However, broken or punctured rods must be overpacked to contain the radioactive material. Most spent fuel is stored in water pools (for example, at Hanford Site, Idaho National Engineering Laboratory, and Savannah River Site). This traditional storage method requires constant maintenance, such as water purification, to prevent corrosion of the fuel rods. Some spent fuel is stored in dry casks (for example, at Oak Ridge Reservation). The Department is developing dry above-ground facilities to provide safer and more efficient storage. Some treatment of spent nuclear fuel may be required before final disposal in a geologic repository. Until a repository is available, the Department will provide for the management of spent nuclear fuel and related facilities, including interim activities necessary to ensure safe storage.

Spent nuclear fuel includes all nuclear fuel generated by Department of Energy production reactors, university and government research reactors, foreign research reactors that use fuel of U.S. origin, and naval nuclear propulsion reactors (including training, prototype, and service reactors). Except for a few special cases (for example, Three Mile Island), the Environmental Management program is not responsible for managing spent nuclear fuel from commercial reactors.

In January 1996, the Environmental Management program transferred management of spent nuclear fuel from the Waste Management program to the Nuclear Material and Facility Stabilization program. This shift occurred because spent nuclear fuel is closely related to the special nuclear materials already managed by the Nuclear Material and Facility Stabilization program. For purposes of the 1996 Baseline Report, spent nuclear fuel is included in the Waste Management program's cost estimates and functional element discussion. Future reports will address spent nuclear fuel with the Nuclear Material and Facility Stabilization program.

Mission

The mission of the Nuclear Material and Facility Stabilization program consists of three primary elements: stabilizing and storing nuclear materials prior to final disposition, deactivating surplus facilities, and managing spent nuclear fuel treatment and storage. Integral within each element is a surveillance and maintenance function. Surveillance and maintenance encompasses all actions required to ensure that adequate material and facility safety and security requirements are met.

The program is responsible for a large number of geographically dispersed sites and facilities; large quantities of radioactive, hazardous, and toxic materials in a variety of chemical and physical forms and storage configurations; and an aging complex of processing and production facilities historically used for chemical and physical processing of many different types of nuclear material. The following summary of major facilities and materials that are under the purview of the Nuclear Material and Facility Stabilization program illustrates the breadth and complexity of the program's mission:

• 13 nuclear reactors;
• 41 radioactive processing facilities;
• approximately 3,000 surplus buildings contaminated with and generally containing radioactive, hazardous, and toxic materials;
• 39 million liters (10.1 million gallons) of acids containing radioactive contaminants;
• nearly 3,000 metric tons (3,300 tons)of spent nuclear fuel;
• several thousand kilograms of plutonium in various forms and locations;
• 37,000 packages of plutonium materials and related waste products;
• 75 million curies of cesium and strontium; and
• a large inventory of nuclear materials awaiting long-term storage and final disposition decisions.

Strategy

Nuclear material and facility stabilization activities manage and mitigate many of the urgent risks facing the Department. These risks are associated with a wide variety of materials and facilities, including various forms of plutonium, uranium and spent fuel; high-activity cesium capsules; aging facilities; hazardous chemicals; and special isotopes. The broad scope and potential impacts on the public and workers associated with these risks reinforce the need for risk-based planning to address the risks posed by the material and facilities.

Nuclear material and facility stabilization activities are also instrumental in reducing the overall scope of materials and facilities that the Environmental Management program must address. Because many special nuclear materials and surplus facilities require significant resource expenditures for maintenance in a safe and secure condition, the program's stabilization, consolidation, and material removal activities are essential to reduce the need for major facility systems and to reduce security perimeters (and other surveillance and maintenance requirements). These actions significantly decrease the annual cost required to maintain materials and facilities in a safe and secure manner, thereby reducing the estimated life-cycle cost of the Environmental Management program.

Nuclear Material Stabilization

The end of the Cold War resulted in an abrupt halt to nuclear material production facilities and reactor operations, leaving nuclear material in a variety of chemical and physical forms, packaging configurations, and geographical locations. Stabilization activities reduce near-term risks associated with current storage configurations by placing these materials in a condition that is suitable for long-term storage. The principal materials of concern include plutonium (solutions, metals, oxides, and residues), uranium (solutions, solids, and gaseous compounds) and special isotopes (americium, curium, neptunium, and plutonium-242). In some cases, stabilization also involves long-term storage of nuclear materials prior to their ultimate disposition.

Facility Deactivation

Upon completion of stabilization activities, the Department undertakes deactivation activities to remove materials, shut down facility systems, and remove or de-energize equipment. Deactivation activities reduce physical risks and hazards to the public, workers, and the environment by placing surplus facilities in a safe, stable condition. Once hazards associated with surplus facilities are mitigated, costs for maintaining the facilities can be significantly reduced.

Mission

Developing new technologies to address the environmental challenges in the former nuclear weapons complex is an integral part of the Environmental Management program. The mission of the technology development program is to develop new technologies that will allow the Department to reduce risks to people and the environment, reduce cleanup costs, and address environmental problems for which no solutions currently exist.

The Department has targeted five major remediation and waste management "focus areas" for action on the basis of risk, prevalence, or environmental requirements and regulations. (See the following box). The focus area strategy is to identify and develop specific technologies to clean up the nuclear weapons complex and manage waste more quickly, more safely, and at a lower cost, using the best capabilities available in industry, academia, and Department laboratories. Focus area management teams include stakeholders and representatives from across the Environmental Management program.

In 1996, the Department initiated an Environmental Management Science program to develop a targeted long-term basic research agenda for environmental problems. One of the goals of the program is to ensure that "transformational" or breakthrough approaches lead to significantly reduced cleanup costs and risks to workers and the public. The program will "bridge the gap" between broad fundamental research performed in the Department of Energy's Office of Energy Research, and needs-driven applied technology development historically conducted by the Environmental Management program. This effort will stimulate the nation's science infrastructure to focus on critical national environmental management problems. Also included in the Office of Science and Technology is the Risk Policy program. The goal of this program is to conduct and integrate risk management and analysis activities into the Environmental Management decisionmaking process.

In addition to the four major functional areas discussed above, the Environmental Management program must perform landlord (infrastructure support) activities that are both directly and indirectly related to its mission. Landlord functions include cross-cutting, site-wide activities such as managing electrical systems, laboratory support, road maintenance and upgrades, fire protection, quality assurance, safety and environmental monitoring, sanitary sewer systems, laundry services (for contaminated clothing and other materials), utilities, roadways, and security reviews. Landlord functions are required to keep communication, transportation, and security systems operational at environmental management sites and, in many cases, to meet environmental regulatory requirements.

Some of the sites under the purview of the Environmental Management program cover hundreds of miles of land, and contain hundreds of buildings and facilities. For example, the 1,450-square kilometer (560-square mile) Hanford Site in Washington State has its own fire department, security force, and medical center. The program maintains a utility infrastructure at Hanford that provides steam and sewage treatment, maintains grounds and roads, and provides onsite mass transit.

In some instances, the Environmental Management program has landlord responsibilities for entire sites. In general, infrastructure-related costs are typical at large sites where the majority of program costs are incurred. For example, Hanford Site, Idaho National Engineering Laboratory, Oak Ridge K-25 Site, Rocky Flats Environmental Technology Site, and the Savannah River Site have large landlord programs.

In addition to its presence at Department of Energy sites, the Environmental Management program performs several functions at Headquarters. These functions are primarily focused on planning, management, and oversight. Specific roles of Headquarters personnel include establishing policy and conducting program reviews to ensure adherence to policy; preparing program-wide budgets based upon field input; coordinating with Congress and other federal agencies; coordinating with national stakeholder organizations; managing national initiatives; overseeing site safety programs; establishing and tracking program performance measures; preparing national reports; and developing program strategic plans.

Construction of the first high-level waste tanks at Hanford Site, Washington, 1944. Designed for a useful life of 25 years, these tanks contain intensely radioactive acids and solvents resulting from reprocessing spent nuclear reactor fuel elements to extract plutonium and uranium. Approximately half of the 177 tanks were a "single shell", such as these, while others were "double shell" tanks. Because workers during the Cold War typically filled the tanks without sampling the waste and without recordkeeping that would meet today's standards, the Department is now undertaking a complex and hazardous effort to characterize the waste already in the tanks.

Installing a mixing pump in tank 101-SY at Hanford Site, Washington, 1993. This custom-built pump was critical in controlling the buildup of explosive gases in the tank, which was identified as one of the most urgent safety risks in the former nuclear weapons complex at the time. The ongoing cost for simply averting serious safety problems in these tanks is approximately $300 million per year. Beyond this routine safety operation, the Department is planning to remove the waste from the tank, which is the focus of a top-priority multibillion dollar, multidecade effort. The cost and complexity of dealing with these tanks provides excellent examples of the benefits of life-cycle planning and cost estimation. Characterizing the waste and treating it for disposal, after many years of storage, is significantly more expensive, complex, and hazardous than if the work was done as part of the production process.

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Appendix -A2- / -B- / -C- / -D- / -E1- / -E2- / -F- / -G- / -H- / Glossary