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DOE OSTI2020

A Comparison of RESRAD and GoldSim Models for Assessing Radiological Dose for a RCRA Landfill - 20418

US Ecology Idaho (USEI) operates a Resource Conservation and Recovery Act (RCRA) Subtitle C, Hazardous Waste Treatment, Storage, and Disposal (TSD) Facility on a 640-acre property in Owyhee County, Idaho. USEI accepts a wide variety of RCRA-exempt low activity radioactive wastes, including naturally occurring radioactive material (NORM) and technologically enhanced NORM (TENORM) (USEI 2009). The performance of the landfill with regard to radiological operating permit requirements was previously assessed using a model constructed with the residual radioactivity (RESRAD) computer program, developed by Argonne National Laboratory for the U.S. Department of Energy (DOE). RESRAD supports the evaluation of several environmental transport pathways related to a radionuclide-contaminated soil source term, but it was not conceived as a model for the evaluation of landfill radiological performance. A more comprehensive and realistic model is desired in order to better support submissions to both the State of Idaho's Department of Environmental Quality as well as the U.S. Nuclear Regulatory Commission. A Performance Assessment (PA) computer model was developed using GoldSim software for the USEI RCRA Subtitle C landfill. The RESRAD computer model was specifically developed for calculating soil cleanup criteria and radiological dose and cancer risk from residual radioactive material in soil. To evaluate site-specific conditions, users may select from among a number of available environmental transport and exposure pathways and modify 'default' parameter values. In GoldSim, a user must construct the model 'from scratch.' However, this modeling is facilitated by a number of specialized elements available in GoldSim to support a radiological mass transport model. These include elements for defining radiological decay and ingrowth, container failure and radiological release, advective and diffusive transport, and other processes. Advantages afforded by the use of RESRAD for modeling radiological dose for a RCRA Subtitle C landfill include ease of use and reasonable flexibility in specifying site-specific conditions. GoldSim allows for considerably more flexibility and site-specificity than RESRAD, including evaluation of potentially relevant environmental transport processes not supported in RESRAD. The probabilistic modeling capabilities of GoldSim also far exceed those of RESRAD. The pros and cons of RESRAD and GoldSim for this modeling problem are explored with a focus on identifying approaches and critical factors in identifying the appropriate platform. The capabilities of RESRAD and GoldSim for mathematically modeling the disposal system will be contrasted and compared. For example, the existing RESRAD radiological safety assessment evaluated potentially complete exposure pathways related to infiltration to groundwater and upwards diffusion of radon. Additional transport pathways identified in the USEI Idaho facility Conceptual Site Model include deposition of radon decay products in cover material, root uptake of radionuclides in disposed wastes by native plants, and mixing of cover material by burrowing animals. Results of the two models and how the different transport and dose pathways affect results will be discussed. (authors)

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DOE OSTI2019

The Post-Closure Inspection Report For Closed Non- Resource Conservation And Recovery Act (RCRA) Corrective Action Units (CAUs) On The Nevada National Security Site (NNSS), For Calendar Year 2018

This letter serves as the Calendar Year 2018 post-closure inspection letter report for the following Non-RCRA CAUs located on the NNSS, including CAUs located on the Nevada Test and Training Range (NTTR) that are accessed through the NNSS Main Gate. Use restriction issues that were identified in the 2017 inspections were addressed in 2018.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2019

HWMA RCRA Storage and Treatment Permit for the Material and Fuels Complex on the Idaho National Laboratory

Owners and operators of facilities that treat, store, and dispose of hazardous waste must obtain an operating permit required by Subtitle C of the Resource Conservation and Recovery Act (RCRA). The operating permit for the Materials and Fuels Complex is the Hazardous Waste Management Act (HWMA)/RCRA Storage and Treatment Permit. The permit defines the conditions and requirements that apply to the treatment and storage of hazardous waste managed at the treatment, storage and disposal facilities (TSDF). The regulations governing the permitting process are found at 40 CFR Pa 124 and 270.

99 GENERAL AND MISCELLANEOUS↗
DOE OSTI2025

Physical and Hydraulic Properties of RCRA Borehole Samples from the Hanford Site : Final Report, Fiscal Years 2023-2024

Sediment from 44 core samples collected from Resource Conservation and Recovery Act (RCRA) boreholes drilled in the 200 East and 200 West areas of the Hanford Site were characterized for physical and hydraulic properties (Table S.1). Characterization data included gravimetric water contents and matric potentials, grain-size distributions, saturated hydraulic conductivity, water retention characteristics, and unsaturated hydraulic conductivity. These properties provide site-specific data and parameters that can be used in subsurface flow and contaminant transport models to assess the transport and fate of contaminants in the vadose zone and underlying aquifer systems. The analyzed core samples come from specific areas and depth intervals at the Hanford Site that were targeted for sampling to address data gaps identified by site contractors (Khaleel 2020). X-ray computed tomography (XCT) was used to evaluate the general textural characteristics of the samples and to determine which samples to use for further physical and hydraulic property characterization. Subsequent sample selection was determined by consensus after review of the XCT images by Pacific Northwest National Laboratory, Central Plateau Cleanup Company, and INTERA staff.

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DOE OSTI2020

Post-Closure Inspection Letter Report for Closed Non-Resource Conservation and Recovery Act (RCRA) Corrective Action Units (CAUs) On the Nevada National Security Site (NNSS), For Calendar Year 2019, With Errata Sheet

Post-Closure inspection letter report for the following CAUs for calendar year 2019 including CAUs located on the Nevada Test and Training Range (NTTR) that are accessed through the NNSS Main Gate. Use restriction issues that were identified in 2018 inspections were addressed in 2019.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2021

Post-Closure Inspection (PCI) Letter Report for Closed Non-Resource Conservation and Recovery Act (RCRA) Corrective Action Units (CAUs) on the Nevada National Security Site (NNSS), for Calendar Year (CY) 2020

This letter report is for the following CAUs for CY 2020, including CAUs located on the Nevada Test and Training Range (NTTR) that are accessed through the NNSS Main Gate. Use restriction (UR) issues that were identified in the 2019 inspections were addressed in 2020.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2023

Addendum 2 to the Closure Report for CAU 577 Area 5 Chromium Containing Waste Disposal Cells, NNSS, Nevada

Corrective Action Unit (CAU) 577, “Area 5 Chromium Containing Waste Disposal Cells,” includes five low-level waste cells at the Nevada National Security Site Area 5 Radioactive Waste Management Site where buried waste received from Nuclear Fuel Services, Inc., was subsequently determined to contain chromium that exceeded the toxicity characteristic leaching procedure regulatory limit, which would require the waste to carry hazardous waste code D007. CAU 577 was created to satisfy the requirements of the Settlement Agreement (SA) executed between the Nevada Division of Environmental Protection (NDEP) and the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office (NNSA/NFO) on April 25, 2019 (NDEP 2019). The SA required that the chromium-containing waste received from NFS would be addressed following the closure process laid out in the Federal Facility Agreement and Consent Order (FFACO). The FFACO process ensures proper closure of the chromium-containing waste and documentation of that closure through FFACO-type documents. The following three Corrective Action Sites (CASs) were closed, and their closure was documented in the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030, dated September 2021 (U.S. Department of Energy [DOE] Environmental Management [EM] Nevada Program 2021a): • CAS 05-21-02, Waste Disposal Cell 12 • CAS 05-21-03, Waste Disposal Cell 15 • CAS 05-21-04, Waste Disposal Cell 17 Closure of the following CAS was previously documented in the Addendum to the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030-ADD, dated September 2022 (DOE EM Nevada Program 2022): • CAS 05-21-05, Waste Disposal Cell 20 This second addendum to the Closure Report documents the closure activities that have occurred for CAS 05-21-06, Waste Disposal Cell 21. This is the last CAS in CAU 577. The final waste shipment was placed in the waste disposal cell on November 21, 2022. Following this, closure activities began on November 28, 2022, and were conducted according to the Corrective Action Decision Document/Corrective Action Plan (CADD/CAP) for CAU 577 (DOE EM Nevada Program 2021b). The following closure activities were performed: • Constructing an engineered evapotranspiration cover • Installing two subsidence monuments and vadose zone monitoring equipment • Seeding the cover with a mixture of native plant species • Installing four concrete monuments on the corners of the cover and placing two use restriction (UR) warning signs on each monument These activities fulfill applicable federal and state regulations for closure of CAS 05-21-06 and minimize potential future exposure pathways to buried waste. Completed closure activities are also consistent with closure of the nine historical Resource Conservation and Recovery Act (RCRA) units included in Section 10.2.2 of the RCRA Permit that governs hazardous waste management activities at the Nevada National Security Site (Permit NEV HW0101) (NDEP 2023). UR documentation for this CAS is included in Appendix B of this report. The post-closure plan is presented in detail in the CADD/CAP for CAU 577 (DOE EM Nevada Program 2021b), and the requirements are summarized in Section 5.2 of this document. In accordance with paragraph 5D of the SA, a request to incorporate the requirements for post-closure monitoring of CAU 577 was included with the permit application for RCRA Permit NEV HW0101 that was submitted in January 2022 (NNSA/NFO 2022). The request included the post-closure requirements for the three CASs that had been closed at the time of submittal of the application as well as requirements that would be implemented upon future approval of closure of the remaining two CASs. All CAU 577 post-closure monitoring requirements have been captured in the April 4, 2023, Revision 7 of the RCRA Permit (NDEP 2023). As the RCRA Permit NEV HW0101 has been revised since the submittal of the original CAU 577 Closure Report (DOE EM Nevada Program 2021a) and Addendum 1 (DOE EM Nevada Program 2022), the post-closure requirements in this Addendum 2 report do not align with the previous documents. Specific changes resulting from the issuance of Revision 7 of the RCRA Permit are discussed in Section 5.2 of this report. The requirements in this report are consistent with the current permit (NDEP 2023) and supersede all requirements listed in the CAU 577 Closure Report and Addendum 1. All CAU 577 post-closure requirements should be conducted in accordance with the version of the RCRA Permit that is current at the time of the activities being performed. The DOE EM Nevada Program is requesting a Notice of Completion from NDEP for closure of CAU 577. Although CAU 577 is not a legacy site, the FFACO process is being followed to ensure proper closure of the chromium-containing waste. Therefore, transfer of CAU 577 from Appendix III of the FFACO to Appendix IV, Closed Corrective Action Units, is requested, as all closure activities have been completed.

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DOE OSTI2019

Path of Disposal for Hazardous and Non-hazardous Waste from Cradle to Grave

Hazardous waste is a threat to human health and the environment and must be managed and disposed of properly. A Solid Waste is defined as any material (solid, liquid, containerized gas) which has been discarded, abandoned (no longer needed), or recycled. The Resource Conservation Recovery Act (RCRA) is a law that creates the framework for the proper management of solid waste. Under RCRA, EPA has developed a program which ensures hazardous waste is managed safely from the moment it is generated to its final disposal (cradle-to-grave)2. To educate about how waste is handled at the Savannah River Research Campus (SRRC) under RCRA, the path it takes from point of generation (cradle) to disposal (grave), and the responsibilities of every person involved in the process. Researcher or other laboratory personnel that generates waste as a result of their work Responsibilities: - Fill out inventory log sheet and corresponding container sheet which includes the constituents of the waste; - Properly label waste container with SAA/WSA ID no., generator's name, what it is, the hazards, and date; - Place waste in designated waste storage area. Laboratory Custodian Responsibilities: - Ensures waste is handled and stored properly; - Ensures inventory is updated; - Ensures all container sheets are completed; - Ensures only authorized personal have access to waste storage areas. Environmental Compliance Authority Responsibilities: - Develops waste procedures; - Provide waste training; - Inspects for improperly handled waste; - Establishes or closes waste storage areas as needed; - Determines if waste can be recycled; - Determines if waste is RCRA hazardous: Is it U or P listed? - Unused commercial chemical products; Is it F listed - Spent solvents; Is it characteristic? - Flammable/Oxidizer, Corrosive, Reactive, Toxic; - Weighs waste to ensure laboratory has not exceeded its monthly or total storage limits; - Maintains waste records; - Determines how waste should be disposed: Trash - Nonhazardous solids; Drain - Nonhazardous Liquids; Labpack; - Prepares waste for shipment with Vendor and Department of Transportation (DOT) personnel. Packages, Transports, and Treats Hazardous Waste Responsibilities: - Must be EPA permitted and approved by the Department of Energy - Picks up hazardous waste for transport to a treatment, storage or disposal facility depending on waste disposal requirements - Must meet all Department of Transportation regulations for transporting hazardous waste - Dispose of waste according to RCRA regulations. Due to the potential risks to human health and the environment, waste must be handled safely through the chain of possession from cradle to grave. To ensure proper handling, there are many safety checks as required by RCRA and DOT regulations. This includes proper labeling, inventory, and characterization to ensure all hazards are known, inspections by the Custodian, ECA, and the state regulator (SCDHEC), and transportation verifications and manifesting. One of the best ways to reduce the risks that waste presents is to minimize or eliminate the creation of waste. This can be accomplished through source reduction which includes: Inventory control, material substitution, process modification, improved housekeeping, and preventative maintenance and recycling.

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DOE OSTI2022

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada (CY2021)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): CAU 90, Area 2 Bitcutter Containment, CAU 91, Area 3 U-3fi Injection Well, CAU 92, Area 6 Decon Pond Facility, CAU 110, Area 3 WMD U-3ax/bl Crater, CAU 111, Area 5 WMD Retired Mixed Waste Pits, and CAU 112, Area 23 Hazardous Waste Trenches. This report covers calendar year 2021. The post-closure requirements for these sites are described in RCRA Permit NEV HW0101 and are summarized in each CAU-specific section of this report. The results of the inspections, a summary of maintenance activities, and an evaluation of monitoring data are presented in this report. This report will address all monitoring requirements noted in the RCRA Permit NEV HW0101, except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site. All required inspections, maintenance, and monitoring were conducted in accordance with the post-closure requirements of the permit. Revision 6 of RCRA Permit NEV HW0101 was issued effective December 10, 2015, and remained in effect until December 10, 2020. At the time of this report submittal, the new RCRA permit application was in review.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2021

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada: For Calendar Year 2020 (Rev. 2)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): 1) CAU 90, Area 2 Bitcutter Containment; 2) CAU 91, Area 3 U-3fi Injection Well; 3) CAU 92, Area 6 Decon Pond Facility; 4) CAU 110, Area 3 WMD U-3ax/bl Crater; 5) CAU 111, Area 5 WMD Retired Mixed Waste Pits; 6) CAU 112, Area 23 Hazardous Waste Trenches The locations of the sites are shown in Figure ES-1. This report covers calendar year 2020. The post-closure requirements for these sites are described in RCRA Permit NEV HW0101 and are summarized in each CAU-specific section of this report. The results of the inspections, a summary of maintenance activities, and an evaluation of monitoring data are presented in this report. Site inspections are conducted annually at CAUs 90, 91, and 112; semiannually at CAUs 92 and 110; and quarterly at CAU 111. Additional inspections are conducted at CAUs 92 and 111 if precipitation occurs in excess of 1.0 inch in a 24-hour period. Inspections include an evaluation of the condition of the units, including covers, fences, signs, gates, and locks. At CAUs 110 and 111, soil moisture monitoring and subsidence surveys are conducted in addition to the visual inspections. At CAU 110, the site fence, gate, lock, and use restriction signs are evaluated. At CAU 111, an ecological survey, direct radiation monitoring, air monitoring, radon flux monitoring, and groundwater monitoring are also conducted. This report will address all monitoring item notes above except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site. All required inspections, maintenance, and monitoring were conducted in accordance with the post-closure requirements of the permit. Revision 6 of RCRA Permit NEV HW0101 was issued effective December 10, 2015, and remained in effect until December 10, 2020. At the time of this report submittal, the new RCRA permit application was in review.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2019

Nevada National Security Site 2018 Data Report: Groundwater Monitoring Program, Area 5 Radioactive Waste Management Site

This report is a compilation of the groundwater and waste cell leachate sampling results from the Area 5 Radioactive Waste Management Site (RWMS) at the Nevada National Security Site, Nye County, Nevada. Groundwater samples from the aquifer immediately below the Area 5 RWMS have been collected and analyzed and static water levels have been measured in this aquifer since 1993. These groundwater data are evaluated for evidence of effects on the aquifer related to the Area 5 RWMS. Leachate from one lined mixed waste cell at the Area 5 RWMS (Cell 18) has been sampled since the cell opened in 2011. These leachate data are analyzed for hazardous contaminants to determine appropriate leachate handling and disposal. A second lined mixed waste cell at the Area 5 RWMS (Cell 25) began receiving waste in August 2018, but no leachate samples were collected or analyzed during 2018. This report includes data from 2014 through 2018 but focuses on the 2018 data. During 2018, groundwater samples were collected and static water levels were measured at three wells surrounding the Area 5 RWMS. Groundwater samples were collected at wells UE5PW-1, UE5PW-2, and UE5PW-3 on March 6 and August 14, 2018. Static water levels were measured at each of these wells on March 5, June 4, August 13, and October 25, 2018. Groundwater monitoring at the Area 5 RWMS complies with Title 40 Code of Federal Regulations (CFR) Part 264.97, General ground-water monitoring requirements , and 40 CFR 264.98, Detection monitoring program. Groundwater samples were analyzed for indicators of contamination (pH, specific conductance [SC], total organic carbon, total organic halides, and tritium) and, beginning in 2017, toxicity characteristic metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver). General water chemistry parameters (calcium, iron, magnesium, manganese, potassium, sodium, sulfate, chloride, fluoride, bicarbonate, and silicate) were also measured. Results from samples collected in 2018 are within the limits for each parameter established by the Nevada Division of Environmental Protection in Resource Conservation and Recovery Act (RCRA) Permit NEV HW0101, Revision 6. Data from the shallow aquifer indicate there has been no measurable impact to the uppermost aquifer from the Area 5 RWMS, and there were no significant changes in measured groundwater parameters compared to previous years. Leachate from lined mixed waste Cell 18 drains into a sump and is pumped into an above ground tank. Samples are collected from the tank when the leachate volume approaches the 3,000-gallon tank capacity. During 2018, leachate samples were collected on March 1, 2018 and August 1, 2018. All leachate analysis results are below the regulatory levels for toxicity characteristic contaminants (40 CFR 261.24) and below the investigation levels for polychlorinated biphenyls (PCBs), tritium, pH, and SC specified in RCRA Permit NEV HW0101, Revision 6. No quantifiable PCB levels were detected in any leachate sample. Based on the leachate analysis results, RCRA Permit NEV HW0101 allowed all leachate collected from Cell 18 to be pumped from the collection tank and used for dust control at Cell 18.

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DOE OSTI2019

Y-12 Groundwater Protection Program CY 2018 Triennial Report of the Monitoring Well Inspection and Maintenance Program Y-12 National Security Complex Oak Ridge, Tennessee

This document is the Triennial Report for the Well Inspection and Maintenance Program of the Y-12 National Security Complex (Y-12) Groundwater Protection Program (GWPP) at U.S. Department of Energy (DOE) Y-12 and includes monitoring well inspections and well maintenance activities performed at Y-12 during calendar years (CYs) 2016 through 2018. This report formally documents well inspections completed by GWPP on active and inactive groundwater monitoring wells that are part of the Y-12 monitoring network and includes well inspections performed by URS|CH2M Oak Ridge, L.L.C. (UCOR), which administers the DOE Office of Environmental Management Y-12 Water Resources Restoration Program (WRRP). The WRRP includes wells that are utilized for the regulatory monitoring of Resource Conservation and Recovery Act (RCRA) post-closure permits and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Remedial Effectiveness and Records of Decision and Solid Waste Disposal Facility (Landfill) permits and includes monitoring wells located at the CERCLA Environmental Management Waste Management Facility. Beginning in 2018, UCOR terminated three of their RCRA post-closure permits and is monitoring the former RCRA-permitted facilities under CERCLA. Consequently, the number of monitoring wells in the Y-12 network that receive UCOR-performed inspections has decreased significantly.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2019

Deactivation and Demolition (D and D) of the Toxic Substance Control Act (TSCA) Incinerator Oak Ridge, Tennessee - 19184

UCOR, an AECOM-led partnership with Jacobs, manages the cleanup of the 2,200-acre East Tennessee Technology Park for its client, the U.S. Department of Energy (DOE), in Oak Ridge, Tennessee. The site was contaminated with radioactive, hazardous and industrial wastes generated by more than 40 years of national defense and energy missions. In 1989, the U.S. Environmental Protection Agency (EPA) added the Oak Ridge Reservation to the National Priorities List of sites and facilities that pose a sufficient threat to human health or the environment to warrant cleanup. The U.S. Department of Energy is cleaning up the Oak Ridge Reservation under a Federal Facility Agreement with the EPA and the Tennessee Department of Environment and Conservation. Many types of waste have been managed and disposed as part of the multi-decade cleanup effort. One unique facility, the Toxic Substance Control Act (TSCA) Incinerator, was constructed at the Department of Energy's Est Tennessee Technology Park (ETTP) in Oak Ridge, Tennessee. The Incinerator was constructed in the mid-1980's and underwent a series of test burns and readiness reviews to obtain the necessary environmental permits and operating approvals from state and federal regulatory agencies. With these in place, the incinerator began routine operations in 1991. It was designed and permitted for receiving, sorting, storing, preparing, and thermally destroying low-level radioactive and RCRA mixed waste contaminated with PCBs. The incinerator was named after a law passed in 1976 that provides the U.S. Environmental Protection Agency with authority to require reporting, record-keeping, testing, and restrictions relating to chemical substances and/or mixtures. During its operating lifetime, the one-of-a-kind thermal treatment facility burned materials regulated under TSCA and the Resource Conservation and Recovery Act (RCRA), most notably radiologically-contaminated polychlorinated biphenyls (PCBs). The TSCA Incinerator met or exceeded environmental regulations and DOE requirements for the treatment of these types of wastes. After more than 18 years of operation and more than 35 million pounds of waste safely incinerated, the TSCA Incinerator shut down operations on December 2, 2009. The TSCA Incinerator has been called a national resource for DOE sites from coast to coast. As the only U.S. facility permitted to incinerate specialized types of wastes, it not only accepted material from the Oak Ridge Reservation but also other facilities across the nationwide DOE complex. Over the years, a dynamic team of hard working and talented people operated and maintained the facility under the most stringent environmental permits and site requirements. The facility has played a key role in the treatment of radioactive PCB and hazardous wastes (mixed wastes) from the Oak Ridge Reservation, as well as from other facilities across the DOE complex. Through its support to over 20 sites in the DOE complex, environmental waste from past and ongoing operations has been safely and permanently treated. In the years since it was shut down, deactivation workers have been preparing TSCA for demolition. This work scope included triple cleaning, rinsing of all production equipment and tanks to RCRA clean criteria, filling sumps, encapsulating PCB and radioactive contamination, removal of universal waste (asbestos. lead and mercury), draining and disposal of residual water in tanks and transfer piping, and removing and disposing of carbon vessels, which were part of the water management system. In 2018, the facility was successfully deactivated and demolished, permanently removing one of the most unique facilities in the DOE complex. (authors)

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DOE OSTI2020

Stakeholder-Engaged Structured Decision Making for the Los Alamos Legacy Cleanup Mission - 20501

The Los Alamos National Laboratory (LANL) environmental legacy cleanup program requires decisions to be made for environmental remediation, decommissioning and disposal or management of radioactive waste. This legacy cleanup program was established to address groundwater contamination, material disposal areas (MDAs) that have been used to dispose of radioactive and other waste material, and 'aggregate areas' that might produce radioactive or other chemical waste as a result of remediation activities. The LANL site is regulated for environmental concerns under the Resource Conservation and Recovery Act (RCRA). However, some parts of LANL, such as material disposal area G (MDA G), have disposed of radioactive waste under DOE Order 435.1, and are subject to other regulations. For example, decommissioning the remote-handled TRU material stored in 33 shafts at MDA G falls under EPA's 40 CFR 191. Collectively, the regulations are all aimed in the same direction of finding the best solution, either through constructs such as 'as low as reasonably achievable' (ALARA), considering balancing factors as opposed to only cost and human health risk, and, under EPA regulations such as RCRA and NEPA, evaluating impact from all chemicals and both human health and ecological endpoints. Despite the basic goals and objectives of the regulations or their guidance, the main challenge is in their implementation. Arguably perhaps, but really in principle, all of these (and similar) regulations are asking for a decision analysis to be performed. Implementation challenges encountered have included lack of understanding of decision analysis in the industry, lack of effective stakeholder engagement in the decision analysis process, and lack of appreciation of the need to separate value judgments from science, the latter leading to developing conservative, or protective, science-based models. Conservative models lead to poor solutions, lack of effective stakeholder engagement leads to long drawn out protracted approaches to finding a solution (which also might never be found with this approach), and lack of understanding of decision analysis and Bayesian statistics causes poor models to be built, which creates unfortunate situations of 'garbage in, garbage out' becoming the basis for decision making. Stakeholder-engaged structured decision making (SDM) is an approach to solving problems that relies on the theory of decision science to involve stakeholders in the decision-making process. This approach incorporates stakeholder values using a scientifically rigorous methodology that separates value judgments from science in a way that helps avoid the pitfalls of biased, protective, or conservative modeling. This approach has its foundation in Keeney's 1992 treatise on value-focused thinking [1]. Keeney advocated a paradigm shift in decision making based on the idea that the standard way of thinking about decisions is backwards. The standard approach of focusing first on identifying alternatives rather than on articulating values results in a reactive approach with the emphasis on mechanics and fixed choices instead of the core values that have meaning to stakeholders. This paradigm shift effectively engages all stakeholders in the decision-making process while using a values focused thinking approach that can lead to the identification of decision opportunities and the creation of better alternatives. The intent is to be proactive and generate solutions that are related directly to values and objectives as identified by stakeholders. There are, perhaps, two overarching reasons why SDM can be used to benefit LANL's environmental legacy cleanup. Some of LANL's remaining waste management and environmental management problems are challenging and complex (for example, the Cr and RDX plumes, and MDAs) and while the traditional approach has, arguably, worked well for relatively simple risk-based problems, it cannot, or should not, be applied to more complex problems if the most effective and efficient solutions are desired. The second reason is cost. This has perhaps become more critical since publication of the Government Accountability Office (GAO) reports that DoE's environmental liability is considered a high-risk concern for the nation [2]. The focus of SDM is on structuring solutions to decision risk problems by first addressing stakeholder and decision maker values and subsequently developing decision objectives and ways to measure those objectives, preference weighting across objectives, identifying decision alternatives that best achieve those values, and characterizing uncertainty in predictions of the measures. Because a complete decision model is created using SDM, it can be evaluated to find the main elements of the model that drive, or predict, the best solution. This approach creates complete decision models that are transparent, traceable, reproducible and technically defensible. The science behind SDM, or decision analysis, is well founded, yet it is not unusual to see ad hoc approaches to decision making implemented under various environmental regulations that are pertinent to the LANL site, including NEPA, RCRA and DOE Order 435.1. Such ad hoc approaches are often not transparent or traceable, and lack reproducibility and technical defensibility. The LANL legacy cleanup program has embarked on using SDM to address the complex problems that remain. Stakeholder meetings have been held, and a prototype version of the stakeholder value system has been developed. Further meetings are expected in the future to address specific project needs. This is a long-term endeavor considering the complex environmental problems faced by DOE EM in Los Alamos (EM-LA), and careful planning, consideration of stakeholder value systems, and engagement with stakeholders throughout the SDM process is expected to lead to a successful endpoint. (authors)

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