Distribution of the Measures of Success of the Streamlined Approach for Environmental Restoration Pilot Projects Report
MEMORANDUM FOR DISTRIBUTION
FROM: | | RICHARD J. GUIMOND |
| | ASSISTANT SURGEON GENERAL, USPHS |
| | PRINCIPAL DEPUTY ASSISTANT SECRETARY |
| | FOR ENVIRONMENTAL MANAGEMENT |
| | UNITED STATES DEPARTMENT OF ENERGY |
|
| | TIMOTHY FIELDS, JR. |
| | PRINCIPAL DEPUTY ASSISTANT ADMINISTRATOR |
| | OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE |
| | UNITED STATES ENVIRONMENTAL PROTECTION AGENCY |
|
|
|
SUBJECT: | | Distribution of the Measures of Success of the Streamlined Approach for |
| | Environmental Restoration Pilot Projects Report |
In February of 1993, the Department of Energy and the U.S. Environmental Protection Agency
agreed to jointly pilot the Streamlined Approach for Environmental Restoration at several sites
within the Department of Energy complex. Subsequently, operable units at Savannah River, Oak
Ridge, Mound, and Hanford were selected as the Streamlined Approach for Environmental
Restoration pilot projects. The attached report summarizes the results of the pilots through the end of fiscal year 1995.
The Department of Energy and the U.S. Environmental Protection Agency believe that the pilot
projects were successful in demonstrating that Department of Energy, U.S. Environmental
Protection Agency, and State personnel could work together to reduce the time lines and costs
associated with various remediation projects. The attached report reproduces letters from State
and U.S. Environmental Protection Agency Regional staff indicating the success of the pilots,
and several regulators have stated that they expect future environmental restoration projects at
the pilot facilities to be conducted using the Streamlined Approach for Environmental
Restoration process. Additionally, Department of Energy Headquarters has stated that the
Streamlined Approach for Environmental Restoration principles should be applied to all of the
Department's environmental restoration efforts and has requested that each of its Operations
Offices nominate a person to champion the use of the process. This person should, of course,
coordinate closely with regulators and other stakeholders. A listing of the champion for each
Operations Office is attached.
The success of the Department of Energy's environmental restoration efforts rests on its ability to
work as partners, using all the tools at its disposal to reduce risk to human health and the
environment as quickly and as efficiently as possible. Certainly the Streamlined Approach for
Environmental Restoration, based on the results of the pilot projects, is one such tool. Therefore,
we strongly encourage the broadest application of its principles.
For more information on the Streamlined Approach for Environmental Restoration or to request
additional copies of the attached report, please contact Claude Magnuson, Department of Energy
Headquarters, at (301) 903-7651. The U.S. Environmental Protection Agency's Headquarters
contact is Marianne Lynch, who may be reached at (202) 260-5686.
Attachments
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STREAMLINED APPROACH
FOR
ENVIRONMENTAL RESTORATION
(SAFER)
PILOT PROJECT
FINAL REPORT
EXECUTIVE SUMMARY
In conjunction with EPA, DOE initiated SAFER pilot projects at four DOE facilities: Savannah
River, Oak Ridge, Mound, and Hanford. Measures of success are summarized below.
SAFER PILOT PROJECTS
Savannah River Site - F-Area and H-Area Retention Basins
- Use of Data Quality Objectives (DQOs) and stakeholder participation facilitated use of
innovative technologies and streamlined data collection and analysis, resulting in reduced
sampling locations and avoided sampling characterization costs of $750,000 (97% cost
savings).
- Stakeholder participation allowed the regulators to feel comfortable using a computer
generated model (RESRAD), which limited the number of contaminants of concern and
avoided $450,000 in additional analytical costs. Use of the RESRAD model is now being
applied to other sites at SRS, resulting in significant potential savings.
- Stakeholder partnering resulted in regulators attending monthly scoping meetings on all
SRS projects.
Savannah River Site - D-Area Oil Seepage Basin
- Incorporation of the Expedited Site Characterization (ESC) allowed the Remedial
Investigation (RI) to begin in June, 1995, about five months before the scheduled start
date. The initial ESC field work was done without an approved work plan, due to
regulatory stakeholders working closely with the project team.
- The ESC RI field work was completed in four months, rather than the 11 months
generally scheduled for field work at SRS, for a total savings of 12 months attributable to
incorporating the ESC into the SAFER pilot project.
- The SRS team is combining the RI and FS report, and has taken on the goal of reducing
the overall schedule from the end of the RI field work to the Record of Decision by nine
months.
Oak Ridge National Laboratory (ORNL) - WAG I Surface Impoundments
- The combined RI/FS was submitted to the regulators for review in May 1995, one year
earlier than originally scheduled. ORNL estimates that at least $2.6 million in cost
savings resulted from the streamlined approach (i.e., merger of the RI and FS, and focus
of the data collection effort).
- Regulator attendance in project meetings has been extended formally to all restoration
projects at ORNL.
Mound - Building Solvent Storage Shed
- Development of a conceptual model that separated the shed demolition from the soil
removal activities resulted in at least four months savings.
- Uncertainty analysis eliminated the planned site characterization, resulting in cost savings
of $88,000 (54% cost savings) and project completion at least six months early.
- A contingency plan developed for the soil remediation removal action was implemented
without a work stoppage.
Mound - Area 7 Actinium Contaminated Soil Removal
- The conceptual model refocused the project from tank removal to contaminated soil
removal.
- Uncertainty analysis was used to eliminate the planned site characterization, saving
$300,000.
Mound - New Properties Transfer
- Decision rule logic demonstrated that the previously collected data were sufficient to
show the property was clean enough to transfer; additional data collection was
unnecessary.
- The land transfer strategy is being implemented for the balance of the targeted property.
Hanford - 100-BC-1
- Using conceptual models, contingency planning, and active regulator involvement, the
100-BC Area was successfully transitioned from the RI/FS stage to the RD/RA stage of
the response; initial remedial activities began on an accelerated schedule with a removal
action in June, 1995.
- The regulators were successfully integrated as active participants on the Extended Project
Team, creating an atmosphere that enabled real-time decision-making. Hanford estimates
that between February and June, 1995, at least two months and $200,000 were saved
because of increased efficiency and teamwork facilitated by the SAFER technical team.
- The SAFER tenet of early stakeholder involvement in the decision-making process has
been formally extended to the entire 100-BC Area.
OTHER NON-PILOT SAFER PROJECTS
Hanford 118-B-1 Burial Ground Treatability Study
- After a contentious year, integration of the regulators into the project team enabled
development within 5 days of a SOW with specified data requirements and objectives;
excavation began within 8 months and the test report was accepted by regulators without
changes.
Ventron Site (FUSRAP)
- The site characterization plan resulted in a 50 percent reduction in the number of samples
and analyses, and a commensurate reduction in the cost of site characterization.
OR Y-12 Bear Creek Valley Site
- The conceptual model, decision rules, and contingencies enabled the project team to
maximize use of existing data and accept and effectively manage higher levels of
uncertainty. OR estimates that $10.3 million was saved over four years (25% cost
savings), and the remediation schedule was reduced by at least two years (13%).
REGULATORS' RESPONSE
- SAFER is an effective communication tool. It provides an opportunity for regulators to
really understand what DOE is doing and why. Dennis Faulk, EPA RPM Region 10.
- SAFER is a smart way to do business. It has had a good impact thus far. Ed Carraras,
EPA RPM Region 4.
- The SAFER process resulted in better data, better decisions, and better solutions. Keith
Collinsworth, SCDBEC.
- SAFER removes politics from the decision-making process. It builds team spirit and
provides an opportunity to voice concerns. Ted Wooley, Washington Dept. of Ecology.
- EPA views the DOE SAFER concept as a successful approach to environmental
restoration activities. Jon D. Johnston, Federal Facilities Branch Chief, EPA Region 4.
SAFER PILOT PROJECTS
FINAL REPORT
January 1996
1. INTRODUCTION
Traditional approaches to environmental restoration can be very time consuming and can apply
resources inefficiently. In an atmosphere of severe budget reductions and high visibility, DOE is
under increasing pressure to streamline its environmental restoration process while remaining in
compliance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
and other applicable regulations promulgated under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) and the Resource Conservation and
Recovery Act (RCRA).
The Department of Energy (DOE) developed the Streamlined Approach for Environmental
Restoration (SAFER) to help address the challenges of environmental restoration conducted
under conditions of significant uncertainty and to help reduce the time and resources traditionally
required to cleanup a hazardous waste site. SAFER integrates the strengths of the Observational
Approach and the Data Quality Objectives (DQOs) process developed by the U.S. Environmental
Protection Agency (EPA) to form a comprehensive methodology. The five essential elements of
SAFER are:
- Use of a dynamic conceptual model as the foundation for remedial planning and action;
- Early convergence on the exact problem(s) that are to be solved;
- Reliance on a "learn-as-you-go" approach enabling a bias for action;
- Incorporation of specific techniques to optimize technical management and reduce
uncertainty (i.e., decision rules, reasonable deviations, contingencies); and
- Explicit recognition of the need for stakeholders to be involved in decision-making
throughout the project.
The DQO process defines the problem and action requiring attention, and defines the type and
quality of data needed for problem resolution. The Observational Approach provides the
operational framework for managing uncertainty and planning decisions. Regulator involvement
in all key decisions and increased communication among all the participants enable project teams
to identify acceptable remedial alternatives to specific problems, including decision rules and
contingencies, that address the exposure pathways and contaminants of concern, and reduce the
likelihood that extensive revisions and rethinking will be needed over time.
STREAMLINING EFFORTS AT DOE
Different aspects of the SAFER process have been in use for several years throughout the DOE
complex and at other hazardous waste sites throughout the nation. For example, the DQO
approach was originally developed and used by EPA in environmental data quality assurance.
EPA has published several guidance documents on the DQO approach. The Observational
Approach is a basic geotechnical engineering technique. The name was first associated with the
technique more than 25 years ago, and EPA has published several directives that discuss
implementing the approach during environmental restoration projects.
SAFER is unique, however, in that it integrates the DQO and Observational Approach, adding
the dimension of early and active regulator involvement, to formalize a dynamic method for
addressing the challenges of uncertainties inherent in environmental restoration. Active regulator
involvement at staff project meetings is critical to the formation of an effective Extended Project
Team, where regulators, DOE, and site contractors have an opportunity to be introduced to the
site details and challenges, can identify issues and raise concerns at critical junctures, and can
help formulate a solution.
SAFER operates in an aggressive, yet cost effective and efficient manner that complies
with existing environmental regulations and
is consistent with Federal Facility
Agreements (FFAs) and Consent Orders. It is
applicable to both the characterization stages
and the design and implementation stages of
the response, and can be used within a
CERCLA or RCRA regulatory context.
"SAFER is an effective communication tool. It brings in different view points and enables the Extended Project Team to reach a consensus. It provides an opportunity for regulators to really understand what DOE is doing and why." -Dennis Faulk, EPA RPM Region 10
3. DEVELOPMENT OF SAFER AT DOE
The SAFER approach to environmental restoration is the product of a collaborative effort by four
different offices within DOE: the Office of Environmental Policy and Assistance [EH-41] within
the Environment, Safety and Health organizations and the Office of Environmental Restoration
[EM-40], the Office of Transportation, Emergency Management and Analytical Services
[EM-76], and the Office of Environmental Activities [EM-22] within the Environmental
Management organization. DOE has worked for several years to develop and continually
improve the SAFER process, providing workshops to disseminate the concepts, and helping to
implement SAFER at various sites.
In 1992, DOE approached EPA with the idea of testing SAFER on a pilot scale. The primary
objectives of the pilot study would be to (1) implement and evaluate SAFER at DOE sites, and
identify reactions, both positive and negative, by DOE field personnel, contractors, and
stakeholders to implementing SAFER broadly throughout the DOE complex; and (2) teach
SAFER to DOE field management and contractors so that the SAFER tenets may successfully be
applied at other DOE sites.
EPA agreed to jointly pilot SAFER, but requested that DOE nominate pilot sites that satisfied the
following criteria:
- The pilot projects must be part of National Priorities List (NPL) sites.
- DOE, EPA, and cognizant State authorities must all agree on candidate projects.
- The DOE Field Office must have signature authority for primary deliverables, including
proposed plans and Records of Decision.
DOE agreed, and in January 1994, the DOE Deputy Assistant Secretary for Environmental
Restoration selected four DOE facilities to host the SAFER pilot projects: Savannah River Site
(SRS) in South Carolina; Oak Ridge National Laboratory (ORNL) in Tennessee; Mound Plant in
Ohio; and Hanford in Washington. ORNL and Hanford each hosted one SAFER pilot; SRS
hosted two SAFER pilots; and Mound hosted three SAFER pilots. The SAFER pilot projects
were conducted at varying stages in the remedial process: the Mound pilot projects included two
removal actions and one land transfer, while the other pilot projects were in the remedial
investigation/feasibility study (RI/FS) stage or the remedial design/remedial action (RD/RA)
stage of the response.
4. LESSONS LEARNED FROM THE PILOTS
In general, DOE project managers, M&O contractors, and Federal and State regulators agree that
the use of SAFER has succeeded in improving the way DOE has traditionally performed its
environmental response activities. In the course of piloting SAFER, however, some very
valuable lessons were learned; they are summarized below.
- SAFER's ultimate success depends upon having a "champion" to drive the process on
each project. It is essential that someone at each site be available to maintain the focus
and momentum, and to carry through on decisions. Without DOE field acceptance and
ultimate implementation by the field team, none of the accomplishments attributed herein
to SAFER would have been realized. In addition, the degree to which the regulators are
involved contributes greatly to the success of the project.
"SAFER is an effective communication tool. It brings in different view points and enables the Extended Project Team to reach a consensus. It provides an opportunity for regulators to really understand what DOE is doing, and why" - Dennis Faulk, EPA RPM Region 10
"For SAFER to be succesful in the long run, there must be resistance to the ever-present urge to take shortcuts in the scoping process" - Harry Boston, Lockheed Martin
- Consensus building, a crucial part of SAFER, can be a frustrating and time
consuming process. However,
investment up front at the scoping
stage of a project will generally yield
significant savings later in terms of
shorter review and revision cycles and
a final product that satisfies
everyone's concerns. Project meetings should be sufficiently documented so that valuable
time is not lost in rethinking issues that had been resolved previously.
- The full benefits of SAFER will not be realized if the success of streamlining the data
collection and analysis process is not translated into schedule reductions. Time savings
are more important generally than cost savings to the regulators at DOE sites, because
their primary function is to get results quickly. They may be unwilling to continue to
invest significant time up front in the scoping and characterization stages of the response
if savings are not translated into faster remediation.
- The DOE budget process makes long term planning and use of contingencies difficult,
and generally does not reward efficiency. In one case, budgetary uncertainties distorted
the decision-making process and caused the site team to be unwilling to commit to
accelerating the schedule with respect to the FFA milestones. Several regulators also
expressed strong concern and frustration over the DOE budget process. SAFER would be
easier to implement throughout the complex if the budgetary process was more flexible
and predictable.
5. PILOT SUMMARIES
Each of the pilot projects described below have been supported by a technical team of experts in
the CERCLA response process. The SAFER technical team played the role of advisors to DOE
field management and their supporting contractor teams. DOE Headquarters spent $1.4 million in
conducting the SAFER pilots. These expenditures generally covered the costs for travel to the
different sites by the SAFER technical team and the time devoted by the team to scoping and
implementation activities at the sites.
5.1 SAVANNAH RIVER SITE
The Savannah River Site (SRS) had two SAFER pilot projects at the RI stage of a CERCLA
response action: the F-Area and H-Area Retention Basins, and the D-Area Oil Seepage Basin.
The scope and results of each pilot are discussed separately below.
F-Area and H-Area Retention Basins
Site Description
The F-Area Retention Basin (FARB) and H-Area Retention Basin (HARB) were designed to
receive contaminated cooling water caused by radiological separation system upsets resulting
from cooling system leaks. The contaminated cooling water was delivered from the separations
operations complex to the unlined basins through large diameter (24 - 36 inch) process pipelines.
The FARB process pipeline is approximately 2,000 linear feet; the HARB process pipeline is
approximately 3,000 linear feet. Part of the HARB process line is still operational, however, and
all but 60 feet of the line is outside the scope of the pilot project.
FARB and HARB were operational for more than three decades. Releases to the environment
occurred in the basins and potentially at leaks along the process pipelines. On a few occasions,
the basins overflowed and released volumes of contaminated cooling water into nearby streams.
The primary contaminants of concern are radionuclides, specifically Cs-137 and Sr-90.
Use of FARB and HARB was discontinued in the late 1970s when cooling water upsets were
diverted to a new lined retention basin. The contaminated soils and sludge from the FARB were
excavated at that time in compliance with the environmental restoration standards of the 1970s.
Data collected during the original cleanup of FARB suggested that Sr-90 and Cs-137 had
migrated into the soils underlying the basins. Although data show that Sr-90, the more mobile of
the two radionuclides, had migrated about two meters into the soil column, the threat to
groundwater at FARB appears to be minimal because groundwater levels are 16 to 20 meters
below the surface level.
Unlike FARB, HARB has not been previously excavated, and vegetation and trees now cover the
basin and surrounding berm. Access to the HARB and overflow areas is restricted to minimize
exposure to high radionuclide concentrations, which are estimated to be greater than 10 mren/hr
at several locations. At times, the HARB contains standing water, reflecting the relatively high
groundwater level (i.e., 3 to 4 meters below the surface).
Remediation Progress
When the pilot began at this site, SRS had compiled an extensive list of potential contaminants
of concern and sought help in developing a streamlined site characterization plan that would
successfully identify the true contaminants of concern and areas of contamination.
- Early stakeholder involvement facilitated the use and acceptance of the RESRAD model
to estimate the migration of radioactive contaminants through soil. Through use of
RESRAD, DOE was able to significantly reduce the number of radioactive contaminants
of concern.
- Similarly, consensus building and integration of the regulators in early project scoping
meetings facilitated the use of innovative technologies, including a robotic pipecrawler
and a hydropunch. The pipecrawler remotely photographed the process pipeline,
identifying potentially contaminated areas (e.g., areas near pipeline joints and cracks).
The hydropunch facilitated the collection of soil and water samples. Following the tenet
of stakeholder participation, all interested parties were able to talk about and feel more
comfortable with the use of the innovative technologies.
- The fact that State and EPA regulators were active participants in the early decision
making stage of this pilot afforded timely and valuable insights into their issues and
concerns, allowing the project team to refocus their activities and limit false starts.
"The upfront investments of time resulted in a better (more efficient/less costly) RL. Although funds were cut and the overall schedule was not shortened, the processresulted in better data, better decisions, and better solutions." Keith Collinsworth, SCDHEC
- Based on the derived limited list of
contaminants of concern, three
separate sampling plans were
developed: the HARB sampling plan
was used to define the boundaries and
magnitude of contamination; the
FARB plan focused on confirmatory
sampling and boundary determination;
and the process pipeline plan
primarily focused on areas of concern
identified by the pipecrawler.
- Budgetary cuts independent of the pilot caused activities at FARB and HARB to be
discontinued after the work plans were completed; no further activities have been
scheduled at the basins. Data were collected and analyzed according to the sampling and
analysis plans described above, but no results have been circulated to date and the
remedial alternatives have not been fully scoped.
Measures of Success
"We made more progress in the one DQO meeting on FARB and HARB than we made in all our other efforts last year." Carl Froede, EPA RPM Region 4
- Uncertainty analysis allowed DOE to
eliminate characterization of
groundwater and the berm around
HARB. DOE conceded that there was
extensive contamination, and
additional characterization would add
little if anything to the remedy
selection process and would needlessly expose workers to high doses of radiation.
- Development of decision rules and consensus building in stakeholder meetings created a
forum that facilitated the use of innovative technologies and allowed DOE to minimize
the number of samples taken around the FARB process line. By developing a reasonable
and technologically innovative approach to identifying potential areas of concern, DOE
was able to limit the number of samples to those around man-hole covers and pipe areas
shown by the pipecrawler to be disconnected.
- SRS estimates that use of the robotic pipecrawler alone resulted in a reduction in the
number of sampling locations from 325 to 11; about $750,000 in site characterization
costs were avoided.
- Use of the RESRAD computer model enabled the site team to limit the number of
contaminants of concern, reducing analytical costs by as much as $450,000. Application
of the RESRAD model has been extended to other applicable sites at SRS, resulting in a
significant potential for additional cost savings.
- The work plans were submitted to the regulators on schedule and within budget. They
were returned to DOE within six weeks with only minor editorial comments that could
easily and quickly be incorporated into the final documents.
- SCDHEC acknowledged that State soil cleanup levels had not existed prior to the pilot,
and there were no national guidelines. The lack of cleanup levels slowed down the
remediation process and frustrated decision-making. The pilot forced SCDHEC to
develop soil cleanup levels that could be used as cleanup goals for CERCLA actions,
RCRA Corrective Actions, tank removals, etc, improving the efficiency of all response
actions at SM.
It has become a habit to do things the SAFER way at SRS - even if it's not always called SAFER." Keith Collinsworth, SCDHEC
- Scoping work plans with the
regulators, developing conceptual
models, creating contingencies and
decision rules, etc., are now part of
standard operating procedures at SRS.
- The State regulators believe that
SAFER creates a process that results in a significant improvement in their understanding
of the issues, facilitates early decision-making, and encourages consensus building. The
State and EPA are very receptive to continuing the implementation of SAFER at SRS.
D-Area Oil Seepage Basin
Site Description
The D-Area Oil Seepage Basin is in the RI stage of a CERCLA response. Constructed in 1952,
the basin is a 40,000 sq. ft. area containing at least three unlined 8-ft. deep trenches that were
used for disposal of waste oil from D-Area powerhouse operations, nonbumable waste (e.g.,
paint cans, drums, metal objects, and concrete), and burnable solid waste (e.g., office trash and
cafeteria waste). Waste oil was poured into the trenches and burned periodically, along with
other waste, until 1973, when open burning ceased plant-wide.
In 1975, the D-Area Oil Seepage Basin was removed from service and backfilled with soil.
Approximately one foot of standing liquid and an unknown number of 55-gallon drums remained
in the basin when it was filled. Historical soil samples indicate the presence of volatile organic
compounds, semi-volatile organic compounds, and metals.
Groundwater elevations fluctuate seasonally within the basin; the groundwater is within the
trenches during periods of high water, and can be six feet below the bottom of the trenches
during periods of low water. A "Carolina bay" and a wetlands area are present within 200 feet of
the basin. Compounds detected to date in the four groundwater monitoring wells include volatile
organic and inorganic compounds.
Prior to the acceptance of the D-Area Oil Seepage Basin as a SAFER pilot, the site had planned
an Interim Action for the Spring of 1995 that had a relatively narrow scope: removal of 55 gallon
drums in the basin and replacement of the disturbed soil back into the trenches. Limited data
collected in 1993 revealed no high risks from the soil; therefore, after removing the drums, SRS
planned to put the soil back in the basin without further analysis.
Remediation Progress
- The Interim Action was postponed because of inclement weather and high water tables.
SRS proceeded with the previously planned Expedited Site Characterization (ESC).
- The regulators and the project team agreed to a bifurcated sampling plan for the basin,
separating the soil characterization into the vadose zone (defined to be ground surface to
four ft. depth) and the saturated zone (defined to be soil below four feet). This bifurcation
enabled the project team to focus on areas of concern (i.e., residents and groundwater
contamination, respectively).
- Articulation of the conceptual site model helped regulators to agree that it was
inappropriate to use preliminary remediation goals (PRGs) as decision thresholds for
contaminants in soil below four feet in depth. Instead, it was agreed that ESC would be
used in two stages to characterize soils in the saturated zone. Phase I would determine if
the contaminants in the saturated zone continue to be a source of groundwater
contamination; if so, Phase 2 would determine if the rate of leaching poses an
unacceptable risk.
Measures of Success
- Incorporation of the ESC into the pilot project allowed the RI investigation to begin in
June, 1995, about five months before the scheduled start date. The initial ESC field work
was done without an approved work plan, due to regulatory stakeholders working closely
with the project team.
- The ESC RI field work was completed in four months, rather than the 11 months
generally scheduled for field work at SRS. The RI work plan was based on the problem,
decisions, and decision rules formulated by the SAFER technical team.
- The SRS team is combining the RI and FS report, and has taken on the goal of reducing
the overall schedule from the end of the RI field work to the Record of Decision by nine
months.
- The different elements of the soils sampling plan focused on the potential exposure
pathways identified in the conceptual model (i.e., contaminated surface soil and the
potential to contaminate groundwater). The sampling approach designed for the
wetlands/surface water would confirm the existence of a problem prior to designing an
extensive investigation of the area.
- SRS has committed to do a preliminary scoping of the FS between the two phases of the
ESC so that FS data needs can be incorporated into the data collection activities planned
for phase 2.
5.2 OAK RIDGE NATIONAL LABORATORY (ORNL)
Waste Area Group (WAG) 1 Surface Impoundments
Site Description
The ORNL SAFER pilot began at the RI/FS stage of a CERCLA response action. The pilot
project focused on the WAG I surface impoundments, which consist of two lined and two
unlined surface impoundments located adjacent to a stream in the highly industrialized main
plant area of ORNL. The surface impoundments were used to store liquid, low-level, mixed
wastes that were generated during ORNL operations in 1945 through 1976.
Substantial historical data on the impoundments were available prior to the onset of the pilot.
The data document historical operational activities, and historical and recent groundwater, soil,
and sediment sampling in the vicinity of the impoundments and adjacent areas. The surface
impoundments are underlain by contaminated groundwater and one impoundment is in contact
with the bedrock. Continued release of contaminants from the unlined impoundments into the
groundwater and surface water is a virtual certainty.
The impoundments are contaminated with radionuclides, including Sr-90 and tritium, which are
of particular concern because of their mobility in groundwater. Pu-239, Pu-240, Cs-137, and
other radionuclides are contained in the sludge and sediments. U-233 may be present in the
impoundments, but its presence has not been documented through analysis. PAH, heavy metals,
and polychlorinated biphenyls are also contained in the impoundments.
Remediation Progress
- ORNL has been using DQOs and the Observational Approach independently for many
years. There was little resistance, therefore, to integrating the two approaches under
SAFER. All participants were very receptive and willing to work with the SAFER
technical team.
- Coordination was a potential problem at OR because many different contractors are
involved in each of the remedial stages. The SAFER technical team facilitated
communication among the different project contractors, minimizing potential schedule
slippages and facilitating the integration of the RI and the FS.
- Initially, the Tennessee regulators became fully integrated members of the project team.
A State regulator attended all project staff meetings, and provided valuable into the
specific type of information the State wanted to see in the RI/FS to enable them to fully
evaluate the remedial alternatives under consideration. State participation at the working
level fostered a greater understanding of the issues and concerns of the State, the public,
and DOE, and created a cooperative working relationship that minimized confrontations
and maximized consensus building. Unfortunately, about two-thirds into the pilot project,
the State regulator who had been attending the pilot project staff meetings left the Oak
Ridge office and was not replaced.
Sometimes at a DOE site, the letter of the law obscures the intent of the law. SAFER helps us do what makes sense." Elizabeth Krispen, ORNL Project Manager
- The conceptual model helped
establish a common understanding of
the mission through early
development of the problem statement
and remedial objectives, and continual
reevaluation of the model in response
to changing information.
- Uncertainty analysis enabled the site project team to identify a limited set of data needed
to analyze the feasibility of remedial alternatives, and to eliminate collection of all other
data or postpone the collection until the design stage of the remediation.
Measures of Success
For SAFER to be successful, the project team must be able to manage change and document how decisions were reached. They must be willing to learn as they go, with continuous team involvement and updates." Harry Boston, Lockheed Martin
- The bias for action created a working
atmosphere that allowed DOE to
produce a streamlined RI/FS,
eliminating development of a full RI
work plan and avoiding review cycles
and redundancies inherent in separate
RI and FS reports. The scoping
workshops resulted in a focused and
abbreviated RI work plan, and
facilitated early initiation of field
work.
- The RI/FS was submitted to the regulators for review in May 1995, one year earlier than
originally scheduled. ORNL estimates that at least $2.6 million in cost savings resulted
from the streamlined approach (i.e., merger of the RI and FS, and focus of the data
collection effort).
5.3 MOUND
July 26, 1995
James M. Owendorff, Acting Deputy
Assistant Secretary, Environmental Protection Agency
1000 Independence Ave, SW
Washington, DC 20585
Re: Streamlined Approach for Environmental Restoration
Dear Mr. Owendorff
The Environmental Protection Agency (EPA) and the South Carolina Department of Health and Environmental Control (SCDHEC) recently participated in a meeting held in Salt Lake City, Utah, where we discussed the Department of Energy (DOE) Environmental Restoration special initiative Streamlined Approach for Environmental Restoration (SAFER). Several of these SAFER projects occurred in EPA Region 4. We discussed the success of this approach and shared in the lessons learned from the various projects. EPA and the various states have worked with DOE in applying the SAFER concepts at both the Oak Ridge Reservation and Savannah River site (SRS),
EPA views the DOE SAFER concept as a successful approach to environmental restoration activities. Additionally, at a recent SRS Workout meeting held in Rock Hill, SC, the DOE SAFER approach was identified as a positive way of streamlining environmental restoration and cleanup. We will continue to support DOW initiatives which show both time and cost savings. It is our hope that you will continue to encourage the implementation of concepts such as SAFER in environmental restoration activities.
Sincerely,
Jon D. Johnston, Chief
Fed Facilities Branch
Waste Management Division
The Mound Plant hosted three SAFER pilot
projects. Two of the projects were removal
actions: (1) the B Building Solvent Storage
Shed and (2) Area 7 Actinium Contaminated
Soil Removal. Because these projects were
removal actions, regulator involvement was
minimal; however, Mound has decided to rely on the SAFER
concepts to help establish priorities for
remediation and will involve the regulators
and introduce them to SAFER. The third
project, New Properties Transfer, was a land
transfer project. Each pilot is discussed
below.
"SAFER has never been adequately explained to this regulating body. There is confusion as to what SAFER means and what it is supposed to accomplish" - Doug McCoy, TDEC
B Building Solvent Storage Shed
Site Description
The B Building solvent storage shed pilot
included the demolition of the shed and
remediation of contaminated soil in a 5,500
square foot area. Historically, the B Building
storage shed was used to store waste and
product-grade solvents from B Building.
Waste solvent was pumped into 55-gallon
drums from B Building through discharge
hoses equipped with automatic shutoff
devices. The drums were then sealed and
stored in the shed. Prior to construction of
the storage shed, solvents were stored in 5-gallon cans inside the B Building and in 55-gallon
drums in an outdoor storage area located adjacent to the shed.
The scope of the original removal action called for complete site characterization, removal of the
shed, and use of soil vapor extraction (SVE) to remove the contaminants from the soil. One of
the reasons for the characterization effort was to focus on determining the depth to bedrock to
ensure the feasibility of the SVE technology.
Remediation Progress
- The conceptual model and matrix of probable conditions, possible deviations, and
contingencies were used to demonstrate that there was no need for further site
characterization prior to beginning the SVE. A simple arid cost-effective contingency
plan was identified that could be implemented quickly in the field if it was determined
that the depth to bedrock was insufficient for the SVE system to operate effectively at
certain wellheads.
- The conceptual model helped the project team separate demolition of the shed from
remediation of the soil. By separating the demolition from other aspects of the removal
action, on-site staff could be utilized and typical on-site D&D procedures followed to
remove the shed. This enabled the removal action to focus on contamination issues in the
soil.
- Both EPA and the State of Ohio have determined that the B-Area soil is sufficiently
clean; the removal action is complete.
Measures of Success
- Because the solvent shed was separated from the soil remediation, implementation of
SVE operations could be accelerated by at least four months.
- Mound estimates that elimination of the planned site characterization and integration of
the design and characterization stages of the response resulted in a cost savings of
$88,000 (54 percent of the original cost proposal), and completion of the project at least
six months ahead of schedule.
- Based on uncertainty analysis, a contingency plan was implemented during the SVE
operations to address lower than optimal depths to bedrock. The plan was implemented
without any delays or work stoppages.
Area 7 Actinium Contaminated Soil Removal
Site Description
Mound's Area 7 was historically used to deposit construction debris, thorium drums, and other
wastes. In 1959, soil contaminated with Ac-227 and Ra-226 was deposited near an abandoned
septic tank that was located near Building 29 in the northeast section of Area 7. The septic tank
historically had received only sanitary waste from the administrative buildings at the Mound
Plant between 1946 and 1952. The septic tank was taken out of service and abandoned in 1952.
The exact location of the septic tank was not known when the project began.
Information gleaned from plant staff interviews and limited written records indicated that three
dump-truck loads of contaminated soil were deposited in or around the abandoned septic tank.
Results from previous sampling efforts showed elevated levels of Ac-227 and Ra-226 in the soil
near the suspected location of the abandoned septic tank, as well as elevated levels of Ra-226 in
the soil downgradient from the suspected location of the abandoned septic tank.
Prior to commencement of the pilot, the response action was focusing on removal of the septic
tank, rather than the contaminated soil. A full site characterization was proposed to locate the
tank prior to implementing the response.
Remediation Progress
- The conceptual model helped to focus the response action on the contaminated soil
instead of the tank. This refocused effort made a significant difference in the nature and
scope of the removal action, enabling the project team to focus on the elements of the site
that posed a threat to human health and the environment.
- The site team and SAFER technical team worked together to develop the basic design
approach, removal goals, and preliminary decision rules. The conceptual model became
the basis of a revised action memorandum and work plan.
- The Area 7 soil excavation removal action is now complete.
Measures of Success
- The conceptual model helped to refocus the removal action from tank removal to
contaminated soil removal, making it unnecessary to locate the tank prior to commencing
action. (The location of the boundaries of the contaminated soil was already known.)
- Through careful planning and analysis of uncertainties, the site team became convinced
that the originally proposed site characterization, estimated to cost more than $300,000,
was not necessary prior to implementing the response.
- DOE Mound credits the SAFER technical team with significantly improving the technical
quality of the work plan, resulting in increased clarity of technical issues and
implementable design parameters.
New Properties Transfer
Site Description
The New Properties site consisted of property that was purchased in 1981 as a buffer area
between the Mound Plant and the City of Miamisburg, Ohio. No DOE operations were ever
conducted on the "new Properties." Prior to DOE ownership, the new properties were used as
agricultural land. DOE now wants to release the new properties to the City of Miamisburg for
industrial development.
Thorium redrumming was performed at the Mound Plant in an area adjacent to the new
properties. The thorium redrumming activities, which include the handling and disposal of
thorium, are well documented. Previous sampling efforts indicated the potential for limited
migration of thorium onto the new properties. No other potential releases of hazardous
substances are known.
Remediation Progress
- The SAFER technical team developed a land transfer strategy for the new properties and
identified a formal approval method (i.e., "Intent to transfer" letter) that ultimately led to
formal EPA approval of the property transfer. The transfer strategy suggested a phased
approach: transfer of the clean area to precede transfer of the potentially contaminated
area.
- By fully integrating the City of Miamisburg as a key stakeholder in the decision-making
process, Mound was able to receive timely feedback and approval of its land transfer
strategy.
- Decision-rule logic was applied to confirm data sufficiency for determining that the first
500 ft. were sufficiently clean to transfer without further action.
Measures of Success
- EPA has approved transfer of the Mound property to the City of Miamisburg. This
property transfer represents DOE's first successful effort at certifying property as clean
and receiving approval from EPA to relinquish responsibility to a local municipality.
"The Fact the HQ was willing to send good people to help us in the field was very much appreciated" - Art Kleinrath, DOE Mound
- Mound and the City of Miamisburg
were so satisfied with the land transfer
strategy that Mound has requested
additional assistance to support the
transfer of the balance of the property.
The SAFER technical team has been
asked to help develop the risk assessment strategy and future data collection requirements
for the remaining property.
5.4 HANFORD
Site Description
The 100-BC Reactor Area was selected as the Hanford SAFER pilot site. The 100-BC Reactor
Area contains two source OUs, 100-BC-1 and 100-BC-2, and one groundwater OU, 100-BC-5.
The 100-BC OUs were listed on the NPL in 1989.
The 100-BC OUs are located approximately 30 miles northwest of the city of Richland,
Washington, on the shoreline of the Columbia River. The 100-BC-5 groundwater OU underlies
the 100-BC-1 and 100-BC-2 source OUs, which together comprise the entire 100-BC Reactor
Area. Groundwater flows directly into the Columbia River, which is approximately one-half mile
from the B and C reactors.
The Hanford SAFER pilot focused specifically on one of the OUs contained within the 100-BC
Area: the reactor liquid effluent OU, 100-BC-1. The 100-BC-1 OU received liquid and solid
wastes resulting from the B Reactor operations, and contains 44 individual waste sites. These
waste sites include cribs, trenches, retention basins, burial grounds, pipelines, river outfall
structures, and septic tanks. Contaminants of concern are fission products (primarily Cs-137,
Co-60, Sr-90, Eu-152, and Eu-154), metals (Cr), and inorganics (nitrous oxide). The l00-BC-1
OU received approximately 183 million liters of radioactive/hazardous liquid wastes and 40
cubic meters of solid waste.
The FFA between DOE, EPA, and Washington Department of Ecology incorporates the
provision that all of the OUs in the 100-BC Area be grouped together and addressed
comprehensively in one RI/FS, ROD, and Remedial Design. When the pilot began, the 100-BC
Area was transitioning from the RI/FS stage to the RD/RA stage of the response.
Remediation Progress
- DOE, EPA, and the State agreed to use a two-pronged approach to resolving some of the
uncertainties inherent in the remediation of the 100-BC Area. The first stage of the
response would require a demonstration project using CERCLA removal authority; the
second stage would include development of an overall design document for the 100-BC
Area.
- The demonstration project was designed to help bracket the costs and limit the
uncertainties inherent in the response actions. The SAFER technical team helped to
develop and design the scope of the demonstration project. Remediation goals and
decision rules were developed; an uncertainty management plan, including potential
deviations and contingencies, was developed to help manage the uncertainty inherent in
the removal action.
- The demonstration project, which encompassed three waste sites, met all its objectives.
The site team now fully acknowledges the value of uncertainty management, including
the identification of potential deviations and contingencies. Although such a plan had
been developed prior to implementation of the demonstration project, the plan was never
incorporated into the field operations. Several of the deviations identified in the plan
actually materialized during the demonstration project; implementation of the
contingencies would have eliminated the need for a month and a half long work stoppage.
"The SAFER team is an invaluable sounding board, providing insights into HQ guidance and experiences at other DOE sites" - "Rick Donahoe, Remedial Design Team, Lead for BC-100 Reactors
- The second stage of the response will
rely on a comprehensive remedial
design of the 100-BC Area. The
design is scheduled for completion in
March, 1996, and relies heavily on the
conceptual model and decision rules
developed by the Extended Project
Team. Information gathered during
the demonstration project is feeding directly into the design document.
Measures of Success
"SAFER removes politices from the decision-making process. It builds team spirit and provides and opportunity to voice concerns. DOE has moved more quickly because of SAFER." - Ted Wooley, Washington Dept. of Ecology
- The regulators were an integral part of
the Extended Project Team for the
100-BC Area response. Such a high
value was placed on early and active
stakeholder involvement that
formalized partnering has now been
extended to the entire 100-BC Area.
- As a result of decision rules and the
role played by the SAFER technical team, the demonstration project was completed on
schedule; they expect to complete the overall design document in March, 1996.
"Since February 1995, at least two months have been saved because of SAFER and the SAFER technical team. The confidences that ERC, DOE, and the regulators have in SAFER allows us to sit down together and come to resolution quickly." - Rick Donohoe, Remidial Design Team, Lead for 100-BC reactors.
6. OTHER NON-PILOT SAFER ACTIVITIES
There are at least three other sites that
were not formally part of the SAFER
pilots, but nonetheless used SAFER
tenets to ensure remedial progress. These
sites are discussed in this report because
they help illustrate SAFER's broad
applicability and high success rate. The
three projects discussed below are: (1) the
Ventron FUSRAP Site; (2) a solid waste
burial ground at Hanford (118-B-1); and (3) the Bear Creek Valley Site at Y-12 in Oak Ridge.
These three SAFER-supported projects do not fit neatly into the SAFER pilot criteria agreed
upon between EPA and DOE. The Ventron site is not listed on the NPL; the 118-B-1 project was
a treatability study; the Bear Creek Valley Site was implemented independently by Oak Ridge,
without delegated signature authority to the Oak Ridge Field Office. In addition, the Idaho
National Engineering Laboratory (INEL) "Bias for Action" is summarized briefly as an
illustration of other streamlining approaches being implemented at sites throughout the DOE
complex.
6.1 HANFORD 118-11-1 BURIAL GROUND TREATABILITY STUDY
Site Description
The 118-B-1 Burial Ground at Hanford
consists of approximately 20 trenches in a
seven-acre parcel. The Burial Grounds were
used primarily as a disposal site for
radiologically contaminated wastes from the
105-B Reactor at Hanford, although historical
records indicate that the Burial Ground
contains a great variety of waste forms. Some
of the wastes were segregated into specific
trenches during disposal. Typical specific
wastes reported to be present in the Burial
Ground include aluminum tubing; gloves,
booties, and other personal protective
clothing; lead and steel piping; lead shielding
and bricks; and paper and cardboard.
EPA requested that DOE perform a
treatability study on this site to determine the
feasibility of excavating, analytically
screening, and handling 5,000 to 10,000 cubic
yards of waste material, while relying on
existing technologies. The 118-B-1 Burial
Ground was selected for the study because of
the availability of historical data for the site
and because the site was believed to be
representative of other primary-use burial
grounds in the 100 Area.
Remediation Progress
- Decision rules were used to develop a
consensus on the inappropriateness of
digging pits to determine the depth
and boundaries of the contamination
at the Burial Ground.
- Stakeholder involvement and
consensus building were used to reach
agreement on the Statement of Work
(SOW) for the treatability study. The conceptual model enabled DOE to maintain the
focus of the SOW on determining the feasibility of mechanically excavating and
separating different waste forms at the site.
- Consensus building helped achieve concurrence on the treatability test plan and test
procedures needed to train work crews prior to initiation of field work.
Measures of Success
- The SOW had been in contention for more than a year. By utilizing the SAFER tenets, a
binding work scope agreement was developed within five days that included clearly
defined assumptions upon which to develop costs and schedules. Very few changes in
the test plan and procedures were required due to the well defined work scope.
- Translation of the conceptual model into field activity was able to occur on an
unprecedented schedule. The work scope concept was finalized in January, 1994, and
excavation into the highly radioactive burial ground began in August, 1994.
-
The contribution to the treatability
study SOW was so significant that
similar assistance was requested from
the SAFER technical team to address
issues at two N Reactor trenches.
6.2 VENTRON SITE (FUSRAP)
Site Description
The three-acre Ventron site, in Beverly, Massachusetts, was used from 1942 to 1948 to produce
uranium metal from uranium oxide and other materials. Radioactive contamination of soils,
interior and exterior building surfaces, and equipment surfaces were initially addressed through a
decontamination and decommissioning (D&D) effort in 1948, which cleaned the site to the
environmental standards that prevailed at that time. Two subsequent radioactivity surveys (1977
and 1980), however, indicated contamination remained above current FUSRAP standards. A site
characterization plan drafted in March, 1992, proposed an extensive sampling and analysis effort
aimed at generally characterizing the residual contamination at the site.
Remediation Progress
- A conceptual model and uncertainty analysis were used in August, 1992, to revise the
characterization plan. Several boring holes and soil samples were eliminated or postponed
until the buildings located above the contaminated soil were scheduled to be demolished.
Similarly, visual evidence of cracked floors and other tell-tale signs were relied on to
identify likely areas of contamination.
Measures of Success
- The SAFER tenets produced a better targeted and less expensive site characterization
plan that would provide a greater understanding of the site for less resources. By focusing
on specific data needs, it was possible to eliminate certain types of samples, such as those
taken generally around drains and sumps.
- The revised characterization plan resulted in a 35 percent reduction in the number of
samples and a commensurate reduction in the cost of the site characterization.
6.3 BEAR CREEK VALLEY SITE - Y-12 PLANT OAK RIDGE
Site Description
Bear Creek Valley, located to the west of the Y- 12 Plant on the Oak Ridge Reservation, is the
site of eight waste disposal areas that were in operation from the early 1940s through the
mid-1980s. The Valley has contaminated soil, groundwater, surface water, and sediments. Until
recently, contaminated sites in Bear Creek Valley had been categorized into two types of
operable units: source term OUs that addressed the waste disposal areas, and an integrator OU
that addressed contamination that had migrated from the sources to environmental media.
Because of the complexity of the interactions between the source term and integrator OUs, it was
difficult to evaluate the OUs independently.
Remediation Progress
- A revised conceptual model consolidated the OUs in Bear Creek Valley to incorporate all
waste disposal areas, soils, groundwater, surface water, and sediments.
- Priorities for action could now be based on relative risk to human health and the
environment, and inconsistent and potentially technically unsound actions could be
avoided.
- The RI/FS for the new OU is being expedited by moving forward with existing data.
Measures of Success
- OR estimates that $10.3 million was saved over four years, and the remediation schedule
was reduced by at least two years through the use of the revised conceptual model,
decision rules, and contingency planning, which enabled the project team to maximize
use of existing data, and accept and effectively manage higher levels of uncertainty.
6.4 THE INEL "BIAS FOR ACTION" APPROACH
In addition to SAFER, other streamlining approaches to environmental restoration are being
implemented at sites throughout the DOE complex. The environmental restoration program at the
Idaho National Engineering Laboratory (INEL) is one example. The INEL program includes the
key elements of SAFER: application of DQOs and the Observational Approach during
assessment and cleanup; frequent interaction with regulators and other stakeholders; and a bias
for action to cleanup facilities as quickly as possible.
Using its SAFER-like streamlined approach, INEL met all 27 FFA-enforceable milestones
required through the end of FY94.
7. SUMMARY AND CONCLUSIONS
The SAFER pilots have shown to varying degrees that use of the SAFER tenets can make a
significant difference in the way environmental restoration is implemented throughout the DOE
complex. Each of these pilots were in different stages of response and presented different
challenges, but all were successful to some extent in saving time and money and in improving
the decision-making process. Federal and State regulators have expressed unanimous support for
the SAFER process, and are especially pleased with the opportunity to provide early input and
obtain a fuller understanding of the site decisions.
The SAFER pilots demonstrated several important lessons:
- Early communication of issues and concerns held by regulators and site personnel
facilitates consensus building;
- Consensus building among all stakeholders is critical to ensuring that false starts are
minimized and that ultimate approval is obtained;
- SAFER helps to focus on, and in some cases, separate complex issues in a manner that
expedites cleanup;
- SAFER helps ensure that the availability of or need for data that could directly benefit
characterization of the critical issues at the site is documented; and
- Success ultimately depends on the existence of a "champion" at the site capable of
successfully driving the SAFER process.
U.S. DEPARTMENT OF ENERGY
POINTS-OF-CONTACT TO CHAMPION THE PRINCIPLES OF THE
STREAMLINED APPROACH FOR ENVIRONMENTAL RESTORATION
ALBUQUERQUE | JULIANNE LEVINGS | (505) 845-6201 |
OPERATIONS OFFICE |
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GRAND JUNCTION | MARY ANN RONDINELLA | (970) 248-6077 |
PROJECTS OFFICE |
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CHICAGO | JIM PAULSON | (708) 252-2770 |
OPERATIONS OFFICE |
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FERNALD | SUE PETERMAN | (513) 648-3179 |
AREA OFFICE |
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IDAHO | NOLAN JENSEN | (208) 526-0436 |
OPERATIONS OFFICE |
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NEVADA | SABINE CURTIS | (702) 295-0542 |
OPERATIONS OFFICE |
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OAKLAND | MIKE BROWN | (510) 423-7061 |
OPERATIONS OFFICE |
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OAK RIDGE | DAVE CARDEN | (615) 576-9262 |
OPERATIONS OFFICE |
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OHIO | SUE SMILEY | (513) 865-3987 |
FIELD OFFICE |
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RICHLAND | NANCY WERDEL | (509) 376-5500 |
OPERATIONS OFFICE |
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ROCKY FLATS | STEVE TOWER | (303) 966-2133 |
FIELD OFFICE |
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SAVANNAH RIVER | BRIAN HENNESSEY | (803) 725-7032 |
OPERATIONS OFFICE |
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