The U.S. Energy Department’s Office of Environmental Management should revamp its 2017 nuclear cleanup policy to make its remediation decisions more risk-informed, according to the Government Accountability Office (GAO).
Reports issued since the 1990s by the GAO and DOE’s Office of Inspector General, among others, urged the nuclear cleanup office, when making decisions about remediation, to “consider trade-offs among risk, costs, and other factors in the face of uncertainty and diverse stakeholder perspectives,” the congressional watchdog said in a just-released report.
However, the Energy Department seems to be making its environmental decisions on an ad-hoc basis, without considering the national scope of the cleanup mission, the GAO said. That includes absence of a list of the most pressing environmental projects within the weapons complex.
In an earlier report from January, the GAO said the Energy Department relies too much on officials at the 16 cleanup sites to develop their own remediation plans. What’s lacking is a well-defined policy that reduces risk to human health and safety, and to the environment, while also complying with relevant laws and court orders and trying to limit costs, according to the GAO’s latest findings.
After much research, and conferring with experts assembled by the National Academies of Sciences, Engineering, and Medicine, the GAO issued a risk-based “framework” to assist DOE in making all types of cleanup decisions. This four-part system should include phases for design, analysis, decision making, and implementation/evaluation.
The design phase defines the scope and goals of the decision-making process and identifies key stakeholders. The second phase involves analyzing how well each option could accomplish to the objectives. The third phase involves picking a preferred option and communicating the basis for the decision. The fourth phase entails analyzing how well each option performs with respect to the established objectives by using leading practices and setting up systems to monitor implementation.
Such a framework is lacking at the Energy Department, but it is needed because the agency accounts for more than 80% of the federal government’s $577 billion in 2018 environmental liability, the GAO said. Based on 2018 figures, the DOE nuclear cleanup office has an environmental liability of $377 billion, which the GAO noted is 40% more than the prior-year estimate of $268 billion.
Energy Department officials cite a variety of reasons for the rise, including mounting year-to-year costs of temporarily storing radioactive waste until it goes to a permanent disposal site; unplanned events, such as the May 2017 partial collapse of a waste-storage tunnel at the Hanford Site in Washington state; and the discovery of previously undocumented hazards at Cold War sites.
Drafting a policy to focus more on the highest-risk remediation projects would be most effective in curbing liability, the GAO said.
A 2017 DOE cleanup policy specifies who in the organizational chart is authorized to make decisions on remediation, but does not spell out how the agency can make its decisions more risk-based, its report says. The GAO wants the agency to fix this shortcoming.
The Energy Department has a risk management guide, but it mainly focuses on risks to a project rather than hazards to human health and the environment, the GAO said.
While most Energy Department Office of Environmental Management sites are regulated by either the 1980 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or the 1976 Resource Conservation and Recovery Act (RCRA), the agency lacks a policy on how to comply with those laws in a risk-informed way, GAO said.
The GAO recommended the energy secretary instruct the Office of Environmental Management to modify its 2017 cleanup policy in order to include basic risk-informed decision-making. The nuclear cleanup office should also develop a risk-based program management plan.
In his formal reply, included in the GAO document, DOE Senior Adviser for Environmental Management William (Ike) White said the department agrees in principle that a risk-informed approach is appropriate for remediation decisions. Risk is already a key factor in remediation planning under both CERCLA and RCRA, White added.
In addition, the Office of Environmental Management “recently reinvigorated efforts” to incorporate risk in its policy in a more consistent manner, White said. The updated policy documents recommended by GAO should be ready by Jan. 31, 2020, he wrote.
“This report makes clear that DOE must incorporate risk-informed decision-making in order to strengthen its cleanup program to protect communities and taxpayer dollars,” said a trio of congressional Republicans who requested the GAO study. Reps. Greg Walden (R-Ore.), John Shimkus (R-Ill.), and Fred Upton (R-Mich.) said in a joint statement they encourage DOE to implement the recommendations outlined in the GAO report.
