Infrastructure issues and technology approaches for
achieving successful “rolling stewardship”
Case studies and lessons learned by Legacy Management
Dave Geiser
Director, Office of Legacy Management
US Department of Energy
January 10, 2014
“Rolling Stewardship” – A process of analysis, evaluation, and
action to maintain remedy protection.
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“Created” by the National Environmental Policy Institute in 1999. Rolling Stewardship builds on
the concept of “stewardship” by focusing on the links needed between generations to carry
long-term stewardship forward.
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The current generation cannot determine the actions future generations will take, but it can
ensure that the next generation is aware of remaining risks and is handed the tools to make
sound and protective decisions.
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Rolling stewardship requires a framework for decisions that can be tailored over time, and
empowers each generation with greater information on stewardship tools and practices.
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The rationale is that there are too many imponderables, in terms of planning for conditions
many decades in the future, to make decisions today that will be effective many generations
from now.
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Rolling stewardship allows greater flexibility, yet ensures there is an infrastructure in place to
empower the next generation of decision-makers. This approach focuses onto practical issues
that we can carry out today with some assurance of success. “Will the solution remain viable
for a generation?” rather than, will it be viable for the next millennium and beyond.
Department of Energy’s Office of Legacy Management
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Established in December 2003 to address DOE long term stewardship issues; started with 33
sites. This has grown to 90 sites in FY2013; projected to grow to ~120 sites by FY2020.
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Current sites are in 28 states, locations range from Puerto Rico to Amchitka, Alaska. 9 of the
90 sites require workers “on site”. The rest require periodic inspections or are limited to
records management.
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We operate under multiple regulatory schemes: CERCLA, RCRA, UMTRCA, Voluntary Cleanup
Agreements. Remedies include disposal cells, landfills, ground water monitoring, surface
water monitoring, institutional controls, pump and treat systems, subsurface barriers.
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Budget is ~$60 million a year for 90 sites: long-term surveillance and maintenance; records,
IT systems and community outreach; and, management of land and assets.
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Long term stewardship costs are typically 1-2% of the annual cleanup budget. The largest
single cost is ground water monitoring: ~2,000 monitoring wells, ~7,000 samples per year.
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100,000+ cubic feet of records, ~1500 records requests per year, ~1800 web hits per day.
Currently responsible for Yucca Mountain records and IT systems.
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32% of LM sites have beneficial reuse (e.g., grazing, forestry, wildlife habitat, open space,
community use, industrial).
LM anticipates having responsibility for 120 sites in 2020
Weldon Spring Site, Missouri
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CERCLA, US EPA and Missouri Department of Natural Resources.
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25 miles west of St. Louis off I-70 corridor – densely populated. 150 acres adjacent
to US Army reserve area and within a large State conservation area.
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DOE uranium processing and US Army explosives production (uranium, nitrates, TCE).
• 45-acre disposal cell, ground water
monitoring, monitored natural
attenuation remedy, all
institutional controls in place.
• Prairie environment with Visitors
Center and hiking/biking trail.
• Achieved EPA’s performance
measure designation of Superfund
Site Wide Ready for Anticipated
Use in March 2013.
Rocky Flats Site, Colorado
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RCRA/CERLCA cleanup, CO Department of Public
Health and the Environment, US EPA.
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16 miles NW of Denver, surrounded by Denver
suburbs – densely populated.
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6500 acres on the Rocky Mountains Front Range.
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Plutonium, uranium, stainless steel, beryllium
and other metal processing; nuclear and nonnuclear weapon and non-defense parts
production (plutonium, uranium, americium,
nitrates, VOCs).
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Landfills, ground water monitoring and
treatment, institutional controls.
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Within the Rocky Flats National Wildlife Refuge,
partnership with US Fish and Wildlife Service.
Amchitka Site, Alaska
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Voluntary Cleanup Program, State of
Alaska. Cooperative Agreement with the
Aleutian Pribilof Island Association.
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~74,000 acres Amchitka Island (western
edge of Aleutian Islands), currently
unpopulated.
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Three underground nuclear weapons test
(tritium and fingerprint left by nuclear
weapon detonation ).
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Ground water monitoring, surface water
monitoring, biota monitoring (every 5
years).
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Within a Wildlife refuge managed by US
Fish and Wildlife Preserve.
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Multi-agency coordination. Alaskan
Native Tribes’ claims. Challenging
weather and logistics.
Pinellas Site, Florida
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RCRA, Florida Department of Environmental Protection, US EPA.
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90 acres of commercial land and one privately owned 4.5 acre parcel and several adjacent
properties affected by ground water plume.
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Pinellas County, 10 miles NW of Petersburg, across the bay from Tampa – densely
populated.
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Electrical systems and electronics packages (organic solvents, metals, no radionuclides).
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Ground water monitoring,
monitored natural attenuation,
institutional controls including
purchase of subsurface rights to
adjacent parcels.
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Sold to Pinellas County for
redevelopment purposes in 1997.
Active industrial area today with
higher employment than when
operated by DOE.
Tuba City Site, Arizona
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Uranium Mill Tailings Radiation Control Act, US NRC. Cooperative Agreement with Navajo
Nation Division of Natural Resources.
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5 miles east of Tuba City, AZ, sparsely populated. 145 acres on the western edge of the
Navajo Nation.
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Former uranium mill: processed 800,000 tons of uranium ore (uranium, radon gas).
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50 acre disposal cell, ground water monitoring, ground water pump and treat remedy. Solar
voltaic field provides part of power for ground water treatment system and is tied to the local
grid.
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Treaty rights, cultural issues, language
barriers, and large concentrations of
naturally occurring uranium.
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UMTRCA sites can be dynamic. SW
deserts experience severe storms - road
washouts, increased sedimentation, and
potential impacts to cell integrity.
Wayne Site, New Jersey
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Formerly Utilized Sites Remedial Action Program site.
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CERCLA cleanup, NJ Department of Environmental Protection, US EPA.
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6.5 acre site in the Township of
Wayne, 20 miles NW of Newark densely populated.
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23 vicinity properties.
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Rare earth and thorium
processing.
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Institutional controls to limit
groundwater use.
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Land transferred to the local
government for a community
park/recreation area.
Mound Site, Ohio
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CERCLA, Ohio EPA and Department of Health, U.S. EPA.
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306 acres split into parcels. Land owners include DOE, the City of Miamisburg, Mound
Development Corporation (MDC) and BOI.
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Montgomery County, 10 miles SW of Dayton, surrounding mixture of industrial, residential,
and agricultural uses, densely populated.
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Production of polonium-beryllium initiators, research of stable isotope separation, tritium
recovery, development of RTGs. Low-level radioactivity in soil and VOCs in the groundwater.
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$1.1 billion industrial level cleanup;
LTS&M includes pump and treat
system, groundwater monitoring of
Monitored Natural Attenuation,
institutional controls.
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Site to be transferred to MDC for
economic development. Congress
provided ~$30 million.
Fernald Site, Ohio
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CERCLA, Ohio EPA, US EPA.
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1050 acres owned by DOE, Water treatment facility, Visitors Center, buildings to support
pump and treat remedy.
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Bulter and Hamilton Counties, located in SW corner of state ~ 40 miles NW of Cincinnati farming community.
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Former Feed Materials Production Center produced high-purity uranium. Uranium in
groundwater.
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$4.4 billion cleanup; LTS&M includes pump
and treat system, onsite disposal cell,
conservation easements, institutional
controls.
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Site open to the public as nature preserve
with the largest man-made wetlands in
Ohio, open water, upland forests, a lengthy
riparian corridor over 30 acres of wetlands,
7 miles of trails, and 360 acres of grassland.
100+ different species of birds.
Site Lessons Learned
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Understand and work within the regulatory structure for your site. You need to comply with
not only the remedy decision but other applicable laws and regulations regarding the land.
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Stay current with changes in demographics, local land use, politics, etc. A remedy designed
for one set of conditions may not be protective over time.
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Create a transparent culture where you invite the public to learn about the site. Engage
neighboring land owners, local governments, and the community. Do this at the frequency,
and with the communication tools and formality, that they desire.
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Pursue beneficial reuse of the site within the restrictions of the environmental remedy.
Informed site use can enhance the effectiveness of other long term stewardship activities.
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Establish institutional controls (ICs) that can be effective when properly managed and
applied. Legally enforceable controls should be used when necessary. In many cases,
administrative ICs are enforced by local governments; effective partnership is important.
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Long time frames mean that natural events must be considered in remedy selection and in
modeling site performance. Assume the subsurface models you are using can be improved
and that when the 100 year flood occurs it will impact your model.
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Plan for, and be able to transition site managers. Make knowledge management a priority.
Program Lessons Learned
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To maintain the remedy you need to budget for and maintain the site infrastructure: roads,
vehicles, equipment, power, fences, signs, water, etc.
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Use common systems and approaches where applicable and allowed. A single nation-wide
contractor facilitates integration, improves efficiency, enhances transfer of lessons learned,
and saves money.
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Long term protection of human health and environment requires you to maintain an
understanding of changes in regulations, policies, knowledge, and advances in technology.
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Encourage cross-site teams, information sharing and promote lessons learned. Rotate your
site managers and have technical experts (e.g., geochemists) work on multiple sites.
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Consolidate your records into a single records center; it is cost effective, you have faster
access, and they are better protected. Make a digital copy when pulling hard copy records.
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Centralize and standardize data management using commercially available software. Use
remote monitoring where necessary. Make all data and reports available to the public
(internet and public meetings) following appropriate quality assurance reviews.
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Invest in science and technology in targeted areas that impact your remedy performance
over the long term. Share the results with the public and the scientific community.