Cleanup of the DOE complex is a national issue. Progress on the Oak Ridge Reservation is inextricably tied to progress at other sites, as well as to the policy and budget decisions that come out of DOE Headquarters and Congress.

We in Oak Ridge are not alone in reaching this conclusion; at meetings around the country, there is a growing sense of urgency from stakeholders who understand they need disposal options for waste now in storage or soon to be generated from cleanup activities.

One sign of this realization is a growing, informal "National Dialogue" of stakeholders. LOC Board and CAP members have made significant contributions to this network. Reports from the San Diego and Chicago Intersite Discussions appeared in the last issue of Insights. Commentary from the Low-Level Waste Seminar, held this past August in Las Vegas, is included in this issue. Occasionally, individual CAP members will travel to technical or policy workshops with support from the LOC or the sponsoring organization. Ultimately, the nationwide impact becomes substantial in the relatively small community of DOE stakeholders.

In early October, I attended the Energy Communities Alliance meeting in Westminster, Colo. Several Oak Ridge city officials, including Mayor and LOC Board member Walt Brown, came to represent the concerns of city government. We heard from Energy Secretary Bill Richardson, Assistant Secretary for EM James Owendoff, and Bob deGrasse of the Office of Worker and Community Transition. While these individuals say they are committed to addressing the needs of the DOE host communities, the trend has been to ignore the tough issues that will directly promote cleanup - setting de minimis standards, finalizing the Waste Management PEIS so that NTS is open to new shippers (e.g. Oak Ridge), and vanquishing the obstructionist legal challenges to opening WIPP.

In a time of declining budgets and with a self-imposed "deadline" of 2006 looming, DOE must make significant progress in cleaning up its sites. Should DOE renege on its promise to expedite cleanups, it is unlikely Congress will continue pouring money into an indefinite, uncertain cleanup program. The work can no longer be delayed for more data, for the "silver bullet" technology just around the corner, or because managers from DOE and the regulatory community are unwilling to make the tough decisions to go forward with imperfect plans.

Perhaps the combined pressure applied by local elected officials and citizen stakeholders as we exchange concerns and potential solutions across the country will encourage DOE to move forward on the difficult points. And even top DOE-HQ officials note that pressure on Congress might be the only way to assure continued financial commitment to this very expensive undertaking.

Understanding risk

by Kenneth Roy

Risk has been defined in many ways by many people. A risk is the possibility of an adverse consequence in the normal course of events. It is different from a gamble. In a gamble, we choose to accept the possibility of a loss in the hopes of receiving a gain.

Within the DOE system, risk is usually thought of as the probability of an event multiplied by the consequences of that same event. Thus, in order to reduce the risk of the event, you can reduce the probability of its happening, the consequences if it does happen, or both. In theory, this model allows us to compare risks objectively.

For example, in the accompanying table, a house fire represents the greater

Event Probability
(per year) Consequences Risk

Car
Wreck 0.1 $4,000 $400

House
Fire 0.2 $3,500 $700

Dog
Dies 0.06 $200 $12

Tune into an ongoing discussion of risk and the applications of risk assessment by joining the RISKANAL listserver. Send the message: subscribe riskanal YourFirstName YourLastName to the email address: listserv@listserv.pnl.gov

risk, the dog dying represents the smallest risk. If we could cut the probability of a house fire in half, then the risk would also be cut in half to $350, which would make it less risky than the car wreck.

It is not easy in real life, however, to determine either the probability of an event or the consequences of that event. Suppose your family had two car wrecks in the past 20 years; this works out to a probability of 0.1 car wrecks per year. This sounds reasonable at first glance, but mathematically it is suspect. It is a very small sample size.

Your family might have been very lucky during the past 20 years, with the "real" probability being 0.25 wrecks per year. Or it might have been very unlucky, with the "real" probability being 0.05 wrecks per year. There is no way to know for sure, and getting to the "real" probability is difficult. It's like flipping a coin ten times and concluding that the probability of getting a head is 0.7 because you got seven heads. Depending on how much data we have, we can make a better or worse estimate of the probability of a given event. But that is all it is, an estimate.

The same problem applies to the consequences column. Typically, it is based on experience or estimates that may represent reality, but also may be off by some degree. Also, the consequences element sometimes has to include the intangible. What is the emotional cost of when a beloved pet dies? How is that addressed?

With a house fire or car wreck, the difficult question of how to value a human life comes into play. If the consequence of an event were similar to the Chernobyl accident - complete with fatalities, cancers and the contamination of cities and farms - how would we arrive at an accurate number to put in the consequences column? Sometimes, instead of dollars, the consequences are listed as low, medium, or high. This achieves simplicity at the cost of some definition, but the overall concept is similar.

The point is not that statements of risk or risk assessments are meaningless; they aren't. The point is that we must understand where the numbers come from and the assumptions that are made in using them. Without this understanding, we risk making a mistake with, perhaps, serious consequences.

(Kenneth Roy is a member of the Citizens' Advisory Panel)

Low-level waste dialogues

LOC members dive into the fray

Members of the LOC Board and CAP have aggressively pursued opportunities to interact with national DOE officials and with stakeholders concerned with other DOE sites. In June, we shared reports on the Intersite Discussions in San Diego and Chicago. Following are reports on the Low-Level Waste Seminar held this past August in Las Vegas, including a tour of the Nevada Test Site.

Al Brooks
Low-Level Waste Seminar

This is the first such meeting I thought was a real success. I believe the interchanges between participants including DOE were informative and excellent. I was impressed by the DOE participants' excellence in listening. They made no attempt to "dominate," yet they supplied information and insight when appropriate.

I was also impressed by the degree of expertise shown by the participants. This is in contrast to many prior meetings and made a huge difference in accomplishments. The commonality of site problems and the common sense of urgency was notable. I believe the sites, though different in detail, have much in common, especially in their relationship to DOE-HQ.

DOE-HQ, at some level, seems ready to accept stakeholder input, but the outcome of the meeting will depend upon prompt and constructive work by the site SSABs (or CABs) and other stakeholders. We must formulate an action plan on these and other items, and take consistent and coordinated actions.

There will have to be a frequent, continuing communication between stakeholders at the formal and informal level. The LOC e-mail server should help support the informal level. I consider the DOE participation to be a real plus in opening informal communications with DOE-HQ and urge participants to "tell it like it is" (politely).

Full report from Al Brooks

Ken Greer
Low-Level Waste Seminar

My overall observation was that the LLW Seminar was a success from the viewpoint that DOE representatives received frequent and specific input from the attendees, and the attendees were able to present their viewpoints to SSAB members from all of the cities located near DOE facilities that are generating and will generate, treat, store, and dispose of LLW.

I participated on the committee considering barriers and suggestions on environmental and safety considerations.

The main topics the committee focused on were:

Lack of clear definition and characterization of LLW throughout the DOE complex, including the subset of mixed LLW;
Clear goals required for minimization of LLW;
Communication required to educate the public of cumulative risks of LLW activities, worker safety and training needs, emergency response training, and LLW shipment scheduling and routing between DOE facilities; and
Emphasis placed that all applicable sites generating and accepting LLW should be proactive in acquiring all relevant environmental permits from state and federal agencies.

I suggest that the messages provided to DOE-HQ, during the SSAB comment session and throughout the seminar were as follows:

Stakeholders are extremely anxious for progress to be made by DOE-HQ on issuing a systemwide LLW PEIS;
LLW shipments should be initiated between facilities;
Stakeholders want their suggestions used by DOE-HQ managers, with frequent feedback provided to SSAB members by high-level DOE-HQ managers.

It will be interesting to observe whether DOE-HQ utilizes the SSAB comments, or at least provides a written response to each of the major SSAB concerns, in the near future. The major reasons that public interest groups could be successful in future litigation against DOE for LLW decisions are:

DOE does not consider and address stakeholder and public comments;
DOE does not follow NEPA requirements for major federal projects; and
DOE does not provide adequate time for stakeholders and the public to provide comments on DOE's LLW systemwide activities.

Full report from Ken Greer

Susan Kaplan
Low-Level Waste Seminar

This meeting provided the stakeholders an opportunity to brainstorm together to identify ways to deal with the Department of Energy's low-level waste on a complex-wide basis. This meeting alerted me to the fact that the proposed Oak Ridge disposal cell is actually the most expensive option for dealing with Oak Ridge's low-level waste. This information was recently confirmed in a newspaper article discussing the results of an analysis performed by the Office of Management and Budget, which pointed out that cheaper disposal options were available (i.e., Nevada Test Site and commercial disposal).

This meeting also provided me the opportunity to deal firsthand with a stakeholder who apparently was not interested in reaching consensus and solving the problem. I had a very frustrating interaction with a lawyer for one of the activist groups. ... His behavior throughout the entire episode made it very clear that his goal was not to work with the other stakeholders to solve the problem, but only to further his own agenda.

Full report from Susan Kaplan

Fay Martin
Nevada Test Site Tour

The tour was fascinating and gratifying, because I had worked on a Plutonium Data Base in the 1970s and had always had a desire to visit the Test Site. We had an excellent guide, Ernest Williams, who had worked at the Test Site "in the old days" and knew all the intimate details of what happened then. We first stopped at the gate for badging and dosimeters and then proceeded to the town of Mercury.

Bruce Becker told us about the Waste Disposal Facility (0.05 mR/hr background here, compared to 0.03 mR/hr in the desert). He pointed out a transuranic waste container that would be shipped to WIPP. It was on a RCRA pad, and also on the pad was mixed waste to be shipped to the TSCA incinerator.

We drove through vast stretches of countryside with scrubby vegetation and several Joshua trees onto Yucca Flat, which is 12 miles wide and 10 miles long. This is the lowest part of the valley, which is why all the silt has collected here. We were told that sometimes they have up to 4 inches of water, but there was none on our visit. Area 3 was interesting where an atmospheric shot was fired. Our guide pointed out the subsidence craters and explained about the gases coming to the surface.

Leroy Duran explained about the Radioactive Waste Management Site. There was some waste there from Fernald, five layers of tanks with 4 feet of soil between the layers, a crater and a special liner called "burrito wrap." Four shipments had arrived that morning from Sandia, N.M. A worker with a monitor checked our bus for contamination when we left this area.

Full report from Fay Martin

Guest editorial

The politics of cleanup

by Gail Corbett

Have you ever noticed how much money gets spent on "cleanup" of the Oak Ridge Reservation? It peaked at about a billion dollars a year, and even though it has been declining ever since, there is still a good piece of change coming in. Now, with all that money flowing through the system, can you name three major cleanup projects that have been completed on the Reservation? By this, I mean projects that involved moving actual dirt and not just shuffling paper.

Oak Ridge has many waste streams, but the most significant may be time and money. If DOE could solve its waste problems with documents, databases and scenarios, we'd be well on the road to a cleaner Oak Ridge. But problems don't get solved this way. Is it too radical to suggest that DOE devote at least some of its resources to moving waste from Oak Ridge to an area less prone to floods, tornadoes, earthquakes and human interaction?

The fact is that the Oak Ridge Reservation has yet to see a year in which it moved more waste off site than it generated on site. In part, this is because DOE is an essentially political organization; if you want to succeed, it is more important to avoid making waves than it is to accomplish actual goals.

In contrast, the armed forces are action-oriented; if you fail to accomplish your task, you are punished. DOE and its family of contractors don't seem to understand this principal as they manage pollutants from the nuclear war industry. In the DOE environment, failure apparently can get you promoted.

Granted that DOE has to work in a highly charged political environment and work within a Superfund Law that requires many studies and many levels of approval before tangible work is done. The obstacles on hand include changing national administrations, bureaucratic constraints and state equity issues that can paralyze decision-making. Another sad fact of life is that congressional support for cleanup in Oak Ridge has diminished significantly, as other DOE communities compete for cleanup dollars and non-DOE constituencies are demanding resources for their own capital projects.

Nevertheless, the job that must ultimately be done is not political in nature, it is technical. DOE needs to create a viable national cleanup plan with a valid technical foundation. It is not good enough just to direct money toward whichever states have sued recently.

As Oak Ridge stakeholders, we cannot let DOE get by with telling us the things it cannot do with a half-billion dollars a year; we must demand that it tell us what it will do. Cleanup and reuse of "dirty" land is critical to saving the beautiful, pristine land that has, so far, avoided the bulldozer. If you want to see our area get cleaned up, get political and demand cleanup results, including the release of usable land to local governments.

To get up to speed politically, ask a few simple questions:

What are we accomplishing by doing the project?
Where did the money for a project come from: defense, non-defense or the D&D (decontamination and decommissioning) fund? ("Defense" implies the waste came from making bombs, "non-defense" implies it came from research, and "D&D" implies it came from uranium enrichment.")
What are the ramifications of a project's success or failure?
When does the project end?
If the work is being contracted out, why is DOE itself not doing the job?
Is it difficult for stakeholders to get information on the project?

It is also important to keep an eye on the cast of characters. Relationships among organizations and individuals are important to note. Don't let reorganizations and job-hopping confuse you as to where the ultimate responsibilities and accountability lie. Consider a few more questions:

Who is in charge of the project budget?
Who is doing the work?
Who is ultimately responsible for the project's success or failure?
Who oversees the project?
Who is making money?

The list of environmental management projects performed by DOE's Oak Ridge Operations is available as part of the annual prioritization process. If you ask questions, and the answers make you feel as though you're in a crooked poker game, you may have hit on a political whopper.

But beware if you're employed by a major player. If you're fired (or promoted) for no apparent reason, you asked too many questions.

(Gail Corbett is former Vice Chair of the Citizens' Advisory Committee)

Hot Flashes

LOC welcomes new board members

Elections in August have brought some new faces onto the LOC Board:

Rex Lynch - Anderson County Executive
Jimmy Wilkey - Rhea County Executive
Pete Jennings - Meigs County Executive

The next regular Board meeting is scheduled for November 5, 1998. We welcome the new members aboard!

RiskWorld and the effective stakeholder

The LOC now has a copy of the new on-line report "Using Stakeholder Processes in Environmental Decisionmaking: An Evaluation of Lessons Learned, Key Issues, and Future Challenges." This report can also be found on-line at RiskWorld's web site. Sponsored by the American Industrial Health Council, the American Petroleum Institute, and the Chemical Manufacturers Association, the study focuses on stakeholder processes, including the major reasons for their increased use, key issues and challenges, and factors shaping their future use.

It concludes that stakeholder-based decisionmaking is increasingly important for managing environmental issues. If you do not have Internet access, call the LOC office for a copy.

CAP member Kaplan founds institute

At the last annual joint meeting of the LOC Board and the CAP, Susan Kaplan, CAP Vice Chair, announced that she has created a new non-profit organization, the Institute for Technology, Social, and Policy Awareness, Inc. ITSPA will educate the public on topics that the LOC and other committees she serves on find too controversial or that do not fit within their mission. One example is the issue of siting a Monitored Retrievable Storage Facility at the former K-25 Site in Oak Ridge, a project that she believes would provide an important long-term mission for the former K-25 Site, with lucrative economic incentives.

Kudos for LOC Web site

"Judging from the extremely impressive site that your organization has put on the WWW, your community is being extremely well served by thoughtful and highly accomplished professionals."

Robert Taylor
Deputy General Counsel
Environment and Installations
U.S. Department of Defense

Alphabet Soup

(Initials and acronyms to make this newsletter and other DOE-related documents easier to read)

CAB = Citizens' Advisory Board
CAP = LOC Citizens' Advisory Panel
CROET = Community Reuse Organization of East Tennessee
D&D = Decontamination and Decommissioning
DOE = Department of Energy
DOE-HQ = Department of Energy Headquarters in Washington
EIS = Environmental Impact Statement
EM= Environmental Management
EQAB = City of Oak Ridge Environmental Quality Advisory Board
ITSPA = Institute for Technology, Social, and Policy Awareness
LLW = low-level waste
LOC = Oak Ridge Reservation Local Oversight Committee, Inc.
NEPA = National Environmental Policy Act
NTS = Nevada Test Site
ORNL = Oak Ridge National Laboratory
PEIS = Programmatic Environmental Impact Statement
RCERB = Roane County Environmental Review Board
RCRA = Resource Conservation and Recovery Act
RTG = Radioisotope Thermoelectric Generation
SSAB = Oak Ridge Reservation Environmental Management Site-Specific Advisory Board
TDEC = Tennessee Department of Environment and Conservation
TSCA = Toxic Substances Control Act
WIPP = Waste Isolation Pilot Plant at Carlsbad, N.M.
WWW = World Wide Web

November 1998

DOE communities nationwide address common concerns