Long-Term Stewardship: Institutional Controls on Department of Energy Sites. Development and Management of Institutional Controls at U.S. Department of Energy Office of Legacy Management Sites
- U.S. Department of Energy, Broomfield, Colorado (United States)
- Battelle Memorial Institute, Grand Junction, Colorado (United States)
- S.M. Stoller Corporation, Grand Junction, Colorado (United States)
The U.S. Department of Energy (DOE) has managed the Long Term Stewardship and Maintenance activities at DOE sites since 1988. DOE's Office of Legacy Management (LM) was established in December 2003, and its specific mission is to manage the DOE's post-closure responsibilities and ensure the future protection of human health and the environment. LM has control and custody for legacy land, structures, and facilities and is responsible for maintaining them at levels suitable for their long-term use. LM uses DOE Policy 454.1: Use of Institutional Controls (ICs) and Associated Guidance. Many major Federal laws, Executive Orders, regulations, and various other drivers influence the establishment and use of ICs at LM sites. LM uses a wide range of ICs as part of efforts to appropriately limit access to, or uses of, land, facilities and other real and personal property assets; protect the environment; maintain the physical safety and security of DOE facilities; and prevent or limit inadvertent human and environmental exposure to residual contaminants and other hazards. ICs generally fall into one of four categories identified by EPA guidance, and DOE is successfully using a 'defense in depth' strategy which uses multiple mechanisms to provide 'layering' for additional durability and protectiveness: - Proprietary controls - such as easements and covenants. - Governmental controls - implemented and enforced by state or local governments. - Enforcement and permit tools with IC components - such as CERCLA agreements or RCRA permits. - Informational devices - such as state registries or public advisories. An additional practice that supports ICs at LM sites entails the use of engineered controls, such as fences, gates, access controls, etc. to ensure public access to applicable areas is limited. An engineered control that is not an IC is the disposal cell itself with its design criteria that protects the contaminated interior, controls the penetration of precipitation, and the provides a physical barrier to environmental and biological intrusion. Other site engineered controls manage surface runoff, restrict access, and provide a monitoring network to track residual contamination and ensure the integrity of the remedy. These engineered controls are part of the remedy and are not considered to be Institutional Controls. As of fiscal year 2006, LM has long-term surveillance and maintenance (LTS and M) responsibilities at 70 sites in 27 states and Puerto Rico with 23 sites planned for transfer to the office during Fiscal Year 2007. ICs are in place at approximately 44 of the current LM sites and they are being tracked to ensure their integrity. A formal inspection process is used at many LM sites to confirm that remedial action components, including associated ICs, remain in place and are effective. Inspections are also critical for determining if additional maintenance or monitoring is necessary. Inspections may be conducted on an as-needed basis and frequencies can vary widely depending on site-specific policies and conditions, but typically occur on an annual basis. At CERCLA sites, the annual inspections are also incorporated into the Five-Year Review process. Inspection procedures are developed for each site and may contain the following components: - Development an inspection checklist based on previous findings or progressive changes in site conditions. - Physical inspection of engineered structures designed to contain or control waste materials. - Review of completed maintenance work and determination of maintenance needs. - Formal inspection of the physical location of IC areas to ensure continued protection of human health and the environment. - Contact of property owners to ensure continued awareness of ICs on their property. - Inspection of the IC areas to ensure that any restrictions imposed by the IC are not being violated, such as drilling of wells in an area that has groundwater restrictions. - Check of county records to verify that deed notices, easements, and other recorded instruments remain in place. - Preparation of report documenting inspection proceedings and schedule for completion of corrective actions, if any. The inspection process is a successful mechanism for ensuring effectiveness of ICs that allow protection of human health and the environment. As the LM site inventory grows to 131 sites by the year 2015, development and management of ICs will continue as an increasingly critical component of LTS and M programs. (authors)
- Research Organization:
- WM Symposia, 1628 E. Southern Avenue, Suite 9 - 332, Tempe, AZ 85282 (United States)
- OSTI ID:
- 21294775
- Report Number(s):
- INIS-US-09-WM-07462; TRN: US10V0309040965
- Resource Relation:
- Conference: WM'07: 2007 Waste Management Symposium - Global Accomplishments in Environmental and Radioactive Waste Management: Education and Opportunity for the Next Generation of Waste Management Professionals, Tucson, AZ (United States), 25 Feb - 1 Mar 2007; Other Information: Country of input: France; 3 refs
- Country of Publication:
- United States
- Language:
- English
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54 ENVIRONMENTAL SCIENCES
CONTROL
ENVIRONMENTAL EXPOSURE
LICENSES
MONITORING
NATIONAL SECURITY
OCCUPATIONAL SAFETY
PUBLIC HEALTH
RADIOACTIVE WASTE MANAGEMENT
RADIOACTIVE WASTES
REGULATIONS
REMEDIAL ACTION
US DOE
US EPA
US SUPERFUND