Oak Ridge Risk Review Project
[Please note: this project and this page are in progress.]
This project will provide source-specific, summary-level information and categorization of human health and environmental risks associated with EM scope at Oak Ridge Reservation (ORR). One of the intended uses of the project’s results is input for prioritization efforts as part of EM strategic planning. DOE continues to recognize and acknowledge the primary significance of risk to human health and the environment, and EM uses risk as one factor in cleanup priority setting and resource allocation. While all EM sites assess risks to human health and the environment as part of decision making when individual projects are being considered, an independent comprehensive site-wide risk review has only been completed at Hanford in the past decade. At the same time, estimates of environmental liability associated with the former defense nuclear sites have increased substantially and challenge available resources.
The objective of this project is the execution of a screening evaluation of risks and impacts on human health and the environment (i.e., groundwater, surface water bodies, and ecological resources) arising from the former defense work that took place at the Oak Ridge Reservation. The evaluation will consider remaining EM scope at ORR; however, the scope may be restricted to more in-depth evaluation only of facilities and areas likely to present higher risks.
Relevance and Impact to DOE:
Since 1996, the Environmental Protection Agency (EPA) has recognized risk as a major factor in priority setting of site cleanup and the allocation of resources, while taking other factors (e.g., land use, life cycle costs, local priorities) into account. In 2012, DOE and states involved in DOE site cleanup developed a set of principles to guide state-DOE planning and prioritization of cleanup, which reaffirmed the risk plus other factors accepted in 1996. Furthermore, Congress and the Government Accountability Office (GAO) have emphasized the need for increased evaluation of remaining risks and the use of this information in EM and site-specific cleanup prioritization. The Consolidated Appropriations Act (Public Law 113-76, 2014) directed programmatic review of risks and a 2015 report developed in response to this direction of Congress entitled “A Review of the Use of Risk- Informed Management in the Cleanup Program for Former Defense Nuclear Sites” emphasized the major role that human health and environmental risk evaluations based on site risk assessments play in guiding priority-setting and budgeting. In May 2019, the GAO released a report (Department of Energy: Environmental Liability Continues to Grow, and Significant Management Challenges Remain for Cleanup Efforts (May 2019, GAO-19-460T)) that found that EM’s environmental liability was $494 billion for fiscal year 2018 and may continue to grow and outpace spending on cleanup. GAO found that one reason for this is that EM lacks a program-wide cleanup strategy and instead relies on individual sites to determine cleanup activities and establish priorities, which according to the report means that overall risks and costs are not sufficiently balanced.
Most recently in September 2019, GAO published a study (GAO-19-339) entitled: “Environmental Liabilities, DOE would Benefit from Incorporating Risk-Informed Decision Making into its Cleanup Policy”, which examines the extent to which EM has a framework for making risk-informed cleanup decisions and identifies the elements of a framework for making these decisions. In a letter dated August 30, 2019 to GAO commenting on the draft of GAO’s study, EM stated: “DOE agrees in principle that risk-informed decision making is appropriate in making cleanup decisions. Risk is an important factor in determining clean-up remedies and prioritization under both the Comprehensive Environmental Response, Compensation, and Liability Act, and the Resource Conservation and Recovery Act.” Additionally, the Management Response attached to the letter comment states that EM concurred with the study’s recommendation to revise its 2017 cleanup policy (EM Policy 7/20/2017) “to establish how the EM program and DOE sites should apply the essential elements of a risk-informed decision- making document framework into their current decision-making requirements and guidance”. This Screening Risk Review Project that is to be conducted at ORR and SRS will assist EM this effort by assuring that the highest risks to human health and the environment are being addressed as the highest priorities.