GAO urges risk-informed cleanup decisions by DOE
ECA Staff | 10/25/2019
The Government Accountability Office (GAO) recently published a report titled, DOE Would Benefit from Incorporating Risk-Informed Decision-Making into Its Cleanup Policy.
Why GAO Did This Report
"As of 2018, the U.S. government faced an estimated $577 billion in environmental liabilities. DOE is responsible for more than 85 percent of these liabilities. DOE is charged with cleaning up contamination from nuclear weapons production and energy research dating back to World War II and the Cold War, which generated large quantities of liquid and solid radioactive waste and contaminated soil and water. Since the mid-1990s, GAO and others have recommended that DOE adopt a risk-informed
approach to making cleanup decisions—that is, an approach that helps agencies consider trade-offs among risk, cost, and other factors in the face of uncertainty and diverse stakeholder perspectives.
GAO was asked to review DOE's environmental cleanup decision-making. This report examines (1) the extent to which DOE has a framework for making risk-informed cleanup decisions, and (2) essential elements of a framework for making risk-informed cleanup decisions. GAO conducted a literature review, interviewed DOE officials, and convened an experts' meeting through the National Academies regarding risk-informed decision-making."
What GAO Found
"[DOE-EM] follows certain laws—including the Comprehensive Environmental Response, Compensation, and Liability Act and the Resource Conservation and Recovery Act—agreements, federal guidance, and court decisions, which establish standards and procedures for DOE's cleanup of hazardous and radioactive waste. However, DOE does not have a framework for implementing these requirements and guidance to make cleanup decisions in a risk-informed manner. For example, DOE's 2017 cleanup policy, which
governs the EM cleanup program, does not direct how EM should make environmental cleanup decisions, including how to make risk-informed cleanup decisions. For more than 20 years, several organizations—including the DOE Inspector General and GAO—have recommended that DOE adopt a risk-informed approach. By revising EM's 2017 cleanup policy to establish how EM should apply the essential elements of a risk-informed decision-making framework into its current decision-making requirements and guidance,
DOE sites would be better able to implement consistent decision-making processes and ensure that resource allocation is risk informed to the extent practicable.
To assist agencies, such as DOE, in identifying and implementing the essential elements of risk-informed decision-making, GAO synthesized key concepts from relevant literature and input from experts who participated in GAO's meeting convened by the National Academies of Sciences, Engineering, and Medicine (National Academies). GAO subsequently developed a framework to be relevant to multiple types of cleanup decisions, from selecting a cleanup approach at a single site to prioritizing cleanup
activities across sites. According to literature, entities implementing the framework should ensure that their decision-making process is participatory, logical, transparent, and traceable, and that it uses current scientific knowledge to produce technically credible results. The framework consists of four broad phases: (1) designing the decision-making process, (2) analyzing different options, (3) deciding which option is preferred, and (4) implementing and evaluating the preferred option. Each
phase consists of several steps, such as identifying stakeholders, developing an analysis plan, and validating the analysis...”
The Importance of Communicating Risk
In its framework for making risk-informed cleanup decisions, one of GAO's recommended phases includes engaging stakeholders. GAO noted, "...the goals of engaging stakeholder groups representing members of the public in a risk-informed cleanup decision should be to incorporate their viewpoints and to seek their acceptance of the decision-making process as transparent and legitimate, rather than to obtain their concurrence with the final decision."
One of the most important issues to ECA is managing the various opinions of risk, and with the question of risk comes the need for risk communication, as discussed in our report, The Politics of Cleanup. A central commonality among a vast number of the disputes at DOE facilities over the
past 10 years, particularly disputes resulting in congressional intervention, concerned differing notions of risk.
For environmental cleanup to proceed, the agency charged with cleaning up the site and the agencies regulating the cleanup must agree on numerous issues regarding risk — e.g., what risk level is achievable and politically acceptable, and what level of cleanup will ensure the agreed-to risk meets regulatory requirements. For cleanup to garner the support of the local governments and other community members surrounding the site, the parties must agree on technical risks as well as
perceptions of risk — e.g., will the community accept the given risk and can the risk that results from contamination being left at the facility support the future use?
ECA believes discussions, which need to take place throughout the process, must include the question of technical risk and perceptions of risk, recognizing perceptions of risks posed do not always align with the technical risk. ECA has recommended the following steps to facilitate these discussions, which can work in tandem with GAO's framework:
- Hold regular technical meetings;
- Provide pre-decisional drafts of cleanup documents to the community;
- Provide local governments and other members of the community with broad access to federal site personnel;
- Hold regular meetings between the federal facilities manager and community members; and
- Educate new parties as they become involved.
Risk communication is an issue that is vitally important for the parties to understand, especially those parties charged with implementing and regulating the cleanup.
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Read about DOE's High Level Waste Interpretation
Have questions about DOE’s recent high-level waste (HLW) interpretation? Download ECA’s Key Points and FAQs on the issue to better understand what ECA believes are the potential benefits of implementation.
Interested in learning more? Read the ECA report “Making Informed Decisions on DOE's Proposed High Level Waste Definition” at www.energyca.org/publications
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