October 2002

Environmental Monitoring,Surveillance, and Control ProgramsWithin theU. S. Department of Energy

Performance Analysis

Office of Independent Oversight and Performance AssuranceU. S. Department of Energy

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HTTable of ContentsEXECUTIVE SUMMARY .............................................................. 1

1.0 PURPOSE AND EVALUATION APPROACH ........................4

2.0 DOE REQUIREMENTS AND PROGRAMS..........................4

3.0 PERFORMANCE ANALYSIS .................................................7

3.1 Groundwater Monitoring and Protection...........................73.2 Environmental Radiological Program Management ........ 113.3 Environmental Radiological Monitoring

and Surveillance ...............................................................153.4 Radiological Air Emissions ..............................................16

4.0 CONCLUSIONS ....................................................................18

5.0 OPPORTUNITIES FOR IMPROVEMENT .........................20

APPENDIX A - RELATED INDEPENDENT OVERSIGHTEVALUATION REPORTS ................................23

APPENDIX B - TEAM COMPOSITION ...................................24

Abbreviations Used in This Report

ALARA As Low As Reasonably AchievableCAA Clean Air ActCERCLA Comprehensive Environmental Response, Compensation, and

Liability ActCFR Code of Federal RegulationsDOE U.S. Department of EnergyEH DOE Office of Environment, Safety and HealthEH-1 Assistant Secretary for Environment, Safety and HealthEPA Environmental Protection Agencymrem MilliremNESHAPS National Emission Standards for Hazardous Air PollutantspCi/g picoCuries per gramRCRA Resource Conservation and Recovery Act

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Executive Summary

Introduction

This report documents the results of a U.S.Department of Energy (DOE) Office ofIndependent Oversight and PerformanceAssurance (OA) analysis of DOE environmentalmonitoring, surveillance, and control activities. Theanalysis is based primarily on DOE Headquartersindependent oversight evaluations of environmentalmonitoring and surveillance activities that wereconducted at 14 different sites across the DOEcomplex during fiscal years 1999 through 2002.

OA conducted this analysis to identify andproactively communicate important performanceinformation identified through past independentoversight activities. These results are being sharedoutside the bounds of a formal inspection to promotecontinuous improvement. It is OA’s intention thatthe results of this analysis will be useful to linemanagement efforts to evaluate and strengthen theirenvironmental monitoring, surveillance, and controlprograms.

The DOE sites that were evaluated throughindependent oversight activities reflect a range ofprogrammatic interests that include scientificresearch, national defense, and environmentalmanagement. These DOE sites support an arrayof ongoing activities, including facility operations,manufacturing, research and development, wastemanagement, environmental restoration,decontamination and decommissioning, andreindustrialization.

Independent oversight evaluations wereconducted to evaluate site performance in a numberof environmental protection areas. These includedgroundwater monitoring and stewardship,monitoring of radiological air emissions, andenvironmental radiological monitoring andsurveillance associated with contaminant migrationand controls for liquid and sediment pathways.While the specific scope of each evaluation varied,all evaluations examined selected aspects ofapplicable Federal regulations and DOE directives.In particular, independent oversight evaluationsexamined the implementation of DOE Order5400.1, General Environmental Protection

Program, DOE Order 5400.5, RadiationProtection of the Public and the Environment,and/or alternative standards invoked in contractsbetween DOE and the site contractors.

Results

Independent oversight inspections identifiedseveral strengths common to most DOEenvironmental monitoring and surveillanceprograms:

• Extensive groundwater monitoring networkshave been developed to support environmentalrestoration efforts. Groundwater plumes thatare highly contaminated and present asignificant threat have been identified, andmany are undergoing remediation.

• The level of the radiological monitoring andsurveillance was consistent with most DOEexpectations and guidance, and was adequateto detect any major releases or migration ofradionuclides.

• All sites evaluated have active NationalEmission Standards for Hazardous AirPollutants (NESHAPS) programs that wereeffective in meeting dose-based radiologicaldischarge limitations.

Notwithstanding these strengths, independentoversight evaluations determined a number ofobservations where weaknesses in implementingenvironmental monitoring, surveillance, and controlprograms were identified at DOE sites. In mostcases, identified weaknesses involved smallamounts of radioactive material and/or pathwaysthat did not result in significant radiation exposuresto workers or the public. While not necessarilyevident at all the sites reviewed, these observationswere identified at multiple sites and weresufficiently significant to warrant communicationto DOE Headquarters and site managers forfurther evaluation. Observations included:

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• Absence of proper data quality objectives insupport of environmental radiological sampling anddecision-making, and an over-reliance on grossalpha and beta analyses

• Ineffective monitoring of sediment migrationpathways

• Weaknesses in the application of the as-low-as-reasonably-achievable (ALARA) principle toenvironmental releases

• Widely inconsistent implementation of radiologicalsoil contamination posting and controls

• Weaknesses in ambient air monitoring and reportingfor radionuclides

• Improper characterization and release ofvolumetrically contaminated materials fromradiological control

• Discharge of liquid effluents without evaluating theapplicability of DOE soil column prohibitions

• Incomplete analysis, control, and monitoring forpotential releases of hazardous materials fromoperational facilities into the groundwater and soilcolumn

• Weaknesses in trending and reporting mechanismsfor anomalous groundwater conditions

• Incomplete monitoring and/or analysis ofgroundwater contamination occurring at lowerconcentrations.

OA’s analysis of the weaknesses identified threecontributing factors:

• DOE expectations for environmentalmonitoring, surveillance, and control are notconsistently understood, fully defined in allareas, or invoked in DOE contracts. Many ofthe weaknesses identified in oversight reviewsstemmed from insufficient understanding or clarityof DOE expectations (e.g., ambiguities in DOErequirements regarding the prohibition on liquiddischarges to soil columns). In some cases,

managers did not incorporate applicablegroundwater protection and radiological monitoringand control requirements into management andoperating contracts.

• There is insufficient professional radiologicalexpertise being applied to environmentalradiological protection programs at somesites. At some sites, personnel who wereresponsible for evaluating technical data, makingdecisions, and preparing and/or reviewing healthphysics-related reports had limited training andqualifications in health physics disciplines. Thissituation contributed to errors and omissions in theplanning, implementation, evaluation, and reportingof a number of elements of site environmentalprograms.

• Insufficient application of resources toenvironmental monitoring programs hasimpacted the ability to fully characterizeenvironmental conditions in some areas.Resource reductions and constraints at some siteshave resulted in a significant reduction of DOEand contractor environmental support personnel,the number of monitoring stations, monitoringfrequency, and analytical parameters. In addition,the capability of some DOE and contractor fieldorganizations to manage and oversee environmentalmonitoring programs has been limited by loss ofexperienced personnel and sustained hiringlimitations.

Conclusions and Opportunitiesfor Improvement

Independent oversight evaluations determined thatall sites had established environmental monitoring,surveillance, and control programs to implementregulatory requirements and DOE contractualobligations. Site environmental surveillance programshave been ongoing for many years, and an extensivebaseline of information on contamination inenvironmental media has been developed. At all DOEsites evaluated, monitoring data demonstrates adecreasing trend in the levels of radiological dischargesto the environment in air and water pathways.

However, some aspects of DOE policy are notclearly delineated and communicated to the field, andcertain requirements are not effectively implemented

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at DOE sites. Further improvements are warranted ina number of aspects of environmental monitoring andsurveillance to ensure that expectations are clearlyestablished, understood, and implemented.

In the spirit of promoting continuous improvement,some specific opportunities for improvement have beenidentified and are summarized in Table ES-1, and arefurther detailed in other sections of this report. It is

OA’s intention that these opportunities for improvementwill be useful in the ongoing efforts by the DOE Officeof Environment, Safety and Health to replace theoutdated DOE environmental protection order with anew environmental management system-based order/manual and to consolidate and re-issue guidancedocuments.

DOE LINE ORGANIZATIONS

1. Review groundwater protection programs to ensure appropriate monitoring and stewardship.

2. Evaluate environmental sampling and analysis methods and approaches to ensure that they are sufficient todemonstrate compliance with applicable limits and provide an adequate technical basis for the environmentalmonitoring program.

3. Ensure that the ALARA principle is systematically applied to environmental programs.

4. Evaluate the adequacy of application of resources to environmental monitoring and surveillance programs.

DOE OFFICE OF ENVIRONMENT, SAFETY AND HEALTH

1. Clarify DOE requirements and guidelines to ensure that a consistent set of expectations has been establishedfor DOE field organizations to implement environmental monitoring, surveillance, and control programs.Specifically, clarify expectations and requirements in the areas of groundwater protection for operatingfacilities; investigation and monitoring of low-level groundwater plumes; policy and guidance for determininglevels of regulatory concern for volumetrically-contaminated material; soil column requirements; and postingand control of areas with radiologically contaminated soils.

2. Re-evaluate the benefits of promulgating regulations that codify DOE internal directives for radiation protectionof the public and the environment.

Table ES-1. Opportunities for Improvement

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Purpose and Evaluation Approach1.0

The U.S. Department of Energy (DOE) Officeof Independent Oversight and PerformanceAssurance (OA) performed an analysis ofenvironmental monitoring and surveillanceprograms at DOE sites. The analysis was basedon 14 independent oversight evaluations—published from October 1999 to July 2002—thatincluded a review of environmental monitoring andsurveillance programs. These oversight reportsare listed in Appendix A.

OA conducted this analysis to identify andproactively communicate important performanceinformation identified through past independentoversight activities. These results are being sharedoutside the bounds of a formal inspection topromote continuous improvement. It is OA’sintention that the results of this analysis will beuseful to line management efforts to evaluate andstrengthen their environmental monitoring,surveillance, and control programs. The

composition of the OA team that performed theanalysis is listed in Appendix B.

Over the last several years, independentoversight evaluations have been conducted toevaluate the ability of DOE sites to appropriatelycharacterize air and liquid process effluents andto identify the existence and impacts ofcontaminants in the environment. Independentoversight evaluations focused primarily onmonitoring programs and controls for radionuclidesbecause of the added technical complexity and theabsence of external regulation of DOE sites in anumber of related areas. This report presentsinformation on the results of these evaluations. Thisreport does not include an analysis of DOE siteperformance in managing non-radiological air andliquid effluents or other areas of environmentalprotection, such as the implementation of hazardouswaste management requirements.

DOE Requirements and Programs2.0

DOE manages a network of sites and facilitiesthat perform scientific research and processing tosupport the national defense, energy research,environmental management, and other missions ofDOE. These facilities use radionuclides and otherhazardous materials in ongoing operations and/orhave had significant quantities of these materialsreleased into the environment through pastpractices. These operations and legacy conditionscreate potential pathways for the transport ofradionuclides and hazardous chemicals to publicand environmental receptors through release andtransmission in the air, groundwater, surface water,and sediment/soil migration. DOE operations havesignificantly reduced their environmental impactsover the past several decades as a result of theestablishment of Federal, state, and DOEregulations and requirements; increased publicscrutiny and concern; pollution prevention and

pollution control projects; and the termination ofoperations resulting from the reduction of nationaldefense requirements.

DOE, the U.S. Environmental ProtectionAgency (EPA), and state agencies haveestablished requirements related to the control andmanagement of radionuclides and hazardousmaterials, including technical and managementrequirements for ensuring that adequate methodsare established to monitor effluents and to determineenvironmental impacts, if any, from these releases.EPA promulgated regulations to implement theClean Water Act, the Clean Air Act (CAA), theSafe Drinking Water Act, the ResourceConservation and Recovery Act (RCRA), theComprehensive Environmental Response,Compensation, and Liability Act (CERCLA), andothers. Federal and state agencies enforce theseregulations at DOE sites through review of plans,

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establishment of permits, periodic inspections, and undersome circumstances, independent sampling andanalysis. Under the Atomic Energy Act of 1954, asamended, DOE is self-regulating in many aspects ofits operations and sets internal standards through thepromulgation of rules and the establishment of internaldirectives. Releases of radionuclides into the surfacewater, soil column, and groundwater are controlled byDOE through DOE Order 5400.5, RadiationProtection of the Public and the Environment. DOEOrder 5400.1, General Environmental ProtectionProgram, establishes additional environmentalmonitoring policy and requirements.

The following is a description of regulatoryrequirements and evaluation elements for the areas ofgroundwater monitoring and protection, environmentalradiological monitoring and surveillance, and radiologicalair emissions. This information is presented asbackground information to support reader understandingof performance analysis results contained in Section 3.

Groundwater Monitoring and Protection

DOE sites are required to monitor groundwaterquality to ensure that ongoing operational impacts areidentified and that migration of contamination throughgroundwater flow is adequately understood in order toidentify impacts to environmental receptors and thepublic. Groundwater monitoring preformed at sitesacross the DOE complex serves two purposes—stewardship and remediation. Groundwater monitoringperformed for stewardship provides for early detectionof leaks, which could originate from operating facilitiesand other activities, resulting in an adverse impact onthe groundwater. These site monitoring and surveillanceactivities are implemented as part of internal DOErequirements for protection of the environment, asdefined in DOE Order 5400.1. Groundwater monitoringperformed as part of a remediation program providesinformation on the extent and concentration of legacycontamination, which can be used to evaluaterestoration options and to determine the effectivenessof cleanup activities. Primarily, these restorationmonitoring activities are conducted in response toregulatory requirements and cleanup agreements withFederal and state regulatory agencies. Typically, thesetwo distinct monitoring and surveillance activitiescomprise the sitewide groundwater monitoring programat a DOE site.

DOE Order 5400.1 includes requirements for sitesto develop plans and strategies to document thegroundwater flow regime with respect to the quantityand quality of groundwater resources; conductmonitoring to determine and document the effects ofoperations; and provide data to permit the early detectionof groundwater pollution or contamination. This Orderacknowledges the flexibility needed by DOE linemanagement in tailoring monitoring programs to site-specific needs and conditions.

Environmental restoration requirements forgroundwater quality and protection are derived fromsite-specific Federal Facility Agreements. These arebased on Federal and state regulatory mandatescontained in RCRA, CERCLA, and state and localgroundwater and aquifer protection laws, regulations,and requirements. In general, these requirements aredrivers for groundwater monitoring associated withenvironmental restoration activities, waste management,and underground storage tanks.

In performing independent oversight evaluations,groundwater protection and monitoring programs wereevaluated against the applicable provisions in DOEOrder 5400.1 and accepted industry practices. Inparticular, independent oversight evaluations critiquedthe adequacy of groundwater plume characterization,groundwater protection activities associated withoperational facilities, and management processes fortrending, tracking, and reporting groundwater monitoringinformation.

Aerial View of a Radioactive Liquid Waste Treatment Facilityat Los Alamos National Laboratory

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Environmental Radiological Monitoringand Surveillance

Effluent monitoring and environmental surveillanceof radioactive materials are a continuing major part ofthe radiological protection programs at DOE sites.Under the Atomic Energy Act of 1954, as amended,DOE is obligated to regulate its own activities to provideradiation protection for both workers and the public.DOE conducts effluent monitoring and environmentalsurveillance programs to determine whether the publicand the environment are adequately protected duringDOE operations and whether operations are incompliance with DOE and other applicable Federal,state, and local radiation standards and requirements.It is DOE policy that site monitoring and surveillanceprograms be capable of detecting and quantifyingunplanned releases and meet high standards of qualityand credibility. DOE’s objective is to properly andaccurately measure radionuclides in effluents andambient environmental media at all DOE sites andoperations.

Radiological effluent monitoring and environmentalsurveillance programs may consist of liquid and aireffluent monitoring, and environmental surveillance ofair, liquids, sediments, soil, food products (terrestrialand aquatic), wildlife, and vegetation. Effluentmonitoring is performed to quantify the amounts andlevels of contaminants released into the environmentin air and liquid process discharges. Environmentalsurveillance is designed to survey and quantify anyeffects that routine and non-routine site operations may

have on the environment or receptors. These programsshould be based on a radiological critical contaminant/critical pathway analysis that considered such factorsas site operating history, release pathways, sourceterms, transport, exposure pathways, dose, and theresulting risk. The requirements applicable toenvironmental monitoring programs are delineated inDOE Order 5400.1, DOE Order 5400.5, and DOE/EH-0173T, Environmental Regulatory Guide forRadiological Effluent Monitoring andEnvironmental Surveillance. Environmentalradiological monitoring and surveillance programs wereevaluated against the applicable provisions of DOErequirements and accepted industry standards.

Radiological Air Emissions

The basic elements of an effective radiological airquality program include source identification, ambientand source air emissions characterization (includingmonitoring programs), air pollution control equipmentoperation and maintenance, and reporting andcompliance management systems. The specificrequirements applicable to DOE radiological airprotection programs include DOE Orders 5400.1 and5400.5, and the National Emission Standards forHazardous Air Pollutants (NESHAPS) requirementsportion of the CAA, as delineated in 40 CFR 61,Subparts A and H. Radiological air quality programswere evaluated against DOE order requirements andcompliance with CAA requirements and associatedregulations.

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Performance Analysis3.0

This performance analysis is based on anexamination of past independent oversightevaluations of environmental monitoring andsurveillance programs and practices that wereconducted at 14 different sites across the DOEcomplex during fiscal years 1999 through 2002.The performance analysis is presented in fourareas: (1) groundwater monitoring and protection,(2) environmental radiological programmanagement, (3) environmental radiologicalmonitoring and surveillance, and (4) radiologicalair emissions. In each area, OA provides ananalysis of DOE’s overall performance, based onthe results of previous independent oversightreviews, and presents DOE-wide observations,which identify areas where DOE line managersand policy organizations should considerimprovements to policy, guidance, programmanagement, or program implementation.

3.1 Groundwater Monitoringand Protection

In general, independent oversight evaluationsdetermined that DOE sites have established stronggroundwater monitoring programs to supportenvironmental cleanup requirements. In mostcases, extensive monitoring networks, supportedby highly qualified personnel, have been developedto analyze subsurface legacy contamination.Groundwater plumes that are highly contaminatedand present a significant threat have been identifiedand bounded. For all sites evaluated, correctiveactions and engineering controls have been or arebeing put into place to address the most significantproblems. With few exceptions, sites wereappropriately sampling groundwater wells,analyzing samples for the appropriate set ofpotential contaminants, and reporting monitoringresults consistent with established cleanupagreements.

Observations in the groundwater protectionarea were made with respect to DOE site effortsto develop groundwater monitoring and protectionprograms to promote stewardship of groundwater

resources, trending and reporting mechanisms foranomalous monitoring results, and monitoring ofgroundwater plumes containing low concentrationsof contaminants.

Observations

1. Weaknesses were identified in sitegroundwater stewardship programs.Many DOE sites have not fully analyzed,controlled, and monitored for potentialreleases of hazardous materials fromoperational facilities into the groundwaterand soil column.

DOE expectations for groundwaterstewardship are included in DOE Order 5400.1.Chapter III.4.a establishes expectations for DOEsites to develop groundwater protectionmanagement programs to guide thecharacterization, protection, and remediation ofgroundwater resources. Chapter IV.9.b requiresthat “Groundwater that is or could be affected byDOE activities shall be monitored to determine anddocument the effects of operations on groundwaterquality.” Additionally, it specifies the developmentof a groundwater monitoring plan and theperformance of groundwater monitoring to providedata to permit the early detection of groundwaterpollution or contamination.

DOE operates numerous facilities in theexecution of its defense, energy research, andenvironmental management missions. Many ofthese facilities use or process hazardous chemicalsand radionuclides and create waste streams andbyproducts that must be recovered, treated, anddisposed. A significant number of DOE facilitiesthat have operated since the Manhattan Projecthave contributed to groundwater contaminationthrough leaks in sumps, process vessels, wastepiping systems, and underground storage tanks.Many of these facilities have been shut down andplaced under the stewardship of the EnvironmentalRestoration Program. Although some new facilitieshave been constructed, many facilities that werebuilt decades ago continue to operate with aging

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equipment, which can be susceptible to leaks anddegraded reliability.

Protection of groundwater resources aroundoperational facilities can be achieved by implementinga systematic approach to groundwater protection thatis consistent with the core functions of the DOEintegrated safety management process, which wouldinclude:

• Identifying the scope of all operations that havethe potential to impact groundwater quality

• Conducting environmental pathway analyses toidentify process equipment vulnerable to releases,and evaluating the potential impacts to groundwaterquality

• Establishing equipment surveillance andmaintenance programs to ensure the reliability ofvulnerable systems, and where appropriate,establishing groundwater surveillance monitoringnetworks in the vicinity of identified pathways toprovide for the early detection of any releases

• Performing groundwater surveillance monitoringand equipment surveillance and maintenance asestablished in internal procedures and plans

• Evaluating and improving operational performancethrough an analysis of surveillance and monitoringdata and periodic re-evaluations of planningassumptions, hazard analyses, and establishedcontrols.

Oversight evaluations determined that groundwaterprotection management programs at many DOE siteshave not been sufficient to provide a systematicapproach to protect groundwater resources. At somesites, releases from operational facilities were notprevented or identified and mitigated in a timely manner.Problems identified through oversight reviews and eventinvestigations included:

• Incomplete identification of threats to groundwater,including the existence of active and legacy tankswith chemical and/or radiological contents. At twosites, large forty-year-old, single-walled concreteprocess tanks, used in radiological process waterstorage and wastewater treatment operations,were not identified as a potential threat togroundwater quality.

• An incomplete understanding of the hydrogeologyin the vicinity of facilities, resulting in a monitoringstrategy that was not able to detect releasesconsistent with management expectations.

• An incomplete analysis of the potential pathwaysfor release of hazardous materials from processvessels, storage tanks, and piping systems to theenvironment, resulting in the existence ofunidentified equipment vulnerabilities and releasepathways. Some sites have good inventories oftanks, sumps, and process lines; however, theirexistence is sometimes not known by facility orenvironmental managers who are responsible forgroundwater protection.

• Configuration of facility piping systems, sumps, andtanks not understood or not consistent with as-builtdrawings, resulting in inappropriate well placementand inappropriate reliance on surveillancemonitoring of building foundation drains.

• Surveillance and maintenance of process equipmentnot adequate to detect deteriorating equipment,creating unmonitored pathways to the environment.

• Inadequate surveillance monitoring in the vicinityof operational facilities and hazardous materialstorage and conveyance systems, resulting inundetected or partially analyzed impacts ongroundwater quality.

• Systematic elimination of monitoring wells nearoperational facilities because baseline informationabout water quality was developed. Thesedecisions were made without the benefit of ananalysis of potential release pathways and resultingpotential threats to the groundwater resources.

Liquid Sampling at an Outfall

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Inconsistent understanding of DOE expectationscontributes to weaknesses in groundwater protectionmeasures for operational facilities. Some DOE fieldoffices have not incorporated groundwater stewardshiprequirements in contracts even though facilities andactivities pose potential threats to groundwaterresources. Additionally, although DOE Order 5400.1contains specific requirements for monitoring, facilitypathway analysis, and groundwater protection planning,DOE sites have various interpretations about the levelof effort and diligence required for operational facilitymonitoring. In some cases, line managers did notunderstand the need to establish controls untilconfronted with an actual site release. Independentoversight reviews found that several sites haveresponded appropriately in reaction to identifiedgroundwater contamination events. DOE organizationsmay want to evaluate efforts that were undertaken atthe Brookhaven National Laboratory and the Oak RidgeNational Laboratory to systematically identifygroundwater contamination vulnerabilities associatedwith current operations.

DOE has not established strategies or requirementsfor the surveillance, maintenance, or phaseout of single-walled tank and piping systems used for someradiological services. While many single-walled tanksand piping systems (i.e., systems used in routineradiological processes or for low-level wasteapplications) have been abandoned or replaced withmodern double-walled equipment that has leak detectioncapabilities, single-walled equipment still remains inservice at some DOE sites, presenting vulnerabilitiesto groundwater resources. This situation is notconsistent with the stringent regulatory standards thathave been promulgated by EPA and state agencies forthe storage of petroleum products. This observationdoes not apply to high-level waste tanks, wheresignificant efforts have been made to developremediation and closure strategies.

The DOE Headquarters Office of Environment,Safety and Health (EH) should work with linemanagement in clarifying DOE expectations regardinggroundwater protection measures associated withoperating facilities, including use of single-walled tankand piping systems for radiological services. DOE linemanagers should review their groundwater protectionmanagement programs to ensure that all operationalactivities potentially impacting groundwater qualityhave been identified; contaminant release pathwaysand potential impacts have been analyzed; andnecessary monitoring and equipment surveillancecontrols have been established and implemented.

2. Independent oversight reviews identified anumber of cases where line management hasnot exercised sufficient diligence in thetrending and tracking of groundwatermonitoring data to ensure that changes ingroundwater contamination conditions arefully identified and reported.

Insufficient attention to groundwater monitoringdata, particularly in the stewardship programs requiredby DOE orders, has contributed to shortcomings in thetrending, interpreting, and reporting of results at severalDOE sites. In a few cases, failure to report newdiscoveries or increases in groundwater contaminationlevels in a timely manner has contributed to stakeholderconcern. Identified problems included:

• The failure to trend monitoring data fromgroundwater wells and building foundation drainscontributed to the delayed discovery of a processwaste pipe failure and a release to the environment.

• The performance of trending and interpretation ofgroundwater monitoring data on an annual basisrather than on a continuous basis resulted in delaysin identifying an anomaly from identified baselinewater quality conditions.

• The utilization of multiple databases forgroundwater monitoring analytical results increasedthe difficulty at several sites in analyzinggroundwater contamination information.

• A lack of formalized processes for systematicallytrending, documenting, and interpretinggroundwater monitoring results limits the utility ofthe monitoring for identifying changingenvironmental conditions. The lack of suchprocesses was particularly noticeable in monitoringof wells near operational facilities and the programsfor monitoring sitewide and backgroundcontamination levels.

• The absence of formalized reporting proceduresand criteria for monitoring results, includingspecifications for identifying unanticipated results,created the potential for delays in notifyingresponsible managers and stakeholders, and delaysin response actions. In one case, site analyticaldata was only captured in a database, and was notreported to responsible facility managers orenvironmental coordinators.

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Trending and reporting of groundwatercontamination information associated withenvironmental restoration program activities weregenerally effectively performed. The rigorous reportingrequirements from site regulators and the high levelsof technical resources and competencies within DOEsites dedicated to cleanup activities contribute to theeffective performance in this area.

Line managers should review their practices fortrending, interpreting, and reporting groundwatermonitoring data to ensure that analytical data is fullyutilized for identifying changing environmentalconditions. Line managers should ensure thatprocedural controls consistent with managementexpectations have been established for trending andfor reporting anomalous conditions.

3. In some cases, groundwater plumescontaining lower concentrations ofcontaminants have not been monitoredthrough direct measurement to determine thefull nature and extent of the contamination.

The presence of groundwater contamination, evenin low concentrations (i.e., in the range of drinking-water standards or below), can cause significant publicrelations repercussions because of a high level ofinterest and concern by residents living near most DOEsites. This is particularly true when contamination ispresent in the vicinity of site property boundaries, aboveaquifers used for drinking water and irrigation sources,or where plumes discharge into surface water bodies.While these conditions may not present significant publicor environmental risks, DOE line management needsto have sufficient information to support definitivetechnical conclusions and to provide assurance tostakeholders. At some DOE sites, much work remainsto complete the investigation of groundwatercontamination occurring at relatively lowconcentrations. Problems identified through oversightreviews included:

• At several sites, contaminated source areas haveresulted in plumes of low concentrations extendingsignificant distances. The furthest reaches of theplumes were not monitored. Plume pathways anddischarges of contamination to surface water werenot understood, leading to uncertainties in the fateand transport of contaminants in the environment.

• At one site, large plumes of contamination havebeen characterized in the upper water table aquifer.

Due to the site’s hydrogeology, migration ofcontaminants downward through less permeablematerials has been expected for several years.Moreover, the regional drinking-water aquiferunderlies the site. Monitoring in the lower watertable aquifer has been sparse and inadequate fordemonstrating the protection of drinking-watersupplies.

• Low-concentration volatile organic compound andtritium plumes at several sites were identified, butwere not fully defined through hydrologicalinvestigations and monitoring. No additionalcharacterization of these areas was planned. Inthese cases, line management assumed thatcontaminants would naturally attenuate within theenvironment; however, they did not have thenecessary level of monitoring to systematicallyevaluate the performance of natural attenuationover time.

• Monitoring was not always performed to definethe presence or extent of offsite groundwatercontamination occurring at low concentrations. Atone site, monitoring was not in place down gradientof a groundwater containment slurry wall to validatethe effectiveness of the wall in preventing offsitemigration. At another site, low levels of tritiumcontamination (below drinking-water standards)were found in wells installed at a site propertyboundary adjacent to a site landfill. Offsitemigration of the plume is clear; however, wellshave not been installed in offsite areas where tritiummigration is highly likely. At another site, monitoringwas not adequate to determine that an offsite plumehad migrated to the point where it discharged to ariver.

• In several cases, published groundwatercontamination maps did not always accuratelyportray the presence or extent of known orsuspected offsite contamination.

Overall, line management has appropriatelyprioritized resources and is appropriately managinginvestigations and remedial activities to address DOE’svast groundwater contamination challenges. However,there are clear liabilities associated with the existenceof low-level contamination plumes. In some cases,stakeholders have expressed significant concerns aboutthe discovery of unanticipated occurrences of

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groundwater contamination from DOE sites occurringat both onsite and offsite locations. DOE has alsoexperienced significant negative media coverage insome cases, which distracts management and detractsfrom the credibility of DOE’s environmental programs.

DOE line managers should review their site-specific groundwater monitoring programs to verifythe adequacy of their programs for monitoring andreporting groundwater contamination occurring at lowconcentrations. Line management should ensure thatsufficient investigations have been performed, orincluded in site project plans, to confidently determinethe extent of all known groundwater contamination.

EH should consider enhancements in DOEdirectives and guidance to better articulate the level ofdiligence required to investigate and monitor low-levelgroundwater plumes on DOE sites.

3.2 Environmental RadiologicalProgram Management

All evaluated DOE sites and contractors haveestablished programs and assigned personnel toimplement environmental radiological protectionresponsibilities. However, independent oversightreviews identified a number of specific programmaticareas where implementation weaknesses existed,inconsistent approaches were implemented acrossDOE, and DOE expectations are unclear.Observations were made in the application of healthphysics expertise to environmental programs,application of ALARA principles to environmentalconcerns, release of materials from radiologicalcontrols that may be volumetrically contaminated, andrequirements and practices for managing radioactivelycontaminated soils and soil columns.

Observations

1. The application of qualified health physicsresources to environmental programs atsome sites has not been sufficient to ensurethat DOE radiological requirements andobjectives are met.

Radiological requirements and standards aregenerally technical in nature, often requiringprofessional interpretation. DOE integrated safetymanagement guiding principles require that allindividuals possess a level of competence

commensurate with their responsibilities. As such,individuals responsible for directing, managing,implementing, or overseeing these programs mustpossess analytical skills and an educational foundationthat includes a background in health physics or radiationprotection.

At some sites, personnel who were responsible forevaluating technical data, making decisions, andpreparing and/or reviewing health physics-relatedreports had limited training and qualifications in healthphysics disciplines. Consequently, errors and omissionsoccurred in the planning, implementation, evaluation,and reporting of a number of elements of siteenvironmental programs, including:

• Several sites published reports containinginaccurate technical information, such as incorrectderived concentration guides for comparison ofsampling data.

• One site failed to consider available isotopicinformation, leading to erroneous calculations thatunderestimated radiological risk.

• At several sites, environmental restoration activitiesin support of CERCLA or RCRA actions were notperformed consistent with DOE and health physicsindustry requirements and guidance.

• Several sites failed to properly post areas ofenvironmental radiological contamination, and mostsites did not have specific posting criteria consistentwith DOE expectations and guidance.

• Several sites failed to investigate unusually highsampling results or to set thresholds for initiatingactions in response to high sampling results.

• Several sites failed to include appropriate dataquality objectives in support of environmentalsampling activities, rendering the data collected oflimited value.

Environmental radiological analyses and decision-making were generally of higher quality, and errors inreports and evaluations were less frequent, at siteswhere responsibility for environmental radiationprotection was more closely tied with the site healthphysics organization. This trend may be partiallyattributed to the greater ability of personnel withenvironmental responsibilities to consult with qualified

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health physics resources and obtain peer review ofhealth physics-related technical work.

Skill shortfalls identified during inspections indicatethat more emphasis is needed to ensure appropriateprofessional competence in environmental radiologicaldisciplines at both the DOE and contractor levels. Sitesshould take measures to ensure that adequate andqualified health physics resources are available toimplement environmental radiological programs, and thatclear accountability mechanisms are established for thetechnical quality of these programs.

2. Many sites did not have mature programs andthe institutional documents necessary toeffect full and effective environmental ALARAimplementation, consistent with DOE Order5400.5.

The basic principle guiding the radiologicalprotection industry is that any exposure to radiation,including background exposures, poses some level ofrisk, even if it is too low to adequately quantify. Thus,while the regulatory framework specifies the familiarconcept of exposure and release limits, it also requiresthat exposures and releases be maintained ALARAbelow these limits, in keeping with the fundamentalpremise that any exposure possesses some incrementalrisk. DOE Order 5400.5 requires the ALARA processto be formally implemented at all DOE facilities thatcause public dose and/or release radioactive materials.The magnitude of the dose is not specified, and DOEguidance indicates that the ALARA process must beapplied no matter how small the dose. The ALARAprocess must also be applied to liquid discharges thatmay result in the need for future remediation or furtherthe spread of legacy radiological contamination withinthe environment.

At many sites, the environmental ALARA programis not sufficiently formalized, and personnelresponsibility for environmental ALARA has not beensufficiently defined. As a result, some activities havenot received adequate and/or documented ALARAreviews that include justification and consideration ofalternatives that might further reduce doses and potentialenvironmental radiological impacts. The following aresome examples of weaknesses in environmentalALARA decision-making and implementation that werenoted during the oversight evaluations:

• Most sites, while having a formal occupationalALARA program, did not have a similarlydeveloped environmental ALARA program.

• At one site, radioactivity in the form of depleteduranium was being intentionally added to wasteprior to incineration to meet nuclear criticality safetyrequirements, without a formal or documentedALARA review that justified this activity andprovided assurance that all possible alternativeoptions were explored.

• Many sites did not adequately incorporate theALARA process in the review and analysis ofenvironmental discharges and monitoring data. Forexample, at one site, derived concentrationguidelines were incorrectly applied as de facto liquidradiological discharge limits. As such, furtherreductions in radiological concentrations, althoughpossible, were not considered. At several sites,radiological effluent concentrations were biasedlow because of the placement of sampling pointsat locations significantly impacted by dilution withprocess streams; thus, the potential for furtherreducing radioactivity in the contributing processliquid streams was not adequately considered.

• At several sites, areas of legacy environmentalcontamination were not being managed in a mannerthat would minimize continued and furtherenvironmental atmospheric releases from fugitiveemission, or minimize the spread of contaminationfrom liquid runoff.

The full integration of the ALARA principle intoDOE environmental programs has lagged behind itsapplication to occupational health and safety programs.Sites should take actions to ensure that the appropriatemechanisms, procedural requirements, and training andperformance criteria are developed and implementedas needed to foster the full integration of the ALARAprocess into environmental programs, consistent withDOE Order 5400.5 and associated guidance.

3. The absence of clear radiological soil postingstandards and requirements has resulted ininconsistent hazard analyses and controlacross DOE sites that have soil and sedimentcontamination.

Title 10 CFR 835 specifies legal requirements forposting of areas that contain surface radioactivecontamination, but it does not include requirements forposting areas of contamination where the radioactivityis volumetrically distributed, such as in the case of

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outdoor soils or sediments. Many DOE sites haveoutdoor areas of soil and sediment contamination bothwithin and outside site boundaries. The DOERadiological Control Standard (DOE-STD-1098-99)calls for the establishment of posted soil contaminationareas for any area that contains soil that is not releasablein accordance with DOE Order 5400.5. However,DOE Order 5400.5 release criteria provisions are notspecific (i.e., concentration limits are not specified),thereby requiring case-by-case approval of volumetriccontamination or “release” limits by EH. A number ofproblems with this approach were identified by oversightevaluations, including:

• The term “releasable” is subjective because thereare a number of different scenarios that could bepostulated for radiological release (i.e., unrestricted,restricted, commercial, and residential). Therefore,a broad range of releasable values (and resultingrisks) for the same radionuclide can be postulatedand derived.

• Most sites were found to have no specific soil orvolumetric posting criteria.

• One site had specific criteria that would requireposting of soil contamination only when the doseconsequence might exceed the DOE public doselimit of 100 millirem (mrem). In this case, the useof 100 mrem as a threshold in the derivation wasinconsistent with DOE’s single pathway doseconstraint of 30 mrem (i.e., residual soil is a singlepathway, and other pathways might contribute doseto an individual who may then exceed the DOE100-mrem limit). The 30-mrem constraint isspecified only in a DOE guidance document.

• Such interpretive variations can allow for significantlevels of contamination to exist in unposted areas,and the resulting levels of contamination could poserisks that are greater than those derived from 10CFR 835 surface contamination posting levels.

• Areas of unposted and inconsistently postedradiological contamination were noted at severalsites.

EH should take steps to revisit standards andguidance and modify the requirements in a manner thatis commensurate with the hazard and the level of riskassociated with surface contamination posting and

release requirements noted in 10 CFR 835 and DOEOrder 5400.5

4. Some sites have not properly followed therequirements of DOE Order 5400.5 andsupporting guidance for offsite releases ofmaterials that may be volumetricallycontaminated with residual radioactivematerials.

The requirements for release of property fromDOE’s radiological control are published in DOE Order5400.5, Chapter II. While numerical standards andmethods have been defined for materials and equipmentthat may have surface contamination, no guidance iscurrently available for release of materials that mayhave been contaminated throughout its volume, suchas activated material or smelted contaminated metals(e.g., radioactivity per unit volume or per unit mass).In accordance with DOE Order 5400.5, such materialsmay only be released if criteria and survey techniquesare approved by the Assistant Secretary for

Air Stack

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Environment, Safety and Health (EH-1). Furtherclarification of this requirement was published in a 1995EH memorandum. Independent oversight reviewshave found several cases where potentiallyvolumetrically contaminated materials were beingreleased to the general public or sanitary landfills withoutanalytical results that adequately demonstrated thematerial did not contain site-derived concentrations ofradioactive material above background or evidence ofappropriate authorization from EH-1.

• At one site, sludge generated at a liquid radioactivewaste treatment facility was being released to asanitary landfill without a requirement for samplingor evidence of EH-1 approval of sampling methodsand limits that were used periodically.

• One site was releasing potentially contaminatedscintillation “cocktail” to a commercial hazardouswaste disposal company without consideration ofDOE Order 5400.5 requirements.

• One site released equipment containing potentiallycontaminated liquid to a private company withoutfull characterization or the required authorizationsfrom EH-1.

Some of the sites were unfamiliar with the 1995clarification of requirements for release of volumetricallycontaminated materials. EH should formalize guidanceclarifying DOE Order 5400.5 requirements to ensurethat personnel responsible for implementation ofrequirements are aware of DOE expectations.Additionally, there is no acceptable industry-wide“below regulatory concern” policy for volumetricallycontaminated material; thus, EH should publish guidanceoutlining examples of the types of materials that needto be evaluated and specifying appropriate analyticalmethods and data quality objectives for demonstratingthat potentially volumetrically contaminated materialsare indistinguishable from background and can thereforebe released. Ultimately, publication of specificvolumetric release limits for volumetrically contaminatedmaterial following industry accepted guidance, such asthe American National Standards Institute HealthPhysics Society standards for clearance (or anotherconsistent approach), would eliminate confusion andsubjectivity associated with current DOE requirements.

5. DOE Order 5400.5 requirements formanagement of soil columns and inactiverelease areas were not always properlyfollowed or considered in dischargestrategies.

DOE Order 5400.5 defines a soil column as an insitu volume of soil through which liquid wastes percolatedown from ponds, cribs, seepage basins, or trenches.The use of soil columns to retain, by sorption or ionexchange, suspended or dissolved radionuclides fromliquid waste streams was prohibited when DOE Order5400.5 was issued in 1990. The practice was usedextensively at some sites prior to 1990, resulting insignificant radiological contamination in certain areasaround these sites. In an effort to prevent the furtherspread of radionuclides in the environment, DOE Order5400.5 placed a prohibition on the use of soil columnsas a treatment practice and prohibits further dischargeof any liquids, including uncontaminated liquids, topreviously contaminated release areas.

A common problem noted at DOE sites wasinsufficient consideration of DOE Order 5400.5 soilcolumn requirements relative to current practices fordischarging radiological, nonradiological, and/orpotentially contaminated liquids to previouslycontaminated land areas. Liquid discharges have beenoccurring at several sites without formal evaluationagainst DOE Order 5400.5 soil column and ALARArequirements, which are intended to prevent thecontinued spread and migration of previously depositedradionuclides in the environment. The hazards posedby ongoing discharges were not evaluated against theDOE Order 5400.5 soil column and ALARArequirements or integrated into sitewide liquid dischargegoals, objectives, and long-term strategies.

Several sites did not consider the DOE prohibitionon new soil columns when ponds or settling basins thatcould have contained radiological contamination wereused or where new basins were constructed. In thesecases, documentation to demonstrate that these areaswere not or would not be receiving contaminated liquidsand thus become soil columns was not available.

There is some ambiguity in the soil columnprovisions contained within DOE Order 5400.5. Forexample, the soil column definition does not explicitlydefine soil columns as engineered features designedspecifically for the treatment of liquid wastes. At somesites, contaminated soil columns (as defined in DOEOrder 5400.5) in the form of trenches and gullies have

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been created naturally where there is a lack of surfacewater flow with a similar end result as an engineeredsystem. While the intent of DOE Order 5400.5 is tominimize contamination in the environment to eliminatethe need for future remediation, application andunderstanding of the requirements have varied. EHshould revisit the soil column requirements, includingdefinitions and sections on liquid releases to previouslycontaminated areas, to provide additional clarity and toeliminate subjective interpretations from lineorganizations responsible for implementation.

3.3 Environmental RadiologicalMonitoring and Surveillance

All sites performed some form of environmentalradiological monitoring and surveillance. The level ofthe monitoring and surveillance was generally consistentwith DOE expectations and guidance. With fewexceptions, site environmental monitoring programswere found to be capable of detecting major releasesor migration of radionuclides. However, areas forimprovement and refinement were noted in a numberof aspects. Observations were identified with respectto radiological characterization of liquid effluents,reliance on gross indicator parameters, data qualityobjectives for environmental sampling, and sedimentmonitoring.

Observations

1. At most sites, settleable solids were notbeing analyzed, and compliance was not beingdocumented.

As discussed in DOE/EH-0173T, water samplingis generally not an effective indicator of low levels ofwaterborne radionuclides. For this reason, sedimentsampling and assessment of radioactivity content ofsettleable solids in liquid discharges is required to ensurethat long-term accumulation of radioactivity insediments is properly controlled. DOE Order 5400.5,Chapter II.3, limits the amount of radioactivity that canbe present in settleable solids in liquid discharges tosurface waters to five picoCuries per gram (pCi/g)alpha and 50 pCi/g beta-gamma. This limit isestablished to prevent buildup of radioactivity insediment. Although it is not likely that any sites areexceeding the limit, numerous problems withunderstanding and demonstrating compliance with

DOE order requirements were evident. Examplesincluded:

• None of the sites visited were conducting therequired analysis of settleable solids to demonstratecompliance with the DOE Order 5400.5 limit.

• Many sites believed that there were insufficientquantities of settleable solids in the effluent toaccurately measure, and used this informal andundocumented belief as a basis for the lack ofmonitoring.

• Some sites incorrectly used information in a 1995EH memorandum (intended to clarify the methodof demonstrating compliance) to justify anexemption from the settleable solids requirements.

The instances of insufficient demonstration ofcompliance with this provision of DOE Order 5400.5may be partially attributed to unclear and/or fragmentedguidance for DOE’s expectations. In addition, mostsites believe that the level of settleable solids in liquiddischarges is so small that it is insignificant, and notworth the expense of monitoring in accordance withthe published DOE methodology. However, indirectmethods of demonstrating compliance have beenauthorized by EH and documented in specificmemoranda. Sites should ensure that they performsufficient analyses and have a sound technical basis todocument compliance with this requirement.

2. Sediment sampling locations and rigor werenot always sufficient to detect contaminationand evaluate trends.

The sampling of sediments from streams or pondscan provide an indication of the accumulation ofundissolved radionuclides in the aquatic environment.The accumulation of radioactive materials in sedimentcan lead to exposure of humans through ingestion ofaquatic species, through sediment resuspension intodrinking-water supplies, or as an external radiationsource for people who are fishing, wading, orsunbathing. Because of the accumulation ofcontaminants, sediment sampling is a more sensitiveindicator of waterborne radionuclides than watersampling or, for some aquatic species, aquatic biotasampling. At a number of sites, the sediment samplingprogram did not adequately characterize environmental

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impacts posed by liquid discharges and runoff fromcontaminated areas. For example:

• Sediment sampling locations were often not closeenough to source areas to detect radionuclidemigration in a timely manner.

• Incomplete characterization of known impactedareas affected the quality and consistency of publicdose estimates.

• Some radionuclides potentially present at sites werenot being analyzed.

Sites should review sediment sampling programsto ensure that sampling locations are sufficient in numberand placement and that analytical methods aresufficiently sensitive to distinguish any site-derivedradionuclides, and to evaluate both short- and long-termaccumulation of contaminants and/or migration ofradioactivity from source areas.

3. A number of sites relied too heavily on grossalpha and beta analyses and did not routinelyestablish proper data quality objectives insupport of environmental radiologicalsampling and decision-making.

Natural background radiation includes both alphaand beta particles, which are emitted from mostenvironmental media. Some DOE site-derivedradionuclides are not present naturally and theirpresence cannot be effectively identified with grossalpha and beta techniques because of insufficientanalytical sensitivity and interference from naturallyoccurring radioisotopes. Some of the possible DOEradionuclides, such as plutonium and neptunium, havea much higher radiotoxicity than the naturally occurringradioisotopes, making it imperative that they be correctlyidentified and quantified if they are present inenvironmental media. Specific radiochemical analysisis often required. For all radionuclides, trending andearly detection of possible impacts, including the abilityto distinguish the site-derived component from naturalbackground, are key objectives of environmentalmonitoring and surveillance programs and are requiredto make effective radiation protection and wastemanagement decisions. The following types ofproblems were identified by oversight evaluations atmany sites and are the result of relying too much onthe use of gross radiation measurements without

corresponding isotopic analysis and data qualityobjectives:

• Failure to establish appropriate volumetriccontamination limits for possible low-levelradioactive waste

• Inability to distinguish site-derived radionuclidesfrom natural background

• Lack of proper requests to provide appropriateminimum sensitivity for requested radiologicalanalyses, resulting in minimum detectable activitymuch higher than that needed

• Use of gross alpha, beta, or total uranium results,with no guidance on levels of concern or specificactions to be taken

• Use of total uranium results to calculate isotopicuranium values without knowledge of specificenrichment levels

• Analytical results with error ranges higher than thestated results.

While the use of gross alpha and betameasurements is an acceptable and valuable tool inevaluating trends and qualitatively determining sampleactivities, sites should ensure that specific isotopicanalyses at a predetermined sensitivity are performedregularly to complement the gross measurements andto provide a technical basis for decision-making. Insome cases, gross alpha and beta measurements canbe used as surrogates for a specific isotopic analysis,provided an appropriate evaluation has been conductedand documented to support the basis. In addition, theestablishment of appropriate data quality objectives,including minimum required laboratory sensitivities andrelated parameters, should be established beforeperforming any analytical work.

3.4 Radiological Air Emissions

All sites were found to have an active NESHAPSprogram that was effective in meeting applicable dose-based Federal air regulations for radionuclides.However, weaknesses were noted in certain elementsof the air quality programs that form the basis for

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compliance with requirements and affect the accuracyand validity of the program’s technical bases. Forexample, one site did not possess appropriatedocumentation supporting the potential to emitcalculations, which determines the status of the stackunder 40 CFR 61, Subpart H. Other areas whereimprovements were needed included stack sample linedesign and placement, and ambient air monitoring. Atseveral sites, although sampling systems comply withbasic requirements, the sites could not demonstrate thatsampling was actually representative of the contaminantflow through the stack because of such variousconditions as saturated stack environments or thepresence of multiple 90-degree bends in stack samplelines.

One observation was made with respect to ambientair monitoring systems.

Observation

1. Ambient air monitoring programs are notalways considering minimum dose sensitivity,release conditions, and particle size.

Data collected from ambient air monitoringprograms is generally used as a supplemental methodto demonstrate and validate the low levels of emissionsmodeled by calculation under NESHAPS. This data isoften reported in site environmental reports andNESHAPS reports as evidence of low emissions. As

such, technical accuracy and rigor are important toestablish and maintain credibility. There are limitationsassociated with these systems that have not alwaysbeen appropriately considered or defined as part ofreporting processes. For example:

• Only one site evaluated had documentation of theminimum dose the samplers would be able tocapture at the minimum detectable activity. Thelow-volume samplers used at many sites furtherhinder the minimum sensitivity of the samplers.Contrary to statements made in annual NESHAPSreports, most sites have not established ordocumented that the limit of detection matches thepurpose of the sampler, such as providing evidence(beyond calculations) that the 40 CFR 61, SubpartH, 10-mrem limit has been met, or that a dose of10 mrem or less, above background, can bedetected.

• Siting of air samplers was problematic at severalsites. Studies were either not performed or did nottake into account the type of release the samplerswere designed to measure.

DOE line managers should evaluate ambient airmonitoring systems for radionuclides to ensure adequateselection and citing of samples. Evaluate and includein applicable environmental reports the minimum dosesensitivity of the ambient air monitoring system.

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Conclusions4.0

Independent oversight evaluations determinedthat all sites had established environmentalmonitoring, surveillance, and control programs toimplement regulatory requirements and DOEcontractual obligations. The level of resources andprogram formality was generally consistent withthe hazards posed by operational activities andlegacy contamination. Site environmentalsurveillance programs have been ongoing for manyyears, and an extensive baseline of information oncontamination in environmental media has beendeveloped. At all DOE sites evaluated, monitoringdata demonstrates a decreasing trend in the levelsof radiological discharges to the environment inair and water pathways. This can be directly linkedto the reduction in operational activities, regulatorypermitting and inspection programs, andimplementation of pollution prevention and pollutioncontrol projects.

Oversight inspections identified a number ofcommon strengths within DOE environmentalmonitoring, surveillance, and control programs.

• Extensive groundwater monitoring networkshave been developed to support environmentalrestoration efforts. Groundwater plumes thatare highly contaminated and present asignificant threat have been identified, andmany are undergoing remediation.

• The level of the radiological monitoring andsurveillance was consistent with most DOEexpectations and guidance, and was adequateto detect any major releases or migration ofradionuclides.

• All sites evaluated have active NESHAPSprograms that were effective in meeting dose-based radiological discharge limitations.

Independent oversight evaluations also noteda number of weaknesses in the implementation ofenvironmental monitoring, surveillance, and controlprograms as discussed in detail in the observationsin Section 3. In most cases, these weaknessesinvolve small amounts of radioactive material and/

or pathways that do not result in significant radiationexposures to workers or the public. Further, forthe most part, DOE sites have adequately identifiedthe higher hazard conditions and are takingappropriate corrective and remedial actions.However, the weaknesses identified in Section 3indicate a need for further analysis and attentionto ensure that improvements are made in DOEenvironmental monitoring and surveillanceexpectations and program implementation.

Three factors appeared to contribute to mostof the observations contained in this report:

1. DOE expectations for environmentalmonitoring, surveillance, and control arenot consistently understood, fully definedin all areas, or invoked in DOE contracts.

Many of the weaknesses identified in oversightreviews stemmed from insufficient understandingor clarity of DOE expectations. Site personnelwere either unaware of DOE expectations or didnot accurately interpret the specific expectationscontained in DOE Orders 5400.1 and 5400.5 andguidance documents. This factor was observedconsistently in the areas of groundwaterstewardship; application of ALARA principles toenvironmental releases; demonstrating compliancewith DOE limits on settleable solids in liquideffluents; and releasing volumetricallycontaminated materials from radiological controls.In several areas, oversight evaluations determinedthat DOE had not established clear expectations.DOE occupational radiation protection regulations(10 CFR 835), Order 5400.5, and standards do notestablish clear expectations for posting and controlof radioactively contaminated soils, resulting ininconsistent and in some cases non-conservativecontrol practices. Additionally, ambiguitiesregarding the prohibition on liquid discharges to soilcolumns were found in DOE requirements.

Problems in the implementation of DOEexpectations for environmental monitoring andcontrols can also be linked to the age of DOEorders and guidance, and deficiencies in theimplementation of the Work Smart Standards.

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DOE Orders 5400.1 and 5400.5 have not been updatedin nearly a decade and contain outdated information.Additionally, supplemental guidance has been issuedover the years by EH and through various memoranda.However, oversight reviews determined that responsiblesite personnel did not consistently have knowledgeconcerning the existence and content of thesememoranda.

DOE managers at some sites have utilized the WorkSmart Standards process to tailor DOE environmentalmonitoring, surveillance, and control requirementsapplicable to the scope of work to be performed bymanagement and operating contractors. In most cases,a diligent effort was undertaken to establish a set ofrequirements appropriate to the work and hazards. Inseveral cases, implementation of the Work SmartStandards process was not consistent with its intent.In these cases, managers did not incorporate DOEgroundwater protection and radiological monitoring andcontrol requirements, or alternate standards, intomanagement and operating contracts, even though therewere substantial operational activities and legacyconditions that necessitated reliable controls anddefensible environmental measurements.

2. There is insufficient professional radiologicalexpertise being applied to environmentalradiological protection programs at somesites.

Oversight evaluations determined that some sitesdid not have or apply necessary health physics expertiseto effectively manage environmental radiologicalprotection responsibilities. At some sites, personnelwho were responsible for evaluating technical data,making decisions, and preparing and/or reviewing healthphysics-related reports had limited training andqualifications in health physics disciplines. This resultedin errors and omissions in the planning, implementation,evaluation, and reporting of a number of elements ofsite environmental programs. Generally, betterperformance was noted at those sites whereresponsibility for environmental radiological protectionwas most integrated with the sitewide health physicsprogram.

3. Insufficient application of resources toenvironmental monitoring programs hasimpacted the ability to characterizeenvironmental conditions in some areas.

Oversight reviews have found that many sites havesignificantly reduced the resources allocated toenvironmental monitoring. Resource constraints atsome sites have resulted in a significant reduction ofDOE and contractor environmental support personnel,the number of monitoring stations, monitoring frequency,and analytical parameters. While some of the observedreductions were justified based upon the developmentof comprehensive baseline information, resourcereductions have directly impacted some sites’ ability tofully characterize DOE contaminants in theenvironment. Resource reductions were observed tohave contributed to an inappropriate reduction ofgroundwater surveillance wells near operationalfacilities; over-reliance of gross alpha and beta analyticalmeasurements; insufficient characterization of sedimentmigration pathways; and failure to periodically monitorcontaminants in some environmental media, includingbiota and foodstuffs, to confirm baseline information.

The capability of many DOE field organizations tomanage and oversee environmental monitoringprograms has been limited by loss of experiencedpersonnel and sustained hiring limitations. In additionto the above-mentioned concerns on environmentalradiological expertise, management contractors havealso experienced staffing constraints for environmentalmonitoring positions. In particular, the loss ofexperienced hydrogeologists has also hinderedgroundwater protection and remediation programs atsome sites.

Sampling Wetlands

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Opportunities for Improvement5.0

In the spirit of promoting continuousimprovement, some specific opportunities forimprovement have been identified. These potentialenhancements are not intended to be prescriptive.Rather, they are intended to be reviewed andevaluated by the responsible DOE and contractorline management and prioritized and modified asappropriate, in accordance with site-specific andDOE-wide programmatic objectives. Also, it is OA’sintention that these opportunities for improvementwill be useful in the ongoing efforts by EH to replacethe outdated DOE environmental protection orderwith a new environmental managementsystem-based order/manual and to consolidate andre-issue guidance documents.

DOE Line Organizations

DOE sites should compare their operationalpractices against the twelve specific observationsin this report to determine their applicability, andshould take corrective actions to address specificproblems and causal factors as appropriate. Specificactions to consider are summarized below.

1. Review groundwater protection programsto ensure appropriate monitoring andstewardship.

• Review groundwater protection managementprograms to ensure that all operational activitiespotentially impacting groundwater quality havebeen identified; contaminant release pathwaysand potential impacts have been analyzed; andnecessary monitoring and equipmentsurveillance controls have been established andimplemented.

• Evaluate efforts that were undertaken at otherDOE sites (e.g., Brookhaven NationalLaboratory and the Oak Ridge NationalLaboratory) to systematically identifygroundwater contamination vulnerabilitiesassociated with current operations. Incorporatelessons learned and best practices as applicable.

• Review practices for trending, interpreting, andreporting groundwater monitoring data toensure that analytical data is fully utilized foridentifying changing environmental conditions.Ensure that procedural controls consistent withmanagement expectations have been establishedfor trending and for reporting anomalousconditions.

• Review site-specific groundwater monitoringprograms to verify the adequacy of theirprograms for monitoring and reportinggroundwater contamination occurring at lowconcentrations. Ensure that sufficientinvestigations have been performed, or includedin site project plans, to confidently determinethe extent of all known groundwatercontamination.

2. Evaluate environmental sampling andanalysis methods and approaches toensure that they are sufficient todemonstrate compliance with applicablelimits and provide an adequate technicalbasis for the environmental monitoringprogram.

• Ensure sufficient analyses are performed toprovide a sound technical basis to documentcompliance with DOE settable solids dischargelimitations.

• Ensure that specific isotopic analyses at apredetermined sensitivity are performedregularly to complement the grossmeasurements and to provide an appropriatetechnical basis for decision-making.

• Review sediment sampling programs to ensurethat sampling locations are sufficient in numberand placement and that analytical methods aresufficiently sensitive to distinguish any site-derived radionuclides and to evaluate both short-and long-term accumulation of contaminantsand/or migration of radioactivity from sourceareas.

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• Evaluate ambient air monitoring systems forradionuclides to ensure adequate selection and citingof samples. Evaluate and include in applicableenvironmental reports the minimum dose sensitivityof the ambient air monitoring system.

3. Ensure that the ALARA principle issystematically applied to environmentalprograms.

• Establish appropriate mechanisms, proceduralrequirements, and training and performance criteriato foster the full integration of the ALARA processinto environmental programs, consistent with DOEOrder 5400.5 and associated guidance.

• Ensure that organizational/individual responsibility forenvironmental ALARA is assigned.

• Ensure that ALARA reviews are documented andare sufficient to identify alternatives that might furtherreduce doses and potential environmental radiologicalimpacts.

4. Evaluate the adequacy of application ofresources to environmental monitoring andsurveillance programs.

• Evaluate staffing allocations and hiring practices toensure that adequate and qualified health physicsresources are available to implement environmentalradiological programs.

• Ensure that clear accountability mechanisms areestablished for the technical quality of environmentalradiological programs.

• Evaluate resources allocated to environmentalmonitoring, with a particular focus on adequacy ofmonitoring stations, monitoring frequency, analyticalparameters, groundwater surveillance wells nearoperational facilities, characterization of sedimentmigration pathways, and periodic monitoring ofpathways, including contaminants in biota andfoodstuffs.

Office of Environment, Safety and Health

EH is currently in the process of replacing DOEOrder 5400.1 with a new environmental management

system order (Draft DOE Order 450.1)/implementationmanual and consolidating and re-issuing guidancedocuments. As part of this effort, and in coordinationwith the DOE program and field organizations, EH shouldevaluate the observations and causal factors identified inthis report and factor them into the ongoing efforts toupdate applicable environmental orders, standards, andguidance. Specific actions to consider are summarizedbelow.

1. Clarify DOE requirements and guidelines toensure that a consistent set of expectations hasbeen established for DOE field organizationsto implement environmental monitoring,surveillance, and control programs.

• Establish clear requirements for posting and controlof areas with radiologically contaminated soils.

• Clarify radiological control requirements for thedischarge of liquid effluents to soil columns.

• Clarify DOE expectations regarding groundwaterprotection measures associated with operatingfacilities, including the use of single-walled tank andpiping systems for radiological services.

• Provide guidance on the minimum level ofinvestigation, monitoring, and reporting of low-levelgroundwater plumes.

• Review requirements and guidance for the releaseof materials from radioactive controls that arevolumetrically-contaminated.

2. Re-evaluate the benefits of promulgatingregulations that codify DOE internal directivesfor radiation protection of the public and theenvironment.

• Evaluate DOE Order 5400.5 to ensure that itsrequirements provide sufficient standards forimplementing DOE’s authorities and responsibilitiesunder the Atomic Energy Act of 1954, as amended.

• Evaluate the benefits of regulations that encompassthe requirements for protecting the public andenvironments from exposure to radiation.

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Independent Investigation of the Paducah Gaseous Diffusion PlantPhase I

Independent Investigation of the Portsmouth Gaseous Diffusion Plant

Pantex Ground Water Monitoring and Reporting Program Review -Report to the Secretary of Energy

Inspection Report on the Gamma Irradiation Facility Pool Leak

Independent Investigation of the East Tennessee Technology Park

Focused Safety Management Evaluation of the Idaho NationalEngineering and Environmental Laboratory

Independent Review of the High Flux Isotope Reactor Tritium Leak

Independent Inspection of the Savannah River Site EnvironmentalMonitoring and Surveillance Programs

Inspection of the Argonne National Laboratory - East EnvironmentalMonitoring and Surveillance Programs

Inspection of the Lawrence Berkeley National LaboratoryEnvironmental Monitoring and Surveillance Programs

Focused Review of Environment, Safety and Health and EmergencyManagement at the Kansas City Plant

Inspection of Environment, Safety, and Health Management at theHanford Site

Inspection of Environment, Safety, and Health Management at theLos Alamos National Laboratory, Volume I

Inspection of Environment, Safety, and Health Management at theLawrence Livermore National Laboratory, Volume I

October 1999

May 2000

May 2000

September 2000

October 2000

January 2001

February 2001

April 2001

August 2001

August 2001

December 2001

March 2002

April 2002

July 2002

REPORT TITLE REPORT DATE

APPENDIX ARELATED INDEPENDENT OVERSIGHT

EVALUATION REPORTS

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APPENDIX BTEAM COMPOSITION

Project Team

Bill Eckroade, Project Leader, OA-50Vic Crawford, Environmental Engineer, OA-50Mario Vigliani, Health PhysicsTom Naymik, Groundwater Hydrogeologist

Quality Review

Michael Kilpatrick, Deputy Director, Office of Independent Oversight and Performance AssuranceDr. Pat Worthington, Director, Office of ES&H Evaluations, (OA-50)Dean Hickman, Project Manager

Performance Analysis cover.pdfPage 1