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OCR for page 38
5
Address Constraints to Technology
Implementation
The committees recognized that OST's ability to promote implementation
of new technologies is constrained by legal and regulatory requirements and
other non-OST factors, both within and external to DOE. Successful
implementation of new and innovative technologies will require OST to identify
these hindrances, evaluate their validity and importance, and in some cases,
take a more proactive role in effecting change. Although some of these changes
can be made by OST itself, most will require working with other elements in
DOE, and some will require working with other federal and state agencies,
Congress, and state legislatures.
CONSTRAINTS WITHIN DOE
OST operates in a complex, ever-changing environment. As pointed out by
the Decision Making Committee, an important complication for OST is that the
sites and EM offices responsible for overseeing waste management and cleanup
activities (e.g., EM-30, EM-40) have a great deal of autonomy in selecting
baseline remediation processes and technologies to deploy, consistent with
current legally enforceable agreements. Furthermore, they are under no
obligation to use OST-developed technologies and often pursue their own
technology deployments (Decision Making report, p. 9~. In fact, contractors
and managers at DOE installations have in some cases resisted efforts by DOE
35 The D&D Committee, as well as others, recognized the "not invented here"
syndrome (i.e., whereby one site is reluctant to accept technologies developed by another
site) at some DOE sites (D&D report, pg. 27~.
38
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ADDRESS CONSTRAINTS TO TECHNOLOGYIMPLEMENTATION
39
headquarters and OST to "push" use of innovative technologies (Subsurface
report, p. 204~. One potential disincentive to the use of innovative technologies
has been that rapid cleanup could lead to loss of revenue for the DOE site
management contractor and loss of local jobs once the cleanup is completed and
the site is closed (GAO, 1994~. Another barrier to deployment of innovative
technologies is the potential liability to the user and embarrassment to DOE if
the innovative technology were to fail (NRC, 1994, 1997b). Moreover, as new
cleanup and waste management problems are found at the sites, new technology
needs arise. This makes it difficult for OST to keep abreast of technology needs
and to have its technologies accepted and deployed. Another problem relates to
remediation contracts, which generally do not allow DOE to specify the
technology to be used. In its review of OST's decontamination and
decommissioning technology development program, the D&D Committee
concluded that the Large Scale Demonstration Project (LSDP) was unable to
overcome important institutional barriers to the deployment of new technologies
(D&D report, p. 2~.
OST and DOE-EM have initiated several efforts to address internal (to
DOE) barriers to deployment. For example, in 1997 OST management initiated
the Accelerated Site Technology Deployment (ASTD) program in which OST
provides funding to a site for the first on-site deployment of a fully
demonstrated technology if the site can show the potential for multiple uses of
the technology in DOE-EM and an associated cost benefit. In 1997, OST
received many more site proposals under these terms than could be funded
(Decision Making report, p. 9~. Also in 1997, DOE-EM established an upper
level management committee, the Technical Acceleration Committee (TAC), to
help deploy technologies (Decision Making report, p. 26~. The Decision
Making Committee found that the use of financial incentives such as those
provided by the ASTD program were not desirable but appeared to be necessary
at the time (Decision Making report, p. 74) The Decision Making Committee
also recognized Cat the lack of strong incentives to deploy OST-developed
technologies is largely out of OST's control, and recommended Cat DOE-EM
seek ways to assist OST in getting its developed technologies deployed at We
sites (Decision Making report, p. 74~.
CONSTRAINTS EXTERNAL TO DOE
Political
Although other EM offices such as EM-30 and EM-40 are obvious users of
OST technology developments, OST has other "customers" to satisfy. For
example, the U.S. Congress must be satisfied that a reasonable fraction of OST
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40
TECHNOLOGIES FOR ENVIRONMENTAL MANAGEMENT
products are useful and worth their cost. Furthermore, some OST expenditures
are congressionally mandated. Consequently, the type and quality of the
information provided to Congress (and to other interested review groups) is
critically important to OST (Decision Making report, p. 3~. The Subsurface
Contaminants Committee recognized that political pressures to meet federal and
state groundwater and soil remediation requirements (e.g., at the Hanford Site)
have created problems for DOE. In particular, DOE faces a major challenge in
cleaning up large quantities of contaminated groundwater and soil with a suite
of inadequate baseline technologies (Subsurface report, p. 248~.
Regulatory
The Subsurface Contaminants Committee noted that regulatory problems
have interfered with deployment of innovative remediation technologies. The
committee cited as especially problematic the slow, linear nature of the
regulatory process and inconsistencies in the way the process has been applied
from site to site. Such problems can delay selection of remediation technologies
and can result in the use of outdated technologies chosen years before site
cleanup begins. In addition, regulatory inconsistencies create uncertainties about
whether a technology proven at one location will meet the regulatory
requirements at another location, making contractors hesitant to take the risk of
using an alternative technology (Subsurface report, p. 10~.
For example, the committees identified differing approaches to waste
management and disposal by the U.S. Environmental Protection Agency (EPA)
for hazardous waste, the DOE for its own radioactive waste, and the U.S.
Nuclear Regulatory Commission (USNRC) for commercial radioactive waste.
EPA requires that all DOE mixed waste sites be designed to comply with
RCRA. The Mixed Waste Committee criticized the approach recommended by
EPA to determine toxicity, the Toxicity Characteristic Leaching Procedure
(TCLP), because it requires grinding the material before a leach test, thereby
destroying any protective coating put around the material by a treatment
process. The report describes this test as bearing "little resemblance to the
environmental conditions experienced by disposed waste" (Mixed Waste report,
p. 72~. The committee reviewed the methods available to characterize the
chemical and physical stability of waste forms for mixed waste and found that
no test methods are accepted by the technical and regulatory authorities to
demonstrate the long-term (greater than a few hundred years) behavior of a
waste form in the disposal environment (Mixed Waste report, p. 80~. No waste
form leachability criteria have been established for radioactive waste by either
the DOE or the USNRC.
As another example, EPA's facility design regulations are site independent
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ADDRESS CONSTRAINTS TO TECHNOLOGYIMPLEMENTATION
41
and hence cannot take into account the advantages one site may have over
another. The EPA facility approval process does take into account site
characteristics but not waste form. The USNRC performance objectives are for
the entire disposal system and do include consideration of site and waste form
characteristics (Mixed Waste report, p. 39~. In the area of containment, EPA
requires containment for only 30 years after closure, whereas the USNRC
recommends performance assessment for at least 1,000 years. Many hazardous
components are either stable elements (e.g., Cd, Be, Ba, Pb, Sb) or very
persistent organic constituents.
The Mixed Waste Committee concluded that a major driver in technology
selection and development by the MWFA has been EPA hazardous waste
regulations, whereas other factors such as economics have received less
attention (Mixed Waste report, p. 654. The committee recognized that technical
issues pertaining to waste management are often overshadowed by nontechnical
(e.g., political and social) issues (Mixed Waste report, p. 99~. Controlling
regulations are complex, confusing, and subject to change and interpretations
(Mixed Waste report, p. 4~.
The OST's Technology Integration Systems Application (TISA) Domestic
Program (formerly known as the Office of Technology Integration) is intended
to facilitate knowledge, communication, and acceptance of new technology
applied to DOE-EM problems among interested and affected parties (Decision
Making report, p. 15~. OST investments in these activities show that attention
to nontechnical barriers, such as regulatory acceptance of new technology ready
for demonstration, has been a program priority, at least until the program's
budget was cut in FY 1998 (Decision Making report, p. 150~.
The Public
Several of the reports observed that public concerns can be an obstacle to
deployment of new technologies. For example, the Tanks Committee wrote that
(Tanks report, pg. 5~:
At present, many public stakeholders at Hanford apparently want
DOE to follow the current compliance-driven Hanford baseline
approach, and they view investment of significant resources in
technology development for alternative scenarios as a diversion from
that effort. Some stakeholders do apparently recognize that
readjustments to the Hanford baseline may become necessary if a
particular approach proves to be infeasible for whatever reason
(whether technical, programmatic, economic, or political). However,
stakeholders generally appear to prefer DOE to limit such
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42
TECHNOLOGIES FOR ENVIRONMENTAL MANAGEMENT
~nvestrnents. Nevertheless, more explicit consideration of alternatives
as proposed herein and greater organizational commitment to a risk-
based approach could make He overall DOE program more robust
with respect to unexpected developments, as well as provide a more
transparent rationale for a particular approach to eventually be
adopted from among He candidate approaches.
The Decision Making Committee also identified an unwillingness to jeopardize
established agreements win interested and affected parties Concluding He public)
as a barrier to innovative technology use (Decision Making report, p. 27~.
CONCLUSION
It is clear from the six reports reviewed for this synthesis, Hat merely
identifying a promising technology will not lead to its implementation at DOE
sites. Many over actions are necessary. Some can be done by OST itself, but
most will require working with other elements in DOE. Some will also require
DOE to work win over federal and state agencies. Because of the historical
autonomy of DOE sites, there is no mechanusm to ensure implementation of
successfully OST-developed technologies. As long as authority for technology
deployment and responsibility for technology development continue to reside in
different entities, centralized development of technologies to be deployed
throughout He DOE complex will not, in the board's view, be effective.
RECOMMENDATIONS
Internal to DOE
· When contracts allow, agreements should be developed between
the sites and OST that, if certain agreed-on conditions are met,
then OST-sponsored technology will be implemented at the sisters).
The sites and OST would agree on technical requirements (e.g.,
throughput and contamination reduction percentages of processing
equipment), schedules (e.g., when testing of equipment or full scale
operation will begin), and deployment costs. If these targets are
met, then the sites would be required by DOE to deploy the
technologies. If they are not met, the sites would be allowed to
deploy any alternative that meets the targets, including those
36 Including economic as well as technological success.
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ADDRESS CONSTRAINTS TO TECHNOLOGYIMPLEMENTATION
43
developed independently of OST. (Some flexibility, however, would
be necessary to accommodate changes in regulations or multiparty
agreements.) If not allowed by current contracts, DOE should
consider adding such provisions to future contracts. For current
contracts, DOE should consider developing incentives to encourage
use of OST-developed technologies, when these meet the above
conditions.
External to DOE
.
.
.
DOE-EM should work to promote consensus among EPA, USNRC,
DOE, and the scientific community on waste form testing methods
that will generally be acceptable for providing at least a qualitative
evaluation of long-term waste performance in disposal
environments (Mixed Waste report, p. 104~.
DOE-EM should work with EPA and the USNRC to agree on clear
guidelines that define acceptable waste forms for disposal of mixed
waste in future near-surface disposal facilities (Mixed Waste
report, p. 1051.
The well-documented decisions and sound technical reviews
recommended earlier in this report should be used by OST to earn
the confidence of Congress and members of the public.
Representative terms from entire chapter:
waste report
