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m) life-cycle costs; and k) actual and anticipated funding levels, as explained in Chapter 5”. On page 27 (PDF—45) the 1996 report stressed process transparency, consensus building and flexibility of response with the following statements : “These, as well as other factors that emerge should be considered by all key decision makers. This may occur concurrently with discovery of site-specific information and the recognition of stakeholder viewpoints. Care should be taken to ensure that the factors to be used are identified in advance of the need to make priority-setting decisions at the site-specific and national levels. Efforts to develop weights for each of these factors or to convert the priority setting decision-making process into an overly quantitatively driven process should be avoided. Rather, the Committee believes we as a nation should find ways to improve participation in the federal facility priority-setting decision-making process such that the decisions made reflect as broad a consensus as possible as to the appropriate path forward”. The 1996 report pointedly reiterates on page 28 (PDF—46) that financial concerns should not be used to justify not implementing appropriate cleanup measures: “To the extent that funding can be isolated from other decision-making factors in determining the appropriate timing of an activity, funding should not be a reason to delay or avoid undertaking a preventative pollution control action. Rather, funding of preventative pollution control activities should be viewed as a cost of doing business and funded in conjunction with the activity causing the pollution”. On page 29 (PDF—48) of the report the following recommendation concerning the participation of local authorities |
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was provided as line item f: “When making cleanup decisions for properties remaining in federal ownership, cleanup advisory boards, local planning and reuse authorities, and the public stakeholders should be consulted about reasonable anticipated future use assumptions”.
On the next page the 1996 report also provided the following recommendations concerning contaminant migration and groundwater: “g) If there is a danger that contaminants and other hazards will migrate to adjacent lands, the migration should be contained or the source eliminated. If such migration has already occurred, the contamination should be addressed in accordance with the risk plus other factors priority-setting process in Chapter 5. h) Where appropriate, the designated groundwater use should have a greater impact on cleanup standard decisions than the future use of the facility”. The 1996 report elaborates further with the following recommendation concerning sites subject to mixed uses: “i) In circumstances where reasonably anticipated future use includes mixed uses such as child care centers, medical facilities, and parks mixed with industrial or office areas, the implications for all uses should be evaluated when making cleanup decisions”. Regarding the potential additional cost due to cleanup delay and cost/benefit evaluations the 1996 report provides |
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c) the ecological impacts of the contamination and the proposed action to address it (in those instances where protection of the environment is not used as the primary basis for establishing cleanup funding priorities as further explained in Chapter 5); d) intrinsic and future value of affected resources (e.g., groundwater and fisheries); e) pragmatic considerations such as availability and continuity of skilled workers, labs, and cleanup contractors to complete the activity or the feasibility of carrying out the activity in relation to other activities at the facility (i.e., capacity and work flow logic), or both; f) the overall cost and cost effectiveness of a proposed activity and especially the relative risk reduction value obtained by the proposed expenditure; g) making land available for other uses, recognizing land uses may change over time; h) the importance of reducing infrastructure costs (e.g., $300 million is spent each year to monitor tanks at Hanford and $130 million is spent each year at Rocky Flats to safeguard special nuclear material); i) the availability of new or innovative technologies that might accelerate or improve the ability to achieve a permanent remedy; j) Native American treaties, statutory rights (e.g., American Indian Religious Freedom Act), and trust responsibilities; k) regulatory requirements and the acceptability of the proposed action to regulators and other stakeholders; l) supporting accomplishment of other high priority agency objectives; |
FFERDC Guidance (pre 2000)
(CONT’D FROM P. 19)
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