• Well developed information dissemination and exchange processes should ensure the timely release of information to public stakeholders and provide the basis for informed involvement in decision making. This should hold true for any facility, whether it is on the National Priorities List (NPL) or not.

 

• The information dissemination and exchange process must be consistent with Freedom of Information Act (FOIA) principles, providing full disclosure of available information. Classification of information on the basis of national security concerns should not be used to bar the flow of relevant cleanup information where security/classification issues no longer exist. Such information should be declassified”.

 

 

The 1996 report specifically recommends the establishment of local information repositories on page 43 (PDF - 61) where it also provides guidance concerning information security restrictions:

 

• “...Local governments can

establish and maintain information repositories that make documents available to the public at the same time as they are made available to regulators;

 

• Designating locations for access to information appropriate and convenient for the affected communities, and make copies available for public stakeholders; and

 

• Applying FOIA exemptions

narrowly; consistent with FOIA, any reasonably segregable portion of a document should be provided to the requesting stakeholder after deleting portions of the document which are exempt”.

 

 

 

 

 

 

The FFERDC’s 1996 report claimed on page 47 (PDF—64) that more than 200 advisory boards addressing federal facility cleanup had been established. Eleven of these were site-specific advisory boards (SSABs) established by the USDoE. The DOD had established  over 200 Restoration Advisory Boards (RABs).

 

On pages 54 to 55 (PDF - 71 to 72) the 1996 report defines the scope of an advisory board’s interest as:

 

“...boards should focus on protection of human health, cleanup, waste management, and technology development issues that are clearly relevant to the cleanup of the facility. In focusing on cleanup, these boards may provide independent advice on issues identified in their mission statements such as:

 

• ensuring that appropriate measures (both interim and permanent) to protect human health and the environment against substantial and imminent risks are implemented as early as possible;

 

• identifying cleanup activities and projects;

 

• tracking progress on those activities/projects;

 

• providing information and perspectives on cleanup priorities;

 

• tracking possible implications for other communities along transportation corridors and in areas of waste storage facilities when discussing final waste disposition possibilities;

 

• evaluating possible employment opportunities and associated risks, local economic benefits provided by the cleanup process, and appropriate vehicles for providing this information to the public;

the following guidance:

 

“j) The cost and delay associated with determining and evaluating the impact of future use may, in some cases, mean that selecting the most stringent cleanup standard or remedy (e.g., one based on a unrestricted use) is the most cost effective and least time consumingapproach to moving forward with the cleanup process when compared to the marginal savings that may result from using a less stringent cleanup standard or remedy. In other cases, this will not be true.

 

 

k) Land not cleaned up to standards permitting unrestricted use should be subjected to appropriate enforceable institutional controls (e.g., deed restrictions, zoning, physical controls, and/or monitoring for the life of the hazard). Such controls are necessary not only to protect human health and the environment, but also to preserve the integrity of the cleanup remedy. The cost of such monitoring and controls should be considered in evaluating the savings achieved by implementing the less stringent cleanup standard. The significant problems and costs posed by maintaining institutional controls over the extremely long life of contaminants such as certain radionuclides merit serious consideration in the decision on what action to take”.

 

 

On page 38 (PDF—56) the 1996 report stated the following three principles concerning information accessibility:

 

• “Federal agencies have an obligation to ensure that information is provided to all interested parties within applicable regulatory, resource, and budgetary constraints.

 

 

 

  FFERDC Guidance (pre 2000)  (CONT’D FROM P. 20)

CONTINUED ON P. 22