Institutional Control Policies and Implementation for the Area 5 and Area 3 Radioactive Waste Management Sites

Abstract

The U.S. Department of Energy (DOE), National Nuclear Security Administration Nevada Site Office (NNSA/NSO) has implemented varying institutional control policies in performance assessment/composite analysis (PA/CA) calculations for the Area 5 and Area 3 Radioactive Waste Management Sites (RWMSs) (Shott et al., 1998; 2000; Bechtel Nevada [BN] and Neptune and Company Inc. [Neptune], 2006). The facilities are within the actively maintained boundaries of the Nevada Test Site (NTS) that are enforced by NNSA/NSO. Under current policies, access required for exposure of the member of public (MOP) or the inadvertent human intruder (IHI) is prohibited. Uncertainties affecting institutional control policies are the duration and effectiveness of the controls during the post-closure period. Implementing a uniform set of institutional control policies for the RWMSs that encompasses waste management and environmental restoration programs and is consistent with the end-state vision for the environmental management programs for the NTS (DOE, 2006) is a primary goal of the maintenance program. The NNSA/NSO Performance Management Plan (DOE, 2002) complies with DOE Policy P455.1, 'Use of Risk-Based End States' (DOE, 2003a). Expected future land uses are a driver in selecting acceptable end state conditions and clean-up goals for the NTS. NNSA/NSO Environmental Management's (EM's) land management assumptions and more » framework for Environmental Management activities are as follows: The NTS will remain under federal control in perpetuity as an NNSA test site, and the large buffer zone surrounding the NTS (the Nevada Test and Training Range) is assumed to remain under the control of the U.S. Air Force. There are no plans for transfer of any NTS lands to other agencies or public entities. Access will continue to be restricted to the NTS and the surrounding areas. For management purposes, NNSA/NV EM activities have been established based on the source of contamination and type of waste requiring management. Environmental Restoration activities within the State of Nevada fall under the purview of a formal regulatory agreement, the Federal Facility Agreement and Consent Order (FFACO); Environ-mental Restoration activities outside the State of Nevada fall under the purview of each affected State's regulatory framework but are planned and negotiated with the State using the FFACO Corrective Action Strategy framework for applicable activities. Waste Management activities are governed by the Federal Facility Compliance Act and Consent Order (and the Mutual Consent Agreement (MCA)). A Joint Low-Level Waste Oversight Agreement is in place to allow state of Nevada representatives to participate in review and approval processes associated with waste receipt and disposal operations (DOE, 2002). The purpose of this document is to describe institutional control policies implemented in the past PA/CA documentation, to discuss concerns noted in reviews of PA/CA documents, and to describe a new basis for institutional control at NTS disposal facilities. The new basis uses combined controls based on policies identified in the end-state vision (DOE, 2006); policies established through the FFACO, (1996) for Hazard Area 1, the Underground Test Area (UGTA) Project, and newly established NNSA policies for the Nevada Site Office. « less