LM Evaluates Site Characteristics to More Efficiently Manage Public Funds

The U.S. Department of Energy Office of Legacy Management (LM) uses a systematic screening process at its 101 sites to help better prioritize resources to ensure management protects human health and the environment, maintains regulatory compliance, addresses stakeholder concerns, and reduces long-term stewardship costs. 

LM sites have a wide range of characteristics. Some sites have very low contamination levels, and subsequently low annual stewardship costs. Others have contaminated groundwater that is being actively treated to reduce concentration levels and limit its spread, which have associated maintenance costs. In general, contamination at LM sites is well understood, although there are sites where LM is still investigating sources of remaining contamination. However, some site elements may be less effective or have less certainty than others, which presents different issues or varying levels of concern. 

“LM is very good at managing sites on an individual basis,” said Jon Damiano, the LM Quality Assurance program manager. “As we grow, we want to excel as good stewards of taxpayer funding. We decided a systematic analysis would help us more objectively make decisions that optimize use of our resources.” 

The decision-making process evaluates key elements that help protect human health, influence how the sites are managed, and directly impact final outcomes. These elements are placed in four categories: 1) potential impacts on human health, 2) stakeholder concerns and input, 3) regulatory impacts and issues, and 4) administrative controls that can help protect human health. 

Human Health Impacts – The process screens potential impacts on human health to evaluate whether people could be exposed to unacceptable levels of site-related contamination. This does not mean that people are currently exposed, only that there could be a risk at some time in the future. The ranking for human health also factors in the likelihood that contamination exposures could occur based on site characteristics, probable future site use, and changes in land and water use around LM sites.  

Stakeholder Concerns – Stakeholder concerns and input are analyzed to account for the likelihood that the management or cleanup of a given site could be affected or questioned in some way based on input from stakeholders (individuals or organizations). Environmental justice impacts, such as people feeling that issues raised in the past were not addressed, may also increase stakeholder concerns. 

“Stakeholder input and education about LM sites are critical to successfully achieving our mission,” Damiano said. “That could include sites where effective communication with stakeholders may require more effort or methods not previously used by LM.” 

Regulatory Impacts – Regulatory impacts and issues pertain to final cleanup goals for the site as well as regulatory requirements associated with the site’s long-term surveillance and maintenance. This reflects the likelihood that a site will not attain compliance goals or that compliance will not be maintained into the future. At a few LM sites, there are multiple regulatory authorities involved that may have different regulatory requirements or goals.

Administrative Controls – LM manages numerous sites that contain contaminated materials or media, such as groundwater, that currently exceed a regulatory standard. Administrative controls (also referred to as institutional controls) are the main tool that LM uses to protect human health when unacceptable levels of contamination are found at sites not owned by DOE. The actual or perceived effectiveness of these controls is a factor. 

Based on the sites’ characteristics, each of the four categories was assigned a relative rank of very low, low, medium, or high. It is critical to note that these rankings are relative within the LM Program only. Since this is a screening-level evaluation that relies somewhat on judgement and a good understanding of the site conditions, LM developed ranking guidelines to ensure that sites with similar characteristics receive the same rank in each of the four categories. The goal is to sort the sites into similar “bins” to efficiently use the funding available to LM. 

After assigning a rank to each of the four categories for each site, LM assigned an overall importance (weighting) to estimate a composite rank for each site. Potential impacts on human health received the highest weight (30%), with the other three categories given a weight of 20%. In addition, a weight of 10% was given to account for the relative complexity of the site, as assigned in the LM Site Management Guide. This composite rank is a major factor in identifying what should clearly be a priority to LM. 

This evaluation was completed in 2020, and LM plans to update this information on an annual basis. Overall, LM is effective at protecting human health and managing stakeholder issues and concerns, as well as regulatory impacts and issues and the use of administrative controls. However, some sites need more attention due to potential issues compared to others, which was the major consideration in this evaluation. 

The associated figure shows this relative range of LM priorities based on the analysis by only using the composite rank. This is just a starting point for LM, and many other factors can influence how the site is managed and how the funding is used. In addition, more value may be gained by addressing issues at sites with a lower overall composite rank because they may have one or two issues that can be more easily, and cost effectively addressed compared to the more complex sites.