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Mixed Waste Working GroupFinal Report |
Executive Summary
The Mixed Waste Working Group (MWWG) of the Federal Advisory Committee to Develop On-site Innovative Technologies (DOIT Committee) submits the following report of its activities to help frame public policy on the development and implementation of innovative technologies.
The DOIT MWWG was established in 1993 to identify ways to overcome barriers to the development and application of innovative technologies needed to clean up mixed radioactive and hazardous wastes at federal facilities in the West. The MWWG has tested ways to improve stakeholder involvement and reduce regulatory barriers using technology demonstrations already planned or underway at three Department of Energy facilities. Site teams were formed in 1994 at: Rocky Flats, Colorado; Sandia National Laboratory, New Mexico; and the Idaho National Engineering Laboratory (INEL). The Site Teams tested stakeholder and regulatory enhancements to the demonstrations of nine selected mixed waste technologies (out of 80 candidate demonstrations).
In addition, a MWWG Solicitation Sub-Group designed a Model Solicitation to test improvements to the federal procurement process, including the involvement of stakeholders in the earliest stages of technology selection. Their work has been incorporated in the form of a pilot procurement for non-thermal mixed waste technologies.
The findings and proposals of the three Site Teams and the Solicitation Sub-Group have formed the basis for this report. Working group activities in these areas have resulted in the following proposals:
PROPOSALS:
1. Use Cooperative Partnerships to Develop Comprehensive Cleanup Strategies
The responsible federal agencies must develop comprehensive cleanup strategies with the full cooperation of technology developers, end-users, affected publics, state, tribal and local governments and their regulatory agencies. In particular, the federal agencies must develop effective partnerships with industry for the purpose of applying their expertise and experience to developing solutions to cleanup problems. The federal agencies must also assure top-level management support and adequate funding for the complete and effective demonstration of technologies selected through a cooperative process for development and application.
Provide Stakeholder Access to Technology Development Information and Decisions at Strategic Points
All interested and affected stakeholders, including the public, tribes, states and local governments, must have access to critical information and have the opportunity to provide input to technology development decisions at strategic points. It is particularly important at the site level to involve stakeholders in collaborative decision-making for such things as early funding decisions and defining performance criteria for demonstrations. Using a coordinated team approach to identifying and planning opportunities for stakeholder and regulator interactions with technology developers increases the credibility of data and demonstration results and decreases the likelihood that barriers to the demonstration and implementation of a technology will be encountered.
3. Cultivate and Maintain Critical Communication Networks
Communication networks such as those established and tested through the DOIT project, linking technology developers and users with affected stakeholders and governments having regulatory jurisdiction, should be cultivated and maintained. The DOIT project showed that such networks function best when coordinated by an entity other than the federal agency involved. The key function of the communication network is the exchange of information and data critical to the technology development process. Opportunities for meaningful stakeholder involvement and participation in demonstration events such as open houses must be adequately planned and publicized.
4. Educate Key Players in Collaborative Decision-making and Meaningful Stakeholder Involvement
Full institutionalization of an effective technology development process will occur only when the value of collaborative decision-making and meaningful stakeholder involvement is internalized by all key players, including stakeholders. The responsible agencies must provide the resources and professional assistance needed to adequately train those involved in all aspects of the cleanup process. A key strategy would be to integrate stakeholder involvement training into current project management systems and training courses.
5. Provide Adequate Resources for Effective Stakeholder Participation
The greatest impediment to meaningful stakeholder involvement in the technology development process is inadequate resources and funding. Federal agencies desiring meaningful stakeholder participation must adequately fund such things as invitational travel, technical assistance, communication tools and other resources that will increase the ability of stakeholders to participate knowledgeably where needed.
IMPLEMENTATION:
Based on the experiences of the MWWG, these proposals will significantly enhance the ability of federal agencies to demonstrate and use innovative technologies. In order to implement these proposals, the MWWG proposes the following immediate actions for the consideration of the DOIT Committee:
1. Communications Plan - By the end of Fiscal Year 1996, convert MWWG and Site Team experiences in establishing effective communications among all technology development stakeholders into a Communication Plan. The purpose of this plan would be to establish an ongoing mechanism for gathering and disseminating, to all interested and affected parties, information and data critical to the technology development process, including opportunities for meaningful stakeholder involvement, both regionally and locally.
2. Integration Plan - By the end of Fiscal Year 1996, develop an Integration Plan to provide adequate resources, professional assistance, and training in meaningful tribal and public involvement, collaborative decision-making and other related issues for both technical and non-technical personnel, including technology development project managers. The plan would facilitate integration of stakeholder involvement training, wherever appropriate, into current project management systems and training courses.
3. Model Solicitation Implementation - Monitor and evaluate the implementation of the pilot procurement to test the model solicitation for non-thermal technologies, approved by the DOIT Committee designees on December 12, 1995. Provide assistance to the DOE Mixed Waste Focus Area solicitation implementation team, gather lessons learned and identify broader applications of the model principles and process.
4. Transition Team - Establish Transition Team comprising representatives from the MWWG Steering Committee, the MWWG Solicitation Subgroup, and additional stakeholders from the MWWG and Site Teams. The Team's purpose would be to develop the Communications and Integration Plans and funding requirements, and to serve in a consultative capacity to DOE as it implements the pilot procurement to test the Model Solicitation process. The Transition Team would monitor the solicitation and help assess its effectiveness.
5. Funding - The Department of Energy should fund the Transition Team and related activities or forums needed to develop the Communications and Integration Plans and monitor the Model Solicitation. As the scope of the Transition Team effort is broad and not limited to a single Focus Area or program, DOE should consider funding the Team outside of Focus Area budgets.
INTRODUCTION:
The Mixed Waste Working Group (MWWG) of the Federal Advisory Committee to Develop On-site Innovative Technologies (DOIT Committee) was established in 1993. Its purpose was to identify ways to overcome barriers to the development and implementation of innovative technologies needed for the cleanup of mixed radioactive and hazardous wastes at federal facilities in the West.
The MWWG focused primarily on improving stakeholder involvement in technology demonstrations and designing a more stakeholder-responsive federal procurement process. They also sought to improve the processes of permitting and commercializing technologies. The initial strategy was to overlay stakeholder involvement enhancements on demonstrations that had already been funded. This approach would provide interaction with actual demonstrations and more immediate results. The MWWG originally selected nine technologies being developed at three Department of Energy (DOE) sites. Site Teams were established at each of the sites to develop and implement plans.
Seven of the technologies eventually participated in the DOIT-MWWG process. Results varied but generally produced a number of important lessons. Some stakeholders felt their involvement had a positive impact on the demonstration, while others were frustrated with constraints imposed by existing schedules and milestones established prior to stakeholder involvement. The MWWG determined that conducting a second project phase that involved stakeholders in the earliest stages of a technology solicitation would be valuable. Additionally, complicated federal procurement processes have been identified in a number of industry forums as being a major barrier to new or innovative technology development. The MWWG has developed a Model Solicitation to address stakeholder (including industry) concerns.
The DOIT project has provided a valuable opportunity for networking among organizations. The MWWG has encouraged information sharing as an effective way to avoid duplication of effort, and has members on a variety of national working groups with complementary objectives. Utilizing the knowledge base of its members, the MWWG has increased the effectiveness of concurrent efforts.
This report of the findings of the MWWG represents the culmination of an unprecedented regional effort to identify a framework for collaborative decision-making in the technology development arena. DOIT has broken down communication barriers and opened the door for greater cooperation among many parties. If fully implemented, the actions proposed in this report can help the nation actually clean up real wastes in a more timely, cost-effective, and safe manner.
SITE TEAM SUMMARIES AND PROCESS EVALUATIONS:
From May 1993 to January 1994, the Mixed Waste Working Group identified promising technologies that could be used for testing improvements to the technology development process. In order to assure that tangible results could be achieved within the time constraints of the DOIT charter, consideration was given only to those projects already funded within the DOE budget process. Since the scope of these demonstrations was, in most cases, already established before stakeholders became involved, it limited the ability of stakeholders to change the demonstrations.
Of the nine technologies originally selected for inclusion in the DOIT process, two were dropped prior to actual demonstration when DOE funding was canceled: the Two-Stage Advanced Oxidation/Reduction Unit at Los Alamos National Laboratory (LANL) in New Mexico, and the Minimum Additive Waste Stabilization (MAWS), which was coordinated out of Pantex, Texas.
The remaining seven technologies were located at three DOE sites: Rocky Flats, Colorado; Sandia, New Mexico; and the Idaho National Engineering Laboratory (INEL). Site Teams formed by the MWWG at each of the sites developed and implemented plans to test technology-specific enhancements to the demonstrations. The activities and findings of the three DOIT MWWG Site Teams are summarized here.
| Demonstration Site: | Technology Demonstration(s): | DOIT Enhancement(s): |
| Rocky Flats | Low Temperature Thermal DesorptionMicrowave Solidification | Regulatory Cooperation |
| Sandia National Laboratory | Alternative Landfill Cover Design | Regulatory CooperationStakeholder Involvement |
| Idaho National Engineering Lab | Dig Face CharacterizationRapid Transuranic Monitoring LaboratoryRadioactive and Hazardous Materials Measurement SystemPlasma Hearth Process | Regulatory CooperationStakeholder Involvement |
ROCKY FLATS
For the complete Site Report, please see Appendix A.
Technology Demonstrations
In early 1995, Rocky Flats researchers conducted demonstrations of Low Temperature Thermal Desorption (LTTD) and Microwave Solidification. The LTTD process heats shredded waste materials in a vacuum dryer to drive off organic contaminants and gases (which are either captured and recycled, destroyed, or condensed to non-radioactive liquid for disposal), leaving behind solid waste products which can be immobilized and safely disposed of.
Microwave Solidification uses microwave energy to heat wastes contained in stainless steel drums to about 10000C. This process combines the contaminant with inert glass- or ceramic-like materials and fuses the mixture into a stable, glass-like form for disposal.
Process Enhancements
The goal of the Rocky Flats Site Team was to test whether early involvement of local and regional regulators in the planning and execution of the demonstrations might spur consideration of those technologies at other sites, and possibly accelerate regulatory review and acceptance of the technologies. Active stakeholder involvement was incorporated in the Rocky Flats demonstrations as an ongoing, parallel part of the project, but was not planned and evaluated as a separate DOIT enhancement.
The Site Team used a variety of meetings and communications with regulators to begin and advance a dialogue among states and to lay the groundwork for interstate cooperation in permitting. The Rocky Flats team worked with the state of Colorado to make the permitting process more efficient. Regulators from New Mexico, Colorado, Texas, Utah and Nevada attended the Rocky Flats demonstrations and indicated a willingness to consider the data generated during demonstrations for permitting purposes in their states with certain provisions.
Findings and Process Evaluation
The technical performance of the technologies and the stakeholder involvement activities, including the participation of the regulators from five states, were considered by the Site Team to be very successful. The site and the technologies received good exposure in the community and among the regulators. Three states requested additional information on other Rocky Flats technologies as a result of their visit.
Early efforts to involve regulators from other states in the demonstration planning prior to the actual demonstrations were ineffective due to lack of state and regional support and schedule constraints imposed by pre-existing demonstration milestones and work plans. As a result, the Rocky Flats Site Team restructured its activities to complement the interstate cooperation mechanisms being developed by the DOIT Interstate Technology and Regulatory Cooperation (ITRC) working group. Low Temperature Thermal Desorption was selected as an ITRC test case, and groundwork has been laid for continued use of LTTD demonstration results by interested ITRC states.
Given the limited time for conducting the demonstration, good progress was made toward streamlining the permitting process. The project resulted in a successful demonstration of technologies for a broad array of stakeholders. The demonstration provided a forum for dialogue with other states who could benefit from the technology.
Unfortunately, the LTTD project was brought to a premature conclusion when cost overruns and other factors contributed to a loss of project funding. Subsequently, the demonstration processed fewer waste streams and generated fewer permitting data than originally planned. As a result, states did not receive the information needed to complete cooperative permitting efforts as originally intended.
The Site Team stressed, however, that diligent follow-up can help ensure that benefits from the DOIT process are maximized. Local follow-up must include maintenance of the communication links with regulators and continuing to provide technical data to the states as it becomes available.
SANDIA NATIONAL LABORATORY
For the complete Site Report, please see Appendix B.
Technology Demonstration
The Sandia Site Team was formed in the spring of 1994 to test enhancements to the Alternative Landfill Cover Demonstration (ALCD). The demonstration will test innovative landfill covers which are specifically designed for arid climates. Six covers are to be constructed and evaluated in two phases over the next five years. Evaluation will be based on construction costs, ease of construction, and performance in reducing such things as cracking and deterioration.
Process Enhancements
The Sandia Site Implementation Plan and Plan for Stakeholder Participation addressed both regulatory and stakeholder barriers to acceptability of the alternative landfill covers. To overcome reluctance by regulators to accept new landfill cover designs, the team organized and facilitated review of the Phase I draft technical designs by landfill regulators in western states and from the U.S. EPA. The review provided them with an opportunity to express their concerns about the designs and make suggestions to the technology developers regarding what might be changed in order for the regulators to more readily accept the results. The team also worked with Sandia National Laboratory to ensure that the technical results of the ALCD will be incorporated into EPA's computer model to facilitate more accurate water balance predictions for landfills in the arid southwest. This model guides state regulators in the approval of permits for landfill covers.
The Site Team also implemented a plan to involve, inform and create trust and agreement among public stakeholders, regulators and technology demonstrators. More than 300 interested stakeholders were identified and informed about demonstration activities. An average of about 100 stakeholders attended both an initial stakeholders' meeting in June 1995 and a Demonstration Open House in September. Follow-up communications to all interested stakeholders addressed key issues and concerns raised. Both regulators and non-regulator stakeholders will be given an opportunity to review and comment on the Phase II draft technical design plans once they become available in 1996.
Findings and Process Evaluation
Final results from the demonstration will not be available for several years. However, the Site Team believes significant progress was made in overcoming the barriers identified in the Site Plans. The activities undertaken by the Site Team improved awareness of the technologies by regulators, landfill owners and operators, and industry. The principal investigator made modifications to the designs for the Phase I Subtitle 'D' test cover based on comments from the regulators. Several regulators suggested that the regulatory minimum for the soil barrier be used rather than a thicker cover. The team believes that this input improved the demonstration.
Serious consideration of stakeholders comments proved to be of benefit to this demonstration, and that the issues and suggestions from this demonstration need to be communicated to a range of stakeholders and technology developers. It is also noted that many interested stakeholders cannot actively participate in the process without at least a small amount of funding to allow them to independently analyze the information and attend meetings. It is also apparent that many stakeholders, in addition to being involved in the implementation of individual demonstrations, want to impact which demonstrations receive funding.
To summarize:
Improved awareness by regulators, landfill owners, and industry helps in the demonstration design and potential acceptability of new technologies;Modifications and suggestions by regulatory and non-regulatory stakeholders improved the demonstration;There needs to be communication and information sharing beyond the site regarding stakeholder impacts on the design of the demonstration;At least some funding must be provided to stakeholders to improve their ability to analyze pertinent information, and to attend meetings; and,Stakeholders want to impact decisions regarding which demonstrations receive funding.
IDAHO NATIONAL ENGINEERING LABORATORY
For the complete site report, please see Appendix C.
Technology Demonstrations
Four technologies being developed at the Idaho National Engineering Laboratory (INEL) were selected to be included in the DOIT testing and evaluation process. Three are waste characterization technologies, and the fourth is a mixed waste treatment system.
The Radioactive and Hazardous Materials Measurement System (RHMMS) is an integrated system of technologies which identify and analyze the contents of waste storage containers using high-energy neutron, gamma rays and X-rays. The Rapid Transuranic Monitoring Laboratory (RTML) is a mobile facility which provides rapid, continuous on-site analysis of air, soil, filter and smear samples. Dig Face Characterization (DFC) is an integrated system of multiple sensors which continuously monitor and characterize hazards at the dig-face during waste retrieval operations.
The Plasma Hearth Process (PHP) uses a plasma arc torch to melt waste drums and its inorganic contents while destroying the organic contents. Two products are created: a vitrified, glass-like waste that is dense, stable and safe for disposal; and a reduced metal waste, easily separated from the vitrified waste and potentially recyclable. Volatile gases and aerosols are either captured and recycled, destroyed, or condensed to non-radioactive forms for disposal.
Process Enhancements
The INEL Site Team was formed in April 1994. Its Site Implementation Plan and Stakeholder Involvement Plan addressed three areas: improving tribal and stakeholder involvement; streamlining the regulatory process; and, enhancing the commercialization and transfer of technologies to the private sector. Improvements in tribal and public involvement were made through a variety of communication tools, including face-to-face meetings with tribes and groups, poster sessions, facility tours and technology open houses. Streamlining the regulatory process was addressed primarily through the development of a "how-to" guide for securing a research and development permit. The Site Team used the RTML demonstration as a case study to improve the process of commercializing and transferring technologies to the private sector.
Findings and Process Evaluation
The INEL DOIT process was complicated by numerous changes in technology demonstration schedules, budgets, and personnel. The RTML project was commercialized and sent to another site for further demonstration early in the process. The Dig Face technology was moved out-of-state when a suitable testing site could not be located at the INEL. Most of the results obtained by the Site Team were related to the RHMMS and PHP demonstrations.
Lessons learned from the DOIT process at the INEL are summarized as follows:
A fully-supported team approach coordinated outside the federal agency has the best chance of success; The technology development decision-making process worked best when it was made more easily accessible to those with a strong interest in the outcome within and outside the federal agency; and Some of the best products of such a process are often intangibles, such as developing new relationships, establishing communication networks, and expediting the decision-making process.
After reviewing its work and evaluating the lessons-learned, the INEL Site Team believes the following approaches should be used to improve the innovative technology development and demonstration process:
Integrate technical and non-technical processes at strategic decision-making points. Use a team approach to project coordination. Coordinate the process outside of DOE. Take the process directly to all interested players. Provide top-level management support and adequate funding. Provide for full accountability to the public.MODEL PROCUREMENT PROCESS:
PEOPLE
The development of the Model Solicitation Process undertaken by the Mixed Waste Working Group/Solicitation Subgroup (MWWG/SSG) was an attempt to respond to issues raised in various DOIT forums addressing expedited development and implementation of innovative technology. Through these forums, DOIT identified the importance of the following:
Getting all stakeholders (tribal, state, and local governments, publics, and regulators) involved early in the procurement process and maintaining involvement through implementation;Reaching out to private industry for their expertise in applying innovative solutions to the most pressing problems; andProviding opportunities for enhanced regulatory cooperation and information exchange.
The intent of the Model Solicitation effort was to establish a generic set of materials incorporating these important features in a process leading to technology selection, demonstration and implementation. State, federal, and tribal governments should benefit from use of the Model Solicitation process. But, it was recognized that a pilot procurement was warranted before recommending the process for broad application. The materials provide:
A foundation for framing a procurement; andProcess guidance on how to obtain input from tribal, state and local governments, publics, regulators and private industry in tailoring a procurement to a specific application.
In developing the Model Solicitation, input was obtained from: public interest groups; state and federal regulators (including an ITRC representative); tribal, state, and local governments; academia; private industry; and, DOE (including EM-30, EM-40, and EM-50) and the Mixed Waste Focus Area. Recognizing the limited private industry representation on the MWWG/SSG, additional ideas from this sector were sought. A Request for Expressions of Interest (RFI) was issued in 1991 which resulted in responses from some 82 firms. In 1995, a letter to a broad industry mailing list was issued which resulted in valuable comments from numerous firms on procurement features that were under consideration (e.g., cost sharing, intellectual property rights, technical project management, reporting requirements, and expedited negotiation). Also, because of their extensive expertise in private industry procurement, DOE's Morgantown Energy Technology Center was consulted in an advisory capacity.
The MWWG/SSG designed the Model Solicitation for technology selection and application at the demonstration stage of the technology development cycle. Effective stakeholder involvement is important at this stage because:
Sufficient data bases exist to judge a technology's performance potential for commercial application; Many stakeholder issues may be defined up-front enhancing the probability of obtaining technologies responsive to the problem; and,Significant funding is at stake.
At earlier stages of development, a myriad of technologies are involved, the data bases are sparse, and the screening costs are relatively low. Also, demonstration represents the single greatest hurdle in the development cycle for private industry. Demonstration requires test of the technology, with all systems fully integrated, at sufficient scale and representative operating conditions to evaluate its operational, environmental, and economic performance potential in its proposed commercial configuration and application.
For the pilot procurement, additional guidance was developed suggesting that "non-thermal"/ "Alternate Waste Treatment Technology" be addressed and that "hot" wastes be used. The former was based on a preliminary assessment of treatment technology needs . The latter was a reflection of certain stakeholders' desires to have the technology undergo as realistic a test as possible (there has also been some expression of interest from sites to use "hot" waste). During the solicitation development stage of the pilot procurement, the site specific stakeholders in conjunction with DOE will have to decide on these matters. The Model Solicitation Process provides the "tools"for such discussion.
PROCESS
Following is a brief description of the process components developed by the MWWG/SSG and adopted by the MWWG in the course of formulating a model solicitation. In preparing these materials, the MWWG/SSG recognized that there would have to be a site specific overlay to provide the specificity associated with all parties technical issues. The materials provide background on the issues addressed, a framework for tailoring the procurement to the site, and a process for integrating stakeholder involvement from solicitation development to project implementation and assessment. Critical to implementing a pilot procurement incorporating the MWWG's proposed guidance is active, willing site participation.
Request for Information from Industry - A request for information on innovative technologies for mixed waste treatment issued by DOIT resulted in industry identifying and describing 82 technologies. Summary of Responses to Industry Letter - These are responses to an MWWG prepared industry letter requesting comment on specific procurement elements offered for consideration. They provide feedback on particular approaches considered and validation that concerns raised in previous forums are still operative.Draft Request for Site Expression of Interest (SRFI) - This document is a planned competitive solicitation for site participation in a pilot effort to try a unique approach to solicitation development, proposal evaluation, and project implementation and assessment. As outlined above, innovative Alternate Waste Treatment Technologies would be sought from the private sector to treat Mixed Low Level Waste. The SRFI: 1) provides a background, or genesis, of the effort to be undertaken; 2) defines resources available for the project; 3) outlines the site support requirements including technical, administrative and financial; 4) describes the information required in responding to the SRFI; and 5) sets forth the criteria to be applied in selecting the host site. Incorporated in the SRFI is Guidance for Development of Non-Thermal Work Scope. The Work Scope provides further definition of the technical effort to be undertaken, i.e., types of waste targeted, tasks to be conducted, the scope/scale of testing, stakeholder involvement, and reporting requirements. It is important to note that the specific wastes identified are provided simply as place holders or examples. The site will define the wastes offered for treatment as part of the response.Selection Criteria Guidance- These are model Selection Criteria developed by the MWWG and intended to serve as a framework for overlaying site specific concerns, as the DOE solicitation development process unfolds. After examining numerous technology program development criteria packages, a decision was made to base the Selection Criteria on the Treatment Selection Guides set forth by the Federal Facilities Compliance Act Task Force March 1, 1994. They are presented in a procedural format that DOE has used to sequence the evaluation process. The purpose of the sequencing is to screen out proposals that are not responsive to the solicitation prior to subjecting them to comprehensive evaluation. The criteria and relative weighting of criteria presented represents the views of the MWWG (which includes representation from public interest groups, tribal, state, and local governments, and federal and state regulators). The MWWG recognizes, however, that site specific considerations will change the criteria and the relative weighting. This guidance is offered as a starting point for discussion. The use of Program Policy Factors is introduced as a tool to select proposals that may not have received the highest score in the technical ranking but are highly responsive to what the solicitation is trying to achieve in the context of the Environmental Management Program.Draft Stakeholder Involvement Objectives and Process - This document, prepared by a representative cross section of stakeholders within the MWWG, draws upon their views, as well as forums conducted to delve into stakeholder concerns. It attempts to: 1) convey the basic tenets of stakeholder involvement; 2) provide insights into sensitivities in dealing with stakeholders in general and tribal governments in particular; 3) outline stakeholder expectations for key events prior to, during and after a project; and 4) provide guidance in forming stakeholder advisory groups and developing stakeholder involvement plans. This document provided necessary input for developing guidance for a process to integrate stakeholder involvement into project procurement and implementation discussed below.The Process Guidance for Procurement and Implementation of Technology Demonstrations - is the primary product of the MWWG deliberations and findings to address the above stated objectives. It addresses use of the above described materials in a process designed to involve the private sector, tribal, state, and local governments, publics and regulators throughout procurement and project execution.
PRODUCT
This Process Guidance document is not procurement specific. It provides a generic process for achieving meaningful stakeholder involvement at the demonstration stage consistent with federal procurement regulations dealing with solicitation development, selection and project implementation procedures . The process allows for dialog among key players, building trust among those who eventually must pass judgement on the technologies. It also involves private industry which has the resources to apply needed innovation but has viewed the federal facility complex as a "closed shop" as expressed in numerous DOIT forums. Application of this process can lead to understanding the concerns of all parties, facilitate problem definition, and provide a basis for dealing with critical site cleanup issues.
Preliminary Outcomes:
On December 12, 1995, the DOIT Committee adopted a formal resolution recommending that DOE proceed with a pilot procurement applying the Model Solicitation Process guidance developed by the MWWG. Assuming that the pilot procurement is initiated in the near future, the MWWG, as a minimum, has the opportunity to serve in an advisory capacity to DOE during solicitation development. If afforded this opportunity, valuable lessons learned might be captured -- solicitation development is the most critical of the Model Solicitation Process stages. Such knowledge would have value in the DOIT final report.
LIAISON REPORT:
BACKGROUND
Terry Escarda of California-EPA was the Mixed Waste Working Group liaison to the DOIT Interstate Technology Regulatory Cooperation Workgroup (ITRC), as well as to the Executive Steering Committee of the National Technical Workgroup on Thermal Treatment of Mixed Waste (NTW). Many benefits were obtained by having one person serve on all three efforts.
Terry Smith of the Idaho Division of Environmental Quality was selected by the DOIT Mixed Waste Working Group to serve as liaison to the DOE Mixed Waste Focus Area (MWFA), and also serves on the MWFA Tribal and Public Involvement Steering Committee. In addition to being a member of the MWWG, Smith is the coordinator for the DOIT Site Implementation Team at the INEL, and is the Chairman of the DOIT Coordinating Group to whom each of the Working Groups reports.
GROUP ORGANIZATION / MWWG INTERACTIONS
The NTW, ITRC, and MWWG have various emphases with respect to the barriers associated with development and implementation of innovative technologies for the treatment of mixed waste. Whereas the MWWG focuses on stakeholder involvement, NTW works to resolve technical issues relating to permitability of thermal treatment processes and the ITRC addresses removal of state barriers to the implementation of technologies for all hazardous waste management, including mixed waste. Each of the groups benefited from the interactions and coordination among the three.
The DOIT-ITRC has a separate report which addresses specific issues and activities of that group, and the DOIT report will note the connections among DOIT Working Groups. For the purposes of brevity, the highlights of interactions with non-DOIT activities (i.e., NTW, DOE Integrated Non-thermal Treatment Study, and MWFA) are noted here.
The NTW was established in 1991 through an interagency agreement between the US Department of Energy and the US Environmental Protection Agency (EPA). NTW is composed of representatives from DOE (headquarters, sites, and contractors), EPA (headquarters, regional permit writers, and researchers), the Nuclear Regulatory Commission (NRC), regulating states, and citizens advisory groups. The mission of the NTW is to support the development of coordinated, consistent, and environmentally protective national permit procedures for treatment of Mixed Waste.
State Perspectives and Stakeholder Concerns - The liaison gave a state perspective to the NTW Executive Steering Committee by providing state regulatory contacts, surveying various state regulatory programs with respect to state requirements, and offering state peer reviewers for comment on NTW documents. ITRC survey results regarding plasma technologies will be shared with NTW. Through a state permit writers forum at the NTW Annual Meeting, NTW became more aware of state and MWWG concerns regarding permitting barriers, DOE privatization plans, lack of non-federal stakeholders in NTW, and stakeholder concerns such as transportation, siting, waste characterization and continuous emission monitoring, and lack of non-thermal systems.Examination of Non-Thermal Systems - DOE established the Integrated Non-Thermal Systems Study (INTS) in response to findings by the MWWG that stakeholders will continue to oppose thermal treatment systems until DOE examines the advantages and disadvantages of non-thermal system on equal footing with thermal treatment systems. The INTS has substantial stakeholder involvement at the earliest point ever in a technology evaluation effort. DOE intends to use the INTS results in a comparison with thermal treatment systems in an effort to determine if some non-thermal/thermal systems should be applied by DOE and in research funding decisions.Communication Improvements - The liaison emphasized to NTW the lack of access by state programs to electronic information; NTW subsequently set up an Internet home page. The liaison used technical evaluation criteria from NTW as a partial basis for that of the model procurement sonication. This allowed a consistent set of selection/evaluation criteria for comparing technologies.Consistent Work Products - One key effort of the ITRC is to increase the transferability of technology demonstrations and thus technologies by developing consistent evaluation protocols, cost and performance data reporting formats, and use of certifications programs. NTW was urged by the liaison to accept the use of the ITRC tools when considering test plans for trial burns. ITRC is now aware that regulatory reforms are as high priority to the DOE members of the MWWG as technology certifications.
Coordination should continue with NTW and ITRC. Technical, stakeholder, and regulatory acceptance and reform issues will be integrated into each other's efforts and consistently addressed by having a liaison. Coordination will also ensure that resources are efficiently used.
The MWFA was established in 1995 by DOE to develop and facilitate implementation of technologies to meet enforceable agreements for the treatment of mixed low level waste and transuranic waste. The Idaho National Engineering Laboratory was selected as the lead organization to provide technical management of the MWFA and to establish an implementation team to carry out the MWFA mission.
The MWFA organized along four primary product areas: 1) Systems Engineering, 2) Technology Coordination, 3) Regulatory and External Liaison, and 4) Program Integration and Control. The Regulatory and External Liaison area is responsible for facilitating regulatory , university, industry, public and tribal input to the MWFA Waste Type Teams. This input helps define needs, address regulatory options, and provide early tribal and stakeholder involvement in product development. It is integral to the MWFA decision-making process for technology selection, prioritization, and evaluation.
A Tribal and Public Involvement Steering Committee was formed to develop a tribal and public involvement strategy that supports the national tribal and public involvement framework established by DOE's Office of Technology and Development. Membership includes participants with expertise in the areas of tribal and public involvement, community relations, communications, project management, and business development. The Steering Committee has accomplished a number of significant products and activities to date. Key accomplishments are highlighted here:
Conducted research and identified key "lessons learned" from previous tribal and public involvement activities with DOE and other federal and state agencies. The lessons learned were extrapolated into general issues of concern or principles. The research is documented in the report entitled, "Taking Stock: An Overview of Public Participation Lessons Learned by the U.S. Department of Energy, 1990-1995," issued August 1, 1995.Used a systems engineering approach to overlay the public involvement principles with the MWFA technology development system and identified opportunities for integrating the principles into the system.Used the results of the "lessons learned" and the principles overlay to develop an implementation plan for integrating tribal and public involvement into the MWFA technology development and decision-making process. The goals of the plan are to a) create a partnership between the technical and non-technical players, b) implement a comprehensive communications plan for supporting MWFA goals, c) provide collaborative decision-making and group communications skills training for participants in the process, and d) facilitate early and ongoing partnerships with regulatory entities.Used a crosswalk approach to link stakeholder and regulatory principles with the technical criteria developed by the MWFA Technical Resource Team for ranking, selecting, and evaluating technology proposals for the mixed waste treatment train technology deficiencies. The Steering Committee hopes to develop applicable performance standards that can be used to establish a baseline for technology test objectives and field operating requirements.Participated in a funding review of the Plasma Hearth Process (PHP), one of the technologies participating in the DOIT MWWG demonstration process. Members of the MWWG and the INEL DOIT Site Team participated in a meeting with representatives of the MWFA Management and Implementation Teams and the PHP project team. The purpose of the meeting was to discuss MWFA objectives, the technical path forward for the PHP, and a proposal to reduce the scope of the PHP field scale demonstration. As a result of discussions at the meeting, a decision was made to delay any decision to eliminate the field scale component and fund the demonstration at a level that would keep it viable until a more thorough evaluation of situation could be done.Participated with MWFA Management and Implementation Teams in a meeting with members of the Community Leaders Network Mixed Waste Sub-Group. The purpose of the meeting was to develop evaluation criteria for selecting and ranking proposals to fill technology deficiencies in the mixed waste treatment systems proposed in the FFCA Site Treatment Plans.
MIXED WASTE WORKING GROUP MEMBER
PROCESS EVALUATIONS:
BACKGROUND:
The DOIT MWWG reviews with considerable satisfaction accomplishments achieved through the Group's efforts since it was formed in 1993. Our goal to expedite implementation of innovative technologies for waste cleanup is within reach, thanks to significant progress and some clear successes meeting specific objectives. During the 1995-1996 period, primary attention was focused on site enhancements and a model procurement process for future use by USDOE.
Individual members of the MWWG provided their views on the accomplishments, shortcomings, and overall "lessons learned" from their participation in the DOIT process through a questionnaire distributed in February, 1996. Responses to the questionnaire are summarized here.
PEOPLE:
Membership in the MWWG included representation from federal, tribal, state and local governments, regulators, private industry, public and environmental interest groups, academia, and labor. Participants, for the most part, agreed that groups represented were adequate, and that membership from them was appropriate. Some expressed the opinion that tribal representation could have been increased. An air regulator would have been a valuable addition. Early representation from USDOE was lacking, or not appropriate to provide information needed by the group. Once DOE organized into Focus Areas, and the Mixed Waste Focus Area representatives started participating fully in the Working Group, progress improved. Overall, members expressed a high level of satisfaction with their own participation in the Working Group.
Because of the Working Group's diverse membership, several members noted the need for a way to bring members to an equal level on the learning curve. Members indicated the importance of funding assistance for some individuals to allow their effective participation.
PRODUCTS:
Several technology demonstrations are underway, or were completed as the DOIT process concludes. The MWWG identified selected "enhancements" to be implemented with each demonstration in order to address technology development barriers such as regulatory, liability, and commercialization issues. The enhancements also included models for comprehensive stakeholder participation. Anticipating future technology demonstrations, the WG has developed a model solicitation process that can be used by DOE (or adapted for use by other agencies) for expedited procurement of cleanup technologies.
Reviewing the original goals established by the MWWG, most members were satisfied with accomplishments. Others expressed disappointment that early setbacks due to funding cuts and administrative changes slowed results or eliminated access to desired data. Our goal to establish an education and training model was not met. Nevertheless, outcomes achieved are valuable. We already have demonstrated successful use of public involvement at the site team level.
There was disappointment expressed over the time lost and value never realized because of the Group's slow start understanding its goals and developing a process to achieve them.
There is a high degree of anticipation of future results. Many members comment that the only true measure of successful outcomes is DOE's application of the procurement model and other DOIT/MWWG products. Future implementation of DOIT processes will also determine whether WG members are willing to claim satisfaction with the investment of their time.
PROCESS:
MWWG members fully recognize the early failure and subsequent successful efforts to establish a workable process for group deliberations and decision-making. Early in the process, the group lacked effective communication. There was confusion about goals, dissatisfaction with process issues, and frustration with the DOE bureaucracy. Selection of our Track I technologies did not meet desired criteria for early involvement. Consequently, resources were not used efficiently.
Two key factors account for the turnaround: participants' development of, and subsequent consensus on, a group management plan to guide activities and communication, and active involvement by appropriate DOE officials. After the management issues were addressed, all members expressed increased satisfaction with the improved process. Also, we recognize and appreciate DOE's open communication and support for WG issues. The level of satisfaction varies with regard to communication among members, and between staff and members. This suggests members have differing needs for information: how much; how often; what method; and, who receives what.
With hindsight's clarity about the future we would address procedural issues early, build teamwork, and establish trust among members to be a more effective group. Since communication is a critical factor to effective participation of members, future groups should examine and address this issue carefully.
PROCESS EVALUATION:
Members of the MWWG feel real progress has been made addressing barriers identified at the beginning of the DOIT initiative, such as stakeholder involvement and commercialization needs. The umbrella of DOIT has provided for effective interagency cooperation and a process to achieve effective stakeholder involvement and acceptance. This process works.
Full participation by the public and by regulators is critical to implementation of cleanup technologies. These stakeholders want and need to get involved in demonstration selections early, in order to have meaningful impact. Stakeholder participation must be more than lip service. Goals will be met if stakeholders have good information and a good opportunity to use it; they need real data and real decision-making power.
Education is important to a successful process, and is especially needed at the site level. An education plan should be done early. DOE should consider sponsoring, or co-sponsoring with states, training for state regulators, tribal representatives, and local or regional interest groups in working with collaborative decision-making processes.
Openness to, and acceptance by, DOE of the DOIT Approach has given the agency new and considerable credibility. DOE shifts regarding priorities and available money such as occurred during the early phases of MWWG work frustrates the staying power of regulators and other stakeholders.
Developing products and meeting goals under the DOIT initiative requires considerable attention to process issues, because the stakeholders involved are diverse and have differing needs. Clarity is needed about goals and objectives, about group procedures, and about staff roles. Real, open discussion is necessary to overcome differences and to reach common goals. Invitational travel is a significant factor in some members' participation and should be continued. This could perhaps be funded through state or university grants.
The ultimate value of MWWG participants' efforts can only be realized if the products developed are used.
FINDINGS AND ASSOCIATED PROPOSALS:
Key findings of the site teams are summarized here by general categories, and followed by the Working Group's recommendation in each area. A proposal for ensuring implementation of these recommendations concludes this section.
FINDINGS: TEAM APPROACH AND COOPERATIVE PARTNERSHIPS
A fully-supported team approach, (bringing together DOE, tribal, state and local governments and regulators, developers and the public) to demonstration design and implementation, coordinated outside the federal agency (e.g. state or non-profit agency) has the best chance of success. (INEL)
Organized stakeholder involvement teams , using Site Implementation and Stakeholder Involvement Plans developed together, accelerated development of innovative technologies through forging new relationships, establishing communication networks, and expediting the decision-making process. (INEL)
Initial problems were experienced in obtaining state and regional regulatory support and were exacerbated by inflexible, pre-existing demonstration schedules. These are now being addressed through activities of the more recently established DOIT Interstate Technology and Regulatory Cooperation Working Group. (Rocky Flats)
Proposal 1. Use Cooperative Partnerships to Develop Comprehensive Cleanup Strategies
The responsible federal agencies must develop comprehensive cleanup strategies with the full cooperation of technology developers, end-users, affected publics, state, tribal and local governments and their regulatory agencies. In particular, the federal agencies must develop effective partnerships with industry for the purpose of applying their expertise and experience to developing solutions to cleanup problems. The federal agencies must also assure top-level management support and adequate funding for the complete and effective demonstration of technologies selected for development and application through a cooperative process.
FINDINGS: TIMELY ACCESS TO INFORMATION AND DECISION- MAKING
Many stakeholders want to impact which demonstrations receive funds, in addition to being involved in the implementation of individual demonstrations. (Sandia)
Involving stakeholders after project scope and funding has been established limits the effectiveness of stakeholder involvement by affording little flexibility in modifying projects. Serious consideration of stakeholder comments proved to be of benefit to the demonstrations (e.g. structuring comprehensive test plans). (Sandia)
The technology decision-making process worked best when it was made more easily accessible to those with a strong interest in the outcome. (INEL)
Actual "hot" tests before the public can be very costly and carry with them inherent risks. This has to be weighed against the greater stakeholder and regulatory interest attracted when engaging in cleanup of actual wastes. (Rocky Flats, Sandia)
Follow up is needed to evaluate the efficacy of the Model Solicitation guidance in integrating stakeholder involvement in technology/project selection and implementation. (MWWG Solicitation Subgroup)
Proposal 2. Provide Stakeholder Access to Technology Development Information and Decisions at Strategic Points
All interested and affected stakeholders, including the public, tribes, states and local governments, must have access to critical information and have the opportunity to provide input to technology development decisions at strategic points. It is particularly important at the site level to involve stakeholders in collaborative decision-making for such things as early funding decisions and defining performance criteria for demonstrations. Using a coordinated team approach to identifying and planning opportunities for stakeholder and regulator interactions with technology developers increases the credibility of data and demonstration results and decreases the likelihood that barriers to the demonstration and deployment of a technology will be encountered.
FINDINGS: COMMUNICATION
Lessons learned from Site Team activities should be communicated to other sites implementing demonstrations. (Sandia)
Attention must be paid to internal Site Team communication and the resulting roles and requirements that evolve. Agreements between developers and any other stakeholder entities should be documented to prevent any misunderstandings as test plans are finalized. (Rocky Flats)
The new relationships developed under DOIT created an effective communication network that greatly enhanced existing networks within and between agencies. Coordinating communications outside of the DOE framework helped break down or eliminate formal communication barriers. (INEL)
The DOIT process provided an effective problem-solving forum. Having key players at the table ultimately expedited the decision-making process. (INEL)
Proposal 3. Cultivate and Maintain Critical Communication Networks
Communication networks such as those established and tested through the DOIT project, linking technology developers and users with affected stakeholders and governments having regulatory jurisdiction, should be cultivated and maintained. The DOIT project showed that such networks function best when coordinated by an entity other than the federal agency involved. The key function of the communication network is the exchange of information and data critical to the technology development process. Opportunities for meaningful stakeholder involvement and participation in demonstration events such as open houses must be adequately planned and publicized.
FINDINGS: EDUCATION AND TRAINING
Involvement of stakeholders in demonstration design did not cause demonstration delays. Education of the public, regulators, and industry stakeholders and their involvement in the demonstration will likely lead to more rapid and less costly adoption of alternative technologies. (Sandia)
Presentations on the technologies by the developers gave stakeholders an appreciation and understanding of the particular technology, but a better job needed to be done in presenting where the technology fits in the overall cleanup picture. (Rocky Flats)
Proposal 4. Educate Key Players in Collaborative Decision-making and Meaningful Stakeholder Involvement
Full institutionalization of an effective technology development process will occur only when the value of collaborative decision-making and meaningful stakeholder involvement is internalized by all key players. The responsible agencies must provide the resources and professional assistance needed to adequately train those involved in all aspects of the cleanup process. A key strategy would be to integrate stakeholder involvement training into current project management systems and training courses.
FINDINGS: FUNDING AND RESOURCES
Many interested stakeholders cannot participate in the process without at least a small amount of funding to allow them to analyze the information and attend meetings. Funding for stakeholders should be implemented in such a manner as to maintain their independence. A potential source of funding could be through state or university grant mechanisms. (Sandia)
Up-front funding of stakeholder involvement would allow for education and continuity of the stakeholders involved in demonstrations, thereby enhancing effectiveness. Stakeholder involvement should be built into project funding. (Sandia)
Proposal 5. Provide Adequate Resources for Effective Stakeholder Participation
The greatest impediment to meaningful stakeholder involvement in the technology development process is inadequate resources and funding. Federal agencies desiring meaningful stakeholder participation must adequately fund such things as invitational travel, technical assistance, communication tools and other resources that will increase the ability of stakeholders to participate where needed.
IMPLEMENTATION
Based on the experiences of the MWWG, these proposals will significantly enhance the ability of federal agencies to demonstrate and deploy innovative technologies. In order to implement these recommendations, the MWWG proposes the following immediate actions for the consideration of the DOIT Committee:
Communications Plan - By the end of Fiscal Year 1996, convert MWWG and Site Team experiences in establishing effective communications among all technology development stakeholders into a Communication Plan. The purpose of this plan would be to establish an ongoing mechanism for gathering and disseminating, to all interested and affected parties, information and data critical to the technology development process, including opportunities for meaningful stakeholder involvement, both regionally and locally.
Integration Plan - By the end of Fiscal Year 1996, develop an Education Plan to provide adequate resources, professional assistance, and training in meaningful tribal and public involvement, collaborative decision-making and other related issues for both technical and non-technical personnel, including technology development project managers. The plan would facilitate integration of stakeholder involvement training, wherever appropriate, into current project management systems and training courses.
Model Solicitation Implementation - Monitor and evaluate the implementation of the pilot procurement to test the model solicitation for non-thermal technologies, approved by the DOIT Committee designees on December 12, 1995. Provide assistance to the DOE Mixed Waste Focus Area solicitation implementation team, gather lessons learned and identify broader applications of the model principles and process.
Transition Team - Establish a Transition Team comprising representatives from the MWWG Steering Committee, the MWWG Solicitation Subgroup, and additional stakeholders from the MWWG and Site Teams. The Team's purpose would be to develop the Communications and Integration Plans and funding requirements, and to serve in a consultative capacity to DOE as it implements the pilot procurement to test the Model Solicitation process. The Transition Team would monitor the solicitation and help assess its effectiveness.
Funding - The Department of Energy should fund the Transition Team and related activities or forums needed to develop the Communications and Integration Plans and monitor the Model Solicitation. As the scope of the Transition Team effort is broad and not limited to a single Focus Area or program, DOE should consider funding the Team outside of Focus Area budgets.