Page 123 - Beyond Decommissioning

104 Beyond Decommissioning

Long-term stewardship (LTS) includes all mechanisms planned and
implemented to protect the public and the environment from legacy waste regarded
as impractical, unsafe, or too costly to remediate to unrestricted release. LTS
reflects the reality that the cleanup of contaminated sites cannot in many cases
achieve unrestricted use conditions and the sites would therefore require the
long-term regulated management. Commonly used synonyms for LTS include
“long-term surveillance and maintenance,” “legacy management,” and “long-term
monitoring and surveillance.” The main reasons for establishing LTS for a site
are one or more of the following:

l priorities—there is not enough funding for cleanup to unrestricted release;
l long-lived contaminants—many radionuclides, chemicals, and metals cannot easily or
rapidly be converted to safe compounds;
l technology—no further environmental benefit is achievable with current remediation
technology or plateau levels have been hit (e.g., in groundwater);
risk—short-term intervention risks in performing remediation exceed the benefits of
l
remediation.
In detail, LTS includes
Physical/engineered controls (e.g., fencing, walls, trenches; locks on wellheads, gates,
l
fences; guards and security patrols; and signs, markers (Fig. 2.11), or monuments).
l Institutional/administrative controls (e.g., zoning, permits, restrictions on land and water
use, and excavation permit requirements; deed notifications and restrictions and title
transfers; and administrative orders).
l Monitoring (for surface water: dam integrity and operations, inflows to ponds, stream flows,
water quality onsite and offsite, etc.; for groundwater: contaminant concentrations, ground-
water flow data for use in water balance and groundwater modeling; drainage wells, water
level monitoring points, etc.; for air: environmental air quality, effluent concentrations,
meteorological data; for ecology: the location and abundance of flora and fauna; noxious
weeds, endangered species; migratory birds, etc.). Monitoring also includes any corrections
of deviations.
l Information management: for example, about the location and nature of residual hazards, the
originating processes, and the controls. Information aspects include collection, storage, cir-
culation to involved parties, and retrieval; relevant factors included data reliability, public
trust in the information, and the ability of future generations to access, understand, and use
the information (Interstate Technology and Regulatory Council, 2004).
Planning for stewardship should be critical to the decommissioning/remediation pro-
cess, as the costs and liability-related stewardship may impact the decommissioning
strategy, extent of remediation, and the future reuse option, if any is possible. If reuse
is envisaged, the level of residual contamination must be compatible with the follow-
on use, and the new user may be assigned responsibility for the stewardship activities
and costs (this will depend on who will be the new owner/licensee, on national leg-
islation, and on contractual agreements inherent to the property transfer). Prior to
transferring the site to a new user, a database should be established, which will store
and maintain the data on location of remaining contamination and details on any
related monitoring and institutional controls: types and detail of information relevant
to DOE property transfer are contained in US Department of Energy (2001).