NNMCAB Committees Hear Presentation From N3B On Interpretation Of ‘Risk’ For LANL Legacy Waste Cleanup


N3B’s Erich Evered, right, chats with Lee Bishop at a pre-COVID meeting. Photo by Maire O’Neill/losalamosreporter.com


Northern New Mexico Citizens Advisory Board committees for risk and the 2016 Consent Order heard a presentation June 24 by Erich Evered on how “risk” is interpreted in connection with making decisions for environmental remediation, particularly as it relates to the cleanup of legacy waste from Los Alamos National Laboratory. 

Evered is director of operations for enhanced stakeholder engagement at N3B Los Alamos, LANL’s legacy waste cleanup contractor and is responsible for novel and expanded outreach and engagement of the stakeholder community. He was invited by the CAB to brief members on how the Department of Energy baseline, the N3B cleanup contract, the Consent Order and the Appendices B and C of the Consent Order all relate to each other and fit together. 

The 2016 Consent Order is an agreement between DOE and the New Mexico Environment Department which provides a framework for accomplishing cleanup for legacy waste associated with LANL.

Evered said that in the course of various conversations over the last year or more it had become clear that there’s not a clear alignment on what is meant by “risk” and that risks were understood by some to be the formal quantified human health risk assessments but that is not necessarily so. The word ‘risk’ can mean different things in relation to an environmental remediation program, depending on the context of its use, he said.

Evered first spoke to the Human Health and Ecological Risk Assessment process which is required under the Consent Order to conduct cleanup work at Environmental Management Los Alamos. 

“Risk assessments in this context are calculations made based on established formulas and algorithms to assess the risk to receptors – a human being or an organism in the environment, an animal or a plant at a specific cleanup site. These risk assessments are conducted for each solid waste management unit or area of concern based on the data we have collected there for the contamination present at that site,” he said. He noted that there are well over 2,000 such sites across the Laboratory. 

The results of those calculations are compared to thresholds for human health risks and for ecological risks and if the resulting calculation of risk falls below that threshold, it qualifies the site as “remediation complete” if some remediation had happened, or “no remediation required” if it’s already below that, Evered said. 

“That calculation is used as a basis for the certificate of completion by NMED which is our green light to move ahead and say we’re done with that site and we’ll continue to work on the others. Having met those thresholds doesn’t mean we automatically stop work. It could mean that for various reasons we conduct further remediation for other reasons, but per the strict requirements of the Consent Order and the Human Health and Ecological Risk Assessment we are not required to,” he said. 

For human health risk, the calculations are based on certain future use scenarios for human activity at the site. 

“For us the Risk Assessments are typically contained in the Investigation Report, which for an Aggregate Area covers multiple solid waste management units (SWMUs) and Areas of Concern but we don’t blend those risk assessments – they’re individual to the contaminated site. There’s a risk assessment for each but they could be combined in a very large document called an Investigation Report. If with those risk assessments we meet the criteria, NMED can issue a certificate of completion for each of those sites,” Evered said.

He noted that the acceptable risk level is formulaic. Under the Consent Order, for human health risks that threshold is one in 100,000 added cancer case in a lifetime statistically added by the presence of the contamination.

“That threshold compares to the population wide risk of getting cancer in one’s lifetime of 39.5 percent, so one in 100,000 versus 39,500 in 100,000 normal lifetime cancer likelihood. For the ecological side, it’s a composite, a mathematical approach to the risk to individual organisms and it’s called a hazard index.” Evered said.

He said safety and health risks that attach to any particular remediation approach are also considered.  He noted that any physical industrial activity is going to carry risks for workers, including excavation, construction, heavy equipment operation, materials handling, or exposure to hazardous or radioactive waste.

“Another risk would be transportation safety mainly for the public and in the hauling of large quantities of material that go up and down the hill for purposes of remediation, including excavation for capping for some of the materials disposal areas and then the empty trucks have to go back. So all of this is a cumulative statistical transportation risk and there are standard formulas for calculating anticipated accidents and injury calculations on the basis of that amount of traffic,” Evered said. 

He noted there are also risks to public safety in the potential airborne release of contamination during excavation of waste in a waste pit or contaminated soil but that there are ways to engineer facilities and techniques to reduce that risk. 

 Evered said political/perception risk is a soft category but it’s an important one. 

“It goes to the heart of what many of us who manage publicly visible programs have to deal with and be sensitive to. We want to avoid unnecessary risk of failure to adequately embrace the intangibles that matter to stakeholders or the community at large,” he said. “For example, if there’s a potential of imminent movement of groundwater contamination off DOE property, one might want to deal rather promptly with that and a potential response strategy might include making that groundwater plume the #1 cleanup priority in the program and implementing an Interim Measure to arrest the plume’s advance and to reduce contamination in the aquifer.”

Evered said that should sound very familiar to many people because that is exactly the case with the chromium plume at Mortandad Canyon.

“It is the #1 priority in the Consent Order. It is the #1 in our program. There is a very successful Interim Measure that’s in operation both in arresting the advance of the plume and reducing contamination. 

He said the second thing under political/perception risk iswhat to tackle first. 

“If you have a wide area that you’re dealing with geographically, and you have adjacent public like we do with the community and townsite of Los Alamos right next to the Laboratory on two sides, what would make sense to do first? It might be to go after that that is closest to the boundary or most visible or closest to the public and that has been done in great measure in this Consent Order in prioritizing sites,” Evered said . 

He said many of the high priority campaigns have to do with the outside of the Laboratory footprint to address that perceived need to protect the public from nearby exposure. 

“Another potential response, given what one might have to deal with, would be to make haste in visibly changing the skyline to demonstrate progress. That’s not something currently we have to deal with. It is for other DOE cleanup sites and it was here at Los Alamos during the Recovery Act Program of bringing down buildings safely at Technical Area 21 at DP Mesa. It’s in that category of addressing what we perceive and have heard from the community is what they’d like us to do first,” he said. “The last example would be if for some reason we chose not to be in a supportive posture towards the commitments the federal government has under public law for land transfer to local jurisdictions. Clearly we choose to make visible progress at TA-21 to enable a timely transfer of that land to Los Alamos County as provided for in the law.”

Evered noted that project risk is something project managers live with every day.

“When you develop a project with a scope and the cost for accomplishing that work scope and a schedule with which you are going to conduct it, you also identify project risks – those  things that could threaten your ability to accomplish your work – and you can build conservatism in your budget to provide for that or set aside management reserve to deal with it if you were to encounter it,” he said. “Any good project manager understands his project risks entering a project, and as he or she goes along those risks either happen in real life or the project progresses to the point where they’re not a risk anymore; then you alter your risk management for the project to delete them.”

Evered gave examples of the kinds of things that could delay or cause a cost increase in any particular cleanup project. 

“A downhole drilling obstruction which causes you to have to abandon that hole and start over – that adds cost and it adds time. If you encounter a greater volume of contaminated soil to be cleaned up than you expected based on previous information that adds time and cost. You might be able to double up crews to get the volume excavated but it’s going to add cost because you’re going to need more people and equipment. And if you encounter a higher level of radiological or industrial contamination in the soil than you had planned for – that’s going to add cost and time. We have encountered each of these project risks in the last two years,” he said.

The last category Evered discussed was programmatic risk where unknowns cause uncertainties in total program size and cost. 

“An example would be when one has a good understanding, or at least preliminary quantification, of contamination at some sites (and hence a reasonable expectation of cleanup costs), but hardly any such information for certain other sites, one may choose to move the latter sites up in priority for investigation to address that uncertainty risk,” he said.

Evered is no stranger to environmental cleanup program management having had contractor program responsibility at seven major DOE sites where he also worked with Citizens’ Advisory Boards and other stakeholder groups.