Recommendation 98-1
Comments on the Leaking White Metal Box Incident

Based on their understanding of the incidents involving the white metal boxes, the Fernald Citizens Advisory Board is concerned about the consequences of this event on the ability to meet the cleanup goals at Fernald in a safe and cost-effective manner. The Fernald Citizens Advisory Board believes the Type B investigation may not fully explain why the event occurred nor identity reasonable measures that need to be taken to provide additional safeguards for future shipments. The Fernald Citizens Advisory Board expressed the following concerns to the DOE: 1) lack of management in box design and construction, 2) lack of testing of the white metal boxes to simulate the repetitive stresses associated with truck travel, 3) lack of redundant systems, 4) the moisture content of the materials was not considered, and 5) lack of a systems planning approach and learning from past mistakes. The results of the investigation may provide insights that could benefit all site operations from a systems point of view to ensure that the FCAB have the right systems and personnel in place to keep the site remediation on track.

Recommendation 98-2
Follow-up on the Leaking White Metal Box Incident

On February 10, the members of the Fernald Citizens Advisory Board attended a briefing of the Type B Investigation report by the DOE. After careful review, the CAB feels the report lacked information as to how the mistakes were allowed to occur in the first place. The CAB has identified some of the questions raised by the Type B investigation report. Only to the degree that these types of questions are answered and broad-based corrections implemented throughout all of the FEMP, will the CAB be satisfied that DOE has implemented a program that is capable of achieving the enormous challenges that face us over the next decade. The FCAB strongly cautions against an investigation that results in simply writing more rules to be followed and hopes that in the end the DOE will be able to devise a process that is not larger but rather smarter. Ultimately, it is important to understand that the key to this investigation is not how to build a better box, but rather how to create systems which allow us to get on with the job of cleanup.

Recommendation 98-3
Achieving Fernald’s Remediation Objectives

A number of issues in the past months have raised serious concerns within the Fernald CAB about the DOE’s ability to achieve Fernald's remediation objectives. The CAB devoted the majority of its May 16 meeting to discussing these issues and developing recommendations. At the time, there were three specific issues that are of major concern: 1) resolving the logjam on off-site disposal 2) accelerating disposition of special nuclear materials stockpile at Fernald and 3) establishing a steady budget sufficient to achieve success. The FCAB recognizes that many of these issues are not of DOE’s making, however, they feel the DOE needs to be more aggressive in resolving these issues, creating contingency plans, and seizing every opportunity possible to remove materials from Fernald.

Recommendation 98-4
Inter-modal Transportation for Materials to the Nevada Test Site

Over the past two years, the Fernald Citizens Advisory Board has taken a considerable interest in the use of inter-modal transportation for materials being disposed at the Nevada Test Site. A number of recent activities have increased the importance of this issue. Most important, the recent incidents with the leaking of the white metal boxes have increased concerns regarding the transportation of hazardous materials through congested and heavily populated areas. The FCAB strongly supports the investigation of alternative transportation routes to NTS. They strongly encourage that DOE and the Air Force explore the idea of making the road through Nellis Air Force Base available for truck transportation.

Recommendation 98-5
Closure Projects

The US Congress designated three Department of Energy facilities (including Fernald Environmental Management Project) as "closure projects." The FCAB had hoped the designation would greatly facilitate the completion of the Fernald site. However, the DOE's Closure Fund Management Plan and subsequent actions have convinced the FCAB that this is not the case. The result of the traditional DOE budgeting for FY2000 was the cutting of tens of millions of dollars from the Fernald budget, which eliminated any chance of achieving closure by 2006. After undergoing the traditional DOE budgeting process for FY2000, the CAB felt unsettled and rather confused about the value of having been placed on the Closure Account list.

Recommendation 98-6
Transfer of Management to U.S. Army Corps of Engineers

The FCAB is strongly opposed to the transferring of management of Fernald Environmental Management Project to the US Army. The Fernald project is on track to achieve closure by 2006. Transferring management will result in a transition period which would cause a delay of a year or more. Instead, DOE and Congress need to provide Fernald with stable funding, DOE headquarters needs to be more responsible to the needs of the site as outlined in the Closure Fund Management Plan, and all parities need to work together to implement the decisions that everyone has worked so hard to make.

Recommendation 98-7
Environmental Assessment for Proposed Final Land Use

The FCAB supports the basic intent to restore the site with a focus on natural resources, however, there are a number of concerns and additions they would like to see addressed. First, the FCAB is concerned about the ability to create a healthy and self-sustaining ecosystem on land that is robbed of topsoil, vegetation, and nutrients. Second, the FCAB believes that future uses of the site must be consistent with the natural resource focus of the site and the rural nature of the surrounding community. They believe Fernald site should have lasting value for the surrounding communities. A cultural and/or historical center would blend in well with the established long-term uses of the site and create something of national significance and offer broader and longer-lasting value to the community. The On-Site Committee of the FCAB is beginning to discuss the details of this future use plan and will be contacting DOE and FDF in the future.

Recommendation #98-8
Implementation of Intermodal Transportation of Fernald Waste

With the release of the Environmental Assessment (EA) for Intermodal Transportation, the FCAB believes that intermodal transportation can begin in the very near term. Private concerns in Caliente have indicated that a facility can be available to transfer from trains to trucks very soon. The FCAB would like to assume a leadership role in this arena and implement an intermodal program as soon as logistically possible.
Ongoing coordination with FDF and DOE.

Recommendation #98-9
Use of Nellis Road

The EA supports the FCAB's belief that the use of intermodal transportation for low-level waste going to the Nevada Test Site will result in significant long term risk reduction and cost savings o by eliminating hundreds of thousands of truck miles through dozens of states. The FCAB strongly encourages the Ohio Delegation to investigate opening the road through the Nellis Air Force Base to truck traffic.

Recommendation #98-10
Support of EA for Intermodal Transportation of Low-level Waste

The FCAB supports the findings of the Environmental Assessment (EA) for Intermodal Transportation of Low-level Waste to the Nevada Test Site. They strongly encourage the DOE to take a more aggressive role in establishing and using intermodal transportation.