Umbrella Work Plan
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UMBRELLA WORK PLAN
For the
Agreement-In-Princople
Between United States Department of Emergency and the State of New Mexico
for
Environmental Oversight, Monitoring
at DOE Facilities in New Mexico
New Mexico Environment Department
DOE Oversight Bureau
2005
Table of Contents
I. Introduction
II. Environmental Surveillance Oversight
III. Environmental Restoration Oversight
IV. Waste Management Oversight
V. Emergency Response Planning and Oversight
VI. Public Information and Outreach
UMBRELLA WORK PLAN
I. Introduction
The Agreement-In-Principle between the U.S. Department of Energy (DOE) and the
State of New Mexico for Environmental Oversight, Monitoring (the AIP) states that “The
general intent of the State actions is to establish a comprehensive, coordinated
environmental oversight and monitoring program; to assess DOE’s compliance with
applicable requirements at the facilities, to update and maintain the emergency response
capabilities of the State; and to facilitate a better understanding by local and tribal
governments and the general public of the State’s perspective on the environmental
impacts and health risks, if any, associated with the facilities’ operations.” The AIP
stipulates that the State will prepare a work plan to address these oversight objectives at
DOE facilities. This Umbrella Work Plan lists the objectives and work elements of the
five primary oversight programs: environmental surveillance, environmental restoration,
waste management, emergency response, and public information and outreach.
Additional detail regarding the State’s oversight program at each facility will be
described in site-specific work plans.
New Mexico Environment Department (NMED) and DOE organizational structure and
program implementation procedures can be found in the Guidance Protocol for
Implementation of the Agreement-In-Principle.
II. Environmental Surveillance Oversight
Objective:
NMED-AIP staff will oversee environmental surveillance at DOE facilities to verify
whether pathways of contaminant migration to the public from sources related to DOE
activities are being adequately monitored and reported to the public.
Program Elements:
Monitoring Systems Assessment. Environmental monitoring systems at the facilities will
be evaluated to determine whether such systems are able to accurately monitor the
appropriate pathways given the contamination sources and environmental conditions.
Systems evaluation will include review of plan and procedures. Findings and
recommendations resulting from such evaluations will be provided to DOE, the facility
and the public.
Environmental Monitoring and Sampling. Environmental media such as air, biota,
ground water, surface water and sediments will be sampled and analyzed to verify
sampling data reported by the facilities. This will accomplished primarily by obtaining
split samples of media collected by the facility. In addition, independent sampling may
be undertaken to evaluate the need to monitor additional pathways or locations. Samples
will also be taken of spills and effluents in order to determine magnitude of source terms
and possible need for remedial actions.
Data Compilation and Review. Facility-generated data and NMED-AIP data will be
compared to determine if there is agreement between the two data sets. In addition, the
data will be statistically analyzed to evaluate spatial or temporal trends.
III. Environmental Restoration Oversight
Objective:
NMED-AIP staff will evaluate and monitor environmental restoration of contaminated
sites located at DOE facilities to assure that risk to human health and the environment are
effectively mitigated in conformance with applicable regulations, DOE orders, facilities
policies and procedures.
Program Elements:
Prioritization of Cleanups. Prioritization of cleanup activities at each facility will be
evaluated on an annual basis to assure that sites posing the greatest risk are addressed in a timely manner. Criteria will be developed in site specific work plans.
Review of Facility Data and Documents. Plans, procedures, data and conclusions based
on the results of the site activities will be reviewed to determine if they are in accordance
with the program objectives. Comments resulting from such reviews will be provided
within 120 days of the receipt of the complete information.
Sampling and Analysis. Samples will be collected at environmental restoration sites in
order to verify facility sampling techniques and analytical results, and to confirm the
adequacy of site characterization or cleanup.
Site Characterization. The adequacy of site characterization information and plans will
be evaluated as part of the review of RCRA Facility Investigations, and accelerated
cleanup or no further action proposals.
Risk Assessment. Review of cleanup proposals may require an evaluation of a
risk assessment completed by the facility.
Remedial Actions. The adequacy of remedial actions such as Corrective Measures and
Expedited Cleanups in protecting human health and environment will be evaluated.
Supporting Information. Background information, framework studies, and guidance
documents provide necessary baseline information for the environmental restoration
program. This information will be evaluated for technical accuracy and its ability to
support site cleanup decisions. Independent studies may be undertaken to fill in
perceived gaps in the facilities’ baseline information, or to verify facility generated
background data or conceptual models.
Comments and recommendations derived from oversight activities within the above
program elements will be provided to DOE, the facility and the administrative authority.
IV. Waste Management Oversight
Objective:
NMED-AIP staff will monitor management of wastes associated with activities at DOE
facilities in New Mexico to help assure that management practices are in conformance
with regulations, DOE orders, facility policies and procedures.
Program Elements:
Waste Management Operations. Facilities which generate, treat, store or
dispose of hazardous or radioactive waste will be visited to evaluate whether the waste
management practices employed confirm with regulations and guidance. Waste
management procedures will be evaluated prior to site visits. Sampling of wastes and
review of records and standard operational procedures will be part of this activity.
Facility Design. Plan for new facilities will be reviewed to assure that appropriated
provisions are made for management of wastes generated by activities associated with
such facilities. Examples of areas of interest in this context would include adequacy of
operational monitors (e.g. stack samplers, radiation monitors), environmental protection
systems (e.g. radiation shielding, secondary/tertiary containment) and waste
handling/storage provisions. Existing facilities will be evaluated in a similar manner.
Waste Minimization. Plan for waste stream reduction, waste segregation, and volume
reduction will be reviewed to ensure the establishment of goals within the facility.
Document Review. DOE or contractor-generated documents discussing waste
management and seeking public comment will be reviewed. Documents to be reviewed
include new regulations, implementation plans, and technical reports on both a national
and site specific basis.
V. Emergency Response Planning and Oversight
Objective:
State and local emergency response plans will be reviewed to assess whether such plans
adequately address off-site response to on-site emergency scenarios at DOE facilities in
order to provide for a coordinated response which will assure the protection of the public
health and the environment.
Program Elements:
Evaluation of Existing Plans. The status of existing community and facility emergency
response plans will be evaluated for their conformance to current regulations and
policies, and their ability to respond to credible on-site emergency scenarios.
Plan Completion. Completion of emergency response plans for communities surrounding
or adjacent to DOE facilities will be facilitated.
Training and Exercises. Staff will participate as observers in joint response training
conducted by DOE, with appropriate State agencies and local governments that could be
impacted by a hazardous materials emergency at a DOE facility. Training may include
planning sessions, tabletop exercises and full scale exercises.
VI. Public Information and Outreach
Objective:
NMED-AIP staff will communicate with the public in order to increase public awareness
and involvement regarding environmental issues associated with DOE facilities in New
Mexico.
Program Elements:
Public Information. NMED-AIP reports will be published that include finding and
recommendations regarding environmental program at DOE facilities. DOE will be
provided an opportunity to develop a disclaimer to be included in any such publications.
In addition, newsletter and pamphlet will be issued regarding oversight activities and
functions. An annual report will be issued covering activities during the calendar year.
Public Meetings. Public information meetings will be held periodically at locations in the
communities surrounding the DOE facilities.
Speakers Bureau. NMED-AIP staff will present upon request, information pertaining to
oversight activities to groups or organizations.
Educational Outreach. NMED-AIP staff will provide presentations to science teachers or
classes concerning their particular scientific discipline and how it is applied to oversight
activities at DOE facilities.