Program Management Strategies for Following EPA Guidance for Remedial Design/Remedial Action at DOE Sites

At the U. S. Department of Energy (DOE) facilities, environmental restoration is being conducted in accordance with Federal Facilities Compliance Agreements (or Interagency Agreements). These agreements establish a cooperative working relationship and often define roles, responsibilities and authorities for conduct and oversight of the Remedial Action Programs. The U.S. Environmental Protection Agency (EPA) has guidelines on how to initiate and perform remedial actions for sites they are remediating under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Re-Authorization Act (SARA). This paper addresses some of the difference and commonalities between the DOE project management procedures and EPA guidance documents. This report covers only the RD/RA phase of environmental restoration. On the surface, there are many apparent differences between the DOE and EPA project management processes. Upon closer review, however, many of the differences are the result of applying different terminology to the same phase of a project. By looking for the similarities in the two processes rather than hunting for differences, many communication problems are avoided. Understanding both processes also aids in figuring out when, how and to what extent EPA should participate in the RD/RA phase for DOE lead cleanup activities. The DOE Remedial Design and Remedial Action process is discussed in a stepwise manner and compared to the EPA process. Each element of the process is defined. Activities common to both the EPA and DOE are correlated. The annual DOE budget cycle for remediation projects and the four-year cycle for appropriation of remediation funds are discussed, and the constraints of this process examined. DOE orders as well as other requirements for RD/RA activities are summarized and correlated to EPA regulations where this is possible. Finally, schedules for typical RD/RA activities are presented and DOE project schedules are compared to EPA restoration schedules. An innovative schedule is presented to meet CERCLA time constraints requirements for continuous remedial activity within 15 months of the ROD.