"Is 'Trust Us, We're the Government' Really A Guarantee? A Review
of Financial Assurance Options for Long-Term Stewardship at the Mixed
Waste Landfill, Sandia National Laboratories" - by W. Paul Robinson,
Research Director, Southwest Research and Information Center. Conclusions " Recent policy initiatives and considerations by the Department
of Energy (DOE) related to long-term stewardship (LTS) do not provide
a clear path to solve the LTS dilemma;
" Transfer of waste sites to other federal agencies does not solve
the LTS dilemma nor dies it address questions about potential long-term
risks associated with specific sites;
" Clean up without removal of hazards will result in a greater emphasis
on LTS;
" LTS necessitates the use of a financial assurance mechanism or
other guarantees to ensure that all post closure activities and contingency
plans will be implemented;
" Trust funds have been established at DOE facilities such as the
Oak Ridge model.
Recommendations 1. The Corrective Measures Study (CMS) that is being conducted for
the Mixed Waste Landfill (MWL) should include costs of full remediation
to minimize or eliminate LTS requirements;
2. The CMS should identify the FULL COST for closure and post-closure
plans including periodic evaluation of the effectiveness of the proposed
evapotranspiration (ET) cap, monitoring, maintenance, and repair of cap
on a PERPETUAL basis;
3. A financial assurance mechanism should be included as part of the post
closure remedies in the CMS as an option to guarantee that the full cost
of LTS at the MWL will be available when needed.
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