Sources of Conservatism in Making Corrective Action Decisions at the NNSS - 20477
During the course of closing nuclear testing release sites at the Nevada National Security Site (NNSS) under the Federal Facility Agreement and Consent Order (FFACO) using the Risk-Based Corrective Action (RBCA) evaluation process, conservative assumptions and estimates were used in many phases of the work. These assumptions and estimates were agreed to during Data Quality Objective (DQO) meetings and published in the FFACO documents. However, the potential cumulative effect of these multiple sources of conservatism was not evaluated. The RBCA process ensures that corrective action decisions minimize the risk of making Type I errors (not applying corrective action to areas that exceed action levels) at the expense of making Type II errors (applying corrective action to areas that do not exceed action levels). Rather than fully characterizing the spatial distribution of contaminants throughout each site, the RBCA process uses a bounding methodology that conservatively estimates spatial boundaries beyond which contamination is not present that exceed corrective action levels. This process accepts that these boundaries may encompass areas that do not exceed corrective action levels and, therefore, may be somewhat larger than for fully characterized sites. This is justified at sites where the reduction in investigation costs are more than any potential increase in corrective action costs. To minimize the risk of making Type I errors, conservatism was used throughout the process. This study documents the many sources of conservatism used in the RBCA process. Conservatism was used in the RBCA process in determining potential receptors, determining action levels, collecting samples, converting sample results into receptor dose, and accounting for uncertainty. This provides decision-makers with a high level of confidence that unacceptable risk to receptors will not result from exposure to residual contamination outside the corrective action boundaries. However, it does not provide an estimate of the actual extent of areas exceeding action levels. This study provides an evaluation of the effects of compounding conservatism on RBCA process decisions. (authors)