Benjamin Franklin said, “Tell me and I forget, teach me and I may remember, involve me and I learn.”
Getting involved is precisely what the U.S. Army Corps of Engineers (USACE) Buffalo and Pittsburgh districts, and their Memorandum of Understanding (MOU) agency partners, did, as they spent approximately eight hours ensuring that every “i” was dotted and every “t” was crossed during a Shallow Land Disposal Area (SLDA) tabletop exercise (TTX) preparing for the start of physical remediation after a nearly 15-year interruption. They discussed work plans, processes, procedures, and contract lists, and used graphic, videos – but more importantly, they got involved.
When Steven Diaz, the deputy director of Readiness Support Center and the TTX facilitator, walked to the lectern in a mostly full conference room at the Allegheny County Emergency Services building, he explained the purpose of the TTX was to enhance interagency coordination, test and refine roles, responsibilities, and response plans. Diaz said the TTX would help to pinpoint system gaps among the partners before active remediation commences later this year. He also wanted the partners to remember why they were there.
"This is not just an exercise," Diaz emphasized. "It's a rehearsal."
To echo Benjamin Franklin’s words, Diaz explained that the tabletop exercise is a rehearsal because it brings the major remediation players together and allows them to "rehearse" their plans and procedures. But more importantly, to be involved.
"This is the perfect opportunity, prior to the start of the project, to get with our federal partners to run through scenarios, iron out the details, identify friction points, and to really level bubbles," said Lt. Col. Robert Burnham, the commander of the USACE Buffalo District. "This is the time when we can pin down the friction points, bring them to light, talk about them as an open group, and work through the issues. It's an excellent opportunity for everyone to contribute and fully understand the process."
Approximately 50 people from various federal agencies participated in the TTX, including USACE regional and headquarters senior leadership, the Nuclear Regulatory Commission (NRC), the Department of Energy - Environmental Management (DOE-EM), and the National Nuclear Security Administration (NNSA), congregated at the Allegheny County Emergency Services Building in Moon Township, Pennsylvania.
"There are many agencies collaborating to clean and remediate the SLDA site," said Maj. Gen. Mark Quander, commander of the USACE Great Lakes and Ohio Rivers Division. "It's essential for us to discuss our different authorities and responsibilities, work together, and safely remediate the site for the nearby residents – it's what they deserve and what we are committed to delivering."
Approximately 2500 homes within one mile of the disposal area.
Shallow Land Disposal Area encompasses 44 acres of privately owned land in Parks Township, Pennsylvania. Between 1961 and 1970, the site owner, Nuclear Materials and Equipment Corporation used the site for radioactive waste disposal operations.
In 2002, Congress added the site to the Formerly Utilized Sites Remedial Action Program (FUSRAP). The FUSRAP program identifies, investigates, and, if necessary, cleans up or controls sites throughout the United States contaminated because of the nation's atomic weapons and energy programs.
Nicki Fatherly, the National Program Manager for FUSRAP, emphasized the importance of conducting tabletop exercises with all MOU partners prior to initiating remediation on a site.
"Our federal partners are an important part of this project. They bring specialized expertise and experience and will assist USACE should we encounter any Special Nuclear Material issues," said Fatherly. "The tabletop exercise will clarify roles and responsibilities to address for various SNM scenarios that could arise during remediation and how they should be addressed under the MOU."
Since August 2023, the Army Corps of Engineers and its remediation contractor, Amentum, have prepared the site for physical remediation. The contractors have added new structures for administrative areas, material processing, and testing buildings. They have placed more than 7,000 cubic yards of concrete and 1,000 tons of structural steel on the site.
“This [the tabletop exercise] is just another part of the pre-remediation process,” explained Lt. Col. Burnham. “We laid out the framework of how to deal with things that are not specifically addressed in the project workplans. We’ve taken a lot of input from our federal partners, and now we must codify these deliverables, these systems and these processes. Our protocols on how we work together most efficiently in different circumstances that we have identified through these scenarios.”
According to Steve Vriesen, the SLDA project manager, the project workplans cover every process and procedure through the characterization of SNM. He said that the MOU states clearly at what point USACE would consult its partner agencies and their authorities and responsibilities.
The tabletop exercise, with its scenarios, served as a preparation tool to ensure the various partner agencies with their different roles were communicating from the same script.
The four hypothetical scenarios crafted for the exercise focused on plans, procedures, and actions USACE. Scenario three and four described the process USACE and its partners would follow if the "shiny object," as Beth Anderson, a project manager for Amentum, described it, were discovered.
"The shiny object is a generic term that means something that's out of the ordinary, the unusual or unexpected material," said Anderson. "The shiny object would have to be a certain size, a certain shape, over a certain enrichment value – abnormal, the unknown."
As Anderson explained, the discovery of the "shiny object" would initiate the actions covered in the hypothetical scenarios devised for the tabletop exercise.
Each of the scenarios builds upon the previous one and was crafted to help define the roles of the MOU partners, determine who should be alerted, ensure established plans are followed, test procedures and verify the identification, handling and transporting the Special Nuclear Material is done safely and limits the potential for future work shutdowns.
“In executing the tabletop, it was so important for all of the partners to understand all of the mechanisms, the pathways and the flow paths, to iron out the nitty-gritty details of the project execution,” said Holly Akers, an Environmental Protection Specialist with the Office of Regulatory at the U.S. Department of Energy. “We couldn’t have asked for a better team coming together and combining all our skill sets. We really need it for the proper execution of the project.”
"The remediation of the SLDA site is a team effort," said Col. Nicholas Melin, the commander of the USACE Pittsburgh District. "Whenever you are getting ready to do something big, you need to get together to rehearse, and you need to practice. This tabletop exercise is that practice. We are getting that practice in now before we begin the real work."