The Alliance for Nuclear Accountability has published four reports under the same title, Missing the Paths to "Cleanup", in which they castigate the DOE for doing it wrong. In reading the reports, I find that some of the logic is flawed in at least the following manners:

1. ANA repeatedly makes the 'all other things being equal" assumption without any justification. For instance, the argument is made that since the government can borrow capital cheaper than the private sector that "privatization' of cleanup must therefore be more expensive than cleanup by the government. This tacitly makes the "all other things being equal" assumption and they seldom are. In addition, it assumes the Congress will appropriate the necessary capital funds which they may not.

2. The reports document the 'failure" of DOE by selecting their "failures" while neglecting their successes. For example, by facilitating public participation in the Lower East Fork Poplar Creek remediation project, DOE, with the publics' help, was able to convince the regulators that the presence of an insoluble mercury species justified raising the remediation goal. This reduced the original estimated cost from $ 1.6 billion to about $10 million. Does ANA feel that this is so trivial as to be ignored or are they just unhappy that public reason prevailed over theirs.

There is an increasing list of successful remediation efforts indicating the current methods are working.

3. The ANA seems to expect perfection by DOE in the face of uncertainty. For example, the failure (by their definition) of the In Situ Vitrification demonstration at the Melton Valley site. Indeed, there was an unexpected event (an explosion by their definition, a low pressure steam expulsion by mine). However, the ANA fails to point out the project was intended to ascertain the feasibility of using ISV under very wet conditions. It is unfortunate that not all such demonstrations are entirely successful on the first attempt. After the experience gained in this test, alterations in the methodology have been made and successful demonstrations have been conducted at other locations.

It is unfortunate that the ANA did not predict this problem and recommend the better methodology before the first test.

4. The ANA makes frequent use of the "undefined pejorative term". The most frequent example of this is: risk or danger. Since all activities have some risk, this cannot be denied. Yet unless the risk is significantly greater than the risk of alternatives including do nothing, the statement contributes little to the choice of cleanup methods. and much to the emotional climate.

5. I find the reports long on "criticism" and short on "constructive criticism" although the last report does claim to be constructive, I find their suggested criteria among the things DOE is already doing. It is easy to lead an elephant, find out where he is going and walk in front of him.

6. Lastly ANA states that the remediation problems are too important to be political. They then cite the Governor of Tennessee of stating the State would accept no more waste shipments to the TSCA Incinerator. To be consistent, ANA should have chastised him for being so political. Further, if ANA were sufficiently aware of the ORR problems to issue sound advice, they would know that the Governor really wants something else and that TSCA is not at ORNL.

The problem is too important not to be political (and based on sound technical grounds). And the ORR stakeholders are properly involved.

I shall leave it to the reader whether we are missing the path or not.