HANFORD ADVISORY BOARD
A Site Specific Advisory Board, Chartered under the Federal Advisory Committee Act

Advising:
US Dept of Energy
US Environmental
Protection Agency
Washington State
Dept of Ecology
CHAIR:
Steve Hudson
VICE CHAIR:
Susan Leckband
BOARD MEMBERS:
Local Business
Don Bouchey
Labor/Work Force
Derek Donley
Liz Mattson
Melanie Meyers
Lynn Davison
Rebecca Holland
Local Environment
Gene Van Liew
Local Government
Bob Suyama
Pam Larsen
Dawn Wellman
Rob Davis
Jerry Peltier
Gary Garnant
Bob Parks

February 4, 2016
Stacy Charboneau, Manager
U.S. Department of Energy, Richland Operations Office
P.O. Box 550 (A7-75)
Richland, WA 99352
Kevin Smith, Manager
U.S. Department of Energy, Office of River Protection
P.O. Box 450 (H6-60)
Richland, WA 99352
Dennis Faulk, Manager
U.S. Environmental Protection Agency, Region 10
825 Jadwin Ave., Suite 210 (A1-43)
Richland, WA 99352
Jane Hedges, Manager
Washington State Department of Ecology
3100 Port of Benton Blvd.
Richland, WA 99354

Tribal Government
Russell Jim
Gabe Bohnee
Armand Minthorn
Public Health
Tony Brooks
University
Gregory Korshin
Yonas Demissie
Public-at-Large
Jan Catrell
Alissa Cordner
Sam Dechter
Tom Galioto
Regional Environment/Citizen
Shelley Cimon
Steve Hudson
Floyd Hodges
Susan Leckband
Gerald Pollet
State of Oregon
Ken Niles
Mecal Seppalainen
Liaison
Representatives
Washington State
Department of Health

Re: Central Plateau Milestone Series Change Package

Dear Ms. Charboneau, Messrs. Smith and Faulk and Ms. Hedges,
Background
The Hanford Advisory Board (Board) provides the Tri-Party Agreement (TPA) agencies
with policy advice that reflects the Board’s core values1 related to Hanford cleanup. Core
values2 pertinent to the Proposed Changes to Hanford Central Plateau Cleanup Work and
Schedule (Change Package) include:
o

protect the Columbia River,

o

protect and restore groundwater,

1 http://www.hanford.gov/files.cfm/HAB_2013O-01_ValuesWhitePaper_Attach.pdf
2 As presented, the values listed are of equal importance.
EnviroIssues
Hanford Project Office
713 Jadwin, Suite 3
Richland, WA 99352
Phone: (509) 942-1906
Fax: (509) 942-1926

HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
Page 1

 o

protect the broader environment,

o

involve the public,

o

secure sufficient funding,

o

maintain the integrity of the Tri-Party Agreement (TPA),

o

incorporate long-term stewardship needs in current and future cleanup
decisions.

The changes proposed by the TPA agencies in the milestone series, M-015-00
(Investigation Work on the Central Plateau), M-016-00 (Cleanup Work on the Central
Plateau), M-085-00 (Canyon Cleanup), M-037-00 (Closure Requirements for Treatment,
Storage, and Disposal units), and M-094-00 (Completion of 300-Area Facilities), are
unprecedented. This is the first time3 in which the Board is tasked to consider an extensive,
negotiated change package to TPA Milestones that provides only losses in the form of
delays and no benefits in the form of accelerated cleanup projects.
The Board expects the TPA agencies to negotiate achievable, legally binding milestones
with the intent of balancing challenges to achieve cleanup goals on schedule with the need
to conduct and regulate a timely cleanup that reduces risk through remediation. The Board
is concerned that the delays negotiated in this milestone series were too easily pushed out
using insufficient funding as an excuse, rather than proposing more stringent cleanup
deadlines to make the case for more funding. Hanford cleanup is not discretionary. It is a
federal obligation to address the legacy of Cold War environmental contamination and
honor regulatory commitments to return the site to compliance with environmental laws.
The Board urges the TPA agencies to negotiate more stringent deadlines as part of this
obligation, to demonstrate the importance of this work, as Congress considers Hanford
funding.
The Board believes there is nothing impossible, nor impractical, about accomplishing
remediation under the original TPA milestones, utilizing technology that is currently
available. Hanford cleanup decisions will have impacts on people and the environment for
hundreds of years to come. The Change Package, as written, assumes that contaminants
contained in unlined trenches, in plumes of vadose zone soil and groundwater, both nearsurface and deep, are going to stay put during the proposed delays. This false assumption
3 The Board previously provided consensus advice on at least 13 proposed TPA Change Packages (Advice #53, 72, 73, 82, 125, 128, 154,
163, 216, 224, 231, 264 and 285).
HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
Page 2

 eliminates the urgency to fund this remediation work by presuming there is infinite time
available to mitigate this waste moving through the environment. For over a decade, many
interests at Hanford, including the TPA agencies, have engaged in discussions in a variety
of forums including the Hanford Lifecycle, Scope, Schedule, and Cost Reports4; centered
on how previous funding shortfalls have created and will continue to create, a large “bow
wave” of unfunded projects. Until this "bow wave" is eliminated, the result will be
exponential increases in the cost of total cleanup and increased risks from aging facilities
and infrastructure. Adequate funding levels are required to avoid this budgetary, and in our
opinion, environmental crisis.
The public should have meaningful opportunities to influence cleanup decisions through
open and transparent processes. Change Packages are particularly complex. The proposed
changes are difficult for the public to understand, and without clarity, make it challenging
for individuals to provide meaningful comments.
The Board believes that information provided about the changes should be more
comprehensive. The TPA agencies provided a coded list of the proposed changes and some
explanation of the process, however, the agencies failed to fully describe how Hanford
cleanup will move forward with these significant delays. The rationale for the proposed
changes or assumptions that were used to both necessitate the delay and support the new
proposed dates was not fully explained. An explanation was not provided for how the
agencies assessed the potential for increased risks to the environment, workers, the public,
or Tribes. A high-level overview of where the proposed changes fit within completion of
Hanford cleanup and how delays may impact overall costs of the cleanup would have
increased the HAB’s and the public’s understanding. In the future, the TPA agencies are
encouraged to provide this information and map an in-depth vision for the Board and the
public detailing the activities that are being recommended for elimination, deferment, or
reassignment from one milestone to another.
The Board has long argued for early access to information and for increased public
participation. It appears to the Board that more consideration should be given to the timing
of public meetings during TPA Change Package public comment periods to ensure
adequate time is provided to build understanding of these complex topics. There were
several conversations through the Board’s Public Involvement and Communications
4 http://www.hanford.gov/files.cfm/2014_Lifecycle_Report_DOE-RL-2013-02_Rev.1_FINAL.pdf
HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
Page 3

 Committee, and the River and Plateau Committee, in which Board members recommended
that meetings be held later in the comment period, as opposed to holding the meetings in
November 2015.
We believe that a more comprehensive suite of information and planned public meetings
are needed to achieve meaningful public involvement. The success of the Board as a group
representing and advocating for varied interests depends on having the latest information
pertaining to the priorities, timelines and funding decisions that impact the completion of
cleanup.
The Board supports the addition of the new milestone M-016-250 which aims to “develop a
three year rolling prioritized schedule consistent with site-wide cleanup priorities to
implement waste site removal actions.” Aggressive pursuit of this milestone by the
proposed March 31, 2016 deadline will help facilitate a much needed, collective
understanding of Fiscal Year 2017 federal budget requirements. It is the Board’s
understanding that initial inputs to budget planning are needed starting in February 2016.
Considerable cleanup is being delayed in contaminated areas that the Board has previously
identified as a high priority. For example, moving forward with the investigation and
remediation of non-tank farm/non-canyon waste sites in the 200 Areas, milestones M-01500 and M-016-00, is consistent with Board values. The Board believes this work to have
higher priority than other projects such as the demolition of U Plant or closure of B Pond, S
Pond or the Non-Radioactive Waste Disposal Landfill (NRDWL), included in milestone
M-085-00.
The Board believes the TPA agencies should expeditiously remediate the plume beneath
the 324 Building and move the Waste Encapsulation Storage Facility (WESF) cesium and
strontium capsules into dry storage, both of which pose very high risks. Proposed milestone
changes should be adjusted accordingly to better reflect these higher priorities.
The Board also believes the TPA agencies should expeditiously investigate potential risks
posed by the PUREX tunnels.
In addition, setting milestones for work described as “To Be Determined” (TBD) is not
acceptable. TBD is neither a guide for the Board or stakeholders, nor a vehicle for agencies
seeking funding for future cleanup. The Board repeatedly heard this message at public
HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
Page 4

 meetings.
The Board supports continuing the practice of setting some, limited target milestones,
based on observations of cleanup work to date. We have seen successful remediation and a
reduction of risk to humans and the environment because of this practice.

Advice
The delays in this change package are difficult to accept; in response the Board provides the
following specific advice:


The Board advises the TPA agencies to meet legal obligations by negotiating
more stringent deadlines in an effort to demonstrate the priority of this work to
Congress and drive adequate funding for Hanford cleanup.



The Board advises DOE to seek adequate resources for all proposed cleanup
activities.



The Board advises DOE to expedite the new M-016-250 milestone5 (3/31/2016)
in order to support efforts to influence the FY 2017 Federal budget planning
process, show progress, keep trained crews together for remove-treat-dispose
work, and to take advantage of “shovel ready work”.



The Board advises the TPA agencies to set a specific, achievable date for the M016-00 milestone6 and to cease the practice of publishing “To Be Determined” as
a place mark for a completion date. The goal should be to establish specific,
achievable milestones within a process that allows for changing milestones when
necessary.



The Board advises the TPA agencies to adjust proposed milestones to reflect an

5 M-016-250: “Develop a three year rolling prioritized schedule consistent with site-wide clean-up priorities to implement waste site
removal actions per Action Memoranda (DOE/RL-2009-37, DOE/RL-2009-48, and DOE/RL-2009-86). This milestone series will
continue on a yearly basis to reaffirm selected sites and recommend any changes to the list, to maintain a three year rolling
prioritized schedule, until such time that removal actions are completed.” (3/31/2016 And Annually Thereafter)
6 M-016-00: “Complete remedial actions for all non-tank farm and non-canyon operable units in accordance with schedules established in
approved RD/RA work plans.” (changed from 9/30/24 to TBD).
HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
Page 5

 acceleration of the M-015-00 and M-016-00 milestones series which cover the
investigation and remediation of non-tank farm/non-canyon waste sites located in
the 200 Areas, ahead of M-085 work related to demolishing plans to demolish U
Canyon and close B Pond, S Pond, and NRDWL. In addition, with regards to M015-00 and M-016-00 milestone sites with below ground contamination, the TPA
agencies should consider temporarily delaying capping to allow for future deep
vadose zone remediation.


The Board advises the TPA agencies to negotiate earlier milestone dates for the
cleanup of the 324 Building and initiate remediation of the plume beneath the
Building7. Extremely high radiation levels and proximity to the Columbia River
and to the people living within the boundary of the City of Richland morally
obligates near-term action.



The Board supports the newly proposed milestone M-016-086 (9/30/21) for
cleanup of the 618-11 burial ground8.



The Board advises the TPA agencies to expeditiously investigate whether the
PUREX tunnels pose a high risk, and if so, to then negotiate milestones to begin
planning for their remediation.



The Board advises DOE to move the WESF cesium and strontium capsules9 into
dry storage. These capsules pose a very high risk. Proposed milestone changes
should be adjusted accordingly to better reflect this higher priority.



The Board advises the TPA agencies to schedule meetings to educate the Board
and the public on expectations for cleanup based on year-by-year goals and

7 M-016-85: “Complete remedial actions for 300-296 Waste Site in accordance with RD/RA Work Plan for 300-FF-2 Soils (DOE/RL-201413-ADD1) and final disposition for the 324 Building and Ancillary Buildings in accordance with the Removal Action Work Plan
(DOE/RL-2004-77).” (9/30/2021)
8 M-016-86: “Complete remedial actions for 618-11 Burial Ground in accordance with RD/RA Work Plan for 300-FF-2 Soils (DOE/RL-201413-ADD1).” (9/30/2021)
9 M-092-05: “Determine disposition path and establish interim Agreement Milestones for Hanford Site Cs/Sr capsules. DOE will assess the
viability of direct disposal of the Hanford Cs/Sr capsules at the national high-level waste repository and provide a schedule
leading to its disposition. If DOE concludes that direct disposal is a viable and preferred alternative to vitrification, DOE will
submit to Ecology specific documentation justifying its conclusion, with a proposed milestone change request establishing
enforceable Agreement Milestones for dispositioning Hanford Cs/Sr capsules.” (06/30/2017) NOTE: This milestone is not
included in this Change Package.

HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
Page 6

 activities for the next decade and beyond. The intent is for the Board and the
public to better understand the overall impact of the delays proposed in the change
package and to address how DOE intends to mitigate the “bow wave” of unfunded
work that has accumulated.


The Board advises the TPA agencies to improve the public review and comment
process on proposed changes to the TPA or other important cleanup actions,
working closely with the HAB's Public Involvement and Communication
Committee on the development of materials and presentations describing change
packages.



During future TPA Change Package comment periods, the Board advises the TPA
agencies to include supplemental plain language explanations of terminology used
throughout the change package in their materials, especially references to
buildings, facilities, and waste sites.



The Board advises the agencies to create materials during future TPA Change
Package comment periods that make information about the following clear and
accessible:
o
Rationale for the proposed changes and assumptions that were used to
both necessitate the delay and support the new proposed dates;
o

Explanation of how the potential for increased risks to the environment,
workers, the public, and Tribes were assessed;

o

High-level overview of all pending cleanup work at Hanford and where
the proposed changes fit within completion of Hanford cleanup;

o

Impacts of the delays on estimated long-term cost increases for cleanup.

Sincerely,

Steve Hudson, Chair
Hanford Advisory Board
This advice represents Board consensus for this specific topic. It should not be taken out of context to
extrapolate Board agreement on other subject matters.

HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
Page 7

 cc:

Jon Peschong, Co-Deputy Designated Federal Official, U.S. Department of Energy
Richland Operations Office
Joanne Grindstaff, Co-Deputy Designated Federal Official, U.S. Department of
Energy Office of River Protection
David Borak, U.S. Department of Energy, Headquarters
The Oregon and Washington Delegations

HAB Consensus Advice # 287
Subject: Central Plateau Milestone Changes
Adopted: February 4, 2016
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