| Hanford Advisory Board Past Advice
The Hanford Advisory Board (HAB) provides a forum for seeking a regional consensus on Hanford cleanup activities. The HAB meets under authority of the Federal Advisory Committee Act. Its primary mission is to provide informed recommendations and advice to the U.S. Department of Energy, the U. S. Environmental Protection Agency and the Washington Department of Ecology on issues related to the cleanup and safe management of waste at Hanford.
HAB membership is broadly representative of the diverse interests affected by Hanford cleanup issues. Members include Native American tribes, local governments, the State of Oregon, workers, environmental groups, public health, state universities, local business, and other public interest groups. The State of Oregon is represented on the HAB by the Oregon Department of Energy and the Oregon Hanford Cleanup Board.
The HAB develops consensus advice through a deliberative process, with advice originating in committee and typically going through several iterations before coming before the full HAB for consensus. Through December 2000, the HAB has issued 113 pieces of consensus advice. The advice has focused on a wide range of issues. All HAB advice is available on the web at http://www.Hanford.gov/boards/hab/advice/adviceindex.htm.
HAB advice has consistently and repeatedly supported sufficient funding for cleanup, endorsed compliance with the Tri-Party Agreement, and advocated on behalf of worker safety and public involvement. Specific cleanup projects which the HAB has also consistently and strongly supported included treating Hanford’s tank waste, removing spent fuel from the K-Basins, stabilizing plutonium at the Plutonium Finishing Plant, and cleaning up waste sites along the Columbia River.
The following excerpts from past HAB advice illustrate the HAB’s primary values and priorities
Cleanup Values
- "Columbia River should be the highest priority. The river is a vital resource in the Northwest…
- Protect public\worker health and safety.
- Put waste in an environmentally safe form.
- Get on with cleanup to achieve substantive progress in a timely manner…
- Accept the fact that interim storage of the waste in an environmentally safe form will occur at Hanford.
- Minimize transportation of radioactive and hazardous materials to and from the site to reduce the risks to the public and the environment." Consensus Advice #6, November 1994.
"The Board supports…moving ahead rapidly with cleanup in the 100 and 300 areas." Consensus Advice #1, June 1994.
"(The Environmental Restoration Disposal Facility) should be limited to waste from Hanford Cleanup." Consensus Advice #2, July 1994.
"Historic and cultural resources have value and should not be degraded or destroyed. Appropriate access to those resources is a part of that value…Cleanup activities should protect to the maximum degree possible the integrity of all biological resources, with specific attention to rare, threatened, and endangered species and their related habitat." Consensus Advice #4, September 1994.
"The goal of (100 Area) cleanup should be to release a high percentage (~95%) of the 100 Area corridor for fully unrestricted surface use by 2018. Earlier phased release of significant portions of the corridor should also be considered…Cleanup levels for all areas that are released for fully unrestricted use should meet cleanup standards established by the responsible regulatory agencies." Consensus Advice #23, May 1995
Protect the Columbia River
"The overall importance of the Columbia River to all stakeholders and public and private organizations in the Northwest cannot be overstated. Thus the minimization of current and future risk to the ecology of the river and the recreational and economic users of the river is a major driver to Hanford cleanup activities." Consensus Advice #21, May 1995.
"The Board supports the agencies’ preferred alternative to remove, treat (as appropriate or required) and dispose of the contaminated soil and associated structures from selected source areas within the three 100 Areas (BC-1, DR-1, and HR-1). We agree with the agencies that these former liquid waste disposal sites are high priority because of their potential health and ecological threats to groundwater and the Columbia River…In addition, these actions will provide needed information and experience that will be valuable in later cleanup projects." Consensus Advice #27, August 1995.
Treat Tank Wastes
"The Hanford Advisory Board has long believed that removal of wastes from the tanks is one of the highest priorities for cleanup of the Hanford site." Consensus Advice #83, December 1997.
"We recommend a contract structure that financially rewards contractors for exceeding, and penalizes contractors for failing to meet, the 2007 hot start milestone…We also recommend a contract structure that provides incentives for increased waste treatment throughput capacity and for expediting tank waste treatment." Consensus Advice #109, June 2000.
K-Basins’ Spent Fuel
"…the Department of Energy, the Department of Ecology and the Environmental Protection Agency…should continue to move toward expedited removal of spent fuel from the K-Basins as quickly as possible…" Consensus Advice #6, November 1994.
Support for the Tri-Party Agreement
"The HAB unanimously urges that the USDOE and the Congress not delay actions to stop the spread of contamination and to accelerate the final cleanup at Hanford. DOE and Congressional actions should be consistent with the following principles:
- Legally binding commitments made by the Federal Government after extensive public participation must be honored. These include the Hanford Tri-Party Agreement (TPA), (and) its most recent negotiations…
- Cleanup activities must be governed by a negotiated agreement, such as the TPA, which is based on stakeholder and public input. The TPA is not only a commitment that is essential to the credibility of the USDOE and the Federal Government, but also represents the only existing set of health, safety, and cleanup prioritization for the Hanford cleanup budget. The TPA is the only cleanup budget prioritization which is responsive to risks presented by the Hanford site, has been subject to outside scrutiny, and incorporated public values and priorities.
- The only acceptable measure of the cleanup activities at Hanford is demonstrated progress to meet the TPA milestones…
- The USDOE and its contractors must continue to work with the EPA and the Washington State Department of Ecology to assure that reasonable and correct interpretations of regulatory requirements are used as the basis for the Hanford cleanup… The HAB advises USDOE not to compromise established cleanup standards under a false expectation that this will provide a cost savings." Consensus Advice #11, January 1995.
"The Hanford Cleanup Tri-Party Agreement (TPA) is America’s contract with citizens of the Northwest…Meeting the TPA’s negotiated milestones is fundamental to protect the region’s public health, safety and environment. The basic TPA milestones and priorities have broad public and regional political consensus – reached after years of controversy, broken promises and delays… Unilateral budget actions that violate TPA commitments, or legislatively-sanctioned actions that avoid compliance, put our region’s health, safety and environment at significant risk." Consensus Advice #17, April/May 1995
"The Hanford Advisory Board protests any and all actions which would allow the federal government to avoid its legal and moral obligations to fully clean and restore the Hanford site. On behalf of the citizens of the Northwest, we urge the three agencies to aggressively defend the integrity of the Tri-Party Agreement." Consensus Advice #26, June 1995
Failure by DOE to request adequate funding should not be the basis for making changes in the TPA milestones. DOE should request adequate budgets to cover known commitments, including compliance with TPA milestones, and a reasonable contingency to address unanticipated technical and safety issues." Consensus Advice #64, February 1997.
"The Board wishes to reiterate its long held value that the Tri-Party Agreement (TPA) is the primary legally controlling document for the Hanford site clean up program. Any other planning must be examined for its compliance with the TPA. Any changes must comply with NEPA or other required regulatory processes." Consensus Advice #78, November 1997.
Cleanup Funding
"USDOE must honor its obligation to request necessary funds." Consensus Advice #5, September 1994.
"DOE should not allow the cleanup budget to subsidize Defense and Energy programs. All transfers of Defense programs, facilities, or materials to the EM Program should be accompanied by full commitment to funding at the time of transfer." Consensus Advice
#8, December 1994.
"The HAB opposes any reduction in funding for the Environmental Restoration (ER) Program. DOE-RL site management stated that it based the proposal to eliminate all cleanup work on strategic choices but this does not reflect the public values for protecting the Columbia River and the promised acceleration of cleanup along the River to release these areas for unrestricted public use. Many of the most visible achievements for the cleanup effort on site are contained in the ER Program." Consensus Advice #94, March 1999.
"Level funding is inadequate to achieve timely and effective Hanford cleanup. Flat budgets over the last several fiscal years have forced the Hanford Site to postpone critical cleanup activities, infrastructure upgrades and facility construction… Target budgets are inadequate to fund all safety and legally required cleanup work." Consensus Advice #107, April 2000.
Off-Site Waste Acceptance
"…Acceptance of off-site waste must be contingent on existing facility capacity and on availability of funding to handle processing and storage needs, while having a neutral or positive impact on Hanford clean-up…Prolonged storage of off-site wastes prior to treatment, or of post-treatment residuals, generally should not be approved…Existing Mixed Waste facilities at Hanford must be in substantial compliance with the Tri-Party Agreement milestones, other orders or agreements and RCRA or state law requirements in order for permits to be issued or amended to allow off-site Mixed Wastes to be treated, stored or disposed of at Hanford." Consensus Advice #13, February 1995.
"Increased disposal of off-site waste should not be considered without charging the fully-burdened costs and without investigation of the cumulative impacts on soil and groundwater from disposal. The diversion of funds or resources, and increased impact of increased disposal of offsite wastes are not acceptable to the HAB." Consensus Advice #98, July 1999.
Groundwater/Vadose Zone
"Tri-Parties should:
- Use pump and treat to ensure that discharged contaminants are contained and do not continue to move toward the river or public drinking water supplies.
- Continually investigate new technology to remove contaminants in the groundwater consistent with current groundwater standards." Consensus Advice #3, July 1994.
"Commence to pump liquids from the highest concentration area(s) to achieve mass reduction and containment (of carbon tetrachloride). Pumping efforts should be increased if outward migration continues, this requires the use of sufficient monitoring wells to measure conditions in both the groundwater plume as well as the vadose zone cloud." Consensus Advice #10, December 1994.
"The HAB recommends continuation of successful pump and treat programs for strontium-90 and chromium remediation in the 100 Area." Consensus Advice #40, February 1996.
Characterization of the vadose zone at the tank farms needs to continue to provide an adequate understanding of the extent to which soil and groundwater beneath the tank farms have been contaminated and to quantify additional releases during (single shell tank) retrieval." Consensus Advice #54, November 1996.
"The Board has recommended in previous consensus advice … that there is a need for an integrated approach that evaluates the cumulative impacts of the various cleanup alternatives for the Hanford Site. The Phase 2 [Columbia River Comprehensive Impact Assessment] would provide a mechanism for such an integrated and systematic analysis." Consensus Advice #61, December 1996.
"Provide adequate resources necessary to develop a comprehensive plan and investigate and document the extent of the radiological contamination of the vadose zone. This should include continued support to the Expert Panel and a budgetary increase of the vadose zone project in consultation with the Expert Panel and this Board." Consensus Advice #67, April 1997.
Public Involvement
"The Hanford Advisory Board believes the process for reaching the broader public (beyond the Hanford Advisory Board) for the Hanford site needs to be more efficient, cost effective, and responsive to the needs of the citizens of the Northwest, and needs to relate to broad key issues onsite…The Tri-Parties should…work with the HAB Public Involvement Committee to choose and develop innovative methods to: inform the public; get input from the public; evaluate public involvement results and make needed changes." Consensus Advice #25, June 1995.
"USDOE should identify where its major assumptions are proposed to be changed and engage the HAB, regulators, Tribes and the public in a dialogue regarding justifications for such major changes. For assumptions that depart significantly from past regional stakeholder consensus advice and values, USDOE should not adopt new assumptions without full written justification and dialogue with the regions stakeholders." Consensus Advice #36, December 1995.
"…in 1994, Secretary Hazel O’Leary endorsed the formation of an Openness Panel as a strategy for furthering communication, public participation, whistle blower protection and general understanding by the public and stakeholders of DOE plans and programs. It is recommended that DOE work immediately with stakeholders to initiate activities to form and charter such an Openness Panel." Consensus Advice #37, December 1995.
"Both the Plutonium Roundtable and the Hanford Advisory Board have repeatedly urged DOE to abandon the current piecemeal approach to nuclear material storage and disposition. The National Equity Dialogue offers an alternative: to address the pros and cons of the entire nationwide disposition problem in an effective, open, representative, rational and equitable fashion…This current, rushed series of hearings, and late availability of materials on nonproliferation, serve as another example of the piecemeal approach that makes a mockery of public participation and frustrates rational decision making. It represents a return to the "decide, announce, defend" strategies of the past which proved so prohibitively expensive to the Department, both in financial capital and public trust." Consensus Advice #56, November 1996.
"Citizens have played a key role in helping guide Hanford cleanup decisions. Given the consequences of a less-than-successful cleanup, and the fact that opportunities for formal comment and to influence cleanup decisions are limited, it is imperative that the Tri-Parties respond quickly, clearly and directly to public comments, concerns and suggestions…The Tri-Parties should proactively inform the public about how comments influence decision-making." Consensus Advice #92, March 1999.
Other Issues
"The HAB is concerned that the long and seemingly unending work force restructuring being applied at Hanford has stressed and demoralized the workforce to a point of extreme risk to the success of the Hanford Mission. We are concerned for the health, safety and dignity of the workforce as the downsizing continues. The HAB believes the methods and timing of any workforce reductions are critical. Whenever such a reduction of force is determined to be necessary at Hanford, affirmative measures should be taken to first minimize the impacts it may cause to the health and safety of Hanford workers and the safety of Hanford’s mission." Consensus Advice #39, February 1996.
"The Board encourages DOE to offer significant incentives to the Management and Integration Contractors to acquire goods and services from the residents and businesses locally and in this region." Consensus Advice #59, December 1996.
"The Board encourages DOE to move away from the concepts of cost reimbursement contracting." Consensus Advice #62, December 1996.
"Physical and administrative institutional controls should not be substituted for cleanup activities or become end states. Cleanup emphasis should be placed on permanent remedies, to avoid reliance on institutional controls. If institutional controls are deemed necessary by regulators, these should be established with consideration of existing and potential future land uses, including local government land use plans and expected tribal use scenarios." Consensus Advice #63, February 1997
"It is mandatory that DOE nurtures a safety-conscious work culture at the Hanford Site. All must ensure that employee concerns and investigation programs are credible by visibly holding management, supervisor and workers accountable to standard environmental, safety and health policies." Consensus Advice #81, December 1997.
"The (Board) urges the Washington Department of Ecology and U.S. Environmental Protection Agency to require a determination if Hanford’s low-level waste burial grounds contain mixed low-level hazardous or dangerous wastes…If it is determined that the low-level waste burial grounds contain mixed low-level waste, the regulators should use their existing legal authority to regulate the burial grounds appropriately. The Board urges no offsite waste be disposed into the low-level waste burial grounds being investigated until the determination is made, and they are appropriately regulated." Consensus Advice #103, February 2000.
"The Hanford Advisory Board (HAB) has an acute concern with regard to the remedial actions for the 618-10 and 618-11 burial grounds. The HAB supports the preferred alternative to remove-treat-dispose these wastes…the recent finding of high levels of tritium near the 618-11 burial ground indicate there are wastes in that burial ground which were not previously known or expected. The tritium is a warning that other contaminants may be migrating from the burial ground…This is a potential threat to the river and to Richland’s drinking water supply. These issues support the need to exhume these burial grounds." Consensus Advice #106, April 2000.
"We are writing to express our concerns over your (decision) changing delegation of approval authority for Environmental Restoration documents. Your memo removed signature authority for Interim CERCLA Records of Decision and RCRA permits from the site managers and transferred those authorities to DOE-Headquarters. The Hanford Advisory Board requests reversal of this decision. We are concerned this change will add an additional layer to an already complex process for review and approval of environmental documents." Consensus Advice #110, June 2000.
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