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Navigating Nuclear Legacy: Insights from Stephanie Schleif on Hanford Site Cleanup and the Role of the Department of Ecology

Jun 28, 2024

Introduction and Historical Context

1. Please introduce yourself, your role, and how long you’ve been in your current role.

My name is Stephanie Schleif, I am the Nuclear Waste Program Manager for Washington State Department of Ecology. I have been with the program and Ecology for almost 11 years and have been the Program Manager since March 2024.

2. Can you provide a brief overview of the Hanford Site and its historical significance in the context of the Department of Ecology?

The Hanford Site produced about 67 tons of plutonium from the end of World War II through the Cold War to fuel the country’s nuclear arsenal. However, this mission resulted in an emphasis on production over environmental protection, leaving behind one of the most complex environmental cleanup efforts in the world.

On May 15, 1989, Ecology signed the Tri-Party Agreement (TPA) with the U.S. Department of Energy and the U.S. Environmental Protection Agency to tackle Hanford cleanup. We partner with EPA as regulators to ensure Energy – the federal agency responsible for Hanford and its cleanup – follows environmental laws and meets cleanup deadlines outlined in the TPA.

Our Nuclear Waste Program’s mission is to protect the State’s air, water, and land at and adjacent to the Hanford Site by overseeing effective and efficient cleanup to ensure sound management of mixed hazardous wastes in Washington. We do this through the permits that we issue for water discharges, dangerous waste treatment, storage and disposal, and also air contamination.

3. What were the primary environmental challenges faced at the Hanford Site in the early years of its operation?

During the production years at Hanford, the emphasis was on creating plutonium for the nation’s nuclear stockpile, and there were no environmental protection laws in place. Throughout production, an estimated 440 billion gallons of wastewater was created and dumped or injected into the ground in cribs, pits, trenches, and injection wells.

About 56 million gallons of some of the most hazardous and radioactive waste was stored in 177 underground tanks. These tanks all were built between 1944 and 1986 with initial design lives of about 25 years. In addition, boxes and barrels containing chemical and radioactive waste were dumped into unlined trenches.

When cleanup began after the signing of the TPA, the agencies began tackling the tough job of cleanup, including retrieving tank waste from aging tanks and placing the waste in newer double-shell tanks; more than 85 square miles of contaminated groundwater plumes; 1,691 waste sites awaiting remediation (including miles of unlined landfills); 1,971 facilities to be demolished; and more, all generated during the site’s plutonium mission.

The TPA was also the start of implementing requirements for Energy to apply for permits issued by the state including to manage, cleanup and close any are where dangerous waste was being stored, treated or disposed of.

The Tri-Party Agreement

4. Can you summarize the Tri-Party Agreement and Consent Decree, and why they were established?

In 1989, the state of Washington, the U.S. Department of Energy, and the U.S. Environmental Protection Agency signed the Tri-Party Agreement, which is the governing document and roadmap for Hanford cleanup.

The TPA ensures that the cleanup of Hanford’s dangerous and radioactive nuclear waste complies with federal and state laws. The TPA originally had 161 enforceable milestones and now contains more than 1,500.

A milestone is a deadline with expectations of a deliverable necessary for environmental compliance to further the cleanup mission of the site. Any of the three agencies can request changes to the TPA. The approval process for changes may also include public involvement, depending on the extent of the change.

Due to continued delays in the progress of retrieving and treating tank waste, the state negotiated a federal Consent Decree with Energy in 2010 addressing tank waste treatment and retrievals.

The Consent Decree was amended in 2016 to reflect further delays in the tank waste mission. Key tank waste retrieval and treatment deadlines are set out in the Consent Decree. It was amended again in 2022 to reflect delays brought on by the COVID-19 pandemic.

The TPA agencies recently sent out for public comment proposed changes to both the TPA and Consent Decree. These changes followed four years of negotiations and represent a realistic and achievable course for cleaning up millions of gallons of radioactive and chemical waste from Hanford’s underground storage tanks.

The Role of Regulators

5. How does the Washington State Department of Ecology contribute to the regulatory oversight at Hanford?

As detailed above, Ecology partners with EPA as regulators of Energy’s cleanup of Hanford. We work to ensure cleanup follows environmental laws and that cleanup deadlines under the TPA and Consent Decree are met. The TPA Action Plan includes a Lead Regulatory Agency framework that divides the responsibilities of the regulatory agencies across the cleanup work.

In addition, the state has delegated responsibilities from EPA to permit dangerous waste, water quality, and air pollution at the Hanford Site. As such, we issue and maintain permits necessary to protect human health and the environment. These permits, when renewed, go out for public comment. Many of the permits can be found on our website.

6. Can you discuss the collaborative efforts between federal and state regulators in managing the site’s ecological challenges?

A lot of the cleanup work done at Hanford is the first of its kind in the world, and incredibly complex. The TPA agencies work closely together to ensure cleanup is safe, effective, and protective of human health and the environment.

In general:

• Ecology and EPA approve cleanup work Energy plans.

• Ecology issues permits for environmental regulations at the site, outside of the TPA, including for dangerous waste, air pollution and water pollution.

• Energy does the cleanup work, and Ecology and EPA oversee that work to ensure compliance with permits and other legal agreements.

• Energy reports the work once completed, and Ecology and EPA check that report and may request further work.

The Tri-Party Agreement’s Action Plan and Milestones

7. What are some of the key milestones outlined in the TPA, and why are they significant for the Hanford Site’s cleanup efforts?

Some of the major milestones in the TPA include:

• Closure of Hanford’s single-shell tanks and final disposal of all tank waste

• Investigation and cleanup of all contamination at soil and groundwater units

• Permitting and closure of treatment, storage, and disposal units

• Ceasing disposal of all contaminated liquids to soils

• Operation of the Waste Treatment Plant

The major milestones are represented by the “M-00s” in the agreement. For example, Milestone M-045-00 in the TPA is the major milestone for completing closure of all single-shell tank farms at Hanford.

The full work schedule of these milestones can be found in Appendix D (page 433) of the TPA on Hanford.gov.

These major milestones are significant for Hanford cleanup efforts because they represent the actions needed to ensure acceptable cleanup progress for the Hanford Site to comply with federal and state environmental laws.

Evolution of the TPA and Its Impact

8. What mechanisms are in place to update and revise the TPA action plan, and how does the Department of Ecology participate in this process?

Section 12.0 of the TPA’s Action Plan includes the process for updates to the plan, which includes Ecology’s involvement. There are three classes of change that can occur to the Action Plan, with varying levels of approval authority and process.

Department of Ecology’s Role

9. Can you describe the Department of Ecology’s role in monitoring and enforcing compliance with the TPA milestones?

The TPA includes a process for enforcing milestones and updating work schedules. Each piece of work has an assigned regulatory agency – either Ecology or EPA. When Energy notifies us that milestones are at risk of being missed, or are missed, there are mechanisms in place for either adjusting the work schedule for a project or for the regulators to enforce compliance with those milestones.

10. How does the Department of Ecology balance regulatory oversight with collaborative efforts to achieve the TPA’s goals?

Ecology is committed to open and transparent discussions with Energy at all levels. These discussions help identify areas of agreement that help drive the cleanup mission forward. As a regulator, there is always inherent tension between a regulator and a regulated entity such as Energy. However, approaching these discussions with an open mindset, assuming noble intent, and prioritizing transparent discussions has been key to coming to an agreement on complex permitting and cleanup decisions.

One of the most recent examples of collaboration has been the significant permitting progress to ensure Direct-Feed Low-Activity Waste treatment start up activities could begin. Ecology issued 55 permits that were needed by Energy to support the startup of DFLAW. We were able to issue those permits on a schedule that supported the needed field activities. This also has been observed in the significant progress we’ve made in completing the Hanford Sitewide Permit renewal which governs treatment, storage and disposal of areas with dangerous waste and preparing it for public comment.

Recent Changes and Ecology’s Role

11. How has the role of the Department of Ecology evolved in response to these recent changes?

Ecology’s role throughout the Hanford cleanup has remained the same. We are here to ensure the Hanford Site is cleaned up and managed in a way that protects human health and the environment. We work closely with EPA and Energy to do so while being responsive to the public’s priorities for work at the site.

Personal and Professional Insights

12. What motivates you and your team to continue striving for ecological improvement at such a historically and environmentally complex site?

Our mission is to ensure a safe, effective cleanup of Hanford that is protective of human health and the environment for current and future generations. This is a huge responsibility, and the decisions that we make as a program can have longstanding impacts. Our program and agency are committed to seeing that mission through; no matter how long it takes, or how tough it gets.

Communities across the Pacific Northwest stand to be impacted if the site isn’t cleaned up, or if something happens at Hanford. Getting the site cleaned up remains a top priority for the State of Washington. We’re also motivated by the continued progress and achievements being made out at Hanford – and by our fantastic team that has been dedicated to cleanup for so long. We have some of the most talented, passionate, and motivated staff and managers leading the permits and decisions that we issue. It’s these folks that have helped create and sustain a culture of positivity, acceptance, respect, and support at our program.

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