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Hanford Cleanup Policy

Every year, dozens of policy issues are evaluated by the Department of Energy while Hanford Communities’ staff monitor the status of these major policy issues, providing in-depth analysis and information to local government officials. Meanwhile, tangible progress is being made to clean up the Hanford Site and meet the requirements of the Tri-Party Agreement and Consent Decree. Adequate funding must be budgeted to keep the progress on track and not continue to drive lifecycle costs higher. The following priorities reflect these focus areas moving forward.

High Level Waste (HLW) Interpretation

The Hanford Communities is encouraged by a December, 2020 Department of Energy (DOE) report which indicates that up to $210 billion could be saved, and the timeline to complete tank waste treatment could be reduced by 10 years, if the revised HLW interpretation is applied at the Hanford Site. This science-based approach would allow DOE to manage and treat waste according to its physical characteristics and risk, rather than simply based on where it originated. If applied at Hanford, this process would open up disposal options other than a deep geologic repository, along with opportunities to permanently ship waste out of Washington state. The Hanford Communities is equally encouraged by the DOE’s December 15, 2021 Federal Register Notice affirming its interpretation. DOE should continue working with its regulators, the Tri-City community and regional tribes to further pursue this approach.

Regulatory Environment

For years the Hanford Communities has been very concerned that the regulatory environment delayed rather than enabled cleanup progress at Hanford, which ultimately prolongs risks to the Tri-City community. We have been encouraged recently, however, by what appears to be a significant improvement in cooperation between DOE and its regulators. The Hanford Communities strongly believes that successful cleanup of complex sites like Hanford requires alignment, agreement on priorities, and the appropriate use of regulatory discretion. We appreciate the efforts of Department of Ecology leadership to achieve this alignment, and encourage the Tri-Party agencies to continue working towards a shared approach to safely expediting cleanup progress.

Sustained Cleanup Progress

The Hanford Communities believe that cleanup of the Hanford site should be risk based and reflect the community’s concerns and priorities. It should also be cost-effective and based on the best available science, applied consistent with the environmental and biohazard risks of the waste. To sustain congressional support for cleanup funding, the Department of Energy’s Richland Operations Office (RL) and the Office of River Protection (ORP) must continue to demonstrate that tax payer dollars are effectively managed, produce the desired results, and comply with Tri-Party Agreement (TPA) requirements and other legal commitments.

FY 2024 Hanford Budget Request

For the first time ever, the Hanford Communities joined 10 other entities, including governors, regulators, community organizations, organized labor, and “watchdog” groups to ask for a significant increase in the funding level for Hanford cleanup in FY 2024. The requested funding level of $3.76 billion is critical in order to continue ongoing work across the Hanford Site while also providing the necessary resources to move forward with the design, engineering and construction of the High Level Waste (HLW) facility. Without this increase in FY 2024 through the end of the decade, important work will be delayed, more TPA milestones will be missed, and the timeline for completion of Hanford cleanup will be further extended. The Hanford Communities recognizes that important work is taking place at other DOE cleanup sites across the country, and that those efforts should be adequately funded as well, therefore we encourage the Administration and Congress to support an increased budget for the entire Office of Environmental Management (EM).

The Hanford Communities remains very concerned about the long-term cost projections for Hanford cleanup which, on the high end, could be over $11 billion annually in order for cleanup to be complete by the year 2078. We do not believe that this funding level is realistic or achievable. Given these funding realities, the Tri-Party Agencies should actively pursue promising new technologies and cleanup options which have the potential to safely expedite cleanup and reduce lifecycle costs over the current baseline.

Tri-Party Agreement

Much of the Hanford cleanup strategy falls under the “Tri-Party Agreement” between DOE, EPA and the State of Washington’s Department of Ecology. The Hanford Communities strongly support the intention of the Tri-Party Agreement including changes and amendments, as appropriate, to incorporate such issues as improved technology developments, better scientific understanding, and options for efficiencies.

The Tri-Party Agreement was entered into by the parties in May of 1989. There have been six amendments and numerous modifications over the past thirty-two years. The Hanford Communities are concerned that the structure of the Agreement may have outlasted its usefulness in moving toward the shared goal of cleanup and removal of waste from the Site. Strict adherence to the Agreement has led various parties to use its terms as a cudgel which has prevented the parties from achieving their shared goals.

Additionally, the commitments in the TPA are out of date and no longer meet the needs of local communities, nor do they promote realistic budgets or schedules. The time is right for the Tri-Parties to reexamine the milestones in the agreement, taking into consideration the current site conditions and prioritized risks over the next decade. This would create an opportunity to bring forward a shared vision that includes input from the local community and provides realistic budget assumptions and achievable schedules. The TPA should also include annual waste volume reduction curves for the tank waste, MLLW, TRU waste, HLW etc. This is the only way the public can measure if the Tri-Party Agencies are actually achieving real cleanup on an annual basis that will lead to completion of the Hanford mission.

Use of CERCLA in place of RCRA for Nuclear Waste Remediation

The Consortium for Risk Evaluation with Stakeholder Participation (CRESP) Omnibus report suggested that using CERCLA (Superfund) regulations in place of RCRA makes more sense for radioactive contamination. We were encouraged that state regulators and EPA have met to explore this and other opportunities to seek solutions for management and disposal of waste that reduces cost and improves schedules. There are numerous examples at other sites within the DOE-EM complex where this appropriate use of regulatory discretion has led to expedited cleanup. These and other efforts are needed now and will reduce unnecessary delays in making cleanup progress and support realistic schedules and annual budgets.

High Level Nuclear Waste Storage

The Blue-Ribbon Commission Recommendation to establish a new entity dedicated solely to implement the nation’s high level waste management program is endorsed by the Hanford Communities. The establishment of a licensed nuclear repository and an interim storage facility in Eddy County, New Mexico, or in another community interested in hosting a site is also supported.

High Level Waste (HLW) Interpretation

The Hanford Communities is encouraged by a December, 2020 Department of Energy (DOE) report which indicates that up to $210 billion could be saved, and the timeline to complete tank waste treatment could be reduced by 10 years, if the revised HLW interpretation is applied at the Hanford Site. This science-based approach would allow DOE to manage and treat waste according to its physical characteristics and risk, rather than simply based on where it originated. If applied at Hanford, this process would open up disposal options other than a deep geologic repository, along with opportunities to permanently ship waste out of Washington state. The Hanford Communities is equally encouraged by the DOE’s December 15, 2021 Federal Register Notice affirming its interpretation. DOE should continue working with its regulators, the Tri-City community and regional tribes to further pursue this approach.

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