What is the purpose of the Hanford Site-Wide Risk Review Project?
In January 2014, the Department of Energy (DOE) asked the Consortium for Risk Evaluation with Stakeholder Participation (CRESP) to conduct an independent Hanford Site-wide evaluation of human health, nuclear safety, environmental and cultural resource risks (hereinafter referred to as the “Risk Review Project”) associated with existing hazards, environmental contamination and remaining cleanup activities. The overarching goal of the Risk Review Project is to carry out a screening process for risks and impacts to human health and resources. In this Risk Review Project, human health and resources evaluated include groundwater and the Columbia River, facility workers, co-located people, the public, and ecological and cultural resources. Collectively, humans and these resources also are referred to as “receptors”.
What will happen with the results of the Risk Review Project?
The results of the Risk Review Project are intended to provide the DOE, regulators, tribal nations, and the public with a more comprehensive understanding of the remaining cleanup at the Hanford Site to help inform (1) decisions on sequencing of future cleanup activities, and (2) selection, planning and execution of specific cleanup actions, including which areas at the Hanford Site should be addressed earlier for additional characterization, analysis, and remediation.
How will this Risk Review affect regulatory decisions made or to be made under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and /or Resource Conservation and Recovery Act (RCRA)?
The Risk Review Project is not intended to make or replace any regulatory decision under CERCLA, RCRA and/or other, applicable laws, regulations, and legal requirements. Further, the Risk Review is not intended to substitute for any document required to be prepared under CERCLA, RCRA, or other, applicable federal law (such as a natural resources damages assessment).
What is the relationship between the Risk Review Project and cleanup commitments made in the Tri-Party Agreement and/or 2010 Consent Decree?
The Risk Review Project’s focus is risk characterization, not risk management decisions. Risk management is within the sole purview of the DOE and its regulators (Environmental Protection Agency (EPA) and the State of Washington). The Risk Review Project is not intended to substitute for the regulatory decision processes found in the Hanford Federal Facility Agreement and Consent Order (known as the Tri-Party Agreement) and/or applicable Consent Decree.
What is the relationship between the Risk Review Project and treaties with Native American Tribes?
The Risk Review Project is not intended to interpret or otherwise affect any treaty entered into between the United States and a Native American Tribe.
Who is conducting the Risk Review Project?
The Risk Review Project is led by the Consortium for Risk Evaluation with Stakeholder Participation (CRESP). CRESP is a multi-disciplinary consortium of universities that includes Vanderbilt University, Rutgers University, New York University School of Law, Oregon State University, the University of Arizona, Howard University, and the University of Wisconsin – Madison. CRESP’s mission is to advance environmental cleanup by finding ways not only to improve the scientific and technical basis for management decisions, but also to foster stakeholder participation in the effort. CRESP is being assisted in this Risk Review Project by researchers from Pacific Northwest National Laboratory (PNNL). Additionally, a Core Team consisting of senior representatives from the Department of Energy (DOE), the State of Washington Departments of Ecology and Health, and U.S. Environmental Protection Agency (EPA) provide advice on the development and execution of the Project. There also are opportunities at key points during the Risk Review Project for input from individuals, organizations, agencies, elected officials and tribal nations.
Has CRESP been involved in other risk review projects?
Yes. CRESP has completed risk informed characterization projects involving complex issues at both large and small Department of Energy (DOE) Environmental Management (EM) sites across the United States. Furthermore, senior CRESP researchers have been in risk evaluation and risk-informed decision making for a broad range of local, state and national issues.
What is the difference between this Risk Review Project and other “risk” initiatives previously conducted at Hanford?
Previous risk initiatives were less comprehensive and were not using information that is now available. Second, previous risk assessments did not systematically summarize the current state of information regarding current hazards and risks across the site. A third difference is that this Risk Review Project is a collaborative effort led by an independent entity (CRESP) involving a core team from all three Tri-Party members – US Department of Energy (DOE), EPA, and State of Washington. Finally, at key points during the Risk Review Project, the views of tribal nations, stakeholders, agencies, and members of the public are solicited and considered.
Why is the review being conducted now?
There are several reasons. First, cleanup has proven to be a much lengthier, more complex, more technically challenging and more expensive undertaking than was envisaged in 1989 when Hanford’s mission shifted from production of weapons material to waste management and cleanup. The remaining cleanup program at Hanford is anticipated to take approximately 50 years or longer and cost more than $100 billion. Thus, this is a multi-generational effort. Despite the many challenges that have emerged over the past 25 years, significant cleanup has occurred at the Site, including the treatment of contaminated soils and groundwater near the Columbia River.
Second, certain key cleanup activities, such as removing the threat from the radioactive waste stored in underground tanks and treating that waste, is taking much longer and proving to be much more difficult to achieve than originally anticipated. This means assessment of current and future risks associated with long term cleanup activities need updating based on strategies already implemented or being implemented and those anticipated to be implemented in the future.
Third, the very nature and sequencing of cleanup activities have been altered over time as findings about site characteristics and disposal options have changed and conclusions as to the efficacy of new or existing technologies have been adjusted.
Finally, the public, DOE and regulatory agencies, organizations, and tribal nations don’t always agree on the challenges posed by cleanup either now or in the future and/or how resources should be directed to be protective of human health and the environment in the near-term and integrated with clean work to address long-term future risks. It is anticipated that the results of this Risk Review Project will allow DOE, its regulators, tribal nations, and the public interested in or affected by site decisions to have readily available a more robust set of information and be better informed when (a) making decisions on sequencing of future cleanup activities, and (b) selecting, planning and executing specific cleanup actions, including which areas at the Hanford Site should be addressed earlier for additional characterization, analysis, and remediation.
Will the entire site be evaluated?
The focus of the review is the currently identified currently remaining waste, facilities, structures and environmental contamination components of the Hanford Site. The Risk Review Project will not evaluate past cleanup actions nor resources on uncontaminated areas of the Site. Cleanup sites at Hanford remaining as of October 1, 2015 have been divided into approximately 60 units for evaluation purposes called evaluation units (EUs). These EUs include the cleanup efforts overseen by both DOE-Richland Operations Office (RL) and the Office of River Protection (ORP). The EU concept was developed by the Risk Review Project to provide a tractable basis for reviewing the wide range of cleanup challenges at the Hanford Site. Categories of facilities, wastes and existing environmental contamination within each EU are based primarily on geographic location. This is because the potential to impact human health and resources (also called receptors) is fundamentally based on geographic location and spatial relations that may lead to exposure of receptors to hazards from specific sources. Thus, EU categories are not based on, and may not correspond with, either the process history that produced the wastes or environmental contamination, nor the groupings used for regulatory purposes (e.g., operable units). An EU may contain one or multiple sources of waste or contamination. What is the process CRESP will use to evaluate risk?
Once the evaluation units have been selected and information on each unit has been gathered, CRESP will develop a summary level catalog of risks to the public and workers and impacts on the environment. Using a carefully-evolved and transparent methodology, CRESP will evaluate and group the risks and impacts of the sites’ units into bins or levels (from very high to negligible) according to the magnitude of potential harm that these units now and in the future may pose to the public, workers, and the environment, including ecological and cultural resources.
Risks evaluations will be consider future land uses that have been designated, potentially augmented by some from regulatory specifications. Consideration also will be given to nearby land uses and activities that have a potential to impact the public, workers, and the environment.
What is the process or approach CRESP is using to evaluate risk?
The evaluation methodology being used to accomplish the Risk Review Project’s goal to carry out a screening process to evaluate risk and impacts to human health and resources consists of several elements. They include:
Identification of Evaluation Units (EUs). The remaining cleanup sites at Hanford as of October 1, 2015, have been divided into approximately 60 EUs, which are composed of geographically co-located sites to the extent possible, considering commonality among source types and the overlapping of impacts and risks to human health and resources. There are five categories: (1) legacy source sites, such as past practice liquid waste disposal and buried solid waste sites; (2) tank waste and farms and associated legacy contamination sources; (3) groundwater plumes; (4) inactive facilities undergoing decommissioning, deactivation, decontamination and demolition; and (5) operating facilities used as part of the cleanup process.
Summary Evaluation Templates. Each EU is described in detail using existing information, including regulatory documents, maps, and studies. Information gathered on each EU includes the unit description and history; an inventory of waste and contamination history; selected or the potential range of cleanup approaches; and the ratings of risks to human resource and environmental receptors, by providing rough order of magnitude relative grouping or binning of risks to each different type of receptor. The primary groupings are Very High, High, Medium, Low, and Not Discernible.
Risk Ratings. The receptors being rated but not ranked are facility workers, co-located people, public, groundwater and the Columbia River, and ecological resources. Developing a ranked list of cleanup priorities is the sole purview of the DOE and its regulators, considering a wide range of factors and input. The groupings of risk ratings (e.g., “high”, “medium”, etc.) for each type of receptor are determined by application of the specific methodology developed for that receptor. Demarcation between ratings uses recognized regulatory or literature thresholds applicable to the specific receptor, if they exist, as screening levels, as well as other factors. This approach is intended to provide relative risk ratings within receptor categories (i.e., relative binning of risks to the Columbia River, groundwater, ecology, etc.). Risk ratings for each receptor are then used to inform the urgency of addressing specific hazards. An overall risk rating is not provided for cultural resources; however, information about cultural resources within each EU and near (within 500 m) each EU is gathered, described, and analyzed as a planning guide or tool for future cleanup activities.
Temporal Evaluation Periods. Risks are evaluated based on distinct time periods: the current status of the EU, typically prior to cleanup although cleanup has been initiated for some EUs; active cleanup period (or until 2064); near-term post-cleanup (until 2164, or assuming a 100 year duration for institutional controls associated with areas transferred from federal control); and long-term post-cleanup (or until 3064, with potential impacts beyond this period noted when possible). Each EU and selected EU components are evaluated as if cleanup were not to occur for 50 years to provide insights into the potential risks of delay, which will help inform sequencing of cleanup actions. However, this is not to infer that delay of cleanup for 50 years is recommended.
Initiating Events. The likelihood of initiating events, both localized and regional in scale, which may occur during any or all of the evaluation periods, such as fire, volcanic eruptions, loss of power, and loss of cooling water, are described. This is to establish a consistent basis for identifying and categorizing phenomena that may remove or degrade barriers thus placing receptors at risk from contaminants. Nuclear safety is considered in the context of potential initiating events and risks to receptors.
What other agencies are involved with the Risk Review Project?
CRESP is leading the Risk Review Project with input from a Core Team consisting of senior managers from the DOE (EM, Richland Operations Office (RL) and the Office of River Protection (ORP)), EPA, and State Washington Departments of Ecology and Health. The Core Team provides advice on the development and execution of the Risk Review Project. Pacific Northwest National Laboratory provides research, analytical, and other assistance to CRESP as directed.
How will the public be kept informed?
It is important that members of the public interested in the Risk Review Project be kept informed and also be given the opportunity to provide information and/or comments as the Project proceeds.
In addition to briefings and other informational meetings, there are three key points during the execution of the Risk Review Project when written input is specifically sought from stakeholders, interested members of the public, tribal nations, and governmental entities. The key points are: (1) on the draft methodology developed to execute the project (Sept. 4 to Oct. 3, 2014); (2) on the interim progress report that provides results of the first set (25) of evaluations and interim observations (Sept. 1 to Oct. 30, 2015); and (3) the final report that provides the results of the remaining evaluations and final observations, conclusions, and/or recommendations (anticipated comment period for 60 days following release of the report).
Any member of the public providing CRESP with an e-mail address will be sent periodic updates on the status of the Risk Review Project and information (including links) on how to provide input. CRESP’s webpage on the Risk Review Project (www.CRESP.org/hanford/) will contain the most up-to-date information on the Risk Review Project.
Will input from the public be considered?
Yes. Every written comment received will be acknowledged, reviewed and considered.
Will the results of the Risk Review Project be made public?
Yes, the results of the evaluations conducted under the Risk Review Project will be made public at two or more points during the Risk Review Project. First the interim progress report submitted to the DOE, State of Washington, and EPA on August 31, 2015 is considered a public document. Written comments received on the interim progress report during the comment period – September 1 through October 30, 2015 – are expected to inform the final report prepared on the Project.
Second, a final report of the Risk Review Project is expected to be completed and will be made available to the public. CRESP will give the public an opportunity to provide written comments on the draft of the final report. All written comments received will be acknowledged and considered before the final report is completed.
The final methodology, which was developed to execute the Risk Review Project, is considered a public document. Written comments were solicited on the draft methodology and over 300 comments were received. Independent experts also provided input. (For a brief overview of changes between the draft and the final methodology, including a list of comments made (without attribution), refer to the Overview of Revisions Made to the Methodology Rev A, Sept. 2014). Revisions were made based on comments received, lessons learned from pilot case studies, and input received from the Core Team agencies. The final methodology was submitted on August 31, 2015.
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What will happen with the final report of the Risk Review Project?
The final report is considered to be a public document and is intended to be of specific value to the Tri-Parties, (DOE, EPA, State of Washington Department of Ecology) as well as to other agencies with specific responsibilities at Hanford, such as the State of Washington Department of Health, the Nuclear Regulatory Commission, and the Defense Nuclear Facilities Safety Board, as well as tribal nations and other interested organizations and the public.