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Hanford Watch 503-232-0848 February 2, 2004 Dear
Northwest Congressional Delegation: Over
the past decade or more, we have worked diligently to build a coalition
of interests in the Northwest to support the critical cleanup of nuclear
contamination at the Hanford site.
We have supported funding, lobbied for greater efficiencies in
contracting, recommended changes in timelines and milestones, and actively
participated in the public involvement process. Over
this period of time, many positive developments have taken place at
Hanford. River shore cleanup
efforts have moved forward expeditiously.
Millions of tons of contaminated soil and other materials have
been moved away from the Columbia River.
C, D and DR Reactors have been cocooned, and work is underway
on F and H Reactors. Much of
the 2,100 tons of spent nuclear fuel in the K-Basins has been removed
from the degrading storage ponds near the edge of the River.
Liquid discharge to the soil has been halted, reducing the amount
of contaminants pushed further down towards the groundwater. Renewed focus and attention has been directed
towards construction of the vitrification plant, and construction of
the plant is now well underway. Each
of these accomplishments were the result not only of actions taken by
the Department of Energy, but also by an engaged and active Congressional
delegation, a supportive public community willing to support changes
in the cleanup program and milestones, and regulators who recognized
that the Department was serious about pursuing a cleanup program that
valued a collaborative approach. Unfortunately,
over the past year or more, we have detected a troubling change in this
previously cooperative partnership.
The DOE seems increasingly unwilling to involve, engage or even
inform regulators, stakeholders or the public.
And even when information is forthcoming, it is becoming clear
that the Department has no interest in paying any attention whatsoever
to the comments received from their “partners.” For
example: · Last January, the Department of Energy unilaterally announced that they had reached agreement with CH2MHill on a new contract that would incentivize the “closure” of 40 tanks. Suffice it to say that this was a surprise to the regulators and to the stakeholders, who viewed the Department’s efforts simply as an attempt to get out from their responsibility to actually remove all of the radioactive and hazardous contents of the tanks, and instead “close” the tanks by filling them with grout or concrete. ·
This
past summer, the Department of Energy announced that it no longer intended
to vitrify all tank waste -- as required by the Tri-Party Agreement. Instead, it planned to study multiple “supplemental
technologies” which might be used to treat as much as 2/3 of the underground
tank waste. Stakeholders were
assured that the process for identifying and selecting the chosen technology(ies)
would involve the public and regulators and would take 12 to 18 months
to reach a conclusion. Yet,
in December, without any advance notice, the Department violated their
earlier assurances to the public, and unilaterally downselected to a
single technology -- with no opportunity for public or regulatory input. ·
Over
the past two years, regulators, stakeholders and the local DOE have
engaged in a collaborative process to identify and take advantage of
risk-assessments to create a roadmap for cleanup of contaminated sites
at Hanford. In spite of this cooperative effort, the recommendations
of the region were flatly rejected by DOE headquarters, which has ordered
the site to go back to the drawing board. ·
Until
2001, the DOE had allowed regulators, stakeholders and even contractors
to review current year budgets, and work to make informed recommendations
for upcoming budgets for the site.
Since 2001, the DOE has refused to release any substantive information
about budgets. Today, more than
four months into the fiscal year, stakeholders have no idea where the
2004 budget will be allocated, and thus, no way to make any reasonable
recommendations for the upcoming budget submission to the Office of
Management and Budget for FY 2006 or to the United States Congress for
FY 2005. ·
Concerns
have been growing that the DOE is seeking to eliminate members and reduce
the influence of the Hanford Advisory Board -- which remains the only
group with long-term knowledge and understanding of the cleanup efforts.
With so much turnover in the DOE and contractors, the HAB is the only
group that retains a sense of historical perspective and memory on the
cleanup effort. ·
The
region worked for several months with local DOE officials to come up
with an acceptable Risk Based End State document which was submitted
to headquarters this past fall. DOE-HQ
reviewed and rejected the plan. Hanford
was commended as best in class for the technical analysis that was included
in their plan. But like all the other similar site plans, we were sent
home to “creatively” come up with ways to reduce cleanup. Now, a draft will be developed by DOE officials alone, and submitted
to DOE-HQ without first being reviewed by regulators or the public.
Regulators have cautioned DOE that the Tri-Party Agreement is the guiding
document for the Hanford cleanup and DOE cannot change that document
without the concurrence of EPA and the State of Washington. ·
Recent
contract awards seem to be focussed almost entirely on driving down
“estimated” costs and accelerating timelines -- regardless of whether
or not these new estimates are credible.
The General Accounting Office’s rejection of the recent River
Corridor contract award, and the subsequent admission of the Department
that they would have to re-open the bidding process, is one clear example
of this trend. In our view, this is designed to create the appearance of savings
in the near term -- savings which cannot be sustained in the long
term. Time
and time again, it is becoming clear that the Department has little
or no interest in stakeholder involvement and input to the process. In our view, this situation is untenable in
the long term. Without public
understanding of the cleanup system and advocacy of funding for the
Department’s effort, support for billions of dollars in appropriations
will eventually wane. As unattainable
milestones are adopted and missed, and unrealistically low cost estimates
are exceeded, Congress and the public will lose patience with the cleanup
program, and the cleanup program will suffer.
The result could be an environmental train wreck. These
are increasingly serious concerns, which we believe warrant immediate
action by Congress and the Administration. As
a result, we are requesting the following action: 1)
Congress
should request that the General Accounting Office conduct a thorough
review of the Department’s five most recent contract agreements, focussing
on whether the costs and milestones sought by the Department are actually
attainable. The report should be the basis for further
action by Congress. Congress
should, during public hearings, ask the Secretary of Energy to personally
assure that new contractual timelines and financial estimates are
credible in the long run, and not simply designed to produce false
claims of “savings” that will later come undone as reality sets in. 2)
Congress
should hold immediate hearings on the issue of regulator and stakeholder
involvement in the Environmental Management program, and should
require monthly updates from the Assistant Secretary for Environmental
Management on steps she is taking to repair the serious damage caused
over the past three years by the DOE’s recent actions. 3) Since as much as 2/3 of Hanford’s tank waste is now under consideration for treatment outside of the vitrification plant, it is essential that all credible alternatives be thoroughly studied and pursued. Congress should require that the DOE fully fund at least two detailed scientific studies into supplemental technologies at Hanford, appropriating the additional funding as necessary. 4)
Congress
should re-emphasize that the Department and the federal government are
fully committed to serious environmental remediation of nuclear sites,
including protection of groundwater resources. 5)
Congress
should require consultation and collaboration with states and public
as the Department reworks its Risk Based End States documents. We
have worked over the past decade to support the Department of Energy,
and to support legitimate efforts to make the cleanup program more efficient,
and responsive to public and regulatory needs.
We were at first encouraged by appointment of officials with
substantial experience in cleanup matters.
But those hopes have been seriously damaged as mistake after
mistake has been made over the past two years.
As a result, we write to you to ask for your immediate intervention
in this situation. Sincerely, Paige
Knight, President, Hanford Watch Shelley
Cimon Tim
Takaro, M.D. Elizabeth
Tabbott Jim
Trombold, M.D.,Washington Physicians for Social Responsibility Norma
Jean Germond |