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. From the onset, this included ratings of the risks and impacts to people and protected resources (i.e. groundwater and the Columbia River, ecological resources, and cultural resources) during the current time period and also during active cleanup and after cleanup has been completed. An overall rating was not provided for cultural resources. Instead, information about cultural resources was gathered, described, and analyzed as a planning guide for future cleanup activities.

What will happen with the results of the Risk Review Project?

From the Project’s onset, the results were intended to provide the DOE, regulators, tribal nations, stakeholders and the public with a more comprehensive understanding of the remaining cleanup at the Hanford Site to help inform (1) decisions on the order and timing of future cleanup activities, and (2) selection, planning and execution of specific cleanup actions, including which areas 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 was never intended to make or replace any regulatory decision under CERCLA, RCRA and/or other, applicable laws, regulations, and legal requirements. Further, the reports prepared for the Risk Review Project, including the final report, are 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 was 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 execution and results of the Risk Review Project were never 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 or amendments to any of these documents.

What is the relationship between the Risk Review Project and treaties with Native American Tribes?

The execution and results of the Risk Review Project were never intended to interpret or otherwise affect any treaty entered into between the United States and a Native American Tribe.

Who conducted the Risk Review Project?

The Risk Review Project was 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 Virginia. 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 was 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) provided advice on the development and execution of the Project. There also have been opportunities at key points (e.g., development of Methodology, Interim Progress Report) during the Risk Review Project for input from individuals, organizations, agencies, elected officials and tribal nations. DOE conducted technical and Official Use Only reviews of drafts of the Methodology document, Interim Progress Report, and Final Report. Outside experts also reviewed and provided input on drafts of the Methodology document, Interim Progress Report, and Final Report.

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.

Why was the review conducted?

There are several reasons. First, completing cleanup has proven to be a much lengthier, more complex, more technically challenging and more expensive undertaking than had been envisioned in 1989 when Hanford’s mission shifted from production of weapons material to waste management and cleanup. The remaining cleanup program at Hanford Site is anticipated to take at least another 40 years to complete and cost more than $100 billion. Thus, cleanup 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, are taking much longer and proving to be much more difficult to achieve than originally anticipated. This means the assessment of current and future risks associated with these long term cleanup activities were in need of updating based on strategies already implemented or being implemented and those anticipated to be implemented in the future.

Third, the very nature, order, and timing 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, DOE’s regulatory agencies, organizations, and tribal nations haven’t always agreed on the challenges posed by ongoing or future cleanup 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. The results of this Risk Review Project should provide DOE, its regulators, tribal nations, and the public interested in or affected by Site decisions with additional analytical tools to help inform decisions on (a) the order and timing of future cleanup activities, and (b) the selection, planning and execution of specific cleanup actions, including which areas at the Hanford Site should be addressed earlier.

Was the entire site evaluated?

The focus of the review was the identified remaining waste, facilities, structures and environmental contamination components of the Hanford Site as of October 1, 2015. The Risk Review Project did not evaluate past cleanup actions or resources on uncontaminated areas of the Site. Remaining cleanup sites as of October 1, 2015 were divided into 64 units for evaluation purposes called evaluation units (EUs). These EUs included 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 basis for reviewing the wide range of cleanup challenges at the Hanford Site. Categories of facilities, wastes and existing environmental contamination within each EU were based primarily on geographic location. This was because the potential to impact human health and resources (collectively called receptors) is fundamentally based on geographic location and spatial relations that may lead to exposure of a receptor or receptors to hazards from specific sources. Thus, EU categories were not based on, and did 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). Certain EUs contained one or multiple sources of waste or contamination.

Once the evaluation units were selected and information on each unit was gathered, CRESP developed a summary level catalog of risks to people and protected resources (groundwater and the Columbia River and ecological resources) during the current time period and also during active cleanup and after cleanup has been completed. An overall rating was not provided for cultural resources. Instead, information about cultural resources was gathered, described, and analyzed as a planning guide for future cleanup activities. Separate and distinct methodologies were developed to assess risks and impacts to people, groundwater, and ecological and cultural resources. Each methodology describes how the risks and impacts are to be rated based on the likelihood of an event occurring that triggers a release of a contaminant that in turn threatens people and/or resources. Triggering or initiating events considered include: fire, accidents, volcanic eruptions, and loss of power and/or cooling water. Each of the methodologies also discusses how risks and impacts at the areas remaining to be being cleaned up, called evaluation units, were to be evaluated over time from both ongoing and future cleanup work. These time periods include: current, during active cleanup (until 2064), and two post-cleanup periods.

What was the process or approach CRESP used to evaluate risk?

At the onset of the project, CRESP, in dialogue with senior officials from the DOE and its regulatory agencies (i.e. Environmental Protection Agency and Washington State Departments of Ecology and Health), divided the risk review project into three parts.

The first was the development of scientifically sound approaches that offered a range of effects (from not discernible to very high) on people (including both the public and workers) and protected resources (groundwater, the Columbia River, ecological, and cultural) from exposure to contaminants in the areas remaining to be cleaned up. These areas range from buried solid waste sites to contaminated groundwater plumes. Separate and distinct methodologies were developed to assess risks and impacts to people, groundwater, and ecological and cultural resources. Each methodology describes how the risks and impacts are to be rated based on the likelihood of an event occurring that triggers a release of a contaminant that in turn threatens people and/or resources. Triggering or initiating events considered include: fire, accidents, volcanic eruptions, and loss of power and/or cooling water. Each of the methodologies also discusses how risks and impacts at the areas remaining to be being cleaned up, called evaluation units, were to be evaluated over time from both ongoing and future cleanup work. These time periods include: current, during active cleanup (until 2064), and two post-cleanup periods.

The project’s second part consisted of the development of an interim report, which contains the evaluations and ratings of 25 of the 64 evaluation units using the methodologies developed for rating risks from contamination on people, groundwater and the Columbia River, and ecological and cultural resources. To conduct the evaluations and make the ratings, publically available information was gathered and analyzed on each unit.

The third part of the risk review project was the development of the final report, which contains the evaluations of all the units including those not analyzed for the interim report, results, and observations. Appendices to the report contain the completed evaluation templates and underlying documentation supporting ecological and cultural resources.
Both the methodology and interim report documents were reviewed by a group of experts as well as by the DOE and its regulators. The public and stakeholders also were given the opportunity to provide written comments. Comments made on the methodology informed the interim report. Input received from the public, DOE and its regulated agencies, and stakeholders on the interim report aided the development of this report. Finally, the final report has undergone technical reviews by the DOE, DOE regulatory agencies and outside experts.

What other agencies were involved with the Risk Review Project?

CRESP led the Risk Review Project in dialogue with 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 of Washington Departments of Ecology and Health. The Core Team provided advice on the development and execution of the Risk Review Project, which included technical reviews of the methodology and interim progress report. Pacific Northwest National Laboratory provided research, analytical, and other assistance to CRESP as directed.

How was the public kept informed?

Throughout the execution of the Risk Review Project, it has been important that members of the public interested in the Project be kept informed and also be given the opportunity to provide information and/or comments.

In addition to briefings and other informational meetings, there have been two key points when written input was specifically sought from stakeholders, interested members of the public, tribal nations, and governmental entities. The key points include: (1) on the draft methodology developed to execute the project (Sept. 4 to Oct. 3, 2014) and(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). The final report provides the results of all evaluations, including the remaining evaluations, final observations, and recommendations. DOE completed a technical and Official Use Only review of the draft final report. Outside experts also reviewed the draft final report and submitted comments. Comments received from DOE and outside experts were considered and informed the final report published August 31 2018.

How has input from the public been considered?

Every written comment received on the draft methodology and interim report was acknowledged, reviewed and considered. Specifically, comments received on the methodology and interim report informed the final report.

How have the results of the Risk Review Project been made public?

The three major products of the Risk Review Project are considered public documents. They are the methodology, interim progress report and final report. The draft final report contains the final results of all evaluations conducted as well as observations that were made during the execution of the Risk Review Project.

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 to the DOE, Washington State Departments of Ecology and Health, and EPA on August 31, 2015. The interim progress report was submitted to the DOE, State of Washington, and EPA on August 31, 2015 and is considered a public document. Written comments received on the interim progress report during the comment period – September 1 through October 30, 2015 – helped to inform the draft final report prepared on the Project. The draft final report is undergoing final review at DOE.

The final report of the Risk Review Project published on August 31 2018 is considered a public document.

What will happen with the final report of the Risk Review Project?

The final report is considered 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. The final report also is expected to be of value to tribal nations and other interested organizations and the public.