PNNL to Pay $200,000 to Settle DOE Concerns Over Beryllium Program
WC Monitor
11/14/2014
Pacific Northwest National Laboratory has agreed to pay $200,000 as part of a settlement reached late last month with the Department of Energy to resolve concerns over the lab’s beryllium protection program. DOE opened a safety investigation at the lab this summer after PNNL voluntarily reported noncompliances related to its Chronic Beryllium Disease Prevention Program. “Battelle reported to DOE noncompliances with 10 C.F.R. Part 850, Chronic Beryllium Disease Prevention Program, requirements, including baseline inventory, hazard assessment, permissible exposure limits, housekeeping, release criteria, medical surveillance, and performance feedback,” DOE Office of Enforcement Director Steven Simonson wrote in a Oct. 24 letter to PNNL Director Michael Kluse that DOE released late this week.
Simonson went on to write, “After these conditions were discovered, Battelle immediately recognized their significance and performed comprehensive evaluations to determine the nature and extent of the causes as well as their impact on PNNL worker safety and health. Battelle implemented compensatory measures to prevent potential worker exposures to beryllium in contaminated areas, and has subsequently initiated corrective actions that fully address the regulatory noncompliances and CBDPP implementation weaknesses.” Explaining DOE’s decision to resolve the investigation through a consent order, Simonson wrote, “The decision to enter into a Consent Order is based upon Battelle’s thorough and self-critical evaluation of the noncompliances, prompt and accurate reporting to DOE of all noncompliances associated with the conditions, and comprehensive corrective actions to address the CBDPP deficiencies that will prevent recurrence.”
In a written response late this week, PNNL spokeswoman Susan Bauer said, “Regarding the Consent Order, we’d like to say that DOE’s and Battelle’s goals are one and the same — to assure and improve worker safety and health. As indicated by the consent order, DOE has confidence in our ability to self-resolve the deficiencies within PNNL’s beryllium program. We took action as soon as we identified the issues and have continued to implement changes and improvements which both our staff and DOE can feel confident about.”
CRESP Study Comes Under Criticism
WC Monitor
11/14/2014
A $4 million study evaluating risk at Hanford is a waste of money that would have otherwise been used for cleanup by the Department of Energy’s Richland Operations Office, according to several members of the Hanford Advisory Board. The board agreed at its November meeting to send a letter to Mark Whitney, acting assistant secretary for DOE environmental management, criticizing the study being started by the Consortium for Risk Evaluation with Stakeholder Participation (CRESP). The advisory board had been asked to provide input on the methodology of the study. CRESP defended its project after the meeting, with principal investigator David Kosson saying that critics either misrepresented or misunderstood the study plans.
DOE commissioned the study from the independent, multi-university group to identify and characterize potential risks at Hanford to help guide the efficient use of federal money on environmental cleanup, according to a January memo from David Klaus, the DOE deputy undersecretary for management and performance. CRESP plans to identify and rate current and future risks to the public, workers and the environment to help DOE Headquarters officials make decisions about the sequence of cleanup activities at Hanford.
Panel Concerned Study May Be Used to Reduce Commitments
But the advisory board said in the letter to Whitney that the federal agency may use the study to try to reduce cleanup commitments. “It is looking for risk-based reasons not to clean up,” said Barbara Harper, who represents the Confederated Tribes of the Umatillas on the advisory board. The Umatillas and Yakamas also sent separate letters of concern. “I cannot imagine anything beneficial to Hanford cleanup coming out of this process,” said Ken Niles, who represents the state of Oregon on the advisory board. It is unclear what decisions the study would support, the board said in the letter. Decisions now are based on federal and state environmental laws that are predicated on risk reduction, the board said. But the CRESP study methodology does not address those legal requirements or the compensation the laws say must be paid for hazardous substances that remain after cleanup is completed.
The CRESP risk evaluation appears to be systematic and consistent, but it “is actually subjective and qualitative,” said the advisory board’s letter. The board criticized some of the assumptions being used as illogical or controversial. The evaluation confuses “risk” with hazards and impacts, the letter said. That could lead to an assumption that Hanford facilities such as the Plutonium Finishing Plant or sludge held underwater at the K West Basin near the Columbia River are very low risk because the public is not exposed to them now and worker exposure to radiation is closely monitored, the advisory board said. The advisory board also criticized the study’s reliance on Hanford’s current land use plan as the rationale for assuring there is little potential for long-term public access and exposure, the letter said. But if cleanup is not completed to standards for residential use or the uses granted tribes by treaty, then those future land use options are precluded. “This is unfair to future generations and creates liabilities for DOE,” the letter said.
CRESP to Look at Industrial and Unrestricted Future Uses
DOE instructed CRESP to place Hanford environmental and nuclear safety hazards and risks in context with currently designated future uses of Hanford land, according to the January memo from Klaus. But CRESP will look at both industrial use of the land, which would require less cleanup, and unrestricted use of the land, Kosson said. CRESP calls its study methodology “scientifically sound.” There are unknowns about Hanford cleanup, but the study would use the best information available from multiple sources to make comparisons and show tradeoffs of different cleanup options, Kosson said. “We are trying very hard with a broad range of technical expertise to do the right thing” for people living near Hanford and the people nationwide, Kosson said. The study will consider not only what contaminants now pollute Hanford but also a range of cleanup options for them, some more disruptive than others. For instance, treating contamination in the ground could be less disruptive that digging it up, Kosson said. “CRESP recognizes that it is frequently asked to take on work on controversial topics that are the subject of intense debate,” Kosson said. It uses expert peer review to ensure high quality of its work.
Oregon Concerned Over Study Methodology
The state of Oregon sent its own letter of concern to CRESP a month ago, saying that Hanford staff already are intimately familiar with the data the study will use, making it unlikely that significant new information will be produced about risks or the relative significance of risks associated with Hanford contaminants and cleanup. Oregon also is concerned that the study methodology appears to assume that planned cleanup methods, such as placing caps over waste or using chemicals to bind contaminants in the ground, will work as planned. The $4 million spent on the report would have been better spent on getting radioactive sludge retrieved on time from Hanford’s K West Basin near the Columbia River, said Susan Leckband, vice chairwoman of the advisory board. The Environmental Protection Agency is fining DOE $10,000 a week for failing to start to retrieving the sludge in September.
CRESP maintains that a sitewide review of the risks at Hanford is needed as cleanup has proved more costly and more technically challenging that when cleanup began in 1989. The study can help guide decisions on the anticipated $100 billion of cleanup work projected over the next 50 years, rather than officials relying on preconceived notions of what should be done. CRESP will use input on the study to make changes to the proposed methodology and to make information clearer, as obviously there has been misinterpretation of it, Kosson said. CRESP had not received a copy of the advisory board letter when Kosson commented.
Advisory Panel Supports DOE Waste Treatment Waiver Request to EPA
WC Monitor
11/14/2014
The Hanford Advisory Board called for common sense in applying rules for disposing of unwieldy pieces of contaminated equipment at its November meeting. The Environmental Protection Agency’s rules prohibit waste from being placed in landfills before it is treated, but that prevents the safest way of treating some Hanford equipment contaminated with radioactive materials, according to the board. The items include rebar and piping that can be 50-feet long, plus other long, extra heavy or irregularly shaped items that cannot be placed in standard waste boxes. The items include contaminated equipment used at Hanford’s underground waste tanks. The Department of Energy has asked EPA national officials to approve a rare waiver of Superfund Land Disposal Restrictions, and the advisory board added its support to the waiver in a letter of advice to EPA.
Now the equipment is wrapped up, shipped and then unloaded near the Environmental Restoration Disposal Facility in central Hanford. The waste is treated there by applying a coat of polyurethane that workers spray on it. The equipment is turned and manipulated by a crane so workers can spray all of it by hand and then a crane is used to pick it up and place it in the landfill. Instead, Hanford officials would like to build a platform in the landfill where the equipment will be placed permanently and then pour grout around it. That would allow cumbersome equipment to be moved fewer times and eliminate the need for workers to get close enough to spray it. The risk of an industrial accident and the potential for an airborne release of radioactive material would be reduced and workers would spend less time in close proximity to radiological materials, the board said. There would be no need to pick up the waste once it is encased in heavy grout because it would already be in its final disposal place within the landfill.
That method had been used before at Hanford until questions were raised about whether it violated Superfund regulations. The Superfund law allows regulations to be waived if an alternative method can be shown to be safer or more environmentally protective, but the decision cannot be made by local EPA officials who support encasing waste in grout as the best method of treatment. The advisory board said it supported the practice of grouting waste after it is placed in the landfill, but the waiver should be limited to certain wastes and not last indefinitely. The waiver should not be used as a precedent for avoiding the use of facilities that are regulated for treating waste, the board said. DOE and EPA should continue to review treatment options for long term use that could better protect workers and the environment, it said in the letter of advice.