The following interview with Stacy Charboneau, the new Manager of the Department of Energy’s Richland Operations Office at Hanford, was conducted last week by ExchangeMonitor Publications Editor-in-Chief Mike Nartker.
WC Monitor
2/6/2014
You’re coming on as the RL Manager as Hanford is reaching the end of what DOE has called its ‘2015 Vision’ for the site. So going forward, what do you see as the next focus for the Richland office beyond that vision?
That’s a great question. We had a lot of conversations here over the last year about that in understanding what is our next vision. And you know, RL not only did a great job of talking about the 2015 vision, but also delivering on the 2015 vision. So sometimes it’s a challenge to remind folks that we still have quite a bit of work left to do here at Hanford on the Richland side on the Central Plateau.
So as we’re moving forward, we really try to focus around four primary areas of interest for us here in the Richland Operations Office. The first thing is we have some still pretty high-risk nuclear projects remaining for the Richland Office. First and foremost, taking the Plutonium Finishing Plant to slab-on-grade, which we’re still working on. And our milestone to do that is September of 2016 and we’re working hard to meet that milestone.
The next nuclear risk that we have, of course, is the sludge along the river within the K West Basin. We’re working hard to get that sludge retrieved up off the river and up on the Central Plateau. So that’s the second of our high-risk nuclear work that we still have remaining for Richland before we move in to maybe our next phase. We still have the Waste Encapsulation and Storage Facility capsules—the cesium/strontium capsules. There’s over 1,900 capsules still in basin there in that facility. And with over a third of the curie content of the Hanford Site in a facility that’s aging, we have some concerns about getting that into a safer, dry storage.
And then we have some remaining work with regard to River Corridor like the waste site under the 324 facility which you’re very familiar with. That’s a high rad waste site that we’d like to be able to remediate as we move forward.
Another focus is our continued success in groundwater. You know, with bringing the 200 West Pump and Treat facility online in 2012 and continuing to expand not just capacity but the capabilities of that facility in conjunction with the five pump-and-treat facilities along the River Corridor, it’s just been a tremendous success story. We want to continue to be able to expand our capacity and capabilities to align with what we’re doing with regard to tank waste, what we’re doing with regard to some of our other Central Plateau Records of Decision to continue to treat the plumes that we’re treating. So we’re going to continue focusing on that as well.
The third area, of course, is just having a secure, safe posture for the Hanford Site knowing that the Richland Operations Office is responsible for safeguarding our special nuclear materials here, and also maintaining a good and safe base operations posture for maintaining the Hanford Site. And then that kind of leads into the third or the fourth piece which is making sure that we not just have maintained but also upgraded our infrastructure and our infrastructure projects to support the sustained mission of Central Plateau cleanup to include ORP’s mission as well. So we have quite a bit of work to do with regard to our water systems, electrical systems, our roads, our sewer systems, to support cleanup on the Central Plateau for the next several decades, whether that’s our continuing remediation of our canyon facilities, our waste sites, our TRU waste, or if it’s supporting WTP startup and low-activity waste, the evaporator facility and others. So that’s kind of our vision looking forward.
Correct me if I’m wrong, but it seems that in the near-term—the next few years—the vision for Richland will be finishing off those high-risk projects you mentioned and then moving into more of a maintenance mode and supporting ORP. Would it be fair to say that RL doesn’t plan on launching any new big cleanup projects, like addressing Hanford’s canyon facilities, in the near-term?
That’s an excellent point that you bring up, because that’s why we’ve tried to focus very much on this next five years. Because in the next five years I think it’s appropriate what you’ve just described. But then we’re going to have to look to where is Hanford at with regard to our prioritization of workscope across the EM complex and where is Hanford at in budget space so that we can bring WTP online which is certainly a high Hanford priority and something that I fully support. That is what we’re looking at—those decisions that need to be made in the 2018-2020 time frame and are we going to transition to our next set of D&D projects on the Central Plateau, and is it smart to do so in conjunction with taking WTP online.
When it comes to annual funding, RL and ORP have been roughly equal, though ORP has gotten a larger share. It sounds, though, that at least in the next five years the emphasis is going to shift heavily over to the ORP side. Is that an accurate way to look at it?
So I would just couch that a little bit differently. As we look at our compliance agreements, Hanford’s compliance agreements take us above $3 billion. And so part of this—and I’m hedging a little bit on answering where is RL going to be in five years—really will hinge on working with our regulators and stakeholders to understand what are Hanford priorities within the budget that we have and be able to understand where are we in five years as we complete PFP, sludge off the river, these other high profile projects.
You know, the budget perspective today for ’14 and ’15 it was roughly $1.2 billion for ORP, and $1 billion for RL. I think ’16 will look very similar to that. We still need to have sustained budgets to finish off some of those high-risk projects. But when we get to, quite frankly, a 2020 time frame, the Hanford budget’s going to need to go up. Even if we did a slow shift in priorities to just bring in WTP online, it’s going to be a heavy lift.
As you head toward that time period, is the option of going back to one site office of all of Hanford back on the table? Or do you think that at that point there’ll still be an advantage to have an RL office and an ORP office?
There’s pros and cons of both. So the pros of having two offices is we have talked about our next set of contracts and what would those next contracts look like. And we have a significant D&D and remediation workscope to go. And so I think that we certainly will need to continue making some progress along those lines and RL is the office to do that as ORP is focused on the tank waste mission.
Even if you look at just ORP scope today, they’re getting into TPA milestones for tank closure which really comes back to soil and groundwater and landfill closure. So who are the expert contracts and who is the expert office on soil, groundwater, and landfill closure? That comes back to RL. So there’s going to be a lot of strategy around our next set of contracts and what those would look like, and I could envision a remediation contract and an operation contract that would still make sense to have those two offices.
Now, if we’re in a position where we have a landlord function and we’re primarily focused on tank waste, does it make sense to have one office? I will tell you that it certainly makes sense to start to look at the functions that we have in common between the two offices and looking to see if it makes sense to have organizations within our offices that are more focused on serving both offices like we do today with regard to legal, finance, and budget. We have an HR organization supporting both offices today. So it might make sense. You know, one thing our two ES&H organizations are looking at is are there functions that we should be doing more similarly and more together that makes sense for the Hanford Site given we have Hanford Site-wide safety programs, Hanford Site-wide safety procedures and processes. So we continue to look for those efficiencies.
And at some point does it make sense to go back to one office? Maybe. I think that’s for folks to understand as we continue to move towards the start of the tank waste mission.
You mentioned future contracting plans at Hanford. Looking at the success DOE has had with the River Corridor closure project and its use of a cost-plus-incentive-fee contract to do a wide variety of work at the site, is DOE considering using that type of approach again for future decommissioning needs? Is DOE considering taking that approach and saying, ‘Okay, we’re going to break this part of the site up into an x closure project and go the same way because of the success we have with River Corridor?’
I would say what DOE is looking at most closely right now is kind of a portfolio of contract types. So I know you’ve heard the last couple of years emphasis on small business-direct-to-DOE-type contracts and we should be doing more fixed-price contracts. And certainly we’ve had tremendous success, like you’ve talked about, with our cost-plus-incentive-fee contracts. And then you still have folks who say, this work is really a level of effort and should be under an M&O type contract.
What I think that we’ll see in our acquisition planning and strategy, particularly for a site as big as Hanford, when you have not just River Corridor but Mission Support Alliance, the tank operations contract, and CH2M Hill Plateau Remediation Co. all coming to a close nearly the same time that you’re going to see us look to what is the portfolio of contract types that we would want to break out to be most effective in managing this work.
And so I know I would be a proponent of cost-plus-incentive-fee again because, as you said, they have served the Department very well. But you need to have enough definition around that kind of work, like soil remediation, for that to be successful.
At the Idaho site, DOE is moving to break up the two current cleanup contacts there from two to four. Do you think that for the next stage at Hanford DOE could look to break up work even more and increase the number of contracts at the site?
Eventually, I think you will see large primes with a combination of smaller fixed-price or small business direct type contract. ATL is an example of managing the 222-S Laboratory as a small business contract. As much as we have opportunities to do those kinds of contracts, I think we will take advantage of that as that makes sense.
For the River Corridor project, what is expected to be left to be completed post-2015, and what will be DOE’s plan for performing that work?
What’s left after 2015 is the 618-10 VPUs and that waste site under the 324 Building, and the 324 Building demolition itself. Obviously we still need to make some decisions on 618-11 that’s currently in the River Corridor contract as well. Although Energy Northwest has asked for us to reconsider our TPA milestone and end date for that project consistent with them operating a nuclear facility right there next to our waste sites.
But as we look at that workscope, we have to continue to evaluate as that workscope is finished and that workscope diminishes, does it make sense to continue on with a full prime contract and all the overhead and infrastructure that requires? Does it make sense to start to transition some of that work? And those are some of the things that we’re looking at. I think we feel pretty good, like you said, about the work WCH [Washington Closure Hanford] has done. And those are two heavy-hitter projects left to go, so I’d like to see us continue with that success without disruption.
Just to clarify, does that mean DOE is considering potentially a separate contract to handle one or both of those remaining projects?
I don’t know if you’re aware, but we actually have placeholders in the PRC contract today for performing some of that work. And it really depended upon where did we land with WCH and when did it make sense for that contract to end. So, for example, 618-11 is currently in the PRC contract. It’s just not turned on. So we wouldn’t have to go out and recompete the work per se if we chose to go a different route.
But like I said and you said, WCH has performed fantastically, and for them to continue the good work that they’ve done is certainly what I would like to see happen.
Can you provide an update on DOE’s plan for addressing the spill under Building 324 and for bringing that building down?
Sure. So in December we reviewed the 60 percent design of the remediation of that waste site under the B-Cell of 324. We anticipate 90 percent design to come in in March of this year. We’re in the middle of building a mockup facility so we can do all the testing of the methodology for remediation of that waste site to include what does the B-Cell look like and what does the air lock out of the B-Cell look like The plan is to remove those contaminated soils and put them in a couple of the other hot cells within the 324 facility and grout those—that’s kind of the current thinking. So the design will be done this fiscal year and the mock-ups will be done this fiscal year. And hopefully we’ll feel good about what that methodology is and be able to proceed.
What’s the anticipated time frame for demolishing the 324 Building?
We had asked WCH to look at what’s ‘cheap to keep’ for that facility. Because as we’ve looked at demolishing that large nuclear facility next to the operating 325 facility that the PNNL still operates just right next door, our thought is when we go in to demolish the 325 facility at some point in the future when PNNL is done with it, it might make more sense to do both facilities at the same time. So instead what we’re looking at is how can we best deactivate the 324 facility to put it in a ‘cheap to keep’ state until we’re ready to take both those large facilities down.
At PFP, is DOE going to be able to meet the TPA milestone for having that building down slab-on-grade in the fall of 2016?
They may be. The contractor’s estimate to complete now is November of 2016. Our TPA milestone is September 30th of 2016. So we’re working very closely with PRC on, like I talked about, some of the demolition sequencing and what we can do with the workforce so that everybody feels good about the work they’re doing there and where they’re going to land when that project’s done so people can stay focused on the job, as well as working on how we’re going to deactivate our safety equipment like ventilation systems, criticality systems, all of that and transition and maintain configuration control to get better confidence on the September 30, 2016, date.
I will tell you, though, honestly—our goal is September of 2016—if that facility is slab-on-grade by December of 2016, I’m having cake and ice cream. I don’t know about you but that will be a huge, huge accomplishment for the Hanford Site.
And you don’t think the work will go beyond 2016?
Right now we’re not projecting that it will, but you know, a big, big project of this size, one major hiccup, and it’s a whole new schedule, right? We were on track to finish by 2016, and hopefully we’ll continue on that trajectory.
At the end of last year, DOE raised concerns over CHPRC’s work at the PFP project, and DOE has asked the contractor to provide a corrective action plan to make improvements. How would you gauge how CHPRC is performing?
I’m going to address that in twofold. I think what you’re referring to is the IG report specific to the cost and schedule performance. So I think you will remember that I was the PFP federal project director in 2003, and at that time—that was before PRC’s day—we put together a pretty comprehensive government estimate of cost and schedule for taking PFP to slab-on-grade.
And then PRC came in in 2008 with different assumptions and an aggressive philosophy on how they would take that facility to slab-on-grade. A big piece of that was their assumptions on how many of those gloveboxes would go out as TRU and how many of those gloveboxes would go out as low-level waste, which can really drive cost and schedule with the 213 gloveboxes at that facility. At that time we thought fantastic. If PRC can deliver on their contract bid, that would be awesome. You know, I think at that time they were looking at a 2013 [completion] and $500-some odd million.
What I will tell you is some of us have been around the block a while. And so we maintained our government estimates, which was originally 2019 and $1.5 billion. But you know, we maintained our estimate which was half those gloveboxes were going out as TRU and half of those gloveboxes were going out as low-level waste instead of a more optimistic more were going to go out as low-level waste. And here we stand today and it’s about half TRU and half low-level waste. So what’s happening is PRC is realizing what a lot of the government folks knew. The good news is with ARRA dollars we were actually able to drive down our cost estimate and schedule down to, I think we’re sitting at, like, $1.1 or $1.2 billion for that project and we’re still going to come in under our independent government estimate and we’re still going to be done before our independent government schedule.
So even though PRC didn’t necessarily deliver on their original contract proposal, their performance has been pretty much in line with what the government’s expectations were with how this project would go. So some significant criticism, I guess, on the increased cost and schedule, but the truth is that our project has gone about how the government expected it to go and PRC’s gotten a lot of flak on that.
But just to transition a little bit, we did have concerns in the last couple of years with work planning and control and conduct of operations. And I’ll be the first to tell you since I’ve been back at RL now I think 15 months, our ES&H oversight are turning conduct of operations at PFP to a green from a yellow. So you know, we think that they’re performing very well in conduct of opps. We just had a HSS assessment out here in December that looked at work planning and control and we got really good feedback specific to work planning and control at PFP. So you know, if we keep our heads in the game here, I think this is doable.
With the K Basins sludge project, DOE is currently facing fines from the Environmental Protection Agency of $10,000 per week for delays in beginning the removal of the sludge. What is the status of that project, and when does DOE expects to have that material up at the T Plant?
So the status is we’ve continued on with the funding that we received on that project and the construction of the annex facilities. The equipment procurement is going on. We’ll be installing equipment in both K West Basin as well as the annex. We’re on track with where we thought the project would be given the funding that we received. What was uncertain at the time when we submitted that TPA change package September of last year was how secure was our funding looking forward.
The good news is I was just back in D.C. last week and we have assurances that sludge is a priority for us and that we should have the funding to be able to continue with that project. And so that’s our plan. Right now we are projecting 2018 for start of retrieval of sludge. We have yet to negotiate on those milestones with the EPA, but we’ve shared where we’re at with our local EPA folks and hopefully they’ll work with us on revising those milestones.
How long it is anticipated to take to have the sludge removed and transferred?
Less than a year.
Does DOE plan to contest the fine being levied by EPA in any way? If the retrieval isn’t expected to begin until at least 2018, that’s going to be a pretty hefty fine at $10,000 per week.
At the end of the day generally these disputes end with some type of a settlement. I think what EPA is looking for most, and that they have shared with us, is we just need the dates. So we then need to negotiate on those dates and I think they’ll give us some relief on the stipulated penalty.
More broadly in terms of DOE’s relationship with regulators, on the tank farms side of Hanford there has been legal action, and the threat of legal action, by Washington state. Is that impacting RL’s relationship with Washington state regulators?
I would say that our relationships are still good with our regulators. I will say it’s impacting the complex as a whole in that nobody wants to be in a situation where you’re litigating your milestones. And so hopefully that doesn’t set a precedent for how we’re going to manage many of the milestone negotiations that we’re going to need to do, not just at Hanford, but across the complex. Because I think we all recognize where we’re at in our funding as a nation and where we’re at with regard to the priorities in the EM complex. Hopefully we can get aligned with our regulators—both the state and the EPA—for what the best path forward is prioritizing the work that we have to do.
To wrap things up, what do you see as the number one thing you and DOE can do at Hanford, at least on the RL side, to help reduce the to-go cost for completing the work?
Oh, that’s a good question. I think probably the best thing that we could do—and I don’t know if this would be the one thing to do for reducing the to-go cost—but it sure would be good if we had one set of cleanup standards. It’s very difficult to manage decades’ worth of waste retrieval, waste storage and waste remediation in a RCRA framework vice a CERCLA framework.
You know, CERCLA was written to do environmental remediation and cleanup. And those regulations fit our situation so much better than trying to instill RCRA requirements around projects that really aren’t current operations, that really aren’t something that we can address within a six-month or a 12-month time frame. So trying to customize RCRA requirements to the Hanford situation is difficult and sometimes takes away from the true intent of what we need to do here from a cleanup posture.
If we could get to a point to understand what we need to do here and CERCLA is the right framework to do that, I think that would alleviate a lot of the pressure that our RCRA regulators feel to hold this to those standards.
Do you think you could get regulators to support such a move?
It really would be EPA’s call and then how much they then delegate it to the state. The state obviously is trying to do the right thing in holding us to the appropriate RCRA standards. And they’re trying to do the right thing for their stakeholders and the public and holding us to the standards that really it goes back to some fundamental discussions between EPA and the Department of Energy about how we’re addressing environment and remediation at these large defense complex sites and is RCRA an appropriate stature to apply to our cleanups.
