Public comment period on proposed TPA changes starts today - NBC Right Now/KNDO/KNDU Tri-Cities, Yakima, WA |

Public comment period on proposed TPA changes starts today

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The following is a message from the Hanford Tri-Party Agreement Agencies:

The U.S. Department of Energy Office of River Protection (DOE-ORP), Washington Department of Ecology (Ecology), and U.S. Environmental Protection Agency – the Tri-Party Agreement (TPA) agencies – are holding a public comment period on proposed changes to the TPA. The proposed changes set new dates for DOE-ORP to submit to Ecology plans and schedules for closure activities in Hanford’s single-shell C Tank Farm as outlined in the M-045 milestone series. Specifically, the affected milestones include M-045-82, M-045-83 and M-045-62; as well as a new proposed milestone, M-045-82A.

The public comment period runs from January 30th through March 17th, 2017.

The complete TPA change package documenting the proposed changes is available at http://pdw.hanford.gov/arpir/index.cfm/viewDoc?accession=0073639H. Copies are also available for review at the Hanford Administrative Record Public Information Repository located at 2440 Stevens Drive, Richland, WA, and at other Hanford Public Information Repositories located throughout the Northwest. 

A summary of the proposed changes: The proposed changes shown below relate to milestones that guide closure activities and set requirements for the first closure of a Hanford single-shell tank (SST) Waste Management Area (WMA), WMA-C. The individual milestones involved include M-045-82, M-045-83 and M-045-62, as well as a new proposed milestone, M-045-82A.

What is a TPA Milestone?
A TPA milestone is a legal agreement between DOE, Ecology and EPA that identifies cleanup actions and schedules.

How do milestones affect work at Hanford?
Milestones set the pace for completing cleanup work. They also set priorities for which work is completed first.

Why are the TPA agencies proposing changing milestones?
The agencies change milestones when new work is identified, the scope or amount of work in an existing milestone is changed, or to reset a milestone that has been or will be missed.

What is the Basis for Proposing these Changes?

M-045-82: In September 2015, DOE-ORP submitted to Ecology a Tier 1 closure plan for all 149 SSTs, but did not submit the Tier 2 and Tier 3 closure plans as required by this milestone. This change resets the date for submitting those Tier 2 and 3 plans.

M-045-82A: The TPA agencies are proposing to phase submittal of Tier 3 closure plans for the 16 tanks in WMA-C over time, so that they can apply lessons learned from preparing the first four closure plans (for the small C-200 tanks) to the other 12 closure plans (for the larger C-100 tanks). The agencies created a new milestone to set a date for a Tier 3 closure plan for those first four tanks.

M-045-62 and M-045-83: Schedules for closure activities are normally included in closure plans. Those schedules become enforceable once the closure plans are added to a permit.

If closure schedules were included in both the TPA and in closure plans within the permit, those schedules could be duplicative or could conflict (have different dates for the same activity). To avoid duplication or conflict, the due dates in the existing M-045-62 and M-045-83 milestones have been adjusted to reference the closure plan schedules.

How Will This Affect Work in the Tank Farms?

This proposed change establishes an incremental approach to tank closure that:

1. Allows lessons learned from one closure to be applied to the planning of the next closure.

2. Demonstrates progress toward WMA-C closure in a way that promotes momentum for remaining closures in WMA-C.

The C-200 tanks were selected as the first single-shell tanks to be closed based on:

1. Ease of access (the tanks are located at
the farm edge, and access from outside the farm would be possible for closure activities).

2. The tanks are prime candidates for the first demonstration of the closure approach.

3. Fewer obstructions and less equipment would be required to be located within the farm than other tanks.
The closure of additional components within WMA-C would follow as additional closure decisions are made, lessons learned are incorporated and closure designs are developed.

Please submit comments via email (preferred) or mail by March 17, 2017 to:

Dieter Bohrmann

U.S. Department of Energy

Office of River Protection

PO Box 450, MS H6-60

Richland, WA 99352

Email: TPA@RL.gov

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