Proposed amendments to Tri-Party Agreement and Consent Decree

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Comment From: Diana Gordon

9/07/24 @ 6:08 PM

HOLISTIC AGREEMENT ON CLEANUP OF HANFORD TANK WASTE Comments due 9/1/24

This agreement is very confusing for the layman and there seem to several changes to understandings I have had over the years. However, we live in a downstream community and...↓

I had thought that the High Level Waste was on a much faster track to vitrification than it apparently is. Now I learn that it will first have to be separated from the Low Level Waste and then vitrified in a plant that is not yet completed. Construction of the High Level Vitrification Plant has been paused due to cost and safety concerns. Construction is now scheduled to resume with the adoption of this Agreement and I feel it is vital to do all we can to accelerate the completion of this plant and get it into use at least by the current deadline of 2033.

Completion of this plant has been paused before and that absolutely should not happen again no matter the cost. We cannot afford to miss this 2033 target. But what if an unforeseen accident or earthquake or new safety issue, etc., comes along and they decide to halt it again. Other decisions, like the one setting new deadlines for extracting and treating the rest of the waste, hinge on the completion of that plant. Now what?Are we just going to push it off into the future with escalating costs and an accepted continuation of leaking tanks? This should never be an option. How about telling us what will happen in that scenario?

Another option that should also never be on the table is the one that the Trump Administration floated of simply re-classifying the waste into something less dangerous-sounding than High Level Nuclear Waste. Although the Agreement bans this kind of re-classification, I am not sure a future administration or cost-cutting schemer couldn’t figure out how to get it done. This definition should be bomb-proof. Period.

I have a few other concerns as well, but I want to get this on its way to you. This Agreement does not bolster my confidence that the folks up at Hanford are moving Heaven and Earth to get things moving quickly. Future generations are going to have enough trouble dealing with aging vitrified glass and grout. Let’s at least get the waste to that stage.

Diana Gordon↓

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Comment From: Columbia Riverkeeper members

9/03/24 @ 12:00 PM

The U.S. government must act to protect the River . from highly radioactive and toxic pollution at the i Hanford Nuclear Site. This includes honoring the • commitments made in Treaties with Tribal Nations • at Hanford, and recognizing that the nuclea...↓

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Comment From: Energy Communities Alliance (Faith Sanchez)

9/03/24 @ 11:22 AM

RE: Energy Communities Alliance Comments on Proposed Changes to the Tri-Party Agreement and Consent Decree on Hanford Site Tank Waste Dear Daina McFadden, Energy Communities Alliance (ECA) 1 is concerned about the ‘forbearance’ of the high-level wast...↓e (HLW) interpretation when disposing of treated waste or closing tank systems at Hanford’s Waste Treatment and Immobilization Plant (WTP). ECA calls on DOE to do an independent analysis to evaluate the impacts of delaying implementation of the HLW interpretation and implementation of this new regulatory scheme and consider its adoption based on the results of that evaluation. DOE’s own web page 2 states: On December 15, 2021, DOE signed the FRN affirming its interpretation of the statutory term “high-level radioactive waste.” The HLW interpretation is consistent with the law, the best available science and data, and the recommendations of the Blue Ribbon Commission on America’s Nuclear Future. In developing the interpretation, the views of members of the public and the scientific community were considered. DOE lists the benefits of using the HLW interpretation as: The HLW interpretation, if implemented through subsequent actions, could provide a range of benefits to both DOE and the public, including: • Reducing the length of time that radioactive waste is stored on-site at DOE facilities, increasing safety for workers, the public, and the environment. • Removing reprocessing waste from the States where it has been stored for decades and providing for the disposal of these wastes in facilities constructed and regulated for such purposes. • Enhancing safety at DOE sites by using lower-complexity waste treatment and immobilization approaches. • Aligning the U.S. with international guidelines for management and disposal of radioactive waste based on radiological risk. • Utilizing mature and available commercial facilities and capabilities to shorten mission completion schedules and reduce taxpayer financial liability. We believe what DOE has stated above to be true. We are concerned that further delay in implementing the HLW interpretation at Hanford has a cost and potential impact to the health and safety of the community. We understand that the State has been against the use, but the local community has supported the use – as they are the impacted communities. DOE should proceed with application of the HLW interpretation based on the independent analysis and reports of GAO, National Academies of Science and the Blue Ribbon Commission, the pilot Hanford project (Test-Bed Initiative) and other actions. The impacts of classifying waste currently “managed” as HLW as non-HLW by way of the HLW interpretation was also evaluated in DOE’s 2020 Report to Congress. If the interpretation is not applied, what is the cost to the whole EM cleanup program, and is this safer for human health and the environment than a decision to use the HLW interpretation? In 2019, ECA wrote in support of DOE’s Federal Register Notice on DOE’s interpretation of the definition of the statutory term of “high-level radioactive waste (HLW)” as set forth in the Atomic Energy Act of 1954 and the Nuclear Waste Policy Act of 19823. The application of the HLW interpretation would base disposal decisions on actual radiological characteristics and risk to human health arising from the waste, rather than the artificial former policy standards that base waste classification on origin. This risk-based approach could reshape DOE’s cleanup mission across the complex, saving taxpayer money and accelerating cleanup. DOE, through two Administrations has supported the policy. DOE is currently implementing the policy at the Savannah River Site. The main considerations for the implementation of HLW interpretation at the Hanford site follow below. 1. Avoid projected costs of $135 billion to $5 trillion as estimated by the Government Accountability Office in May 20234. If applied at Hanford, the HLW Interpretation could cut more than $100 billion in environmental cleanup costs and allow for expedited cleanup activities. That, in turn, would allow DOE to focus sooner on other high-priority cleanup projects, ultimately reducing risks across the complex. EM’s environmental cleanup mission accounted for $406 billion in fiscal year 2020, and it is trending upwards with EM’s environmental liability outpacing its spending on cleanup activities5. 2. Enables EM to better address one of its largest environmental risks/liabilities with a scientific, risk, and data-driven approach that protects the surrounding communities and environment. The HLW Interpretation allows DOE to address some tank waste as non-HLW and dispose of it in accordance with its radiological characteristics. In our report, “Disposal Drives Cleanup: Re-energizing Momentum for Disposal Solutions for Radioactive Waste,” ECA urges DOE to prioritize use of the HLW interpretation, stating “DOE should re-energize its use of the HLW interpretation, including pursuing a pilot implementation at Hanford for a single-specific waste stream. This would be intended to help foster broader support for the use of the HLW interpretation at Hanford, which could have significant benefits to DOE and the local communities near the site.” DOE has already demonstrated that the HLW interpretation can be safely and successfully applied. At the Savannah River Site (SRS), the Department first used it to address small amounts of wastewater from the SRS Defense Waste Processing Facility that was sent to Waste Control Specialists LLX (WCS) for stabilization and disposal as non-HLW in late 2020. In December 2021, DOE announced their second HLW interpretation project with the release of Draft Environmental Assessment (EA) for the Commercial Disposal of Savannah River Site Contaminated Process Equipment (DOE/EA-2154) for public comment. In July 2023, the Savannah River Site Office issued a Finding on No Significant Impact and, based on the information and analysis collected in the Final EA, DOE will also send the contaminated process equipment to WCS for disposal. The SRS process equipment includes Tank 28F salt sampling drill string, glass bubblers, and glass pumps, all contaminated with reprocessing waste. In total DOE has moved eight gallons of waste from the Savannah River Site (SRS) to Texas in the last several years, but DOE can and must do better if they are going to save over $200 billion in cleanup costs. 3. Reduces the amount of time that radioactive waste is stored onsite at DOE facilities, increasing safety for workers, host communities, and the environment. If properly implemented, applying the high-level waste interpretation can cut years of DOE operations and reduce risk at Hanford and to the surrounding communities. The policy adoption would enable simplification and acceleration of treatment and disposal plans for the low activity fraction of the tank waste inventory, because once stabilized, a significant share of the tank waste volume will be low level waste (LLW). Optimized planning can make use of existing technologies and facilities, allowing tank retrieval and treatment actions to begin sooner. Any progress toward acceleration and implementation of tank retrieval and waste stabilization will directly contribute to reductions in the environmental and worker risks from the deteriorating tank storage system. This alternative provides needed redundancies that reduce future programmatic risk by providing a near-term path to disposal, mitigating costs, schedule and compliance impacts resulting from delays in WTP construction and commissioning, will shorten the extent of indefinite onsite storage for stabilized wastes. Promotes environmental justice for the communities around the sites by potentially accelerating retrieval and disposition of reprocessing waste. Environmental justice and equity, as applied to waste disposition, means that the communities where this waste has been produced and stored should be given priority. Hanford and the surrounding communities fall under that commitment made by DOE, EPA, and Ecology. Innovative disposal alternatives for all the waste types for which DOE is responsible must be analyzed and, if there is informed support for an alternative approach, fully implemented. Various external organizations (National Academies of Sciences, Engineering, and Medicine; seven national laboratory directors; NRC staff; and others) have stressed the benefits of the interpretation of EM’s cleanup efforts. Opposition to the HLW interpretation could mean that the tank waste at Hanford, once treated, will remain at the site. Vitrified low-activity waste is intended for onsite disposal and vitrified HLW will remain in storage for the foreseeable future given the absence of a geological repository. Again, ECA appreciates the opportunity to provide this input on the proposed changes to the Tri-Party Agreement, the consent decree on Hanford Site tank waste, and the evaluation of any alternative that accelerates safe, risk-based, technically feasible, and cost-effective cleanup. We look forward to working with you as partners to identify and support options for moving waste out of our communities more expeditiously. Many DOE sites across the complex were never intended to store waste yet serve now as de facto interim storage sites. Simply leaving waste in place is neither acceptable nor the safest option. For any questions, or for addition information, please contact Faith Sanchez, ECA Program Director, faiths@energyca.org. Sincerely, Mayor Brent Gerry ECA Chair 1 ECA is the national association of local governments of communities that host or are affected by DOE and National Nuclear Security Administration (NNSA) activities. ECA’s mission is to bring together leadership from DOE-affected communities to share information, establish policy positions, and advocate for common interests in order to effectively address and increasingly complex set or environmental, regulatory, and economic development. ECA board members include local elected officials and community leaders from communities across the DOE complex. 2 https://www.energy.gov/em/high-level-radioactive-waste-hlw-interpretation Energy Communities Alliance 3 Energy Communities Alliance Comments on the October 10, 2019, Federal Register Notice – DOE’s Interpretation of High-Level Radioactive Waste based on actual radiological characteristics and risk to human health, January 8, 2019. 4 Hanford Cleanup, DOE Should Validate Its Analysis of High-Level Waste Treatment Alternatives, GAO, May 2023. Energy Communities Alliance 5 Environmental Liability Continues to Grow, but Opportunities May Exist to Reduce Costs and Risks, GAO, June 2021. Energy Communities Alliance

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Comment From: Diana Gordon

9/03/24 @ 9:13 AM

HOLISTIC AGREEMENT ON CLEANUP OF HANFORD TANK WASTE due 9/1/24

RE:LAW Disposal

I am wondering what is happening with the low level waste vitrification plant. It sounds as though it is just about ready for use and I would like to know if the TP...↓

I like the idea of vitrification much more than grouting because it sounds safer for longer. However, the Test Bed Initiative is showing positive results so far and I do like the idea of removing low activity grouted waste from Hanford and shipping it for storage in a place where groundwater is not a problem. (Needless to say, liquid waste should never be shipped.)

Both licensed low level waste repositories where the waste is headed are many miles from Hanford - in Texas and in Utah. It sounds as though shipping grouted waste is pretty safe though I have been unable to find out very much about how the grouted waste will be shipped. I am assuming that the cylinders of grouted waste will be in metal containers so that, in case of accident, the waste would have an added layer of protection. (The picture on Energy’s Test Bed Initiative page isn’t very clear.) However, even in the best case scenario, the danger to the public in communities the grout is shipped through is not negligible. Those communities are entitled to know about the routes the waste will take and examine an EIS detailing the planned route, the form the waste is in, especially the safety issues, etc. Oregon does not seem thrilled with the prospect of waste traveling through and I doubt Spokane and other cities will be either.

But what about the low level waste vitrification plant? Surely it should be used for as much of the waste as possible. I am sure that such a plant cost millions (at least) and I hope we are not losing that investment. I’m sure it shows my ignorance to say that I think they should use both methods and finish the job more quickly! Faster is better for us downstream communities.

Dian Gordon↓

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Comment From: Shannon Cram

9/01/24 @ 11:52 PM

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Comment From: Shannon Cram

9/01/24 @ 11:51 PM

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Comment From: Randi Fitch

9/01/24 @ 11:50 PM

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Comment From: Randi Fitch

9/01/24 @ 11:49 PM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

Please, please do what is right, not what is expedient. We need to take care of this nuclear waste and not just truck it to another community to share devastating health implications.

Sincerely,
Randi Fitch

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Comment From: Mary Hanson

9/01/24 @ 11:48 PM

Dear To Whom It May Concern,

Thank you for accepting my comments on the Holistic Settlement Agreement. After four years of closed-door negotiations, I expected a robust public involvement plan that was created with input from groups and entities wor...↓king on Hanford, materials that are transparent and easy to understand, enough time to review documents, and an opportunity to comment and table at public meetings in major cities. I am incredibly disappointed. You need to do better.

For all major comment periods in the future:

- GET INPUT EARLY AND OFTEN: Consult with groups, organizations, and Tribal Nations on your public involvement plans for materials, public meeting design/timing/location, and presentations. Use that input to improve the plan.

- DESIGN FOR MEANINGFUL INVOLVEMENT: Design regional public meetings with an open house where all interested parties can table, provide information and chat with attendees, incorporate time for a local perspective to provide an alternate viewpoint, and schedule meetings in the fall and spring for maximum participation.

- USE PLAIN LANGUAGE, PLEASE: Use plain language in your presentations and materials to provide a high-level overview of the cleanup work the administrative tool (in this case, the Consent Decree & Tri-Party Agreement) covers, instead of overly focusing on the intricacies of the administrative tool itself.

- BE TRANSPARENT: If there is important information buried in your materials and presentations, bring it forward and make it transparent. For example, plainly state how much liquid tank waste you are planning to grout and plainly state that instead of delaying cleanup now, cleanup milestones will be delayed in the future. Plainly state when those delay decisions are anticipated as well as what the public process will look like that accompanies those decisions.

- STOP PUSHING YOUR CRITICS AWAY: Instead of running from critical feedback and responding with defensive/avoidant behavior, invite your critics to the table and make time to learn from their feedback.

Thank you for considering my comment. I appreciate how difficult your job is, and I hope you will take these suggestions as constructive. We can look back on a better result if we improve the process.

Sincerely,
Mary Hanson

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Comment From: Mary Hanson

9/01/24 @ 11:47 PM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

Thank you for considering my comment. I appreciate your understanding that we get this right. Doing things wrong in haste is what got us into this mess, and we cannot afford to compound it.

Sincerely,
Mary Hanson

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Comment From: James Plunkett

9/01/24 @ 11:42 PM

Thank you for letting me express myself here.

I attended the recent online meetings in Olympia and Hood River. I know that we all feel the same daunting responsibility to the future.

The Tribes at Hanford should be made whole as near as possible af...↓

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Comment From: Glenna Cole Allee

9/01/24 @ 11:38 PM

Glenna Cole Allee

Dear U.S. Department of Energy, U.S. Environmental Protection Agency, and Washington Department of Ecology,

Thank you for inviting public commentary on the Holistic Settlement Agreement. As an artist who has researched the Hanford...↓ site for many years, I'm extremely concerned about the toxic waste at the site and the danger it poses to the entire northwest. I feel it is imperative that the cleanup be expedited, safely. Please add my concerns, below, to the public record.

1. The USDOE must commit to immediate action to stop the leaks from single shell tanks, and dramatically increase the pace of waste retrieval. They need to construct new tank space much faster than the proposed date in the current agreement, listed as 2040, and they must provide much more tank space than the current proposed amount of one million gallons.

2. The removal of waste from tanks in the 200 West Area (where tanks are currently known to be leaking) needs to be accelerated, but the waste must be treated and solidified into a grout before being transported. If disposed offsite, it needs to be placed in licensed facilities that have no groundwater.

3. Before finalizing any decisions about the grouting processes, all Test Bed Initiative results and any other relevant information need to assessed and considered, and made available for public review. A public comment period must be provided. The date mentioned for New Interim Milestone M-062-64 must be changed. The current date is Dec 2024: this is before the results from the Test Bed Initiative can be considered. Please see that the date in the agreement is changed to read: "Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative."

4. Before any decisions are finalized about shipping grouted waste, communities along potential transportation routes who might be impacted must be provided with transparent plans and options for the shipment. There needs to be ample public input to finalize any plan.

5. Please strengthen the language re the re-classification of waste. It needs to state a clear commitment, in binding language, that high-level waste will not be re-classified.

6. Before the Holistic Settlement Agreement is finalized, all environmental impact analyses and all projected cleanup costs must be made available for public review. There must be a transparent process, with ample time for public commentary and input, particularly for local Tribal Councils to offer input.

Thanks for entering my comments into the record,
Glenna Cole Allee

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Comment From: Joyce Follingstad

9/01/24 @ 11:16 PM

I strongly support removal of waste from the tanks in the Hanford 200 West Area. Of immediate concern are the three tanks that are leaking. As an Oregonian, I appreciate that our Govenor Kotek has strongly objected to shipping liquid radioactive wa...↓

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Comment From: stephanie shandera

9/01/24 @ 10:52 PM

I support removing waste from Hanford for disposal offsite where there is no risk to contaminate groundwater or a river. I live in Seattle but grew up in Yakima. This issue has been ongoing my whole life and it is incredibly confounding that we are ...↓

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Comment From: Thomas & Diana Gordon

9/01/24 @ 9:43 PM

A report titled, "Radiation Flowed 200 Miles to Sea, Study Finds",
in The New York Times, July 17, 1992, included:

A Government contractor's preliminary study of radiation released over the years from the Hanford Nuclear Reservation into the Columbi...↓

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Comment From: Diana Gordon

9/01/24 @ 9:07 PM

HOLISTIC AGREEMENT ON CLEANUP OF HANFORD TANK WASTE due 9/1/24

RE: Leaking Tanks

We live downstream from Hanford and have a major concern about tanks that are leaking radioactive liquid into the soil which is then moving toward the Columbia River...↓ in the groundwater.

In Washougal, people fish, canoe, kayak, paddle board, swim and picnic at the lovely Clark Park Beach and engage in countless other activities in and near the Columbia. We even have a marina with a restaurant located on a pier. No one wants to have the worry of tanks leaking radioactive chemicals into ‘our’ stretch of the River.

Tank T-111 is leaking and so is Tank B-109. These are not new leaks. Now the Tri-City Herald reports a possible leak in T-101. As I understand it, we have the technology to remove the liquid from these tanks. We can do it with existing technology using the ‘In-Tank Pretreatment System’ combined with salt-well pumping. We can move the waste nearby to be treated as soon as possible. Both Federal and State law support and indeed require the expedient removal of leaking waste as soon as practicable. We should do that and get started ASAP.

Possibly, if we study this problem to death, we could come up with something cheaper or easier. But this is an urgent problem to us. It can affect the health and well-being of the nearby tribes, communities both nearby and downstream, river users, wildlife and flora, and the environment. It is not as though anyone asked us if putting this off indefinitely is all right with us - this agreement was finalized without the involvement of any of those parties. It can have an impact on us eventually, and we feel an urgency to get it done. It is especially egregious for the tribes and communities near Hanford who have had to tolerate the terrifying pollution and attendant problems for over 80 years.

It is time to get this done.

Diana and Tom Gordon↓

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Comment From: Linda Devlaeminck

9/01/24 @ 7:40 PM

I support removing waste from Hanford for disposal offsite
where there is no risk to contaminate groundwater or a river. I live in Vancouver.
I expect my Washington State agencies and Governor to use every power they
have to ensure that liquid radioa...↓

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Comment From: Hanford Challenge

9/01/24 @ 6:53 PM

It is critically important to Hanford Challenge that the cross-site transfer lines work. Please consider our additional comments regarding Attachment B: Establish New TPA Milestones to Activate Cross-Site Transfer Lines Connecting Double-Shell Tanks ...↓

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Comment From: Louisa Hamachek

9/01/24 @ 4:53 PM

I have a right to protect the whole Columbia River System from the irresponsible military Hanford rad waste, even though i live up the Willamette River tributary.

Fund all projects that immediately and by set deadlines prevent the Hanford Radioactiv...↓

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Comment From: Louisa Hamachek

9/01/24 @ 4:35 PM

Prevent nuclear waste from entering the Columbia River

Sacrifice the area of Hanford snd its huge mistakes

Reroute the Columbia River with a bipass canal that would cut across the bend in the river which wraps around Hanford

Cover over from rain ...↓

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Comment From: Thomas & Diana Gordon

9/01/24 @ 3:44 PM

Oregon Department of Energy wrote in April 2024, "A proposal to implement large-scale transportation of liquid tank waste still containing long-lived mobile key radionuclides introduces potentially additional and unnecessary risk of contaminant sprea...↓

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Comment From: Karin Engstrom

9/01/24 @ 3:36 PM

I've read a long list of books on Hanford, but not as thorough as Steve Olson's The Apocalypse Factory that gave me meaningful insights from the discovery of fission, the coming together of scientists to explore the phenomena, through the establishme...↓

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Comment From: David Parrish

9/01/24 @ 3:00 PM

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Comment From: Sylvia Haven

9/01/24 @ 2:59 PM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

Why don't you pay attention to the watch dogs that are trying to keep you honest?

It shouldn't be this difficult for you to do the right thing to protect our citizens, our environment and indeed our national security for generations to come.

Funding for cleanup should come before funding our military adventurism which does not enhance our national security at all. Spend your time lobbying congress to fully fund a real cleanup and get on with your work to finally vitrify all that harmful waste.

Thank you for considering my comment.

Sincerely,
Sylvia B Haven

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Comment From: Becca Hall

9/01/24 @ 2:58 PM

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Comment From: Cathryn Chudy

9/01/24 @ 2:57 PM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

Thank you for considering my comment.
I am not sure if my comment got through so am re-submitting my support for these recommendations made by Hanford Challenge.

Sincerely,
Cathryn Chudy

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Comment From: Thomas Gordon

9/01/24 @ 2:39 PM

More than 60 square miles of Hanford sit above groundwater too contaminated for use. Radionuclides reach the Columbia River now. Also, tritium in the ground water is under the Columbia Generating Station.

The new plan should concentrate on getti...↓

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Comment From: Nancy Morris

9/01/24 @ 12:08 PM

To the Tri-Party Agencies:
A final comment before the deadline tonight. I am asking why the USDOE and Washington State Ecology did not agree to prioritize retrieving waste before 2040 from the "T Tank Farm" where two of the leaking tanks are currentl...↓

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Comment From: Heart of America Northwest, -1... (Gerry Pollet)

9/01/24 @ 11:53 AM

Attached are the comments of Heart of America Northwest "the public's voice for Hanford cleanup". Please respond to gerry@hoanw.org and office@hoanw.org
For the public seeking information, our comments begin with an overview of "WHY WE CARE ABOUT HA...↓

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Comment From: William Corr

9/01/24 @ 11:35 AM

Liquid nuclear waste should not be shipped. The danger of accidental leakage is too great with liquid shipping by truck or rail. Liquid waste needs to be solidified before shipping to a safe location.

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Comment From: Barbara LaMorticella

9/01/24 @ 11:34 AM

From a Concerned NW Citizen :

US nuclear production at Hanford has created 55 million gallons of high-level nuclear waste that is stored in underground tanks. It has released radiation into the diet of the Yakima people, who are heavy eaters of fish a...↓

To all appearances, the government has written the NW off as a sacrifice zone. Some waste will be stored onsite permanently.

The 324 building, 1000 feet from the river, is leaking underground. Tanks B-109 and T-111 are leaking. Liquid from B-209 will reach groundwater in 25 years, and will be radioactive for thousands of years.

The USDOE has a pattern of requesting less funding for Hanford Clean-Up than the federal government allocates, and the amount requested for clean-up grows smaller as the threat grows bigger. Meeting the clean-up milestones set forth in the Hanford Cleanup Agreement (TPA) would require $4.56 billion in FY '25. But the USDOE is requesting only $3.1 million. It is also is requesting $2.4 billion in new nuclear production and modernization, and $500 million for "deployment and support of reactors." All waste from these "safe" reactors will then be shipped for storage to Hanford.

Liquid waste from Hanford will be shipped over highways through Spokane and Oregon, as will liquid to Hanford from distant reactors. This, though a functional vitrification plant is located right next to the site.

Legislators who make these decisions know nothing about the Northwest's earthquake prone geology, care little about the Columbia River and its importance to all living creatures in the NW, and know little about nuclear energy itself. At best their ignorance makes it possible, at worst it makes it simply expedient, to designate the Northwest as sacrifice zone.

Please do not let the USDOE do its own cost estimates of nuclear clean-up plans, and please realize it is an urgent necessity and moral responsibility to spend and do whatever necessary to ameliorate this threat to life in the Northwest.

Sincerely,

Barbara LaMorticella

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Comment From: Carolyn Treadway

9/01/24 @ 11:28 AM

Cleanup of radioactive waste in Hanford is imperative. But please do not ship liquid highly radioactive waste through inhabited areas, as it is very dangerous and could be lethal.

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Comment From: Karen Verrill

9/01/24 @ 11:14 AM

I am deeply concerned that there is any proposal to transport nuclear waste anywhere before it is treated and solidified. Why risk contaminating any land or waterway by transporting this waste in tanks that do or could be leaking. Why is it ok to tak...↓

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Comment From: Tony Cochran

9/01/24 @ 4:47 AM

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Comment From: Tony Cochran

9/01/24 @ 4:46 AM

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Comment From: Nancy Morris

9/01/24 @ 4:45 AM

Dear To Whom It May Concern,

Thank you for accepting my comments on the Holistic Settlement Agreement. After four years of closed-door negotiations, I expected a robust public involvement plan that was created with input from groups and entities wor...↓king on Hanford, materials that are transparent and easy to understand, enough time to review documents, and an opportunity to comment and table at public meetings in major cities. I am incredibly disappointed. You need to do better.

For all major comment periods in the future:

- GET INPUT EARLY AND OFTEN: Consult with groups, organizations, and Tribal Nations on your public involvement plans for materials, public meeting design/timing/location, and presentations. Use that input to improve the plan.

- DESIGN FOR MEANINGFUL INVOLVEMENT: Design regional public meetings with an open house where all interested parties can table, provide information and chat with attendees, incorporate time for a local perspective to provide an alternate viewpoint, and schedule meetings in the fall and spring for maximum participation.

- USE PLAIN LANGUAGE, PLEASE: Use plain language in your presentations and materials to provide a high-level overview of the cleanup work the administrative tool (in this case, the Consent Decree & Tri-Party Agreement) covers, instead of overly focusing on the intricacies of the administrative tool itself.

- BE TRANSPARENT: If there is important information buried in your materials and presentations, bring it forward and make it transparent. For example, plainly state how much liquid tank waste you are planning to grout and plainly state that instead of delaying cleanup now, cleanup milestones will be delayed in the future. Plainly state when those delay decisions are anticipated as well as what the public process will look like that accompanies those decisions.

- STOP PUSHING YOUR CRITICS AWAY: Instead of running from critical feedback and responding with defensive/avoidant behavior, invite your critics to the table and make time to learn from their feedback.

Thank you for considering my comment. To Tri-Party Agencies:
I have been involved in commenting on Hanford nuclear waste cleanup since the late 1980's onward to present. Cleanup should be much further along than it is now. Truly the 177 underground leak-prone tanks holding 56 million gallons of high-level waste are a serious threat to human health now and generations to come, the entire environment at Hanford and all its surrounds, and the Columbia River. The First Nations people of the 'Confederated Tribes and Bands of the Yakama Nation' and the 'Confederated Tribes of the Umatilla Indian Reservation' should have had more involvement and need to be involved to insure a better schedule and prognosis than has been offered by the Tri-Party Agreement Agenices of the Dept of Ecology, EPA Region 10, and the USDOE. Generations are at risk beyond your lifetimes. Time to stop passing this horrific toxic legacy to your children and grandchildren and focus needed funding, research, and political will to cleanup the most toxic area in North America. Stop the continued delays.

Sincerely,
Nancy Morris

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Comment From: Nancy Morris

9/01/24 @ 4:44 AM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

To Tri-Party Agencies:
I have been involved in commenting on Hanford nuclear waste cleanup since the late 1980's onward to present. Cleanup should be much further along than it is now. Truly the 177 underground leak-prone tanks holding 56 million gallons of high-level waste are a serious threat to human health now and generations to come, the entire environment at Hanford and all its surrounds, and the Columbia River. The First Nations people of the 'Confederated Tribes and Bands of the Yakama Nation' and the 'Confederated Tribes of the Umatilla Indian Reservation' should have had more involvement and need to be involved to insure a better schedule and prognosis than has been offered by the Tri-Party Agreement Agenices of the Dept of Ecology, EPA Region 10, and the USDOE. Generations are at risk beyond your lifetimes. Time to stop passing this horrific toxic legacy to your children and grandchildren and focus needed funding, research, and political will to cleanup the most toxic area in North America. Stop the continued delays.

Sincerely,
Nancy Morris

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Comment From: Ted Grudowski

9/01/24 @ 4:43 AM

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Comment From: Theodora Tsongas

8/31/24 @ 10:26 PM

Thank you for this opportunity to provide comments. I am writing to express my concerns regarding the transportation of Hanford waste through communities and states, not limited to but including central Oregon.

Regarding the plan to transport Hanfo...↓rd tank waste through central Oregon, it must be considered that our region's closest Hazmat Regional Response Team is in Salem Oregon, making central Oregon particularly vulnerable to transportation incidents involving hazardous materials. The plan for transporting the so-called low-activity waste has not been specified and the commitment for additional public engagement once specified is unclear. This is problematic as it requires transport by either truck or rail through populated corridors, no matter which route is selected, and it is clear that waste in a liquid form poses significantly more risks to our communities, environment and health than waste in a solid form.

There are three critical issues still unresolved: treatment of waste prior to transport, means of transport, and NEPA. These issues have been left open for future decisions by the Department of Energy without assurance of further consultation and notification of the public, Tribes, or the state of Oregon or other states and communities through which the waste would be transported.

Specifically, the terms of the current agreement do not specify whether liquid tank waste will be solidified into a cake form and/or grouted or vitrified before transport or after transport to a final disposal site. The transport of liquid tank wastes is unacceptable because of the extreme danger of mishaps during rail or truck transport that would only exacerbate the long term dangers to the public and our lands and waters, and defeat the purpose of transporting the waste from Hanford. Only solidified tank waste, preferably vitrified in glass, should be considered for transport from Hanford.

Offsite tank waste disposal requires close cooperation between several levels of government, some of whom have never previously been impacted by Hanford issues and must be consulted prior to decision-making. The current draft agreement leaves critical issues open for decision by the U.S. Department of Energy without assurance of further notice, engagement, or comment. We simply cannot accept this lack of transparency and participation.

Furthermore, the plan for transport is not finalized and will be left up to the Department of Energy to make decisions without consultation or notification or public comment. This is unacceptable! It is NECESSARY that the public, Tribes, states and potentially impacted communities be consulted prior to any such plan being put into place. It is our right to have input into these decisions that will surely impact our lives!

It is not clear how the federal agencies intend to address NEPA requirements for assessing the risks of the alternatives for transport of the waste to the final destination for disposal. A roadmap for incorporating input and consultation is missing and must be developed before any action is taken to transport the wastes. At the very least, a complete environmental impact assessment of the risks of this proposed activity must we conducted with necessary public involvement and transparency in the process.

Finally, this agreement seems to have given little to no consideration to equity or environmental justice in its decision making process. Low income and rural communities will reap the brunt of long and short term adverse effects on health, home, and livelihood of any miscalculations or errors in this process or in the implementation of this plan.

The agreement represents an important step toward risk reduction at the Hanford site but it requires innovative solutions and careful consideration of the long-term environmental and public health impacts. It is absolutely incumbent upon the agencies involved to ensure the Hanford tank waste mission can progress more effectively and safely, while minimizing long-term environmental and public health risks, and with the full involvement of the public who stand to be most impacted by missteps, errors, and accidents.

Thank you for your attention to these concerns.

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Comment From: Ann Dorsey

8/31/24 @ 9:59 PM

I am concerned about the three leaking tanks at the Hanford site since the liquids put the water supply, local communities, the environment and wildlife at risk. As such, I support and encourage plans to accelerate the leaks being stopped and site cl...↓

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Comment From: Tika Bordelon

8/31/24 @ 9:04 PM

No nuclear!

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Comment From: Kristen Bruner

8/31/24 @ 5:58 PM

I agree with the plan to remediate and address the high-level radioactive liquid waste at the Hanford Nuclear Reservation, but transporting it in liquid form poses significant risks. Before any shipment, the waste should be solidified using available...↓

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Comment From: Nancy Morris

8/31/24 @ 4:30 PM

To Tri-Party Agencies:
I have commented on Hanford nuclear waste cleanup since the late 1980's onward to present – around 35 years. Cleanup should be much further along than it is now. Truly the 177 underground leak-prone tanks holding 56 million...↓ gallons of high-level waste are a serious threat to human health now and generations to come, the entire environment at Hanford and all its surrounds, and the Columbia River. The First Nations people of the 'Confederated Tribes and Bands of the Yakama Nation' and the 'Confederated Tribes of the Umatilla Indian Reservation' should have had more involvement and need to be involved to ensure a better schedule and prognosis than has been offered by the Tri-Party Agreement Agencies that are comprised of the Dept of Ecology, EPA Region 10, and the USDOE.

I agree with Governor Kotek who stated to the USDOE that . . ."three critical issues that are left open for future decisions by Energy, without any commitment for public comment or consultation with Tribes or Oregon. These issues include, what form tank waste will take if shipped off site, how communities along shipping routes will be engaged, and clarity around the environmental review for these major decisions".

I urgently demand that:

The federal government treats tank waste as the law requires. The Nuclear Waste Policy Act defines tank waste as high-level waste. Rather than forbearing the use of a new, weaker definition of high-level waste, Energy should permanently abandon plans to apply this definition at Hanford;
The TPA agencies provide adequate information and opportunities for the public to comment on major proposed changes to cleanup, such as the adequacy of proposed new tank capacity and the proposal to ship large volumes of tank waste through communities in liquid or solid form;
Ecology and EPA explain why the standard "as good as glass" applies to treated and immobilized tank waste in Washington, but not elsewhere.
Environmental reviews are available to the public to review while commenting on the proposed changes. The agencies seem to be putting the cart before the horse, making sweeping changes to Hanford's cleanup plan and finalizing a settlement without having conducted a full environmental NEPA and SEPA analysis of the impacts of its decisions.
The 2024 date for selecting a grouting alternative be removed from the proposed changes. This date is inappropriate and premature, it is not possible to have the information necessary to make such a decision at this time, much less provide the public, Tribes, states, stakeholders, and every person impacted by the storage, transportation, and disposition of tank waste notification so that they can consent to the risks being imposed upon them. WAIT FOR GROUT TEST RESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64. Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pre-treatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. YOU MUST PROVIDE A PUBLIC COMMENT PERIOD ON YOUR PROPOSED GROUT DECISION PRIOR TO FINALIZING.

Finalization of the proposed changes be delayed until Tribal Nations have consulted with the TPA Agencies on the proposal. This should have happened prior to the settlement going public, robust consultation is not equivalent to after-the-fact "familiarization," with decisions that directly impact the lives and livelihoods of generations of Indigenous people. The settlement is astoundingly inappropriate in this regard, lacking entirely an analysis of how the people most impacted by these decisions will navigate the hazards and harms imposed on them.
Generations are at risk beyond our and the Tri-Party Agency representatives' lifetimes. Time to stop passing this horrific toxic nuclear waste legacy to your children and grandchildren and focus needed funding, research, and political will to cleanup the most toxic area in North America. Stop the continued delays.

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Comment From: Western Interstate Energy Boar... (Melanie Snyder)

8/31/24 @ 1:31 PM

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Comment From: Pamela Gross

8/31/24 @ 12:25 PM

My family and I have strong concerns and objections to transporting millions of gallons of tainted nuclear liquid wastes – especially when transporting treated waste as a solid is a readily available,
and much safer, alternative that would still allo...↓

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Comment From: Don Williams

8/31/24 @ 9:46 AM

The proposal to remove contaminated high level radioactive liquid waste from the Hanford Nuclear Reservation is one I support. But shipping such liquid waste is not safe until it is converted to a solid form. The technology exists to do that. I ex...↓

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Comment From: Bonnie McKinlay

8/30/24 @ 11:14 PM

Thank you for the opportunity to comment on the Hanford Tri-Party Agencies Holistic Settlement Agreement.

I have concerns about the process of developing the Agreement.
Above all, the lack of consultation from Washington State Dept of Ecology, EPA, ...↓USDOE with the directly impacted Native People: the Yakama Nation, Confederated Tribes of the Umatilla Indian Reservation and the Nez Perce Tribe (The Nimiipuu) is unconscionable. I urge the Tri-Parties to correct this serious oversight by apologizing to the Tribes and suspending the Settlement process long enough to listen and work towards their demands.

Direct quotes from Ecology's page on "Environmental Justice at Hanford":
"Missed cleanup milestones and consistent underfunding at the U.S. Department of Energy's Hanford Site in southeastern Washington exponentially increase overall costs, delay cleanup completion, and exposes surrounding populations to environmental and health risks. Those most vulnerable to harmful impacts are overburdened and underserved communities, including people of color, low-income populations, Tribes, and indigenous people.
We must ensure that the rights of sovereign nations are upheld through cleanup, and that we align with federal and state environmental justice obligations to address and eliminate environmental and health disparities around Hanford. We need to demonstrate, through adequate funding and aggressive deadlines, our commitment to protect the Tribes, area residents, and communities who face the highest risks from Hanford contamination and persistent delays.
Communities At Risk
Hanford's plutonium production contaminated the area for 40 years before cleanup began in 1989. Consistent underfunding of the cleanup mission has caused legal deadlines to be missed, increased overall cleanup costs, and extended projected completion into the 2080s. Currently, there are two leaking underground tanks on site. Each additional year of cleanup means improperly stored waste or accidental releases could further contaminate the soil, air, aquifers, and Columbia River impacting communities in the surrounding area and down river. Cleanup delays mean prolonged threats to habitat and wildlife, and risks to the physical, cultural, and economic wellbeing of local Tribes and communities.
Tribal Impacts
There are three Tribal Governments in the area that the state partners with on environmental issues attributed to nuclear waste. These indigenous populations have reserved rights per their 1855 Treaty of Yakama and the Treaty of Walla Walla: the Confederate Tribes and Bands of the Yakama Nation, Confederated Tribes of Umatilla Indian Reservation and the Nez Perce Tribe. The Wanapum Tribe is one of the Bands of the Yakama Nation. They once inhabited year-round villages where Hanford is now before being forced off their ancestral territory. The Wanapum have not received any compensation for their loss of lands and Treaty territory. All of these indigenous populations have expressed significant interest in the oversight and thorough cleanup of polluted areas that once provided hunting, gathering and cultural resources for multiple sovereign Tribes and Nations.
Our Responsibility
We must ensure that the rights of sovereign nations are upheld through cleanup, and that we align with federal and state environmental justice obligations to address and eliminate environmental and health disparities around Hanford. We need to demonstrate, through adequate funding and aggressive deadlines, our commitment to protect the Tribes, area residents, and communities who face the highest risks from Hanford contamination and persistent delays."

I share Oregon Governor Tina Kotek's concern about the transport of liquid high waste through our state. She commented, "The ongoing process for receiving and accounting for input from the State of Oregon, Tribal governments, and the public on substantive issues relating to the solidification and transport of liquid tank waste is insufficient and risks undercutting support for the accelerated reduction of radioactive waste at the Hanford site that is in everyone's interest."

I zoomed into the Richland and Olympia public hearings. I found the audio almost unintelligible.
It was disturbing to see the public hearings limited to these three sites. The Hanford Holistic Settlement Agreement affects people throughout the region. Why were hearings not also held in Spokane, Portland and Bend?

Sincerely,
Bonnie McKinlay

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Comment From: Hallie Appel

8/30/24 @ 9:03 PM

I am surprised and horrified that it has taken until now to achieve an Agreement to clean up millions of gallons of radioactive and chemical waste from leaking tanks at Hanford. However I am relieved and pleased that there will now be deadlines for t...↓

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Comment From: Lois Barnett

8/30/24 @ 5:52 PM

Liquid radioactive wastes from Hanford's tanks should not be transported through
Spokane or Oregon when an option to solidify and treat the waste before shipping it is available:

There must be an Environmental Impact Statement(EIS).

I strongly supp...↓

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Comment From: William Engels

8/30/24 @ 4:01 PM

I am a resident of eastern Washington and am strongly opposed to transporting liquid radioactive waste by truck or rail from Hanford through Oregon or Spokane. The waste must be solidified and treated before being transported. This treatment can be...↓

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Comment From: Kimberly Sims

8/30/24 @ 3:59 PM

I am opposed to the transporting of liquid radioactive waste across Washington and Oregon. Please consider solidifying this waste into a group and disposing of it offsite. At a
minimum, an EIS should be done to consider the different options. Tha...↓

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Comment From: Confederated Tribes of the Uma... (Matthew Campbell)

8/30/24 @ 3:27 PM

Attached PDF

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Comment From: Tri-City Development Council (Karl Dye)

8/30/24 @ 3:04 PM

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Comment From: Hanford Communities (David Reeploeg)

8/30/24 @ 2:51 PM

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Comment From: Columbia Riverkeeper (Simone Anter)

8/30/24 @ 2:44 PM

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Comment From: Columbia Riverkeeper (Simone Anter)

8/30/24 @ 2:42 PM

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Comment From: Richard Honour

8/30/24 @ 1:21 PM

Richard C. Honour, PhD
19211 64th Place NE, Kenmore, WA 98028
425.772.1473 rhono@precautionarygroup.org
August 30. 2024

Re: Proposed amendments to Tri-Party Agreement and Consent Decree.
"The U.S. Department of Energy, Washington State Department of...↓

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Comment From: Linda Andersson

8/30/24 @ 12:26 PM

I support removing the waste from Hanford to a place where there is no chance of harming life of any form. I honestly don't see why we continue to use nuclear power. The cancer rates of people living near these plants is much higher than the nation...↓

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Comment From: FAYE VLIEGER

8/30/24 @ 12:26 PM

Both Federal and Washington State law require notification of leaking tanks. The US Dept. of Energy has historically ignored and delayed reporting tank leaks. Their reporting on the kind and quantity of tank leaks always lags the spill to the determe...↓

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Comment From: Janna Rolland

8/30/24 @ 12:14 PM

Dear Department of Ecology:

I'm deeply concerned that Hanford's High Level Nuclear Waste tanks continue to leak without any action to stop the leaks.

Since the public meetings on the Agreement were held in July, USDOE has announced that a third ta...↓

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Comment From: Doris Cellarius

8/30/24 @ 9:28 AM

I live in Oregon near the Columbia River. People in Oregon and elsewhere are threatened by this plan - which must change!

DOE must accelerating removal of waste from tanks in the 200 West Area. This is
where 2 of the 3 tanks that are currently leak...↓

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Comment From: EnergySolutions LLC (TImothy Orton)

8/30/24 @ 7:47 AM

See attached letter signed by Joe Heckman, EnergySolutions President, Waste Management. The body of the letter is presented in this comment section:

EnergySolutions, LLC is pleased to comment on the changes to the Holistic Agreement on Cleanup of H...↓anford Site Tank Waste posted on May 30, 2024. The revision provides several new and revised cleanup deadlines. Commercial processing of tank waste will greatly increase the probability of meeting the milestones and deadlines within the revised agreement. EnergySolutions is uniquely qualified to provide that service to the Hanford cleanup project.
EnergySolutions comments are specific to Attachment M, Change Number M-62-24-04, Establish New TPA Milestones to Create Alternative Treatment Capacity for LAW for 200 West Area SSTs. The modifications within this change number (M-062-64, M-062-65, and M-062-66) all describe waste being grouted on-site with the grouted waste disposed outside of the Hanford Nuclear Reservation (outside the state of Washington). The modifications are also concerned with a backlog of grouted waste awaiting shipment to an approved disposal facility. An alternative that is not addressed in the revised agreement is for liquid waste to be shipped off-site for grouting and disposal at an approved facility. This alternative would be beneficial to meet milestones since proven, commercial infrastructure serving the DOE is already in place to perform this treatment and could begin immediately. It would also solve the backlog of grouted waste on-site issue, as well as the existing lack of tank space for wastes being processed out of the Tank Side Cesium Removal system, and truly begin the process of reducing waste on site.

The EnergySolutions Clive Facility in Utah has the infrastructure in place and has over 30 years of experience successfully treating contaminated liquids to meet Land Disposal Restriction standards and disposes the grouted residue in an on-site permitted mixed waste embankment. Although not to treatment capacity, the EnergySolutions Clive facility has managed (stabilized/solidified) approximately 700,000 gallons of liquid waste from 200 shipments over the last five years with radiological characteristics consistent with the intended Hanford wastes. Further, the facility has a current campaign with two DOE sites that have shipped approximately 150,000 gallons of similarly characterized water in 32 tanker shipments over the last six months. Over the course of liquid treatment at the Clive facility, there has never been a transportation incident from a liquid tanker shipment. Additionally, tankers of hazardous and radioactive liquids with similar constituencies containing upwards of 500,000 gallons annually are routinely transported into and through the state of Washington.

Liquid waste can be safely transported using existing methods and equipment and in fact is currently being done constantly. EnergySolutions feels the addition of off-site liquid shipments into the holistic agreement would allow more flexibility and efficiency and help meet or even exceed the agreement milestones and deadlines.

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Comment From: Sean Edmison

8/30/24 @ 12:34 AM

I write in support of the removal of waste from Hanford for disposal offsite, in a location clear of rivers, lakes, and groundwater. As a Washington resident, I expect our governor to use every possible means and power to prevent radioactive wastes ...↓

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Comment From: Shelley Cimon

8/29/24 @ 4:44 PM

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Comment From: Sharon Fasnacht

8/29/24 @ 2:12 PM

I am a former resident of the Tri-Cities and I’m deeply concerned that Hanford’s High Level Nuclear Waste tanks continue to leak without any action, or very little, to stop the leaks.

Since the public meetings on the Agreement were held in July, US...↓

It is also not acceptable not to consider the earthquake that has been predicted under Hanford, and not to pursue current information on when that earthquake might take place. It is not acceptable not to include the possible outcome of that predicted earthquake, and what must be done to ALL TANKS, AS SOON AS POSSIBLE, including those that are already leaking.

It is my considered opinion that the tri-parties managing Hanford cleanup need to include information regarding this "pending" earthquake in every plan they develop. There are those agencies and personnel who can predict when an earthquake will happen and their severity quite accurately

If there is an earthquake pending at any time in the future under Hanford, then a plan must be considered to solidify ALL waste so that it can be transported more safely, and "move all that waste ASAP to a safe storage area with no rivers or ground water, like those in Texas, etc.. Our Government should be investigating additional safe storage sites to reduce the distance solidified waste must be transported to be stored.

Thank you, Sharon Fasnacht ↓

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Comment From: Mrs. Susan & Mr. Peter Risser

8/29/24 @ 11:20 AM

The dangerous radioactive liquid must never be transported by any by publicly exposed methods
but the leaking tanks cannot be left as they are to continue polluting the river. Find a way to dehydrate the liquid before transporting it !! And STOP MAK...↓

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Comment From: Eric Adman

8/29/24 @ 8:49 AM

I support removing waste from Hanford for disposal offsite
where there is no risk to contaminate groundwater or a river. I live in Kenmore, WA.
I expect my Washington State agencies and Governor to use every power they
have to ensure that liquid rad...↓

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Comment From: Carolyn Treadway

8/29/24 @ 2:19 AM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

Thank you for considering my comment. Hanford has been far too lethal for far too long.

Sincerely,
Carolyn Treadway

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Comment From: Robert Richard

8/29/24 @ 2:18 AM

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Comment From: Robert Richard

8/29/24 @ 2:17 AM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

Thank you for considering my comment. This must be prioritized like the Manhattan Project was for World War, but without the haste for our Earth.

Sincerely,
Robert Richard

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Comment From: Carolyn Croom

8/29/24 @ 2:16 AM

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Comment From: Carolyn Croom

8/29/24 @ 2:15 AM

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Comment From: Patricia Morton

8/29/24 @ 2:14 AM

Dear To Whom It May Concern,

Thank you for providing an opportunity to comment on the Holistic Settlement Agreement. Please update the Consent Decree Changes and New/Changed TPA Milestones to reflect the following comments:

1. WAIT FOR GROUT TEST R...↓ESULTS BEFORE ANY GROUT DECISION, DELAY NEW INTERIM MILESTONE M-062-64: Change the date for this milestone from Dec 2024 to *Within 12 months of receiving all relevant information from the 2,000 gallon Test Bed Initiative, including; the time it takes to find a grout recipe that works and hardens tailored to this specific tank waste, grout-to-waste ratios, grout setting time, performance of in-tank pretreatment system, transportation reports, cost reports, and vendor quality of work from both commercial treatment and disposal sites in Texas and Utah. (P.S.- Please require a public comment period on your proposed grout decision prior to finalizing.)

2. PROVIDE ENVIRONMENTAL IMPACT ANALYSES FOR PUBLIC REVIEW PRIOR TO FINALIZING HOLISTIC SETTLEMENT AGREEMENT CHANGES: The agencies need to provide all analyses of environmental impact through NEPA and SEPA documentation and provide this information to the public for review, PRIOR to finalizing changes to the Holistic Settlement Agreement.

3. ASSESS GROUT SHIPMENT TRANSPORTATION IMPACTS: Create and share a transparent plan to assess the transportation impacts and options for potentially shipping millions of gallons of tank waste through communities as part of your proposed grout plan. Consult with communities along potential routes and get public input before making your decision.

4. BUILD NEW TANK SPACE FASTER AND BUILD MORE THAN 1M GALLONS: Move up the date in Milestone M-045-139 to have new tank storage and staging space sooner than 2040. Sixteen years is too long to wait for new tank space, build it faster and increase the volume beyond the one million gallons in the proposed agreement.

5. SHARE COST IMPLICATIONS: Be transparent about the budget implications of your proposed changes to Hanford tank waste work scope and deadlines. Please provide this information as a part of the public comment period.

Members of my family were made sick by leaks at Hanford. A proper cleanup at Hanford matters to me a great deal.
Thank you for considering my comment.

Sincerely,
Patricia Morton

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Comment From: Kevin Gallagher

8/29/24 @ 2:13 AM

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Comment From: Jonathan Betz-Zall

8/29/24 @ 2:12 AM

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Comment From: Ellen Rumel

8/29/24 @ 2:11 AM

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Comment From: Karen Mensinger

8/28/24 @ 8:07 PM

Above all else, the people of Washington and Oregon, and the Columbia River must be protected from any further possible leaks of radioactive waste! The leaking tanks must be sealed and transporting any waste out of the Hanford Project forbidden!

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Comment From: David Turnoy

8/28/24 @ 4:23 PM

I'm deeply concerned that
Hanford's High Level Nuclear Waste tanks continue to leak without any action
to stop the leaks. Since the public meetings on the Agreement were held in July,
USDOE has announced that a third tank is now leaking. USDOE clearl...↓

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Comment From: John and Polly Wood

8/28/24 @ 12:44 PM

You all know the reasons that the general population resists and rejects your plan to ship liquid radioactive waste through the state. Our family is one of those. We know it is important to do something about the waste, but we also recognize (as do y...↓

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Comment From: David McCracken

8/28/24 @ 12:39 PM

I'm writing to request that nuclear waste from Hanford not be shipped by truck through Spokane, Oregon or over mountain passes when an alternative exists to solidify the waste before disposing of it. This is dangerous stuff: we do not want it contam...↓

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Comment From: City of Bend Oregon (Jeff Wyatt)

8/28/24 @ 12:27 PM

See attached comments from the City of Bend, Oregon forwarded by the Oregon Hanford Cleanup Board by request of Carrie Karl

Director of Risk and Emergency Management

City of Bend

Attachments:

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Comment From: Anonymous Anonymous

8/28/24 @ 11:43 AM

Hello and thank you for the opportunity to comment. Over thirty years ago I worked on a documentary about Hanford's toxic legacy, and am stunned (but sadly not surprised) that the dangers have not been meaningfully addressed in the intervening decade...↓s.

Now it's 2024 and once again efforts to meaningfully address the ongoing crises fall short. I'm deeply concerned that Hanford's tanks continue to leak without any action to stop the leaks. The Agreement must include enforceable requirements to remove leakable liquids from leaking tanks starting next year, and to prioritize full retrieval of wastes from the tank farms that have leaking tanks. Is this so much to ask? It is not acceptable to let those tanks keep leaking until sometime after 2040. How is it that we continue subsidizing pollution all over the nation yet lag so hard on cleaning up messes dating back to the mid 20th century?

Additionally, Washington State and Ecology need to adopt conditions that ensure the
wastes will be treated and solidified before shipment through Spokane or
Oregon. Treatment and solidification before shipment is available and a
necessary mitigation measure for inherently greater risks from shipping liquid
wastes. This is a no-brainer--it would be grossly negligent to do otherwise. And under SEPA, Ecology has a duty to adopt such a mitigation measure before it can adopt any USDOE NEPA finding of no significant impact or that impacts were discussed in an outdated EIS 25 years ago.

Pursuant to federal and state hazardous waste laws--and proper care for the health of one's neighbors, the general public and the wildlife of the Pacific Northwest--removal of leakable liquids is required "as soon as practicable." The Agreement fails to include any commitment to meet this fundamental environmental protection standard. If removal of liquids from a leaking tank is documented as not being practical, then that tank should be prioritized for early retrieval.

The agencies must also explain the rationale for why they did not include the tank farm with leaking tanks (T Farm) to be amongst the 3 tank farms they chose to be retrieved by 2040 in the Agreement. Not only is 2024 a grossly slow timeline that keep sour communities in danger--it doens't even include all of the leaking tanks!

Lastly, an EIS is required to review the impacts of decisions, such as not retrieving waste from leaking tanks; and to present reasonable alternatives to stop the leaks and speed up retrieval before more tanks leak.

Thank you again for the opportunity to comment and for considering our comments.

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Comment From: Richard Ellison

8/28/24 @ 9:59 AM

August 28, 2024

Commenting on Hanford's Proposed amendments to Tri-Party Agreement and Consent Decree

Hello,

I visited the Hanford site with a congressional aide tour in 1985. At that time if became obvious that Hanford officials were deliberately...↓

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Comment From: Derek Dexheimer

8/28/24 @ 9:54 AM

Appropriate, vigorous action must be taken NOW to empty leaking tanks and remediate their waste into a safe form before shipping, not in 2040.

Hanford's single-shell radioactive waste tanks are leaking NOW, and no adequate action is being taken to s...↓

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Comment From: Elena Rumiantseva

8/28/24 @ 9:40 AM

I'm deeply concerned that Hanford's High Level Nuclear Waste tanks continue to leak without any action to stop the leaks. Since the public meetings on the Agreement were held in July, USDOE has announced that a third tank is now leaking. USDOE clearl...↓

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Comment From: Dwight Rousu

8/28/24 @ 9:30 AM

Leaking tanks must be prioritized for removal of all leakable liquids or full
retrieval. Leaking tanks cannot be allowed to keep leaking until 2040 or later.
USDOE needs to commit to immediate action to stop or reduce the leaks
from Single Shell Tank...↓

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Comment From: Lynne Ashton

8/28/24 @ 8:51 AM

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Comment From: Burbank Neighborhood Assoc. (Lee Riner)

8/28/24 @ 8:34 AM

hELLO;
Hanford's High Level Nuclear Waste tanks continue to leak without any action
to stop the leaks. Since the public meetings on the Agreement were held in July,
USDOE has announced that a third tank is now leaking. USDOE clearly knew
about this l...↓

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Comment From: Carol Van Strum

8/28/24 @ 8:28 AM

I strongly support accelerating removal of waste from tanks in the 200 West
Area. This is where 2 of the 3 tanks that are currently leaking are located.
Acceleration is only possible if this waste can be treated and solidified into a
grout and dispos...↓

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Comment From: West Seattle Administrative & ... (Susan Baker)

8/28/24 @ 8:09 AM

High Level Nuclear Waste tanks are leaking and the contamination is spreading to the groundwater that flows to the Columbia River. But will anything be done to stop the leaks as required by federal and state hazardous waste laws?

The USDOE and Washi...↓

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Comment From: Patrick Henry

8/28/24 @ 7:35 AM

Stop the leaks.
Protect our waters.
Solve this problem now.

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Comment From: Aliah O'Neill

8/28/24 @ 3:52 AM

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Comment From: Aliah O'Neill

8/28/24 @ 3:52 AM

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Comment From: Ian Freeman

8/28/24 @ 3:50 AM

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Comment From: Tonya Enger

8/28/24 @ 3:49 AM

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Comment From: Tonya Enger

8/28/24 @ 3:49 AM

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Comment From: Pedro de la Torre III

8/28/24 @ 3:48 AM

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Comment From: Pedro de la Torre III

8/28/24 @ 3:47 AM

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Comment From: Thomas Gordon

8/27/24 @ 5:54 PM

The "holistic" agreement looks more like Swiss cheese than a reliable document.
To begin with, the nearby Indian tribes should have been included.
Also, hearings should have been included where transported LAW waste is proposed to p...↓