Advocate’s Guide to 324 Building
Last Updated: October 21, 2024
324 Building Updates
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324 Building Updates -
OCT 2024 UPDATE: At a recent committee meeting for the Hanford Advisory Board, USDOE gave an update on plans for 324 Building cleanup (watch the video). USDOE, through its contractor, is finalizing a Draft Focused Feasibility Study that looks at two options for 324 Building cleanup. That study will go to EPA for review and eventually out for Tribal consultation and public review with an accompanying Draft Proposed Plan for 324 Building cleanup.
The two options being considered include:
Remove Some Contamination First, Then Demolish the Building and Finish Cleanup: Update some internal building infrastructure and remove as much high-level contamination as possible. Then demolish the building, build a structure around the site, and remove the remaining contamination. This option will get some contamination out sooner, but will take longer in total because of the need to redo the design, make modifications internally, dig out soil, and THEN start the demolition of the building.
Demolish Building First and Then Remove Contamination: Start by demolishing the building, build a structure around the site, and then remove the contamination. The recently released Hanford 5-Year Plan assumes option 2, which references completing the demolition of the building in FY 2029. A decision has not yet been made.
Other options are not currently being considered, but comments and input from EPA, workers, Tribes, and the public could help in the creation of other ideas to consider. For example, some workers are extremely concerned about worker exposure during the cleanup and have recommended that the building go “Cold and Dark” to let the contamination decay to safer levels prior to doing any demolition or cleanup work.
The good news is that the public will have at least 30 days to review and comment on both the Focused Feasibility Study and the Draft Proposed Plan before a decision is made.
In the Q&A that followed the presentation a few things were clarified including:
324 Building is currently a Category 2 Nuclear Facility. The categorization of the building triggers different requirements. It is not “Cold and Dark” or in “Min Safe” or “D&D.”
The nearly 1,000 R/hr reading of contamination found under the building in Aug 2022 is 11 feet below the hot cell. The exact reading was 984 R/hr.
A 775 R/hr reading of contamination is 13 feet below the hot cell.
USDOE is anticipating that they will have to excavate soil very deep to get all of the contamination, but did not have an estimate of how deep yet.
Concerns were raised about how the building demolition would be conducted—whether it would be done under a contained structure or open air. There were also concerns raised about water/fixative (which is used to prevent the spread of airborne contamination) driving the contamination further into the ground.
Water was sprayed in the airlock and there is some concern that the contamination is right under the airlock and may impact the spread of contamination. There was some confusion that the water was sprayed in the hot cell, but it was sprayed in the airlock.
The Defense Nuclear Facility Safety Board has been briefed and kept apprised.
In some of the samples they have found more cesium than strontium, which was unexpected. They are trying to figure out why this is happening.
Characterization (sampling to get data about the extent of contamination) has been conducted from Aug-March 2023 with borings in the northeast, south, west, and east sides of the building footprint. They got an 1R/hr reading on the east side, which they were not expecting.
The waste that is excavated is planned to be disposed of at the Environmental Restoration Disposal Facility (ERDF) in shielded containers. Some of the waste would be mixed with grout. The waste will be sampled to ensure that it meets the disposal criteria for ERDF.
The changed cleanup plan is not opening up the entire 300 Area Record of Decision, just the part relevant to 300-296 (324 Building). Decisions about 618-11 and uranium sequestration will not be opened up as part of this process.
They are looking at wells, making sure they are in a good position to catch contamination if it migrates out of the building footprint.
The timing of seeing the Focused Feasibility Study and Draft Proposed Plan for 324 Building is estimated for spring 2025.
JAN 2024 UPDATE: EPA and DOE are continuing to meet and are looping in Ecology to evaluate different options for 324 Building cleanup and map out a schedule of next steps. During the Jan 16 Oregon Hanford Cleanup Board meeting, Dave Einan of EPA announced that DOE is working on a limited focus feasibility study that will be used to determine next steps and evaluate options that will eventually lead to an amendment of the Record of Decision (ROD) for the 324 Building. Though it sounds like the next formal opportunity for public comment would be after a Proposed Plan is issued (and there are many steps that would need to occur before the Proposed Plan), there may be more informal updates in 2024. During this process to determine how 324 Building cleanup work needs to change, which will include opportunities for public input, some limited work will continue at 324 Building. A December 2023 letter from DOE to EPA outlines the projects that “are limited to those not inconsistent with the ROD” and will continue while the agencies figure out the path forward.
OCT 2023 UPDATE: USDOE started meeting with EPA after EPA shared its frustration in Aug with being kept in the dark about problems with 324 Building cleanup and left out of conversations between US DOE and its contractors to rework cleanup plans, and after the Sept 2023 update on 324 Building for the Hanford Advisory Board that contained information EPA was also hearing for the first time. We’re so glad that these meetings are taking place, but EPA should have been involved from the beginning - let’s hope this is a lesson learned for the future. Stay tuned!
The Defense Nuclear Facilities Safety Board report on September 8, 2023 shared information about another worker contamination event at the 324 building:
“Building 324: Following an entry into the Radiological Engineering Complex hot cell airlock to troubleshoot issues with the A Cell crane, a worker alarmed a personal contamination monitor. Radiological control technicians were able to identify the source and decontaminated them successfully. This is the first skin contamination event since radiological work was paused after a series of personal contamination events at the facility (see 11/19/2019 report). A resident inspector observed a critique held after the event and noted that participants were forthcoming with their observations and concerns. Two workers in the airlock had contaminated oil on their outer set of anti-contamination clothing, which was not successfully wiped off prior to doffing. In addition, the contaminated worker had sweated considerably, which could transport contaminants through his anti-contamination clothing. While no direct cause could be readily determined, the work had been delayed and then extended to add a new scope of work that had not been briefed that morning. Based on the critique meeting, facility management has paused airlock entries pending further evaluation by contractor performance assurance.” (Sept 8, 2023 DNFSB report)
On August 23, 2023, Central Plateau Cleanup Company (CPCCo) president John Eschenberg gave Hanford Advisory Board the first public briefing about big changes for 324 Building cleanup since we learned that work was shut down. (Video recording, PDF) This is what we learned:
Work stopped when DOE and its contractor, CPCCo, realized the contaminated soil under the building is worse than expected - way hotter (radioactively) and way bigger (than existing equipment can reach).
U.S. Department of Energy and CPCCo think the better approach right now is to dig it up later: deactivate the building (get rid of water, electric, gas), grout the contaminated “hot cells” in 324 Building, knock down the building to “slab on grade” (flush with the ground), build a structure over it, and dig up the contamination later. (No specificity was shared about how much later.)
Workers haven’t been consulted to get their input on how to proceed with a problem that is bigger than the existing solution can fix. (Spoiler, we think they should be involved.)
Much to our dismay, U.S. Environmental Protection Agency has not been consulted on how to move forward and sent a letter calling this out. We agree that as regulator of 324 Building cleanup, EPA needs to be at the table discussing options for protecting workers and the environment from this lethally radioactive waste.
With new data from horizontal probes, Pacific Northwest National Library (PNNL) modeled that the contaminated soils contain closer to 740,000 curies (around four times the original projections), which is decay adjusted and is consistent with what would be expected from the 135 gallon spill from 1986. Original spill contained 1.3 million curies of Cesium-137 and Strontium-90.
Infrastructure issues are giving workers more dose and slowing down the work, with 30 workers needed to suit up to go into highly radioactive spaces to fix cranes and shield doors that keep breaking. [1]
Hanford Challenge provides this Advocate’s Guide to 324 Building as a public resource for drafting public comments, providing testimony, and other advocacy work and to generally help assist the public’s overall understanding of the history, issues, and current status of 324 Building.
324 Building is located about 1.5 miles north of Richland, WA, and about 300 yards west of the Columbia River in the 300 area of Hanford Nuclear Site. Originally a nuclear research and development facility, 324 Building contains radiological and non-radiological laboratories, “hot cell” facilities for high-level radiological activities, support facilities, and administrative areas. Since decommissioning and cleanup efforts for 324 Building began, work has been delayed and halted several times due to contamination of radioactive cesium and strontium into the soil beneath 324 Building’s B Cell (designated the 300-296 Waste Site).
Photos and Information Courtesy U.S. Department of Energy [2]
QUESTIONS/CONCERNS/GOALS:
Lack of Broad-Based, Meaningful Involvement.
Regulator and worker participation. We would like the Environmental Protection Agency (EPA), our federal regulator for Hanford, and 324 Building workers (who know the issues intimately from working on this cleanup for years), involved in determining the path forward.
Public Involvement. If the remedy is going to change, we support the approach to start at the beginning with data analysis and put together a new proposed plan for 324 Building cleanup. It is important to present well vetted options in a formal public comment period to ensure that the public gets a chance to weigh in.
Tribal Consultation. We are assuming that Tribal Nations will be consulted on 324 Building cleanup. If that isn’t happening, then please make it a priority.
Lack of Transparency.
More transparency is needed. The August 23, 2023 briefing CPCCo president John Eschenberg gave to Hanford Advisory Board was a good start and it was well done with clear information shared in language that was accessible. However, we want more broadly reaching and accessible presentations and briefings that share the positives and negatives of different approaches as agencies troubleshoot how to proceed.
Hanford Challenge was able to track down references to issues with the 324 Building prior to the June 29, 2023 email, which shared the change in plans due to higher than expected radiation levels. We are concerned with the lack of transparency in openly sharing information and updates with the public and workers about the status of the project. Even the 324 Building fact sheet updated in July 2023 isn’t clear about the timeline of work or changes. The fact sheet, updated slightly in Aug 2023, is also unclear about the timeline of work and changes.
In documents we found starting in September 2022, U.S. DOE makes reference to, “Unexpected elevated radiological readings encountered work paused for assessment of work controls.” A December 2022 document references 324 Building readings of 850-900 rad for the dose.
In letters going back and forth between U.S. DOE and EPA, it is clear that there were major issues identified before June 29 that could have been shared with the public and workers. (4/25/23 EPA to U.S. DOE letter, 5/16/23 U.S. DOE to EPA letter, 6/22/23 EPA to U.S. DOE letter, and 7/5/23 U.S. DOE to EPA letter)
In a July 2023 updated fact sheet on 324 Building U.S. DOE states, “Due to the larger volume of contaminated soil under the building and the additional challenges of maintaining an aging facility, DOE and CPCCo changed previous demolition and remediation plans to an approach that is safer for workers and the community and is still protective of the Columbia River.
Working with the U.S. Environmental Protection Agency, DOE and CPCCo are resequencing the work. Crews will demolish the building first, then construct a containment superstructure over the remaining foundation and remediate the contaminated soil below.” It’s still unclear what the implications are to the timing. Does this mean the facility is going cold and dark?
The Aug 2023 fact sheet updates this language to: “Working with the U.S. Environmental Protection Agency, DOE and CPCCo are resequencing the work. Crews will deactivate the facility, which includes grouting the B Cell and fixing in place any contamination; demolish the building; then construct a containment superstructure over the remaining foundation and remediate the contaminated soil below.” We would like to note that EPA has written in an Aug 22, 2023 letter that “DOE’s proposal to change the sequence of work at the 324 Building appears to have been solely developed by DOE and its contractors, without collaboration with EPA.”
Inconsistent information U.S. DOE shared with the Hanford Advisory Board prior to August 2023 has caused confusion and led many to speculate whether information is being withheld or misrepresented.
In a Hanford Advisory Board meeting on April 19, 2023 we directly asked Brian Vance if U.S. DOE is expecting delays to the 324 Building cleanup. The answer we received was, “no impact to schedule.”
We appreciate that U.S. DOE brought CPCCo to present an update on 324 Building at the August 23, 2023 Hanford Advisory Board meeting. The presentation was clear and presented in plain language which was much appreciated. (Video Recording, PDF)
Lack of information shared with workers about the status of 324 Building work/cleanup prior to the June 2023 announcement. A 324 Building worker who attended the HAB meeting briefing, shared that that was the most information they had received to date.
High-Level Waste?
Is the contaminated soil under the 324 Building high-level waste? How is DOE differentiating between high-level waste and high-level waste contaminated soil?
Many have expressed concerns about the waste classification process, including Hanford Challenge, Columbia Riverkeeper, Yakama Nation, and Oregon Department of Energy.
On Aug 30, 2023, US DOE responded to the Oct 18, 2022 Yakama Nation letter regarding the designation and disposal of 324 building waste at ERDF (generated during the 300-296 waste site cleanup).
In US DOE’s Aug 30th letter DOE claims that “neither the spilled material nor contaminated soils are HLW.”
US DOE follows this up later in the letter by saying the waste may be disposed of at the Environmental Restoration Disposal Facility: “Based upon a rigorous evaluation, DOE has determined that the contaminated soils in their final waste packages are not expected to exceed Class C concentration limits, are expected to meet the ERDF WAC [Waste Acceptance Criteria], and are expected to meet the performance objectives for disposal of LLW so that the soils can be disposed of at ERDF as LLW.”
Contamination Spread, Monitoring, & High RAD Readings.
Data is still being gathered to understand the full extent of the contamination underneath 324 Building.
Proximity to the City of Richland and its drinking water intake.
Risks to groundwater, the Columbia River, and the surrounding habitat.
Consistent delays and newly discovered issues. The potential of 324 Building entering a cold/dark/entombed status.
Newly discovered issues causing monitoring delays, such as encountering boulders while measuring radioactivity levels in the soil. We’re hoping more information is shared publicly and transparently about these issues.
Protecting Worker Health & Safety.
We support decisions that protect workers and want to ensure that worker health and safety is at the forefront as plans to clean up 324 Building are resequenced.
As workers retire, there is a loss of institutional knowledge. What happens to knowledge gained to date about 324 Building B-Cell cleanup while the building is in cold/dark status awaiting cleanup at a future date?
324 BUILDING TIMELINE
*Please note: Hanford Challenge will continue to add to this timeline past and present as more documents and information become available*
TIMELINE SUMMARY:
The basic pattern with 324 Building is the repeated discovery that the contamination situation is worse than expected.
In 2010, U.S. DOE announced that there was unexpectedly high contamination under B-cell, a room in 324 Building that was used for research and testing. One 1980’s test involved a spill of 1.3 million curies of radioactive strontium, cesium, and other contaminants, which is likely how the soil was contaminated. In 2010, work pivoted to a slower cleanup plan to address the extremely hot waste under the building. In 2019, they halted work to improve worker health and safety protections after a series of worker exposures. In 2022, work was halted again when U.S. DOE found another unexpectedly high reading in a place they weren’t expecting contamination to show up. Work has halted again in 2023 as U.S. DOE and EPA consider what to do next.
Workers have been preparing to remotely excavate the soil under B-cell, characterize the waste, immobilize it, and dispose of it.
Since September 2022, red flags have been popping up in public meeting minutes, DNFSB reports, and snippets of information shared with the Hanford Advisory Board that cleanup is not going well.
In July 2023 news was shared that cleanup plans are changing because the waste is more widespread and more radioactive.
The Aug 2023 the Hanford Advisory Board received a more detailed briefing from 324 building contractor, CPCCo.
Going forward, we’d like more transparent information about the 324 Building cleanup that is easily accessible. Before cleanup plans are finalized, it is important that Tribes are consulted and that the public has a formal chance to comment on the plan.
cONTAMINATION OVERVIEW:
*Please note: this is based on notes taken from a presentation provided by CPCCo to the Hanford Advisory Board.
Originally, U.S. DOE estimated that there were 175,000 curies (we are waiting for confirmation this number but until video is posted of the recorded presentation - the presenter ) in the contaminated soil that they needed to remove. With new data from horizontal probes, PNNL modeled that it is closer to 740,000 curies, which is decay adjusted and is consistent with what would be expected from the 135 gallon spill from 1986. Original spill contained 883,000 curies of Cs-137 and 388,000 curies of Sr-90.
With new data from horizontal probes, PNNL modeled that the contaminated soil contains to 740,000 curies, four times the original curie estimate. The new estimate is decay adjusted and is consistent with what would be expected from the 135 gallon spill from 1986. Original spill contained 1.3 million curies of Cesium-137 and Strontium-90 as reported in a 1993 document [footnote 5].
It is 1R/hr 30 feet below grade.
The division between higher and lower contamination is 23 feet below grade.
The highest dose that CPCCo found was 900R/hr. They did a survey every foot along the 100 ft of probe, so every foot they took a reading and recorded those data points. They logged the highest readings per point.
The highest dose recorded before CPCCo took over the project was 13,000 R/hr
CPCCo estimates that they need to remove 25,000 cubic feet of contaminated soil. 6,600 cubic feet of that is in the high rad area. They have high confidence in this footprint of contamination because the additional soil borings around the perimeter of the hot cell had low levels or no levels of contamination at 15-20 feet down.
No information shared about the timeline if slab on grade approach is used - how long will it sit before it is remediated?
Originally they estimated that there were 175,000 curies in the contaminated soil. The highest recent readings from soil are at 900 rad/hr. This is wicked hot. Since radiation decays (gets less radioactive over time), delaying cleanup to let the radiation decay is often a strategy to protect workers as long as the contamination doesn’t spread in the environment or contaminate groundwater.
1964-1966:
324 Building was constructed as a Fuel Recycle Pilot Plant, but it was known as the Chemical Materials Engineering Laboratory throughout most of its history. [3]
1966-1996:
324 Building operated as a nuclear research and development facility. [4]
1986-1990: 324 Building workers operated a program on cesium heat source manufacturing for the Federal Republic of Germany. [5]
1986: Workers identified contamination in 324 Building’s B Cell of 1.3 million curies of concentrated cesium and strontium. Reportedly, the contamination “reached the cell floor but apparently did not flow beyond the dust and debris on the floor.” [6]
1993: U.S. DOE documents B Cell issues in its High Activity Radioactive Waste Issues at Hanford report. [7]
1997:
Memo on Acceptance of the Federal Republic of Germany Isotopic Sources of Radiation and Heat. [8]
2001:
Strategic Planning for Hot Cell Closure report documents B Cell leaks. [9]
2010:
324 Building work halted due to a spill of radioactive cesium and strontium into the soil beneath B Cell. [10]
2011:
324 Building workers inserted probes under a recently demolished portion of 324 Building “recorded radiological doses in excess of 14,000 R/hr in the soil beneath B-Cell.” [11]
2012:
The Site’s 325 Building Radiochemical Processing Laboratory performed analytical data and subsequent waste designation, in accordance with Washington Administrative Code § 173-303-070, and confirmed the soil contamination is “high-activity, low-level radioactive waste” and thus, not designated as “dangerous waste.” [12]
2017:
324 Building workers began early steps of clean up and demolition. [13]
2019:
324 Building work halted due to a worker exposure (the 8th worker exposure on site in 2019). In response, U.S. DOE required a plan of correction. [14]
2020-2021:
Delays to 324 Building clean up and demolition proposed by U.S. DOE due to off-site factors such as COVID-19 and annual budget. [15]
2022:
August 29, 2022: Central Plateau Cleanup Company (CPCCo) work crews detected additional, unexpected soil contamination under 324 Building during stabilization efforts. [16]
U.S. DOE did not release detailed analysis on the newly detected contamination; however, reports later released indicate a 984 R/hr hotspot found at the end of 2022. [17]
2023:
MARCH:
March 3, 2023: The Defense Nuclear Safety Board reported that U.S. DOE stopped work at 324 Building “when they determined that repetitive use work documents (RUWDs) were being used incorrectly to perform some work activities.” [18]
March 8, 2023: At the River and Plateau Committee meeting, U.S. DOE provided an update that workers must continue to gather data to determine the source, extent, and boundaries of the “newly discovered” soil contamination under 324 Building because boulders encountered while drilling boreholes prevented sample gathering. The composition of the waste contaminating the soil must be confirmed to determine the path forward, including disposal location. U.S. DOE expected to finish mapping the contamination levels by the end of April (unfortunately, the status on the final mapping has not been shared with the public to date). [19]
March 16, 2023: The Tri-Party Agreement Quarterly Milestone Review Meeting for the Central Plateau/River Corridor provided that U.S. DOE “reported that additional horizontal characterization holes were drilled above and below the 984 R/hr hotspot. However, the data has been significantly different than expected so they are pulling more data and running additional characterization above the hotspot and in other areas around to figure out what is happening.” [20]
March 17, 2023: The Defense Nuclear Safety Board reported that a wire rope lifting a 5-ton crane shield door for 324 Building’s D Cell broke causing the door to slam shut. [21] Work halted, [22] but information was lacking.
APRIL:
April 3, 2023: U.S. DOE paused work related to 324 Building structural stabilization while Pacific Northwest National Laboratory evaluated new soil characterization data. [23]
April 25, 2023: U.S. EPA wrote a letter to U.S. DOE to express its concern that the work pause may impact the Tri-Party Agreement milestones. [24]
MAY:
May 2, 2023: Washington State, U.S. DOE, Washington State Department of Ecology (Ecology), and the U.S. Environmental Protection Agency (EPA) announced a conceptual agreement in Hanford Site holistic negotiations. [25]
May 16, 2023: U.S. DOE’s reasons for halting work at 324 Building include: “high contamination was found in areas beneath the 324 Building outside the boundaries of the current remediation design, unexpected underground interferences and obstructions prevent installation of the current structural stabilization design, and the 324 Building was constructed in the 1960s, and the facility continues to be plagued by the failure of critical equipment, including hot-cell cranes and doors, required to support remediation of the waste site.” [26] These issues jeopardize 324 Building’s M-016-85A milestone of the Tri-Party Agreement, [27] which states that DOE will “complete remote excavation of the 300-296 waste site in accordance with an approved Remedial Design/Remedial Action Work Plan,” by November 30, 2025. [28]
JUNE:
June 22, 2023: U.S. EPA wrote to U.S. DOE to address U.S. “DOE’s intent to propose a change in the selected remedy for 324 Building and surrounding waste sites in the near future.” In the letter, U.S. EPA reminds U.S. DOE that (1) the Record of Decision (2013 ROD) set remedial actions for 324 Building and (2) amending the 2013 ROD must comply with the Tri-Party Agreement and applicable law. [29]
June 29, 2023: U.S. DOE announced to Hanford workers in an employee message that work at 324 Building was “paused after crews discovered a significant amount of additional soil contamination under the building.” Given the changed condition, U.S. DOE in coordination with U.S. EPA work to develop a new plan intended to be “safer for the workforce, protective of the environment and effective in completing the mission.” “Any changes to the cleanup approach will follow applicable regulatory processes including, as appropriate, soliciting tribal and public input.” [30]
JULY:
July 2023: U.S. DOE updated the 324 Building Disposition Project fact sheet background and future plans for resequencing work at 324 Building “due to the larger volume of contaminated soil under the building” confirmed by analysis by CPCCo and Pacific Northwest National Laboratory “and the additional challenges of maintaining an aging facility[.]” [31]
July 5, 2023: U.S. DOE wrote a response to U.S. EPA’s June 22, May 16, and April 25 letters providing a timeline of events and expressing its intent “to determine the best path forward to achieve a safe and efficient remedy” for 324 Building and its underlying contaminated soil. [32]
AUGUST:
August 22, 2023: Letter from EPA to US DOE stating “DOE’s proposal to change the sequence of work at the 324 Building appears to have been solely developed by DOE and its contractors, without collaboration with EPA.”
August 23, 2023: Central Plateau Cleanup Company (CPCCo) president John Eschenberg gave the Hanford Advisory Board the first public briefing about big changes for 324 Building cleanup since we learned that work was shut down. New information about the problem:
The contaminated soil under 324 Building’s B-cell (where a lot of experiments were conducted) is a result of a spill in 1986 that included 883,000 curies of Cesium-137 and 388,000 curies of Strontium-90.
CPCCo and Pacific Northwest National Library (PNNL) are estimating that the leak of contamination was active from 1986 to 1992 until they were working with grout in B-cell and it plugged up the sump which stopped the leak.
Contractor Washington Closure Hanford found the leaked waste in 2009.
From 2011-2013 they used geoprobes to get temperature and radiation readings under the building. The highest readings since the contamination was found were at 13,000 rad/hr.
Because of trouble getting horizontal borings under the building, the extent of contamination was underestimated.
Once they got the borings to go through, they found that the contamination was much bigger and hotter than they thought.
The equipment/approach in the current plan uses remote excavators. But, since they thought the area of contamination was smaller, they realized that they can only get a quarter of the contamination with the remote excavators they have on hand.
There is also an issue with degrading infrastructure that is creating problems logistically and also increasing dose rates to workers as they go in to repair broken equipment needed to do the work. For example, the presenter referenced that if a crane breaks, or a hot cell door fails, it takes 30 workers going into the airlock to make a repair and every time they do this each worker gets 250 mrem of exposure. So the maintenance burden is high, and so is the exposure risk to workers. A U.S. DOE rep mentioned that two cranes broke in the last week.
The presenter mentioned a concern that if they start digging into B-cell’s floor, it could undermine the structural integrity of the building. We’re not clear about whether this was solved by the structural supports that have been installed or not. They did put in a lot of structural supports including:
13 micropiles to fortify the hot cell structurally. The micropiles are 2ft wide and 30ft long.
42 horizontal borings 60-110 ft from outside the building, under the building and airlock. THey are installed and injected with polyacrylamide
162 other mini micropiles in a U shape around B-cell. [33]
August 30, 2023: US DOE letter responding to the Yakama Nation concerns related to disposal of 324 building waste [34]
SEPTEMBER:
September 8, 2023 Defense Nuclear Facilities Safety Board report shares worker contamination event:
“Building 324: Following an entry into the Radiological Engineering Complex hot cell airlock to troubleshoot issues with the A Cell crane, a worker alarmed a personal contamination monitor. Radiological control technicians were able to identify the source and decontaminated them successfully. This is the first skin contamination event since radiological work was paused after a series of personal contamination events at the facility (see 11/19/2019 report). A resident inspector observed a critique held after the event and noted that participants were forthcoming with their observations and concerns. Two workers in the airlock had contaminated oil on their outer set of anti-contamination clothing, which was not successfully wiped off prior to doffing. In addition, the contaminated worker had sweated considerably, which could transport contaminants through his anti-contamination clothing. While no direct cause could be readily determined, the work had been delayed and then extended to add a new scope of work that had not been briefed that morning. Based on the critique meeting, facility management has paused airlock entries pending further evaluation by contractor performance assurance.” (Sept 8, 2023 DNFSB report)
DECEMBER:
December 7, 2023 US DOE responds to the letter US EPA wrote in August 2023. The letter includes a list of short-term and long-term activities that are consistent with the ROD and can occur while discussions continue between US DOE, US EPA, and CPCCo to determine the CERCLA post-ROD process.
ADDITIONAL RESOURCES:
Columbia Riverkeeper: Deadly Radioactive Waste 1000 Feet From the Columbia River
Oregon Department of Energy: Historic Hanford Contamination is Worse Than Expected
Oregon Public Broadcasting: Feds say Hanford’s building has more waste under it than previously known, float new plan for cleanup
Tri-City Herald: Highly radioactive spill near Columbia River in E. Washington worse than expected
Stay Tuned for Updates and Public Comment Opportunities on the 324 Building
[1] Hanford Advisory Board Meeting (August 23, 2023) (Central Plateau Cleanup Company president John Eschenberg gave Hanford Advisory Board the first public briefing about big changes for 324 Building cleanup). Video Recording Link, PDF of Presentation.
[2] 324 Building, U.S. DOE (Last Updated 07/05/23); Hanford Virtual Tour, U.S. DOE. See also Taking a Look at the 324 Building …, TRI-CITY HERALD (11/21/19); 324 Building B Cell Contamination, U.S. DOE (11/2010).
[3] Multiple Missions: The 300 Area in Hanford Site History, U.S. DOE OFFICE OF ENV’T RESTORATION & WASTE MGMT. at 48-51 (09/1993).
[4] 324 Building, U.S. DOE (Last Updated 07/05/23).
[5] Multiple Missions: The 300 Area in Hanford Site History, U.S. DOE OFFICE OF ENV’T RESTORATION & WASTE MGMT. at 51 (09/1993).
[6] Evaluation of Options for Disposition of Dispersible Material in B-Cell, PACIFIC NW NATIONAL LABORATORY (prepared for U.S. DOE under contract) at 1.1 (10/1993).
[7] High Activity Radioactive Waste Issues at Hanford, U.S. DOE (04/30/1993).
[8] German Logs Waste Designation, FLUOR DANIEL HANFORD, INC. (08/07/97) (made available online by Hanford Challenge).
[9] Strategic Planning for Hot Cell Closure, U.S. DOE (04/30/1993).
[10] River Corridor Closure Project: 324 Bldg. B Cell Contamination, U.S. DOE (11/10); Highly contaminated soil found at Hanford, TRI-CITY HERALD (11/18/10).
[11] 324 Building Dangerous Waste Management Units Closure Plan, U.S. DOE at H-4 (06/07/16); Numerical Modeling of 90Sr and 137Cs Transport from a Spill in the B-Cell of the 324 Building, Hanford Site 300 Area, PACIFIC NW NATIONAL LABORATORY (prepared for U.S. DOE under contract) (03/12).
[12] 324 Building Dangerous Waste Management Units Closure Plan, U.S. DOE at H-4 (06/07/16); Numerical Modeling of 90Sr and 137Cs Transport from a Spill in the B-Cell of the 324 Building, Hanford Site 300 Area, PACIFIC NW NATIONAL LABORATORY (prepared for U.S. DOE under contract) (03/12).
[13] Workers Prepare to Tackle Hanford’s Potentially Deadly Spill, TRI-CITY HERALD (05/03/17).
[14] Contamination Stops Work …, KING5 NEWS (11/21/19); … 8th Worker Exposure This Year, TRI-CITY HERALD (11/21/19).
[15] Cleaning up Hanford’s ‘Greatest Risk’ and Other Radioactive Waste Could be Shelved for 10 Years, TRI-CITY HERALD (03/10/2020); ‘Disappointed.’ WA Sen. Murray puts Energy Secretary on Hot Seat Over Hanford Cleanup, TRI-CITY HERALD (05/05/2022).
[16] Response to June 22, 2023, U.S. Environmental Protection Agency Letter Re: Addressing Changed Conditions at the 324 Building and Underlying Soils, U.S. DOE at 1 (07/05/23) [provides the date additional soil contamination was discovered, August 29, 2022]; 324 Building Disposition Project, U.S. DOE (07/23).
[17] Tri-Party Agreement Quarterly Milestone Review Meeting Minutes for the Central Plateau/River Corridor, U.S. DOE, U.S. ENV’T PROT. AGENCY, WA STATE DEPT. OF ECOLOGY at 2-3, 19 (03/16/23).
[18] Hanford Activity Report for the Week Ending March 3, 2023, DEF. NUCLEAR SAFETY BD. (03/03/23).
[19] River and Plateau Committee Meeting, HANFORD ADVISORY BD. (03/08/23); Draft March RAP Meeting Minutes, RIVER & PLATEAU COMM. at 3-5 (03/08/23).
[20] Tri-Party Agreement Quarterly Milestone Review Meeting Minutes for the Central Plateau/River Corridor, U.S. DOE, U.S. ENV’T PROT. AGENCY, WA STATE DEPT. OF ECOLOGY at 2-3, 19 (03/16/23).
[21] Hanford Weekly Report Ending March 17, 2023, DEF. NUCLEAR SAFETY BD. (03/17/23).
[22] EPA Notification of Concern Regarding Schedule Compliance with M-016-85A, U.S. EPA (04/25/23); Response to the U.S. EPA Notification of Concern Regarding Schedule Compliance With M-016-85A, U.S. DOE (05/16/23).
[23] Response to June 22, 2023, U.S. Environmental Protection Agency Letter Re: Addressing Changed Conditions at the 324 Building and Underlying Soils, U.S. DOE (07/05/23).
[24] EPA Notification of Concern Regarding Schedule Compliance with M-016-85A, U.S. EPA (04/25/23).
[25] WA, Federal Agencies Announce Conceptual Agreement in Hanford Site Holistic Negotiations, U.S. DOE (05/02/23).
[26] EPA Notification of Concern Regarding Schedule Compliance with M-016-85A, U.S. ENV’T PROT. AGENCY at 1 (05/16/23).
[27] Response to the U.S. Environmental Protection Agency Notification of Concern Regarding Schedule Compliance With M-016-85A, U.S. DOE (05/16/23).
[28] Tri-Party Agreement, Action Plan Appendix D, U.S. DOE, U.S. ENV’T PROT. AGENCY, WA STATE DEPT. OF ECOLOGY at D-4 (current as of 06/14/23).
[29] Addressing Changed Conditions at the 324 Building and Underlying Soils, U.S. ENV’T PROT. AGENCY (06/22/23).
[30] Highly Radioactive Spill near Columbia River in E. Washington worse than Expected, THE SPOKESMAN-REVIEW (06/29/23).
[31] 324 Building Disposition Project, U.S. DOE (07/23).
[32] Response to June 22, 2023, U.S. Environmental Protection Agency Letter Re: Addressing Changed Conditions at the 324 Building and Underlying Soils, U.S. DOE (07/05/23).
[33] Hanford Advisory Board Meeting (August 23, 2023) (Central Plateau Cleanup Company president John Eschenberg gave Hanford Advisory Board the first public briefing about big changes for 324 Building cleanup). Video Recording, PDF of Presentation.
[34] U.S. DOE Response to Yakama Nation regarding 324 building waste disposal AR-25832 (08/30/23).