Risk Based EMS Strategy

“Risk-Based” Environmental Management System Strategy Example DRAFT

Risk-Based Environmental Strategy TABLE OF CONTENTS 1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . 2 1.1 Purpose and Scope . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . 3 1.2 Environmental Management System ...... .................... 4 1.4 Superfund Implementation ................................. 4 2.0 HANFORD SITE MISSION AND OBJECTIVES ...................... 5 3.0 ENVIRONMENTAL POLICY ...................... 7 3.1 RL Environmental Policy ................................. 8 3.2 Tri-Party Agreement ..................................... 9 3.3 Pollution Prevention (P2) and Waste Minimization ................... 9 3.4 Integration of Environmental Regulatory ................................. 11 Strategies with Risk Basee End states Strategies 3.5 Guiding Principles . . . . . . . . . . . . . . . . . . . .. . . 11 4.0 REGULATORY STRATEGIES AND OBJECTIVES ....................... 14 4.1 Long-Term Objectives and Strategies ......... .................... 14 4.2 Key Near-Term Objectives ........................... 23 5.0 FIGURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . DRAFT

U.S. Department of Energy – Richland Operations Risk-Based Environmental Strategy 1.0 INTRODUCTION The U.S. Department of Energy (DOE) has transitioned from a mission of nuclear weapons material production to missions that range from environmental cleanup to the development and deployment of science and technology to address the nation’s environmental, energy, and national security needs. The environmental cleanup of the Hanford Site involves the safe treatment, storage, and final disposal of radioactive and chemical wastes, surplus nuclear materials, and spent nuclear fuels that remain at the Site. The RL Risk-Based Environmental Strategy reflects an approach to managing and monitoring environmental regulations that developed from an intensive “Top-to-Bottom Review” that emphasized the need to reduce risk rather than manage it. This document places an emphasis on management planning, workforce accountability, and innovation in the application of environmental regulations. As structured, this strategy document will assist RL and the Hanford Site contractors in accomplishing the accelerated cleanup of the Hanford Site; in the reduction of risk to the public, the workforce and the environment; and aid in the reduction of tax dollars applied to cleanup costs. The Risk-Based Environmental Strategy adopts an approach that is consistent with DOE Order 450.1, Environmental Protection Program. The Strategy provides central direction and challenge to RL’s project teams and then empowers them to meet the challenge. The intent is to establish regulatory priorities that will minimize the top-down flow of requirements and empower people to get work done safely and efficiently. Recognizing that an exclusive reliance on bottom-up initiatives tends to lead to disengagement and inefficiency, this Strategy is designed to provide sufficient application of requirements to point projects toward the source of regulatory requirements and give top-level uniform guidance on performance against those requirements. DRAFT

1.1 Purpose and Scope The RL Risk-Based Environmental Strategy was developed with a focus on eliminating unnecessary regulatory requirements while ensuring the safe, timely and complete closure of the Hanford site. The approach defined within this strategic document is to establish clearly defined regulatory endpoints; to reduce uncertainty (where it exists) regarding regulatory outcomes; to reduce DOE’s long-term environmental liability; and to define conclusive transitions of land and facilities from DOE-EM to the private sector or to other government agencies (i.e., U.S. Fish and Wildlife, Office of Legacy Management, etc.). Such critical regulatory decisions are independent of corporal completion, but must be instituted sooner rather than later to ensure the ability of the agency to achieve the accelerated cleanup and closure of the Hanford Site as defined within the DOE/RL Performance Management Plan for the Accelerated Cleanup of the Hanford Site (RL-PMP). RL has developed this strategy as a roadmap to understanding and attaining environmental regulatory compliance at Hanford. It provides high level decisions designed to ensure compliance with federal and state laws without applying regulations that do not provide assurance of a healthy end-state. The strategy considers all environmental regulations and articulates the way we will do business relative to the management of risk, obtaining permits, performing and documenting work, establishing priorities, meeting obligations and interacting with regulatory agencies and stakeholders. Transition of the site to future land users (whether it be DOE, another Federal agency, or a private entity) is the ultimate goal of this strategy. Integral to this goal is: (1) satisfactory completion of all CERCLA and RCRA activities; (2) completion of decommissioning and demolition (D&D); (3) documented transfer of land and facilities from DOE-EM to the ultimate stewards; and (4) the eventual de-listing of the Hanford site from the NPL. The baseline, goals, regulatory sunset provisions, and criteria for transition of the site to the final land user constitute the tools required to accomplish RL’s accelerated cleanup program. DRAFT

1.2 Environmental Management System The DOE/RL Environmental Management System (EMS) was instituted to implement the requirements of Executive Order 13148, “Greening the Government through Leadership in Environmental Management” by ensuring that DOE applies environmental accountability through fundamental and integral components of policies, processes, planning, and management. DOE O 450.1 Environmental Protection Program was approved and released by the agency on January 15, 2003. This Order provides direction to RL and it’s contractors for the effective implementation of sound stewardship practices that protect air, water, land, and other natural and cultural resources impacted by current and past DOE operations and by which the agency could cost effectively meet or exceed compliance with applicable environmental; public health, and resource protection laws, regulations, and requirements. This strategy further defines a program of improvements that when complete will ensure the implementation of an EMS that will be fully compliant with DOE O 450.1 and the E.O. All DOE/RL employees and contractors are the stewards of the Hanford environment, as clearly reflected in the Order. Satisfactory stewardship of the environment includes protection of natural, archeological, cultural, and historic resources, as well as the health of the public. DOE/RL is committed to achieving stewardship excellence by systematically integrating EMS principles into all aspects of work performed at Hanford. 1.3 Superfund Implementation On January 23, 1987, the President of the United States signed Executive Order (EO) 12580 entitled, “Superfund Implementation”. The EO delegated to various Federal officials the responsibilities vested in the President for implementing Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA). The EO and the National Contingency DRAFT

Plan (NCP) (the implementing regulations of CERCLA) are the basis of DOE’s authority to implement CERCLA at its facilities. The EO delegates the authority and responsibility to DOE, while the NCP describes EPA’s procedures for implementing the CERCLA program. Through the authorization of the EO, DOE is required to carry out a number of key functions, including, (1) providing representatives to the National Response Team (NRT), the interagency organization responsible for planning for and responding to CERCLA releases; (2) acting as a natural resource trustee for land that DOE manages; (3) performing natural resource damage assessments (NRDA); and (4) assuming authority for response actions resulting from releases of hazardous substances on, over, or under land that DOE manages. Because EO 12580 is the primary source of DOE’s delegated authority under CERCLA, it is important that DOE/RL develop and document strategies that ensure accurate and timely implementation of the authority that has been delegated to DOE through the EO and the NCP to conduct environmental restoration activities at its facilities. This perspective of DOE ownership of the CERCLA process will be incorporated into all of the strategic objectives and initiatives described hereafter. 2.0 HANFORD SITE MISSION AND OBJECTIVES The vision of DOE/RL is to be effective and efficient in attaining accelerated cleanup of the Hanford site. To accomplish this vision DOE/RL must find techniques and implement methodologies that ensure the provision of evidence essential to validate the elimination of a major threat to human health and the environment; to verify permanent protection of the groundwater and the Columbia River; to free up large stretches of land including the Columbia River shoreline and part of the Hanford Reach National Monument for conservation, Tribal, recreational and industrial uses; and to rapidly and safely bring to an end DOE’s Environmental Management mission at Hanford thereby, removing a major taxpayer liability. DRAFT

The regulatory goal of RL is to ensure the establishment of clear expectations for performance and quality of work, and implement and achieve them through a cooperative approach among contractors, regulator’s, tribes and the stakeholders to ensure that regulations applied to cleanup activities are appropriate for achieving the desired outcome. In order to effectively and safely expedite cleanup efforts at Hanford, DOE/RL has instituted a rigorous requirements management process that provides the basis for developing the necessary processes and procedures for our federal and contractor staff to effectively complete their assigned work. This process also provides for the elimination of unnecessary or “non-value-added” federal, state and local regulatory requirements. As follow-on to applying appropriate regulatory requirements based on risk, DOE/RL recognizes a need to better manage and streamline our environmental, safety and health management systems in order to enable accelerated cleanup, reduction of risk and reduction of Hanford’s lifecycle costs. The focus of revising the safety management system will be an increased emphasis on Integrated Safety Management (ISM) implementation with consideration given to Environmental Management System (EMS) requirements. This approach will provide a greater level of confidence in the application of controls commensurate with the hazards of the work. Critical to balancing accelerated cleanup activities and risk is performance monitoring through oversight and measurement of critical regulatory activities and outcomes. DOE/RL is committed to sharpening the focus on metrics that can be used objectively to determine performance, analyze problem areas, and benchmark successes. DRAFT

3.0 RL ENVIRONMENTAL POLICY The cornerstone of the EMS and this regulatory strategy is the Environmental Policy which is designed to address the core environmental management system themes. These core EMS themes include; (1) A clear management commitment to the system; (2) Defining the core framework for the EMS; and (3) Establishing the ultimate benchmark of the EMS performance. RL’s Environmental Policy consists of an overarching policy statement which is further interpreted through this regulatory strategy. The policy and the strategy combine to influence the requirements and processes that define how RL performs environmental protection program activities. The policy and the strategy also ensure the organization from the top down is conducting business in a manner consistent with its cleanup mission by providing a framework for defining and validating environmental objectives and targets. DRAFT

RL ENVIRONMENTAL POLICY At the U.S. Department of Energy, Richland Operations Office, we are committed to providing a safe and healthy work place for all staff; and protecting the general public and the environment from unacceptable environmental risks. In support of this policy, we are committed to: • Identifying, evaluating, and managing the environmental hazards associated with our work; • designing and planning work to prevent pollution, minimize waste, conserve resources; properly dispose of or recycle all waste generated; • complying with all environmental laws and regulations that are relevant for the U.S. Department of Energy; • sharing information based on experience (e.g., lessons learned) to promote continuous improvement in environmental and regulatory compliance work practices; • continuously improving our processes, systems, and capabilities so that we can increase the technology- based value of products delivered to our customers; • establishing performance objectives, indicators and targets; conducting self-assessments to collect data and monitor progress; and evaluating data to identify performance strengths, weaknesses, and areas for improvement; and • providing staff and the public with timely, accurate, and appropriate information related to our cleanup mission activities. Five key-risk based performance standards emphasize the Richland Operations Office’s commitment to environmentally responsible and sustainable Hanford Closure Project operations: • Identify and manage hazards and environmental impacts; • prevent pollution; • abide by applicable laws and regulatory requirements; • monitor and continually improve environmental processes; and • communicate. DRAFT

3.2 Tri-Party Agreement The Tri-Party Agreement (Hanford Federal Facility Agreement and Consent Order) was signed in 1989 by the US DOE, EPA and Ecology. The original TPA outlined a 30-year cleanup schedule to bring the Hanford Site into compliance with state and federal environmental laws. The TPA is a legal agreement made up of action plans that include milestones, or deadlines, for specific cleanup actions to be completed. The TPA also outlines the processes for changing, removing or adding milestones; the conditions under which penalties may be issued; and the requirements for public participation activities pertaining to Hanford Site cleanup actions. Implementation of the goals and objectives of this regulatory strategy will require the US DOE, EPA and Ecology to revisit the TPA and determine if the Agreement is consistent with the strategy for ending the EM mission at Hanford and bringing the Hanford Site to final closure. This becomes a strategic initiative within itself. Such negotiations are difficult but in order to expedite the cleanup of the Hanford Site and to bring the closure goals closer to reality will require the affected organizations to reconsider how the environmental laws and regulations have been applied to the work activities. 3.3 Pollution Prevention (P2) and Waste Minimization Pollution prevention (P2), resource conservation and waste minimization are established as national policy objectives by the Pollution Prevention Act of 1990 and RCRA. Responding to the requirements and expectations of these Acts, DOE issued the Pollution Prevention Program Plan in 1996 which outlined the basic elements of pollution prevention programs to be developed at DOE sites. This P2 Program Plan also established extremely aggressive goals for waste reduction and minimization. As stated in the P2 Program Plan, DOE’s P2 mission is to reduce risk and cost associated with pollution by minimizing the generation and release of pollutants to the environment through the use of cost-effective pollution prevention technologies, practices, and policies. DRAFT

The role of P2 and waste minimization in DOE was reiterated with the issuance of DOE O 450.1. Critical to the success of the DOE P2 program is the integration of pollution prevention into DOE life-cycle planning, execution and evaluation of programs and projects. Critical elemental approaches must be inclusive throughout the RL regulatory strategy to ensure the greatest return on investment. P2 has been integrated as a good business practice in the planning, execution and evaluation of RL mission-related activities, including the strategies and objectives described in this document. 3.4 Integration of Environmental Regulatory Strategies with the Risk-Based End States Strategies DOE P 455.1, Use of Risk-Based End States is consistent with and emphasizes the provisions of CERCLA, RCRA, and the Atomic Energy Act (AEA), that either explicitly or implicitly authorize the consideration of future land use and associated risk in making cleanup decisions. Emphasis is needed because there has been uneven progress at DOE sites in implementing cleanup strategies that integrate both risk and future use considerations. This risk-based end state approach requires a common acceptance among stakeholders and regulators of the site-wide post-remediation future prior to individual remedy evaluation and selection actions. Efforts to develop and achieve risk-based end states require incorporation of the following: • RL shall continue to comply with applicable Federal, state, community, and treaty requirements when proceeding with this effort, including but not limited to RCRA, CERCLA, AEA, National Contingency Plan (NCP) and its Natural Resource Damage Assessment (NRDA) provisions. • End states shall be based on an integrated site-wide perspective (including the current and future use of land), rather than on isolated operable units or release sites. DRAFT

• End states are the basis for exposure scenarios developed in baseline risk assessments that help establish acceptable exposure levels for use in developing remedial alternatives in the feasibility study. • Risk reduction measures, life-cycle costs, uncertainties, and other relevant policy factors of the decision shall be made visible in site cleanup strategies and remedy decision documents. • All nine CERCLA remedy selection criteria shall be evaluated. Remedies passing the threshold criteria will require a complete evaluation of the balancing criteria. Modifying criteria shall also be considered in remedy selection. • When the selected remedy results in the need for long-term surveillance and maintenance, risk control concepts should include layered and redundant institutional controls, commensurate with the risks to maintain protectiveness. Long term surveillance and maintenance methods shall be designed to assure that the contaminants remain isolated to the extent practical, and that human health and the environment is protected. • To ensure protection of human health and the environment once the end state is achieved the Department shall address how it manages the impacts of future risks, uncertainties, and vulnerabilities, including the creation of contingency plans and the identification of responsible parties in the event that site conditions change after cleanup is completed. In the case of CERCLA sites, such plans shall be integrated with the five-year reviews. Because these issues deal principally with implementation of DOE’s cleanup commitments, they will not be discussed further here. However, the Risk-Based End States documents developed and implemented at Hanford will integrate the Environmental Regulatory Strategies detailed in section 4.2. DRAFT

3.5 Guiding Principles The following regulatory principles guide DOE – RL in its endeavor to accelerate cleanup of the Hanford Site in a safe and effective manner: 1. The Tri-Party Agreement is the overarching document that defines the requirements and schedules for achieving compliance with the regulations defined in RCRA and CERCLA. 2. End-state agreements will be developed jointly with the regulators and will embrace the concepts contained in the DOE – RL Implementation Plan for DOE Policy 455.1, “Use of Risk Based End States.” 3. Hanford Site cleanup decisions will be made consistent with the Comprehensive Land Use Plan. 4. DOE – RL will maintain a comprehensive Environmental Management System (EMS) that ensures a continuous cycle of planning, implementing, evaluating, and improving processes and actions undertaken to achieve environmental goals and compliance with DOE O 450.1, “Environmental Protection Program.” 5. The Hanford Site is a single RCRA facility. The Hanford Site RCRA Permit will grow into a single permit for the entire Hanford Site and will include all TSD Groups/Units. 6. DOE has assumed a stewardship role on behalf of the American public with respect to managing the Hanford Site and its cultural and historical resources. 7. The Atomic Energy Act of 1954, as amended, so completely occupies the regulation of radiation hazards, that regulation by state and local governments is generally preempted. 8. The NEPA process is a valuable planning tool and provides DOE – RL an opportunity to improve the decision making process. DRAFT

4.0 REGULATORY OBJECTIVES AND STRATEGIES In order for DOE to implement this approach DOE/RL and its Hanford Site contractors will work to achieve fourteen critical environmental regulatory objectives. As these objectives are achieved by attaining the incremental strategic goals associated with each, they will result in significant cost savings, more effective remediation approaches, and simplification and clarification of regulatory requirements. 4.1 Long-Term Objectives and Strategies This section of the Hanford Environmental Regulatory Strategy describes the long-term objectives and strategies that define our path to achieve an environmentally restored Hanford end state, within the framework of our values and goals. The strategies associated with these objectives are considered dynamic and from time-to-time will be reviewed and updated to reflect the fact that schedules may change, budgets may change, priorities may change, and initiatives will come and go. OBJECTIVE 1: Develop regulatory management systems that will drive the establishment of clearly defined and demanding environmental, regulatory compliance and permitting performance goals thereby reducing the excessive costs associated with site cleanup. STRATEGY: 1. Develop and implement an effective and compliant Environmental Management System. Ensure the Tri-Parties (EPA, Ecology and DOE) continue to work together to identify and resolve Hanford cleanup problems in alignment with the TPA. 2. Make appropriate modifications to the TPA to ensure that it is an effective governing document for the Hanford accelerated cleanup goals. 3. Identify opportunities where we can optimize the physical and DRAFT

administrative cleanup process and work with the Tri-Parties and other stakeholders and contractors to proactively and cooperatively improve methodologies. 4. Develop a long-term regulatory oversight function with a focus on identifying potential problems before they occur and ensuring that resolution is defined in accordance with the TPA and agreed to by the regulators. OBJECTIVE 2: Clearly define Hanford Site end-states to effectively facilitate consistent cleanup decisions and activities. STRATEGY: 1. Compile existing regulatory and permitting documentation on end-states and identify gaps required to implement the final Hanford Site risk-based end-state vision. 2. Propose specific changes to TPA and regulatory implementation documents necessary to support negotiation with the regulators and other stakeholders for the Hanford Site Risk-Based End States Vision document. 3. Ensure that regulatory decisions are aligned with the end-state maps through a documented decision process within the EMS. 4. Integrate Risk-Based End States visions, variances and strategies with baseline schedules for Hanford’s RCRA, CERCLA, TPA, CAA, and NEPA regulatory programs. Ensure that all deliverables are identified through the conclusion of EM’s mission at Hanford. DRAFT

OBJECTIVE 3: Eliminate the potential for follow-on remedial actions by using “final” criteria for all regulatory documentation and interim cleanup decisions. STRATEGY: 1. Perform a gap analysis identifying gaps between the existing Hanford Past Practice Strategy relative to Interim Actions and the regulatory requirements for Final Actions. 2. Develop and implement an EMS process that focuses on using risk assessments to demonstrate “protectiveness” and how to proceed to NPL deletion. 3. Develop and implement an EMS process that ensures the effective transition from Interim Actions to Final Actions. 4. Develop and implement an EMS process that defines how to proceed from interim Records of Decision (ROD) to final RODs. 5. Develop and implement an EMS process that defines how to sum up partial deletions to get a final deletion from the NPL. 6. Replace the existing Hanford Past Practice Strategy with the new Hanford Closure Strategy. Develop and publish the Hanford Closure Strategy document. 7. Monitor the new Hanford Closure Strategy and implementing processes using Regulatory Oversight and working with regulators, identify opportunities for improvement and modify the strategy and/or implementing processes accordingly. DRAFT

OBJECTIVE 4: Ensure a clearly defined division of responsibility between DOE, the EPA and Ecology is documented and maintained. STRATEGY: 1. Coordinate and negotiate with the EPA and Ecology to clearly define the responsibilities for each regulator. Define DOE’s role as lead agency under CERCLA. 2. Document the division of responsibilities and obtain concurrence from each regulator. 3. Produce resulting agreements and document on the RIMS EMS to ensure accessibility by DOE, regulators, contractors and stakeholders. OBJECTIVE 5: Streamline RCRA permitting processes to further accelerate cleanup by minimizing regulatory documentation planning, preparation, review and approval cycle times. STRATEGY: 1. Perform a gap analysis identifying gaps between the existing Hanford Past Practice Strategy relative to RCRA cleanups and closures and the regulatory requirements for Final permits and Closure Plans. 2. Negotiate with the regulators, develop and implement an EMS process that ensures the effective implementation of closures performed under Interim Status. 3. Develop and implement a baseline schedule for completing all RCRA permitting activities through the final RCRA closure of Hanford. OBJECTIVE 6: Integrate and standardize repeating regulatory processes and documentation requirements thereby removing artificial constraints and eliminating redundant processes. STRATEGY: DRAFT

1. Develop standardized Hanford data reporting protocols, regulatory documentation templates, and routine/repeating permit submittals. 2. Develop a standard set of DOE-approved Applicable or Relevant and Appropriate Requirements analyses for incorporation in all Hanford CERCLA decision documents and implementation plans. 3. Develop model statements of work for RI/FS Work Plans, Baseline Risk Assessments, Records of Decision/Proposed Plans, radiological emissions air monitoring plans and NESHAPs license applications. OBJECTIVE 7: Initiate CERCLA “removal” processes and DOE’s authorities delegated by the President in Executive Order 12580 to address immediate risks to human health and the environment. STRATEGY: 1. Work with regulators to determine what it means to follow the CERCLA process. 2. Prepare Memorandum of Agreement that includes the results of the CERCLA process clarification. 3. Obtain approval signatures of DOE and regulators on MOA. 4. Place final MOA on RIMS EMS for ready access to Hanford contractors, regulators, DOE Mission Elements and applicable stakeholders. 5. Prepare a training module that provides an overview of the MOA and include in the RIMS EMS. OBJECTIVE 8: Define Hanford Site boundaries that clearly delineate what areas are included in the National Priorities List (NPL). STRATEGY: 1. Work with regulators to finalize what Hanford Site boundaries are included in the NPL. 2. Prepare Memorandum of Agreement that includes the results of the DRAFT

boundary mapping. 3. Obtain approval signatures of DOE and regulators on MOA. 4. Place final MOA on RIMS EMS for ready access to Hanford contractors, regulators, DOE Mission Elements and applicable stakeholders. 5. Prepare a training module that provides an overview of the MOA and include in the RIMS EMS. OBJECTIVE 9: Refocus Tri-Party Agreement implementation practices to hold the contractors to high quality standards by collaboratively developing and implementing simplified standard operating procedures. STRATEGY: 1. Establish a work group including Hanford contractors and the regulators to identify TPA practices and procedures that could be simplified and standardized. 2. Prepare a proposal recommending actions that should be taken to publish simplified TPA standard operating procedures. DRAFT

OBJECTIVE 10: Develop, approve and implement an exit plan for removal of Hanford Site from the NPL. STRATEGY: 1. Work with EPA and Ecology to develop a definitive strategy for removal of the Hanford Site from the NPL. 2. Document the closure and removal approach in a Memorandum of Agreement. 3. Obtain approval signatures of DOE, EPA and Ecology on MOA. 4. Place final MOA on RIMS EMS for ready access to Hanford contractors, regulators, DOE Mission Elements and stakeholders. 5. Prepare a training module that provides an overview of the MOA and include in the RIMS EMS. OBJECTIVE 11: Establish an Environmental Quality Assurance program that fully integrates the quality requirements of the TPA with the existing Hanford Integrated Safety Management System and the Hanford Environmental Management System. STRATEGY: 1. Perform gap analysis on the current DOE QA Program Description and the Quality Assurance requirements contained in the TPA and identify improvements needed to comply with applicable requirements. 2. Perform gap analysis of the HAZQARD and identify changes required to ensure contract-required Quality Assurance references to this document are appropriate . 3. Prepare draft attachment, requirements matrix and crosswalk (as appropriate) for the Hanford Quality Assurance Program Description based on results of gap analysis. 6. Publish and post revised Hanford Quality Assurance Program Description on RIMS. DRAFT

OBJECTIVE 12: DOE must establish a fully-integrated Administrative Record that is indexed as required by RCRA and CERCLA, and that meets the needs of these regulations for documenting final remedial/corrective actions. STRATEGY: 1. Perform gap analysis on the current applicable Federal regulations (RCRA, CERCL A, CAA, CWA, TSCA, and SDWA) to identify conflicts between current Hanford Administrative Record practices and regulatory requirements. 2. Perform gap analysis on the current applicable Washington State regulations (Washington State Hazardous Waste Management Act, Model Toxics Control Act, and Washington Clean Air Act) between current Hanford Administrative Record practices and regulatory requirements. 3. Prepare Implementation Plan to resolve conflicts existing between Hanford Administrative Record practices and Federal and State regulations. Include EPA, Ecology and Hanford contractor team members in Implementation Plan preparation. 4. Post Administrative Record Implementation Plan on RIMS EMS. DRAFT

OBJECTIVE 13: Create shared Tri-Party responsibility for early identification of regulatory endpoints thereby making “Last Remedy in Place” determinations for all operable units and waste sites. STRATEGY: 1. Work with regulators to develop a documented process for aligning all Hanford CERCLA environmental response actions with regulatory requirements for “Last Remedy in Place” determinations.. 2. Ensure documented process includes criteria for Hanford Site land transfers and development. 3. Ensure documented process includes response actions initiated under Hanford Past Practice Strategy as well as actions documented in Final RODs and Closure permits . 4. Place approved alignment Process Agreement on RIMS EMS. OBJECTIVE 14: Eliminate unnecessary Clean Air Act and NESHAPs permitting requirements by obtaining EPA exemption for minor activities from the requirements to submit radioactive air emission Notice of Construction and notifications of startup for approval. STRATEGY: 1. Upon completion of the Hanford Clean Air Act Federal Facility Compliance Agreement, prepare a detailed request for EPA exemption as authorized under 40CFR 61.96(b) for new construction or modifications that result in estimated effective dose equivalents of <0.1 mrem per year. 2. Post the exemption description on the RIMS EMS. DRAFT

4.2 Key FY ’05 Regulatory Objectives In order to effectively implement the strategic goals presented in Section 4.2, a number of near-term objectives are required to be implemented. These near-term objectives lay out a roadmap designed to ensure the accomplishment of the regulatory goals through the application of project management methodologies. FY ’05 Objective 1: By the end of FY 2005 revise the Tri-Party Agreement Handbook. By developing a composite set of multi-agency standard operating procedures that address the following collaborative implementation processes: • DOE’s Role as CERCLA Lead Agency • RCRA/CERCLA Integration and Documentation • NESHAPS Air Monitoring • Administrative Record Management • State Initiated Disputes • Quarterly Tri-Party Agreement Milestone Reviews • Waste Site Reclassification • Notification of Milestone Completion • NEPA/SEPA Integration • Sampling and Laboratory Analytical Standard Operating Procedures • Implementation of EPA QA-R5 • Proposing and Approving ARARS FY ’05 Objective 2: By the end of FY 2005 fully implement Integrated Project Teams (IPTs) that have a clear understanding of the DOE/RL strategies, goals and objectives defined in this document. DRAFT

FY ’05 Objective 3: By the end of FY 2005 revise OES Integrated Project Team Individual Performance Plans (IPPs) to clearly define roles and responsibilities that are aligned with this strategy. Build in reward systems to drive cultural change and new behaviors including: • Creating shared responsibility and accountability for the whole project • Focusing on necessary and sufficient processes • Re-synthesizing regulatory tasks around Hanford projects • Minimizing preparation times • Minimizing return rates (rework) FY ’05 Objective 4: By the end of fiscal year 2005 publish a comprehensive and integrated RL specifying a Hanford site wide schedule for delivering environmental permits, NEPA documents/decisions, Tri-Party Agreement documents and supporting regulatory documents or decisions for successful execution of Hanford’s environmental restoration projects. FY ’05 Objective 5: Fully implement an Environmental Management System, in compliance with DOE Order 450.1, by the end of CY 2005. Integrate DOE and contractor environmental processes with safety and project implementation processes. Establish demanding regulatory compliance performance goals. FY ’05 Objective 6: By the end of fiscal year 2005 develop a plan leading to divesting Hanford’s collection of cultural resource artifacts to responsible third- party curation and exhibition partners by FY ‘07. Re-focus cultural resources activities and processes on project execution. DRAFT

Transition Last Remedy in Place By 2024 Closure Regulatory Strategies Strategy Perspective Project • Restore the River Corridor 1. Develop Regulatory Management Systems • Close the 100 Area 2. Streamline regulatory documentation, permitting and compliance processes • Close the 300 Area 3. Create shared responsibility across DOE projects, support orgs and contractors • Transition the Central Plateau 4. Use CERCLA “removal” processes/DOE authority under E.O. 12580 to address risks • Close the Fast Flux Test Facility 5. Refocus TPA implementation practices/hold contractors to high QA standards 6. Create shared responsibility for early identification of regulatory end-points 7. Eliminate potential for follow-up remedial actions by using “final” criteria 8. Realign regulatory work from functional to process driven Perspective Public HAB Regulatory State of Customer External Factors Agencies Washington And • Public Participation • Tribal Scenario Plan • Integrated Actions • Cleanup Standards • Offsite Waste Receipt • Protect Groundwater • Regulatory Rqmts/ • High-level waste reclassification • Meet NEPA rqmts. Documents • Hanford Solid Waste EIS I RBES HPMP DOE DOE TPA E.O. I Institutional Order Order 12580 Perspective • TBA 2005 • Close by 2004 450.1 413.1 • Integrated RCRA/ • Define Regulatory CERCLA • DOE/CERCLA lead agency End points • EMS fully integrated in • Action-based milestones • Natural Resource Trustee • Project centric • Reduce liabilities ISMS • State and public • Perform NRDA approach • Transition • Stewardship approach involvement in CERCLA • Authority for Response Actions • Reduce risk • RL Environmental Policy actions Improvement Perspective RIMS Regulatory Compliance Operational Effectiveness Process Policy • Process Definition • Emulate EPA reg. implementation processes • Process-based excellence • R2A2s • Continuous Improvement • Establish Best Practices • IPTs • Standard Operating Procedures (SOP) FIGURE 1 – Regulatory Strategy DRAFT

Assign Compliance Assign Team and Officer (CO) Document Manager Determine Receive final Place reviews into appropriate Conduct licensing Notify Licensing POC Develop review licensing schedule licensing “In-Process” application of expected reviews. plan, team and and obtain document, provide Reviews document. schedule. AR # guidance, and agree on schedule Obtain comments Conduct and Brief FPD Receive DOE/RL YES review in resolve. OES formally on submittal and Authorization Document accordance with transmits to anticipated from Acceptance Review Plan appropriate approval. Regulator Regulatory Agency and NO AR File Document basis Transmit to for rejection. Project (FPD) Notify FPD Conduct on submittal and Compliance prepare Notify Project (FPD) of results. Assessments rejection letter. Based on Permit Conditions Regulatory Review and Approval Process DRAFT

CERCLA ENVIRONMENTAL RESTORATION PHASES AND MILESTONES INTERIM REMEDIAL ACTIONS REMEDIAL ACTION (OPTIONAL) CLOSEOUT INTERIM CLOSEOUT Work Plan Interim Work Plan Remedial Interim Remedial Investigation/ Investigation/Feasibility FINAL ACTION Feasibility FINAL ROD Study (RI/FS) Study (RI/FS) INTERIM ROD Cleanup Verification Cleanup Package (CVP) Petition for Partial Delisting Verification Package (CVP) NRDA Pre-Assessment Interim Remedial On-Scene Coordinator Screen Design/Remedial Action (OSC) Report Work Plan (RD/RA) Remedial Design/ Closeout Final Remedial Action Remedial Action Work Plan (RD/RA) Closeout Report REMOVAL ACTION LEGEND Petition for Final Delisting Engineering Evaluation/Cost Assessment No further action decision point (EE/CA) Phase Start Stop Long Term Monitoring for Action Memo Milestone Some Remedy Selections DRAFT

QA PLANNING AND DATA LIFE CYCLE Data Quality Objectives Process PLANNING Data Quality Objectives Process Quality Assurance Project Plan Development Data Data Quality Quality IMPLEMENTATION Objectives Design Field Data Collection and Associated Quality Assurance/Quality Control Activities Quality Assurance Project Plan Development ASSESSMENT Data Validation Data Quality Assessment Quality Assurance Project Plan (QAPP) DRAFT

Minor Dispute Resolution Issues EPA/Ecology Review and DOE Incorporate Lead Regulatory Agency Comments and Dispute Resolution Update Document and Respond if Appropriate Minor Issue Final Document Minor Prepare Response or Initiate Dispute Issues or Initiate Dispute Issues Letter if Needed Resolution Resolution *45 Days 30 Days 30 Days No Issues Favorable Response or Final Document Update No Response in 30 Days Feasible (two extension request) Final Document EPA/Ecology Dispute Resolution Review and Lead Minor Prepare and Regulatory Issues Submit Agency Respond *45 Days No Issues Final Document Issues with Comments (i.e. added words) Final Document No EPA/Ecology Review Comments DOE Prepare Response DOE Response and Lead and if Applicable Provide Regulatory Agency Respond or Favorable Update Document Plan for Document Update Initiate Dispute Resolution Response and Resubmit 30 Days 30 Days 45 Days (or per plan) Major Issues DOE = U.S. Department of Energy Dispute Resolution EPA = U.S. Environmental Protection Agency Ecology = State of Washington Department of Ecology TPA Primary Document Process DRAFT

Prepare/Revise & Submit/Re-Submit Part B Permit Application or Closure/Postclosure Plan Rev. 0 Rev. 0 Rev. 0 NOD Workshop DOE Response Ecology Review Ecology Review to Resolve Issues (NOD Response Table) Response Table * 120/90 120/90 120/90 210/180 Rev. 1 Rev. 1 DOE-RL Issue DOE-RL Page Ecology Review Project Managers Revision 1 Change Revisions /Issue NODs Issue Resolution 120/90 60/60 30/30 60/60 Ecology Prepare Public Public Public Hearing Draft Permit/Permit Notification Review (if requested) Modification 60/60 90/90 5- or 10-Year Issue Permit or Review Permit Modification * Permit or Closure/Post Closure Days for Completion RCRA Permit Application and Closure/Post Closure Plan Process Flowchart. DRAFT

Risk Based EMS Strategy

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Risk Based EMS Strategy Document Transcript