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7.0 SCOPING, PUBLIC PARTICIPATION, AND CONSULTATIONS

The Tank Waste Remediation System (TWRS) scoping process provided interested Federal and State agencies, Tribes, and members of the public an opportunity to identify issues or concerns to be analyzed in the TWRS Environmental Impact Statement (EIS). The Council on Environmental Quality (CEQ) and Washington Administrative Code (WAC) regulations require an early and open process to determine the scope of an EIS (10 Code of Federal Regulations [CFR] Parts 1500 through 1508 and WAC 197-11). The purpose of the scoping process was to determine the scope and issues to be analyzed in the Safe Interim Storage of Hanford Tank Waste EIS (DOE 1995i) and the TWRS EIS. The scoping process also identified and eliminated from detailed study areas of potential impacts that were identified as less important and narrowed the discussion of such potential impacts to a brief presentation of why they were not included. The scoping process for the TWRS EIS is described in Section 7.1.1.

Federal agencies, Washington State, and local agencies are required by the National Environmental Policy Act (NEPA), CEQ, and Washington State Environmental Policy Act (SEPA) regulations to involve the public in the decision making process associated with proposed actions that have potentially significant impacts on the human environment. Public participation activities give the public both access to information and the opportunity to participate meaningfully in the decision making process throughout the EIS preparation and at key EIS milestones. The public participation program for the TWRS EIS is described in Section 7.2.

Federal agencies as part of the NEPA process and State agencies as part of the SEPA process also consult with appropriate Tribal Nations and Federal, State, and local agencies. Various Federal and State agencies have responsibilities for certain geographic areas, natural resources, or environmental regulations that may be impacted by the proposed action. Federal and State laws regarding cultural, historical, and archaeological sites as well as treaties and intergovernmental agreements require consultation with Tribal Nations that may be impacted by the proposed action. Section 7.3 describes U.S. Department of Energy (DOE) and Washington State Department of Ecology (Ecology) consultations with applicable agencies and Tribal Nations. Volume Five, Appendix J contains formal consultation letters from DOE and Ecology, and the associated response received.

Section 7.4 describes the public comment process for the Draft EIS and information about how comments were submitted and then considered by DOE and Ecology when preparing the Final EIS . Section 7.4 describes how public comments provide issue-specific information to the decision makers and how to follow comments through the decision process.

7.1 SCOPING SUMMARY

On January 28, 1994, DOE published a Notice of Intent in the Federal Register announcing its intent to prepare the TWRS EIS and the Safe Interim Storage EIS (59 FR 4052). The Safe Interim Storage EIS has been completed (DOE 1995i). The Notice of Intent also announced DOE's intent to conduct a series of public scoping meetings on the proposed actions in accordance with CEQ regulations and DOE Implementing Procedures (10 CFR 1021). After publishing the Notice of Intent, DOE and Ecology agreed to co-prepare the two EISs (MOU 1994).

7.1.1 The Public Scoping Process

During the 45-day scoping period, which ended on March 15, 1994, DOE and Ecology invited all interested parties to submit comments or suggestions concerning the scope of the issues, alternatives, and environmental impacts to be analyzed within each EIS . The public was also invited to attend scoping meetings, at which both oral and written comments were accepted on each proposed EIS. The agencies placed advertisements in local newspapers to announce the public scoping meetings. The newspapers and advertisement dates are included in the Implementation Plan for the TWRS EIS (DOE 1995b).

The purpose of the scoping meetings was to inform the public about the proposed action and the nature and content of the decision-documents to be prepared. These meetings also allowed the public an opportunity to identify, for the record, areas of potential impacts that should be considered by DOE and Ecology in preparing the EIS. The public scoping meetings dates and locations are included in the Implementation Plan for the TWRS EIS.

A verbatim transcript was made by a court reporter of all oral comments from each meeting. Written comments were accepted at the meetings and throughout the comment period. Copies of all transcripts and comment letters are available in the DOE Reading Rooms and Information Repositories listed in Table 7.1.1.

The initial scope of the TWRS EIS was provided in the Notice of Intent and at each public scoping meeting. The scope called for consideration of impacts associated with the following actions:

• Continue tank waste and encapsulated cesium and strontium management;
• Retrieve single-shell tank (SST) and double-shell tank (DST) waste;
• Process the waste into high-level waste (HLW) and low-activity waste (LAW) streams;
• Immobilize the HLW stream and store the treated material until a potential geologic repository is available; and
• Immobilize the LAW stream and dispose of it or put it into retrievable onsite storage.

The analysis of impacts for implementing the No Action alternative was also included in the scope of the EIS.

Table 7.1.1 DOE Reading Rooms and Information Repositories

7.1.2 Public Scoping Process Results

The EIS scoping process provided an opportunity for interested parties to address both the TWRS EIS and the Safe Interim Storage EIS. The scoping process resulted in comments that were relevant only to the TWRS EIS, relevant only to the Safe Interim Storage EIS, or relevant to both of the EISs. The Implementation Plan for the TWRS EIS summarizes and responds to those scoping comments relevant only to the TWRS EIS as well as those scoping comments applicable to both EISs (DOE 1995b).

DOE and Ecology's responses to scoping comments are summarized in the Implementation Plan for the TWRS EIS, which is available at the DOE Reading Rooms and Information Repositories listed in Table 7.1.1. These documents are also available upon request by calling 1-800-321-2008 or writing to Carolyn Haass, DOE TWRS EIS NEPA Document Manager, U.S. Department of Energy, P.O. Box 1249, Richland, Washington 99352, or Geoff Tallent, Ecology TWRS EIS Project Lead, Washington State Department of Ecology, P.O. Box 47600, Olympia, Washington 98504-7600.

Those issues raised during the public scoping process and analyzed in the TWRS EIS are listed in Table 7.1.2. All the topics originally identified in the Notice of Intent have been addressed in this EIS.

Table 7.1.2 Issues Identified During Public Scoping and Analyzed in the TWRS EIS

7.2 EIS PUBLIC PARTICIPATION PROCESS

A Notice of Availability of the Draft EIS was published in the Federal Register and advertisements were placed in local newspapers (61 FR 16248) . These notifications also informed the public of the comment period for the Draft EIS and the schedule for public hearings . Copies of the Draft EIS were distributed to interested individuals, public interest groups, agencies, and Tribes. The public comment period extended from April 12 to May 28, during which time the public and others had the opportunity to submit written comments on the Draft EIS. Additionally, DOE and Ecology conducted a series of five public comment hearings and meetings at which the public had the opportunity to submit oral and written comments. During and after the comment period, DOE and Ecology held consultation meetings with Tribal Nations and agencies to address issues associated with the Draft EIS . DOE and Ecology considered comments on the Draft EIS prior to completing the Final EIS. The Final EIS include s a list of public comments and the responses to comments from DOE and Ecology (Volume Six, Appendix L) . The Final EIS has been distributed to the public and others and placed for public inspection in DOE Reading Rooms and Information Repositories, as listed in Table 7.1.1.

The decision regarding the proposed action will not be made until at least 30 days following the publication of the Final EIS Notice of Availability. DOE and Ecology will prepare a Record of Decision, which will be published in the Federal Register and be available for public inspection in DOE Reading Rooms and Information Repositories. A Mitigation Action Plan will be prepared to analyze any commitments to mitigate environmental impacts contained in the Record of Decision. Copies of the Mitigation Action Plan will also be available for public inspection at the locations listed in Table 7.1.1.

The goal of the TWRS EIS public participation program is to create an open and accessible decision making process that results in TWRS decisions that are technically feasible, environmentally sound, health and safety-conscious, and that address public concerns and values. Provisions for meaningful and informed public involvement within the TWRS decision making process will help achieve this goal. A detailed discussion of the goal and objectives is presented in the Implementation Plan for the TWRS EIS (DOE 1995b).

The following documents, activities, and avenues of communication for the TWRS EIS have and will continue to encourage direct two-way communication between the agencies and those stakeholders, Trib al Nation s, and Federal, State, and local agencies interested in the TWRS EIS and the decisions to be made.

Notice of Availability

In addition to the Notice of Availability that was published in the Federal Register for the Draft EIS and Final EIS .

Public Notification

Public notices (advertisements in local newspapers, broadcasts via radio or television stations, and mailings) are used to announce DOE and Ecology activities and plans and to encourage public involvement in the TWRS EIS decision making process.

Stakeholders, Agencies, Tribal Nations, and Media

Direct notification via phone calls, facsimile, press releases, Notices of Availability, or mailings are used to announce DOE and Ecology decisions and major project milestones (e.g., the public comment period for the Draft EIS, availability of the Final EIS . Copies of the Record of Decision will be provided to agencies, Tribal Nations, and interested stakeholders.

Briefing of DOE Headquarters, DOE Richland Operations Office, and Ecology Advisory Boards and Committees

DOE Headquarters, DOE Richland Operations Office, and Ecology have established communication channels with advisory boards and committees to provide public input into agency policies, programs, and decisions. These boards and committees, including the Hanford Advisory Board , the Environmental Management Advisory Board, and the Defense Nuclear Facility Safety Board , have provide d input into the TWRS EIS.

Public Comment Period

The public comment period provided an opportunity for interested Tribal Nations, agencies, public interest groups, and the public to provide their input on the proposed action and environmental impact analysis contained in the EIS. The public comment period for the Draft EIS began on April 12, 1996 and ended on May 28, 1996.

Public Hearings

Public hearings and meetings were held in conjunction with the public comment period for the Draft EIS. Public hearings were announced a minimum of 15 days prior to any hearing and diverse channels of communication were used to reach the broadest possible audience.

Administrative Record and DOE Reading Rooms and Information Repositories

The Administrative Record for the TWRS EIS is maintained under the direction of DOE Richland Operations. The Administrative Record contains an index of all documents in the record, guidance documents, final reports, technical information, comments by the public and agencies, DOE and Ecology's responses to comments, decision documents, and other documents used as a basis for analysis during the development of the EIS. These documents, including an index of the Administration Record files, may be found in the DOE Reading Rooms and Information Repositories listed in Table 7.1.1.

Toll-Free Telephone Line, Hanford Cleanup at 1-800-321-2008 (Hanford Hotline)

A toll-free telephone number is available to provide stakeholders with an opportunity to ask questions and obtain information about the TWRS EIS.

Hanford Home Page

TWRS EIS documents have been and will continue to be made available on the Internet via the Hanford Home Page (www.Hanford.gov). Documents placed or to be placed on the Hanford Home Page include the Draft EIS, Final EIS, Record of Decision, meeting notices, fact sheets, and press releases.

7.3 CONSULTATIONS WITH TRIBAL NATIONS AND FEDERAL, STATE, LOCAL, AND REGIONAL AGENCIES

To ensure full compliance with NEPA and SEPA regulations and to help keep concerned agencies informed of DOE actions, the consultations listed in Table 7.3.1 were conducted. Consultations consisted of written correspondence regarding the proposed action, alternatives, environmental impacts, regulatory requirements, issues of concern, and information available from Federal, State, and local agencies and Tribal Nations. Copies of formal consultation letters are contained in Volume Five, Appendix J.

Table 7.3.1 Agency and Tribal Nation Consultations

In addition to written consultation, and when appropriate, DOE and Ecology consulted agencies and Tribal Nations to clarify areas of potential impacts, attain an understanding of concerns, and receive information provided by the agencies and Tribal Nations. Meetings or other consultations were held with the following Tribal Nations, organizations, and agencies:

• Benton County, Washington;
• Community Council, Benton and Franklin Counties, Washington;
• Confederated Tribes and Bands of the Yakama Indian Nation;
• Confederated Tribes of the Umatilla Indian Reservation;
• Defense Nuclear Facility Safety Board;
• Environmental Management Advisory Board;
• Hanford Advisory Board;
• Hanford Natural Resources Trustee Council;
• National Academy of Sciences;
• Nez Perce Tribe ;
• U.S. Environmental Protection Agency;
• Washington State Department of Fish and Wildlife; and
• Washington State Department of Health.

In addition to consultations conducted prior to and following the release of the Draft EIS and Final EIS , DOE and Ecology provided consulting agencies and Tribes with copies of the documents for review. The Record of Decision will also be provided to Tribal Nations and agencies.

7.4 PUBLIC COMMENT PROCESS FOR THE TWRS DRAFT EIS

Distribution of the Draft EIS

Beginning on April 4, 1996 and continuing through the end of the comment period on May 28, 1996, DOE and Ecology distributed in excess of 850 copies of all or portions of the Draft EIS. Distribution included copies sent to local, State, and Federal agencies and elected officials; Tribal Nations; and interested stakeholders. A copy of the EIS and supporting documents was made available at five DOE Reading Rooms and Information Repositories (Seattle, Spokane and Richland, Washington; Portland, Oregon; and Washington, D.C.). The Draft EIS was posted on the Hanford Home Page.

Notice of Availability

On April 12, 1996, a Notice of Availability for the Draft EIS was published in the Federal Register (61 FR 16248).

Public Notification

The public was notified of the availability of the Draft EIS for review, the public comment period, and the dates and locations of public meetings through a variety of channels of communication.

• On April 8, 1996, officials from DOE and Ecology held a press conference for regional and national media to announce the start of the comment period and the availability of the Draft EIS for review and public comment. The press conference generated extensive coverage in the local and regional newspapers.
• The press release announcing the start of the public comment period was placed on the Hanford Home Page.
• An EIS fact sheet was mailed on April 12, 1996 to more than 1,200 individuals on the Hanford Tri-Party Agreement mailing list. The fact sheet summarized the EIS, listed the locations of information repositories where the document was available for public review, informed readers of the dates and locations of public hearings and meetings, and informed readers how a copy of the EIS could be obtained.
• On April 12, 1996, copies of the EIS and supporting documents were made available for public review in five DOE Reading Rooms and Information Repositories.
• On April 12, 1996, public notification advertisements on the start of comment period and meeting dates and locations were published in newspapers in Seattle, Spokane, and Richland, Washington; Portland and Hood River, Oregon; and Washington, D.C.
• On April 12, 1996, information on the Draft EIS and comment period was posted on the Hanford Calendar (revised and distributed weekly throughout the comment period).

Hearings and Meetings

DOE and Ecology sponsored five public hearings and meetings on the Draft EIS. Meetings were held in Seattle on May 22, 1996, Spokane on May 15, 1996, and Pasco, Washington on May 2, 1996; Portland, Oregon on May 9, 1996; and Arlington, Virginia on May 7, 1996. At the public meetings, information was provided to attendees regarding the Draft EIS, representatives from DOE and Ecology responded to questions from attendees, and oral and written comments were submitted by attendees. Comments were recorded and a transcript of each comment is available for review at DOE Reading Rooms and Information Repositories.

In addition to notifications regarding the meetings that were included in information disseminated on the start of the comment period and notification of the availability of the Draft EIS for review, the following activities were completed:

• Display advertisements were placed in general circulation newspapers in the region near the hearing or meeting sites the week prior to the hearing or meeting.
• Post cards were mailed to individuals living in the region surrounding the hearing or meeting locations.
• A press release was issued to the media in the region surrounding the hearing or meeting to announce the meeting time, date, and location.
• Hearing or meeting times, dates, locations, and formats were coordinated with public interest groups (Heart of America Northwest, Hanford Energy Action League, and Government Accountability Project), State agencies (Oregon Department of Energy), and the Hanford Advisory Board to maximize attendance.
• Meeting times, dates, and locations were included in Hanford Happenings and Hanford Update.

Consultation Meetings

Meetings, formal and informal, were held during and following the comment period with the following agencies, Tribal Nations and advisory groups to receive input on the Draft EIS:

• Hanford Advisory Board, Waste Management Committee Meeting, Seattle, Washington;
• Yakama Indian Nation, Richland, Washington;
• Nez Perce Tribe, Lapwai, Idaho;
• Hanford Advisory Board, Richland, Washington;
• Community Council, Richland, Washington;
• Washington and Oregon Congressional Delegation, Washington, D.C.;
• Environmental Management Advisory Board, Arlington, Virginia;
• U.S. Environmental Protection Agency, Seattle, Washington;
• Confederated Tribes of the Umatilla Indian Reservation, Mission, Oregon;
• Defense Nuclear Facility Safety Board, Richland, Washington; and
• National Academy of Sciences, Washington, D.C.

In addition to the above meetings, other communication or meetings were held with the technical staff of the following organizations, agencies, or Tribal Nations to support submission of comments and review of the EIS and to receive additional technical information for inclusion in the Final EIS:

• Yakama Indian Nation, Richland, Washington;
• Nez Perce Tribe, Lapwai, Idaho;
• Confederated Tribes of the Umatilla Indian Reservation, Mission, Oregon;
• Benton County, Washington;
• National Academy of Sciences, Washington, D.C.;
• Heart of America Northwest; and
• Hanford Energy Action League.

DOE also requested that the National Academy of Science review the Draft EIS to determine its adequacy to support decision making for the TWRS program. DOE has consulted with the National Academy of Science review committee since the publication of the Draft EIS and responded to initial comments and questions during preparation of the Final EIS. DOE intends to consider final comments by the National Academy of Science in the Record of Decision for the TWRS program.

7.5 COMMENTS ON THE DRAFT EIS

The Draft EIS was provided for public comment from April 12 to May 28, 1996. During this time, 5 public hearings and workshops were held and approximately 750 written and oral comments were received from more than 350 individuals, agencies, stakeholders, Tribal Nations, and organizations provided comments. In response to these comments and emerging technical information that was not available when the Draft EIS was published, a number of changes have been incorporated into the Final EIS.

DOE and Ecology prepared Appendix L, Draft EIS Comments and Agency Responses, to address and respond to public comments on the Draft EIS. In addition, DOE considered comments from the public, agencies, and Tribal Nations, along with other factors such as programmatic need, short- and long-term impacts, technical feasibility, and cost, in arriving at DOE's preferred alternative. Appendix L contains the comments on the EIS received during the public comment period and DOE and Ecology responses to those comments. In compliance with the provisions of the NEPA and CEQ regulations [40 CFR 1502.14(e)], public comments on the Draft EIS were assessed and considered both individually and collectively by DOE and Ecology. Some comments resulted in modifications to the EIS. Other responses contained an explanation of the reasons that the comments did not warrant any further response or modification to the EIS.

As required in the CEQ regulations, the Final EIS identifies DOE's and Ecology's preferred alternatives. The preferred alternatives were identified based on consideration of environmental impacts, regulatory compliance, DOE and Waste Management programmatic missions, public comments, and DOE policy. Public, agency, and Tribal Nation input considered in DOE's and Ecology's identification of preferred alternatives included concerns, preferences, and opinions regarding the activities addressed in the EIS, as well as expectations of DOE in making the decisions on environmental restoration and waste management programs at the Hanford Site.

A major purpose of NEPA is to promote efforts that will prevent or eliminate damage to the environment by ensuring informed decision making on major Federal actions that significantly affect the quality of the human environment. This EIS has been revised, as appropriate, in response to comments. Comments were received on a wide variety of issues including:

• General and specific preferences for one or more of the alternatives;
• The cost estimates presented in the Draft EIS;
• The characterization and modeling of vadose zone and groundwater contamination;
• How repository fees were calculated and the assumption that HLW would be disposed of at an offsite repository;
• The sufficiency of characterization data to support retrieval and treatment of the waste;
• Calculation of post-remediation risk to a Native American Site user;
• Calculation of potential accident risks;
• The extent of waste retrieval from the tanks;
• Consideration of closure in the scope of the EIS;
• Consideration of impacts to cultural and natural resources; and
• Consideration of alternatives that would not comply with Federal and State laws and regulations.

Based on review of public comments along with consultations held with commenting agencies and State and Tribal governments, primary EIS enhancements include the following.

• Discussion and analysis associated with the disposal of HLW at the potential national geologic repository were reviewed, clarified by separating the discussion and analysis from other components of the alternatives, and current data and formulas for calculating costs were added to Volumes One and Two, as appropriate. DOE has refined the cost estimates for disposal of HLW at the offsite geologic repository. Changes were made in the number of canisters as well as the cost-estimating methodology, which impacted the HLW disposal fees. The size of the HLW canisters was increased to reduce the number of HLW packages requiring disposal. Repository disposal fee estimates were performed using the current disposal fee methodology along with revised canister projections. This approach to estimating disposal fees is a refinement over the estimates presented in the Draft EIS, which were based on a fixed cost per canister for all alternatives.
• The option of longer interim onsite storage of immobilized HLW pending availability of an offsite geologic repository was included in the Final EIS.
• In Volume One, Section 5.11 and Volume Three, DOE revised the risk analysis to include a Native American subsistence user scenario. This exposure scenario was developed at the request of and in consultation with the Yakama Indian Nation, Nez Perce Tribe, and Confederated Tribes of the Umatilla Indian Reservation. This scenario represents a Native American who might engage in both a traditional Native American lifestyle and contemporary lifestyle activities such as irrigated farming.
• Additional consultation with the affected Tribal Nations is reflected in the environmental justice analysis and throughout the EIS, as appropriate.

As committed to in the Draft EIS and in response to comments on the Draft EIS, a discussion of emerging data regarding vadose zone contamination beneath the tanks resulting from past leaks has been added to the Final EIS in Volume One, Sections 4.2 and 5.2, Appendix F, and Appendix K. The data were unavailable for inclusion in the EIS at the time the Draft EIS was published. Much of the data presented in the Final EIS are based on preliminary analysis of the vadose zone contamination, and thus the EIS presents several scenarios that are currently under review by DOE and Ecology regarding the cause, nature, and extent of the contamination. Cesium-137 and other radioactive contaminants from past leaks from the tanks have recently been found at greater depths below the tanks than previously known. This means that some of the contaminants that were expected to move very slowly towards the groundwater have moved more quickly than previously anticipated. The mechanisms for how these contaminants have moved more quickly than anticipated are not fully understood, and DOE has implemented a program to determine the mechanism(s) for this transport. The Final EIS presents a discussion of the data collected to date, potential mechanisms for the transport of the contaminants, and how each mechanism might affect the impacts presented in the Final EIS. Potentially this issue could affect closure of the tank farms and the measures taken to control leaks during retrieval.

Other enhancements to the EIS included modifying the Phased Implementation alternative. The Draft EIS included one full-scale separations and immobilization facility during Phase 2 (full-scale production). This was modified for the Final EIS to include two smaller facilities that together would process the same volume of waste as the large facility shown in the Draft EIS. This change was made to ensure that the EIS bounded the impacts associated with the phased approach for the implementing extensive retrieval alternatives. Accident discussions and analysis were reviewed and emerging data were added to Volume One, Section 5.12 and Appendix E. The EIS was also revised to reflect 1995 Site environmental monitoring and reporting (PNL 1996).

Additional analysis was performed to assess the volume of HLW that would be expected for the ex situ alternatives. This analysis provided an improved planning basis for the volume of HLW that would require interim onsite storage and offsite disposal at a geologic repository. Refinements in the alternatives and revised tank waste inventory were also made. These refinements included 1) adding provisions for 50 years of onsite storage of HLW for those alternatives that included the disposal of HLW in a geologic repository; 2) using dedicated trains to ship HLW to a geologic repository; 3) increasing the amount of contaminants that could potentially be released during certain accidents; 4) adding 22 curies of iodine-129 to the tank waste inventory; and 5) refinements in the amount and source of construction materials and other resource requirements. Also, the Draft EIS contained an analysis of uncertainties for each relevant component of the environment (e.g., risk, waste inventory, groundwater migration) in the applicable section of the EIS. For the Final EIS, the evaluation and discussion of uncertainties was expanded and presented together in Volume Six, Appendix K.

Finally, DOE expanded the EIS analysis of a variation to the Ex Situ/In Situ Combination alternative (known as Ex Situ/In Situ Combination 1 alternative in the Final EIS) presented in the Draft EIS. This alternative was described in the Draft EIS in the cover letter and preface to Volume One and is called the Ex Situ/In Situ Combination 2 in the Final EIS. The Ex Situ/In Situ Combination 2 alternative is similar to the Ex Situ/In Situ Combination 1 alternative that was fully assessed in the Draft EIS, except that the waste would be retrieved from 25 tanks rather than 70 tanks. Both of these alternatives are based on the retrieval of the wastes that would provide the greatest contribution to long-term health risk. The discussion and analysis for this alternative are presented in Volume One and Appendix B.

The changes and refinements described previously resulted in relatively small adjustments in the resource commitments and the calculated environmental and human health impacts. The only large change in impacts resulted from the reevaluation of an energetic fire in a hydrogen generating tank for all of the alternatives and the costs associated with the disposal of the HLW for the ex situ alternatives. Overall, the relative relationship of the impacts between alternatives did not substantially change except that the potential operational accidents for the No Action and Long-Term Management Alternatives would be substantially higher than the other alternatives.