Fortifying Environmental Compliance Strategies at Hanford - 19541

At the Hanford Site, located near Richland, Washington, the Department of Energy is cleaning up legacy radioactive and mixed-waste generated from the Manhattan Project in the 1940's. A major component of cleaning up the waste is maintaining compliance with federal and state environmental regulations. Environmental compliance is also determined through permits, agreements, and consent orders issued by regulating agencies such as the Washington State Department of Health: Office of Radiation Protection, Washington State Department of Ecology Nuclear Waste Program, and the Environmental Protection Agency. Maintaining compliance at Hanford reduces environmental impacts and addresses violations, or non-compliances. The following strategies improve compliance and support the avoidance of enforcement actions. At Hanford, regulatory agency environmental enforcement actions, and their corrective actions, are tracked to completion using databases maintained by inspection subject matter experts. The databases are used to provide the Department of Energy and contractor management with up-to-date status of regulatory agency activity and the required corrective actions. Trending enforcement actions helps target compliance vulnerabilities. Findings and corrective actions that are entered into the databases are then trended by date, location, responsible contractor, agency, and type of compliance issue. The ability to review previous non-compliances in certain locations of the Site, or by general alleged violation, provides the project's environmental contacts with information on what types of issues to look for on pre-inspection walk downs. Finding non-compliances during pre-inspection walk downs allows the contractor to correct the issue and avoid potential fines from regulating agencies. The walk downs are conducted by environmental specialists and project personnel looking for issues that may be viewed as a compliance problem. Using agency checklists and previous inspection correspondence can help to provide valuable information during pre-inspection activities. Training regulatory agency inspectors on Site security requirements, cultural and ecological standards, and inspection protocols allows for increased efficiency and reduces potential miscommunication between regulatory agencies and the regulated contractors. The training also allows the contractors to give the regulating agencies the up-to-date policies and procedures that will be addressed during the inspection. Hanford has pre-identified inspection coordinators within each contractor to assist in coordinating with Department of Energy personnel, projects, and management prior to the inspections. These inspection coordinators notify affected management, accommodate and escort the regulators to locations they ask to inspect, set up requested interviews, and gather requested information that will need to be cleared for public release. These practices make for positive experiences and interactions with the regulating agency personnel and help reduce and eliminate environmental non-compliances, findings, violations, and fines. (authors)