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Dennis Faulk’s Interview

Manhattan Project Locations:

Dennis Faulk served as the project manager for the Environmental Protection Agency at the Hanford Site. He began working for the EPA in 1991. In this interview, Faulk explains the early years of Superfund cleanups in the 1990s, forming the Hanford Advisory Board, and the EPA’s relationship with the Department of Energy at Hanford.

Date of Interview:
September 11, 2018
Location of the Interview:


Cynthia Kelly: I’m Cindy Kelly. It is September 11, 2018. I have with me. Dennis Faulk. And my first question is to please say your name and spell it.

Dennis Faulk: Dennis Faulk, D-E-N-N-I-S F-A-U-L-K.

Kelly: Terrific. 

Kelly: You had an illustrious career with the Environmental Protection Agency. 

Faulk: It was a great place to work.

Kelly: It was a great place. Tell me about where you were from, when you were born, and how you got interested in environmental.

Faulk: I was born in Grandview, Washington, down in the Yakima Valley. It’s about 40 miles from here and about 40 miles from Hanford, as the crow flies. I never really knew much about Hanford growing up, except that Hanford kids were special because they got a special slip they brought to school. It turns out it was, they got money for working at Hanford—payment in lieu of taxes type thing. But as a kid, I didn’t know that. I didn’t give Hanford much thought.

My brother came to work out here back in the early ‘70s. I went on to WSU [Washington State University] to become a school teacher. Taught Ag [Agricultural Education] for three years. Wasn’t the greatest teacher in the world, but I did like education.

I came out to Hanford to earn some extra money to go back to college. I was supposed to be here three months. It ended up lasting 32 years. I started in N Reactor and reactor operator. When Chernobyl happened, the fate of N Reactor was sealed. It never restarted, and I ended up at the Plutonium Finishing Plant, and from there, EPA.

Kelly: Wow, that’s quite a career.

Faulk: Quite a jump.

Kelly: Oh, my goodness.

Faulk: I don’t know if others have told you, but when the clean-up started in 1989, if you had a degree, pretty much any environmental job was open to you. Because back in the late ‘80s, there was really not the environmental field. That was really the big beginning, ‘85 and on, where the environmental field grew so large.

Kelly: What was your field?

Faulk: My field is Ag education teacher. I have a degree. I have a K-12 certificate that’s still valid today. At some point, I may go back and teach some school. Right now, I am enjoying retirement. Lots of golfing, lots of traveling. 

Kelly: That’s great. I want to hear about your world, about all of those years you spent at EPA, starting in ’80—which year?

Faulk: I started in 1991 with the EPA. Our role at Hanford and pretty much every other federal facility was oversight role. We basically make sure that all of the federal environmental laws are followed.

We also are the ones who select the remedy, if there happens to be a disagreement between the parties. We’ve never had to do that alone. We always had both the State of Washington and DOE [Department of Energy] on board with the remedies we’ve selected. Again, we would set the “how clean is clean” standard within our decision documents. For Hanford, it was a big unknown. No one had done radioactive clean up before, and there was a lot of skepticism that it could be done.

Turns out, cleaning up radioactive soil is probably one of the easiest things in the world to do because almost all of our waste sites, at least along the river, had gamma emitters. Of course, a Geiger detector can detect it in the soil. In retrospect, it turned out to be one of the easier clean ups, because we could actually chase the contamination with our day to day handheld equipment. That was a big surprise to a lot of people.

The other surprise is just how much chemical contamination there is at Hanford. If you look at all the major groundwater pump and treat systems, they are all focused on chemicals, be it chromium along the river or carbon tetrachloride on the central part of Hanford.

The reason for that is, the Department of Energy and their contractors were so focused during the production years on radionuclides, they never checked for chemicals. When a retention crib or whatever had met its doom because it failed for a radionuclide, more than likely, it also failed for chemicals. We didn’t check for chemicals until the mid-‘80s. Of course, when we started looking for them, we found them everywhere.

Kelly: Interesting.

Faulk: I don’t know if you had heard that one yet. Had you heard that about, again, the chemicals being more problematic than the radionuclides?

Kelly: No one said that.

Faulk: You have to kind of look at it in retrospective. Feed me another question. 

Kelly: Well, this is interesting. You were there in ’91. In ’92 was the Federal Facilities Compliance Act. Can you talk about that, and how it changed things?

Faulk: For Hanford, not a lot on the work that I oversaw because I oversaw the Superfund cleanup, which was clean up the soils, groundwater, and old buildings. The Compliance Act really put DOE on a schedule to get them in compliance with RCRA, the Resource Conservation [and] Recovery Act. Each site would come up with these site management plans. That was a pretty big deal, for that.

Then the other thing coming out of that was, the idea of having these federal advisory committee groups around the nation. The Department of Energy jumped on it immediately, and formed them at all of their major sites. The Department of Defense was a little slower to act, but they also set up—they called them Restoration Advisory Boards. That was the other good thing that came out of that whole Federal Facility Compliance Act, and then led to the Keystone Dialogue and ultimately establishment of these boards.

Kelly: Interesting. When we go back to your perspective working on the Superfund cleanup, maybe you could talk about what was Superfund and what did this cleanup entail?

Faulk: The Hanford site is unique, and the Hanford agreement is unique in that it tries to incorporate RCRA and CERCLA [Comprehensive Environmental Response, Compensation, and Liability Act] together. We always call it RCRA/CERCLA integration. The best integration is when everything works together perfectly, which is never.

But ultimately, we are taking care of historic sites under the Superfund program. It was those 2,000 cribs and trenches out there that had received historic discharges. The decision was made pretty early on to take care of all of the groundwater under the Superfund program. It’s got more flexibilities than RCRA, and it did seem like a better tool. The state was agreeable to that. Then we took down a lot of old buildings using the Superfund process also. It’s a different part of the Superfund process called removals. Very effective.

The other thing about the cleanup that most people have lost is—probably the number one thing we did in the early ‘90s was turn off liquid waste discharges to the soil. It’s pretty hard to clean up ground water if you’ve still got millions and millions of gallons of contaminated water continuing to recharge it. By about 1995, all of the liquid discharges, outside of one or two septic systems, had been turned off. That really—if you look at Hanford cleanup—it got started in earnest about 1995. Ground water systems were starting to go in, because we were drying up the aquifer and not putting millions of gallons back into it.

Kelly: In ’95, how many plants were operating that were discharging these wastes?

Faulk: Just about every plant was discharging wastes. They weren’t operating, but they still had cooling water that had to go through them, large septic systems. Hanford is a big city—well, 20,000 people. All of that infrastructure water still had to happen.

They built two treatment facilities, one in 200 West—or excuse me, 200 East—and one in 300 Area. Those processes that still had chemicals in them and radionuclides actually went to treatment facilities. Then the water was injected in a site where it wasn’t contaminated.

Kelly: Were any of the reactors out there part of this? I know it was ten miles away from—

Faulk: The reactors, or the most part, were already in a mothballed state. Outside of N had a few people, but again, they had discharged all the fuel. In fact, the N area fuel is what gave rise to the problems in K Basin, because all that fuel got moved over there, and then over the years corroded.

Kelly: The other sources of this continuing discharge were just plants around the central plateau?

Faulk: Central plateau and the 300 Area. The process water was still running, because the facilities hadn’t been cleaned out. Until you put a facility in to what we call “dark and dry,” you’re going to have some liquids generated, more than likely.

Kelly: You were able to do that in just a year?

Faulk: It took about three years. We started in 1992. Then by about 1995, those two plants had been built and the discharges had ceased.

Kelly:  Had they ceased, or were they going through the cleanup thing?

Faulk: Well, some of them—we say they were ceased, because they were no longer going to the soil column.

Kelly: I see.

Faulk: It’s one of those little-known facts that nobody ever even thought about. They had set a milestone to turn those liquid discharges off, and it was met.

Kelly: Then in ’95, you mentioned there were 2,000 cribs. 

Faulk: About 2,000 waste sites at Hanford.

Kelly: Two thousand.

Faulk: About 1,000 along the river and about 1,000 up on the central part of Hanford. When we originally started, they thought there would be about 1,000, but through the process of clean up, we discovered a number of new sites. The contractor had a program they called the Orphan Sites Program. They would just go out and find sites, quite literally. Then we would add them to the cleanup decisions, and clean them up as we went along.

Kelly: You said earlier that the ground contamination was easy to detect because you could just use Geiger counters. How did you find all these orphan sites?

Faulk: Manpower. They would just line up hundreds of people—a lot of times, interns—and just start walking. They would walk the desert.

Kelly: With Geiger counters?

Faulk: No, just visually.

Kelly: Really?

Faulk: You would see a lot of the sites [that] were added later turned out to be were laydown yards where paint was disposed of and oils, greases—those types of things. Usually you would see physical debris on top. Then they would GPS them in. We had a process to say, “Does it look like a duck?”

“Yes, it does.” So, it got put in. If it didn’t look like a duck, then it would be excluded, because that’s the one thing with the Superfund program is, you actually have to have a hazardous substance there in order to use the process.

Kelly: It has to be on your list of chemicals that are suspected carcinogens or some other—

Faulk: Right.

Kelly: —known adverse effect?

Faulk: Yeah. 

Kelly: But they weren’t hard to find?

Faulk: Apparently not, yeah.

Kelly: Wow, so 2,000. How did you go about prioritizing them?

Faulk: This was done really by my predecessor, Doug Sherwood, and his team. We looked at the amount of volume, the material that went to a particular disposal facility. The very first cleanups were at the high liquid waste disposal facilities, where literally billions of gallons of water and radionuclides and chemicals had been dumped. That was the first bite of the apple, along the 100 Area.

The last ones we did were the burial grounds because they contained dry waste. There wasn’t the driving force for them to get to ground water. That’s how the prioritization worked. Now, there’s just a handful of sites left to do along the Columbia River. 

Kelly: Let me just get a sense for this liquid waste. They poured gallons of liquids into the earth without a containment?

Faulk: Correct. They would build either trenches or cribs. In my view, the difference is, a trench is a lot bigger than the crib.

Kelly: Yeah, describe a crib. Is it lined?

Faulk: No, it’s not lined. Some of them did have timbers in the tops of them, but no. Literally, you would go dig a hole, run your discharge pipe out to it, and similar to like a septic tank drain field, most of them would have a pipe down the middle where the water would then disperse. Most of them were for fuel failures. Given that there were hundreds of cribs and trenches out in the 100 Area told you that they had an awful lot of fuel failures over the course of the production years.

Every time they would have a pinhole leak in a piece of fuel, they would divert that water to a trench. The normal method of operating was to go to a retention facility. They were actually called 116C5’s, B5’s. They were big metal retention facilities where they hold the water for a few minutes, let it thermally cool. Some of the really short-lived nuclides would decay off. Then it would go directly out into the middle of the river. That’s the normal process for how the reactors would operate. Every time they would get a fuel failure, they would divert that water. That ultimately led to all of these contaminated sites.

Kelly: Can you just explain it—I think this is really important, that people understand what a fuel failure is.

Faulk: The uranium fuel was inside a jacket of either zirconium or some other type of protective metal. That outer sheathing would get a pinhole in it where it would start to spray out radionuclides into the cooling water. The operators would know that, because they are monitoring what’s going on within that water system. As soon as they would detect higher radiation levels, they would divert the water to these cribs. As I said, they had a lot of fuel failures, because of the number of cribs and trenches they ended up having to build. 

Kelly: There were a couple of thousand fuel rods in a reactor at any one time.

Faulk: Right.

Kelly: Correct, and these process tubes are independently monitored. They would know the water that was contaminated is from this one process tube. Then they would just empty that.

Faulk: They would empty that tube out.

Kelly: The tube out.

Faulk: Yeah.

Kelly: And replace it. This was really a temporary—of course, the water is going through there quickly. So, it’s a lot of water fast.

Faulk: Right, yes. I don’t know how long it took them to do the diversion. But it was probably relatively quickly. Someone had to go out in the field and turn a valve, send the water that way instead of that way.

Kelly: Right. The level of contamination probably varied, with one little pinhole versus several.

Faulk: Most of the liquid waste sites really had very low levels of radionuclides discharged to them. But doing that over a 20- or 30-year period, it builds up. You are just continuing to add and add and add. The cleanup levels in today’s environmental standards are quite low. It doesn’t take very much to push you over that limit.

Kelly: What are the cleanup levels as compared—

Faulk: For radionuclides, there actually is none under EPA for soils. What we were using in the early years was a 15 millirem cleanup standard. Then you would back calculate to a picocurie per gram for each radionuclide. That 15 millirem came from some already published standards, which was 10 millirem out of the air pathway and also 4 millirem from groundwater. The thought was, “Well, 15 millirem from soils is pretty equivalent to the other two pathways.”

EPA then came out a few years later with a policy, “No, 15 millirem is not the right number. You should be using 10-4, 10-6 risk levels, which when you can back calculate is a little below 15 millirem.” But the way most clean ups are done, you are really getting back to background, because you are removing all of the contamination and replacing it with clean backfill. Although you might have a little bathtub ring with some radionuclides, could you ever go find them again? Probably not, because you have all of that clean backfill sitting in your bathtub. 

Kelly: So, 20-30 years of pouring these liquids that are slightly contaminated with radionuclides, and your cleanup fix is to dig with backhoes or whatever?

Faulk: That’s it.

Kelly: The entire pit, and then what happens to that contaminated soil?

Faulk: Most of the soils went directly up to the central part of Hanford at our Environmental Restoration Disposal Facility. It’s the largest disposal facility, at least in the United States, and maybe the world.

Kelly: How big is it?

Faulk: I can’t tell you now, but it’s really big. I’ve lost track in a year of retirement of how much was in it. Then, if it had chromium contamination, almost all of the chromium contaminated soils need to be treated, because the chrome is very mobile. The last thing that you want to do is put it up in the central part of Hanford and have it get back in the environment. All that waste was treated up at the disposal facility, to bind it up. So that’s a simple thing.

The other thing that’s pretty interesting is, the cleanup always got the mantra that it went to 15 feet, which is vetted in state law. For an unrestricted type cleanup, you have to go to 15 feet. That is to allow for a basement to be built. Most basements are 12 feet, at least in this state. It gave you a three-foot buffer. At Hanford, the rods required more than that. They required you to take out the engineered structure, or to the mass of contamination.

The reasoning was, most of the big disposal facilities, the actual discharge pipe was about 15 to 17 feet below the surface. The last thing you want to do is dig down through basically clean soil, and leave hundreds of thousands of picocuries right below you. The Department of Energy was agreeable, because it didn’t seem smart to spend taxpayer dollars to dig clean soil. It’s a nuance in the records of decision that probably only the authors know and those people who have to actually go out and implement the cleanup.

The other thing, and I will never forget this: I was talking to one of the managers about it. He happened to be the B Reactor manager. I said, “I bet your guys who are doing this digging don’t understand what they are doing.” Because, well, the way the cleanup was set up, we had two different clean up levels. We had surface exposure, so how much millirem could you get. Then we had protection of ground water. When you got below that engineered structure, we went from worrying about someone getting external exposure to the groundwater pathway. We could still leave quite a bit of contamination at depth, if it wasn’t going to get to groundwater.

The person’s name was Ken. I just said, “I bet these guys sit down at the tavern and go ‘I don’t know why we stop when we stop. There is no rhyme or reason to it.’” We actually sat down with them and explained, this is why we are doing what we are doing. I don’t know if it helped or not, but it seemed like the right thing to do at the time.

Kelly: Were there any sites where there was a not a threat to the groundwater because the aquifer wasn’t underneath it? How does it work?

Faulk: Yeah, many sites didn’t have a groundwater issue with them. As soon as you got to that bottom of the engineered structure or 15 feet, then you would look and see. Particularly like cesium or strontium, they were relatively stable in soils. If you had a site with those two contaminants, once you got down to that level, you could leave the rest.

Kelly: The rest of the cesium and strontium?

Faulk: Right, so again some of those waste sites could have cesium and strontium another ten or 15 feet below where we stopped digging. That’s all recorded.

Ultimately, if the property ever gets transferred—not that anybody thinks it will—all of that will be recorded in deeds, etc. The recommendation from the GSA [General Service Administration] was, if the Department of Energy ever decides to sell this land, they should keep the mineral rights regardless. Because then you can control, “If you go below X, you are trespassing.”

But there is no expectation that this will be anything but open recreational area, more than likely either controlled by the federal government or the state government in the long term.

Kelly: When was this? People credit you with being the mastermind and sort of the maestro of the [Hanford] Reach protection.

Faulk: Yeah, I wouldn’t say the maestro. I would say I was one of the architects, along with a person from the Department of Energy and a person from the State of Washington. The smartest thing the Department of Energy did was, they actually brought in a coach for us and made us a high performing team. It wasn’t DOE. It wasn’t EPA. It wasn’t the state. It was the three of us and the contractor support working on a common goal.

That was probably the best investment the Department of Energy ever made. They even made us take Meyers-Briggs tests. It was so interesting because one of the contractor people, I just couldn’t work with. After we got those results back, we realized that our styles were so different. From there, we actually began to work together, and it was simply understanding that we had very different styles of learning. That was probably the greatest thing, was the teamwork that we had to get to those cleanups.

Under the Superfund program, we start small. You never do anything in Superfund big at first, because you want to make sure you can do it. In the case of that team and our cleanup, we actually started at five sites. We called them treatability tests, and we just went out and practiced, basically. As I said earlier, there was a lot of skeptics of whether you could clean up radioactive material. Through those five sites, we proved yeah, you can, and it works really well. No glamour to it. It’s simply digging a hole—brute force against the soils.

Cindy, one other thing—I don’t know if we are going to go there—but one of the things that the early organizers of the Tri-Party Agreement realized is, we had to have public buy-in into this clean up. Back in the early ‘90s, we formed something called the Future Site Uses Working Group, which ultimately gave rise to the Hanford Advisory Board. 

The Future Site Uses Working Group report became the road map that at least the regulatory agencies used to help guide the cleanup. The basic message in that report was, “Clean up along the river to the best of your ability, knowing that we are going to have to use the central plateau for waste management into the future.”

A pretty simple concept, but to get people from so many different walks of life to agree to those premises—that really became a road map. It made things a lot easier because when push comes to shove, we could come back and say, “This is really the will of the people.” So that was a really helpful tool to have as we sat down to negotiate what this clean up might look like. 

Kelly: Who was DOE’s lead for this, do you know?

Faulk: DOE is the one who approached us about the Hanford Advisory Board. 

Kelly: About having the Future Use?

Faulk: I believe that really came from my former boss, Paul Day. He understood that. At the time, Leo Little and Ron Izat were with the Department of Energy. They were very agreeable to it. Energy pays for everything here, pretty much. EPA did contribute $10,000 to that multimillion-dollar effort, but ultimately, I think it was Paul Day with his folks at Energy that said, “This is something we ought to do.”

Kelly: Yes. That led to the creation of the Hanford Advisory Board?

Faulk: Yeah, in between, there was a Tank Waste Task Force, which was set up very similar—almost the same players. It went from the Future Site Waste Working Group to the Tank Waste Task Force, then morphed into the Hanford Advisory Board.

At EPA, I felt like we had a big part in helping get the board established. Department of Energy was originally going to set up their own board, and we were not going to be part of it. The state wasn’t going to be part of it. The state already had the Nuclear Waste Advisory Council. EPA is sitting here going like, “All we need is dueling boards, and we are not part of either one.”

Working with my colleague at the time, Max Power, Max was able to work through the state. The state allowed the Nuclear Waste Committee to sunset, and join the Hanford Advisory Board. The unique thing there is, Energy gave us an equal say. We are the only board I believe in the nation, for either Department of Defense or Department of Energy, where the board advised all three agencies.

That was a big give for the Department of Energy, especially because the stakeholders tend to be watchdogs. EPA and Ecology were watchdogs. A lot of times, their advice tended to favor our viewpoints. But they have been together over 20 years now, incredibly successful. I’m very proud of them, since I helped put that together, too.

Kelly: That’s fabulous. What else worked about this whole experience in cleaning up this immense—

Faulk: For me, it was keeping those core values of, “We are going to try to do the very best job possible on the river and return it to”—we never dictated what the use would be, but the idea was pretty much any future use, outside of gravel pits, could happen out along the river.

The Department of Energy, every few years, would get a new head of the cleanup program and they always had a new idea. One of the things that we tended to do, at EPA particularly—we had very little turnover. I was from the cleanup from 1991 until I retired last year. Our institutional knowledge was pretty strong. Every time they would come with a new flavor of the month, we would be able to say no.

Probably the biggest one there was, they had something called Risk-Based End States. I am not sure what it really meant, but in Energy’s mind, it was going to be cheaper. We were just making the decisions on the burial grounds along the 100 Areas at the time. Energy was adamant that everywhere else in the nation capped burial grounds. That was EPA’s standard. Why don’t we cap them in the 100 Areas? We go back to that premise of, “Why would we want to leave all of this junk”—the official term we called it was “crap”—”along the river?”

We were able, in the end, to get the department to dig them up. I’m thankful we did because we ended up finding literally hundreds of spent fuel pieces in the burial grounds, that even today are reading incredibly high levels. If somebody had gotten into those in the future, it would not have been a good situation.

The funniest thing—I was talking to one of the historians, and I said, “Why didn’t we know about this?” Because  finding the spent fuel in the burial grounds was an absolute shock to us. The gentleman said, “That’s because they had make-up buckets, so their counts were always right.” It was just a little-known fact that never got actually recorded into the cleanup history.

The other thing that we missed is, we were expecting an awful lot of—I’ll call it plastic type material, things that came out of the reactors’ cleanup, the clothes, etc. None. It turned out they all had incinerators. They burnt all that loose material. Those were two big surprises that none of our records really told us. This historian said, “Well, I could have told you that.” Okay, ell, now we know.

Kelly: Interesting. What do you think of the future? Where are we going to go with this?

Faulk: Oh, the future. This is a tough one for me. I feel like my legacy was leaving the river in a really good condition.

We’ve really not done much up on the central part of Hanford. That a disappointment for me. Well, and as I said, we ran into a heck of a lot more waste in the 100 Areas than we ever expected. I think it was almost double the volume.

The other thing is, most people know projects are very expensive at Hanford. When I left, we really had our money tied up in three major projects on the cleanup side: the Plutonium Finishing Plant, K Basin sludge, and the groundwater treatment systems. There is not a lot of money to go around for the rest.

The big question that Hanford has to wrestle with is, what do we do with that central plateau long term. Is it going to be a waste management area in perpetuity? The logical side of my brain says yes. If it is, then why don’t we clean it up like a waste management area?

Then the environmental side of my head goes, “But if we do that, we are going to leave a lot more waste in place,” because you will treat it as a ten-mile waste pile instead of each individual. Those decisions haven’t been made yet. That is ultimately going to be a really difficult decision for somebody in the next five or so years.

Kelly: Did you say there were 1,000 different—

Faulk: There’s about 1,000 waste sites in the central.

Kelly: In the central plateau?

Faulk: Yeah.

Kelly: Those have not yet been addressed?

Faulk: No. The groundwater in 200 West has a decision over it. Then plutonium sites right outside the Plutonium Finishing Plant have a decision. That decision is to dig up some of the plutonium.

The logic for moving those plutonium sites forward is, you’ve got an experienced crew working at PFP [Plutonium Finishing Plant] that could transition, because working with plutonium is very special. Not everybody can do it. You definitely want trained workers, and people who have been doing it for ten or 15 years tearing down PFP seemed like a logical break.

Having said it, it’s incredibly expensive to dig into those plutonium cribs. They are not going anywhere fast. I doubt if they get done in the near term, but that’s not my call anymore.

Kelly: You mentioned all of these 100, or 1,000 cribs, minus whatever you’ve addressed. You had two other priorities or things that are being addressed—PFP and what was the other one?

Faulk: The groundwater.

Kelly: The groundwater. But you haven’t mentioned the tanks. Is that by implication, that the tanks direct attention towards the groundwater?

Faulk: I had the luxury of never having to deal with the tanks, because I was Superfund and we dealt with old contaminated buildings, groundwater, and soils.

The tanks are being cleaned up on the Resource Conservation Recovery Act, and the state has the oversight there. Luckily, I kept my career completely away from that. The only tie I have is on the groundwater part of the cleanup. Ultimately, I think the Department of Energy will deal with the deep contamination under the Superfund program under those tanks. But as we sit today, they are all still RCRA.

Even to the non-novice, people I have worked with for 20 years, “I didn’t know that.” What we realized is, a lot of the practices at Hanford never got translated into the Tri-Party Agreement. What we do on the ground may not really reflect what’s in the agreements.

Then the question we’d always ask is, “Is this big enough that we would go change the Tri-Party Agreement?” The only really major change we did under my career is, we did add a section to specifically deal with old buildings, and that’s section eight of the Tri-Party Agreement. It had really not been thought of when the original cleanup was done, or the cleanup agreement was done

Kelly: Did you do the 300 Area buildings?

Faulk: We did the 300 Area. In the most simplistic view, we say the state has the tank farms. EPA oversees the rest of the cleanup. In practicality, the state was there with us because they do a lot of the Superfund work, too, because our staff was way too small. We split the Superfund work pretty much down the middle with the state, but we retained all the regulatory authorities.

That worked pretty good, because the state are paid by DOE. They have a much larger staff. EPA now is down to three people working on Hanford, from a high of eight during the ramp up of the cleanup.

Kelly: Is this a reflection of just the woes of EPA that kind of got cut back? Or is it just the way it—

Faulk: I wouldn’t say it’s the woes of EPA. I would say it’s the woes of the cleanup. If you have your money going into three major projects, those projects are very mature. They take very little regulatory oversight.

Just the nature of the beast now is, there is not going to be 15 [inaudible] investigations going on at one time. There are going to be one or two. Probably for the rest of the cleanup, about three people is probably about right. Because there is no expectation, we are going to get millions and millions of dollars infused into a very large clean up budget already.

Kelly: That’s pretty well spoken for, command released direction is laid out.

Faulk: Correct. The direction is laid out for at least the next few years.

Both the K basins and the PFP have not gone as well as they should have. Every year those facilities don’t get done, that’s taking that $100 or $200 million that was going to go to do this work to finish that. That’s probably been the biggest culprit at Hanford—100 Areas, twice the number of waste sites. We were supposed to be done in 2012. We are going to get done in 2021. But the scope of work has continued to grow.

Kelly: Because that’s really the K basins?

Faulk: In the scheme of all the work EPA oversaw, K basins has been the thorn in our side. As we walked in here, I was telling you the philosophy was, “Just let’s get out there and do it. Let’s do what we can do.”

K basins was one of those few projects that kept saying, “We can invent a better plan. We can invent a better plan.” They did it five times. Finally, the fifth time, they said, “Enough is enough.” They were starting to go move the rest of the sludge out of there now. 

But a lot of times it’s just, “Get a plan. Stick to the plan.”  To quote one of the DOE or contractor managers was like, “Plan the work. Work the plan. Plan the work. Work the plan.” That gets it done.

Kelly: Someone was saying earlier today about the tank situation, you had five different plans and they get scrapped for different reasons.

Faulk: Right. I can say this because I didn’t have anything to do with it. In retrospect, if we had been doing the tank clean up under the Superfund program, I think we would have done exactly what we did on the soil and groundwater side. We would have started with baby steps. We would have proved that we could do it. Maybe clean up one tank. Prove we could do it, and then scale up from there.

As an example, the big pump and treat systems that’s treating 2,000 gallons a minute in the central at Hanford started as a 50 gallon a minute pilot. We got good at it. We went to 150, and then we moved it to, at that time, full scale at 200. Then now ultimately, it’s 2,000. I think if we had gone out and tried to build a 2,000 gallon a minute plant in 1992, I don’t think we would have been successful.

But the tank program is now 25-30 years down the road. You can’t go back and say, “Gosh, I wish I had done it differently.” Now, you’ve got to work the plan.

Kelly: Although I get the sense that it’s still up in the air.

Faulk: Well, certainly what to do with the low-level fraction is up in the air. But there are a lot of people that don’t think vitrification is the right answer. The plant they are building now doesn’t have the capacity to deal with it all. Ultimately, I think you will see different decisions made for the low-level fraction of the tank waste. Grout is getting to be a popular word again.

Kelly: It is. It seems to be.

Faulk: Yeah, and it may be a good answer. That’s the other thing at Hanford, and it’s been a bugaboo for me is: it’s always all or nothing. “We are going to have to dig clear to groundwater, or we are going to have to treat 100 percent of that, etc.” When the real answer is somewhere in between. If you go back and look at our Superfund decision documents, almost the first drafts always had us chasing something that was absolutely ridiculous. But it was just the philosophy of, “You either got to do it all, or you don’t do anything. 

Kelly: Were these first plans generated by the contractors?

Faulk: Yes.

Kelly: They had incentive to do the ultimate, because this was their bread and butter that will see them through a decade.

Faulk: You could look at it that way. I never viewed it that way. I viewed it as a mantra that was really permeating from the highest levels of DOE: “We are going to make this thing so expensive and so ridiculous nobody will want to do it.” We always came back to the middle. But I can’t tell you how many drafts always had that, “We’re digging to groundwater.” In three instances, we did, but we were chasing chromium that was contaminating the groundwater consistently.

Kelly: You were singing your praises of the Hanford Advisory Board in this mix of stakeholders and tribal members. 

Faulk: The Hanford Advisory Board is an interesting—I will use the word “beast,” because they are large. They are the only board that actually has members and alternates who function as equals. Some can say the Hanford Advisory Board is actually over 60 people, instead of 30 seats. They have always held to their values, and their values are always very pristine: “Protect the Columbia River. Do no further harm. Take forceful actions against groundwater.” All of their core values have always been there, but they also overlay a pragmatic sense. 

They are really good at not saying, “I told you so,” because a lot of times their advice—if it had been followed to the T—would have turned out better for Hanford cleanup. They’ve issued over 200 pieces of advice now. Some of their more memorable ones—the biggest thing back in the early ‘90s was, “Not in my backyard.” They called it “NIMBY.” We didn’t have a disposal facility for Hanford. For them to accept us building the ERDF [Environmental Restoration Disposal Facility] was a really big step and we spent a lot of time.

This was when I’ll say “bad EPA” is, I was talking about all or nothing. Our proposal was to build a seven square mile facility. The Hanford Advisory Board goes, “That is the dumbest thing we’ve ever heard. Why wouldn’t you build it as you need it? 

Oh, well, we hadn’t thought of that.” That’s what we ended up doing is, we authorized the first two cells. Then as we would need more cells, we would authorize them. That was some really good advice they gave us.

They worked really hard on groundwater values and produced a fabulous chart that we still use today. It’s been really good. I was one of three architects that helped put that together. It was really—the foundation was like what the future is like [inaudible] working group. We didn’t really deviate too far from how that was set up. I think that’s why they have become so successful.

Kelly: That’s neat. That’s a great story. Is there anything that we haven’t talked about that you would like to add to spur on the next generation who will be working on this.

Faulk: You have to remember, Hanford is a marathon. You’ve got to just keep running and keep running because ultimately, the people working out there will get to the finish line. It’s hard. It’s hard to keep public interest. The weird thing—I had a lot of private sites, too, that I oversaw clean up. The big difference between the federal government and the private side is, the private side has their money. You don’t have to all of a sudden wait for that fiscal year to bring some money in.

That—at least the last 15 years—has been the biggest challenge for these big federal facility clean ups is, we never had a budget October 1, and a lot of times you didn’t know what your budget would be until halfway through the year. It’s really hard to plan clean up work when you don’t know what kind of money is going to be behind you. That also gave rise to why milestones move so often.

I am not going to penalize the Department of Energy for not getting the money. They have to ask for it. Congress doesn’t give it. So be it. Schedule has got to slide. That to me was probably the biggest frustration of not having that, “We know exactly how much we are getting, and we know exactly what we are doing every year.” We had something called the integrated priority list that we would draw a line. If extra money came available, we would move something above that line. That’s how we dealt with it.

Kelly: And the Hanford Advisory Board was part of that process?

Faulk: Not really. The Hanford Advisory Board—and I think it was wise—they never got in a position of picking priorities. They said that’s not their job. That’s our job to figure out how we end up dealing with the resources. I think that was a wise thing for them to do because when they start picking priorities, things will start falling off the table that maybe they didn’t want to.

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