DOE/RL-97-56

Appendix C - Comment Resolution on Draft of Hanford Site Manhattan Project and Cold War Era Historic District Treatment Plan (May 15, 1997)

Advisory Council on Historic Preservation (submitted July 24, 1997)

Comment: The Table on page 40 that depicts contributing properties recommended for documentation includes a column of information titled, Hanford Theme(s). The information identified included in the column, however, does not correspond with the six Hanford Historic Themes identified on page 10 of the document. Rather, the column seems to identify the primary functions/mission of the Hanford Site, identified on page 21, that a particular property supports. Therefore, we recommend clarifying the title of the column to reflect more accurately its contents.

Response: The title of the column will be changed to Process/Function Classification(s). An explanation of each of the column headings will be provided as an introduction to Tables A.5, A.6, and a.7 (formerly Tables 1, 2 and 3).

Comment: In response to your specific request for input concerning the "Future Use" portions of Tables 1 and 2, it is unclear what is meant by the blank cells in the column. Does this indicate that the future use of the property has not been determined or that no future use is planned for the property?

Response: As noted on page 25, buildings for which no post-cleanup uses have been identified will be demolished. The column was left blank to allow reviewers an opportunity to insert a use code other than the default "DD" for demolition.

Comment: Lastly, properties for which a future use is designated...seem to represent a little less than half of the primary functions of the Hanford Site identified in the draft plan...other important aspects of the site, including health and safety, site security, and waste management are not represented by the properties chosen to be preserved and maintained in place. We recommend broadening slightly the list of properties selected for future use on the Hanford Site, safety and budget concerns permitting, so that a more complete picture of the Hanford mission will be retained for future study and use.

Response: DOE-RL will meet individually with identified interested parties to again request information on future uses before finalizing decisions on which properties will be razed. To the extent possible, DOE-RL will seek the retention in place of properties that represent all functions conducted on the Hanford Site.

B Reactor Museum Association (BRMA) (submitted August 7, 1997)

Comment: The term "mitigate" is used extensively, and members of the public such as those in the BRMA believe it might have meanings other than those we usually find in the dictionary. State explicitly what the term means, or use other terms to make the meaning clearer for a wider audience.

Response: Accept. The term "mitigation" will be defined as used in this document following its first occurrence in the text.

Comment: The necessity of the section "Hanford Site: Origin of Variation" is unclear, unless it is to establish the overall historical context for what follows.

Response: Section IV(A)(1) of the Programmatic Agreement (DOE 1996a) requires that the Treatment Plan address the "variation present in the contributing properties." As you note, this section of the Plan provides an abbreviated discussion of the composition of the Hanford Site by noting both the planned diversity in the location of functions, and the redundancy of properties within similar functional complexes.

Comment: We disagree with the exclusion of the Bruggeman Warehouse, although we understand the reason for doing so. We feel that the Bruggeman Warehouse is of significant historic value in its own right. But further, we feel it may yet play a role in the overall scheme of B Reactor as a museum. Our BRMA Vision Statement is currently being updated, and will include recommendations for this structure.

Response: The Treatment Plan addresses only Manhattan Project and Cold War Era properties. The Bruggeman Warehouse and similar pre-Hanford properties are considered under a separate historic context entitled "The Euro-American Resettlement of the Hanford Site, Washington (Lewis and Clark 1805 - Hanford Engineer Works 1943)." DOE-RL shares your finding of the Bruggeman Warehouse as historically significant. Indeed, the Feasibility Study to be undertaken in support of opening B Reactor to the public will contain a recommendation that the Bruggeman Warehouse be investigated for use as an interpretive center for not only B Reactor history but for that of the Hanford Site from prehistoric times forward as well.

Comment: We all recognize that the B Reactor qualifies under so many different National Register (of Historic Places) criteria that it is not necessary to go into a detailed discussion here.

Response: The section on National Register Criteria is presented to acquaint all readers with the standards that were utilized to evaluate all Manhattan Project and Cold War Era properties on the Hanford Site.

Comment: We strongly recommend the addition of another Hanford Historic theme: the Advancement of Modern Engineering. Indeed, this is the very point we stress when talking to people about B Reactor. Never before or since has a structure of this magnitude been constructed with such swiftness and efficiency. We believe the National Landmark awards given to the B Reactor by three national engineering societies (the American Nuclear Society, the American Society of Mechanical Engineers, and the American Society of Civil Engineers) signify the B Reactor's profound contribution to history.

Response: The focus requested is already represented in the Hanford Themes as expanded in Appendix B (formerly Appendix A). The Defense Mission calls out the timeframe associated with the creation of the Hanford Site as a topic for discussion (1-A-1-a). Architectural History and Landscape History (now in section entitled Construction History) both contain references to the planning, design, and construction of the Hanford Site and its buildings (5-A-1 and 6-A and B respectively). Significant engineering accomplishments are specifically noted in Selection Criterion 5 (page 14) and will be a key component in the chapter devoted to Research and Development (page 21).

Comment: On page 14, the Architecture/Engineering section should include "new reactor arrangement" as one of the unique or innovative processes or scientific achievements.

Response: Accept. Example will be added.

Comment: In criterion 10, "Contamination Level", we believe the task group should have asked, "Could the contamination be contained?"

Response: While not presented as a question under Selection Criterion 10, the nature and mobility of the contamination were considered.

Comment: We believe there would be value in disclosing the National Park Service's guidelines for establishing the level of "appropriate" documentation.

Response: For the State of Washington, "the responsibility for determining the appropriate level of mitigation documentation for structures...lies with the Western Regional Office of the National Park Service." This statement is taken from an NPS document entitled "Historic American Engineering Record, Guidelines for Preparing Written Historical and Descriptive Data" (NPS1992). NPS has also published a companion document "Photographic Specifications, Historic American Buildings Survey, Historic American Engineering Record" (NPS 1989). Discussion of NPS decision-making was determined to be outside the scope of the Plan.

Comment: State what considerations would override the preferred option of retention in place.

Response: A statement will be added to note those conditions that work against retention in place.

Comment: BRMA has provided comment and other correspondence on many occasions in the past, and will continue to do so whenever DOE requests. We are particularly interested in ongoing discussions concerning the detailed steps necessary for conversion of B Reactor to a first-class public museum, the timing of those steps, and the resources necessary to carry them out.

Response: BRMA is recognized as an "interested party" and full participant in these objectives.

Comment: The BRMA feels keen concern about the objects that may be discarded. The need for curation is acute and we urge DOE to hire local experts to curate these items immediately, rather than pay out-of-town experts to continue studying the issue.

Response: DOE-RL has established interim procedures for the identification of items that may have educational or interpretive value. A team approach, uniting local and state experts in architectural history, artifact conservation, curation, history, historic archaeology, and records management, has been initiated to perform building interior assessments. These assessments will be conducted over the next year.

Comment: The BRMA has an oral history project under way that might be mentioned in the Oral Histories section. With our modest budget we employ a professional Seattle-area filmmaker to record the recollections of veteran Hanford people who will not be with us much longer.

Response: The BRMA oral history program will be called out in the discussion under Public Interpretation.

Comment: Add "Construction" to "Site Selection, Acquisition, and Design" in the Chapter 1 description.

Response: Accept. "Construction" will be added.

Comment: Add "Design/Construction" to the topics to cover in Chapter 2. Considering the scientific and engineering advancements and the phenomenal speed with which this occurred, this would make the chapter more complete and more enjoyable to read.

Response: As noted above, these topics will be addressed under the Architectural History, Defense Mission, Landscape History, and Research and Development themes. In fact, the Architectural and Landscape History sections have been combined and renamed as the Construction History section. These are critical concepts in the interpretation of Hanford; they will not be overlooked.

Comment: In the list at the bottom of the page [page 21], we interpret "Social History" in the broadest sense; that is, world history. In that context, B Reactor looms large on the world stage. It would be difficult to overemphasize its pivotal role in the course of human events. Its importance begins with the significance of its very creation - an immense engineering feat not possible to duplicate today. This accomplishment alone should ensure the structure a permanent place in our nation's history. Adding its role in ending WWII, and its decades-long contributions to our nation's nuclear deterrent makes preservation of B Reactor an imperative if generations yet to come are not to be denied access to this crucial time in history.

Response: Because of the international significance of B Reactor, this facility is being individually recognized through HAER documentation. All the aspects called out in your comment will be incorporated within that narrative. Besides this singular treatment, B Reactor will also figure prominently in the general report narrative.

Comment: We are pleased to see that B Reactor is to be central to the discussion of reactor technology in the Final Treatment Report. In fact, as we continue reading the outline of the Final Treatment Report, it strikes us that B Reactor and the records and artifacts it should contain has the potential of satisfying many, if not most, of the goals of the report.

Response: While B Reactor, as just noted, will be a featured property, the objective of the Final Treatment Report is to give a representative accounting of those processes, events, and facilities that constitute the Hanford Site. No single property can satisfy this objective.

Comment: In the discussion of the types of resources (primary documents, technical reports, etc.), we note your uncertainty as to "...how or where these resources will be curated." We have a ready answer. We propose using one of the side rooms at B Reactor as a "Resource Room" to house and preserve much of this material. Its use would be monitored during the times the Museum is open and staffed. There would be a large amount of it in one location, making it attractive to researchers. And it would certainly compliment the use of B Reactor as a museum.

Response: An investigation into what steps are necessary to release rooms within B Reactor for storage of artifacts and records is underway.

Comment: In the lower paragraph in this discussion [page 24], the terms "accessioning" and "deaccessioning", even if found in the dictionary, sound like Federalese and do not enhance understanding. Please use simpler terms.

Response: These terms will be changed to "acquisition" and "disposition" respectively.

Comment: We suggest that in the next iteration of the Hanford Strategic Plan a sentence or two be devoted to the need for preservation of historical artifacts. This seems logical in view of the significant effort currently being devoted to this subject in general and B Reactor in particular.

Response: Accept. Information will be provided for incorporation within future revisions of the Hanford Strategic Plan.

Comment: Two to four drawings or photographs is insufficient for a facility like a reactor, and we urge the Expanded Hanford Property Inventory Forms (ExHPIFs) include more than that number if the facilities so warrant.

Response: The HAER documentation to be prepared for B Reactor will contain numerous drawing and photographs of the facility. These illustrations will provide a visual image of B Reactor specifically and, by extension, Hanford reactors in general. Similar HAER documents for T Plant and the 313 Building will provide an opportunity for depiction of facilities of this type. In addition to the photos and drawings contained within ExHPIFs and HPIFs, the text of the Treatment Report, particularly Chapter 2, will be illustrated.

Comment: The public was not involved in task group decisions besides those for 700 and 1100 Areas, which one local stakeholder described as "throwing out the scraps--fish food." Delete the first paragraph of the Public Involvement Opportunities" section after the first two sentences.

Response: The statements made in the paragraph referenced are statements of fact. Public meeting were held on those dates; the public was informed of the work of the Task Group including a presentation of the classification process and selection procedure. The public was also notified that an opportunity for review of the recommendations made by the Task Group would be offered. This document was provided for public comment in fulfillment of that statement. The final Treatment Plan will incorporate comments received within its text, and copies of the review letters, together with this comment resolution statement, will be attached as an appendix.

Comment: The "Public Involvement Opportunities" section should not cover the Treatment Plan. The type of review you seek from the public should be stated explicitly in a cover letter rather than deep within the report on which you seek comments.

Response: A cover letter explicitly requesting comments on property selection and future uses was prepared and accompanied the Treatment Plan when it was sent out for public review on June 10, 1997.

Comment: We believe the DOE-RL lacks "established" public involvement procedures, and recommend the public involvement techniques (page 29) be specified--and be determined in consultation with affected groups.

Response: DOE-RL, through the Office of External Affairs, has procedures for obtaining public comments on its activities and documents. The techniques noted on pages 27-28 of this document are in keeping with those procedures.

Comment: The schedule in Figure 6 should take into account the documentation already in place. Further, we recommend the documentation be contracted to local experts whose hourly costs are likely to be a fraction of those of DOE's prime contractors, and whose expertise and commitment would enhance the Sitewide Treatment Plan.

Response: As noted on page 23: "...the final report will utilize existing information...to the fullest extent possible." Work will be accomplished through subcontracts with local experts and through existing contract staff as appropriate. Budget containment is a given for this project. Coming in under budget is a key objective.

Comment: We recommend a header for every page showing the Table number and Table Title.

Response: Accept.

Comment: We strongly recommend that all buildings associated with B Reactor which are still standing be preserved indefinitely for their historic value, and that all documentation relating to them be preserved.

Response: Accept the Future Use codes provided. Negotiations are underway now to ensure that 116-B, 117-B, 119-B, 181-B, and 182-B will remain in place in addition to 105-B itself.

Comment: It concerns us that 202-S Redox Canyon would not be documented.

Response: While the history and significance of Redox would have been captured in the narrative section on "Chemical Separation/Byproducts", 202-S will be added to Table A.5 (formerly Table 1) as a property for individual documentation. Documentation will be accomplished through an ExHPIF.

Comment: It is unclear what the meaning of the "DOE-RL" column is in Table 3.

Response: This column was added during internal DOE-RL review. It was meant to capture which program within DOE manages the property. This column will be deleted from the table.

State of Washington, Office of Archaeology and Historic Preservation (submitted September 5, 1997)

Comment: On page 14 under discussion about integrity as selection criteria, questions about specific properties should recognize that changes to a building or structure could gain significant historical associations and therefore be worthy of recognition.

Response: Accept. Structural change does not necessarily imply a loss of integrity. Change often occurred as the result of the addition of a new function or the improvement of an existing process. Such modifications were interpreted as an indication of adaptation over the functional lifetime of the property. This was the case, for example, with 108-F which began as a chemical treatment facility for reactor coolant water and was later converted into a laboratory for the Hanford Site Biology Program devoted to radiobiological research. No property was dismissed from consideration because of structural changes.

Comment: At the top of page 19, and under the section entitled "Retention In Place", does this treatment option include mothballing historic buildings? I recommend expanded narrative about the potential for mothballing as an option for preserving historic properties at Hanford.

Response: Given declining budgets, those facilities for which a future use could be identified were viewed as more likely to survive demolition pressures than those for which no use could be attached. "Mothballing" was not addressed as an end point. However, one may argue that those properties now under the Surveillance and Maintenance (S&M) Program fit the definition. These buildings have been emptied, secured, and all services, save those required for a yearly inspection, have been discontinued. Provided that S&M funding could be maintained in support of preservation, a case could be made for the retention of select properties.

Comment: Under the heading of "Public Interpretation" beginning on page 19, I recommend the treatment plan address the potential for public visitation, how the public will be accommodated, and how the site will be interpreted to the public. In essence, I recommend a comprehensive and far reaching approach to public access to the Site be developed at some point in the overall planning process for Hanford.

Response: DOE-RL agrees with the concept that a comprehensive plan for public access be developed. However, this topic is well beyond the scope of the Treatment Plan; it is more pertinent to the efforts now underway to draft a Comprehensive Land Use Plan. A section addressing how the Hanford Site may be interpreted is appropriate and will be added to the Treatment Plan.

Letter from Advisory Council On Historic Preservation

Letter from State of Washington, Office of Archaeology and Historic Preservation

Letter from B Reactor Museum Association