Summary
Section 3125 of the National Defense Authorization Act for Fiscal Year 2021 (Public Law 116-283) (Sec. 3125) calls for a Federally Funded Research and Development Center (FFRDC) to “conduct a follow-on analysis to the analysis required by section 3134 of the National Defense Authorization Act for Fiscal Year 2017 (Public Law 114–328; 130 Stat. 2769) (Sec. 3134) with respect to approaches for treating the portion of low-activity waste at the Hanford Nuclear Reservation, Richland, Washington, intended for supplemental treatment.”1 The analysis “shall be designed, to the greatest extent possible, to provide decisionmakers with the ability to make a direct comparison between approaches for the supplemental treatment of low-activity waste at the Hanford Nuclear Reservation based on criteria that are relevant to decisionmaking and most clearly differentiate between approaches.” For the criteria that Congress wants considered, see Appendix A, which provides the complete texts of Sec. 3125 and Sec. 3134.
As with Sec. 3134, Sec. 3125 calls for the National Academies of Sciences, Engineering, and Medicine (the National Academies) “to conduct a review of the analysis” performed by the FFRDC that is independent of and concurrent with the FFRDC’s analysis and intended to improve the quality of the analysis. The U.S. Department of Energy (DOE) has contracted with Savannah River National Laboratory (SRNL), an FFRDC, to provide the called-for analysis. SRNL assembled a team of experts from SRNL, other national laboratories, and from outside the national laboratories’ network to perform the analysis. The Statement of Task for the National Academies review is provided in Appendix B.
This review report, the first of three to be issued by the National Academies to address the Congressional mandate, focuses on the Statement of Task’s study charge for the committee to “evaluate the technical quality and completeness” of the FFRDC’s draft framework with respect to the questions:
- “Does the FFRDC’s report clearly lay out a framework of decisions to be made among the treatment technologies, waste forms, and disposal locations?
- Does the FFRDC’s report consider in its analysis all the elements, criteria, and factors specified in Section 3125 of the National Defense Authorization Act of 2021?”
The committee’s comments in this review report are based on the FFRDC’s draft framework report of 74 pages, titled “Hanford NDAA 3125 FFRDC Working Draft Compilation,” dated September 30, 2021, and a set of 71 slides produced by the FFRDC and presented at the public meeting on October 20-21, 2021, as well as others’ public presentations (see Appendix E) at that meeting.2
The committee’s overarching task is to provide a concurrent, independent peer review of the ongoing FFRDC analysis. The committee is neither charged to evaluate the supplemental treatment approaches nor recommend any particular approach. Equally important, the committee notes what is not in the scope of the FFRDC’s analysis and the committee’s review, namely, tank waste management, high--
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1 According to DOE’s Radioactive Waste Manual, low-activity waste means the waste that remains after as much of the radionuclides as technically and economically practicable have been removed from the tank waste, and that when immobilized in waste forms, may be disposed as low-level waste in a near-surface facility, as long as the waste meets criteria in the Waste Incidental to Reprocessing determination. Supplemental treatment refers to processing of the low-activity waste that is excess to that portion to be treated by vitrification in the Waste Treatment and Immobilization Plant.
2 To access all these documents and presentations from the public meetings, please go to nationalacademies.org and enter the search terms “Review of the Continued Analysis of Supplemental Treatment of Low-Activity Waste at the Hanford Nuclear Reservation.” This search will show the hyperlinks to the public meetings and provide access to the recordings of the events as well as the FFRDC draft documents and other presentations.
level waste (HLW) processing and treatment, and the Waste Treatment and Immobilization Plant’s (WTP’s) design, construction, and operations. The de facto baseline is vitrification of the LAW in the supplemental LAW (SLAW) treatment facility followed by disposal of the resulting wastes in the Integrated Disposal Facility (IDF), which is currently under construction at Hanford. This baseline is the current expectation of many stakeholders. The FFRDC’s task is to provide data and analysis to enable DOE, with congressional oversight, to decide whether to use vitrification, grouting, fluidized bed steam reforming (FBSR), or some combination of these approaches to treat the SLAW by converting it into a waste form suitable for disposal.
Importantly, the committee notes that the evaluations of treatment options for the SLAW include more than just the processing of the liquid LAW retrieved from the tanks by dissolving the semi-solid and solid wastes. The objective of the SLAW treatment is to ensure that the solidified wastes can be permanently disposed of in a near-surface land disposal site. Because these sites have “waste acceptance criteria,” additional pre-treatment processing is sometimes required so that the final waste forms can be accepted for disposal. Additionally, the primary treatment and pre-treatment processes produce “secondary wastes” that also need to be disposed of in a near-surface disposal site. It is this entire process from pre-treatment through treatment to disposal that the FFRDC will evaluate and make side-by-side comparisons in its forthcoming complete draft analytic report.
In addition to the three primary treatment options, the FFRDC also will assess on-site and off-site near-surface land disposal options. The existing IDF located at Hanford is considered as the “baseline” LAW disposal facility, again because it is the current expectation of many stakeholders and is under construction. In this baseline option, the liquid LAW (including SLAW) would be solidified using vitrification, and the secondary waste would be grouted. While both types of waste are slated to be disposed of at the IDF, the Washington State Department of Ecology has yet to approve waste acceptance criteria that would allow for the disposal of grouted secondary waste or even the primary vitrified LAW in the IDF.
As to off-site disposal facilities, in the Sec. 3134 study, the FFRDC provided a preliminary analysis of the facility operated by Waste Control Specialists (WCS). WCS is located near Andrews, Texas, an arid and isolated region, and it has become an active commercial low-level waste disposal facility in recent years, as well as being designated as a Federal Waste Disposal Facility. In the draft framework, the FFRDC only mentions WCS “as a placeholder off-site location”3 and does not describe the WCS’s specific waste acceptance criteria. During the public meeting, the FFRDC team mentioned the lack of a pathway to the aquifer near the off-site disposal facility as a benefit. The forthcoming FFRDC draft report would add value to decision-making choices by identifying specific additional off-site locations and evaluating those sites’ waste acceptance criteria.
Based on the committee’s technical review (see Chapter 2 and Appendix D for details) of the FFRDC’s draft report and the presentation materials from the October 20-21, 2021, public meeting, the committee has reached consensus on the following findings and recommendations.
Findings and Recommendations
Finding 1: Given the limited available space in the tanks that can safely store waste (e.g., non-leaking double-shell tanks), there may not be enough capacity to receive wastes from other tanks that presently contain the waste that will become immobilized HLW, LAW, and SLAW if more than a few tanks fail. While Sec. 3125 calls for analysis on “the costs and risks in delays with respect to tank performance over time,” the FFRDC draft framework does not include provisions to address the probability of tank failure with respect to time. The analysis will have to deal explicitly and urgently with the fundamental issues of budgetary constraints and the risks of breach of tank containment. Moreover, tank cleanup costs appear to exceed, under nearly any scenario, current funding levels.
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3 This phrase is in a graphic in the draft framework; the committee takes it to mean that it is a placeholder for any off-site disposal location.
Recommendation A: To address the risks of failure of the tanks within the context of budgetary constraints, the committee recommends:
(1) Reframing the fundamental question to be addressed in the FFRDC analysis going forward as: How can decisions about treatment of SLAW facilitate the fastest removal of the waste from the tanks and into a disposal facility, all things considered (e.g., budget limits, technology uncertainties, and regulatory acceptability)? This reframing will focus consideration on the most pressing issue of the risks of tank containment breach.
(2) Having the forthcoming FFRDC report address the risks associated with these potential leaking tanks as quantitatively as possible as well as potential structural failure of the tanks in a clear manner such that the decisionmakers will understand the magnitude of the problem and the potential risk and increased costs of the cleanup if waste retrieval is delayed until additional tank failures occur.
Finding 2: In the committee’s view, the FFRDC’s task is to simplify and narrow the analysis to the factors whose incremental differences will highlight the key considerations likely to dominate the choices that DOE must make.
Recommendation B: The FFRDC report should (1) identify the relevant factors that “most clearly differentiate between approaches,” and (2) identify and bound the incremental difference that each such factor makes in the decision. The committee emphasizes that “narrowing” is not prioritizing factors, but rather identifying and highlighting the factors that account for the most salient, decision-relevant differences among the alternatives. That is, there needs to be a critical assessment of factors (cost, scope, and schedule, in particular) to understand which differentiate among approaches, and by how much.
Finding 3: While the FFRDC draft analysis is still at an early phase, identifying major uncertainties (possible range of outcomes and their likelihood) for each factor will be useful for decisionmakers in their deliberations.
Recommendation C: The FFRDC draft report should identify and analyze the major uncertainties in each of the selection criteria assessment results, the implications of the uncertainties, and the cost and benefit of investing in uncertainty reduction within the subset of selection criteria that most clearly differentiates among alternatives that DOE would need to consider in reaching a decision promptly.
Finding 4: The FFRDC has identified all of the relevant factors, criteria, and elements set out in the enabling legislation, and the FFRDC compilation reflects the early stages of its analysis and appears to be making significant progress as evidenced by the systematic definition and characterization of alternatives that reflect what was learned in the first phase study.
Recommendation D: Having identified the relevant factors, criteria, and elements, the remaining analytical task of the FFRDC is to distinguish among them and describe uncertainties in each, as discussed in Section 2.1 of this review report.
