Appendix C
List of Relevant Factors for Consideration in the FFRDC’s Analysis
Based on the committee’s reading of Sec. 3125 of the FY2021 National Defense Authorization Act (NDAA) and Sec. 3134 of the FY2017 NDAA, the following are relevant factors, criteria, and elements for consideration in the FFRDC Analysis (the letters and numbers refer to relevant parts of Sec. 3125 and Sec. 3134; the text below is thus the committee’s compilation of the points from the two pieces of legislation):
(c)(1) The most effective potential technology for supplemental treatment of low-activity waste that will produce an effective waste form, including an assessment of the following:
(A) The maturity and complexity of the technology;
(B) The extent of previous use of the technology;
(C) The life cycle costs and duration of use of the technology;
(D) The effectiveness of the technology with respect to immobilization;
(E) The performance of the technology expected under permanent disposal;
(F) The topical areas of additional study required for the grout option identified in the analysis required by Sec. 3134:
(A) The risks of the [three] approaches … relating to treatment and final disposition.
(B) The benefits and costs of such approaches.
(C) Anticipated schedules for such approaches, including the time needed to complete necessary construction and to begin treatment operations
(2) The differences among approaches for the supplemental treatment of low-activity waste considered as of the date of the [FFRDC] analysis.
(3) The compliance of such approaches with the technical standards described in section 3134(b)(2)(D).
- CERCLA
- RCRA [administered by Washington State]
- Clean Water Act
- Clean Air Act
(4) The differences among potential disposal sites for the waste form produced through such treatment, including mitigation of radionuclides, including technetium-99, selenium-79, and iodine-129, on a system level.
(5) Potential modifications to the design of facilities to enhance performance with respect to disposal of the waste form to account for the following:
(A) Regulatory compliance
(B) Public acceptance
(C) Cost
(D) Safety
(E) The expected radiation dose to maximally exposed individuals over time
(F) Differences among disposal environments
(6) Approximately how much and what type of pretreatment is needed to meet regulatory requirements regarding long-lived radionuclides and hazardous chemicals to reduce disposal costs for [technetium-99, selenium-79, and iodine-129].
(7) Whether the radionuclides can be left in the waste form or economically removed and bounded at a system level by the performance assessment of a potential disposal site and, if the radionuclides cannot be left in the waste form, how to account for the secondary waste stream.
(8) Other relevant factors relating to the technology described in paragraph (1), including the following:
(A) The costs and risks in delays with respect to tank performance over time.
(B) Consideration of experience with treatment methods at other sites and commercial facilities.
(C) Outcomes of the test bed initiative of the Office of Environmental Management at the Hanford Nuclear Reservation.
