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The Committee’s Technical Review of the FFRDC’s Complete Draft Report

This chapter starts with the committee’s approach to reviewing the Federally Funded Research and Development Center (FFRDC) report (Bates, 2022a,b). Notably, the FFRDC report is long and detailed—with its appendixes, it runs to 770 pages. Thus, the committee’s review does not constitute a detailed edit of the entire report, and the committee has sought to avoid comments that amount to “we would have done it this way instead.” Rather, the committee has highlighted issues that, in the committee’s view, are important to informing decision makers and deserve careful reconsideration from the FFRDC in its final report. One consequence of this approach is that this review may appear excessively negative—all criticism and no praise, all disagreement and no concurrence. That is not the committee’s reaction to the FFRDC report. The FFRDC team has put an enormous amount of excellent work in the current report, building on its previous report and predecessor analysis. The committee greatly admires the thoughtfulness and expertise that went into it. Therefore, except in a few instances where the Statement of Task requires a particular finding, or the committee feels it important to reinforce a choice made by the FFRDC, the findings and recommendations below highlight only the items that the committee believes should be considered for change in the final version.

The committee is appreciative and acknowledges that this second FFRDC draft report incorporated the advice from the first report review. In that first review (NASEM, 2022), the committee recommended

• Reframing the fundamental question to be addressed in the FFRDC analysis going forward as: How can decisions about treatment of supplemental low-activity waste (SLAW) facilitate the fastest removal of the high-level waste from the tanks and from the site, all things considered (e.g., budget limits, technology uncertainties, and regulatory acceptability)?
• Identifying the relevant factors that “most clearly differentiate between approaches,” and identifying and bounding the incremental difference that each such factor makes in the decision.
• Identifying and analyzing the major uncertainties in each of the factors within the subset of factors that most clearly differentiates among alternatives that the U.S. Department of Energy (DOE) would need to consider in reaching a decision promptly.
• Distinguishing among the relevant factors, criteria, and elements and describing uncertainties in each.

The first review also recommended outlining the risks associated with potential leaking tanks as well as potential tank structural failure in a clear manner to inform decision makers of these potential risks and costs. As described in Finding 2, below, rather than seeking to characterize, even qualitatively, the likelihood of tanks leaking or otherwise failing, DOE and its contractors have chosen to rely—both for their response to this recommendation and as their operational approach to the tanks—on an extensive monitoring and mitigation program, which was described to the committee in detail by DOE. This review will describe how the committee recommends this issue be addressed while staying within its Statement of Task (Westesen et al., 2022)

2.1 STATEMENT OF TASK #1: FRAMEWORK OF DECISIONS

The Statement of Task (see Appendix B) is the core of the committee’s work. It is derived from the following portion of section 3125 of the National Defense Authorization Act (NDAA 2021): “The analysis

required by subsection (a)(1) shall clearly lay out a framework of decisions to be made among the treatment technologies, waste forms, and disposal locations.” In responding to this mandate, the committee first defines the term “framework of decisions” and addresses whether the FFRDC’s report constitutes the required framework (this section). Next, the committee evaluates various aspects of the framework: the selection and analysis of decisional criteria (Section 2.1.2), the selection and analysis of the alternatives among which to choose (Section 2.1.3), and the presentation of the comparison of alternatives (Section 2.1.4). Last, the committee assesses the FFRDC’s recommendation as part of its analysis (Section 2.1.5).

2.1.1 Is It a Framework of Decisions?

NDAA 2021 requires the FFRDC to provide “a framework of decisions to be made among the treatment technologies, waste forms, and disposal locations by including an assessment [of numerous listed factors]” relevant to a decision, such as risks, costs, technological maturity, and others. The committee considers the term “framework” to refer to a structured way to present side-by-side comparisons of the treatment approaches and disposal options in a format that is useful for decision making. That is, it would inform and facilitate making a reasoned decision among a number of realistic alternatives by applying a manageable number of independent, relevant criteria that meaningfully discriminate among the alternatives. A useful framework includes:

• Relevant decision criteria,
• Realistic alternatives,
• Analysis of the alternatives according to the criteria, and
• Direct comparison of the alternatives using the results of the analysis.

Note, a framework of decisions is distinct from the decision itself. The central players in the actual decision are anticipated to be DOE, Congress, and regulators working interactively within their respective roles to reach a feasible and acceptable (or at least tolerable) result.

While the committee has several findings, recommendations, and observations about various aspects of the framework that will be discussed later, in general the FFRDC has (1) identified a tractable number of top-level decisional criteria that are relevant to the decision at hand, (2) identified a limited number of alternatives that are representative of the choices realistically available to the decision makers, (3) applied the criteria to the alternatives, and (4) directly compared them, which is consistent with the committee’s previous recommendations.

Finding 1: With respect to the FFRDC analytic framework, the committee finds:

2.1.2 Did the FFRDC Select Appropriate Criteria?

The criteria chosen to evaluate the alternatives should be (a) relevant, (b) limited in number, (c) distinct from each other (not repetitive), and (d) capable of differentiating among the selected alternatives (Recommendation B; NASEM, 2022).

The FFRDC identified numerous criteria for evaluating and differentiating the alternatives that it identified. These were organized into six “top-level” or “key” criteria, and lower-level criteria that were considered under the six. The top-level criteria are:

1. Long-term effectiveness: environmental health and safety after disposal
2. Implementation schedule and risk: environmental health and safety prior to completion, including risks posed by waste tank integrity
3. Likelihood of successful mission completion: affordability, and robustness of technologies
4. Life-cycle costs: capital, operations
5. Regulatory approval
6. Community and public acceptance

The committee strongly commends the FFRDC in the current report, as in their first report, for taking a hard look at the cost of SLAW treatment and disposal in relation to current funding and other demands on funding at Hanford. As the first National Academies’ committee noted (NASEM, 2020), awareness that funding is not unlimited is an essential element of the decisions that must be made. Choosing an unaffordable or unfundable alternative could be the practical equivalent of taking no action, and so life-cycle costs are appropriately one of the top-level criteria. The FFRDC takes the additional step in the present report of treating availability of funding as a technical barrier to completion of certain alternatives, especially vitrification. While lack of funding could be a practical barrier to timely tank waste management, this consideration, as described below in greater detail, is better considered as a funding issue, as opposed to a technical barrier to completion.

The committee observes one potentially important instance concerning cost where there is some duplication. One lower-level criterion under key criterion #3 (probability of successful mission completion) is “failure to complete due to funding shortfalls” and key criterion #4 is “life-cycle cost.” The committee finds that the quantitative costs developed to evaluate criterion #4 provide sufficient insights for decision makers to decide whether the costs are high enough to prevent timely mission completion.

2.1.2.1 Long-Term Effectiveness: Environmental Health and Safety After Disposal

The committee understands that the primary goal is to protect the aquifer and Columbia River. The FFRDC concluded that all of the technologies have the technical capacity for meeting this criterion, albeit with different costs, timescales, and likelihood of success. The committee agrees with this conclusion but notes that it remains unclear whether and which pretreatment measures may be needed for treated SLAW to be adequately effective.

2.1.2.2 Implementation Schedule and Risk: Environmental Health and Safety Prior to Completion, Including Risks Posed by Waste Tank Integrity

It is generally acknowledged that the integrity of the tanks at Hanford presents a significant challenge to the waste treatment program, both as to the ability to maintain the waste in a configuration that does not affect human health or the environment (e.g., by structural failure or by leaking, respectively), and as to the critical importance of the tanks as interim storage during the treatment. It is also acknowledged that “time is not our friend” in this respect (Recommendation A.2 in NASEM, 2022). The committee thinks that characterization of tank integrity issues constitutes useful information for decision makers regarding the potential costs and risks of delays in retrieving waste from the tanks. The issue here goes beyond the potential for additional tank leaks in the single-shell (especially) or double-shell tanks (DSTs). Rather, the committee’s concern is with the possibility of major structural failures that would preclude waste retrieval

as currently planned. Any such failure would surely add significant time and cost to the activities to treat tank wastes; however, a detailed description of the Hanford tank integrity program was presented during the April meeting as well as the preemptive efforts to avoid potential tank failure. An overview of the presentation is described in a subsequent paragraph (see below).⁵

In the previous review (NASEM, 2022) the committee recommended: “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 decision makers 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.” The FFRDC report has a mostly qualitative discussion of tank leak history, with little discussion about surveillance measures, mitigation measures, and potential impacts (Volume I, pp. 10-13; Bates, 2022a). The FFRDC discussion on page 13 of Volume I acknowledges that concerns regarding structural failures of tanks have led to “extensive surveillance programs” to “allow for mitigation measures to be taken if signs of imminent structural failure were noted” but these are not described further. Moreover, the results of any prior studies of the risks of structural failures are not discussed nor are any specific studies cited.

In the April 2022 public meeting the committee received a briefing from Washington River Protection Solutions (WRPS) representatives who described the tank and pipeline integrity strategy program at Hanford, which may be described as active monitoring (stewardship) with prompt treatment when issues or potential issues are discovered (Subramanian and Nelson, 2022). They also stated that they do not plan to undertake efforts to estimate quantitatively the likelihood of individual tank failure because (a) the information would not be useful and (b) it would be a costly tank-by-tank undertaking, diverting resources from cleanup while the tanks continue to degrade and the mission completion is delayed. Risk assessments are based on informed judgment derived from detailed knowledge of each tank. As mentioned above, the FFRDC draft briefly discussed surveillance programs at the Hanford Site to monitor for tank structural: “the Hanford Site has extensive surveillance programs for the waste tanks that should allow early detection of any structural issues and allow for mitigation measures to be taken if signs of imminent structural failure were noted” (Volume I, p. 13; Bates, 2022a). References to the tank integrity program should include Bernards et al. (2020), Campbell et al. (2021), DOE-ORP (n.d.), Garfield et al. (2021), WRPS (2022).

Finding 2: The FFRDC report states (Volume I, p. 12, Bates, 2022a) “Failures of selected DSTs may have little to no impact on the overall immobilization program if the tank failure does not prevent continued operations with the other DSTs.” The DOE tank integrity program, which applies to single-shell and double-shell tanks, is briefly mentioned without references or a description; however, the addition of these references to the next version of the report would assist the stakeholders by providing a report with the necessary information for decision making. The committee understands and appreciates the challenges faced by DOE concerning Hanford tank integrity and the adoption of an active oversight, monitoring, and mitigation approach including historical measures such as dewatering tanks and installing asphalt water intrusion barriers in favor of focusing resources on getting on with cleanup sooner. Although less than ideal, this approach is allowing DOE to focus resources on accomplishing cleanup in a more timely fashion, but does involve risks if a tank’s physical integrity were to fail.

Recommendation A: The committee recommends that the FFRDC include in its report a discussion of the tank integrity program with annotated references to describe the strategy that is adopted and the status of the program to provide perspective for decision makers.

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⁵ Text was added following release to the sponsor for clarity and to remind the stakeholders of the Hanford Site active program on tank integrity.

2.1.2.3 Likelihood of Successful Mission Completion: Affordability and Robustness of Technologies

As described above, cost is appropriately one of the six top-level criteria. In addition, the availability of sufficient funding to meet the cost is relevant to whether treatment will take place within a reasonable period of time (which, at Hanford, covers decades). This can be fairly described as the “affordability” of a particular alternative. However, “affordability” is not an absolute value—it depends entirely on the willingness of the federal government to provide sufficient funding. “Sufficient” is not an absolute amount, either—even putting aside the difficulties of predicting costs far in advance, one must ask “sufficient to do what?” Can some aspects of the plan be safely eliminated? Reconfigured or done more efficiently? Done over a longer period of time (which is contrary to “time is not our friend”)? However, it seems inarguable that the less an alternative costs, the more likely it will be “sufficiently” funded.

For all of these reasons, “affordability” is not an attribute of an alternative, but rather a conclusion; and it is a conclusion that depends entirely on the amounts appropriated to Hanford treatment, which is manifestly a political (in a nonpartisan sense) decision committed to DOE and Congress. A snapshot of the recent funding levels is available from a U.S. Government Accountability Office (GAO) report in 2022 (GAO, 2022b). While it was appropriate and important for the FFRDC to highlight this issue, using affordability to evaluate the relative likelihoods of the selected alternatives goes beyond a technical evaluation, because “affordability”—as opposed to cost—simply cannot be predicted on a reliable technical basis.

• Determining affordability essentially involves calculating the annual cost of an alternative and then comparing those costs to the limited funding available. That is, affordability in the first criterion is based on life-cycle costs in the second criterion which means that cost is accounted for in two criteria.
• Limit of $450 million per year is arbitrary in the strict sense of “based on comparability to the DFLAW budget” (Volume I, p. 44, line 13; Bates, 2022a) and in another place it is deemed a “plausible annual budget” (Volume I, p. 66, line 1; Bates, 2022a). If the appropriated funding limit was exceeded in any year, then the duration of the project for that alternative was extended, resulting in higher life-cycle costs and a longer mission duration (Volume II, p. 459, line 44; Bates, 2022b).
• The committee believes that deciding on a funding limit is an appropriate role for decision makers such as DOE, the Office of Management and Budget, and Congress, not the FFRDC. Thus, more analysis allowing for alternative assumed annual funding limits is needed to allow these decision makers to understand the impact of funding uncertainty on the relative completion risks of the SLAW alternatives.

It bears emphasizing that the FFRDC’s assumptions of future funding levels are neither unreasonable nor ill-informed, nor does the FFRDC claim more for their authority than is justified. The concern, rather, is that no one can predict a complex, changeable, highly political process such as governmental budgeting, especially over the long times relevant to the SLAW treatment and disposal process.

Finding 3: The FFRDC addressed the possibility of funding shortfalls by establishing a flat annual budget of $450 million and comparing this to the year-by-year funding requirements of SLAW remediation alternatives. Annual surpluses, if any, could be carried over for future use. Funding shortfalls are recognized to result in extensions of the cleanup mission duration and thus an additional cost penalty resulting from the assumed budget limit. Alternatives that had consistent shortfalls were deemed “unaffordable” and thus unlikely to be successfully implemented. The committee believes that this approach is inappropriate because the $450 million budget limit is arbitrary (strictly speaking) and based on predictions and value judgments that are better left to decision makers such as Congress.

Recommendation B: The “failure to complete due to funding shortfalls” subcriterion (Section 2.1.2) should be removed from key criterion #3. The FFRDC should remove the affordability concept from the likelihood of successful mission completion criterion and not assume any funding limit for this purpose. Instead, cost considerations should be addressed by estimating a life-cycle cost profile for constructing and operating each alternative that is designed to treat SLAW at the rate consistent with the nominal mission duration assumed in the report (operation from 2034 through 2075) while accounting for the variation in construction time. The FFRDC should then compare and contrast the life-cycle cost profiles accompanied by explicitly quantified sensitivity analyses about what funding levels would be required.

As the committee has previously found, the technologies analyzed by the FFRDC are the ones mostly likely to be capable of treating SLAW to achieve DOE’s treatment goals at this time. As has also been found, each technology has the possibility of internal variations and uncertainties in application to the Hanford tank waste that foreclose the possibility of absolute guarantees of performance. This, of course, is inevitable in a project of this complexity, and the lack of guarantees cannot stand in the way of making decisions. However, it does have implications for the nature of the decision, and particularly for using the timeline of the treatment to learn (NASEM, 2020) and to build flexibility into current treatment plans.

The committee concluded that the current trio of technologies is appropriate, and the committee believes that considering the flexibility of the current technologies and the ability to incorporate new technologies over the several decades of activity can reduce cost and mission duration (Recommendation 4-1 in NASEM, 2020).

Note that after the FFRDC draft analysis was released, the GAO published a report that, among other things, assesses the readiness of technologies related to Hanford cleanup, and it is less optimistic about their technological readiness than the FFRDC (GAO, 2022a). The FFRDC could consider the impact of GAO-22-104772 in its final report and respond to it for the benefit of decision makers.

2.1.2.4 Life-Cycle Costs: Capital and Operations

The report presently uses an assertion of future federal funding level constraints to make the case for the affordability of cost in the assessment of SLAW alternatives. There are, however, more fundamental reasons that cost matters in public policy choices, such as the need for society to allocate its large—but not unlimited resources—across a wide range of important environmental and social objectives. When Hanford tank waste cleanup is viewed within this larger context of competing societal needs, how much to spend on it for incremental improvements in the final outcome is more clearly a relevant decision criterion.

The committee believes that the report’s analysis of the impacts on cleanup timing of specific federal funding budget limits provides useful insights and perspective.

The report would do a service to decision makers and other stakeholders by providing a sound rationale for giving cost some weight in the comparisons among SLAW cleanup options while also strengthening the basis for its recommendation by not including implicit value judgments on affordability that may not be commonly shared.

The FFRDC report would be stronger with a more clearly articulated and robust sensitivity analysis, which will be more effective in informing decision makers about the challenges of making a decision by more transparently presenting the basis for the FFRDC’s judgments.

For example, the FFRDC could also develop and provide a few graphs that show the amount of tank waste remaining in each year from the present through final cleanup (using one or more risk-relevant units of the remaining waste). This would provide information relevant to the question of how well SLAW treatment options compare in terms of the rate at which risks from tank failures is being reduced. Additionally, the insights may not be as simple as showing that if SLAW treatment can start earlier, remaining in-tank waste risks will decline sooner; these timelines may differ depending on which tanks would be emptied first under the different types of SLAW treatment and may therefore differ across the treatment options even if all of the options are assumed to start in the same year. The committee expects that this analysis of

near-term in-tank waste reduction timing could supplement the FFRDC team’s rationale for its recommendation, although one cannot be sure without seeing such timeline graphs.

Finding 4: The committee notes that the report attempts to address how the confluence of costs, available budgets, and technological realities affect the cleanup mission timing. However, this attempt is confounded by the use of assumed annual budget limits (see Finding 3 and Recommendation B), cost tables that are not adequately explained, and limited comparison tables and graphics. The committee also notes that the insights about timing of cleanup appear to be limited to the final date of site closure, many decades out for all the alternatives. The committee expects that additional valuable insights could help differentiate the SLAW treatment alternatives by also displaying the rate of cleanup progress over time.

Recommendation C: The committee recommends that the FFRDC:

2.1.2.5 Regulatory Approval

Regulatory approval is one of the six top-level decision criteria identified by the FFRDC. The FFRDC report has a comprehensive discussion of the regulations relevant to management of SLAW including identification of regulatory issues on which DOE and the Department of Ecology disagree to provide background for decision makers. The description and documentation of the Department of Ecology’s concerns related to off-site treatment and disposal in Appendix J (Bates, 2022b) is thorough and very informative.

However, the FFRDC did not consider regulatory approval in its comparison of SLAW alternatives, stating “Likewise, securing regulatory approval is part of the negotiation process between government agencies, and it would be inappropriate for the FFRDC team to assign likelihood of specific outcomes.” This is a defensible approach, given the very different views of legal regulations for SLAW, the long history of legal and political conflict, and Washington State’s ultimate control of Resource Conservation and Recovery Act (RCRA) permitting.

However, regulatory hurdles are very real obstacles to certain SLAW management alternatives, especially grout that will need to be dealt with by decision makers using technical analyses and the assembled public comments as input. Thus, not taking regulatory approval into account leaves the reader and decision maker without information on considerations important to making decisions. These are make-or-break considerations, and so a decision maker will have to deal with them ultimately. FFRDC implicitly deals with them by recommending a redundant system of off-site disposition.

The most important difference between DOE’s and the Department of Ecology’s positions is concerned with the form of treated SLAW (a solid monolithic waste form) that would be acceptable for disposal in the Integrated Disposal Facility (IDF) at Hanford. Ecology contends that the U.S. Environmental Protection Agency (EPA) Land Disposal Restrictions call for the SLAW to be vitrified, that any other waste form has to be “as good as glass,” and that grouted SLAW does not meet this criterion.⁶ A primary driver for this difference is an EPA regulatory requirement in the Drinking Water Standard (DWS) that calls for the concentration of various contaminants in water to be less than specified Maximum Contaminant Levels (MCLs)

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⁶ A statement referring to the DOE position on the “as good as glass” criterion was deleted as it could not be accurately attributed to an author or report.

(NASEM, 2020, pp. 17, 29). Performance assessments and performance evaluations estimate that the concentrations of certain species such as Tc-99 and I-129 will be very close to their limits if a grout waste form is disposed of in IDF (in the case of I-129, within a factor 2) (NASEM, 2020; supporting information available in a February 28, 2018, presentation from Pat Lee, WRPS, available in the National Academies Public Access Files),² which leads the Department of Ecology to appear to conclude at this time that grout is not good enough. On the other hand, the current MCLs in the DWS are based on outdated models of contaminant uptake and impact, and when modern models are used to calculate concentrations associated with a 4-mrem/year dose rate on which MCLs are based, the contaminant concentrations differ from the current MCLs (Downs et al., 2020).⁷ The previous National Academies’ SLAW committee recommended that DOE consult with its regulators to ascertain whether risk-informing the MCLs in terms of its underlying dosimetry and point of compliance would be useful. The committee is not aware of any dialog among DOE and its regulators concerning risk-informing MCLs. The committee reiterates Recommendation 5-1 in its fourth review report (NASEM, 2020) in the previous study concerning the need for DOE to consult with its regulators concerning risk-informing MCLs.

Another approach to reducing the amount of radionuclides potentially released to drinking water is to modify the design of IDF and/or the use of getters. Getters are a means of sequestering ionic species in waste forms or disposal sites. For example, silver compounds are commonly considered as getters for iodine as their reaction results in the formation of silver iodide, an insoluble compound that cannot be readily transported in the environment. Note, getters are not selective for anionic species of long-lived Tc-99 or I-129. See, for example, a report on getter technology from Pacific Northwest National Laboratory (Asmussen et al., 2018). The committee notes considerable discussion by the FFRDC of using getters in SLAW grout to lower the estimated concentration of I-129 to reliably meet the drinking water standard. The committee also notes the FFRDC’s discussion of uncertainties in the performance of getters. The uncertainties in the performance of getters coupled with the relatively high cost of alternatives other than grout suggest that more emphasis might be placed on other tank side pretreatment options to lower the concentrations of technetium, iodine, and perhaps other species.

The committee offers no position concerning whether a grout waste form is “good enough” or how the parties should go about resolving the issue. The committee finds that these are tasks reserved for the regulatory agencies, stakeholders, and decision makers. Findings and recommendations related to regulatory approval as a criterion are presented below.

Finding 5: The FFRDC made a defensible decision to refrain from attempting to estimate in qualitative or quantitative terms the likelihood of specific regulatory outcomes; however, the regulatory approval criterion section would be strengthened by including a more in-depth discussion on potential challenges that may need to be addressed in obtaining the necessary various regulatory approvals.

Recommendation D: The FFRDC should include a discussion of issues associated with obtaining regulatory approval for the various options. Specifically, it would be helpful to focus on the significant adverse consequences of grouted SLAW not being acceptable for disposal at IDF or other out-of-state disposal sites.

The committee also notes that some of the alternatives involve off-site transportation of SLAW and, in particular, pretreated liquid SLAW which will require regulatory approval. This is considered in Finding 6 and Recommendation E, below.

2.1.2.6 Community and Public Acceptance

Community and public acceptance, which the committee takes to mean acceptance by stakeholders other than regulators and decision makers, is one of the six top-level decision criteria identified by the

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⁷ This statement was modified following release to the sponsor to better reflect the analysis in the Downs et al. (2020) study.

FFRDC. The FFRDC did not consider community and public acceptance in its comparison of SLAW alternatives, stating that “the FFRDC team concluded that stakeholders should have the benefit of [the ongoing FFRDC] and other analyses (e.g., by the National Academies and the GAO) prior to formulating input as part of the decision-making process.” As with regulatory acceptance, the FFRDC treats community and public acceptance largely as an uncertainty, resulting in the same problem of addressing an essential but unquantifiable factor as above.

However, community and public input has not been absent from the FFRDC analysis and the committee’s reviews. In the first FFRDC analysis and National Academies’ review of SLAW management and now this follow-on effort, community and public input has been sought during the public meetings and with a formal call for comments on the previous and now the current draft FFRDC report. A 60-day window was opened for public comments to be submitted to the National Academies and shared with the FFRDC. These comments are provided in Appendix C. In addition, the April 2022 meeting in Richland, Washington, had sessions set aside for public speakers. Presentations are available on the webcast recordings and in the Public Access Files. Presentations were received from the Oregon Department of Energy, Hanford Challenge, Heartland of North America, and the Tri-City Development Council.

The need for community and public acceptance is not limited to cleanup of the Hanford Site. The Western Governors Association (WGA) released Policy Resolution 2022-09, “Radioactive Materials Management” (WGA, 2022). In this document WGA captures many concerns shared by the present FFRDC report and the National Academies’ review that involve the Hanford Site cleanup and transportation of waste. Of note and quoted from this resolution:

• “WGA believes that the safe and event-free transport must be paramount in all Federal policies regarding transportation of radioactive materials and [spent nuclear fuel]. This is true of all transportation modes, including truck and railway.”
• “WGA support existing federal radioactive waste transport safety requirements designed to protect public health and safety, including the Hazardous Materials Transportation Authorization Act.”
• “If DOE decides to transport radioactive waste … by rail, federal agencies should work with states to design and implement such a transportation system. The rail industry should fully cooperate in this process and commit to implementing best practices for such a transportation system. Congress should provide a firm legal basis for transportation system design and implementation.”
• “Early coordination and effective communication with state, tribal and local governments are essential to the ultimate success of any nuclear waste transportation safety program.”

Finding 6: Like the regulatory approval criterion, the FFRDC treated public acceptance as an uncertainty to be considered by the decision makers. The committee found that there was little discussion or analysis of the dimensions or potential ramifications of community and public acceptance in the FFRDC report. In particular, as the SLAW alternatives now consider off-site options, the importance of stakeholders along transportation routes and at disposal sites other than IDF have become relevant. In its work to date, the FFRDC has received input from individuals and organizations near Hanford, but not from stakeholders at other disposal locations under consideration or along transportation routes. The committee agrees with the findings in the report that the FFRDC should not attempt to estimate the likelihood, in qualitative or quantitative terms, of community and public acceptance outcomes.

Recommendation E: The FFRDC should expand its consideration of the consequences of potential impediments impacting the safe and expeditious SLAW management, such as grouted SLAW not being accepted for transportation, disposal at IDF, or other out-of-state disposal sites. The FFRDC should incorporate insights from public comments obtained to date in the final report, as well as the experiences of other sites that have transported radioactive waste to distant treatment or disposal locations.

2.1.2.7 Other Criteria for Consideration

Input from the Tribal Nations is a key component of community and public acceptance. During the study, the committee has heard testimony from the Yakama Nation, the Nez Perce Tribe, and the Confederated Tribes of the Umatilla. Two of the comments that best convey the concerns discussed during the National Academies’ study meetings are quoted here.

Laurene Contreras for the Yakama Nation writes in a message to the first Hanford SLAW study,

It is important for Federal, State, and private entities to appreciate the nature of our present rights. In the Treaty of 1855 we ceded over 12 million acres of land to the United States. That land now covers nine separate counties in central and eastern Washington. Our Treaty further reserved, “right of taking fish at all usual and accustomed places, in common with the citizens of the Territory, and of erecting temporary buildings for curing them; together with the privilege of hunting, gathering roots and berries, and pasturing their horses and cattle upon open and unclaimed land.”

Jack Bell for the Nez Perce Tribe shared this message:

The Nez Perce Tribe believes that the ultimate goals of the Hanford cleanup should be to restore the land to uncontaminated pre-Hanford conditions for unrestricted use. This includes air, soil, groundwater, and surface water. Tribal members, ecological resources, and cultural resources within Usual and Accustomed areas should not be exposed to any potential adverse risk above that which has always existed for the tribe prior to the establishment of the federal government projects and facilities at Hanford in 1942.

Finding 7: Native American Nations and Tribes also have a unique interest in what remains on the site and the location and size of the areas that will be accessible to them following completion of treatment. The tribal representatives made a compelling case that maximizing tribal access (reducing contaminated or off-limits footprint), especially to areas of particular cultural or resource significance, are vital interests.

Recommendation F: The FFRDC should acknowledge as a subcriterion under key criterion #6 (community and public acceptance), consideration of the location and amount of land to which tribal members are likely to have access among the four alternatives that were evaluated and include this in the discussion of community and public acceptance (see Section 2.1.2.6).

2.1.3 Did the FFRDC Select Appropriate Alternatives?

The FFRDC described alternatives that covered the three treatment technologies that have previously been determined to be sufficiently mature to be seriously considered for management of SLAW: vitrification, Fluidized Bed Steam Reforming (FBSR), and grouting. They initially identified 22 alternatives (3 vitrification, 4 FBSR, and 15 grout), which they initially down-selected to 15 (1 vitrification, 2 FBSR, and 12 grout), and ultimately to 4 “key alternatives” which would be most representative for comparison, understanding that the ultimate choice might be a variation or combination of the predefined alternatives (FFRDC slides 75-80).²

The final four key alternatives are

1. Vitrification 1: disposal on-site at Hanford
2. Steam reforming 1A: solid monolith product disposal on-site at Hanford
3. Grout 4B: off-site grouting and disposal
4. Grout 6: phased approach—off-site grouting and disposal and then on-site grouting and disposal.

2.1.3.1 Vitrification 1: Disposal On-Site at Hanford

The vitrification process is well described in the report. In the vitrification process, a previously characterized aqueous SLAW stream from the Hanford tanks is thoroughly mixed with glass forming chemicals such as metal oxides and metal carbonates. Sugar is also added to assist in denitration during waste treatment. The stoichiometry and precise composition of the additives will be optimized depending on the waste stream composition, and the addition of sugar may be eliminated. There are advantages and disadvantages to the addition of sugar; however, removing sugar from process is advantageous as it has been found to contribute to acetonitrile in the off-gas, a known hazardous organic chemical that needs additional capture and treatment. The additive-waste slurry is then fed into a melter and converted to a monolithic glass form for disposal. Current plans call for the vitrified waste to be disposed of in stainless steel canisters on-site at the IDF.

Vitrification has been used in the United States and other countries as a stable form for radioactive waste. While vitrification has been deployed and is understood relatively well, it does have some inherent advantages and disadvantages. Vitrification is a high-temperature process to achieve a stable waste form with maximum passive safety. The high temperature also destroys nitrates and organics, and with the removal of the water from the slurry, results in significantly reduced volume compared to grouted waste forms. One potential disadvantage of this process is that it operates at high temperatures (~1,150^oC) which must be maintained whether the melter is producing molten glass or just idling and which results in the volatilization of a number of elements to varying degrees, which requires a complex off-gas treatment system. Additionally, vitrification of radioactive liquid waste requires a large, complicated engineered facility such as the LAW facility presently under construction at Hanford. At Hanford, moreover, the process will confront a challenging and heterogeneous feedstock. The design and construction of such a facility requires significantly more time than what would be needed to build a treatment facility based on a less-complex, lower-temperature facility using a technology such as grouting or FBSR, which operates at 750^oC.

Finding 8: The long lead time of the Vitrification 1 option results in a much later waste treatment start date than the other options. This inevitably contributes to an increased life-cycle cost and a higher potential for tank failure. The committee found the discussion on this finding to be lacking sufficient details in the FFRDC report.

Recommendation G: In their final report, the FFRDC should provide more discussion of the consequences for cost, time to completion, and likelihood of completion, given the delayed start date of the vitrification treatment.

2.1.3.2 Steam Reforming 1A: Solid Monolith Product Disposal On-Site at Hanford

FBSR offers a somewhat lower-temperature process than vitrification (750^oC versus 1,150^oC for vitrification) to treat radioactive wastes that are high in organics, nitrate, and other contaminants. FBSR involves mixing the treated LAW feed with a clay source. A carbon source is combined with the clay mixture and the stream fed into the fluidized bed steam reformer unit. The result is a granular product of mixed mineral phases trapping the radionuclides. Creating the monolithic waste form requires further processing and is part of the FBSR key alternative evaluated in the FFRDC report.

The committee noted that experience with and technological readiness of FBSR is less than either vitrification or grout, making it more difficult to compare reliably with the other alternatives. It is not, however, an entirely untested or unused technology, and it has been the subject of numerous studies. The committee encourages the FFRDC to consider the detailed observations, including references, in Chapter 3 to clarify and correct the description of the FBSR process in their final report.

2.1.3.3 Grout 4B: Off-Site Grouting and Disposal

Grouting refers to treatment of aqueous waste resulting in the radionuclides being trapped in a cementitious matrix which may not be based on common Portland cement. Grouting at the Savannah River Site (SRS) has resulted in 3 million gallons of waste being converted to stable forms followed by disposal in large monoliths in near-surface vaults at the Saltstone Production Facility (DOE-EM, 2022). While this is an ambient-temperature alternative that was determined to be a lower-cost alternative in the report, the resulting grouted forms are about 80 percent larger in volume than vitrified or FBSR forms. Hence, they will require more space in disposal facilities. Grouting operates at ambient temperatures which means that less power is consumed, potentially resulting in a smaller carbon footprint. (A full life-cycle analysis of grouting and the other alternatives, including the aspects that contribute to the carbon footprint, will be publically available before the final report.) The low temperature greatly reduces the volatility of various elements, leading to the need for minimal off-gas treatment system but also does not destroy undesirable hazardous species such as nitrates and organics, which may lead to the need for additional pretreatment. Lower temperatures also might imply potential lower technology risks and higher worker safety.

The FFRDC’s descriptions of the three potential waste disposal sites are accurate and complete, although detailed information regarding the engineered lining and cover systems at the IDF would be helpful. The report paints an accurate picture of two out-of-state disposal sites having advantageous climatic and hydrogeological conditions that inherently minimize the risk of deleterious groundwater impacts. Likewise, the description of the Department of Ecology’s concerns in Volume II, Appendix J (Bates, 2022b) related to off-site treatment and storage fully covers the concerns that Ecology has raised. The committee is appreciative of the effort to prepare this appendix.

This grout alternative raises some logistical issues: the location of the grouting process itself, the location of the disposal of the grouted material, transportation of SLAW to any off-site locations, and the potential for the SLAW to be orphaned (i.e., the planned off-site disposal location becomes unavailable). Additionally, specific grout formulations tailored to the varying SLAW composition must be selected or developed. The grouting process could potentially take place on-site at a central or tank side location, at an off-site facility in the vicinity of Hanford, or at the disposal location. Disposal could take place on-site in the IDF or at an off-site location. Clive, Utah, or the Waste Control Specialists (WCS) site in Andrews, Texas, have been mentioned in this regard. An off-site location for either purpose will require transportation of pretreated waste (still in liquid form) or grouted waste to that location. In addition, it is possible that multiple locations would be used.

Finding 9: If grouting is pursued, flexibility in disposal options will be important, given the uncertainties in future availability of disposal sites; therefore, the FFRDC’s case for pursuing flexibility via multiple pathways is well founded.

2.1.3.3.1 Transportation for Off-Site Grouting and Disposal

With off-site treatment and disposal, the role of transportation in the SLAW management is one important consideration in the framework of decisions. Uncertainty is introduced by the heterogeneity of the waste in individual tanks (Porcaro and Subramanian, 2022), potentially unknown locations, and moving liquid waste and/or grouted material to these facilities. The locations at which the activities occur are interconnected by nuclear waste transportation with important considerations being the state of the waste while in transport (liquid or solid) and the transportation mode(s) and routes. For example, for off-site treatment, the FFRDC assumes liquid waste would be transported either by trucks and/or rail. The details of the transport activity could lead to very different risk profiles. This is true not only for the public along the route that is exposed to the transport activity but for the workers as well. There are also risks associated with incident and accident events as well as during the normal conditions of transport. Emergency response procedures and protocols and handling and operating assumptions are important. For background and a review, see TRB and NRC (2006).

The FFRDC alternatives 4B and 6 involve transporting some or all pretreated liquid SLAW in 5,000-gallon tanks off-site for treatment and/or disposal. Such transport is accepted practice for low-specific-activity (LSA) waste in common industrial packaging that is not subject to U.S. Nuclear Regulatory Commission licensing. Transport by truck is mentioned in the FFRDC report, but only one tank can be transported in a truck shipment. The main focus is on transport of multiple tanks by rail in trains composed of multiple railcars each containing multiple tanks. The FFRDC has conducted analyses to determine whether SLAW pretreated to remove 99 percent of the cesium and strontium at the Hanford site can qualify as LSA.

For present purposes, most of the risk issues are adequately addressed by ensuring compliance with existing regulations for transport of radioactive waste. There are three key limitations for transporting radioactive liquids as LSA. The limitations and how the FFRDC addressed them are as follows:

• Limitation 1: The specific activity of radionuclides in the waste (e.g., Ci/g) must be less than values given in 10 CFR Part 71 using a “sum-of-the-fraction” approach that is standard in many regulations. The FFRDC calculated the specific activity of SLAW liquid for the monthly average of the multiple tanks of SLAW and found that it was less than the regulatory limit for all months for two feed vectors (see Volume II, Figures H-2 and H-4; Bates, 2022b).
• Limitation 2: The total radioactivity in a single shipment which may involve multiple tanks must be less than 100 times values given in 10 CFR Part 71. The FFRDC calculated the total activity and used this to determine the number of tanks that could be in a single rail shipment. The result was that the number of tankers allowable in a single shipment varied from hundreds to just a few (see Volume II, Figure H-8; Bates, 2022b).
• Limitation 3: The radiation dose of the waste form must be less than or equal to 10 mSv/hour (1 rem/hour) at a distance of 3 meters (10 feet) from the unshielded material and the dose at the external surface of the shipping package must not exceed 2 mSv/hour (200 mrem/hour) on contact. The FFRDC calculated the maximum specific activity of the monthly averaged grout from two different feed vectors. On this basis, FFRDC stated that the dose rates from the solid wastes would be less than the limit. The specific activity of liquid SLAW is higher than for treated SLAW because the liquid is not diluted by materials needed to make the grout waste forms. The report then states that “The liquids will be transported in tanks that will provide an adequate shielding” (Volume II, p. H-10; Bates, 2022b) verified by measurements.

The FFRDC concluded that SLAW liquid waste could be shipped as LSA waste in 5,000-gallon tankers.

Finding 10: The methods and assumptions by which the FFRDC has calculated that pretreated liquid SLAW will qualify as LSA waste are not described in adequate detail to allow the validity of the FFRDC claim that SLAW is LSA. In particular, the required calculations and associated information (e.g., feed vector concentration to sum-of-the fractions specific activity, radionuclide concentrations in the tanks and variability thereof, how dose rates were calculated) are significant and are not in evidence in the report or by reference.

Finding 11: The FFRDC estimates the shipping rate of 5,000-gallon tanks to range from 23 to 45 tanks per month depending on the details of the assumed feed vector (FFRDC presentation slide 60). However, the FFRDC calculations for Limit 1 (specific activity) and Limit 2 (total activity) are based on the average of all shipments during each month. On the basis of the variability of Hanford tank waste compositions, the committee would expect significant variability of the liquid SLAW composition in each tanker—and the specific and total activity of the waste in the tanker. The implications of using monthly averages of pretreated liquid SLAW compositions when dose limits are on a tanker-by-tanker basis are not evident.

Recommendation H: The FFRDC report should address the implications of using monthly averages of pretreated liquid SLAW compositions when dose limits are on a tanker-by-tanker basis.

Finding 12: There appears to be an inconsistency between the dose rate limit at 3 meters having to be met by analyzing unshielded liquid waste and the statement that liquids will be transported in tanks that provide adequate shielding. Meeting the terms of the limit may require more pretreatment or smaller packages.

Recommendation I: The FFRDC needs to resolve this possible inconsistency. The FFRDC should

A concern with the options for off-site treatment and disposal is “orphaned waste.” What if the acceptance criteria cannot be met for off-site disposal and the waste cannot be disposed of in IDF. Members of the Hanford Challenge expressed concern and publicly stated that (see Appendix C)

the report makes assumptions about the reliability of grout, the willingness of off-site disposal facilities to accept the grouted waste, and the openness of the residents in those states to receive grouted waste from Hanford. Ensure these assumptions account for the possibility of off-site disposal failing before making a final decision. We do not want grouted waste to be “orphaned” at Hanford because of overstated assumptions about the willingness of off-site facilities to take Hanford’s waste.

This concern is echoed by Ecology in their response to the FFRDC (Volume II, Appendix J; Bates, 2022b):

However, the decision to perform these grouting activities in Washington State would increase the risk of creating an orphan waste stream that would remain at (or return to) Hanford in the event it is rejected by the disposal site or its regulatory authority.

Finding 13: The report contains no discussion of the possibility of future unavailability of the WCS or Clive, Utah, sites, even though such a possibility appears to be real and, if it were to happen, would have enormous negative potential consequences.

Recommendation J: The FFRDC report should elaborate the potential negative consequences of the unavailability of off-site disposal by (1) discussing the possibility that permission to dispose of grouted SLAW at WCS and/or Clive might never occur or someday be withdrawn; (2) discussing what is known about public acceptance regarding potential grouted SLAW disposal in Texas and Utah; and (3) providing more information surrounding the orphaned waste issue including specifics on how the issue might develop and what the consequences and coping measures might be.

2.1.3.4 Grout 6: Phased Approach: Off-Site Grouting and Disposal and Then On-Site Grouting and Disposal

The fourth recommended alternative is initiating SLAW treatment with off-site grouting and disposal and later shifting to on-site grouting and disposal. As described in Appendix D of Volume II (Bates, 2022b), this alternative “takes advantage of the opportunity for an early start as part of a hybrid or concurrent alternative treatment. There is potential for reducing risk of leaks.” With the off-site processing of SLAW, there will be time for infrastructure at the Hanford site to be put in place for on-site treatment, such as the cross-site transfer line and the grout facility. Having the off-site facility could also prevent future bottlenecks in case of maintenance issues on-site.

The report addresses the shift to on-site processing:

The eventual transition to on-site production and disposal is expected to lower the overall mission cost and therefore the overall mission duration and risk. Of course, the on-site production and disposal alternative could instead be initiated immediately, avoiding off-site production and disposal. However, this approach is not the fastest at reducing risk of tank leaks, in part because it is reliant on the timing for approvals and the federal budget cycle, followed by grout plant construction time. (Volume II, p. C-52; Bates, 2022b)

The committee notes that the assumption that approvals for the phased approach will be quicker than designing, funding, and building an on-site grout plant may not be correct and this represents a significant uncertainty in the decision-making process.

The committee noted that one challenge with beginning on-site disposal is the lack of a performance assessment for grouted waste at IDF and the associated waste acceptance requirements necessary for on-site storage. However, the previous SLAW management analysis did develop a performance evaluation that has many of the elements of a performance assessment (NASEM, 2020, Appendix F).

2.1.3.5 Other Alternatives

The committee would like to acknowledge that the FFRDC followed Recommendation 4-1 in the first National Academies’ review of SLAW (NASEM, 2022). This recommendation asks that the report incorporate the concept of parallel approaches. Parallel approaches involve the consideration of multiple, parallel, and smaller-scale technologies, which would have the potential to reduce the startup time to removing tank waste by

• applying a “resilience through redundancy” operational concept,
• using the timeline for the treatment to optimize processes and incorporate new technologies or materials chemistry, and
• potentially lowering overall cost and program risk by creating the ability to pivot to more successful processes or formulations.

Time is not our friend especially when it comes to tank integrity, IDF integrity, costs, and the willingness to continue to budget Hanford. Accordingly, it is appropriate for the FFRDC to emphasize prompt reduction of risk and speedy completion. However, even under the most optimistic assessments, completion will require many years, and so it is important to develop alternatives that allow for change and flexibility in response to new knowledge, technology, or conditions. It should be clear that multiple pathways include flexibility to account for changes in technology, understanding of waste stream, or other unforeseen developments.

Finding 14: The committee found that options Grout 4B and Grout 6, especially 6, are intended to emphasize flexibility (multiple pathways). Because of the numerous uncertainties that all alternatives involve, including the likelihood that time will bring new or refined treatment and disposal options, this is a sensible approach, and it should be as flexible as possible in considering variations in on-site and off-site alternatives.

Recommendation K: The differences between on-site and off-site grouting treatment should be separately analyzed in the same level of detail as on- and off-site disposal. The grout alternatives should identify potential variations on the on-site and off-site alternatives, such as tank side treatment or pretreatment, to provide DOE with the ability to make a financial “business case” with a range of budgetary possibilities for on- and off-site alternatives, including additional upfront DOE funding. This is also captured by a public

comment from Rob Hastings (see Appendix C) regarding possible technologies to increase the speed with which tank waste is retrieved.

2.1.4 Presentation and Comparison of Alternatives

Throughout this process, the National Academies’ committees have focused on the clarity and usability of the presentation of the relevant data and analysis. This point is clear in section 3125 of the 2021 NDAA (“shall be designed, to the greatest extent possible, to provide decision makers 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 decision making and most clearly differentiate between approaches”) and subsequently reinforced in congressional briefings.

Finding 15: The FFRDC has made great progress in condensing the number of key criteria and the number of alternatives considered, as well as in presenting key information in side-by-side comparisons. There are, however, limits on how much a complex issue like this can be simplified, and some comparisons are oversimplified.

Recommendation L: Comparisons should be quantified, and as such, charts and graphs that lack a quantified basis should be eliminated (see Finding 4). This recommendation is particularly directed at the presentations in Section 4.0, Comparative Analyses (Bates, 2022a).

2.1.5 The FFRDC’s Formal Recommendation

The first National Academies’ review committee cautioned against the FFRDC making explicit recommendations of particular priorities or results, reasoning that these would intrude on the responsibilities and value judgments of DOE and ultimately Congress. However, the 2021 NDAA (sec. 3125(c)(1)) directs that FFRDC include “an assessment of … [t]he most effective potential technology for supplemental treatment of low-activity waste that will produce an effective waste form” (emphasis added), which can reasonably be interpreted to expect identification of a single best approach. This is what the FFRDC has done in making the following recommendation: “DOE should expeditiously secure and implement multiple pathways for off-site grout solidification/immobilization and disposal of LAW in parallel with the DFLAW vitrification process.”

A stated recommendation has the advantages of transparency about the FFRDC’s intentions and opinions, and of organizing the report in a more readily comprehensible way. The FFRDC’s discussion of its recommendation mentions several of the six top-level criteria, in particular environmental protection, reducing cost to levels that are more likely to be funded, and likelihood of being implemented—the last being based on the FFRDC’s view that grout might never be approved by the Department of Ecology for on-site disposal. The recommendation also introduces a number of second-tier criteria that are worthy of consideration:

• Rapid risk reduction is a particular concern, on its own terms and because of the problem of the structural integrity of the tanks. The FFRDC regards off-site grouting and disposal the fastest way to deal with SLAW, facilitating faster management of HLW and LAW.
• Grouting also offers time to develop and deploy improved technologies (i.e., learning from experience).
• The FFRDC regards grouting as the most flexible treatment alternative, and thus the most resilient to unforeseen technical or other difficulties. In addition, by reaching agreements with multiple off-site locations, DOE can limit the impact of problems with one location.

At the same time, the recommendation necessarily embodies certain values or weightings that are unstated, and the expert elicitation or other process that resulted in the recommendation is not described.

The FFRDC recommendation to dispose of the grout off-site has the virtue of realism, but it also allows avoidance of addressing key issues (e.g., permanent disposal of grouted forms in IDF), the challenge of meeting the “as good as glass” concept.

The as-good-as-glass concept has been a point of contention between DOE and the Department of Ecology for a very long time. While the FFRDC recommendation of off-site grouting and disposal attempts to avoid this obstacle, off-site grouting and disposal are themselves not without uncertainties, and so, DOE and the Department of Ecology will need to continue efforts to come to terms on it (NASEM, 2019).

As noted above, the FFRDC’s decision to handle the regulatory and public acceptance criteria as uncertainties to be factored in by the decision makers means that, for all practical purposes, they do not figure into the recommended FFRDC decision. However, these two criteria represent fully one-third (two of six) of the primary criteria for making a recommendation. As important, the statement of the recommendation per se does not explicitly acknowledge that it is essentially a recommendation based on just technical considerations to inform the decision makers who will then need to factor in the two criteria that were not considered. The need for decision makers and the public to consider criteria #5 and #6, respectively, is clearly acknowledged in the FFRDC report, but this occurs separately from the recommendation, which could make it subject to being misrepresented out of context.

Finding 16: While stating a recommendation may assist decision makers in their deliberations regarding analyzed approaches, the process by which these recommendations were reached and who participated are not described. The off-site recommendation also avoids confronting the lack of a performance assessment for on-site grout disposal and the possibility that it might show that grout might be made acceptable by using additional pretreatment processing and/or getters (see Section 2.1.3.4).

Recommendation M: If the FFRDC is to offer a recommendation, it needs to be fully transparent concerning the methods used to reach the recommendation and the analysis that supports the recommendation. In particular:

2.2 STATEMENT OF TASK #2: DID THE FFRDC CONSIDER ALL OF THE LEGISLATIVE ELEMENTS?

The congressionally required considerations are set out with specificity in the 2021 NDAA, incorporating by reference those in the 2017 NDAA, as well. The listed factors are comprehensive and include those relating to medium- and long-term environmental health and safety, cost, available technologies, and regulatory and public acceptance. As this committee reported in its first review, the FFRDC has addressed all of these considerations (see Finding 4). The committee further recommended that: “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” (Recommendation D).

The second FFRDC draft, building on the first, also addresses all of the congressional considerations. In addition, the second draft expressly addresses the uncertainties, as in Recommendation D, in Volume II, Appendix E, of its report. The second draft, indeed, makes further progress in focusing on six “key criteria” that are most relevant and differentiating (see Finding 2, above).

The 2021 NDAA also requires the FFRDC to consider:

Read literally, this is an infeasible charge, as there are many, many potential modifications of the highly complex technologies being analyzed. Moreover, if this is taken to include process changes, the potential scope is huge. The FFRDC’s approach was to identify a finite number (23) of reasonable alternatives and down-select to 4 representative ones in order to make their framework and analysis of practical use to decision makers. This is a sensible approach to the legislative requirement. While the committee has numerous comments on various aspects of the FFRDC analysis, the FFRDC approach meets the intent of the legislation by casting a wide net for alternatives among the primary technologies and disposal locations and reducing them to a manageable number for detailed analysis and comparison.

As the committee has previously reported (see Finding 1), the FFRDC did consider all of the criteria enumerated in the 2021 NDAA, including those incorporated by reference from the 2017 NDAA.

2.3 STATEMENT OF TASK #3: DID THE FFRDC PROVIDE “ADDITIONAL ANALYSIS” OF GROUT?

The committee’s statement of task requires assessment of whether “the FFRDC’s report provide[s] additional analysis for the grout treatment approach.” This charge reflects the motivation of both the present and previous FFRDC studies, to understand whether grout treatment, which has been used for a large amount of LAW at SRS, would be suitable for SLAW treatment at Hanford.

The FFRDC in fact gives grout “additional attention,” beyond that of the other two candidate treatment technologies, vitrification and FBSR, in a number of dimensions. First, the FFRDC analyzed more initial alternatives involving grout (15) than vitrification (3) and FBSR (4) before narrowing the grout alternatives to 2 for detailed analysis. For vitrification, the de facto baseline, there is little reason to explore numerous alternatives, as the pathway to on-site disposal of glass is relatively well understood and accepted by Washington State and can build on the experience in building the WTP LAW facility. The FFRDC has consistently questioned the maturity of the FBSR technology as it applies to Hanford’s heterogeneous and incompletely characterized waste stream, and but it did carry FBSR as a primary alternative in parallel with the other three.

Second, following a previous committee recommendation, the FFRDC conducted an extensive analysis of the SRS experience with grout. This type of analysis was not seen as necessary for vitrification or meaningful for FBSR (at INL), and so here, too, grout received additional analysis.

Third, the FFRDC uses its recommendation to highlight the advantages of grout—specifically, off-site disposal of grout—as the path forward for SLAW. In general, FFRDC’s report and recommendation clearly see grout as having the highest level of technology readiness and greatest likelihood of technical mission success.

As noted in the first SLAW committee review, the availability of raw materials for grouting, such as blast furnace slag or fly ash, cannot be assured over a decades-long period of treatment, as working incinerators and/or thermal treatment facilities are being reduced or phased out. Alternatives, such as kaolin clay or metakaolin or engineered cellular magmatics made from recycled glass, may have to be considered.

Finding 17: The FFRDC provided additional analysis of grout for consideration, including a number of alternatives described in detail and an examination of SRS’s experience with grouting.