3
The Committee’s Observations Concerning the FFRDC’s Draft Report
The National Academies’ committee’s overall task is equivalent to a peer review of the Federally Funded Research and Development Center (FFRDC) report. In any peer review, especially of a document as lengthy and detailed as the FFRDC draft, there are many comments that could be offered. Moreover, in a traditional peer review, it is up to the editor and the author of the document under review to decide which comments to take and which to discard. Instead of treating all of the committee’s comments the same, the committee has, as described earlier, first avoided commenting on the merits of different writing and organizational approaches; the committee’s task is to comment only on the “technical quality and completeness” of the FFRDC’s report. Furthermore, as the committee has done previously, the committee has divided its comments into the formal findings and recommendations in Chapter 2, which represent significant concerns that in its view require serious attention; and the observations in the present chapter that are offered for the FFRDC’s consideration. It is not expected that the FFRDC will respond to each individual observation in detail, but addressing many of them could improve the accuracy of the report.
3.1 GENERAL COMMENTS
| 3.1b | The committee noted that some of the tables and figures contain print so small as to be unreadable, especially in Appendix F. This needs to be fixed in the final report. It would be helpful if there were not two Appendixes A-E in the report. Maybe make one volume numerical or call them annexes or attachments |
| 3.1e | Considering the “as good as glass” basis for the analysis of Washington State Department of Ecology in discussing (and discarding) all other waste form possibilities, it would be helpful if the report provided some detail on the glass formulations that are under consideration in the Vitrification 1 scenario (or suitable models selected from among nationally or internationally assessed standard glass formulations) that could be used in a technical baseline comparison in this regard. |
3.2 REVIEW OF THE CHOICE OF THE SIX DIFFERENTIATING CRITERIA
The following observations focus on the criteria formulated by the FFRDC that best apply to the supplemental treatment of LAW (Volume I, p. 39, Appendix A; Bates, 2022a). Presented again, these are
- long-term effectiveness (environmental and safety risk after disposal);
- implementation schedule and risk (environmental and safety risks prior to mission completion, including risks driven by waste tank storage duration);
- likelihood of successful mission completion (including affordability and robustness to technical risks);
- life-cycle costs (discounted life-cycle costs);
- securing and maintaining necessary permits and authorities (regulatory approval); and
- community and public acceptance.
By topic the committee’s observations (categorized as comments, clarifications, and corrections) are presented with Findings and Recommendations supported by the observations.
3.2.1 Long-Term Effectiveness (Early Reduction of Risk, “Time Is Not Our Friend”)?
One of the touchpoints of the study committee is the theme, “time is not our friend.” The storage tanks and process facilities for the waste are aging at the Hanford Site and this was highlighted in a U.S. Government Accountability Office (GAO) report “Hanford Cleanup. DOE Has Opportunities to Better Ensure Effective Startup and Sustained Low Activity Waste” (GAO, 2022a) that was published after the April 2022 meeting in Richland, Washington. A clear concern is the challenge of tank integrity, a concern shared by the U.S. Department of Energy’s (DOE’s) Office of River Protection. Short-term reduction of risk is therefore an important consideration, and its application might result in important decisions about removing curies quickly, a greater focus on tank integrity, removal of liquids expeditiously from double-shell tanks, identifying the riskiest tanks, and planning for future bottlenecks in the event of facility maintenance issues. During the April 2022 meeting, Karthik Subramanian (Washington River Protection Solutions) and Erik Nelson (DOE Hanford) gave a presentation on the tank integrity program and answered questions from the committee. The presentation is publicly available as a part of this study (see Appendix C). Listed here are additional observations from the committee on the use of “long-term effectiveness” as a differentiating criterion for the four treatment options.
| 3.2.1a | The FFDRC team has included environmental impacts from radionuclides and other chemical hazards within the decision framework as part of criterion #1 (long-term effectiveness) and criterion #2 (implementation schedule and risk). However, the committee believes that it is important to emphasize that the environmental risk should be clearly supported by evidence. |
| 3.2.1b | References to peer-reviewed studies and finalized technical reports are necessary to thoroughly support statements. An example of the need for additional citations includes the first sentence on Volume I of the report, page 21 “Based on prior analyses, the FFRDC team believes that disposal of grouted LAW at the IDF may well meet applicable standards for groundwater” (Bates, 2022a). |
3.2.2 Implementation Schedule and Risk
Comments and reviews from this section have been included as Findings and Recommendations in Chapter 2.
3.2.3 Likelihood of Successful Mission Completion
| 3.2.3c | Implementation schedule and risk. The report would also benefit from a more explicit discussion of how the schedule, risk analysis, and business case address the various concerns and weaknesses raised in previous DOE reviews of this cleanup activity. |
3.2.4 Life-Cycle Costs
| 3.2.4c | It appears the FFRDC is quoting Circular A-4 of the Office of Management and Budget, which provides federal guidance on the conduct of sound regulatory analysis, as the basis for using a 3 percent discount rate (see Volume II, Appendix F, Table F-15; Bates, 2022b). Note, however, that Circular A-4 calls for present values of a policy’s costs and benefits (once themselves stated in real dollars) to be calculated using both a 3 percent and 7 percent real discount rate (see Circular A-4, pp. 33-34), while not proscribing sensitivity analyses to yet other discount rates. To achieve consistency with the federal guidance, the FFRDC would do well to provide at least some sensitivity analysis regarding whether alternative discount rates would alter the merits of its recommendations. |
| 3.2.4d | The lack of uncertainty analysis in the FFRDC draft can be compared to the recently released Hanford Lifecycle Cost Reports (Hanford LCR), DOE/RL-2021-47v0 that was written in 2021 (DOE |
| Richland Operations Office, 2022b). The Hanford LCR follows guidance given by GAO in “Estimating and Assessment Guide: Best Practices for Developing and Managing Program Costs” (GAO, 2020). A risk analysis as suggested by the GAO might be considered in future studies. | |
| 3.2.4e | There is an assumption that the cost of throughput from tank side cesium removal (TSCR) is $15/gallon (see Footnote 3, Volume II, Appendix F, p. F-4: “‘Pretreatment via TSCR,’ was assumed for all alternatives throughout the DOE-ORP mission. A singular value of $15/gal was selected based on TOPSim modeling”). Given that a TSCR unit is operating, determine the CapEx and OpEx costs of this facility. |
3.2.5 Securing Regulatory Permissions
The consideration of regulation and public opinion is quite different—treated as an uncertainty rather than as values to be compared. Taken from Volume I, p. A-4 (Bates, 2022a),
“For top-tier criteria 5 [Securing and Maintain Necessary Permits/Authorities] and 6 [Community/Public Acceptance], the FFRDC team concluded that stakeholders should have the benefit of this and other analyses (e.g., by the National Academies of Sciences, Engineering, and Medicine [the National Academies] and GAO) prior to formulating input as part of the decision-making process. 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. These criteria are included in the taxonomy but not included in the roll-up with the other criteria. Instead, the criteria are addressed in discussions of the alternatives.”
| 3.2.5a | The FFRDC took the position that it is not a legal arbiter or a gatherer of public opinion. Those are roles for courts and federal, state, and local governments, respectively. That is a defensible approach, given the very different views of legal requirements for SLAW, the long history of legal and political conflict, and Washington State’s ultimate control of Resource Conservation and Recovery Act (RCRA) permitting. The FFRDC nevertheless undertook a very helpful analysis of the issues. A similar analysis of disagreements concerning potentially relevant treaties with the Tribal Nations should be considered. |
| 3.2.5b | The FFRDC could include a brief analysis on how the speed of the cleanup could be accelerated and environmental liability reduced if DOE modifies its DOE Order 435.1 on Radioactive Waste Management to enable processing of waste based on its actual characteristics as opposed to its source of origin. |
3.2.6 Public Acceptance
The FFRDC team did not include criteria #5 (maintaining necessary permits and authorization) and #6 (public acceptance) in the final taxonomy of criteria. This decision was made because additional analyses necessary for community stakeholders and regulatory negotiations are outside the FFRDC scope. They did identify the key regulations and statutes within the report that would need to be taken into account when considering vitrification or the alternatives, including the Tri-Party Agreement, RCRA, Washington State, the U.S. Environmental Protection Agency, the Atomic Energy Act, and the National Environmental Policy Act. However, the report does not include a similar description related to the communities that need to be considered for public acceptance. The committee understands that the boundary conditions needed for the decision framework may not be conducive to including these two criteria and acknowledges that (1) regulatory negotiations are outside the discussion of this report and (2) additional studies are necessary to understand public acceptance on this issue. However, the committee would like to reiterate the importance of
these two criteria on the overall success of the mission and recommends that this be clearly articulated within the report so that their importance is not overlooked by decision makers.
| 3.2.6c | The FFRDC report states in Volume I, page 20 (Bates, 2022a), that the reason for Department of Ecology’s opposition is “on account of Hanford’s geology, disposal of grout-treated LAW in the IDF would cause exceedances of the SDWA [Safe Drinking Water Act] maximum contaminant levels for some tank waste constituents, potentially threatening groundwater and the Columbia River” (Volume II, Appendix J). The committee’s review of Appendix J revealed a more complex and nuanced explanation of the Department of Ecology’s reasons for concern including regulatory authority over the decision, timing of the decision, orphaned waste concerns, balancing short- and long-term risks, and others. It may be naïve to assume that the Department of Ecology would automatically approve disposal of grouted waste in the IDF even if groundwater modeling were to indicate compliance with drinking water standards. It would be helpful to a decision maker to understand the process that would likely be needed if regulatory approval is ultimately to be achieved. |
| 3.2.6e | Public health is considered within the regulatory guidelines listed in report. DOE Order 435.1 and DOE Manual 435.1-1 also include procedures for the management of radioactive waste for both workers and public health. It is also considered in the U.S. National Regulatory Commission regulation 10 CFR Part 71, Packaging and Transportation of Radioactive Material, which sets package criteria for the transport of radioactive materials and wastes. In addition, public health is a guiding principle within the Tri Party agreement in which the general purpose is to “Ensure that the environmental impacts associated with past and present activities at the Hanford Site are thoroughly investigated and appropriate response action taken as necessary to protect the public health, welfare and the environment.” |
| 3.2.7f | The FFRDC should contact Oak Ridge personnel to help address the transportation issue. Oak Ridge National Laboratory shipped contaminated B and C pond waste to Clive. The B and C pond waste was RCRA-regulated low-activity waste. The committee does not know if the B and C pond waste was shipped in barrels of wet waste sludge or if it had been grouted before shipment to Clive. Those studies and issues should be very relevant to this discussion. |
3.3 REVIEW OF THE CHOICE OF ALTERNATIVES TO ANALYZE AND ADEQUACY OF THEIR DESCRIPTIONS
This section provides a technical review of the FFRDC choices for immobilization. The four represent the down-selected alternatives that are representative of the available technologies. The rationale for these is discussed in Volume I, p. 23 (Bates, 2022a). As a reminder these are:
- Vitrification 1: Single vitrification plant, on-site disposal
- Fluidized Bed Steam Reforming (FBSR) 1A: Fluidized bed steam reformer, on-site disposal
- Grout 4B: Off-site vendor for grouting, and off-site disposal
- Grout 6: Phased off-site and on-site grouting and disposal
By topic the committee’s observations (best described as comments, clarifications, and/or corrections) are presented as technical assistance from subject-matter experts. With this in mind, the primary focus of this FFRDC report was an additional analysis of grout alternatives. Earlier FFRDC reports have been published to describe the vitrification, steam reforming and grouting technologies for immobilizing supplemental low-activity waste (Skeen et al., 2020).
3.3.1 Vitrification 1: Single Vitrification Plant, On-Site Disposal
| 3.3.1a | In Volume II, Appendix C2.1 (Section 1.1.1.5; Bates, 2022b) the report states that with respect to greenhouse gas emissions, that there are no carbon footprint differences between the [vitrification] alternatives. However, the Hanford vitrification process uses sugar to assist with denitration, and the equation below demonstrates how the sugar forms CO2. |
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| In addition, any carbonate-based glass former addition will create CO2, and the decomposition of organics creates CO2. This item should be reworded. | |
| 3.3.1b | The Hanford bubblers bubble air and so the melter is oxidizing (not reducing like the Defense Waste Processing Facility (DWPF) at the Savannah River Site which bubbles argon gas) and so the chromium will be present in the glass as Cr6+ and in the off-gas as Na2Cr2O7 which are soluble forms of chromium versus the Cr3+ that is present in the DWPF reduced flowsheet glasses. The same is true of Ru-104 in the oxidized state (Ru7+ or Ru6+) which is more volatile in the melter and more soluble in the glass than Ru4+. The same is true for the more volatile oxide (Tc2O7) than the +4 state (TcO2). The discussion of the glass retaining RCRA metals and radionuclides may need to be revisited by the FFRDC to point out these differences; for example, they cannot rely on any data from DWPF glasses or off-gas. |
| 3.3.1c | The discussion of demolition, removal, and modification in Volume II, Appendix C (C3.1.1.4) states “it is expected that siting will not require demolition or removal of existing facilities.” The committee questions whether this means the melter itself. Refractory K-3 linings of only 6 inches thick are being used (DWPF used 12 inches and recently dropped down to 10 inches). The K-3 refractory is reducing, so running an oxidizing flowsheet in Hanford will degrade the lining faster than a reducing flowsheet. The committee knows of two publications about this with projected rates determined by experimentation (Jantzen et al., 2015a,b). This section should be reworded to include the contingency plans, if any, when the melter needs to be relined or more likely replaced with a melter that has new K-3 linings. A comprehensive review of corrosion of glass contact refractories is also available (Bingham et al., 2011). |
3.3.2 FBSR 1A: Fluidized Bed Steam Reformer, On-Site Disposal
| 3.3.2a | There were comparisons to the Integrated Waste Treatment Unit (IWTU) in Idaho that are not completely correct (e.g., not a 1:1 comparison because of the differences in the flowsheets, such as carbonate at IWTU and Na-Al-Si at Hanford). Added value could be given to the report if it is corrected with respect to the original information from IWTU reports. |
| 3.3.2b | Table B1.2 (Volume II, Appendix B; Bates, 2022b) makes the statement “Iodine performance in the final waste form is unknown.” The fate of iodine is discussed in the reports SRNL-STI-2011-00387 (Jantzen et al., 2015c) and in SRNL-STI-2011-00383 (Jantzen et al., 2013) and leaching information is given. |
| 3.3.2c | In Subsection 1.1.2.1 of Section C.2.2 (Volume II, Appendix C; Bates, 2022b), statements are made that only short-term testing was performed. Long-term (1-year) product consistency tests (PCTs were performed, and in addition, the following tests were performed: there is additional pressure unsaturated flow-through (PUF) and single-pass flow through data previously published by McGrail et al. (2003a). |
| The data from the PUF testing of the P-1B material, which was made with the Rassat simulant on the engineering scale, can be compared to PUF testing performed by Pierce (Jantzen, 2004; Pierce, 2012) and Pierce et al. (Jantzen, 2006; Pierce, 2007) on the Rassat simulant made on the pilot scale at INL SAIC-STAR (bed products 1104/1123 and fines 1125) and the PUF performance testing (McGrail et al., 2003b) on AN-107 made in a pilot scale FBSR. For example, Figure 8-26 shows the release of the elements from the AN-107 FBSR product to be lower than the release … from LAWA44 glass. | |
| This quote is from SRNL-STI-2011-00387 (Jantzen et al., 2015c). This extensive report has a summary table (Table 3-2) that summarizes all the pilot-scale testing from 2001 through 2013 and bench-scale testing on radioactive and nonradioactive testing with references. | |
| 3.3.2d | Section 1.1.2.1.1 (Volume II, Appendix C; Bates, 2022b) states “PCT is not indicative of long-term IDF performance, no comparative performance exists for FBSR.” A risk assessment (RA) was performed on FBSR products. And a preliminary RA (Mann et al., 2003) demonstrated that the release rates for the FBSR mineral product were the same as glass LAWA44 and 100 times slower than glass LD6-5412 formulated with the same AN-107 waste simulant. Note, the PA evaluation required the pH dependence of the nepheline dissolution rate (η) since the Na-Al-Si phases in the waste form (nepheline, nosean, and sodalite) all share the basic nepheline crystallographic framework structure. Values of η were available in the literature for natural single-crystal nepheline and for nepheline glass, but the published η values differed widely, allowing only bounding PA calculations to be performed. |
| 3.3.2e | In Section 1.2.1.4.2 regarding the REDOX of Cr and Section 1.2.1.4.3 (Volume II, Appendix D; Bates, 2022b) regarding other RCRA metals, the description of the process is at issue. The denitration mineralization reformer (DMR) is a very reducing environment. In fact, the process “cracks” water, which is itself a redox reaction between steam and carbon, and the DMR stays reducing and so does the granular product. The granular product is “harvested” off the bottom of the DMR. Only the gasses and some small amount of fines go on to the oxidized carbon reduction reformer (CRR) or TO. Comments such as the clause at the end of the sentence of Section 1.2.2.6.2 “but no long-term testing on oxidation” suggests that the representation of the process in this section does not appropriately describe the process because the granular product will not pass through the CRR or TO. |
| 3.3.2f | Section 1.2.2.4 (Volume II, Appendix D; Bates, 2022b) states that Se-79 was not tested for in RCRA testing. Correction is needed. SRNL-STI-2011-00387 (Jantzen et al., 2015c) has three tables (Tables 8-47 through 8-49 for granular and 9-16 for the monolith) of RCRA testing on the granular product of actual Hanford radioactive waste made with varying redox, and all the RCRA metals were tested for (Sb, As, Ba, Cd, Cr, Pb, Se, Ag, Hg, Ni, Tl, Zn). |
| 3.3.2g | Many of the issues at IWTU were due to Idaho National Engineering and Environmental Laboratory personnel choosing the internal components (including choice of materials of construction), rather than THOR Treatment Technologies (TTT). Others were due to the reliance on the high CO2 fugacity needed, as discussed above. This is not a problem in the Na-Al-Si flowsheet, which relies on the steam reactions rather than the carbonate fugacity. |
| 3.3.2h | For the likelihood of successful mission when considering FBSR 1A, relevance to the IWTU lessons learned is not exactly a 1:1 comparison. All pilot-scale demonstrations with the Na-Al-Si flowsheet have been successful since 2001. There are disagreements to Section 3.1.1.1.6 (Volume II, Appendix D; Bates, 2022b) that states “Only limited work has been done on variability and consistency of the granular waste form” and ends with “high consequences that waste form leaches radionuclides.” DOE invested a substantial amount of money in demonstrating this technology over a variety of LAW compositions (i.e., the focus of the down-select document). |
| 3.3.2i | Alumina is listed as an additive; however, it is a startup bed requirement. No alumina is added during the process, only clay. The DMR is not usually idled, and product can be recycled instead of adding excess alumina. Usually during a process upset, the DMR is shut down and restarted. Additionally there is disagreement with a second point in the description of the process, “excess clay ensures that off-spec product is not created.” This second bullet under Section 3.1.1.2.2 (Volume II, Appendix D; Bates, 2022b) needs to be corrected as it states “a composition and control model could be developed as the technology matures.” It has already been developed at SRNL and proven multiple times as it was used during all pilot-scale campaigns at INL and Hazen Research. |
| 3.3.2k | Multiple ways to encapsulate the granular product were proposed and investigated, including high-integrity containers (HICs), supercompaction, grout, and geopolymer. The geopolymer was chosen because it is an Na-Al-Si product and shares the Na-Al-Si chemistry with the FBSR granular product. The cements, geopolymers, and HICs, with or without supercompaction, yielded a disposal volume decrease compared to caststone and Envelope B (high SO4) vitrification because the sodalite mineral in FBSR sequesters SO4, which vitrification cannot handle. |
| 3.3.2o | In Section 3.1.1.3 (Volume II, Appendix D; Bates, 2022b), the origin of “sulfur-impregnated activated carbon” is unknown. The calcined coal is chosen for the Na-Al-Si flowsheet to be low sulfur. All units use a CRR, not a TO, which would eliminate the need for propane, natural gas, and/or fuel oil. The sections following 3.1.1.3 also have many incorrect statements about a cold shutdown requiring 1-2 days. |
3.3.3 Grout 4B: Off-Site Vendor for Grouting and Off-Site Disposal
| 3.3.3a | Very limited data were presented on off-site grouting, specifically that would allow for technical review. The clear mention is in Volume II, p. F-25 (Bates, 2022b). “Note that the off-site grouting cost used for Grout 6 and Grout 4B is the lower cost per gallon ($30 versus $45/gallon).” A more thorough analysis is necessary. |
