Appendix D
Findings and Recommendations from “Review of the Continued Analysis of the Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #1”
Finding 1: Given the limited available space in the tanks that can safely store waste (e.g., non-leaking double-shell tanks), there may not be enough capacity to receive wastes from other tanks that presently contain the waste that will become immobilized HLW, LAW, and SLAW if more than a few tanks fail. While Sec. 3125 calls for analysis on “the costs and risks in delays with respect to tank performance over time,” the FFRDC draft framework does not include provisions to address the probability of tank failure with respect to time. The analysis will have to deal explicitly and urgently with the fundamental issues of budgetary constraints and the risks of breach of tank containment. Moreover, tank cleanup costs appear to exceed, under nearly any scenario, current funding levels.
Recommendation A: To address the risks of failure of the tanks within the context of budgetary constraints, the committee recommends:
- Reframing the fundamental question to be addressed in the FFRDC analysis going forward as: How can decisions about treatment of SLAW facilitate the fastest removal of the waste from the tanks and into a disposal facility, all things considered (e.g., budget limits, technology uncertainties, and regulatory acceptability)? This reframing will focus consideration on the most pressing issue of the risks of tank containment breach.
- 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.
Finding 2: In the committee’s view, the FFRDC’s task is to simplify and narrow the analysis to the factors whose incremental differences will highlight the key considerations likely to dominate the choices that DOE must make.
Recommendation B: The FFRDC report should (1) identify the relevant factors that “most clearly differentiate between approaches,” and (2) identify and bound the incremental difference that each such factor makes in the decision. The committee emphasizes that “narrowing” is not prioritizing factors, but rather identifying and highlighting the factors that account for the most salient, decision-relevant differences among the alternatives. That is, there needs to be a critical assessment of factors (cost, scope, and schedule, in particular) to understand which differentiate among approaches, and by how much.
Finding 3: While the FFRDC draft analysis is still at an early phase, identifying major uncertainties (possible range of outcomes and their likelihood) for each factor will be useful for decision makers in their deliberations.
Recommendation C: The FFRDC draft report should identify and analyze the major uncertainties in each of the selection criteria assessment results, the implications of the uncertainties, and the cost and benefit of investing in uncertainty reduction within the subset of selection criteria that most clearly differentiates among alternatives that DOE would need to consider in reaching a decision promptly.
Finding 4: The FFRDC has identified all of the relevant factors, criteria, and elements set out in the enabling legislation, and the FFRDC compilation reflects the early stages of its analysis and appears to be making significant progress as evidenced by the systematic definition and characterization of alternatives that reflect what was learned in the first phase study.
Recommendation D: Having identified the relevant factors, criteria, and elements, the remaining analytical task of the FFRDC is to distinguish among them and describe uncertainties in each, as discussed in Section 2.1 of this review report.
