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Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
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Summary

Section 3125 of the National Defense Authorization Act (NDAA) for Fiscal Year 2021 (Public Law 116-283) (Sec. 3125) calls for a federally funded research and development center (FFRDC) to “conduct a follow-on analysis to the analysis required by Section 3134 of the National Defense Authorization Act for Fiscal Year 2017 (Public Law 114-328; 130 Stat. 2769) (Sec. 3134) with respect to approaches for treating the portion of low-activity waste at the Hanford Nuclear Reservation, Richland, Washington, intended for supplemental treatment.”1 The analysis “shall be designed, to the greatest extent possible, to provide 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.” For the criteria that Congress wants considered, see Appendix A, which provides the complete texts of Sec. 3125 and Sec. 3134.

As with Sec. 3134, Sec. 3125 specifies that the National Academies of Sciences, Engineering, and Medicine (the National Academies) are “to conduct a review of the analysis” performed by the FFRDC that is independent of and concurrent with the FFRDC’s analysis and intended to improve the quality of the analysis. The U.S. Department of Energy (DOE) has contracted with Savannah River National Laboratory (SRNL), an FFRDC, to provide the required analysis. SRNL assembled a team of experts from SRNL, other national laboratories, and from outside the national laboratories’ network to perform the analysis. The Statement of Task (SoT) for the National Academies review is provided in Appendix B.

This third and final review report from the National Academies in response to the congressional mandate again addresses the SoT given to the committee.

  1. Does the FFRDC’s report clearly lay out a framework of decisions to be made among the treatment technologies, waste forms, and disposal locations?
  2. Does the FFRDC’s report consider in its analysis all the elements, criteria, and factors specified in Section 3125 of the National Defense Authorization Act of 2021?

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1 According to DOE’s Radioactive Waste Management Manual, low-activity radioactive waste means the waste that remains after as much of the radionuclides as technically and economically practicable have been removed from the tank waste, and that when immobilized in waste forms, may be disposed as low-level waste in a near-surface facility, as long as the waste meets criteria in the Waste Incidental to Reprocessing determination. Supplemental treatment refers to processing of the low-activity waste that is excess to that portion to be treated by vitrification in the Waste Treatment and Immobilization Plant.

Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×
  1. Does the FFRDC’s report provide additional analysis for the grout treatment approach as identified in the FFRDC report for Section 3134 of the National Defense Authorization Act of 2017?

The committee’s comments in this third review report are based on the FFRDC report received January 16, 2023, titled Follow-on Report of Analysis of Approaches to Supplemental Treatment of Low-Activity Waste at the Hanford Nuclear Reservation (Volumes I and II). This 829-page report (Bates et al., 2023) includes an updated report and appendices to the report delivered in April 2022 (Bates, 2022a, b). Changes to the report made specifically in response to the second review are summarized in Appendix F. Presentations supporting the material were provided by the FFRDC during a public meeting to discuss the report in Richland, Washington, January 31–February 1, 2023.

As specified in Section 3125, the National Academies committee is neither charged to evaluate the supplemental treatment approaches nor recommend any particular approach but is instead to review the FFRDC’s analysis. The FFRDC’s task is to provide data and analysis that will enable DOE, with congressional oversight, to decide on an approach, or some combination of approaches, to treat the supplemental low-activity waste (SLAW) by converting it into a waste form suitable for disposal.

As discussed in the first and second review reports (NASEM, 2022a, b), the impact of treating SLAW has ramifications across the entirety of the Hanford operations to meet the milestones of solidifying wastes for permanent disposal. As part of the directive, the FFRDC has selected four alternative approaches that are most likely to succeed as they have been demonstrated at other DOE sites including Savannah River Site (SRS) and Idaho National Laboratory. The baseline alternative is vitrification with disposal at the Integrated Disposal Facility (IDF) at Hanford. The three others are treatment using fluidized bed steam reforming (FBSR) methods with on-site disposal (IDF), off-site grouting and disposal, and finally a phased approach that begins with off-site grouting and disposal then transitioning to on-site operations. Sec. 3125 specified the requirement for “criteria that are relevant to decision making and most clearly differentiate between approaches.” The criteria used by the FFRDC are:

  1. Long-term environmental and safety effectiveness,
  2. Implementation schedule and risk,
  3. Likelihood of successful mission completion,
  4. Life-cycle costs,
  5. Securing regulatory permissions, and
  6. Public acceptance.

Notably, a recurring theme in the FFRDC report is the on-going discussions with the Washington State Department of Ecology. DOE Hanford, its contractors, and regulators are working toward issuing the Resource Conservation and Recovery Act of 1976 (RCRA) permit modifications needed to allow disposal of vitrified low-activity waste (LAW) and associated grouted secondary solid waste at IDF.

In this review findings and recommendations with supporting narratives are presented in Chapters 2-4. Chapter 2 contains the committee’s findings and recommendations that are directly responsive to the questions contained in the committee’s Statement of Task (Appendix B). Chapter 3 contains the committee’s assessment of the strengths of the FFRDC’s report; and Chapter 4 contains the committee’s assessment of its limitations. Taken together, Chapters 3 and 4 can be seen as the committee’s reflections on the most appropriate ways decision makers and stakeholders could make use of the extensive data, analysis, and conclusions of the FFRDC report.

FINDINGS AND RECOMMENDATIONS

The following findings and recommendations are made based on the SoT given to the National Academies of Sciences, Engineering, and Medicine committee, the strengths of the report as determined by the committee, as well as limitations.

Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×

Question 1. Has the FFRDC produced a decision framework for SLAW?

Finding 1. As the committee has reported in its prior reviews, the FFRDC has produced a useful framework for deciding how to treat and dispose of SLAW. While its application has some important limitations, which are described below, the latest FFRDC report contains the key elements of a decision framework and provides an evaluation of the key criteria that the FFRDC is qualified, as subject matter experts, to address.

Finding 2. The latest report contains several new and revised ways of comparing the alternatives and subset of options for each alternative according to relevant criteria (i.e., tables that highlight different factors and make different pairwise comparisons), which will be helpful to decision makers (Bates et al., 2023, Vol. I Sections 4 and 6, Appendix E).

Finding 3. The FFRDC’s application of the full decision framework that it has developed is incomplete from a decision maker’s perspective because two important decision criteria that were discussed in the report have, appropriately, not been included explicitly in the comparative analysis by the FFRDC during its evaluation: regulatory approval and public acceptance. The committee considers it appropriate for the FFRDC not to have evaluated these two criteria because that requires policy judgments outside of the FFRDC’s areas of expertise. However, the committee considers it important that decision makers recognize that they should scrutinize the robustness of the FFRDC’s recommendation in the context of their own judgments regarding these two remaining criteria.

Question 2. Did the FFRDC consider all of the factors listed in NDAA 2021 (and, by reference, NDAA 2017)?

Finding 4. The FFRDC considered and gathered information concerning all of the statutorily required factors. While two important criteria—regulatory approval and public acceptance—were treated as uncertainties and not included in the team’s comparative analysis, their potential importance as obstacles to implementation of any given alternative or option was acknowledged. This is discussed further in Finding 17 and in the narratives associated with other findings below. In the case of regulatory approval, a thorough summary of issues was provided as an appendix in the FFRDC report (Bates et al., 2023, Vol. II, Appendix I). Note, additional factors might result from the ongoing Tri-Party Agreement (TPA) Consent Decree/Order negotiations but were not considered due to the confidentiality of the negotiations.

Finding 5. The FFRDC did an excellent job of disaggregating the technical statutory criteria into specific factual considerations that can be analyzed, often quantified, and compared with each other. (This is not the same as weighting the criteria for the purposes of a recommendation or decision as discussed below.)

Question 3. Did the FFRDC provide additional analysis of grout?

Finding 6. The FFRDC report considered grout in greater detail than the prior FFRDC report, including (a) analyzing 15 grout options, (b) analyzing various off-site scenarios for grout treatment and disposal, and (c) considering in detail the SRS experience with grout treatment (FFRDC presentation January 31, 2023, slides 150 and 151, and Bates et al., 2023, Vol. I, Appendix D 3.7 and Vol. II, Appendix H). The main criteria used to defend consideration of off-site vendors was the cost effectiveness of off-site grouting and the ability to start LAW treatment earlier using an already operational grouting facility off-site.

Finding 7. While the FFRDC provided additional analysis of grout, the FFRDC also offered a specific recommendation that DOE expeditiously begin to develop multiple off-site, out-of-state pathways for either grouted SLAW or off-site treatment of liquid SLAW and off-site disposal. The recommendation is not identification of a preferred option (as one would expect in an Environmental Impact Statement (EIS) and associated Record of Decision), but rather seeks to identify a course of action, such as a programmatic EIS, that would remove SLAW from the Hanford site (and Washington State) quicker than the current plan of record.

Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×

Recommendation A. Within the scope of the committee’s Statement of Task, the FFRDC report should be accepted as a useful technical framework for future decisions about the treatment and disposal of SLAW. Should the grout technology be chosen, detailed analysis will need to be done to select the best grout option and to implement it.

Report Strengths

Finding 8. The result of the iterative process is a stronger report that will be useful to decision makers in understanding the issues and trade-offs and ultimately determining how and where the SLAW will be managed. It has gathered together a great deal of relevant technical material from a variety of domains in one place.

Finding 9. The FFRDC has made a strong technical case (1) that off-site disposal of grout is for the most part a valid option, and may be a technically valid option with on-site disposal, depending on the results of a performance assessment for the on-site disposal facility; (2) that there is a clear and persistent difference between grout and the other two alternatives (vitrification and FBSR) on virtually all technical criteria that the FFRDC evaluated; and (3) that grout dominates the other two alternatives on the basis of cost and time to operational start-up.

Finding 10. The committee notes multiple studies that have been done to demonstrate that the FBSR product is as stable as vitrification and has equivalent immobilization of the radionuclides (NASEM, 2020, 2022b). The FFRDC report notes the same: that FBSR is less expensive than vitrification but has a much higher technical risk than grout or vitrification in the context of Hanford SLAW. On this basis the FFRDC concludes that FBSR is not an attractive alternative for treating Hanford SLAW. The committee is in agreement with the FFRDC assessment on this point based on the evidence given.

Finding 11. The FFRDC has made a technical case that grout treatment and disposal of SLAW could occur at locations other than the Hanford site—and in various combinations of function, location, and time (e.g., Grout 4B)—and thus articulated a clear rationale for disposing off-site if that is the choice of the relevant decision makers. The addition to the analysis of off-site treatment and/or disposal has created a new set of SLAW options for decision makers, noting the off-site locations do not reside near potable water or above aquifers.

Finding 12. The FFRDC recommendation, based on the importance of speed, flexibility, and cost in the disposition of SLAW, recognizes that time both is and is not our friend. It is not our friend in the sense that the longer the cleanup process goes on, the greater the risks (worker and public exposure, accidents, leaks, etc.) and costs. At the same time, it recognizes the value of time in allowing multiple pathways for resilience (NASEM, 2022b) and that a decades-long program offers opportunities for learning and the deployment of new technologies (NASEM, 2022a, b).

Finding 13. The analysis of the extent to which organic chemicals subject to land disposal restrictions could impede the use of grout is a valuable addition to the assessment of on-site disposal because it touches on something that will have a significant role in seeking regulatory approval of grout.

Finding 14. Volume 2, Appendix I of the FFRDC report provides an excellent overview of the regulatory issues for SLAW, especially when used in conjunction with Appendix J, which is the detailed position of the Washington State Department of Ecology. However, as the FFRDC emphasizes, Appendix I does not attempt predictions about actual approval of specific options, the permitting process, and other aspects of regulatory approval.

Finding 15. The Conclusions and Recommendation section of the FFRDC report is a helpful guide to the significance of the details in the main body of the report and its appendices. This section also improves the transparency of the report, in that it clearly sets out the inferences that the FFRDC team has drawn from their analysis. (As stated above, however, assessment or endorsement of the substance of the recommendation is beyond the scope of the National Academies committee’s Statement of Task.)

Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×

Recommendation B. DOE faces many uncertainties inherent in decisions with long-term completion horizons, challenging materials, complex technology, evolving technology, and an unpredictable regulatory and stakeholder environment. Under these circumstances, it should emphasize flexibility in its overall approach, allowing for multiple, redundant options and pathways, as well as the ability to change over time. (Grout 6 is an example of such an approach because it allows for changes in treatment and disposal location during the long-term mission.)

Report Limitations

Finding 16. The FFRDC report has been completed during—but separately from—an ongoing “holistic review” of the Hanford facility construction, waste recovery, and disposition schedule, which is related to a review of the TPA and revision of the federal district court’s consent decree regarding Hanford cleanup. While these proceedings are almost entirely opaque to the committee (inevitably so, given the confidential nature of the discussions), the FFRDC stated to the committee that they had access to some of the technical underpinnings, such as the Analysis of Alternatives (AoA) that DOE released publicly just a few days before the committee’s last meeting.

Recommendation C. The FFRDC report should not be used in a vacuum. Rather, decision makers must integrate the AoA, consent decree, holistic negotiations, and especially the regulatory approval and public acceptance criteria, in reaching a final decision on how to manage SLAW.

Finding 17. The FFRDC chose to exclude Criterion 5 (regulatory approval) and Criterion 6 (public acceptance) from its analysis of the four options it identified, limiting its analysis to purely technical considerations (Criteria 1–4). While this exclusion is preferable to having the FFRDC speculate on the probability of regulatory and public responses, these criteria will inevitably have to be considered in the future by decision makers to achieve in order to implement any option chosen. Moreover, the conditions and likelihood of regulatory approval and public acceptance are likely to vary considerably among options, e.g., off-site disposal of grouted SLAW versus disposal of grouted SLAW in IDF. The exclusion of Criteria 5 and 6 from the analysis thus represents a significant, albeit deliberate, limitation on the FFRDC’s decision framework.

Finding 18. Based on the necessity of regulatory approval and public acceptance for any final SLAW decision, assumptions about regulatory approval and public acceptance appear frequently in the FFRDC report, despite its disclaiming consideration of Criteria 5 and 6. For example, there are many generalizations about specific regulatory standards (e.g., that non-organic land disposal restrictions (LDRs) can be met, that every alternative is capable of being permitted), and public acceptance of low-level waste (LLW) transportation has not been a problem. In addition, regulatory standards will determine when the project is “done,” in that the project cannot be completed until such standards are met.

Recommendation D. The FFRDC’s decision framework excludes regulatory approval and public acceptance (Criteria 5 and 6), which are essential considerations for the success of the mission. Decision makers should immediately begin a thorough assessment of these two criteria to provide input to their consideration of how to manage SLAW.

Finding 19. Because of a number of limitations noted in Box 4-1, the committee finds that the cost estimates are usable as indicators of relative costs but are not suitable for predicting actual costs and or establishing budgets. The cost estimates also can be useful as a constraint on the timing of various alternatives and a relative basis for comparison among alternatives.

Finding 20. The cost estimates are sufficiently robust to demonstrate that there is a very significant gap between the costs of vitrification and FBSR on the one hand and the various grout options on the other. The costs of the former and the latter, even after accounting for the wide ranges of cost estimation uncertainty also identified in the FFRDC report, do not come close to overlapping.

Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×

Finding 21. The timing estimates in the FFRDC report depend on assumptions concerning available funding, and thus they must be used cautiously as a rationale for choosing among technological options. It is nevertheless clear based on their respective technical characteristics that grouting of SLAW would need far less lead time for operational use than either vitrification or FBSR.

Finding 22. Before reaching a decision on the FFRDC recommendation, there will still be the need for detailed analysis of a wider variety of grout options than 4B and 6, including but not limited to:

  • the location of the grouting plant(s): on-site vs off-site, tank-side versus tank farm versus regional (west/ east) versus central;
  • the possibility of building commercial SLAW facilities on the Hanford site and then the possibility of operating them; and
  • detailed assessment of the waste acceptance criteria, cost, and other aspects of off-site treatment or disposal, including regulatory and public acceptance.

Recommendation E. DOE should promptly turn attention to a thorough review of all types of grout options—not limited to FFRDC options 4B and 6, and also extending the set of grout options that the FFRDC initially considered to include some of the additional ways that grouting can conform with the general attributes of the FFRDC recommendation that the committee has noted, while perhaps reducing some of the regulatory and public acceptance features of options 4B and 6. Specifically, the options considered should include on- and off-site grouting facilities, nearby and distant treatment options, commercial and public vendors (or public-private partnerships), commercial versus government facilities, and parallel strategies driven by structured analysis of technology status and technology maturation requirements.

Finding 23. The FFRDC analysis in their previous report led to a conclusion that liquid SLAW would easily qualify as low-specific activity (LSA) that would allow it to be transported at low cost in bulk quantities. This opens the door to more cost-effective SLAW management options involving off-site treatment and disposal. The revised analysis in the current FFRDC report indicates that the liquid SLAW may still qualify as LSA but only with careful attention to the composition of the SLAW going into each tank and then using measures such as partially filling the tanks, adjusting the number of tanks in a unit train, and/or additional pretreatment to comply with regulatory requirements. Even then, ensuring that precipitates will not form in variable SLAW compositions of wastes from different sources and possibly for tanks needing to be mostly full or mostly empty will be an operational and regulatory challenge.

Recommendation F. The fact that low-level liquid radioactive and mixed waste is and has been routinely qualified as LSA waste and transported in bulk over long distances and across multiple states in other contexts should not be seen as unconditional defense that all transport of the SLAW is acceptable. However, this is not a conclusive prediction of how much of and how readily the SLAW can qualify as LSA and the operational difficulties of doing so. Additionally, the assurances (however sincere) of receiving facilities (Bates et al., 2023, Vol. II, Appendix K) that such transport and receipt is accepted practice should not be viewed as meaning regulatory approval and public acceptance of sustained transport of large amounts of liquid SLAW would be acceptable without question or contention. DOE should conduct additional and more detailed investigations and assessments of operational feasibility, regulatory approval, and public acceptance at receiving sites and the transportation corridors to improve understanding of the advantages and disadvantages of transporting liquid SLAW before definitely settling on offsite pathways as the solution.

Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×
Page 1
Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×
Page 2
Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×
Page 3
Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×
Page 4
Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×
Page 5
Suggested Citation:"Summary." National Academies of Sciences, Engineering, and Medicine. 2023. Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3. Washington, DC: The National Academies Press. doi: 10.17226/26872.
×
Page 6
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The Hanford Nuclear Reservation in the state of Washington produced about two-thirds of the nations plutonium for nuclear weapons from 1944 until the last reactor was shut down in 1987. The U.S. Department of Energy Office of Environmental Management (DOE-EM) manages the ongoing clean-up at Hanford and has built a plant to convert the high-level radioactive waste into a glass form (vitrification) for safe disposal. However, decisions remain about how best to treat and dispose of the low-level waste at Hanford, which comprises over 90% of the volume of waste. To inform its decision, DOE contracted with key Federally Funded Research and Development Centers (FFRDC), led by Savannah River National Laboratory, to carry out an analysis. This final in a trilogy of reports from the National Academies reviews the FFRDC third report released in January 2023.

The review finds that the FFRDC team made a strong technical case that converting the supplemental low-level waste from the vitrification process to a grout form (like cement) is the best option in terms of cost-effectiveness and timeliness, and that off-site disposal of that grout is a valid option as it will be away from potable water. The FFRDC provided a useful framework to help decision-makers understand the issues and trade-offs of the disposal options and did an excellent job of isolating specific factual considerations that can be analyzed, often quantified, and compared with each other. The FFRDC chose to provide a purely technical analysis that excluded analysis of two important factors to be considered - securing regulatory permissions and public acceptance - treating them, for now, as uncertainties. Looking ahead, the DOE faces many uncertainties and should emphasize flexibility in its overall approach, allowing for multiple, redundant options and pathways, as well as the ability to change over time.

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