Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation Review #2 (2022) / Chapter Skim
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2 The Committee's Technical Review of the FFRDC's Complete Draft Report
2 The Committee's Technical Review of the FFRDC's Complete Draft Report
Pages 12-29
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From page 12... ...
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.
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From page 13... ...
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.
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From page 14... ...
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.
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From page 15... ...
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)
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From page 16... ...
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.
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From page 17... ...
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.
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From page 18... ...
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.
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From page 19... ...
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.
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From page 20... ...
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.
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From page 21... ...
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.
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From page 22... ...
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.
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From page 23... ...
, 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)
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From page 24... ...
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.
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From page 25... ...
describe how tanker dose rates were calculated and provide some summary results, especially for the dose rate at 3 meters and ii. reconcile the inconsistency between using shielding to meet the dose rate limit at 3 meters with the statement that such an approach is prohibited to underpin the conclusion that liquid SLAW will be LSA waste (10 CFR Part 71)
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From page 26... ...
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 suc cessful 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.
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From page 27... ...
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.
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From page 28... ...
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.
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From page 29... ...
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.
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