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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3 The Committee's Observations Concerning the FFRDC's Draft Report
3 The Committee's Observations Concerning the FFRDC's Draft Report
Pages 30-36
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From page 30... ...
; 2. implementation schedule and risk (environmental and safety risks prior to mission completion, including risks driven by waste tank storage duration)
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From page 31... ...
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)
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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.
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, 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)
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From page 34... ...
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)
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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.
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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)
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