Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation Review #3 (2023) / Chapter Skim
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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.
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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)
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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.
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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.
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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.
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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.
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Note, the LAW vitrification facility is currently undergoing startup and commissioning. To increase the LAW treatment capacity, DOE-EM intends to decide on a supplemental treatment approach and to implement it.
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