Appendix E

Presentations at the Committee’s Information-Gathering Meetings and List and Summary of Comments Received During the Public Comment Period

PUBLIC MEETING #1: WASHINGTON, DC, DECEMBER 12-13, 2017

Invited Presentations

• Congressional Perspectives on the Tasking, Jonathan Epstein, professional staff member, Senate Armed Services Committee
• Overview of the Department of Energy-Environmental Management (DOE-EM)’s Program and Perspective on the Committee’s Tasking, Betsy Connell, Director, EM Regulatory, Intergovernmental, and Stakeholder Affairs
• DOE’s Office of River Protection (DOE-ORP): Program Scope and Status, Delmar Noyes, Assistant Manager WTP Start-Up, Commissioning, and Integration, DOE-ORP
• Presentations by members of the Federally Funded Research and Development Center (FFRDC) Team, led by Savannah River National Laboratory (SRNL), Bill Bates, project leader, SRNL, with Michael Stone, SRNL, and Thomas Brouns, Pacific Northwest National Laboratory
• Perspective Regarding Congressional Interests about Cleanup at the Hanford Site, David Bearden, Congressional Research Service
• Perspective from Government Accountability Office’s Reports on Treatment Options for Low-Activity Waste at the Hanford Site, David Trimble and Nathan Anderson, U.S. Government Accountability Office
• Independent Assessment of Challenges Concerning Cleanup at the Hanford Site, Robert Alvarez, Senior Scholar, Institute for Policy Studies

Public Comments

• John Greeves, independent consultant
• Suzanne Dahl, Washington State Department of Ecology
• Geoff Fettus, Natural Resources Defense Council
• Ian Pegg, Vitreous State Laboratory, The Catholic University of America

PUBLIC MEETING #2: RICHLAND, WASHINGTON, FEBRUARY 28-MARCH 1, 2018

Invited Presentation

• Introductory Remarks on DOE-ORP, Jon Peschong, DOE-ORP

Presentations by Washington River Protection System’s Contractors

• Introduction, Jason Vitali
• Hanford Low-Activity Waste Historical Overview, Dave Swanberg
• System Plan 8 Baseline Case SLAW Sizing, Jeremy Belsher
• History of Supplemental LAW Treatment Reviews, Dave Swanberg

• History of Supplemental LAW Cost Comparison, Dave Swanberg
• Advanced Glass Program, John Vienna
• ILAW Glass Testing Program Status, Elvie Brown
• Overview of the 2017 IDF Performance Assessment for LAW, Pat Lee
• Radioactive Waste Test Bed Initiative, Stephanie Doll
• Cementitious Waste Form Formulation and Testing Status, Dave Swanberg

FFRDC Team’s Presentations

• Introduction to Study and Lines of Inquiry Table and Schedule Overview, Bill Bates (SRNL)
• Process Flowsheet Overview and Feed Vector Overview, Michael Stone (SRNL)
• Baseline and Vit Flowsheets and Preliminary Technical Readiness Levels (TRLs), Alex Cozzi (SRNL)
• Grout Flowsheets and Waste Forms and Preliminary TRLs, George Guthrie (Los Alamos National Laboratory)
• Steam Reforming and Waste Forms and Preliminary TRLs, Nicholas Soelberg (Idaho National Laboratory)
• Technologies Considered and Not Included, Thomas Brouns (Pacific Northwest National Laboratory)
• Disposal Facilities Overview, Waste Acceptance Criteria, and Transportation, John Cochran (Sandia National Laboratories)
• Analytic Approach to Risk, Thomas Brouns
• Cost Estimating Methodology, Frank Sinclair (SRNL)
• Wrap Up, Bill Bates

Stakeholders’ Presentations

• Alex Smith, Washington State Department of Ecology
• Dave Bartus, U.S. Environmental Protection Agency Regional Office
• Ken Niles, State of Oregon Department of Energy
• Susan Leckband, Chair, Hanford Advisory Board
• David Reeploeg, Vice President, Tri-City Development Council (TRIDEC)
• Pam Larsen, President, Hanford Communities
• Matthew Johnson, Confederated Tribes of the Umatilla Indian Reservation (CTUIR)

Public Comments

• Paul Flaherty, CHC Consulting, LLC, who made an oral presentation and submitted a written comment on behalf of Knauf Insulation
• Vince Panesko, Retired from the Hanford Site
• Don Alexander, Retired from DOE

Submitted Written Comments at the Public Meeting

• John Vienna, Pacific Northwest National Laboratory
• John Williford, Chrysalis Technology Group, Ltd.
• Tom Carpenter, Hanford Challenge

Submitted Written Comments to the National Academies of Sciences, Engineering, and Medicine Darryl Siemer, a consulting scientist who is retired from the Idaho National Laboratory, submitted a number of comments via e-mail.

PUBLIC MEETING #3: RICHLAND, WASHINGTON, JULY 23-24, 2018

Invited Presentations

Committee Members’ Presentations

• Observations from the committee’s Hanford Site tour during the morning of July 23, 2018, John S. Applegate (chair)
• Observations by two committee members and study director of the FFRDC’s expert elicitation on May 1-3, 2018, Anne E. Smith (member)

Stakeholder Presentation

• Agency’s Comments on the First FFRDC Draft Report and the Committee’s First Review Report, Alex Smith, Washington State Department of Ecology

FFRDC Team’s Presentations

• FFRDC Team Overview, Bill Bates (SRNL)
• Baseline, Feed Vector, Uncertainties, Michael Stone (SRNL)
• Analysis Approach, Tom Brouns (Pacific Northwest National Laboratory)
• Base and Variant Case Overview, Michael Stone
• Pretreatment Approaches, Michael Stone
• “Other” Considerations, Tom Brouns
• Vitrification Cases, Alex Cozzi (SRNL)
• Grout Cases, George Guthrie (Los Alamos National Laboratory)
• Steam Reforming Cases, Nick Soelberg (Idaho National Laboratory)
• Transportation and Disposal Site Considerations, Paul Shoemaker (Sandia National Laboratories)
• Estimate Methodology and Results, Frank Sinclair with William “Gene” Ramsey (SRNL)
• Analysis Results, Sharon Robinson (Oak Ridge National Laboratory)
• Summary, Bill Bates

Stakeholder Presentation

• Alfrieda Peters, Yakama Nation

Public Comment

• Mark Hall, Hanford Solutions and a former DOE employee

Submitted Written Comment to the National Academies

• Tom Galioto, long-term Tri-Cities resident, a former Hanford employee, and a current member of the Environmental Management Site Specific Advisory Board (EM SSAB) at Hanford that advises DOE on cleanup activities; he contacted the committee in his capacity as a private citizen and not as a member of the advisory board.
• John F. Williford, President, Chrysalis Technology Group, Ltd., Richland, Washington, submitted on July 22, 2018, a report that he wrote and titled, “Commercial Viability Assessment of Iron Phosphate Glass for Immobilization of Low-Activity Nuclear Waste for MO-SCI Corporation,” Chrysalis Technology Group, Ltd., December 8, 2002; he also submitted an opinion piece that proposes the idea of “treating all the tank waste without separation by vitrification.” The opinion piece’s citation is John F. Williford, “Is there a better way to treat tank waste?” Tri-City Herald, June 21, 2015.

PUBLIC MEETING #4: RICHLAND, WASHINGTON, NOVEMBER 29-30, 2018

Invited Presentations

Committee Member’s Presentation

• Observations on the FFRDC Working Meeting in Albuquerque, New Mexico, on October 16-17, 2018, Rachel Detwiler, Committee Member

Stakeholders’ Presentations

• Washington State Department of Ecology’s Perspective on the Most Recent FFRDC’s Draft Report and the Committee’s Review Report, Suzanne Dahl and Alex Smith, Washington State Department of Ecology
• Perspective from Hanford Advisory Board’s Chair on the Recent Report, Susan Leckband
• Perspective from the Hanford Communities’ Executive Director on the Recent Report, Pam Larsen
• Perspective of the Nez Perce Tribal Nation, Jack Bell, Director of Environmental Restoration and Waste Management Program

FFRDC Team’s Presentations

• Introduction of FFRDC Team Study, Bill Bates (SRNL)
• Process Overview and Major Assumptions/Bases, Michael Stone (SRNL)
• Analysis Approach, Tom Brouns (PNNL)
• Pertinent Pretreatment Technologies and Maturities, Robert Jubin (ORNL)
• Vitrification Case, Alex Cozzi (SRNL)
• Grout Cases 1 and 2, George Guthrie (LANL)
• Steam Reforming Cases 1 and 2, Nick Soelberg (INL)
• On-site Disposal Performance Evaluation (IDF), Tom Brouns
• Off-site Transportation & Disposal (WCS), John Cochran (SNL)
• Risk Analysis, Steve Unwin (PNNL)
• NDAA—Hanford Supplemental LAW Evaluation Cost Estimate Status, William “Gene” Ramsey (SRNL)
• Additional Discussion with the FFRDC Team

PUBLIC MEETING #5: ATLANTA, GEORGIA, JANUARY 8, 2019

There were no formal presentations. The FFRDC team and the National Academies committee had a 3-hour long discussion about the FFRDC’s incomplete draft report and next steps toward completing the report.

PUBLIC MEETING #6: KENNEWICK, WASHINGTON, MAY 16, 2019

Invited Presentations

Committee Member’s Presentation

• Independent Assessment of Science and Technology for the Department of Energy’s Defense Environmental Cleanup Program, John Plodinec, Vice Chair of the Committee on Independent Assessment of Science and Technology for the U.S. Department of Energy’s Defense Environmental Cleanup Program.

Stakeholder Presentation

• FFRDC Draft Report, Suzanne Dahl, Section Manager of Tank Waste Treatment, Washington State Department of Ecology

FFRDC Team’s Presentations

• Introduction of FFRDC Team Study & Final Draft Report, Bill Bates (SRNL)
• Performance Evaluation (PE) Inputs &Overview, Tom Brouns (PNNL)
• Performance Evaluation Results, Tom Brouns (PNNL)
• FFRDC Conclusions, Michael Stone (SRNL)
• Additional Discussion with the FFRDC Team

Public Comment

• Allyn Boldt, e-mailed submitted comment that was read at the public meeting.

PUBLIC MEETING #7: RICHLAND, WASHINGTON, OCTOBER 31, 2019

Comments received at this meeting from stakeholders and members of the public are included in the congressionally mandated comment period.

Invited Presentations

Committee Member’s Presentation

• Description of the Scope of the Committee’s Final Task and Summary of the Main Findings, Recommendations, and Observations of the Committee’s Review #3, John S. Applegate, Committee Chair

FFRDC Team’s Presentations

• FFRDC Overview—Final Report on Analysis of Supplemental Treatment Approaches for Low-Activity Waste at the Hanford Nuclear Reservation, Bill Bates (SRNL)
• Evaluation of Supplemental Low-Activity Waste Treatment Options: Performance Evaluation and Other Options, Thomas M. Brouns (PNNL)
• Key Updates, Conclusions, & Areas for Further Study, Michael Stone (SRNL)

Stakeholders’ Presentations

• Perspective from Tri-City Development Council (TRIDEC), David Reeploeg, Vice President, TRIDEC
• FFRDC Draft Report & NAS Review #3, Alex Smith, Program Manager, and Suzanne Dahl, Section Manager of Tank Waste Treatment, Washington State Department of Ecology
• Perspective from the Hanford Communities and the Energy Communities Alliance, Pam Larsen, Executive Director, Hanford Communities
• Office of River Protection Glass Science Program, Albert A. Kruger, Office of River Protection (presentation by invitation of the Executive Director of Hanford Communities)
• Perspective from the Hanford Advisory Board, Susan Leckband, Chair, Hanford Advisory Board
• Perspective from Oregon Department of Energy, Jeff Burright, Nuclear Waste Remediation Specialist, Oregon Department of Energy
• Perspective of the Wanapum Tribe, Rex Buck, Jr., Chief of the Priest Rapids Band

Public Comment

• Perspective of the Yakama Nation, McClure Tosch, Remediation & Restoration Specialist, Yakama Nation Fisheries

WRITTEN COMMENTS RECEIVED DURING THE COMMENT PERIOD FROM AUGUST 15, 2019, TO NOVEMBER 20, 2019

• Anonymous, as a final summary, the FFRDC should provide a qualitative, relative risk assessment of the viable treatment technologies over time, as compared to the increasing risk of potential tank ruptures and radioactive leaks to the subsurface. The NAS should review, comment, and recommend best future options for decision-makers to mitigate further environmental contamination at Hanford. This includes new tank construction to empty tanks that are high risk for rupture/leakage and treatment options that offer a quicker pathway for waste removal from tanks that are high risk for failure, August 19, 2019.
• Anonymous, asks if the study is surveying cancer incidence east and northeast of the plant over many years past; also expresses concern about rail transport through Hanford, August 28, 2019.
• Steven Fine, sent e-mailed comments on different dates; raises concern about whether the vitrification plant will be completed on time and if so, will it operate safely and effectively; cautions that “time is the enemy” and that further delays increase risks and that there is a chance for “a black swan event” happening such as a major flood or earthquake; asks to examine the options “in a total cost way”; emphasizes the Perma Fix technology that can treat low-activity waste as grout that can be shipped to WCS in Texas, September 3, 4, and 5, 2019.
• Anonymous, draws attention to the potential treatment of some waste streams including from the Effluent Management Facility and the Effluent Treatment Facility as commercial-treatment streams and that these “streams can contain significant ⁹⁹Tc and other isotopes. If processed as proposed, this waste would be transported as a liquid to a commercial facility in Richland (“Perma-Fix”) which is within just a mile or two of local food processing facilities [as well as] local residential areas and schools”; would appreciate if the risks of this inside the city limits approach could be considered in comparison to grouting the effluent/wastes in the Hanford 200 Areas (where it belongs). The lesson here is from the contamination found at a local school in Portsmouth, Ohio, from DOE waste remediation of a gaseous diffusion facility”; raises concern about the new disposal dilemma posed by the plan to place cesium-137 in ion exchange columns; asks if the number of curies of iodine-129 is overcounted because of the multiple evaporation passes in the tank farms have resulted in iodine releases and whether it makes sense to salt with non-radioactive iodine to reduce the potential exposure to the public; asks that the “all-glass” approach at Hanford be reconsidered in light of the “proliferation of secondary wastes, brines, and effluents that must now be treated,” September 4, 2019.
• Catherine Lee, expresses the position that the incomplete study does not yet provide the complete technical basis needed for a decision; asks that a final decision not be based on “least expensive” considerations but instead favor “most likely to contain radioactivity effectively for long periods of time”; in addition, asks for a decision to take into consideration what is acceptable for disposal outside of Washington state and notes that she is from Texas, September 5, 2019.
• Steve March, chair, and Dan Solitz, vice chair, Oregon Hanford Cleanup Board, who sent a letter dated September 3, 2019, which referenced a briefing and paper from the Oregon Department of Energy’s staff (the National Academies also received that paper on August 14, 2019, and Jeff Burright of the Oregon Department of Energy presented about the topics of this paper to the committee at the public meeting on October 31, 2019; that paper is part of the record for the comment period); the main positions from the letter from the Oregon Hanford Cleanup Board are (1) Hanford tank wastes pose an inherent hazard to the Columbia River; (2) decisions about waste forms should proceed from an ethical foundation of precaution; (3) there remains significant uncertainty regarding the performance of a grouted waste form disposed of at Hanford; (4) removal of technetium-99 and iodine-129 from low-activity waste would make a grouted waste form safer and more feasible for Hanford; and (5) if these radionuclides stay in the LAW, vitrification appears to remain the option most likely to result in long-term safety if disposed of at Hanford.

• Geoff Daly, an engineer, mentions consideration of the syn-rock project that was applied to about 25,000 pounds of low and high activity waste products and that immobilized this material into “a fully vitrified mass” at Oak Ridge; asks that this and potentially other additional methods be considered and for Hanford’s engineers to “think outside the box”; also suggests that Washington Department of Ecology should convene a public seminar to collect additional ideas, September 5, 2019.
• Anonymous, notes that the effort to recover from the loss of the WTP Pretreatment Facility, which was supposed to feed supplemental LAW, has resulted in a number of patchwork facilities that will create even more waste; also, no one should underestimate or gloss over the costs associated with high temperature process off-gas treatment; steam reforming off-gas, for example, will have similar design, safety, and cost issues as vitrification, September 9, 2019.
• Anonymous, expresses concern about the steam reforming facility being developed at Idaho National Laboratory that “has had both technical and project management failures, which are continuing”; cites as evidence the recent U.S. Government Accountability Office report on this facility (GAO-19-494); “would appreciate if the National Academies committee will consider the exponential savings that are possible by not having a technically complex process and by not having a high temperature off-gas process,” September 17, 2019.
• Don Meyers, recommends (1) getting all the authors of the TPA together to revisit, evaluate, and update the existing very stringent TPA requirements, (2) planning how to meet those updated and more realistic requirements, sell the plan to Congress and obtain the needed time and funding to finish the cleanup, (3) retrieving high risk liquid wastes from tanks, basins, cribs, etc. with past, proven Hanford methods, i.e., sluicing and evaporating, (4) disposing of structures/solid waste volumes in place, (5) completing cleanup with funds separate from the WTP, October 1, 2019.
• Richard O. Zimmerman, retired Hanford safety professional, mentions that the Hanford site’s railroad system is not cited in the FFRDC final draft report or in Review #3 and that there is a need to understand what are the applicable federal railroad regulations, October 4, 2019.
• FFRDC team’s comments on Review #3, see Chapter 2 for the summary and committee’s responses, October 10, 2019.
• Harry D. Harmon, Ph.D., retired nuclear processing consultant, mentions that bulk vitrification has not received much attention in the FFRDC’s analysis and specifically cites GeoMelt’s melters that have been treating nuclear and hazardous wastes since the 1990s and have produced more than 26,000 metric tons of glass for disposal in the United States and other countries; DOE’s technical concerns from 2006, when a technical assessment of bulk vitrification was published, were that during the melting process, “some of the technetium in the waste feed deposits in the refractory material as a soluble salt. In the performance assessment, the salt has the potential to create a technetium peak in the groundwater concentration”; “Metal inclusions have been observed in the resulting glass product. It is unknown whether these inclusions have a deleterious effect on the long-term performance of the waste”; mentions that all three studied options have remaining technical issues; asks for the specific glass composition that was used for the FFRDC performance evaluation be described; supports Review #3’s finding about learning valuable lessons and studying data in more depth from other sites, especially the Savannah River Site; points out that it is difficult to understand the bases for the schedules for implementation of the three technologies and that a schedule table with time required for technology development, design and construction, start-up, etc. would be helpful; add the Direct Feed LAW facility to the list of facilities that could affect future implementation of SLAW treatment; finally, points out the negative impact on the progress toward SLAW treatment by the frequent changes in direction which create further delays and increase costs, October 10, 2019.
• Tom Carpenter, executive director, Hanford Challenge, and Marco Kaltofen, Ph.D., engineering consultant to Hanford Challenge, wants “to be clear that Hanford Challenge considers Hanford’s tank waste to be high-level waste as defined by the Nuclear Waste Policy Act”; expresses concern

• that the cleanup “challenges tilts decision making towards faster, cheaper solutions at the expense of environmental protectiveness and human health and safety”; efforts to find alternatives to vitrification “have all ended with the conclusion that nothing proposed is ‘as good as glass’”; “firmly believes that waste containing long-lived radioactive toxins that will take millions of years to decay should not be buried at Hanford above an aquifer that feeds into the Columbia River” and “that cost savings should not be the dominating factor that drives cleanup decisions … and can often be deceptive”; for example, “if further research shows that the getters are not guaranteed to confine the technetium-99 and iodine-129 in grout form and pretreatment is required to remove these radionuclides prior to putting it in grout form, those cost savings could quickly disappear”; expresses concern about DOE’s “enthusiasm” for grout for SLAW, “despite the need for further research and development” and “seems premature to declare that there is a clear scientifically defensible path forward for grout … under the assumption that further study and research will confirm the best-case scenarios”; their technical concerns include: that “the grout form proposed by the FFRDC report is itself toxic and a potential threat to the environment”; “long-term integrity of grout is untested”; grouting “will not effectively bind residual high-level waste components such as iodine-129 and technetium-99”; “Hanford’s climatic and soil environments are particularly harsh for grout monoliths”; “Grout performance and the rate of groundwater flow through the grout monolith is critically dependent on near-perfect, fracture-free, installation”; “Future use scenarios assume continuous institutional controls over the entire life of the project, including unrealistic restrictions on land uses”; “Climatic scenarios exclude dam failures, Columbia River flooding, concentrated rainfall events, glacial flooding/damming, and climate change-induced alterations in evapotranspiration/rainfall, all of which are plausible and even predictable events for this region,” October 25, 2019.

• Paul Flaherty, CHC Consulting, LLC, expresses concern that Review #3 does not provide a clear determination that “the FFRDC performance evaluation has a poor technical basis for waste degradation model and mechanisms”; does not see that “any new technologies were identified or considered” by the FFRDC and is thus concerned about whether the FFRDC followed the congressional mandate; cautions that “the predicted degradation on the structural integrity of the landfill [IDF] will ultimately lead to adverse groundwater impacts” and “modeling variables should also consider daily operational activities during the active life of” the IDF “prior to capping of the landfill”; recommends considering the impacts of weather events on the structural integrity; also believes that the federal government should “provide post-closure integrity assurance into perpetuity”; mentions that at a previous public meeting he briefed the committee and the FFRDC team on a new vitrification technology that should be considered but that he “was never contacted by the FFRDC” despite providing his contact information; fully supports Recommendation 4-1 in Review #3, October 29, 2019.
• Julie Reddick, points out a potential risk that the ILAW flowsheet underestimates the volume of liquid secondary waste that will be produced; suggests that an unreliable water balance is a substantial uncertainty and risk, which should not be outside the scope of the task; the “add-on” cesium removal systems do not have disposal decisions approved by regulatory authority; “ETF is easily overwhelmed if liquid feed goes up. A flowsheet with the uncertainty in liquid volumes included is needed”; cites the GAO report DOE and NNSA Should Improve Their Lessons-Learned Process for Capital Asset Projects, GAO-19-25, December 2018; “The cost estimates in the FFRDC report are for only limited portions of the complete scope. The FFRDC report provides part of the picture, but does not examine the overall life cycle costs”; evaluate “the beyond the scope topics” for risk; there is a need for rebaselining of the waste treatment project using root cause analysis, which would meet the requirements of DOE Order 413.3B; expresses concern about tritium releases, October 29, 2019.
• Jean Wynn, opposes use of grout for Hanford’s tank waste disposed of at Hanford; requests use of glass because of its long-term durability, October 29, 2019.

• Nancy Arbuckle, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 30, 2019.
• Steven Fine, “grouting is a misnomer for the process that Perma Fix would use”; “Once the neutralized state is reached, then the whole container that has been processed will be encompassed by a special concrete mixture, that folks like Hanford Challenge [have] simply addressed as grouting as if the product coming in would just be encompassed with grouting without extensive neutralization”; “Then the encapsulated sample would appropriately by rail car be shipped to WCS in Texas, a process that has been affirmed. This process would save some 15 to 20 billion dollars and cost less than 1/3 of what the vitrified low rad product would cost to process”; characterizes Hanford Challenge’s opposition to the grouting process as “a scare tactic,” October 30, 2019.
• Julie Reddick, follow-on to previous message in order to send a steam reforming technology report that “confirms that both tritium and carbon-14 are not abated, but are discharged in bulk up the stack in the steam reforming ventilation system,” as shown on page 12 of THOR Treatment Technologies, LLC, THOR Steam Reforming Process for Hazardous and Radioactive Wastes, Technology Report, TR-SR02-1, Rev. 1, [undated], October 31, 2019.
• Gary A. Cooke, provides a link https://www.osti.gov/biblio/1523279 to an assessment of over 100,000 analyses of organic compounds in Hanford tank waste, concentrating on double-shell tank supernate. “It will be discussed in December’s Cementitous Waste Technical Exchange at SRNL,” October 31, 2019.
• Sandra Witherup Hankins, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Robert V. Masterson, Ph.D., opposes use of grout for disposal at Hanford, expresses concern about safely storing long-lived radionuclides, October 31, 2019.
• Dan Solitz, expresses appreciation for the “diligent attention to this matter” and the quality of the meetings that he viewed via webinar; wants to know what is the “cost of mining a full failed tank and processing the tailings to meet a waste acceptance criteria”; also seems to him that “there is time, as it will take a while to formulate good as glass grout,” October 31, 2019.
• James E. Strick, Professor, Dept. of Earth and Environment, Franklin and Marshall College, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• James P. Thomas, notes in his comment that he has “been involved with Hanford environmental issues since 1984” and that he is “currently writing a book on the history of Hanford’s plutonium processing and the resulting environmental harm,” opposes putting Hanford’s tank waste in grout; “vitrification of the waste and deep geologic burial is the only way to adequately protect future generations,” October 31, 2019.
• Patricia Janesh, Ph.D., M.P.H., opposes grout and believes that the “use of glass appears to be the most effective” treatment approach,” October 31, 2019.
• Laura Feldman, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Alexandra K. Smith, Program Manager, Nuclear Waste Program, Washington Department of Ecology (this is a summary of the Department of Ecology’s submitted written comments, which address several of the same as well as additional themes presented by the in-person presentation by Suzanne Dahl at the public meeting on October 31, 2019), (1) staff of the Department of Ecology “appreciate the enormous body of information that underlies the scope of the FFRDC study, and acknowledge that it is virtually impossible for the FFRDC to address every issue for every audience in this report”; (2) “the greatest disappointment of this report was the terse discussion of pretreatment for Tc-99 and/or I-129 removal upstream of supplemental low-activity waste (SLAW) treatment …

• selection of a SLAW treatment technology other than vitrification as a general proposition, it is not sufficient to be acceptable as the basis for selection of a SLAW treatment technology other than vitrification for on-site disposal. This is because the enhanced grout and FBSR waste forms have not yet proven to have long-term performance”; (14) “was heartened that NAS included the ‘Considerations for Decision-Makers’ in their review”; highlights that there has been one double-shell tank failure, AY-102, and three years were required to retrieve the contents; four more double-shell tanks are in similar condition; in addition, double-shell tanks’ availability will further decrease during DFLAW operations and due to Tank Side Cesium Removal pretreatment; therefore, the state of Washington wants to avoid “any technology that will require additional research and development where possible, because the evidence is mounting that the existing tank infrastructure is running out of capacity and time,” October 31, 2019.

• Pam Larsen, Executive Director, Hanford Communities (this is a summary of her submitted written remarks, which address the themes in her in-person presentation at the public meeting on October 31, 2019), points out that the parties of the Tri-Party Agreement have agreed that the low-activity waste will be vitrified and that there is a Federal Court Consent Degree to that effect; as to the treatment of SLAW, steam reforming was studied extensively at Hanford at the cost of hundreds of millions of dollars and “was not found to be acceptable”; as to the grout option, she had previously spoken to the committee about the Test Bed Initiative (TBI), a process for separating the cesium and solids from low-activity waste, grouting the remaining other material and shipping it to WCS for disposal; she expressed disappoint in how the TBI is addressed in Review #3; while the TRU permit request “has been temporarily withdrawn for timing, not technology reasons, TBI offers a low tech, low cost option to remove waste from tanks, grout it and [send] it to an appropriate landfill”; in addition, she expressed that there are historic concerns about grouting waste and burying it at Hanford because “previous studies have demonstrated that some constituents of Hanford waste leach out of grout”; wants to make sure that members of Congress and their staff understand that appropriate cost comparisons about treatment options and especially consider the relatively low cost of TBI, October 31, 2019.
• Laurene Contreras, Program Manager, and McClure Tosch, NRIA Lead, Yakama Nation ERWM (many of the themes in the summary of these written comments were presented by Mr. Tosch at the public meeting on October 31, 2019), requests an extension of the comment period in light of new information presented at the public meeting [the National Academies subsequently extended the comment period to November 20, 2019], emphasizes that the Hanford area “holds cultural significance for many reasons” such as providing “foods and medicines that cannot be found anywhere else”; underscores that under the Treaty of 1855 the Yakama Nation was established and “ceded over 12 million acres of land to the United States,” but preserved rights for the Yakama people to, among other usages, “right of taking fish at all usual and accustomed places” to include places on the Columbia River; notes the vital importance of this river to the Yakama Nation; notes that Review #3 makes it “very apparent that the committee has found substantial uncertainties in the technologies for waste treatment and disposal” as analyzed by the FFRDC; believes that the committee “should include a recommendation for evaluation of impacts to Tribal people and resources in recommendations 2-1 and 3-1”; states their view that leaving waste on the Hanford site is not an acceptable alternative because it will restrict their access to their “accustomed places,” impacting their Treaty rights, and notes that the Hanford Challenge’s submitted comments supports their position; suggests “the committee add Tribal, State, and Other Entities opposition as a bullet point to Recommendation 2-1 (d)”; “shares the concerns with Hanford Challenge regarding the threats posed to groundwater, the use of impractical long ranged institutional controls, and the potential effects of climate change and severe weather events that could compromise the protection of human health and the environment from long lived radionuclides present in this waste stream,” October 31, 2019.
• Anonymous, do not re-classify radioactive waste as low-activity waste; take it to a geological formation and away from the river, October 31, 2019.

• James Byron, states that he is anxious to hear of the findings, October 31, 2019.
• Rob Roy Rowley, “I do not believe the leaking tank waste or its by-product should be put into grout. It is already a sin what has been done in the Columbia Basin”; “do the right thing and clean up properly and stop making waste,” October 31, 2019.
• Adam Romero, Ph.D., University of Washington, concerned by the FFRDC’s recommendation that Hanford’s tank waste be immobilized in grout. Hanford’s Supplemental Low-Activity Waste (SLAW) should have long-lived radionuclides removed and then be immobilized in glass to ensure protection of future generations. “Protection of the environment and people is my priority, not short term cost savings,” October 31, 2019.
• The Hayden Family, sent by Melissa Bethke, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Caroline Bryant, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Steven G. Gilbert, Ph.D., Institute of Neurotoxicology & Neurological Disorders, Seattle, Washington, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Ted Granger, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site; he also noted in his comment that “This is the stock text from Hanford Challenge, which is fine, but perhaps too mild in reacting to the absurdity of encasing nuclear waste in concrete or grout.” He also mentioned his 60 years of experience in construction, mostly as a registered architect, with extensive experience in dealing with concrete, October 31, 2019.
• Gail Grinnell, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Judith Klayman, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobileized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Jenna McLellan, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• James P. Milbauer, “a concerned Hanford worker,” opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Patricia Morton, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Kelly Norton, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Jeanne Poirier, do not take short-cuts to save money today; opposes grout and favors glass, October 31, 2019.
• Beth Sanders, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.

• Carol Shaffer, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• John L. Swanson, troubled by the use of the word “supplemental”; it is sometimes used as “supplemental treatment of LAW” and other times as “treatment of supplemental LAW”; such phrases do not mean the same thing; he recommends correcting imprecision in terms in final reports, October 31, 2019.
• Randolph W. Urmston, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• John Wolcott, opposes putting Hanford’s tank waste in grout; SLAW should have long-lived radionuclides removed and immobilized in glass; do not dispose of grouted SLAW at Hanford site, October 31, 2019.
• Kathleen M. Saul, Ph.D., expresses anger about the many years and many dollars spent in trying to develop a new technology while very little progress has been made in cleaning up the waste; opposes use of grout because experience “around the world has shown that concrete type materials degrade over time and due [to] the heat and radiation from the materials surrounded by the concrete; believes that the SLAW should have the long-lived radionuclides removed and be immobilized in glass to ensure protection of future generations,” October 31, 2019.
• Chuck Broscious, President of the Board, Environmental Defense Institute, agrees with Hanford Challenge’s concerns about the use of grout for Hanford waste and that grouted SLAW should not be disposed of at Hanford; also cautions that the technical and management problems over several years in trying to treat Idaho National Laboratory’s waste using steam reforming should serve as a lesson for Hanford; expresses concern about the many billions of dollars that “have been wasted on quick-and-cheap solutions,” October 31, 2019.
• David Kosson (Principal Investigator), Craig Benson, Kevin Brown, Kathy Higley, Andrew Garrabrants, Jane Stewart, Richard Stewart, and Hans van der Sloot, members of the Consortium for Risk Evaluation with Stakeholder Participation (CRESP), recognize the fundamental goal of protecting human health and the environment and that “Hanford tank waste cleanup is fundamentally different and more complex and costly than ever imagined during the development [of] the current complex web of federal and state laws and regulations governing nuclear waste and environmental management. Current cost and schedule estimates should only be considered coarse estimates, with cost and schedule growth inevitable, as has been shown to be typical for federal projects of this magnitude”; this “leads to a fundamental choice: (i) continue along the current plan of record, or (ii) chart a course that results in more rapid and cost effective cleanup while assuring tank waste management is consistent with expectations of adequate protection of human health and the environment that is applied elsewhere in the country”; the “Tank Closure and Waste Management EIS (2012) and Record of Decision (2013), which provide the foundation for the current plan of record, are predicated on overly conservative and bounding assumptions (biased towards overestimating risk). Similarly, performance assessments carried out under DOE 435.1 are biased towards overestimating risk and with bounding assumptions to demonstrate that the proposed action is adequately protective, rather than providing best estimates of performance based on the best available science and engineering with uncertainty”; supports the committee’s point in Review #3 “that having start/stop capability may be particularly important because … the receipt rate [of the SLAW] is projected to be highly variable”; “suggests that the focus should not be on any specific waste form (e.g., glass versus others) but instead on defining the necessary technical performance requirements of any waste form that would be used for low-level waste burial in the IDF”; “suggests that these potential worsening conditions [of the integrity of the tanks] and delays be considered more directly in future decision making concerning the Hanford tank wastes”; “would like to reinforce the opin

• ion that the R&D will be an ongoing need during development and operation of the treatment facilities, and that the current investment in directly supporting R&D is insufficient”; “encourages the Committee to recognize that Hanford also competes for resources across the entire DOE Environmental Management mission, and greater expenditures at Hanford will likely slow progress at other sites”; believe that it would be incomplete for the committee “not to include analysis of options for SLAW disposition using the current HLW definition adopted by the Department” [in the Federal Register notice in June 2019], but they note that this definition has yet to be implemented at Hanford; highlights that Review #3 “begins with the premise that there is a ‘perceived agreement’ that the final waste form for tank SLAW will be vitrification or another final waste form that is ‘as good as glass’”; “DOE has not entered into any such agreement, and CRESP urges that this error in [Review #3] be corrected” and “should make clear that the Hanford Federal Facility Agreement (FFA), which is the legally binding agreement, … contains no such agreement”; Review #3 “does not address the important issue of regulatory authority over mixed waste, and its implications for regulation of SLAW. RCRA regulators have the authority to regulate the chemically hazardous aspects of mixed waste, whereas regulators with nuclear regulatory authority—here DOE—have authority over the radioactive components. Under this allocation, RCRA regulators do not have authority to impose different regulatory requirements depending on the radioactivity of mixed wastes unless those differences affect the chemically hazardous character of the wastes”; “Developing an adequately protective and cost-effective treatment plan for non-HLW SLAW wastes requires that DOE, Washington state, and EPA fully and carefully consider the potential applicability of all available LDR flexibility mechanisms…. The analysis should evaluate the prospects for each major category of non-HLW SLAW waste stream to meet the criteria required for regulatory approval for use of each of the RCRA LDR flexibility mechanisms.… If the analysis is not possible for this Report, we strongly recommend that it be considered for a follow-on NAS study”; there is the need for a more accurate inventory of RCRA tank wastes and that the current operating assumption is that all of the tanks contain all of the hazardous materials under RCRA, thus substantially increasing the costs for cleanup; there is a need to understand the impact of RCRA tank closure requirements on SLAW volume; the report “should evaluate a full range of disposal site options, both on-site and off-site” and in particular, should consider “the Nevada National Security Site (NNSS) as a potential disposal site for Hanford SLAW”; underscores the noncompliance with the Federal Facility Compliance Act (FFCA) at the IDF such that the FFCA provides that requirements to federal facilities apply “in the same manner, and to the same extent” as requirements applicable to private parties and to “impose on Hanford a requirement that LAW be vitrified or the equivalent, when no such requirement is imposed on private LAW disposal sites, could constitute a violation of the parity requirement of FFCA,” October 31, 2019.

• Shannon Cram, Ph.D., University of Washington, as a member of Hanford’s Advisory Board, “I would like to voice my opposition to putting Hanford’s tank waste in grout. Instead, I would like Hanford’s long-lived radionuclides to be removed from its Supplemental Low-Activity Waste (SLAW) and immobilized in glass. We need to prioritize long-term human and environmental health over short-term cost savings. I am very concerned that the FFRDC is recommending grout for Hanford’s SLAW. Not only is this recommendation myopic, it could set a dangerous precedent for other waste management areas on site,” November 1, 2019.
• Gary Peterson, retired from Hanford, expresses concern that the “as good as glass” concept is not defined in law and that trying to vitrify all the waste in Hanford’s tanks would take too long and cost too much money; mentions the estimated significant cost savings for use of grout and the option for shipping that waste form to WCS in Texas, November 6, 2019.
• Anonymous, “I saw the presentation from the October 31, 2019 meeting regarding the Office of River Protection Glass Science Program. The ORP Glass Program provided the perspective that better glass formulations have the ‘potential to realize nearly the entire soda inventory in the WTP LAW Facility and within an acceptable mission duration.’ I believe this perspective requires the flow sheet and mass balance to be closed around all of the WTP equipment, not just the melters. If

• the process duration is compressed that means the tank waste feed is being treated at a rate much faster than was used as the basis for design of the WTP LAW Off-Gas treatment system, or the tank waste effluents management system. The promise of an easy fix with good glass must be evaluated in terms of the concentrations in the off-gas effluents, and whether the increased off-gas burden creates equipment capacity problems, including at ETF, or equipment corrosion problems, due to higher concentrations of halides, for example. It may be premature to suggest relying on better glass as a basis for deleting secondary LAW treatment. This will be especially true if the DFLAW off-gas and effluents systems do not perform as advertised,” November 6, 2019.

• Carlgh, expresses concern that the FFRDC report seems to confuse terms of high-level, low-activity, and supplemental low-activity waste, and that this apparent confusion appears to contradict the legal definition of HLW as defined by the Atomic Energy Act, as amended, November 7, 2019.
• Leah Boehm Brady, do not reclassify radioactive waste; “keep this poison away from the river”; “protect the Columbia River,” November 7, 2019.
• Carol Davis, has the committee investigated best practices of European countries such as those presented at the 43rd Annual Symposium on the Scientific Basis for Nuclear Waste Management, held October 21-24 in Vienna, Austria, November 18, 2019.