Appendix C

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

PUBLIC MEETING #3: APRIL 26-28, 2022

Presentations from the U.S. Department of Energy’s (DOE’s) Office of River Protection

• Site Cleanup Overview, Brian Vance, Hanford Site Manager
• Site History and Cleanup Progress, Elaine Porcaro, Chief Engineer, DOE Hanford, and Karthik Subramanian, Chief Engineer, Washington River Protection Solutions (WRPS)
• The Tanks and the Groundwater, Elaine Porcaro and Naomi Jaschke, Soil and Groundwater Division Supervisor, DOE Hanford
• Tank Integrity, Karthik Subramanian and Erik Nelson, Tank Integrity Lead, DOE Hanford
• Treatment and System Planning, Todd Wagnon, Flowsheet Integration Manager, WRPS, and Richard Valle, Tank Farms Program Manager, DOE Hanford
• Other Impacts of Treatment Options, Laura Cree, Flowsheet Definition and Analysis Manager, WRPS
• Summary, Ricky Band, Tank Farms Program Division Director, DOE Hanford

Presentations from the Federally Funded Research and Development Center (FFRDC) Team

• FFRDC Team Draft Report Overview, Bill Bates, Deputy Associate Laboratory Director for the Environmental and Legacy Management (ELM) Directorate, Savannah River National Laboratory (SRNL)
• Process and Feed Vector Overview, Michael Stone, Senior Fellow Engineer, SRNL Alternatives Evaluation Team
• Decision Framework Overview, David Tate, Senior Defense Analyst, Institute for Defense Analyses
• On-Site Disposal Description, Stephanie Johansen, Advisor, Energy and Environment Directorate, Pacific Northwest National Laboratory (PNNL)
• Off-Site Disposal and Transportation Description, Elena Kalinina, Principal Member of Technical Staff, Sandia National Laboratories
• Alternative Descriptions, Daniel McCabe, Senior Fellow Scientist, Materials Technology, SRNL
• Uncertainty Drivers in the Alternatives and Updated Information Since 2017-NDAA-3134, Matt Asmussen, Scientist, Principal Investigator, PNNL IDF PA Program
• Alternative Analyses, Daniel McCabe, Senior Fellow Scientist, Materials Technology, SRNL
• LAW Supplemental Treatment Alternatives: Cost and Schedule Methodology and Estimates, William R. Ramsey, Technical Advisor, ELM SRNL
• Assessment Summary and Results, Matt Champagney, Vice President, Engineering and Planning Sector, Parsons
• Wrap-Up and Summary, Bill Bates, Deputy Associate Laboratory Director for the ELM Directorate, SRNL

Stakeholder Presentations

• Perspectives from the Oregon Department of Energy, Jeff Burright
• Perspectives from the Washington Department of Ecology, Jay Decker
• Nuclear Waste Disposal: Actions Needed to Enable DOE Decision That Could Save Tens of Billions of Dollars, Jeffrey Larson, Nathan Anderson, and Amanda Kolling, U.S. Government Accountability Office (GAO)
• Yakama Nation Radioactive Waste Remediation and Natural Resources, McClure Tosch and Laurene Contreras
• Perspectives of Hanford Challenge, Nikolas Peterson and Marco Kaltofen
• Perspectives of the Tri-City Development Council, David Reeploeg

Public Comments

• Gerry Pollard, Executive Director, Heart of America Northwest
• Rob Hastings, unknown affiliation
• Dwayne Schmoker, unknown affiliation
• Richard Grondent, Permafix Environmental Services
• Marek Merciar, Jacobs Slovakia

WRITTEN COMMENTS RECEIVED DURING THE COMMENT PERIOD FROM APRIL 12, 2022, TO JUNE 12, 2022

• Anonymous, submitted 10 comments to the committee. The focus of these comments was on potential off-site and on-site grouting facilities. These comments are available in the Public Access Files for this study.
• Anonymous comment was submitted that discussed the report not adequately addressing the way decisions will affect tribal communities. This comment is available in the Public Access Files for this study.
• Max Kiefer, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health (NIOSH) (retired). Worker health and safety should be a key component of any and all activities regarding decisions about how to immobilize portions of the waste and should be formally incorporated into the planning documents. This includes a robust industrial hygiene exposure assessment program that is involved in the beginning to anticipate issues prior to completing designs and ensuring appropriate controls are implemented. It is critical to develop and implement engineering and administrative controls as a prudent precautionary approach for circumstances such as those found at the Hanford tank farms, where scientific uncertainty about the potential for complex and changing exposures and associated health effects may exist. It is important to use a precautionary and conservative approach to establish, as much as possible, an evidence-based rationale for all worker safety and health issues, including personal protective equipment, appropriate tank farm and other perimeters. The use of respiratory protection for routine work should be considered a temporary control only and not an acceptable permanent solution. Where supplied air is determined to be necessary, utilize airline systems where possible. The need for respiratory protection should be determined by a qualified IH professional and based on objective data where possible. From a Safety Program Management perspective, it is important to focus on establishing and maintaining strong labor–management interaction, communication, transparency, worker inclusion in safety and health decisions, and implementation of recommendations from previous reports, such as the 2014 Hanford Tank Vapor Assessment Report and the 2016 NIOSH report “Review of Hanford Tank Farm Worker Safety and Health Programs” and other reports provided to the NIOSH team with similar recommendations.
• Nikolas Peterson and Marco Kaltofen, Hanford Challenge, submitted a written statement that reiterates Hanford Challenge’s opposition to the use of grout at Hanford in the treatment and disposal

• of nuclear waste. This message is captured in full in the recordings from the National Academies’ April meeting in Richland, Washington.
• Steven Gilbert, Kathy Barker, Susan Crampton, Leah Boehm-Brady, Kelly Norton, Shannon Cram, Patricia Morton, Diane Burke, Cary Lambert, Coral Shaffer, Richard Honour, Robert Richard, Robert Masterson, and Laura Feldman shared the same comment with the National Academies.
  • ANALYZE EFFICIENCY OF VITRIFICATION: Before endorsing a grout plan that may lock us into grouting 56 million gallons of low-activity waste, examine assumptions about how well the Waste Treatment Plant (WTP) will perform in vitrifying tank waste. The WTP may be able to treat more than the predicted 40-50 percent of the low-activity waste, and supplemental low-activity waste may not be needed at all. Instead of hastily rushing into a decision to grout tank waste now and regretting it later, let’s wait and see how vitrification goes.
  • COMMUNICATE UNCERTAINTY: Require more research and development to ensure that the grouted waste form has the scientific rigor that a decision of this magnitude requires. Question conclusions that claim grouting Hanford tank waste will be easy, but only reference the Test Bed Initiative’s 3-gallon test of tank waste and compare Hanford’s tank waste characteristics to Savannah River’s tank waste.
  • BE SKEPTICAL OF THE “GROUT IS CHEAPER” SALES PITCH: Choose the option that is the most protective of the environment and future generations, not the option that places cost savings above all else.
  • DON’T SEND WASTE TO PERMA-FIX NW: Perma-Fix NW has a recent history of serious worker overexposures, two unreported fires, and a lack of coordinated agency oversight. Do not send 56 million gallons of tank waste to Perma-Fix NW. Doing so may put nearby communities, workers, and the environment at risk.
  • THE STATE OF WA IS NOT THE ENEMY: Question FFRDC and USDOE messaging that casts the State of WA as the enemy and a roadblock to proceeding with grout. The State of WA demands that the final treatment option be “as good as glass” because that is the most protective form for the waste. If the State believes grout isn’t “as good as glass,” then we should stick with glass.
  • CONSULT TRIBES AND ENSURE COMPLIANCE WITH THE TREATY OF 1855: Ensure consultation with the Confederated Tribes and Bands of the Yakama Nation, the Nez Perce, and the Confederated Tribes of the Umatilla Indian Reservation as equal parties in this review process. Recognize how treaty rights impact each alternative and ensure that the alternative chosen is in compliance with the Treaty of 1855.
  • ANALYZE SYSTEMIC BARRIERS TO SUCCESS: Analyze barriers that may continue to prevent USDOE from completing projects on time and on budget, before recommending a path forward with Hanford’s supplemental waste that could be thrown off course by mismanagement, lack of transparency, lack of accountability, and a broken safety culture. Ensure assumptions are complicated by tank waste treatment history.
  • NO GROUTED “ORPHANED” WASTE AT HANFORD: The report makes assumptions about the reliability of grout, the willingness of off-site disposal facilities to accept the grouted waste, and the openness of the residents in those states to receive grouted waste from Hanford. Ensure these assumptions account for the possibility of off-site disposal failing before making a final decision. We do not want grouted waste to be “orphaned” at Hanford because of overstated assumptions about the willingness of off-site facilities to take Hanford’s waste.
  • INCLUDE A FINAL PUBLIC COMMENT PERIOD: Congress does not require a public comment period when the final report from the FFRDC is issued in the fall. However, adding a public comment period after the final report is released would demonstrate increased transparency and openness to engage the public. We appreciate that you have intentionally given the tribes, stakeholders, the State, and general public the space to comment and influence the outcome before the final SLAW treatment recommendations are formed.

• Tracy Barker provided the following comment and recommendation. Elements of this report have been publicly available for a number of years. During this time frame stakeholders have expressed concerns associated with the use of grout. The current report mentions some of these concerns, and more (new) concerns will likely be expressed during the current comment period.
  • RECOMMENDATION: Set aside a section of the report to list prevailing concerns and then provide a clearly worded response that either resolves the concern, or that lists out recommended steps for getting the information needed to resolve the concern.
  • ECY CONCERN (Volume I, pp. 16 and 21): Containerized grout waste could be rejected by off-site disposal sites and then returned to be “orphaned” at Hanford. It seems the FFRDC team could describe the “process” that waste generators and treatment facilities go through to ensure that orphan waste is not created. For example, list the prerequisites, approvals, and related steps that both off-site and on-site grouting contractors go through to get: (1) their waste treatment program qualified for using the intended disposal site, (2) waste characterized, (3) waste tested with the intended grout formulation, and (4) packaged waste preapproved for disposal.

    For even further assurance related to on-site treatment and off-site disposal alternatives, Hanford could establish a contract with the disposal site(s) to have trained packaging and shipment technicians come on-site at Hanford during the initial months of operation to oversee and approve the waste for shipment and disposal. Once stakeholders understand the thorough “process,” then they would likely agree that the chance of waste being orphaned at Hanford is negligible. Other regulatory and stakeholder concerns could be listed and responded to in a similar manner.

• Jeff Wyatt, Oregon Hanford Cleanup Board (OHCB), comments:

  The OHCB provides policy advice on Hanford cleanup issues to the Governor and Legislature of Oregon, and to the state’s lead agency on Hanford cleanup, the Oregon Department of Energy. We are writing to endorse recent comments sent to you by the Oregon Department of Energy on the Phase 2 Study of Supplemental Low Activity Waste Options for Hanford.

  During our May 2 Board meeting, we received a briefing on the study and the latest work by the Federally Funded Research and Development Center from staff at the Oregon Department of Energy. Based on the presentation and our discussion that followed, the Board agrees with the positions taken by and advocated by the Oregon Department of Energy, which specifically include:

  • Once the long-term remedy for low activity waste (LAW) treatment and disposal has been selected, DOE and EPA can refocus on the disposal of high-level waste (HLW) in a geologic repository. Most members of the OHCB would like to see renewed urgency in addressing Hanford’s HLW.
  • Both grouting and vitrification appear to be technically viable options for supplemental LAW treatment. Fluidized bed steam reforming should be eliminated from further consideration due to its high technical and schedule risk.
  • The age and deteriorating condition of both the single- and double-shell tanks favor an alternative with a shorter implementation schedule.
  • Assuming the technical and regulatory issues the report and the Oregon Department of Energy (ODOE) staff highlighted are addressed, cost and schedule favor off-site grouting and disposal in currently approved disposal facilities.
  • Neither DOE nor the FFRDC have yet made a compelling argument that retaining the option of on-site grout disposal has strong merit as an acceptable future alternative. Additional work is needed to support this future alternative.
  • In his presentation to the OHCB, ODOE [Oregon Department of Energy] staff member Jeff Burright made a convincing case that shipments of liquid LAW may pose less of a risk to the public than a higher number of solid grouted shipments. Existing standards for the

• • transportation of highly flammable and toxic liquids (e.g., gasoline, light fracked crude oil, LNG, solvents) by rail and truck are highly effective in protecting human health and the environment. Incidents where there is a release to the environment are very rare. Shipments of liquid LAW must have even higher standards combined with robust monitoring and emergency response capability—much of which is already in place for shipments of radioactive materials.

  We encourage you to consider the points made by the ODOE staff to better ensure long-term protection of the Hanford Site and the Columbia River.

• Maxwell Woods, Assistant Director for Nuclear Safety and Emergency Preparedness, Oregon Department of Energy, provided the following comment.

  Oregon appreciates this opportunity to comment once again on the National Academies’ ongoing study of options for Supplemental Treatment of Low-Activity Waste (LAW) at the Hanford Nuclear Reservation. The State of Oregon retains a long-term interest in the safety and value of the Columbia River, which stands to be directly affected by the final end-state of Hanford wastes disposed on-site. Oregon is also invested in the safe transportation of radioactive materials through our state.

  Oregon has been involved in the National Academies’ study of Supplemental LAW options since its beginning [1], and the question of greatest concern to us continues to be whether Hanford LAW may be safely disposed as a grouted waste form on-site. Our technical reviews have highlighted the uncertainties that still must be resolved before we perceive the state of the science to support an on-site grout alternative. Our comments during the first study focused predominantly on the potential risk from long-lived key radionuclides that would be present in a grouted Supplemental LAW waste form [2].

  In this second study, Oregon has again kept its focus trained on those potential risks that would remain on-site under each alternative. We have been active participants during the three public National Academies’ committee meetings to date, providing both technical observations and Oregon’s policy perspective as the study developed [3, 4, 5, 6, 7]. Please consider these prior presentations as part of Oregon’s formal comment on the federally funded research and development center (FFRDC) report, to inform the Committee’s review.

  We continue to stand behind the technical observations we made during the prior study, and we did not find that this latest FFRDC report adds compelling new evidence to support the claims of long-term grout performance beyond what was presented during the first study. In addition, we have grown increasingly focused on the potential hazards associated with nonradiological constituents in the LAW—nitrate and nitrite in particular—which have presented technical challenges to an on-site grout alternative since the early days of the tank waste treatment mission and which ultimately caused DOE to turn away from grouted waste forms in the early 1990s [8].

  However, the most recent FFRDC report that is the subject of this letter has put forward a potentially acceptable alternative strategy to manage the effects of these uncertainties and reduce the final risk inventory of the Central Plateau while the science of grout performance continues. We do not arrive at this conclusion lightly, or without reservation as described in our technical comments below.

  As was stated in the remarks from Department staff at the April 28, 2022, National Academies’ meeting, we are nearly convinced by the FFRDC’s latest report that the Hanford tank waste mission would be overall best served by incorporating an off-site grout pathway for a portion of the low-activity tank waste. We see value in reducing the overall risk budget burden for the Hanford Central Plateau—most notably from the key radionuclides Tc-99 and I-129 and the hazardous chemicals nitrate and nitrite—while continuing to improve and verify the recent advancements in grout performance. Furthermore, any reduction in the total inventory of risk-significant constituents disposed on the Hanford Central Plateau serves to reduce the consequences of those on-site grout

• performance uncertainties that remain. We also appreciate the operational efficiencies gained by early creation of double-shell tank space, which will allow more rapid single-shell tank retrievals and faster completion of both the LAW and HLW vitrification activities.

  From a precautionary standpoint, Oregon would prefer that if off-site grout disposal is pursued via the Grout 4B option, that off-site disposal would continue throughout the mission, rather than eventually transform into the hybrid Grout 6 alternative that conceives of large grout volumes disposed on-site. This preference is supported by a desire to reduce the cumulative risk burden of the Hanford Central Plateau to the maximum extent possible, given that the results of sitewide cumulative risk assessments are still pending at this time. This risks making a decision for on-site grouted waste for investment purposes before the necessary grout performance studies have reached a satisfactory conclusion. We also acknowledge the long-held expectation of the Yakama Nation, as reiterated at the April 2022 National Academies’ meeting, that the Hanford tank waste would be vitrified if disposed of on-site.

  Despite this preference, Oregon is not beyond convincing that a hybrid grout alternative presents an overall lower risk when considering the lesser off-site transportation miles and the increased operational certitude provided by a third disposal option in addition to the two off-site facilities. The FFRDC has the opportunity to refine their comparison of risk and other intangible factors between these two alternatives in their final report.

  In the cost- and time-constrained environment we face at Hanford, the two grout alternatives presented in the FFRDC analysis may actually achieve the management trifecta of making the tank waste mission faster, cheaper, and better for the region. Once the long-term remedy for low-activity waste treatment and disposal has been selected, DOE can refocus on finalizing and communicating how the treatment and disposal of high-level waste (HLW) will proceed. Oregon would like to see renewed urgency in addressing Hanford’s HLW, including the highly radioactive radionuclides extracted from the LAW using the TSCR system. To the extent that a grouted SLAW alternative can improve our capabilities to address these larger needs and prevent the release of more tank waste to the environment, Oregon is willing to support the effort.

  1. https://energyinfo.oregon.gov/blog/2018/03/07/odoes-ken-niles-weighs-in-on-hanford-waste-treatment-we-must-remain-vigilant-informed-and-involved
  2. https://www.oregon.gov/energy/safety-resiliency/Documents/NAS-Supplemental-LAW-study-Aug-2019.pdf
  3. https://www.oregon.gov/energy/safety-resiliency/Documents/2021-07-15-NAS-ODOE-Remarks.pdf
  4. https://www.oregon.gov/energy/safety-resiliency/Documents/2021-07-15-NAS-PPT.pdf
  5. https://www.nationalacademies.org/event/10-20-2021/review-of-the-continued-analysis-of-supplemental-treatment-of-low-activity-waste-at-the-hanford-nuclear-reservation-meeting-3-open-session
  6. https://www.nationalacademies.org/event/04-26-2022/docs/D1D5485813E0F259131C047AF33BD475AAE5A4C8CB3D
  7. https://www.nuclearenergytv.com/Events/NAS-220426/VideoId/1952/840am-oregon-department-of-energy
  8. Hanford Challenge, 2021. “Why Grout Failed at Hanford: Chronology of the Failed Grout Program.” Page 16 discusses nitrate and nitrite technical challenges from a 1998 options analysis that recommended calcination to destroy nitrate. https://static1.squarespace.com/static/568adf4125981deb769d96b2/t/60f9b2bdb9480b7aeb6cbe15/1626976958173/2021+06.15+Why+Grout+Failed+at+Hanford.pdf
• Rob Hastings submitted 10 comments captured here in the order the comments were received.
  • CONSIDER A DEMONSTRATION OR PROTOTYPE GROUT TREATMENT SYSTEM:
    Ref.: Vol 1, B.2.3.1—Supplemental Low-Activity Waste Feed Vector

• • The report recommends: (1) Off-site grouting and off-site disposal immediately, and then (2) On-site grouting with off-site or on-site disposal beginning in 2034 with full-scale system(s) capable of treating up to 360,000 gal/month under the DFLAW scenario. Alternatively, application of a demonstration or prototype system has proven benefits. Both Hanford and Savannah River have had success with demonstration or prototype systems for treating tank waste.

    • Hanford’s modular Tank Side Cesium Removal (TSCR) system is approximately one-half the scale of the Tank Farms Pretreatment (TFPT) System—5 gpm versus 10 gpm, respectively. TSCR is a two phased demonstration project. The first phase will monitor system performance and demonstrate the ability to safely operate and provide treated liquid waste in support of WTP hot commissioning and early operations. The second phase will demonstrate the ability to treat tank waste reliably and efficiently for an extended operating period.
    • Similarly, at Savannah River the Actinide Removal Process (ARP) and Modular Caustic Side Solvent Extraction Unit (MCU) were part of the Interim Salt Disposition Project (ISDP) that demonstrated technologies liquid waste treatment technologies. The ARP and MCU were installed in existing facilities (512-S and 241-96H, respectively) for treating liquid tank wastes.

    These demonstrations systems—installed in modular or existing facilities—allowed Hanford and Savannah River to “get the ball rolling,” gain valuable experience, and advance the mission at reduced costs as compared to full-scale systems that would be installed into a new facility.

    RECOMMENDATION #1: Evaluate an alternative (possibly an alternative similar to 2B or 3B) for a near-term demonstration system for grouting treated waste on-site at Hanford, and then transporting the grouted waste to an off-site disposal facility.

    Like TSCR, the near-term demonstration system could be specified and bounded in a manner that facilitates fast deployment at reduced capital costs. For example, the need for an evaporator or other technology for organic removal could be eliminated by restricting the feed to liquid waste with LDR-compliant organic concentrations. Similar decisions could be made to reduce costs such as:

    • Eliminate need for waste receiving facility by placing TSCR and grouting systems near a DST (like SY-101).
    • Eliminate need to empty or clean out multiple DSTs by using a single DST (e.g., SY-101) for feeding as well as for receiving drains and vented fluids from TSCR.
    • Eliminate need for a rail spur by initially using trucks for transporting grouted waste off-site.

    The demonstration system would allow DOE, on-site contractors, regulators, and public stakeholders to become familiar with all facets of grouting, such as on-site operations, off-site transportation, and disposal. Data collected from the demonstration system would inform and likely improve operational techniques and technologies to accomplish treatment of the full monthly liquid waste volume.

    A single TSCR system can treat well over 1.5 Mgal/yr of liquid tank waste. This volume is likely greater than needed for a “demonstration grouting system.”

    RECOMMENDATION #2: Use a single TSCR system to create treated liquid for an on-site “demonstration grouting system” as well as for off-site disposal.

    This alternative would allow Hanford to simultaneously demonstrate a treatment scenario very similar to that described for grout alternative 4B.

    Typo on Vol. 1, Table 1.3-3 Ref.: Vol 1, Table 1.3-3 The table lists 12 tanks in SX Farm. There are actually 15 tanks.

• • GROUT PACKAGE CONFIGURATION AND METRICS:

    Ref.: Vol 1, § 3.3.3, “Grout #4B”; § D.3.3, “Off-Site Transportation”

    Ref.: Vol 2, § C.8, “GROUT 1A”

    The reports consistently describe the use of an 8.4 m³ polypropylene bag for packaging the grout, but the description of the structural frame/forms and/or container surrounding the bag varies from section to section. In one place the frame is disassembled and in another location the split-box is lifted from the grout bag.

    CLARIFICATION/COMMENT:

    1. Provide a consistent description of the steel appurtenance that will surround or encase the grout bag.
    2. Please verify that it will be feasible to have a package weight of 15 metric tons. The 15-metric-ton bag (33,000 lbs) is twice the weight of an ILAW canister.
    3. If a box or container is used, then please confirm that the walls of the box/container can be removed to release the grout bag for removal by the disposal site.

       The frame/box/container is described to support the polypropylene bag during grout filling. In this scenario there would be a significant amount of force between the bag and the wall of the support.

    4. Is area between the grout bag and the support frame or container going to be surveyed for smearable contamination. The reports describe the grout bags as being “closed and the exterior decontaminated.” It appears that the inaccessible area between the bag and the frame/container would be difficult to survey.
    5. In the case of shipment of grouted waste for off-site disposal, are the disassembled grout bag support frames going to be returned as a radioactive materials shipment?
    6. Similarly, if a box or container is used, then is it going to be shipped back under the DOT radioactive EMPTY regulations? (49 CFR § 173.428)
    7. Please confirm that the costs accurately reflect that the fact that returned railcar gondolas or trucks won’t be empty but loaded with empty frames or containers. The weight will be substantially less, but the volume could be approximately the same—to and from the disposal site.
    8. Please describe how the grout bag will be stored. More specifically, confirm that provisions have been taken to minimize UV degradation of polypropylene. The report describes that grout bags will not be shipped until after a 28-day cure time. Polypropylene is susceptible to sunlight/UV degradation; therefore, the curing conditions should be such that the bag has sufficient strength to lift the 15 mt (33,000 lbs) grout block.
  • WASTE FEED PREPARATION: DOE and its contractors currently have teams of people working on integration and waste feed delivery. In 200 East, these teams are currently mixing together waste from differing tanks in the AP Farm (≈AP-105) in order to create a liquid waste stream that meets the DFLAW (TSCR/LAW-Vit) interface and waste acceptance criteria.

    RECOMMENDATION: Have these integration and waste feed teams add waste class (10 CFR Part 61) parameters to their model so that all the grouted waste is Class A. It is ≈ 5.5× more expensive to dispose of Class B/C waste at commercial disposal sites; thus making all waste Class A could yield substantial savings.

  • CONFIRM THE VALIDITY AND POLITICAL FEASIBILITY OF LIQUID SHIPMENT
    Ref.: Vol. 2, Figure H-8 and Presentation by Elena Kalinina (SNL)

    The above-referenced figure and presentation portray the transportation of hundreds of tankers per year (≈2 Mgal/yr) of radioactive liquid as common, and that there is only a transportation moderate risk (#4B). The 16,000 gallons per month of liquid waste

• • from Vermont Yankee as mentioned in Section L.4.1 is likely one of the largest volumes of liquid radioactive waste to be shipped.

    RECOMMENDATIONS:

    • Review the integrity of your sources. The photograph from the “Offsite Disposal and Transportation” presentation states “Tankers with Radioactive Liquid Arriving at Clive” with a photo of hundreds of liquid tanks on railcars with an Energy Solutions name on the containers. If you look closely at the photo, you will see grass and trees. Grass and trees do not exist at the Clive, UT disposal site. Furthermore, this same photograph is readily available on the Internet with multiple company names on the side of the containers (e.g., AsepTrans, Odyssey, and EnergySolutions)—who’s photoshopping who? It makes reviewers question the validity of information.
    • Verify that disposal sites in Clive and Andrews have actually received trains with the depicted intermodal or tankers, railcar tankers and/or tanker trucks.
    • Transporting this volume of liquid is going to be a true paradigm/philosophical shift and the FFRDC should discuss this fact with regulatory stakeholders in Washington and Oregon to confirm that it is feasible from a political perspective.
  • TANKSIDE CESIUM REMOVAL SYSTEM ALSO REMOVES Sr-90: The FFRDC used a decontamination factor (DF) of 1,000 for Cs-137 for the Tank Side Cesium Removal (TSCR) system with its crystalline silicotitanate (CST) ion exchange resin. However, it does not appear the FFRDC used the current DF for Sr-90 which is also 1,000. The FFRDC should use an accurate DF for Sr-90. In doing so, it should reduce the amount of grouted waste that exceeds Class A disposal limits, thus reducing the disposal cost estimates for off-site disposal.
  • RAIL TRANSPORTATION COST ESTIMATES: Volume II, Appendix H, Section H.8: The rail transportation cost estimates to EnergySolutions in Utah and WCS in Texas should be updated with better estimates. The transportation costs will still only be a small fraction of the overall SLAW grout mission, but better estimates could be obtained without significant effort.
  • RAIL TRANSPORTATION ACCIDENT RATES: Volume II, Appendix H, Section H.9 through 11: The fatality rate for rail transport along with the assumptions used should be validated. The fatality rate of 1E-06 per mile for rail transport was used with a resultant fatality rate of 0.06 fatalities per year. Using data from: (1) U.S. Department of Transportation, Federal Motor Carrier Safety Administration, “2021 Pocket Guide to Large Truck and Bus Statistics,” and (2) U.S. Department of Transportation, Federal Motor Carrier Safety Administration Analysis Division, “Large Truck and Bus Crash Facts 2019, FMCSA-RRA-20-055, October 2021, results in a fatality rate of 1.7E-8 per mile traveled for large trucks. Comparing these fatality rates, trucks versus rail, results in a rail transport fatality rate 58 times higher than truck transport which seems intuitively incorrect. A point to consider is the rail fatality rate for freight rail transport is 30 percent lower that the total rail transport. Consideration should also be given to reducing the rail fatalities to only those at rail crossings which was an average of 165 per year, using the same reference and data range as the FFRDC used.
  • USING GROUT TREATMENT TO INCREASE DFLAW EFFICIENCY: The FFRDC should evaluate grouting all of the Effluent Management Facility (EMF) concentrate rather than recycling it back into the LAW Vitrification facility feed tank to be vitrified again. The only reason for feeding this secondary waste stream back into the melter is to try and increase the concentration of Tc-99 in the glass. However, this concentrate stream is also high in halides and sulfates which is damaging to the melter. The volume of the concentrate stream is estimated to be between 10 percent and 17 percent of the waste fed from AP-106.

• • By taking this action, 10 percent to 17 percent more waste could be treated by TSCR and vitrified in the LAW facility, the expected life of the melters could be increased beyond 5 years, and the concentrate stream would not be reintroduced into the AP Tank Farm. Since this action would be tied to LAW Vit operations, grouting should be accomplished on-site in order to maximize operational control. Small, low-cost grouting options can be used to treat this relatively small volume. The grouted EMF concentrate should only be disposed off-site in either the Utah or Texas commercial disposal facilities. According to Ecology this is secondary waste from the vitrification treatment process and does not have to be re-vitrified.

    Performing this action would also provide a valuable opportunity to gain experience grouting a routine waste stream on-site with disposal off-site. This process could help jump-start a parallel pathway for treating waste along with DFLAW vitrification.

  • REGULATORY COMMENTS AND RECOMMENDATIONS: In Volume I, Section 2.0, the FFRDC did an excellent job of describing the regulatory framework and current impasse between Ecology and DOE. Ecology’s view is that all of the tank waste is currently HLW and that DOE’s authority under the AEA to declare a waste as non-HLW only serves the purpose of allowing land disposal of vitrified LAW (i.e., MLLW). Ecology also considers their declaration of tank waste being HLW is separate and distinct from DOE’s authority under the AEA to make waste determinations. Interestingly, on Ecology’s website they use the HLW definition from 33 USC, Chapter 27, Ocean Dumping, Section 1402(j) which is for Ocean Dumping. A more appropriate reference is 42 USC, Chapter 108, Nuclear Waste Policy, Section 10101, Definitions, (12) which mirrors the definition in DOE M 435.1-1.

    Due to Ecology’s belief that all tank waste is HLW requiring HLVIT, Ecology would still effectively block off-site shipments of TSCR-treated waste by requiring HLVIT treatment by the receiving treatment and disposal facility. While a treatability variance is theoretically possible, it is highly unlikely that either Utah or Texas would want to grant an HLVIT treatment variance from a political perspective.

    In addition, with Ecology’s view that HLVIT is required, they consider TSCR treatment of tank waste as only a pretreatment step in the HLVIT process versus DOE’s treatment process to generate a liquid MLLW stream from tank waste. By considering TSCR as only a pretreatment step to HLVIT, DOE may be hard-pressed to take advantage of the new point of generation principle and the corresponding change in the characteristic waste class from a non-wastewater to a wastewater (<1 percent TSS and <1 percent TOC). This provides additional clarity since the RCRA LDR treatment standards clearly indicate that HLVIT is not applicable to wastewater.

    The FFRDC should consider providing recommendations on how to resolve the multiyear stalemate caused by Ecology. It has severely impacted the Test Bed Initiative, hampered consideration of alternatives to vitrification for Supplemental LAW treatment, and may cause tens of billions of dollars to be wasted along with decades of delayed cleanup at Hanford.

    One such possible solution could be for Congress to address this issue in legislation or within the next issuance of the NDAA. A single sentence could be all that is needed: “The RCRA Land Disposal Restriction High-Level Waste Vitrification (HLVIT) treatment standard does not apply to waste determined by the U.S. Department of Energy to not be High-Level Waste pursuant to their authority under Atomic Energy Act of 1954, as Amended.”

  • MODULAR APPROACH TO TREATMENT: The FFRDC should consider relatively small (low capital cost) on-site grout capabilities in both the 200 East and 200 West Areas. Many of Hanford’s Tank Farms are in remote areas and are no longer served by transfer lines. Even the supernate transfer line between the East and West areas has been shut down

• • for over 15 years and needs repair and upgrades. Having smaller on-site tank waste treatment and grout capabilities allows DOE to bring the treatment system to the waste, and not the waste to the treatment system, minimizing Hanford infrastructure costs. The TSCR project serves as an excellent example of this concept and was completed on schedule and well under its initial baselined budget.