Final Review of the Study on Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation Review #4 (2020) / Chapter Skim
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Appendix A: Major Parts of Review of the Final Draft Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3
Appendix A: Major Parts of Review of the Final Draft Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #3
Pages 34-86
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From page 34... ...
35 1 CONTEXT AND SETTING ................................................................................................................... 43 Proposed Treatment Plan and Congressional Mandate to Analyze and Review the Analysis of Supplemental Treatment Approaches, 43 Study Process, 45 Brief Historical Context of Tank Waste Treatment Approaches, 47 Review Report Organization, 49 2 THE COMMITTEE'S TECHNICAL REVIEW OF THE FFRDC'S FINAL DRAFT ANALYSIS ................................................................................................................................
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From page 35... ...
treatment facility because it is the current expectation of many stakeholders and a similar facility (the WTP) is currently under 1 According to DOE's Radioactive Waste Manual, low-activity 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.
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From page 36... ...
Because these sites have "waste acceptance criteria," additional pre-treatment processing is sometimes required so that the final waste forms can be accepted for disposal. Additionally, the primary treatment and pre-treatment processes produce "secondary wastes" that also need to be disposed of in a near-surface disposal site.
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From page 37... ...
Does not yet clearly lay out a framework of decisions to be made among treatment technologies, waste forms, and disposal locations; but c. Can form the basis for further work as described below in the committee's findings and recommendations.
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From page 38... ...
data and analysis prepared by the FFRDC. Therefore, it was impossible for the committee to critically review the differences in the performance of the three waste forms and their associated disposal systems over time.
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From page 39... ...
Finding 5-2 The committee was repeatedly told that the selection and implementation of an approach to treat tank waste would be hampered by the insistence by the State of Washington and some other stakeholders that any approach other than vitrification must be "as good as glass." The term "as good as glass" is not defined in law, regulation, or agreement, and it is only tentatively defined by its advocates. The analysis in, and the public presentations of, the draft FFRDC reports offer a follow-on opportunity for DOE to engage with its regulators and stakeholders to identify performance standards based on existing regulatory requirements for waste form disposal and to pursue a holistic approach to selecting a treatment technology.
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From page 40... ...
and uncertainties therein? • The waste forms and associated disposal sites: o How effective is each waste form in immobilizing the waste (e.g., the materials science of the incorporation, corrosion, and release processes)
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From page 41... ...
• How might the disposal facility design be modified to enhance the performance of each waste form? Important site-related issues include regulatory compliance, public acceptance, cost, safety, expected radiation dose to the maximally exposed individual over time, and differences among the disposal environments.
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From page 42... ...
Faster startup to reduce risks from tank leaks or structural failures if adequate funding is available to support parallel approaches; b. Resilience through redundancy (like the parallel uranium enrichment and plutonium separation methods during the Manhattan Project)
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From page 43... ...
, which is already under construction at Hanford. To treat these two waste streams, the current plan is to use vitrification, that is, immobilization in glass waste forms, for all of the HLW stream and for at least one-third and perhaps all of the direct (primary)
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From page 44... ...
3134, the treatment approaches considered should at a minimum include: 1. Vitrification, to produce glass waste forms either using Joule-heated melters, which are to be used in the WTP, or bulk vitrification; 2.
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From page 45... ...
(GAO, 2017) In its report, GAO noted that "DOE agreed with both recommendations." STUDY PROCESS In this third review report, the committee provides its peer review and discusses its observations of the FFRDC's final draft report, dated April 5, 2019, 2 and the FFRDC's presentations at the public meeting in Kennewick, Washington, on May 16, 2019.
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From page 46... ...
The FFRDC received the committee's review to take into account during its work on its final draft report. November 29-30, 2018 Public meeting #4 in Richland, Washington, that presented the second review report and the FFRDC's progress toward its final draft report, as well as heard from stakeholders.
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From page 47... ...
October 31, 2019 Final public meeting of the committee in Richland, Washington, and the cutoff date for receipt of stakeholders' and public comments. January 2020 Anticipated publication of the committee's fourth and final review report that will consider stakeholders' and public comments on the third committee review report and the FFRDC final draft report.
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From page 48... ...
. Here, pre-treatment refers to separation of the tank waste into high-activity and LAW portions prior to the treatment stage that would produce the waste forms for each portion.
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From page 49... ...
For example, on November 14, 2001, Assistant Secretary for Environmental Management Jessie Roberson sent a memorandum to the Director of the Office of Management, Budget, and Evaluation at DOE that outlined a plan that would not vitrify about 75 percent of the LAW, and would develop two alternative technologies that could include grout and FBSR waste forms (Roberson, 2001)
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From page 50... ...
Final Review of the Study on Supplemental Treatment Approaches of LAW at Hanford: Review #4 chapter and are intended to focus on potential improvements in any follow-on efforts. In Chapter 3, the committee poses questions that a decision-maker might ask when making a decision on the preferred alternative for the SLAW treatment and then addresses how the FFRDC's final draft report does or does not provide an adequate technical basis for the decision-maker to choose among the alternatives considered.
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From page 51... ...
2 The committee's technical review follows the topical elements -- specified in the major section headings -- in study charges one through four in the Statement of Task. TABLE 2-1 List of the Chapters and Appendixes in the FFRDC Final Draft Report, "Report of Analysis of Approaches to Supplemental Treatment of Low-Activity Waste at the Hanford Nuclear Reservation," Dated April 5, 2019 Chapter No.
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From page 52... ...
Even so, a reader easily could miss the pressing concerns about the waste tanks, the potential for future failures, and the hazards of the tank waste to current and future generations. Notably, extending tank cleanup schedules -- whether it be the result of seeking better technologies, funding limitations, or technology or project management inadequacies -- increases the chance that additional tanks will fail and release radionuclides and hazardous chemicals into the air or subsurface environment.
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From page 53... ...
The consequence metrics on which the study primarily focused were the incremental cost and the required extension in duration of the tank waste treatment mission associated with each scenario. Fol lowing the analysis of the risks associated with the individual SLAW cases, the team performed a side-by-side comparison among the alternatives.
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From page 54... ...
24) , the FFRDC mentions the assessed benefits or advantages of each approach to treating Hanford SLAW, including waste form volume of both primary and secondary wastes, 4 The chart in the FFRDC report uses the term "expectation values," which is a term more common to physics than to risk analysis, and itself lends to the overall opacity of the discussion.
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From page 55... ...
it can efficiently destroy hazardous organics, nitrates and nitrous oxides, and ammonium compounds; (c) recent waste form durability tests indicate that this process can produce a durable waste form that would not increase waste volume during treatment and would not have liquid secondary wastes; and (d)
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From page 56... ...
A cost-benefit optimum occurs when the marginal cost of "doing more" is equal to or greater than the marginal benefit gained by that increment in cost. Such an analysis is particularly appropriate when selecting among SLAW treatment alternatives that represent a discrete part of a larger system that is mostly well established (e.g., Hanford tank cleanup)
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From page 57... ...
Funding Risks On pp. 24-25, the report provides information about annual funding requirements to complete the Hanford tank waste treatment mission beginning with current funding levels.
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However, on p. 24, the report points out "project funding has often been ‘capped,' i.e., annual funding limited, independent of the project estimate." If this continues to be the case, SLAW technology development, facility design, and facility construction would compete for priority and funding with other large capital expenditures at Hanford including Direct Feed Low-Activity Waste treatment, WTP's major construction projects, tank waste retrieval, and other operations involving the tanks.
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From page 59... ...
This highlights the fact that the identified approaches -- vitrification, grouting, and steam reforming -- are part of a larger system that provides the LAW feed and considers multiple potential disposal locations. In addition to the LAW feed from other parts of the tank waste remediation system, the SLAW facility will produce and have to manage its own secondary wastes and may include pre-treatment to make the SLAW more suitable for treatment or disposal.
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From page 60... ...
The particles can be mixed with additives to produce a monolithic solid waste form. This process also generates secondary wastes that the FFRDC assumed would be grouted.
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From page 61... ...
During the information-gathering meeting on May 16, 2019, slide #37 presented by the FFRDC team concluded: • Treatment for LDR organics may be required for some of the waste for both on-site and out-of state disposal. • Technetium and iodine removal is not needed for out-of-state disposal of grouted or steam reformed waste forms.
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From page 62... ...
These secondary waste streams may be handled by direct disposal (which was assumed in the analysis) or by further processing for incorporation into waste forms designed for iodine.
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From page 63... ...
and liquid wastes produced during primary processing which are then assumed to be grouted. In particular, high-temperature processes volatize iodine and a small fraction of it is present in the grouted secondary waste forms.
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From page 64... ...
The FFRDC team also conducted a PE of vitrified SLAW and secondary waste disposal using its own waste form models and assumptions. As discussed on p.
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From page 65... ...
This information was used by the FFRDC to inform their cost estimates for the grout alternative. Because of the similarities in some of the wastes, the committee believes that there are lessons to be learned from the activities at other sites that are not reflected in the FFRDC report, not only regarding the design and operation of these similar facilities, but also regarding the performance of the grout waste form, which has been widely used to immobilize radioactive and chemically hazardous wastes.
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From page 66... ...
Options for the treatment of the secondary waste streams also need to be described and evaluated. • A comparison of material properties of the three waste forms.
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From page 67... ...
Other parameters, such as the time to reach the peak radiation dose rate and the time for dose rates to diminish, may be relevant to the decision-maker's consideration of the three technologies and their waste forms. The committee acknowledges that the FFRDC has made a valiant effort to compile and compare data on the different waste forms.
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From page 68... ...
At the most recent public meeting on May 16, 2019, Suzanne Dahl, section manager of tank waste for the Department of Ecology, described the FFRDC's final draft report as a "feasibility study" and as a "potential first stepping stone to changing SLAW treatment." She also noted several new pieces of information in the report, including the "cost of nearly complete LAW vitrification plant," (sic) "WCS as new candidate waste disposal site," "new high performance grout waste form performance data," and "new FBSR [fluidized bed 68
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From page 69... ...
When taken alone, does not yet provide a complete technical basis needed to support a final deci sion on a treatment approach; b. Does not yet clearly lay out a framework of decisions to be made among treatment technologies, waste forms, and disposal locations; but c.
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From page 70... ...
Therefore, it was impossible for the committee to critically review the differences in the performances of the three waste forms and their associated disposal systems over time. Additionally, the technical bases for waste degradation models and mechanisms used in the PE analyses for the IDF by the FFRDC team are not well documented and justified.
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From page 71... ...
The analysis in and the public presentations of the draft FFRDC reports offer a follow-on opportunity for DOE to engage with its regulators and stakeholders to identify performance standards based on existing regulatory requirements for waste form disposal and to pursue a holistic approach to selecting a treatment technology. Comparisons Finding 6-1 Over multiple iterations, the FFRDC report has increasingly enabled side-by-side comparisons among the SLAW treatment approaches, exemplified by the table of alternatives and criteria.
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From page 72... ...
includes treatment approaches to the SLAW plus the directly related ancillary processes such as pre-treatment and secondary waste management. Neither the FFRDC nor the committee was tasked to offer views on broader policy issues or on the overall system for managing tank waste at Hanford.
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From page 73... ...
DOE has made the further decision to construct the multi-billion-dollar facilities on the basis of separating high-activity waste and LAW streams, and the particular flowchart on which these facilities are based requires the separate treatment of the SLAW. The decision to adopt an approach that not only divides tank waste into high-activity wastes and LAWs, but also requires separate treatment of the SLAW, is the starting point of the FFRDC team and thus of the committee.
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From page 74... ...
In particular, the committee believes it will not be clear to the reader when and what type of pre-treatment is required or desirable for the various waste form-disposal destination combinations. • The two high-temperature technologies (vitrification and steam reforming)
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From page 75... ...
In particular, each alternative treatment technology requires pre-treatment of the feed stream and management of secondary wastes to varying degrees. The maturing of the necessary pre-treatment technologies does not seem to have been taken into account in the FFRDC's assess ment.
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How Will Each Waste Form Perform Over Time in the Expected Disposal Environments? The FFRDC team identified two disposal options, and suggested the possibility of a third option at the facility near Clive, Utah.
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, and "all three primary waste forms can meet applicable DOE requirements for disposal at IDF or WCS" (Sec.
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From page 78... ...
• Regulatory issues introduce uncertainties into the schedules. Examples are permitting the IDF for disposal of primary and secondary treated LAW wastes, the acceptability of waste forms other than glass for disposal in the IDF, and the continued acceptability of the SLAW wastes for transport to and disposal at WCS.
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From page 79... ...
Furthermore, in multiple public meetings during the course of this study, Department of Ecology representatives have indicated resistance to consider ing any waste form other than glass for the SLAW, based on their belief that DOE committed to a glass waste form for the SLAW many years ago. (See the subsection on the "As Good as Glass" Conundrum in Chapter 2 of this review for details on the Department of Ecology's most recent views.)
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From page 80... ...
While the length of the cleanup period is undoubtedly frustrating, it also offers opportunities to learn from experience and new information to improve the effectiveness, efficiency, and possibly the speed and cost of the Hanford tank waste management effort. In this connection, the committee observes that some of the treatment approaches may be considered to be hybrids even though only a single treatment (immobilization)
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From page 81... ...
It would be extremely unrealistic to think that the nature of the Hanford tank waste easily or inexpensively lends itself to multiple treatment options; on the other hand, the uncertainty of current technologies and the length of time of the management project suggest, respectively, the need for and the opportunity to experiment with parallel, sequential, or hybrid approaches. Could Developments Outside the Scope of This Study Affect the Use of the FFRDC's Report and the Committee's Review?
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From page 82... ...
• The waste forms and associated disposal sites: o How effective is each waste form in immobilizing the waste (e.g., the materials science of the incorporation, corrosion, and release processes) and over what time periods?
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From page 83... ...
, iodine (I) , and other long-lived radionuclides in the waste form for the SLAW, with possible use of enhanced engineered barriers such as getters, which are added materials that can better retain the contaminants of concern; and • Removing the Tc and I (and possibly other radionuclides)
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From page 84... ...
Final Review of the Study on Supplemental Treatment Approaches of LAW at Hanford: Review #4 c. Taking positive advantage of the unavoidably long remediation period to improve existing tech nologies and adopt new ones; and d.
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From page 85... ...
2018b. Review of the Draft Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation: Review #2.
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From page 86... ...
In Science and Technology for Disposal of Radioactive Tank Wastes, W.W. Schulz and N.J.
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