3

Analysis of the Alternative Treatment Approaches

The Federally Funded Research and Development Center (FFRDC) team presents three primary treatment alternatives, together with variants on each: vitrification, grouting, and steam reforming. As discussed in Review #1, the committee observes that the FFRDC team has appropriately limited its analysis to these three alternatives and key variants due to technical maturity. Therefore, as described in Chapter 2, the task for the team is to gather the information and provide analytical results necessary for a decision-maker to distinguish, weigh, and ultimately choose among these particular alternatives. (More fundamental alternatives—such as no-action, not separating high-level waste [HLW] and low-activity waste [LAW], or redesigning the treatment system currently under construction to eliminate the need for supplement LAW [SLAW] treatment—are beyond the scope of the team’s task and thus beyond the committee’s scope as well.)

Finding 3-1

As a compilation of information, the FFRDC draft report has collected and documented an impressive amount of material that is relevant to a decision regarding the treatment and disposal of SLAW. Nevertheless, there remain gaps in data and analysis results that have been acknowledged by the FFRDC team that will be required for the U.S. Department of Energy’s (DOE’s) decision-making.

Finding 3-2

The FFRDC’s draft report limits its detailed consideration to three main approaches (vitrification, grout, and steam reforming)—those explicitly identified in Section (Sec.) 3134—and variations of those alternatives. The limitation to these three main approaches is justified by the current state of the relevant technologies, and the inclusion of variations takes into account opportunities to improve the effectiveness of each approach and to take advantage of opportunities created by each approach.

Recommendation 3-1

Before finalizing its report, the FFRDC should identify and provide the information and analysis that are critical for a decision by DOE. If it is impossible to gather the necessary information within the time permitted by the authorizing statute, the FFRDC team should clearly identify the gaps and assess their potential impact on the analysis.

The four sections of this chapter are intended to reflect in general terms the approach recommended above. Put informally, the core questions for decision-makers concerning the selection of the treatment approach and the corresponding waste form are:

• How safe is an alternative in comparison to others following waste disposal?
• What is the level of confidence that each waste form production process will work? For example, are these technologies safe, reliable, and feasible?
• How much will each waste formation process cost? In addition, how do the costs for the various waste formation processes compare to each other, and what are the effects of funding constraints?

• Will the waste form comply with applicable laws and regulations?

By presenting these issues comparatively, the FFRDC’s final report can provide invaluable assistance to DOE, the regulators, Congress, and stakeholders in seeking the best approach to the management of SLAW.

SAFETY OF THE ALTERNATIVES FOLLOWING WASTE DISPOSAL

How safe is an alternative in comparison to others following waste disposal? This section considers essential issues for understanding how waste form performance affects safety with the view toward what the FFRDC needs to address in its forthcoming report. The performance assessments of the waste disposal sites are fundamental documents for determining what waste forms are acceptable for a particular site or sites. As mentioned in Chapter 1 of this review, DOE has finished its performance assessment (PA) of the Integrated Disposal Facility (IDF) at Hanford, but as of July 15, 2018, the release date of the FFRDC’s draft report, DOE had not yet made the PA publicly available and had not done so during the time of the committee’s writing of this review. However, at the public meeting on February 28, 2018, the committee and the FFRDC received briefings relevant to the PA.

While these briefings were useful, the committee observes that it would improve the FFRDC’s report to describe the source term, that is, a description of the types, chemical forms, and amounts of radioactive or hazardous materials released from the waste form, which is fundamental for any PA. In addition to describing the source term, it would be useful for the FFRDC’s final report to discuss what percentage of the total inventory of radionuclides of concern (e.g., iodine-129 and technetium-99) will end up in the LAW stream. The committee appreciates that Table H-2 in the draft report shows the radiological content (in curies per cubic meter) of the radionuclides for April 2060, based on computer simulation of the LAW stream from the Waste Treatment and Immobilization Plant’s (WTP’s) pre-treatment facility, and the committee suggests it would be relatively easy to use these data to provide percentages of each radionuclide in the total inventory of the stream.

The presentation on the IDF’s performance assessment from the second public meeting has useful data on the inventory and concentrations of iodine-129 and technetium-99, as shown in Table 3-1, but it is important to have similar data for any other radionuclides of concern. Recognizing that compositions will vary over time and from tank to tank, the committee suggests it would be helpful for the report to contain data on the average and expected range of compositions and chemical forms and for the FFRDC to discuss these data in its final report.

Because the underlying question is how well the disposal of the waste forms from the alternatives meets the performance requirements, the committee suggests that the final report describe the waste form in enough detail (including materials description, location of key radionuclides and metals [as listed in the Resource Conservation and Recovery Act] in the waste form, radionuclides’ chemical form, and release mechanisms) such that a decision-maker can understand the basis for analysis of performance in the relevant disposal site. The discussion of release mechanisms is very important to understanding the basis of the risk assessment or “mini-PA” that the FFRDC mentioned it will perform to compare the various waste forms that could be considered for the IDF. Section 3.3.2 of the draft report provides a brief description of the methodology that the FFRDC proposes it will use in its mini-PA.

As to descriptions of the waste forms, the draft report provides the most detailed information on the fluidized bed steam reforming (FBSR) waste forms in Appendix C, but the data are presented without analysis and a cogent summary. Appendix B discusses vitrification but provides no information on the glass waste forms. Appendix D discusses the grout approach and has a section on the cast stone waste forms with a brief discussion about how these compare to earlier grout formations for Hanford LAW. The committee observes that this is a useful discussion and suggests that the FFRDC’s final report provide further analysis that addresses the issues above and a thoughtful summary.

TABLE 3-1 Inventory and Concentrations of Iodine-129 and Technetium-99

NOTE: Ag = silver; CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act of 1980; FFTF = Fast Flux Test Facility; GAC = Granular Activated Carbon; HEPA = high-efficiency particulate air filter; ILAW = immobilized low-activity waste; IX = ion exchange; LSW = liquid secondary waste; SSW = solid secondary waste.

¹The waste volume is an estimate of the as-generated waste volume.

²The waste volume is an estimate of the as-disposed waste volume of secondary solid waste after it has been compacted or solidified.

SOURCE: Washington River Protections Solutions, LLC, TOC-PRES-18-0441-VA, Rev. 0 (p. 4).

Finally, the committee mentions for the FFRDC’s awareness that the comparison of waste forms has a long history (e.g., Chapter 12 in Lutze and Ewing, 1988). It is not easy to make such comparisons because the results depend on the disposal environment. The unique opportunity in this study is that the disposal environments, whether the IDF at Hanford or the Waste Control Specialists (WCS) facility in Texas, are well defined—perfect for making a defensible comparison.

CONFIDENCE IN WASTE FORM PRODUCTION TECHNOLOGIES

What is the level of confidence that each waste form production process will work? This section focuses on the practicalities of producing each waste form. Because the production processes for the three waste forms differ significantly, the specific questions that need to be addressed are not necessarily the same for each of them. Nonetheless, the committee points out here common themes it suggests the FFRDC address for each production process.

First, provide a qualitative comparison of the important hazards to workers and the public assuming that production facilities would be designed to meet regulatory and DOE standards. While the expert elicitation discussed in Appendix F of the draft report considered, as criteria, hazards and safety to workers and the public, the draft report does not provide underlying discussion of the hazards for each of the production processes. For example, hazards associated with materials common to grout and concrete production in the construction industry include exposure to nuisance dust, silica dust, and chemical burns due to the high alkalinity of portland cement-based grout.

Second, list the experience with each production technology in radioactive applications. The draft report gives a well-informed discussion for the fluidized bed steam reforming production’s experience with radioactive applications but not as well for the other two primary production alternatives.

Third, provide a high-level analysis of the technical readiness levels and technology maturity requirements for each production process. In the subsections below, the committee highlights significant issues concerning reliability and feasibility of the production processes, and the committee offers observations and suggestions to the FFRDC for help in improving the final report.

Programmatic risk is a fundamental issue at the Hanford Nuclear Reservation. The combination of extremely hazardous and heterogenous waste forms, high-cost storage facilities (e.g., the tanks), a history of false starts and missed deadlines, a history of regulatory and policy disagreements, and the prospect of decades of waste treatment as the best case—all indicate that there are very significant programmatic risks going forward for any technical approach. While all have significant programmatic risks, they are not necessarily identical in their nature or extent, and this section outlines the committee’s observations in this regard.

Vitrification

Reliability

Vitrification is a high-temperature process with multiple steps. Each step must work properly for the operation as a whole to function. This multi-step process raises concerns about the effects of periodic shutdowns that would be necessary for repair and maintenance. In general, it is expected that the more system operations that occur, the greater the operational risk. Even if most shutdowns are due to scheduled maintenance, there will be some that are unforeseen. The FFRDC appears to recognize these concerns, and in the section on “Risks” in Appendix B, it states: “The current assumptions for LAW WTP facility availability [70 percent] are higher than achievable in actual operation.” But the committee suggests that in the final report the FFRDC provide a detailed discussion of reliability concerns in general and the basis for a value of 70 percent availability being higher than achievable.

The baseline vitrification facility has two melters and four primary and secondary off gas handling systems. What are the consequences to scheduled throughput if and when one of the melters would need replacing or when the high-efficiency particulate air (HEPA) filters need to be replaced? Here again, the committee observes the FFRDC has not included a detailed discussion of such operational risks in the draft report and the final report would benefit from including such a discussion. Notably, the draft report, however, does mention on page 46: “The design life of a melter is five years. Bubbler replacement is expected to be the most frequent maintenance requirement, with each bubbler having an estimated life span of 26 weeks.” The draft report does not discuss how challenging it would be to replace the bubblers or a melter, and the committee suggests that the FFRDC discuss this issue in its final report.

Feasibility

The committee observes that the draft report does not discuss prior experiences with similar or comparable vitrification processes but suggests the FFRDC do so in its final report. It is worth observing that supporters of the technology are quick to cite successful deployment, and critics are equally quick to cite failures. Consideration of U.S. and international precedents will greatly increase the report’s credibility.

Fluidized Bed Steam Reforming

Reliability

Similar to vitrification, FBSR is a multi-step, sequential process. The committee suggests that the FFRDC’s final report address similar concerns regarding possible causes of shutdown, ease of shutdown or idling if necessary, ease of restart, and the potential length and cost of likely delays. The committee observes that pages 84-89 of the draft report have an extensive discussion of the startup challenges of the Idaho National Laboratory’s (INL’s) Integrated Waste Treatment Unit (IWTU) and how these challenges have been addressed or will be addressed. However, the draft report mentions on page 89 that

The committee suggests that the FFRDC summarize these important points in the main body of its final report.

Feasibility

FBSR has been extensively tested at various facilities and at various scales and has demonstrated success in eliminating organics, nitrates/nitrites, sulfates, chlorides, fluorides, and other contaminants from waste streams. As the draft report states, FBSR is a continuous process that needs little or no additional pretreatment of the waste stream beyond that already planned to take place in the WTP and Direct Feed LAW facilities. It seems likely that the aluminosilicate process could be used for Hanford SLAW but may not be as high on the technical readiness level (TRL) scale as the other options. The committee suggests the FFRDC summarize these important points in the main body of its final report.

The committee notes that the reliance on a foreign supply of coal to operate the FBSR is particularly vulnerable to loss of supply. The committee suggests the FFRDC mention this issue in its final report.

Grout

Reliability

Based on the draft report’s description of the flowsheet for grouting, this production process is much simpler than the other proposed methods. From an operations standpoint, it thus appears to be inherently more reliable. Even so, components do require routine maintenance as well as repair and eventual replacement. For example, in the construction industry, equipment that is less robust such as concrete pumps may require spares on hand to permit continuing operations. Also, in the construction industry, the use of chemical admixtures allows for such measures as set retardation should a pump fail. The committee understands that chemical admixtures are not used in waste form grouts. If not, what other measures can be employed in such circumstances? The committee suggests the FFRDC provide a discussion of how operational reliability would be addressed for a potential grouting program.

The shortage of fly ash for grout formulations is not an immediate risk to a grouting program, but the risk will grow as inefficient coal-fired plants are shut down. Because fly ash is a byproduct, supply and demand works differently than for manufactured products: shortages cause price increases, but high prices do not provide incentives to increase the supply. Organizations such as the American Concrete Institute, as well as private corporations, are exploring the development of alternative supplementary cementitious materials; the committee suggests that the FFRDC consider such action as well. While the committee agrees with the FFRDC that stockpiling of materials would provide insurance against occasional shortages of key

materials, it believes that systemic changes to the market will make fly ash increasingly scarce and suggests the FFRDC briefly discuss these material shortage issues and consider this eventuality in its comparative analysis.

Feasibility

The committee recognizes that page 105 of the draft report identifies the risk that:

The committee also notes the construction industry has developed techniques, equipment, and practices that could prove instructive.

The committee suggests that the team consider the potential benefits of using rectangular blocks or vaults for the grout. Rectangular blocks might more completely and efficiently fill the space in a landfill and might hinder the ingress of water between blocks.

COSTS OF WASTE FORMATION PROCESSES

How much will each waste formation process cost? In this section, the committee provides observations about the FFRDC’s cost estimations for the waste treatment processes and makes suggestions about how the FFRDC could improve cost estimates in its final report. In the draft report, section 1.5 “Cost-Estimation Summary” mentions the FFRDC used cost data from analogous facilities where the various treatment technologies have been developed and the team’s subject-matter experts then “identified technical and/or programmatic gaps between selected facility analog and the pertinent technology.” While section 1.5 gives a brief summary of the methodology, it does not provide a summary of the cost estimates, which the committee believes would be useful in the section near the beginning of the report so that decision-makers could have these cost estimates readily accessible. The draft report provides a more in-depth discussion and a table of cost estimates in Appendix G.

Appendix G starts by explaining that the team is just providing a “Rough Order of Magnitude (ROM) Class 5 Planning Estimate for research and development, design, construction, lifecycle costs including transportation and disposal.” As Appendix G notes, these estimates “have the least project definition available … and therefore have wide accuracy ranges.” In Review #1, the committee suggested “that the FFRDC team in its forthcoming analysis [its second draft report, dated July 15, 2018] discuss how order of magnitude (which is significantly uncertain) cost estimates could be useful to decision-makers.” However, the FFRDC has not provided this discussion in the second draft report. Thus, the committee reiterates its suggestion for the FFRDC to discuss this issue in the final report.

The committee also suggests that any discussion of uncertainty in the report’s cost estimates would have to address the question of asymmetry in the uncertainty, for example, what percentage error around the base estimate can be expected in the upward and downward direction. In addition, and particularly important, the committee suggests the FFRDC try to identify whether those ranges of uncertainty are larger for some of the options than for others. Even if every option is costed only to a ROM Class 5 level, it seems unlikely that they will all, in actuality, have similar uncertainty ranges when accounting for the differences in their TRLs and system complexities, among other factors. It would also be useful for the factors that may make one option’s cost estimate more inherently subject to surprise increases (or decreases) to be discussed and summarized in terms of their overall impact on the magnitude of each option’s cost contingency.

In its review of Appendix G, the committee appreciates the detailed listings of items relevant for the estimates’ scope and assumptions. The committee observes that these lists appear comprehensive. Appendix G then briefly mentions the analogous facilities used for the cost estimates. In particular, the FFRDC team has selected WTP’s LAW facility and associated Effluent Management Facility (EMF) as the best analogy for SLAW vitrification. The draft report also mentions the Defense Waste Processing Facility (DWPF) at the Savannah River Site as another useful analog.

The FFRDC has selected the saltstone method applied at the Savannah River Site as the analog for the grout treatment cost estimate and notes that this method “can produce at the same scale as required for Supplemental LAW grout … but significant handling, pretreatment (in some of the variants), and logistical unit operations must be included.” As with the vitrification analog, it would be helpful for the FFRDC’s report to discuss more fully why the team has chosen this grout treatment method in its cost estimation. The FFRDC has selected the IWTU at INL as the analog for the FBSR treatment cost estimate, but the draft report notes the IWTU is nominally half the capacity required for SLAW processing and will produce a different mineral (aluminosilicate proposed for Hanford versus sodium carbonate in IWTU) form, and the IWTU has been built for more highly radioactive material. Nonetheless, the FFRDC believes the IWTU “is the best available analog.” It would have been useful for the FFRDC to have discussed whether there are more suitable analogous facilities for its cost estimation. The committee notes that including more than one analog could help with giving a range of cost estimates based on actual construction and operational experience.

The committee observes that the draft report does not list references for the cost-estimation data and does not provide much detail as to why these analogous facilities were chosen. For example, while the FFRDC acknowledges the IWTU produces a different mineralized waste form than what would be produced with Hanford waste if FBSR were used, the FFRDC does not discuss other FBSR facilities that might be better analogies or at least mention other facilities it may have considered. Furthermore, the DWPF facility for HLW vitrification has significantly different requirements than for SLAW, and the WTP LAW vitrification facility has encountered numerous difficulties and is not yet operating. Thus, the committee suggests that the FFRDC in its final report provide more details into the rationale for selecting the best analogous facilities for the FFRDC’s cost-estimation, address the uncertainties entailed in the selection of these facilities, and provide a list of references to the cost data.

The committee understands that tank integrity is outside the scope of the FFRDC’s tasking. Nonetheless, the committee notes that early tank failures represent a cost uncertainty. In particular, a sudden loss of double tank shell capability could result in dramatic increase in the time it takes to transfer waste for treatment. Thus, the committee suggests that the FFRDC consider the potential of tank failure in the context of the time required to develop and deploy the various treatment alternatives and variants (longer development and deployment times increases the chances of tank failures).

REGULATORY COMPLIANCE

The committee’s fourth fundamental question is: Will the waste form comply with applicable laws and regulations? For obvious reasons, compliance is a fundamental requirement for any approach that DOE chooses, but such an analysis is also mandated by Sec. 3134, which requires the FFRDC to analyze the compliance of the various treatment approaches “with applicable technical standards associated with and contained in” relevant regulations. (See Appendix A for the list of regulations.) The committee observes and appreciates that the draft report’s Appendix J has an extensive discussion of regulatory compliance issues and that Appendix H on Disposal Site Considerations and Appendix I on Transportation Considerations include discussions of relevant regulations affecting these issues.

The committee calls attention to the important issue of designation of Hanford waste that the FFRDC team discusses on page 166 of Appendix J, which mentions that in 1997, DOE and the U.S. Nuclear Regulatory Commission (U.S. NRC) “provisionally agreed that the vast majority of waste from Hanford tanks is not high-level waste, but rather is low-level waste that is not subject to the NRC’s licensing authority.”

However, to be managed under DOE’s regulatory authority, the waste designated as LAW has to meet the Waste Incidental to Reprocessing (WIR) criteria in DOE M 435.1-1 (DOE, 2011). The criteria as paraphrased from page 166 of the draft report are:

• Processed to remove key radionuclides to the maximum extent that is technically and economically practical;
• Managed to meet safety requirements comparable to performance objectives in Title 10 Code of Federal Regulations Part 61, Subpart C, “Performance Objectives”; and
• Managed pursuant to DOE’s authority under the Atomic Energy Act of 1954, as amended, and in accordance with provisions in DOE M 435.1-1, Chapter IV, provided the waste will be incorporated in a solid physical form at a concentration that does not exceed the applicable concentration limits for Class C low-level waste, as specified in 10 CFR 61.55, or will meet alternative requirements for waste classification and characterization as DOE may authorize.

Before waste is emplaced in the IDF, it will have to meet a WIR determination.

In Review #1, the committee suggested the FFRDC’s analysis discuss what would be required for the non-vitrified waste forms being assessed to be considered “as good as glass” in the context of the current state of technology for waste forms other than glass from a technical and human health risk perspective. As Chapter 1 of this review has noted, the FFRDC’s draft report does not provide this analysis.

Regulatory Compliance and the Performance Assessments for Waste Disposal Facilities

In Review #1, the committee also suggested the FFRDC’s analysis discuss how consideration of [additional] pre-treatment processing alternatives to remove radionuclides such as technetium-99 and iodine-129 could expand on-site and off-site disposal options, taking into account compliance with applicable laws and regulations, and the extent to which various treatment (immobilization) options affect the need for pretreatment to remove key radionuclides.

Appendix A of the draft report has an expanded discussion on pre-treatment and shows results of calculations of how strontium removal would affect the waste classification for the three waste forms, which is potentially relevant to disposal at WCS. Appendix A on page 34 also provides information on the removal levels in percentages required for technetium and iodine to meet the EPA groundwater protection requirements for the IDF based on the PA. While recognizing these data are useful to have, the committee underscores that the PA has not yet been released and calculations to assess the performance of grout and FBSR waste forms for SLAW have not been presented or provided to the committee. Due to these limitations, the draft report does not provide comparisons of the post-disposal performance of the three supplemental LAW waste form alternatives being evaluated although it does state on pages 27-28 that a “mini-PA” will be performed to provide a basis for comparing the three waste forms for the IDF.

As the draft report makes clear, the FFRDC has identified WCS, a commercial low-level waste disposal site near Andrews, Texas, as a potential off-site disposal facility for the final waste forms of SLAW. WCS has been licensed to receive Class A, B, and C low-level waste (LLW) and mixed low-level waste (MLLW). The FFRDC has analyzed the radionuclide concentrations in a grout waste form and compared these concentrations with radionuclide concentration limits in the WCS waste acceptance criteria (WAC). The FFRDC has found the grouted SLAW can easily be accepted under this WAC.

Interestingly, there are different regulatory requirements for the IDF and commercial LLW disposal facilities. The IDF is regulated by DOE Order 435.1 and includes performance objectives of not only dose requirements, but also having to meet EPA groundwater standards as well as specifying a compliance time frame (1,000 years) and a point of compliance. Commercial LLW facilities are regulated under U.S. NRC Title 10 of the Code of Federal Regulations Part 61 (U.S. NRC 10 CFR Part 61) or agreement states that have acquired this authority. (Texas is an agreement state and thus regulates disposal of LLW within its borders; the Texas LLW law has to be at least as restrictive as 10 CFR Part 61, but can be more restrictive.)

This regulation defines classes of waste (Class A, B, and C) based on radionuclide-specific concentration limits and performance objectives consisting of dose limits, but no groundwater protection requirements, and the point of compliance is defined on a case-by-case basis.

From the July FFRDC presentation by Robert Jubin and Michael Stone on “Pretreatment Approaches,” in order to comply with the safe drinking water requirements in the groundwater, an overall technetium-99 removal of 92 percent and an overall iodine-129 removal of 48-57 percent are required.¹ Even in the case where LAW is vitrified, the performance of IDF in terms of meeting the groundwater standard is dominated by iodine-129 and technetium-99 present in the grouted secondary wastes, not the vitrified LAW per se. Yet, the FFRDC’s February presentation by John Cochran on the WCS disposal facility indicates that for the same waste composition but in grouted waste form, the average concentration of technetium-99 is about 1 percent of the Class C limit of 10 CFR Part 61, and iodine-129 concentration is about 0.1 percent of the Class C limit.² With such large margins below Class C limits, it is natural to consider whether the potential need for additional treatment of SLAW to remove iodine-129 and technetium-99 could be avoided if WCS disposal is selected. It is important to note that the 10 CFR Part 61 waste class definitions are driven mainly based on the intruder scenarios; PA analyses are still required to demonstrate compliance with the performance objectives (dose requirements).

Based on the technetium-99 and iodine-129 removal requirements for the IDF, it appears that the IDF has more stringent compliance requirements than WCS; however, it is not clear if this is because the WCS site characteristics can provide much better waste isolation, or the IDF PA may have used very conservative assumptions and data, or a combination of both.

The committee was not provided the PA information on WCS. However, a WCS document as part of its license application indicated PA analyses were performed for 100,000 years after facility closure and 10 CFR Part 61 performance objectives were met for its license application inventory (WCS, 2011). This indicates the availability of PA calculations for WCS.

As noted on pages 27-28 of the FFRDC’s draft report, the FFRDC proposes to perform analyses of the waste forms that could be considered for the IDF. In order to have meaningful comparisons, it is desirable that best-estimate data and assumptions are used to the extent possible, and that similar degrees of conservatism in data and assumptions are used when necessary in these analyses. It is also important to understand the conceptual models and data supporting the treatment of barriers, preferably from the publicly released IDF PA with a short summary in the team’s report. Questions include:

• Which IDF barriers are modeled in the PA?
• For barriers not included in the PA, are there analyses that show these barriers are not important to long-term performance, or are they excluded due to lack of information to support a credible analysis?
• Are barriers assumed to fail instantly, or is there a time-related degradation of performance?

Other Important Regulatory Issues

Resource Conservation and Recovery Act of 1976

Wastes that would be disposed of in the IDF are subject to regulation by both the Resource Conservation and Recovery Act of 1976 (RCRA) and DOE Order 435.1. The Washington Department of Ecology is the regulator for RCRA issues, and a permit is required before the IDF can be operated. Currently, there is a draft permit for disposal of vitrified LAW in the IDF, but no other waste forms are authorized, and WAC acceptable to both DOE and Washington Ecology have not been finalized.

RCRA requirements do not address radionuclides. The requirements for disposal of the radionuclides in LAW or SLAW are defined in DOE Order 435.1. These requirements establish dose limits of 10 millirem (mrem) per year by an air pathway and of 25 mrem per year from all pathways to someone at the accessible

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¹ See slide 62 in http://dels.nas.edu/resources/static-assets/nrsb/miscellaneous/hanford3-bates.pdf.

² See slide 98 in http://dels.nas.edu/resources/static-assets/nrsb/miscellaneous/Hanford2/hanford11.pdf.

environment, defined to be 100 meters downgradient from the disposal site. This order also establishes higher acute and chronic dose limits for an on-site intruder. These requirements apply for 1,000 years after site closure although the IDF PA results shown in the public presentations extend to much longer times.

Transportation

If the final SLAW waste will be disposed of at WCS, major transportation activities would be involved. Appendix I of the draft report and the FFRDC presentation during the July public meeting included regulatory and operational analysis of potential transportation. The FFRDC showed in its analysis the feasibility of transporting grouted and steam-reformed wastes from Hanford to WCS using a maximum of 26 gondola railcar loads per month for slightly less than 30 years. The analysis was based on the assumption that dedicated trains would be used. Appendix I stated that a shipping program of this scale will most likely require the development of an Environmental Impact Statement (EIS) under the National Environmental Policy Act (NEPA). The EIS process includes input and involvement of stakeholders along the rail lines. The committee suggests that in the assessment of alternatives that require transportation of nuclear wastes through multiple states, the FFRDC consider concerns of potential opposition of local stakeholders along the transportation routes.

Finding 3-3

The regulatory environment for the Hanford tank waste is complex and contested. While the committee does not express an opinion on the correct legal interpretations and policy choices, especially with respect to the “as good as glass” issue, it finds that contested regulatory standards represent a significant program risk to any approach.

Recommendation 3-2

The FFRDC report should define to the extent possible the contested regulatory issues with regard to each approach it considers, and describe to the extent possible the impact of the likely outcomes on the choice of approach and program schedule.