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The Committee’s Technical Review of the FFRDC’s Draft Analytic Framework

For this first review, the Statement of Task (see Appendix B) requires the committee to evaluate the technical quality of the FFRDC’s draft analytic framework with respect to the questions:

1. “Does the FFRDC’s report clearly lay out a framework of decisions to be made among the treatment technologies, waste forms, and disposal locations?
2. Does the FFRDC’s report consider in its analysis all the elements, criteria, and factors specified in Section 3125 of the National Defense Authorization Act of 2021?”

At this stage, as expected and intended, the FFRDC only has a detailed outline to be reviewed by the committee and does not have much analysis to review. This review report is narrowly focused on: (1) has the FFRDC team identified an acceptable range of alternatives or variants to be considered in the team’s forthcoming more detailed analysis; (2) are there serious omissions in the selection criteria and factors needed for decisionmakers to be able to make an informed decision. Henceforth, the committee uses the term “factors” as shorthand for the phrase “elements, criteria, and factors.” In addition, Appendix D provides the committee’s observations about additional issues for consideration in the forthcoming FFRDC complete draft report.

The committee notes that “framework of decisions” in the first question was a term the previous committee for the Sec. 3134 study and review used in its final review report (NASEM, 2020). This current committee considers the “framework” as a structured way to present side-by-side comparisons of the treatment approaches and disposal options in a format that is useful for decisionmaking [italicized for emphasis]. The FFRDC in its presentation at the October public meeting stated that it developed a “framework of criteria for comparison of alternatives” and that it uses the term “decision framework” with the overall goal to “provide decisionmakers with the ability to make a direct comparison between approaches for the supplemental treatment of low-activity waste” and “based on criteria that are relevant to decisionmaking and most clearly differentiate between approaches.” The factors are listed in Appendix C.

The committee believes that, when complete, the combination of the alternatives and their characteristics, and evaluation of the “selection criteria” identified in the FFRDC compilation in a side-by-side format constitutes the framework for decisionmakers to determine how best to proceed with SLAW treatment and disposal. It is best thought of as a “decision-informing framework.” The committee also believes it would not be appropriate for the FFRDC to actually list the decisions that must somehow be made, who should make the decisions, in what order, etc. because this is largely an interactive policy/political process involving many stakeholders (e.g., DOE, Congress, State of Washington, tribal nations, local community groups) that will be informed by the FFRDC’s results.

This chapter has two sections: (1) consideration of question 1 in the Statement of Task and (2) consideration of question 2 in the Statement of Task.

2.1 QUESTION 1: DOES THE FFRDC’S REPORT CLEARLY LAY OUT A FRAMEWORK OF DECISIONS TO BE MADE AMONG THE TREATMENT TECHNOLOGIES, WASTE FORMS, AND DISPOSAL LOCATIONS?

2.1.1 Fundamental Constraints Faced with Cleanup of the Tanks

The committee assesses that the FFRDC draft framework does not yet fully satisfy question 1, but

as explained in this section, it appears to be on the right track. First, the committee wants to raise an important consideration concerning tank waste treatment. This committee, like its predecessor, believes that DOE faces two fundamental constraints with the clean-up of the tanks at the Hanford Site:

(1) The current waste storage configuration continues to age and thus degrade, and the likelihood of a serious breach of containment (and subsequent threat to the underlying aquifer and Columbia River) continues to grow, while removal and treatment of waste waits. As one commenter at the October meeting aptly put it, “Time is not our friend.” Sec. 3125, in fact, expressly recognizes the urgency of this issue in § 3125(c)(8)(A) (“costs and risks of delay”). In November 2014, a report by the U.S. Government Accountability Office (GAO) highlighted the reduced available capacity in the double-shell tanks. That GAO report also noted that in 2012, the U.S. Department of Energy (DOE) discovered a leak in the primary shell of the double-shell tank AY-102 and stated that the leak was likely caused by corrosion in the bottom of the tank (GAO, 2014). According to the latest waste tank summary report from June 2021 prepared for DOE, 59 tanks (58 single-shell and one double-shell) are listed as assumed or confirmed leakers (WRPS, 2021). There are 149 single shell tanks and 28 double shell tanks at the Hanford Site. In GAO’s most recent report on Hanford, GAO stated that in January 2021, it found “that DOE may soon run out of tank space. Specifically, in internal project management documents, DOE identified insufficient tank space as the top risk to its cleanup mission. It also estimated there was a 95 percent chance it would run out of double-shell tank space, as it continues moving waste” (GAO, 2021).

(2) The costs of tank waste clean-up, under nearly any scenario, appear to far exceed current funding levels at Hanford.⁸ In 2019, GAO reported that the environmental liability costs at the Hanford Site increased by nearly $130 billion from fiscal years 2014 to 2018 and that most of the estimated increased costs are due to tank waste treatment. Moreover, GAO underscored that DOE’s budgeting has “not reflected the funding need to meet schedule milestones” and that a major challenge has been the “annual discretionary appropriations,” which entail “difficult tradeoffs” between cleanup and other defense nuclear programs (GAO, 2019).

While it is tempting to think that sequencing the various elements of treatment and disposal can address this problem, each part—including SLAW treatment—would have to be available simultaneously if the system is to be operated at full capacity. Moreover, even if a sequential approach was used, it would further extend a clean-up timeline that is already decades long, thus increasing tank leakage risk and the potential that funding will be reduced.

At this stage, the FFRDC draft framework does not include information regarding the costs of the alternatives. If the cost estimates that this FFRDC team will make are similar to those of the previous FFRDC report, the vitrification option will be much more expensive than the other two alternatives, further straining future Hanford budgets which are already projected to need to be many times higher than recent levels of funding (NASEM, 2020). For this reason, the committee is concerned that vitrification of SLAW is not likely to be an economically feasible option, whether or not it is technically superior or preferred by key regulators and stakeholders. While the current configuration of the tank waste at Hanford does not present an imminent threat to human health and the environment (thanks to millions of dollars of ongoing effort), it is not stable in the long (several decades) or even medium term (a couple of decades); rather, the configuration is inevitably deteriorating, despite all of the effort and resources that go into maintaining its current safety. The committee sees this as a matter of great urgency, and a way must be quickly found to address the deteriorating tanks within the significant constraints of budgetary reality. Thus, the first finding and recommendation concern the need for reframing the FFRDC’s analysis to account for the risks of tank failures, the limited tank storage capacity to handle potential process upsets, and the budgetary constraints.

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⁸ Typically, total Hanford Site funding levels are about $2 billion per year. The most recent fiscal year had a significant increase to $2.6 billion, but this is still much less than the FFRDC’s cost estimation projections for the Sec. 3134 study that peak at almost $5 billion per year for just vitrification of both LAW and SLAW as well as the operations of the WTP and tank farms (NASEM, 2020), i.e., not including other cleanup activities on the Hanford site.

Finding 1: Given the limited available space in the tanks that can safely store waste (e.g., non-leaking double-shell tanks), there may not be enough capacity to receive wastes from other tanks that presently contain the waste that will become immobilized HLW, LAW, and SLAW if more than a few tanks fail. While Sec. 3125 calls for analysis on “the costs and risks in delays with respect to tank performance over time,” the FFRDC draft framework does not include provisions to address the probability of tank failure with respect to time. The analysis will have to deal explicitly and urgently with the fundamental issues of budgetary constraints and the risks of breach of tank containment. Moreover, tank cleanup costs appear to exceed, under nearly any scenario, current funding levels.

Recommendation A: To address the risks of failure of the tanks within the context of budgetary constraints, the committee recommends:

(1) Reframing the fundamental question to be addressed in the FFRDC analysis going forward as: How can decisions about treatment of SLAW facilitate the fastest removal of the waste from the tanks and into a disposal facility, all things considered (e.g., budget limits, technology uncertainties, and regulatory acceptability)? This reframing will focus consideration on the most pressing issue of risks of tank containment breach.

(2) Having the forthcoming FFRDC report address the risks associated with these potential leaking tanks as quantitatively as possible as well as potential structural failure of the tanks in a clear manner such that the decisionmakers will understand the magnitude of the problem and the potential risk and increased costs of the cleanup if waste retrieval is delayed until additional tank failures occur.

2.1.2 Differentiating among Alternatives

From the perspective above, it cannot be emphasized too strongly that the purpose of the FFRDC analysis is to provide actionable information for DOE to make a decision in the reasonably near future. Sec. 3125 in fact directs the FFRDC to consider “criteria that are relevant to decision-making and most clearly differentiate between approaches” §3125(b) [Emphasis added]. (Note: Sec. 3125 uses “approaches” while the FFRDC uses “alternatives.”) The FFRDC envisions a comprehensive review of three alternatives (vitrification, fluidized bed steam reforming (FBSR), and grout) and variants of the alternatives (e.g., differing location of treatment and disposal) for SLAW management. Since the Sec. 3134 study, the FFRDC has come a long way toward organizing its forthcoming report to support decision-making. Nevertheless, as many of the FFRDC presentations and commenters’ presentations make clear, the amount of information needed for a truly comprehensive assessment and comparison is nearly infinite, riddled with significant uncertainties, and extremely challenging to compare directly, even with the application of sophisticated analytical tools.

Finding 2: In the committee’s view, the FFRDC’s task is to simplify and narrow the analysis to the factors whose incremental differences will highlight the key considerations likely to dominate the choices that DOE must make.

Recommendation B: The FFRDC report should (1) identify the relevant factors that “most clearly differentiate between approaches,” and (2) identify and bound the incremental difference that each such factor makes in the decision. The committee emphasizes that “narrowing” is not prioritizing factors, but rather identifying and highlighting the factors that account for the most salient, decision-relevant differences among the alternatives. That is, there needs to be a critical assessment of factors (cost, scope, and schedule, in particular) to understand which differentiate among approaches, and by how much.

To identify the subset of factors that most clearly differentiate among alternatives, the FFRDC will likely need to consider the factors that they have identified and provide the basis for determining

which are the most relevant. To foster clarity in the main body of the report, the FFRDC might consider documenting all of the factors in an appendix accompanied by sufficient analysis to support identification of the most relevant subset that will be analyzed and discussed in detail in the main report. In addition, the FFRDC might consider use of factor analysis, which is sometimes called dimension reduction and is a method that can reduce the number of variables to a fewer number in order to make the research data and analysis more tractable.

A straightforward approach for both finding and communicating about the decision-relevance of the subset of key factors would be to develop a set of two-dimensional graphs that plot the estimated outcomes of each SLAW option in terms of two of the key factors. For example, one graph could plot the SLAW options’ estimated costs on one axis and their respective time until completion of cleanup on the other axis. Other graphs could illustrate the options’ estimated peak individual risk associated with the ultimate disposal form/site against speed of cleanup, and against cost. Yet another type of graph would be one that inspection of a family of such graphs can help identify SLAW options that are clearly inferior to others in all the important dimensions and further help narrow the scope of the decision. The graphs can also help readers visualize the magnitude of the trade-offs between options without requiring the FFRDC to apply any specific sets of weights to the decision-relevant factors. Uncertainty ranges for each key factor can be illustrated by adding ranges in both the vertical and horizontal dimensions around each option’s “dot” in such scatterplots. Use of an array of simple graphics of this sort can help the FFRDC in its own task of narrowing the complexity of its evaluation as well as, ultimately, to communicate about the decision-relevance of the key factors to readers of the FFRDC report in an accessible and intuitive manner.

2.1.3 Organizing the FFRDC Analysis

In addition to narrowing and defining the influence of the factors, the forthcoming FFRDC report needs to enable DOE and stakeholders to compare a limited number of alternatives according to the most decisionally relevant subset of factors. Using the FFRDC analysis, DOE will apply whatever process it deems appropriate to make the decisions.

Finding 3: While the FFRDC draft analysis is still at an early phase, identifying major uncertainties (possible range of outcomes and their likelihood) for each factor will be useful for decisionmakers in their deliberations.

Recommendation C: The FFRDC draft report should identify and analyze the major uncertainties in each of the selection criteria assessment results, the implications of the uncertainties, and the cost and benefit of investing in uncertainty reduction within the subset of selection criteria that most clearly differentiates among alternatives that DOE would need to consider in reaching a decision promptly.

2.2 QUESTION 2: DOES THE FFRDC’S REPORT CONSIDER IN ITS ANALYSIS ALL THE ELEMENTS, CRITERIA, AND FACTORS SPECIFIED IN SECTION 3125 OF THE NATIONAL DEFENSE AUTHORIZATION ACT OF 2021?

The committee commends the FFRDC for designing and using a consistent template for the characteristics of alternatives and variants. The committee observes that the FFRDC appears to have done a thorough job of identifying the factors to include in its decision framework. (See Appendix C for a list of relevant factors, as based on Sec. 3125 and Sec. 3134, which are replicated in Appendix A.) In Section 2.1, the committee makes suggestions on how to narrow this comprehensive list (Appendix C) to the factors that seem to offer the best promise of differentiating among alternatives. The committee looks forward to reviewing the FFRDC’s forthcoming efforts in this regard.

Finding 4: The FFRDC has identified all of the relevant factors, criteria, and elements set out in the enabling legislation, and the FFRDC compilation reflects the early stages of its analysis and appears to be making significant progress as evidenced by the systematic definition and characterization of alternatives that reflect what was learned in the first phase study.

Recommendation D: Having identified the relevant factors, criteria, and elements, the remaining analytical task of the FFRDC is to distinguish among them and describe uncertainties in each, as discussed in Section 2.1 of this review report.

In Appendix D, in fulfilling its peer review function, the committee provides several observations on issues that the FFRDC might consider for its forthcoming report. The observations consist of issues relevant for the factors that the FFRDC is analyzing and comments on particular items of text in the FFRDC’s draft framework.

In addition, the following four observations are of particular importance, and the committee believes they should be addressed by the FFRDC in its next report. Specifically, the FFRDC’s draft framework does not yet quantify some factors likely to be useful in discriminating amount alternatives:

1. The benefits and costs of identified approaches: The framework mentions consideration of the benefits, but it indicates that cost estimates are forthcoming.
2. The differences in the performance (post-closure risk, dose, and relation to maximum concentrations in waste acceptance criteria) from potential disposal sites for the waste form produced from SLAW treatment, including technetium-99, iodine-129, and possibly selenium-79, on a system level. Although the draft framework does mention these radionuclides, it does not yet provide a discussion of differences among potential disposal sites for the potential waste forms. Only general information was provided with no specific, detailed comparison information, which will most likely be forthcoming, as indicated by the FFRDC team during the October public meeting.
3. Differences among disposal environments: The FFRDC’s draft framework does not appear to consider any potential modifications to enhance performance such as to the backfill materials in order to reduce releases, except for a brief mention about potential addition of “getters” to some waste forms. There was no mention of other potential modifications to enhance performance, e.g., enhanced engineered cover systems that could be more protective. Such enhancements, if considered, might be important down the road in terms of issues, such as performance risks and public acceptance.
4. The costs and risks in delays with respect to tank performance over time (which was noted in Section 2.1.1 in this review report): The draft framework, however, includes in its treatment approach tables the entry “Potential new tank leaks” and notes “No change from baseline.”