Review of the Final Draft Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation Review #3 (2019) / Chapter Skim
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treatment facility 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. Supplemental treatment refers to processing of the low-activity waste that is excess to that portion to be treated by vitrification in the Waste Treatment and Immobilization Plant.
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The objective of the SLAW treatment is to ensure that the solidified wastes can be permanently disposed of in a near-surface land disposal site. 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.
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These involve very large annual appropriations, which are inevitably uncertain over the planned decades of activity, especially because current planning assumptions anticipate a two- or three-fold increase in expenditures at certain points in the SLAW treatment process. This, too, introduces the possibility that funding shortfalls will lead to longer schedules, increased total costs, and higher chances of additional tank leaks or structural failures, which will themselves increase costs as well as health and environmental risks.
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over time for all of the long-lived radionuclides that are listed in Table F-2 of their report, not just iodine-129 and technetium-99. Finding 3-4 The FFRDC report gives little consideration in its analysis to the environmental, health, and safety consequences of hastening or further delaying remediation of the Hanford waste storage tanks, which is related to the probability that additional tank leaks or structural failures will occur over the long period of time expected for the removal and treatment of the waste in the tanks.
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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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The draft report should either be substantially revised and supplemented (though the committee understands that the FFRDC team's funding may not permit this) , or be followed by a more comprehensive analysis effort and associated decisional document, which needs to involve the decision-makers or their representatives.
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Other factors that would affect the selection of a SLAW treatment alterna tive include: The costs and risks of delays in making decisions or funding shortfalls in terms of additional resource requirements and the increased chance of tank leaks or structural failures over time, and the need to address the consequences (notably, all 149 single-shell tanks have exceeded their design life and the 28 double-shell tanks will have exceeded their design life before the waste is slated to be removed) ; DOE's proposed reinterpretation of the definition of HLW waste could change the SLAW size and performance requirements by altering the feed volume and composition depending on how the reinterpretation is implemented; Thorough consideration of the experience at other DOE sites (e.g., Savannah River Site)
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Review of Final Draft Analysis of Treatment Approaches of LAW at Hanford Nuclear Reservation: Review #3 Consideration of Parallel Approaches Recommendation 4-1 The FFRDC report could also provide the springboard for serious consideration of adopting an approach of multiple, parallel, and smaller scale technologies, which would have the potential for: a. Faster startup to reduce risks from tank leaks or structural failures if adequate funding is available to support parallel approaches; b.
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