Review of the Continued Analysis of Supplemental Treatment Approaches of Low-Activity Waste at the Hanford Nuclear Reservation Review #3 (2023) / Chapter Skim
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4 Report Limitations
4 Report Limitations
Pages 21-32
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From page 21... ...
The FFRDC report should not be used in a vacuum. Rather, decision makers must integrate the AoA, consent decree, holistic negotiations, and especially the regulatory approval and public acceptance criteria, in reaching a final decision on how to manage supplemental low-activity waste (SLAW)
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From page 22... ...
Finding 18. Based on the necessity of regulatory approval and public acceptance for any final SLAW decision, assumptions about regulatory approval and public acceptance appear frequently in the FFRDC report, despite its disclaiming consideration of Criteria 5 and 6.
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From page 23... ...
Recommendation D The FFRDC's decision framework excludes regulatory approval and public acceptance (Criteria 5 and 6)
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From page 24... ...
In brief, this single graph makes a defensible technical case in favor of the FFRDC's recommendation to expeditiously move in the direction of developing grouting as a pathway for managing SLAW. The primary question left for decision makers, therefore, is to evaluate whether issues of regulatory approval hurdles or public acceptance are so significant in the case of grout to overcome the technical advantages of every one of the various grouting options in the FFRDC report (or other variants not actually in the FFRDC evaluation such as grouting through modular facilities on-site, followed by on-site or off-site disposal)
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From page 25... ...
." With regard to the assumed $450 million/year budget constraint, and assuming a 4 percent escalation factor for capital expenditures (CAPEX) , vitrification is estimated to exceed that budget by $10 billion by 2070, as reported in the main FFRDC report (Table F-1)
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From page 26... ...
Thus, while it is a sufficient flat funding level to achieve a net budget neutrality for the vitrification alternative, assuming the 4 percent CAPEX escalation rate, it also would increase the estimated budget surpluses for grouting and FBSR upward by another $10 billion. The committee also notes that if the CAPEX escalation factor assumption is 8 percent, vitrification would still have an estimated budget deficit of $10 billion or more, just as it does for the case in which the funding is $450 million/year with an escalation rate of 4 percent.
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From page 27... ...
The foregoing narrative represents important limitations on the use of the FFRDC's report -- one which the committee believes the FFRDC would endorse as discussed during the round table discussions on February 1, 2023 -- and decision makers will need to develop further technical detail related to the FFRDC's recommendation (in addition to full consideration of the previously mentioned regulatory and public acceptance criteria, which were excluded from the FFRDC analysis) before making a decision.
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From page 28... ...
The FFRDC analysis reviewed here contains a much more detailed analysis of off-site transportation of SLAW for disposal and possible treatment than in the prior FFRDC report. The FFRDC analysis considered off-site options involving grout and FBSR waste forms.
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From page 29... ...
. The current FFRDC report contains a more complete analysis of five criteria that have to be considered for liquid SLAW to qualify as LSA.
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From page 30... ...
. Based on the more thorough analyses underpinning the LSA determination in the current FFRDC analysis as summarized above, it appears that their conclusion "…that untreated supplemental LAW liquids…can be transported in IPs in all off-site disposal options with considerable margin" (Bates, 2022b, Vol.
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From page 31... ...
that such transport and receipt is accepted practice should not be viewed as meaning regulatory approval and public acceptance of sustained transport of large amounts of liquid SLAW would be acceptable without question or contention. DOE should conduct additional and more detailed investigations and assessments of operational feasibility, regulatory approval, and public acceptance at receiving sites and the transportation corridors to improve understanding of the advantages and disadvantages of transporting liquid SLAW before definitely settling on offsite pathways as the solution.
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