A ton of documents have come out recently. Some are open for public review and input, but are not official public comment periods. Some are just food for thought. We wanted to share them with you and let you know we’re digging in and we’ll be in touch when we have more information.
Federally Funded Research Development Council Supplemental Low-Activity Waste Report
In January 2023, the Federally Funded Research Development Council (FFRDC) issued its final report to the National Academy of Sciences (NAS) on supplemental low-activity waste. Through the 2017 National Defense Authorization Act, Congress tasked the U.S. Department of Energy (USDOE) to contract with the FFRDC “to conduct an analysis of approaches for treating the portion of low-activity waste at the Hanford Nuclear Reservation.” Savannah National Labs, a USDOE contractor, was assigned the job of comparing three different waste forms for Hanford’s supplemental low-activity waste: vitrification, fluidized steam bed reforming, and grout.
Starting in 2018, the FFRDC analyzed the options for supplemental treatment and wrote a report, that was then reviewed by the NAS. During this review process, the NAS solicited comments and concerns from WA State, tribal governments, stakeholders, and the public. The NAS provided a report back to the FFRDC, including questions and recommendations for the next iteration of the report. The process began again, with the FFRDC reviewing the NAS report recommendations, followed by another analysis that considered those recommendations. This happened five times. We are on round six of the NAS review of the FFRDC results.
In April 2023, the NAS will publish a final review of the FFRDC’s report. The final FFRDC report and NAS review will go to USDOE, which will pass the reports on to Congress, along with comments from the State of Washington.
You may be wondering, what is supplemental low-activity waste? Here’s the short version: the Hanford Site has 56 million gallons of high-level nuclear waste stored in 177 underground tanks. The plan is to separate this waste into two different waste streams (high-level and low-activity) and immobilize it in glass (vitrification). The Waste Treatment Plant (WTP) will vitrify the waste, but it was never designed to treat all of Hanford's tank waste. The portion of the tank waste that the WTP can't handle is called supplemental low-activity waste.
The amount of tank waste that won't be treated by the WTP is huge—56 million gallons. You're probably wondering; wait, but aren't we starting with 56 million gallons of high-level waste? It’s confusing. The total waste volume increases because liquid is being added to the waste during the treatment process to immobilize the tank waste, thus essentially doubling the volume of waste that requires treatment. The FFRDC is looking at options for how to treat the waste that the WTP won’t be able to handle. Keep an eye out for the final NAS report in April.
Analysis of Alternatives for High-Level Waste Treatment
Due to technical issues that plague the vitrification (immobilization in glass) of high-level tank waste, discussions are underway to find new paths forward that fix issues and make achievable paths forward to getting that high-level waste in glass. This document is a study that analyzes potential options for preparing high-level tank waste for vitrification. Fair warning, it is a super confusing document. USDOE has plainly stated that it does not include a preferred alternative. As we understand it, the Analysis of Alternatives is being used by decision makers to figure out the path forward. However, it is not a decision document. You can comment on the Analysis of Alternatives here, but it's not an official public comment period. USDOE is only requesting feedback. Comments are due April 28, 2023.
Final Waste Incidental to Reprocessing Evaluation for the Test Bed Initiative Demonstration
The Final Waste Incidental to Reprocessing (WIR) Evaluation for the Test Bed Initiative (TBI) is part of the push for grout—to test using grout as a way to immobilize tank waste and clear the path for scaling it up. The plan is to pretreat 2,000 gallons of SY-101's tank waste inside the tank to remove cesium. Then the waste would be shipped offsite, likely to Perma-Fix Northwest, and mixed with grout. The grouted waste would be shipped to an offsite disposal facility in Texas or Utah for final storage.
The way the United States classifies nuclear waste determines how it must be treated and disposed. One category of nuclear waste is high-level waste. Federal law defines high-level waste by its source—how it was created. High-level waste comes from reprocessed spent (used) nuclear fuel and requires permanent isolation.
WIR is the method that USDOE is currently using at Hanford to reclassify high-level waste. The WIR process focuses on three criteria:
As fully as possible, key radionuclides must first be removed from tank wastes.
All applicable (10 CFR 61C) safety requirements must be met.
Wastes must be in a solid form with radionuclide concentration limits not exceeding Class-C low-level waste (10 CFR 61.55).
The WIR process was created by USDOE through an internal order declaring that they could redefine high-level waste on their own. This process has never gone through a formal public review. It isn’t a rule, regulation, or law.
The WIR process was challenged in 2002, resulting in a federal court decision declaring that the WIR determination was contrary to the federal law.
The labeling of nuclear waste as high-level or low-level is very important, because it determines what rules and restrictions apply to the final disposal of the waste. High-level waste must be immobilized in glass and buried in a deep geologic repository, while low-level waste can be buried in a near-surface landfill.
This document addresses how USDOE would use the WIR process to change the classification of 2,000 gallons of tank SY-101's liquid waste from high-level to low-activity in order to immobilize the waste in grout and ship it offsite for disposal. A WIR Determination was issued on the same day as the Final TBI WIR Evaluation. The WIR Determination declares 2,000 gallons of tank SY-101's liquid waste to be other than high-level waste.
Hanford Challenge's concern is that while we support efforts to vitrify Hanford's tank waste, we don't believe that USDOE should use the WIR process to reclassify this waste, and should instead be using a Nuclear Regulatory Commission determination. The use of WIR was found to be contrary to the law under the Nuclear Waste Policy Act.
Final Waste Incidental to Reprocessing Evaluation for Vitrified Low-Activity Waste Disposed Onsite at the Hanford Site
This document is an updated evaluation of USDOE’s position that treated and vitrified liquid tank waste will result in low-level waste that can be disposed of onsite, in a shallow landfill, at the Integrated Disposal Facility. A WIR Determination was issued on the same day as the Final VLAW WIR Evaluation. The WIR Determination declares vitrified low-activity waste to be other than high-level waste. See above for an explanation of WIR and Hanford Challenge’s position.
This material is funded through a Public Participation Grant from the Washington State Department of Ecology. The content was reviewed for grant consistency, but is not necessarily endorsed by the agency.