Movement of Cesium/Strontium Capsules to Dry Storage
The Waste Encapsulation and Storage Facility (WESF) in the Central Plateau holds 1,936 capsules of cesium and strontium that were removed from tank waste and stored underwater. These capsules represent approximately one-third of the total amount of curies at the Hanford Site. WESF was not built for permanent storage of cesium and strontium and the facility presents a significant risk and long-term mortgage cost. The Hanford Communities support the ongoing effort to move the capsules to dry interim storage as soon as possible, and we encourage DOE to release a schedule to the public that delineates when this will be completed.
Tank Farm Operations
Funding for Tank Farm operations must be adequate to prepare for waste treatment and ensure maintenance of the aging infrastructure in a safe configuration while waste is removed from tanks. Enhanced surveillance confirms assessments that tanks are routinely exceeding design life. Two single-shell tanks (SSTs) are actively leaking, 34 SSTs have indication of intrusion, and 58 SSTs plus one double-shell tank have leaked. Elimination, or proactive action to address the risk, must continue to be a top priority. Additionally, the Hanford Communities encourage the Department of Energy to adhere to the Agreed Order between Ecology and DOE to develop enhanced response to leaking tanks.
DOE and its regulators must also proceed with closing the C Farm tanks with grout, which will prevent tank collapses and intrusions. Retrieval of C-Farm was completed several years ago; however, Ecology has not taken action to allow DOE to proceed with tank closure. We call on DOE and Ecology to move forward on plans to begin grouting C-Farm to protect the workforce, environment, and to allow closure of these waste management areas.
Great progress had been made in recent years on groundwater remediation with the completion of pump and treat facilities. However, groundwater remediation is far from complete, and these efforts must be continued across the Hanford Site. In addition, the existing systems should be optimized to reach their full capacity and be able to respond to emerging conditions in the tank farms or elsewhere in the Central Plateau. This is essential to ensure the protection of the Columbia River and prevent the migration of contamination from the Central Plateau to the River Corridor.
Tank Waste Treatment
The Hanford Communities believe that removing waste from the tanks, stabilizing and immobilizing the material, and putting it into safe storage to reduce risk must continue to be a high priority for the cleanup effort. The tanks are aged, and there is a possibility that there could be another leak in a Double Shell Tank (DST) that could significantly impact available tank space. It is also imperative that the Tank Farms are prepared to safely and reliably deliver waste feed to the WTP. Great progress is being made at WTP with commissioning and the transition to start-up of the Direct Feed Low Activity Waste Facility (DFLAW). Successful operations of the Tank-Side Cesium Removal (TSCR) system will also aid in addressing the tank waste issues and prevent unnecessary spending to construct new tanks. We encourage DOE to acquire additional modular systems like TSCR instead of proceeding with new large capital facilities that require substantial budgets and long schedules to construct, commission and eventually decommission. TSCR units have been shown to be cost effective and reliable. Multiple units will enable consistent feed to both DFLAW and to parallel, out of state, disposal pathways.
The Hanford Communities is also very supportive of pursuing grout as a treatment method for Hanford’s Supplemental Low Activity Waste (SLAW). Analyses from the Government Accountability Office (GAO) and the National Academies of Science, Engineering, and Medicine (NASEM) show that grouting has the potential to reduce costs by billions of dollars while permanently eliminating the risk from tank waste sooner. The Hanford Communities encourages DOE and its regulators to move forward with Phase 2 of the Test Bed Initiative (TBI) as expeditiously as possible. Furthermore, DOE and its regulators should establish a goal to commercially grout and dispose of 500,000 gallons of Hanford’s low activity waste outside of Washington state by the end of FY 2025.
The Hanford Communities believe it is critical for DOE to remediate the radiological waste site underneath the 324 Building and continue remediation efforts in the 100 K Area as quickly as possible given their close proximity to the Columbia River and/or the City of Richland. DOE should issue a schedule for the public to monitor progress on measurable activities to accomplish this work.
Legacy Facilities, High Risk Mitigation
Subsequent to the PUREX tunnel collapse, additional high-risk situations have been identified as requiring mitigation. The Hanford Communities believe it is critical for DOE to continue to proactively address the highest risks across the Hanford Site.
Waste Treatment Plant (WTP) Diesel
The Hanford Communities remains concerned about plans to burn tens of thousands of gallons of diesel per day at full operation of the WTP. DOE is encouraged to explore opportunities to use steam from a proposed new advanced nuclear reactor (supported by DOE’s Advanced Reactor Demonstration Program) to provide steam for the WTP, and to look at biodiesel, hydrogen or other promising technologies as well.
Grout Treatment of Low Activity Waste
The Hanford Communities is encouraged by the report issued by the Federally Funded Research and Development Center (FFRDC) in April 2022 analyzing approaches for supplemental treatment of the low-activity waste (LAW) from Hanford’s tanks. The report provided a strong recommendation that DOE quickly develop and implement multiple pathways for grout treatment and offsite disposal of the LAW in parallel with DFLAW. The report indicates the timeframe to complete the tank waste treatment mission could be reduced by at least 15 years, save up to $111 billion, and increase the probability of successful mission completion from “very low” to “very high.” In addition, all the grouted waste would be disposed outside of Washington state at much more suitable locations, resolving Tc-99 and I-129 groundwater concerns at Hanford.
Unfortunately, the report indicates that the Washington State Department of Ecology and DOE are still struggling with definitions of LAW and HLW. Science, not politics should determine the correct definitions. The Hanford Communities call on DOE and Ecology to meet the FFRDC recommendation by using waste treated by the Tank Side Cesium Removal (TSCR) system by completing the Test Bed Initiative demonstration by the end of 2023, completing 500,000 gallons by the end of 2025, and fully implementing the recommendation with multiple pathways to grout 2,000,000 gallons/year of LAW with offsite disposal in 2027.
Disposal of Waste Outside of Washington
The Hanford Communities is aware of the opportunity to ship and permanently dispose of low-level waste (LLW), mixed LLW, and TSCR resin outside of Washington state at existing permitted commercial facilities. These disposal facilities have no credible pathway to groundwater, unlike disposal at Hanford. A significant portion of the inventory of risk-driving constituents (e.g., 99Tc and 129I) could be disposed at these off-site facilities to provide long-term environmental protection to the aquifers underlying the Hanford Site and the Columbia River. Taking this approach, along with grouting the supplemental low-activity fraction of the tank waste, would provide the capability to achieve the most rapid reduction in the amount of waste stored in Hanford’s tanks, and therefore would result in the most rapid reduction in risk to human health and the environment attributed to potential future tank leaks. The Hanford Communities call on DOE and Ecology to engage with the Tri-City community and regional tribes to begin implementing this approach without delay.