L.3.0 DESCRIPTION AND COMPARISON OF ALTERNATIVES
L.3.1 INTRODUCTION
L.3.2 SITE AND WASTE DESCRIPTION
L.3.2.1 Tank Waste
Comment Number 0005.10
Swanson, John L.
Comment On another matter related to tank-by-tank inventory, on page A-2 it is said that "...tank farms were grouped together based on tank contents (inventory)..." Again, what data were used to perform such groupings? The inventory data presented in the EIS, and represented to be used therein, do not allow such groupings to be made. We thus have no way of knowing (or estimating) how valid these groupings are. I detect no special bias here, as I do in the consideration of the combined ex situ/in situ alternatives cases, but the story presented in the EIS should be complete and consistent.
Response DOE and Ecology acknowledge the concern expressed in the comment. The text has been modified to show that the tanks were grouped according to configuration, not according to content. This text modification appears in Volume Two, Appendix A, Section A.2.1.1.
Comment Number 0005.22
Swanson, John L.
Comment On page A-3, it appears to be stated as a fact that the K Basins sludges will be added to the tanks. This is news to me, and I do not believe that it is reflected in other portions of the EIS.
Response One proposed option for disposition of K Basin sludge identified by the 1996 K Basins EIS ROD is to remove and transfer the sludge to the DSTs. If implemented, the final disposition of this waste would be in accordance with the alternative implemented for tank waste management and disposal under the TWRS EIS. The Draft EIS included, in Appendix A, the K Basin sludge inventory as a potential source of new waste to be added to DSTs. K Basin sludges are discussed in Volume One, Section 3.4.1 and Volume Two, Appendix A, Section A.2.4.
Comment Number 0005.37
Swanson, John L.
Comment On page 3-11 it is said that "--new leaks are developing in these tanks at a rate of more than one a year." Are data available to support this statement, or is it an assumption that is stated as fact?
Response At the time the Safe Interim Storage (SIS) EIS was published, 67 SSTs were assumed to have leaked over the past 50 years. This number was used to support the statement that leaks would develop at a rate of more than one a year in the future. The saltwell pumping program, which involves removing liquids from the tanks, is expected to slow the rate of corrosion and substantially reduce future leaks (see Volume One, Section 3.4). Data are not available to accurately predict the number of new leaking tanks that will develop. The data identified above provide the best estimate available at the current time. Based on the saltwell pumping program to stabilize the SSTs and for the purposes of analysis in the TWRS EIS, no new leaks are assumed to occur during the 100-year administrative control period. The text of the EIS in Volume One, Section 3.2 has been modified to state that, "... new leaks are developing at a rate of one new tank known or assumed to have leaked per year."
Please refer to the response to Comment numbers 0072.70 (leak detection methods), and 0072.85 (predicted and anticipated future leaks).
Comment Number 0012.14
ODOE
Comment Tank Waste Characterization
The tank wastes are complex and poorly understood. The complex operating history of Hanford tanks has created a situation where the contents and character of the waste in every tank varies significantly from every other tank.
USDOE is working to characterize tank wastes. This should allow USDOE to narrow the uncertainties and mitigate severe hazards such as flammable gas generation. But, the data will not be detailed or accurate enough to ensure the risk assessments can accurately predict the fate of these wastes if they are left in the tanks.
Response The tank wastes are not well characterized on an individual tank basis, but an estimate of overall tank contents can be made. As noted in the EIS in Volume One, Section 3.2 and Volume Two, Appendix A, DOE has implemented a program to characterize tank waste on a tank-by-tank basis, which will be instrumental for resolving tank safety issues and final design activities for waste treatment. This program will aid in narrowing uncertainties regarding the waste in the tanks. However, DOE and Ecology believe that the existing historical data, laboratory data, and characterization reports provide an approximate estimate of tank contents from which the analysis of the tanks alternative can be completed to support the analysis and comparison of potential environmental and human health impact under National Environmental Protection Act (NEPA). The EIS acknowledges the uncertainties involved with the level of knowledge of the tank waste inventory and uses a conservative approach to assessing impacts based on the available data. This approach, known as bounding, provides an inventory of tank wastes that supports a risk assessment that DOE and Ecology believe fairly and objectively informs the decision makers and the public of the potential impacts associated with each alternative and support a comparative analysis of the alternatives. Tank-by-tank characterization will be needed to implement detailed design and operation of the TWRS action. If characterization data become available that are not bounded by the EIS analysis, DOE would complete an appropriate NEPA analysis to support analysis of environmental impacts and, if appropriate, alternatives that address the new data. See Volume Two, Appendix A for a discussion of tank inventory and Volume Five, Appendix K for a discussion of uncertainties.
Comment Number 0072.07
CTUIR
Comment In particular, two aspects are deficient within the TWRS-EIS. First, thorough characterization of the natura and composition of Hanford's chemically and physically ckmplex tank wastes is in its infancy. It is clear that not enough information exists about these wastes within this EIS to adequately support retrieval and treatment needs, let alone facility design(s). If overall planning goals are not well understood in advance, the CTUIR SSRP asks, how will it be possible to design retrieval, treatment, and disposition systems that will meet protective waste management endstate and Tri-Party Agreement goals? This EIS should fit hand in hand with the Hanford sites overall guiding, framework document.
Response Though the characterization program for the tank waste is not complete, the EIS functions primarily as an environmental planning document, not as an engineering design document, and as such, will not include the complete details of programs like tank inventory and characterization or retrieval. As required by the Tri-Party Agreement, the tank waste characterization program will be completed September 1999. Assuming the tank waste characterization sample collection, analysis, and data interpretation must be finalized well in advance of the program, in addition to the reservoir of existing information, sufficient data would be available to support the detailed design of the transfer and retrieval systems, as well as of the treatment facilities. Where appropriate, the EIS incorporates such information by referencing the publicly available information on relevant topics. The locations of DOE Reading Rooms and information repositories containing publicly available information are given in the Summary, Section S.8. For example, the EIS contains references WHC 1995b, WHC 1995o, WHC 1994f, and WHC 1994g pertaining to tank contents and WHC 1994h pertaining to the characterization program. Tank retrieval and blending strategy is the subject of reference WHC 1995p. DOE and Ecology agree that it is necessary to ensure that tank waste remediation decisions are based on this EIS and are consistent with overall goals or designed endstates for the Hanford Site. To this end, the EIS describes the relationships among the alternatives and broader goals and policies, both nationwide and for the Hanford Site. For example, the relationship between the alternatives and tank closure is discussed in Volume One, Sections 3.3, 5.1-5.10, and 6.0. Further, Volume One, Section 6.0 describes the policy and regulatory background, including the Tri-Party Agreement, in relationship to the proposed action. Please refer to the response to Comment number 0012.14.
Comment Number 0072.14
CTUIR
Comment Considering the controversy surrounding the characterization of tank waste, the documentation of the contents of individual tanks and development of the "supertank" inventory should be better.
The entire tank waste characterization strategy needs to be examined and improved.
Response More complete knowledge of the tank contents would be preferable. At present, there is a program of tank characterization which, when completed, will provide information on the contents of each tank. Because that program of characterization is not completed, estimates of tank components were used in the EIS. The documentation of the inventory estimates that were used in the EIS is discussed in Volume Two, Section A.3.0 and in Volume Four, Appendix E (Section E.1.1.3.1). The use of the super tank inventory is specifically discussed in Appendix A (Section A.3.3). The super tank inventory is intended to present the most conservative impacts from an accident so that the effects of accidents will not be underestimated. The super tank concentration of a chemical or radionuclide is the highest reported value that has been measured or calculated for that substance. This means that for assessing the impacts of an accident, a uniform inventory will be used for every accident scenario. For assessment of impacts, the use of this inventory data provides an equitable comparison of impacts. For the Final EIS, Appendix K (Volume Five) has been added to provide expanded information regarding uncertainties including inventory and accident. Please refer to the response to Comment numbers 0012.14 and 0072.07.
Comment Number 0072.67
CTUIR
Comment P 3-2: Sect. 3.2.1.2: Tank farm description: It is indicated here that 67 SSTs have leaked 2.3 million -3.4 million liters of liquids, it would be useful if there were a description on how this was calculated.
Response The estimate for the volume of waste that has leaked from the 67 known or assumed leaking SSTs was taken from the cited reference (Hanlon 1995). The referenced document, titled Tank Farm Surveillance and Waste Status Summary Report is one of a series of periodic reports that contains tank volume data as well as estimates and data for leak volumes from each of the known or assumed leaking SSTs. The methods used to estimate the volume of waste to have leaked varied by tank. The estimating method and the other parameters that impacted the assessment are contained in the footnotes to Table H-1 in the Waste Tank Summary Report for the month ending February 29, 1996 (Hanlon 1996).
Comment Number 0072.68
CTUIR
Comment P 3-4: PP 1: A vadose zone baseline characterization program could not possibly have determined the structure of the region underneath the tank farms given the amount of liquids presumed to have leaked and the large number of unknowns associated with the vadose zone points to an enormous amount of error in the ground water assumptions changing the future predictions on the rate of contaminate transport through the vadose zone will necessarily change the risk.
Response There are uncertainties and unknowns associated with the vadose zone modeling of rate and transport of contaminants from the tanks. Many of the uncertainties were addressed in Volume Four, Sections F.4.3.5 and F.3.4. The impact assessment modeling in Appendix F only addresses impacts from releases associated with TWRS remediation, not past leaks. Additional modeling was performed with evaluations provided in Volume Five, Appendix K that address potential transport mechanisms that may have been active during past leaks. Together, these evaluations and assessments provide the basis for developing appropriate mitigating measures. The response to Comment number 0012.15 contains an extensive discussion of vadose zone contamination issues, particularly uncertainty and subsurface geology.
Comment Number 0072.69
CTUIR
Comment P 3-7: PP 3: S 5: what is the precipitation process for the metal-salt compounds indicated here.
Response The sentence cited in the comment refers to the sludges in the tanks. Sludge is contained in a layer of water-insoluble chemicals that precipitated and settled to the bottom of the tank when the waste liquid from the processing plants was made basic by the addition of sodium hydroxide. Because of their reaction with sodium hydroxide, the sludge compounds are composed of primarily of metal hydroxides. Because the sludge composition may vary and other compounds may precipitate, the precipitate also is termed hydrous metal oxides.
Comment Number 0072.70
CTUIR
Comment P 3-11: PP 3: Bullet 1: How was the rate of leakage determined? Please explain how the control wells or the leak sensors are strategically placed.
Response The statement cited in this comment, taken from the SIS EIS, is as follows: "Removing saltwell liquid from older SSTs to reduce the likelihood of liquid waste escaping from corroded tanks into the environment. Many of these tanks have leaked, and new leaks are developing in these tanks at a rate of more than one per year" (DOE 1995i). This statement was intended to reflect the age, condition, and historical perspective of the SSTs. This statement also reflected the thinking at the time that since 67 SSTs were assumed or confirmed to leak, the leakage rate would continue at more than one per year in the future.
Several methods are used to find leaks. Starting in the early 1960's, vertical monitoring wells, called drywells, were drilled around the SSTs. These wells are called drywells because they do not reach the water table. Approximately 760 drywells, located around the SSTs, are used to measure increases in radiation in the ground caused by tank leakage. Multiple drywells are located around the perimeter of the tanks in order to monitor around the tanks. A second way to detect leaks is to use a lateral drywell. This is a drywell drilled horizontally underneath a tank where the radiation in the soil can be measured by a detection probe. A third way to detect leaks is to lower radiation probes into liquid observation wells inside the tank and measure the radiation as a way to identify the level of liquid. By comparing the current liquid level with the last recorded level, a large leak can be detected. Detecting leaks in SSTs is an imprecise activity. As all tanks continue to age, the number of leaking tanks will likely increase. Please refer to the response to Comment number 0005.37.
Comment Number 0072.71
CTUIR
Comment P 3-11: PP 5: Bullet 3: In the event of loss of institutional control, and the loss of the mixer pump in 101-SY, could the microcrystalline mat reform much stronger and thicker, resulting in greater entrapment of hydrogen and other flammable gases?
Response The loss of institutional control, as an assumed event, would result in the termination of continuing operations at the tank farms. The loss of institutional control would mean that the day-to-day activities concerned with management of the tank wastes would no longer continue. This would mean that the mitigative measures currently being applied to the tank wastes would no longer be performed including the use of the mixer pump in tank 101-SY. The tank would revert to its condition before the mixer pump was installed. Whether the sludge layer would reform much stronger and thicker is unknown; however, this possibility cannot be ruled out. A discussion of potential remediation and post-remediation accidents is contained in Volume One, Section 5.12 and Volume Three, Appendix E. Please also refer to the response to Comment numbers 0040.02 and 0040.03 for more information related to administrative controls and the response to Comment number 0072.80 for discussions of the reason and basis for assuming a 100-year administrative control period.
Hydrogen and other flammable gas deflagration accidents were analyzed in the EIS. For post-remediation accidents, an analysis of the flammable gas deflagration accident, among others, determined that a seismic event would result in bounding case accident conditions and therefore the post-remediation accident presented in Volume One, Section 5.12 is the seismic event.
Comment Number 0072.72
CTUIR
Comment P 3-13: PP 1: This is the first notation on complexing of tank waste, please include a discussion on exactly what is meant by complexing waste.
Response The subject discussion regarding the SIS EIS ROD is provided in the EIS to inform the reader of planned activities to address urgent safety or regulatory compliance issues. The discussion of complexed and noncomplexed waste with respect to tank 102-SY was presented in the SIS EIS (DOE 1995i). A definition of complexed and noncomplexed waste is also provided in the glossary of the TWRS EIS. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted. Please also see the response to Comment number 0072.170 for more information about complexed waste.
Comment Number 0072.73
CTUIR
Comment P 3-13: PP 2: S 3: What part if any has the DOE done to insure that the affected tribes are involved and kept up to date with the transfer of responsibility, accountability, and liability?
Response The phased approach to implementation of the alternatives is discussed in Volume One, Section 3.3. Contracting strategy is not an issue addressed in the EIS. However, DOE recognizes the importance of maintaining an interactive relationship with the affected Tribes. Informal discussions as well as meaningful consultation and cooperation result in better understanding of important cleanup issues.
In the developing months of the privatization effort (Spring/Summer 1995), invitations were issued to the affected Tribes to present the initially envisioned concept. Letters and follow-up communiqués were issued to J.R. Wilkinson, Hanford Program, Confederated Tribes of the Umatilla Indian Reservation (CTUIR); Donna Powaukee, Environmental Restoration and Waste Management (ERWM) Manager, Nez Perce Tribe; and Russell Jim, Confederated Tribes and Bands of the Yakima Indian Nation. Of the invitations, only the Nez Perce requested and participated in a discussion of the project with a DOE representative and staff. Follow up correspondence addressing questions and concerns was issued August 1995.
Following issuance of the TWRS Request for Proposals (RFP) (February 1996), a request was made for a copy by Joseph H. Richards, Environmental Compliance Auditor, CTUIR on February 23. The following day, the document was forwarded to him.
Progress reports and status updates are routinely provided to the Hanford Advisory Board, which has Tribal representation. This is not to suggest that interactions with the Board substitutes, or may be conducted in lieu of, both formal and informal interactions with the Tribes. DOE encourages such interactions and welcomes opportunities to discuss important cleanup activities with the Tribes. An in-depth discussion of the Tribal consultation process for the TWRS EIS is presented in the response to Comment number 0072.252.
Comment Number 0072.74
CTUIR
Comment P 3-13: PP 2: S 7: The CTUIR agrees that the plan for privatization is subject to the final record of decision of the TWRS EIS.
Response The TWRS EIS ROD will document the decision for how to remediate the tank waste. DOE intent in preparing the schedules for the TWRS EIS and the award of Phase 1a contracts was to have the EIS ROD completed prior to the contract award. To ensure that the award of contract could proceed in the event of a schedule disruption to the EIS ROD, DOE clarified in the final RFP that action under the contract would be contingent on the outcome of the TWRS EIS ROD, a decision which would be considering other alternatives and, if chosen, might necessitate renegotiating or voiding the contract award.
DOE NEPA Implementing Procedures (10 CFR 1021) require DOE to "complete its NEPA review for each DOE proposal before making a decision on the proposal (e.g., normally in advance of, and for use in reaching, a decision to proceed with detailed design)" (10 CFR 1021.210 [b]). The November 1995 draft RFP indicates that Phase 1a is intended as a "development period to establish the technical, operations, regulatory, and financial elements required in privatized facilities." It is only in Phase 1b that the selected contractors will provide detailed, complete design, and be authorized to proceed with construction and operations. These circumstances and requirements comply with NEPA procedures that provide for submittal of environmental data and analysis by offerors and incorporation of an environmental synopsis of that data and analysis in any NEPA document prepared (10 CFR 1021.216 [h]), as long as the actions taken prior to beginning detailed design do not "have an adverse environmental impact" or "limit the choice of reasonable alternatives." Based on the planned Phase 1 approach of splitting the action into two subphases, DOE would be able to proceed with Phase 1a (conceptual design) prior to completion of the TWRS EIS ROD and be within the intent of NEPA. However, the TWRS EIS ROD would be required prior to the anticipated April 1998 award of Phase 1b contracts.
Comment Number 0072.80
CTUIR
Comment P 3-21/22: while it is acknowledged that NEPA requires that an EIS includes a no-action alternative, it should also be acknowledged that leaving leaking tanks violates several laws, regulations, and statutes. Also, no-action would not necessarily be a "continue the current waste 'management' program." It would more likely be a walk-away situation where institutional controls fail.
Response The No Action alternative would result in failure to comply with Federal and State laws and regulations. This information is presented in Volume One, Section 6.2 and in the Summary, Section S.7. EIS Sections S.7, 3.4, and 6.2 describe the Federal and State compliance issues applicable to the No Action alternative. DOE guidance on NEPA requires that EIS alternatives be addressed regardless of "conflict with lawfully established requirements" (DOE 1993d). DOE is required to identify the laws and regulations that apply to each alternative and indicate whether the alternative, if selected, would comply with applicable laws and regulations (40 CFR 1502.2d). Please refer to the response to Comment numbers 0093.02 and 0072.52.
Guidance on the implementation of NEPA Council on Environmental Quality (CEQ) Memorandum to Agencies: Forty Most Asked Questions Concerning CEQ's National Environmental Policy Act Regulations states the following.
Section 1502.14(d) requires the alternatives analysis in the EIS to "include the alternative of no action." There are two distinct interpretations of "no action" that must be considered, depending on the nature of the proposal being evaluated. The first situation might involve an action such as updating a land management plan where ongoing programs initiated under existing legislation and regulations will continue, even as new plans are developed. In these cases "no action" is "no change" from current management direction or level of management intensity. To construct an alternative that is based on no management at all would be useless academic exercise. Therefore, the "no action" alternative may be thought of in terms of continuing with the present course of action until that action is changed.
In the case of the TWRS program, there is an ongoing program to safely manage the tank waste that would continue under any reasonable scenario for the 100-year administrative control period. For this EIS, no action is assumed to be no effort other than the safe management practices currently conducted. The "walk-away" alternative was not evaluated, because it would present an imminent danger to human health and the environment and would be a useless academic exercise.
Comment Number 0072.81
CTUIR
Comment P 3-24: last paragraph: exactly what does "enough waste would be remediated"? Does this mean that the characterization of the tanks, tank farms, intra-tank, tank mixtures, solubility mixtures would be done on a pilot scale in ten years on an order of magnitude to justify 1.6 billion dollars of set-aside moneys. Is this amount of money justified in terms of removal of tank waste, lowering of risk, characterization, and achieving Tri-Party Agreement milestones.
Response The referenced language means that a sufficient quantity of waste would be remediated during Phase 1 to prove that remediation would be effective for the entire remediation program. The sentence was modified in Volume One, Section 3.3 as follows for clarification. "A sufficient quantity of a variety of tank waste types would be processed to demonstrate the effectiveness of the process and to provide the necessary data to design a full-scale facility." Please refer to the response to Comment number 0005.38.
Comment Number 0072.168
CTUIR
Comment P A-1: Sect. A.2.1: It is appropriate to list the estimated radionuclide and non-radionuclide inventory for each tank or tank farm for comparison.
Response Please refer to the response to Comment numbers 0012.14 and 0072.07. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0072.169
CTUIR
Comment P B-8: What is actually in the miscellaneous underground storage tanks? The characteristics of an expected waste indicates a need for a comprehensive characterization, even if the total combined inventory of MUSTs volumes is less than one half of one percent of the total tank inventory.
Response Please refer to the response to Comment numbers 0012.14 and 0072.07 for issues related to tank waste characterization. Please also refer to Comment number 0072.99 for MUST content information. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0072.170
CTUIR
Comment P B-10: What are the characteristics of concentrated complexant waste?
Response Concentrated complexant waste is the concentrated aqueous raffinate from strontium-90 liquid-liquid extraction operations performed in the 1960's and 1970's. This waste is a component of the wastes in the AN and SY tank farms, although some is in the DSTs because of saltwell pumping. It is characterized by a high organic content including the complexants ethylenediaminetetraacetic acid (EDTA), citric acid, and hydroxyethylenediaminetriacetic acid (HEDTA).
Comment Number 0072.171
CTUIR
Comment P B-12: PP3: Please explain what is meant by 'have or may have' greater than 50,000 gal of drainable liquid.
Response The section describes the installation of liquid observation wells in the tanks. The criteria for installation is the presence, or suggested presence, of at least 50,000 gallons of drainable liquid. The criteria retains the provisional phrase 'have or may have' because the exact quantity of liquid remaining in the saltcake will not be known until the liquid has been removed and its volume is measured.
Comment Number 0072.172
CTUIR
Comment P B-12: PP4: How many and how often are radiation measurements taken in the drywells?
Response Radiation measurements taken in the drywells are included in the discussion of ongoing tank monitoring and maintenance activities and are one of the methods used to monitor for tank leaks in Volume One, Section 3.2 and Volume Two, Appendix B. Two drywells at two SSTs (tanks 241-C-105 and 241-C-106) are currently monitored monthly by gamma radiation sensors. The remaining tanks are monitored by the TWRS program periodically based on the need to detect potential new leaks and/or to document the extent and nature of past leaks.
Comment Number 0072.173
CTUIR
Comment P B-16: PP5: Please re-do this paragraph. It is confusing and could be better written. For example, the description of the majority of radioactive elements in the sludges needs to be expanded and an indication needs to be made whether the sludges are at the bottom of the tanks or elsewhere.
Response The referenced paragraph provides a generic description or overview of the waste in numerous tanks rather than in individual tanks. The three types of waste (i.e., liquid, sludges, and saltcake) are present in the individual tanks in varying combinations and proportions. For example, sludges may be located at the bottom of the tank, caked along the side of the tank, or both. Although there is a considerable amount of tank waste inventory available from process records and past sampling activities, this information is not considered adequate to characterize the waste in individual tanks. However, DOE is actively involved in an ongoing waste characterization program that is using waste sampling and analysis, in situ measurements, monitoring, surveillance, and waste behavior modeling to provide more detailed and accurate characterization data for the content of individual tanks. Current agreements among DOE, Ecology, and EPA require that all characterization reports be issued by September 1999. Volume Two, Sections A.2 and A.3 present additional information on the tank inventory data including the estimated radionuclide inventory for SSTs and DSTs, ongoing tank characterization programs, and tank inventory data accuracy and its effect on the EIS. Please refer to the response to Comment numbers 0012.14 and 0072.07. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted.
Comment Number 0072.174
CTUIR
Comment P B-18: PP3: The statement, "upgrade the regulatory compliance status" implies that the DOE may not be in compliance even after they complete the SIS EIS activities.
Response In the context of the TWRS EIS alternatives, the referenced statement regarding the SIS EIS refers only to the compliance status of the cross-site transfer portion of TWRS. Installing the cross-site transfer pipeline would comply with applicable regulations whereas the existing cross-site transfer pipeline does not. It is DOE policy to conduct its operations in an environmentally safe and sound manner in compliance with applicable environmental statutes, regulations, standards, and the Tri-Party Agreement. Routine operations at the tank farms include monitoring and maintaining the regulatory status, and operations and maintenance of facilities and equipment. However, upgrading the regulatory compliance status as part of the process of placing the tank farms in a controlled, stable condition involves multiple and continuing activities, particularly as facilities age. The EIS addresses upgrades specific to the waste transfer system (Volume Two, Section B.3). The cross-site transfer system and upgrades under the TWRS EIS are actions identified in the Tri-Party Agreement Resource Conservation and Recovery Act (RCRA) compliance provisions. Volume One, Sections 1.1 and 3.2 provide additional information regarding how the SIS EIS and TWRS are interrelated. Volume One, Section 6.0 describes the statutory and regulatory requirements potentially applicable to TWRS.
Comment Number 0072.175
CTUIR
Comment P B-20: PP1: If the goal of privatization has a component that transfers a share of accountability and liability to industry, have the affected Tribes been properly notified and consulted regarding this? If so, when and with whom were the notifications and consultations addressed to?
Response Please refer to the response to Comment number 0072.73.
Comment Number 0072.176
CTUIR
Comment P B-20: PP2: Once again the statement "upgrade the regulatory compliance status" indicates that even after the current planned upgrades the tank farms may not be in compliance. The planned upgrades listed including instrumentation, ventilation, and electricity is supposed to place the tank farms in a controlled stable condition. Please bring forth a discussion on how these three upgrades will accomplish this.
Response DOE and Ecology acknowledge that even after the current planned upgrades, the tank farms may not be in full compliance. However the upgrades are required by the Tri-Party Agreement which is the RCRA enforcement agreement among DOE, Ecology, and EPA. The upgrades when completed along with other projects such as the saltwell pumping program will result in the attainment of controlled onsite conditions for the SSTs. Upgrades to the instrumentation, ventilation, and electrical systems are not included in the scope of this EIS; however, these activities are the subject of other NEPA documents. Please refer to the response to Comment number 0072.174. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0077.01
ODOE
Comment More than a million gallons of high-level wastes have already leaked from these tanks, threatening the aquifer and the groundwater. Plutonium and americium from one tank leak at Hanford have migrated over 100 feet through the soil and may have reached the groundwater. A third of the tanks have been placed on a "watch" list because of the danger of explosions.
Response DOE and Ecology concur the magnitude and complexity of the tank waste issues that constitute the purposes and need for the TWRS action. DOE must implement decisions to manage and dispose of tank waste to reduce existing and potential future risk to the public, Site workers, and the environment. The EIS includes an analysis of alternatives to manage and dispose of tank waste. The analysis of impacts includes potential impacts to groundwater in Volume One, Section 5.2 and Volume Four, Appendix F; remediation and post remediation health impacts in Volume One, Section 5.11 and Volume Three, Appendix D; and remediation and post-remediation accidents, including the risk of explosions, in Volume One, Section 5.11 and Volume Four, Appendix E. The cumulative impacts of past leaks and TWRS actions are presented in Volume One, Section 5.13. Please refer to the response to Comment numbers 0072.61 (estimates of tank volume thought not to have leaked), 0072.63 (leak volume thought to be cooling water) and 0072.67 (leak volume estimating methods) for more information about tank leaks. Current methods used to detect leaks are discussed in the response to Comment number 0072.70.
Comment Number 0089.10
Nez Perce Tribe ERWM
Comment Page A-13, Table A.2.1.2
The Table delineates the soluble and insoluble portions of chemical species. This information is useful, but it would be helpful to see a listing of the chemical compounds rather than just anions and cations listed separately. A better understanding of tank chemical processes is possible with a listing of chemical compounds.
Response DOE and Ecology concur that more complete knowledge of the tank contents, including the exact nature of the chemical compounds would be advantageous. At present, there is a program of tank characterization which, when completed, will provide greater depth of knowledge as to the contents of each tank. Because that program of characterization is not yet completed, estimates of tank components were used in the EIS. Information on the chemical compounds within the tanks is limited. The inventory estimate provided for use in the EIS (WHC 1995d) gives the chemical species in their ionic form. For purposes of assessing impacts from the release of the tank contents, the use of the ionic forms was sufficient. Please refer to the response to Comment numbers 0012.14 and 0072.07. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
L.3.2.2 Cesium and Strontium Capsules
No comments were submitted for this topic.
L.3.3 DEVELOPMENT OF ALTERNATIVES
L.3.3.1 Tank Waste
Comment Number 0005.17
Swanson, John L.
Comment The fact that tank closure is not included in the analysis seems to me to be a serious deficiency. The statement on S-15 that "Closure is not within the scope of this EIS because there is insufficient information available concerning the amount of contamination to be remediated." seems to me to be a cop-out. You go on to base the analysis that you do on an assumed 1 percent left in the tanks; data given on page S-7 indicate that 0.5 percent of the waste activity has been released or leaked to the ground. Isn't an estimate of 1.5 percent of the contamination to be remediated during closure sufficient information on which to base an analysis? (It is certainly as close an estimate as many of those used in the analyses that were done in this draft).
Response Closure is not within the scope of this EIS because information, such as the nature and extent of vadose zone and groundwater contamination to identify and analyze reasonable closure alternatives is insufficient to support an evaluation of closure alternatives. The Notice of Intent to prepare the TWRS EIS stated, "The impacts of closure cannot be meaningfully evaluated at this time. DOE will conduct an appropriate NEPA review, such as an EIS, to support tank closure in the future" (59 FR 4052). However, some of the decisions to be made concerning how to dispose of tank waste may impact future decisions on closure, so the EIS provides information on how tank waste remediation and closure are interrelated. A single and consistent method of closure was assumed for all alternatives to allow for a meaningful comparison of the alternatives. The closure method used for purposes of analysis was closure as a landfill, which includes filling the tanks and placing an earthen surface barrier over the tanks after remediation is complete. For a discussion of how closure was addressed within the EIS, see Volume One, Section 3.3.
Specific and detailed information on the distribution of contaminants from tank leaks and past practice activities is not available in sufficient detail to provide a meaningful comparison of impacts. When sufficient information is available to evaluate the closure options, DOE will submit a final closure plan to Ecology for review and approval, and an appropriate NEPA analysis will be completed. An extensive discussion of closure and issues related to closure is presented in Comment number 0072.08.
Because the analysis requested in the comment is not within the scope of the EIS, no modification to the document is warranted.
Comment Number 0005.18
Swanson, John L.
Comment The assumptions of a) 1 percent of the contaminants (including the water soluble ones) left in the tanks and b) no attempt to immobilize this residual, lead to a lack of discrimination risk is dominated (by a factor of 100) by the risk of the non-immobilized 1 percent assumed to be left in the tanks. This is a classic case of "assumption driving the conclusion." For the purposes of this EIS, wouldn't it be better to assume a closure approach that would allow differences in the considered alternatives to apparent? It would be strange to me if the same "public" that drove out grout as a LLW form because of perceived contaminant release problems would be willing to accept a situation where the overall release is 100 times greater than that from their preferred waste form because something was not done to immobilize the waste left in the tanks (or to rinse out more than 99 percent of the water-soluble contaminants).
Response As stated in Volume One, Section 3.4, the calculations in the EIS are based on the assumption that the waste residual would be composed of the average tank contents, which is a very conservative assumption because the liquids used to retrieve the waste would remove a high percentage of water-soluble contaminants. The water-soluble contaminants are those that contribute to long-term risks because they can be transported over the long term into the groundwater. In response to the issue raised in this comment and others, calculations have been performed and presented in the Final EIS based on a less conservative content of the residuals where most of the water-soluble contaminants are removed. This provides both a bounding and nominal calculation of risks and provides the public and decision makers with greater information concerning long-term risks. This new information is contained in Section 3.4, 5.2 and Appendix F of the Final EIS. For more information regarding closure assumptions and how closure was addressed in the EIS, please refer to the response to Comment numbers 0005.17 and 0072.08 and Volume One, Section 3.3.
Comment Number 0005.26
Swanson, John L.
Comment Page A-7 contains a statement that conservative values of distribution coefficients"--would ensure that travel times of contaminants were at the upper bound--." Shouldn't that be LOWER bound?
Response The distribution coefficient is defined in such a manner that the constituents with the lowest distribution coefficients are those that travel with a greater velocity. The higher the distribution coefficient, the greater the resistance to movement. Therefore, the text is correct as written.
Comment Number 0005.38
Swanson, John L.
Comment At the bottom of page 3-24 and top of page 3-25, it is said that the Phased Implementation approach Phase 1 would remediate enough waste to prove that the many waste types in the tanks could be remediated effectively. This sounds good, but for it to be true you must have a different Phase 1 in mind that the Privatization Phase 1, which will prove essentially nothing about the pretreatment of SST sludges. (On page 3-92 I find "The waste processed during Phase 1 COULD (emphasis added) also include selected SST waste." This is a much different slant than the statement on page 3-24,-25).
Response The referenced text in Volume One, Section 3.3 has been revised to be less encompassing. It is DOE's intent to process enough different feedstocks (e.g., waste types and compositions) during Phase 1 to demonstrate the treatment processes before implementing Phase 2. Different feedstocks processed during Phase 1 would be expected to demonstrate maximum facility thruput, treatment of high cesium level waste, and treatment of organically complexed TRU and Strontium-90 waste. It is believed that by treating the different waste feedstocks identified during Phase 1, the majority of the waste types present in the tanks, including the SST sludges, would be adequately demonstrated to proceed with Phase 2. As explained in Volume One, Section 3.3, the contracting strategy known as privatization is not within the scope of the EIS. Please refer to the response to Comment number 0072.81.
Comment Number 0022.02
Sims, Lynn
Comment In terms of all human history we are treading on unchartered ground. Here we are confronted with a terrible cold war legacy which threatens our lives and environment. We are engaged in a monumentally serious and expensive undertaking which projects itself far into the future. Our current technology is not totally adequate, but we are morally obligated to do the very best we can NOW and not pass this dilemma to future generations.
We do know we are in this situation because of poor management and inadequate long-term planning during the production years. We do not wish to repeat these mistakes and impose disastrous results upon future generations by shortcomings in clean up decision making now.
Response The magnitude and potential impact of the tank waste are among the most extensive of the Cold War legacies. Moreover, the type and volume of waste and the scale of the technologies required for retrieval, treatment, and disposal are unprecedented. The waste poses substantial potential risks to human health and the environment. The costs for implementing any of the alternatives are substantial, and all alternatives would involve tasks that would continue for many years into the future.
It is for these reasons, among others, the Federal agencies are required to complete an EIS before decisions are made and before actions are taken. This allows decision makers and the public to be aware of the potential environmental consequences of the proposed action and ways to mitigate those impacts and for the public to be involved in decisions that affect the quality of the human environment.
Comment Number 0072.05
CTUIR
Comment The idea of NEPA is to identify and assess the full range of available options and technologies to address an issue -- in this case, the safe, effective, and protective treatment and disposition of dangerous Hanford high-level radioactive and hazardous mixed tank wastes. The current TWRS-EIS focuses only on retrieval of wastes and the explicit thermal treatment option of vitrification. Moreover, although 'closure' is not within the scope of the TWRS-EIS, a number of identified alternatives and considerable discussion throughout the EIS either pre-determine or limit ultimate closure options. The CTUIR SSRP, as a result of their interactions with other federal agencies, have noted that other potentially applicable technologies for tank waste treatment exist. A more broad range of applicable and feasible alternative treatment/disposal technologies needs to be systematically assessed with our consultation.
Additionally, NEPA requires a thorough scoping and assessment of key issues, a systematic set of screening or decision criteria, and a comprehensive consideration of a range of technological (or other) approaches to reach the desired endstate. The current TWRS-EIS examines only a limited set of treatment/disposal options and therefore cannot possibly compare the full spectrum of risks, costs, and benefits of alternative treatment/disposal options.
The Tank Waste Task Force (TWTF) identified that a "portfolio" of options for tank waste treatment and disposition should actively be explored, analyzed, and maintained for contingency planning purposes. The sheer complexity, diversity, and volume of Hanford tank wastes should intuitively mandate such an option-as-necessary-and-available approach.
Response A wide range of potentially applicable technologies exists for treating tank waste. One challenge was to eliminate from consideration technologies that were not viable and develop a range of reasonable alternatives for detailed analysis and presentation in the TWRS EIS. This discussion describes how the alternatives were developed.
There is a distinction between technologies and alternatives. Technologies are specific processes (e.g., cesium ion exchange) that relate to a component (e.g., retrieval or treatment) of an alternative. Alternatives include a set of technologies, or building blocks, that have been engineered to work together, forming complete systems for accomplishing the purpose and need for action. Alternatives are made up of a number of technologies linked together.
The evaluation of potential technologies for inclusion in the TWRS EIS began with a review of available technologies from a variety of sources including the Tank Waste Technical Options Report (Boomer et al. 1993), the Tri-Party Agreement (Ecology et al. 1994), Hanford Defense Waste EIS (DOE 1987), and the engineering data packages prepared by the Site Management and Operations contractor (WHC 1995a, c, e, f, g, h, i, j, and h).
The first step in developing alternatives was to screen out technologies that were not viable. The full range of available technologies for each component of the proposed action was evaluated, and technologies that were not viable were eliminated from further consideration. The technologies eliminated by this screening process are described in Volume One, Section 3.8 and Volume Two, Appendix C.
After rejecting technologies that were not viable, a large number of potential technologies remained for inclusion in the EIS. It would not be practicable to develop alternatives that include all of the potential combinations of technologies. In accordance with NEPA, representative alternatives were developed for detailed analysis to bound the full range of reasonable alternatives (DOE 1993d). Upper, lower, and intermediate bounding alternatives were developed in terms of cost, risk, and technologies for the two primary decisions that affect environmental impacts: the amount of waste to be retrieved from the tanks and the degree of separations of retrieved waste into HLW and LAW. The full range of applicable technologies and alternatives therefore is included in the EIS.
Similar to the approach used by the Tank Waste Task Force, representative alternatives were developed for detailed analysis in the EIS. There are many other viable technologies for individual components of the alternatives that could not be included. These technologies are included in Volume Two, Appendix B and constitute the "portfolio" of options that could be substituted for one of the technologies that is included in an alternative without a substantial change in the impacts of that alternative. An evaluation was performed for each of the technologies identified in Appendix B. Where there would be changes in impacts, the changes are discussed in Appendix B. The level of analysis was dependent on the magnitude of the change on impacts.
The alternatives developed for presentation in the EIS were chosen to be representative of many of the possible variations of the alternative. The design information for all alternatives is at an early planning stage, and the details of the alternative that ultimately is selected and implemented may change as the design process matures. Therefore, the alternatives are intended to represent an overall plan for remediation at a level of detail sufficient for impact analysis and alternative comparisons.
DOE and Ecology are not aware of any other viable technology EIS for tank waste treatment. Please refer to the response to Comment numbers 0005.17 and 0072.08 for a discussion of the reasons closure was not addressed in the EIS.
Comment Number 0072.08
CTUIR
Comment The second major deficient factor is closure, both of waste treatment/disposal facilities and the tank farms themselves. The resolution of the tank waste issues are complex, time-transgressive, and fundamentally impact life-cycle costs. Closure issues, while not within the scope of this EIS, are essential to comprehensive planning for both waste retrieval and treatment from the tank farms. Additionally, closure will significantly impact long-term waste management and land consumption requirements on Hanford's Central Plateau -- a directly connected action which must be specifically assessed and coordinated with the CTUIR SSRP. A specific and incremental plan must be developed to accomplish safe and effective long-term waste management, and this necessarily requires a known endstate goal.
Response The final disposition of the tanks and associated equipment and the remediation of contaminated soil and groundwater associated with leaks from the tanks is a process called closure. Closure is not within the scope of this EIS because there is insufficient information concerning the amount of contamination to be remediated. The amount and type of waste that ultimately remains in the tanks after remediation may also affect closure decisions. The Notice of Intent to prepare the TWRS EIS stated that: "The impacts of closure cannot be meaningfully evaluated at this time. DOE will conduct an appropriate NEPA review, such as an EIS to support tank closure, in the future (59 FR 4052)." However, some of the decisions made concerning how to treat and dispose of tank waste may impact future decisions on closure, so the tank waste alternatives provide information on how tank waste remediation and closure are interrelated. Closure options and assumptions are discussed in Volume One, Section 3.3.1 of the EIS.
Under the Tri-Party Agreement, the tanks are classified as hazardous waste management units that eventually would be closed under the State Dangerous Waste Regulations (WAC 173-303) and the requirements of the Tri-Party Agreement. Three options exist for closure of the tanks. The first option is clean closure, which would involve the removal of all contaminants from the tanks and associated equipment, soil, and groundwater until natural background levels or health-based standards are achieved. The second option is modified closure, which would involve a variety of closure methods and would require periodic (at least once after 5 years) assessments to determine if the modified closure requirements were met. If modified closure requirements were not being met, additional remediation would be performed. Modified closure is a method specific to the Hanford Site Permit under the State Dangerous Waste Regulations (WAC 173-303). The third option is closure as a landfill, which would involve leaving some waste in place with corrective action taken for contaminated soil and groundwater performed under postclosure requirements. This type of closure usually involves the construction of a low permeability cover over the contaminated media to reduce water infiltration and prevent inadvertent human intrusion. When sufficient information is available to evaluate the closure options, DOE will submit a final closure plan to Ecology for review and approval and an appropriate NEPA analysis will be completed.
Although sufficient information is not available to make final decisions on closure, some of the alternatives affect future closure decisions, so information is provided to allow the public and decision makers to understand how the alternatives would be interrelated with future closure of the tank farm system. For example, some of the alternatives addressed in the EIS involve removing most of the waste from the tanks (the ex situ alternatives) and would not substantially affect options for future closure decisions. Conversely, some of the alternatives do not involve removing the waste from the tanks (the in situ alternatives) but rather, would treat and dispose of the waste in the tanks. These alternatives include placing a low permeability cover over the tank farms to reduce water infiltration and prevent inadvertent human intrusion (e.g., Hanford Barrier). This would be considered closure as a landfill. Clean closure would be precluded by implementing one of the in situ alternatives. However, this would not address remediation of the soil and groundwater previously contaminated, so it would not represent complete closure of the tank farms. Therefore, the in situ alternatives would preclude clean closure of the tanks. The ex situ alternatives would not preclude any closure alternative. The decisions on closure will be made in the future when sufficient information is available.
For purposes of comparing the alternatives, a single and consistent method of closure was assumed for all of the alternatives. Closure as a landfill was chosen as the representative closure method for purposes of analysis and is included in all of the alternatives (except the No Action and Long-Term Management alternatives). This does not mean that closure as a landfill is proposed or necessarily would be selected in the future. It is included to allow a meaningful comparison of the in situ and ex situ alternatives and to provide information to the public and the decision makers of the total cost and impacts of final restoration of the Site.
Because decisions on closure cannot be made at this time but are interrelated with decisions to be made on remediation of the tank waste, the EIS presents an analysis of impacts with and without closure in Section 5.0. In each applicable subsection of Section 5.0, the impacts of the activities associated with remediating the waste are presented first. This is followed by the presentation of the combined impacts of remediating the tank waste and closing the tank farms by closure as a landfill. This provides the public and the decision makers with information on the impacts of the issues that are ripe for decision making (remediation of the tank waste) and information on the total project impacts (remediation and closure) as well as how they may be interrelated with the decisions on remediation of the tank waste.
A comprehensive land-use plan (CLUP) is being developed for the Hanford Site, and another NEPA analysis will be prepared on the tank farm closure. The CTUIR will be consulted during the preparation of both documents.
Comment Number 0072.50
CTUIR
Comment It is not clear whether any of the alternatives will allow clean closure, and none of the alternatives include removal of tanks (or support structures).
Response Please refer to Comment number 0072.08 for a discussion of the relationship between the TWRS EIS and future closure decisions. Selection of the No Action, Long-Term Management, In Situ Fill and Cap, In Situ Vitrification (ISV), or Ex Situ/In Situ Combination alternatives would preclude clean closure. The extensive retrieval alternatives would not preclude any closure option. The discussion of closure in Volume One, Section 3.3 was modified to identify which alternatives would preclude clean closure.
Comment Number 0072.51
CTUIR
Comment There is an ongoing problem with failure to define retrieval and closure goals before retrieval is begun. At present, the action plan is to attempt retrieval, and then determine how well we did and therefore whether the tank farms will be closed as a landfill or clean closed.
Response DOE has plans to perform retrieval tests. The project is called The Hanford Tank Initiative and is discussed in Volume One, Section 3.2 of the Final EIS. The information gained from this program will provide data on the effectiveness of a variety of retrieval techniques. The waste retrieval goal is discussed in Volume One, Section 3.4 of the EIS. Please refer to the response to Comment number 0072.08 for a discussion of the relationship between NEPA requirements, the TWRS EIS alternatives, and closure. If an ex situ alternative is selected, the success of retrieval would be a factor in determining the type of closure performed.
Comment Number 0072.75
CTUIR
Comment P 3-18: PP 6: Because closure is not in the scope of this EIS, the CTUIR feels that this EIS is incomplete and actions to correct this should be taken, for example, by designing how a closure plan should be incorporated into this EIS.
Response Please refer to the response Comment number 0005.18 for a discussion of the reasons why tank farm closure alternatives cannot be analyzed at this time. The response to Comment number 0072.08 discusses the relationship between this EIS and future closure options. This response contains a discussion of the relationship between NEPA requirements, the tank waste remedial alternatives
evaluated, and related closure issues. DOE, in the Notice of Intent to propose this TWRS EIS, has committed to complete the appropriate NEPA analysis when data become available to support the analysis. The Tri-Party Agreement contains milestones relative to the preparation and approval of a closure plan for the SSTs.
Comment Number 0072.76
CTUIR
Comment P 3-20: PP 1: The CTUIR SSRP technical staff states that anything less than clean closure would result in excess risk to tribal members.
Response DOE and Ecology acknowledge the preference expressed in the comment and will consider this and other concerns when selecting the final action for TWRS waste. Closure will be addressed in a future NEPA analysis when sufficient data are available to provide a meaningful comparison of closure alternatives. Please refer to the response to Comment numbers 0072.08 and 0072.50.
Comment Number 0072.77
CTUIR
Comment P 3-20: PP 2: For the purposes of comparing the alternatives and as not to preclude ruling out any closure alternatives, the clean closure is, should, and will be replaced in all the following alternatives sections. Additionally it is impossible to do a meaningful comparison between in situ and ex situ alternatives.
Response Tank farm closure was presented in the EIS as a hypothetical closure scenario to demonstrate the relationship between remediation and closure to the public and the decision makers and so in situ and ex situ alternatives could be equitably compared. Using closure as a landfill as the hypothetical closure scenario does not mean that it has been or will be selected for implementation. Tank farm closure will be addressed in a future NEPA analysis when sufficient data are available to provide a meaningful comparison of closure alternatives. Please refer to the response to Comment number 0072.08 for a discussion of the reasons closure alternatives are not appropriate for inclusion in the EIS.
Comment Number 0072.78
CTUIR
Comment P 3-20: PP 3: S 4 : Environmental restoration, waste management, and remediation together which define clean-up have been and are ripe for tank farm decision making. You can not separate a removal process from a closure process and plan for privatization without truly considering the future. This process has to be fair, open, meaningful and involve the complete integration of the affected tribes in order to insure true tank farm closure.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0072.08 for a discussion of the reasons closure alternatives are not appropriate for inclusion in the EIS. Volume One, Section 5.13 of the EIS presents an analysis of the cumulative effects of tank farm remediation and other projects at the Hanford Site. Section 5.13 has been updated to include emerging information concerning the environmental remediation program.
Comment Number 0072.79
CTUIR
Comment P 3-21: PP 4: S 2: Why is it not practical to compare the potential acceptable technologies with the alternatives considering the time and effort used to produce this document? It would seem at the very least to be a reasonable thing to do. If you could not include all of the potential combinations of technologies, how can a reader be sure you have included a full range of applicable technologies?
Response In accordance with the regulations (40 CFR 1500 to 1508) that implement NEPA, the full range of reasonable alternatives were developed and analyzed in the EIS. All other viable technologies and their impacts were also addressed in Volume Two, Appendix B. The purpose of the TWRS EIS was to evaluate reasonable methods or processes (i.e., alternatives) of removing, treating, and disposing of tank waste at the Hanford Site. Including all of the potential combinations of technologies in full alternatives would result in dozens of alternatives to be addressed in the EIS. This would be unmanageable and confusing to the public and the decision makers. Specific removal, treatment, and disposal technologies will be evaluated during the detailed design phase following approval of the Final EIS. Selected technologies will be tested against specific effectiveness and efficiency criteria during the Phase I demonstration (preferred alternative). Please also refer to the response to Comment number 0072.05 and Volume One, Section 3.3 for a detailed explanation of the process used to determine the range of technologies to include in the evaluation.
The Draft EIS addressed the full range of reasonable alternatives. The alternative identified in the comment (i.e., evaluate all potential technologies) is bounded by the alternatives addressed in the Draft EIS, and therefore, DOE and Ecology believe that including the analysis of all the potential combinations of technologies would not provide valuable additional information to the public or decision makers.
Comment Number 0072.177
CTUIR
Comment P B-29: PP2: The in situ alternative may be required by NEPA, but it violates the Tri-Party Agreement. Please insert language regarding this with all in situ alternatives for clarification purposes.
Response The in situ alternatives would not meet the requirements of the Tri-Party Agreement. The Summary, Section S.7 and Volume One, Section 6.2 discuss whether the alternatives meet all applicable laws, regulations, and agreements (including the Tri-Party Agreement). As required by CEQ, the TWRS Draft EIS identifies and analyzes the range of reasonable alternatives for the proposed action. Potential violation of existing laws, regulations, or agreements (any of which may be revised) is not considered basis for eliminating an otherwise reasonable alternative from consideration. Please refer to the response to Comment numbers 0072.80 and 0072.52.
Comment Number 0089.07
Nez Perce Tribe ERWM
Comment Page 3-32, Paragraph 1
The EIS assumed that 99 percent recovery of the tank wastes would be achieved. The remaining 1 percent of tank waste volume left in the tanks will leave a sizable volume of contamination in the tanks to continue to contaminate the vadose zone and groundwater. Future tank closure and soil remediation will not be possible without removal of all tank wastes.
Response The residual waste would likely contain a very low concentration of soluble contaminants because the large volume of liquids used to retrieve the waste would leach the soluble contaminants from the residual waste. The Final EIS presents human health risks based on two scenarios: 1) that the residual waste would contain the average tank contents; and 2) that the residual waste would have been leached to reduce the concentration of soluble contaminants that could be leached into the groundwater. Closure of the tank farms is not within the scope of the EIS. Please refer to the response to Comment number 0072.08 for a discussion of the reasons why closure of the tank farms will be addressed in a future NEPA analysis and 0005.18 for a discussion of the waste retrieval assumption.
Comment Number 0094.01
Moore, Jennifer
Comment I just want to say the thing I find the most disturbing about this EIS, well one of the things I find the most disturbing about this EIS, is the fact that they list not one, not two, but quite a few alternatives which violate the Tri-Party Agreement and other laws and standards. We are dealing with a ... laws which were put so that the public would be protected and that this clean up would keep going at a standard that eventually can ensure that people can live around this area and use the drinking water and basically not live in fear of dying of fatal cancer from being exposed to nuclear waste. The fact the Department of Energy is listing these as viable alternatives, viable options indicates that they do not seem to take the public safety into account very much and somewhat see themselves as above the law which they themselves entered into.
Response The NEPA regulations (40 CFR Parts 1500 to 1508 and 10 CFR 1021) require DOE to evaluate reasonable alternatives even if they do not comply with laws and regulations, so it was necessary to include such alternatives in the EIS. The response to Comment number 0072.80 contains an extensive explanation of NEPA requirements and the criteria used in this EIS to analyze the tank waste alternatives. Please refer to the response to Comment number 0072.05 and Volume One, Section 3.3 for a discussion of how DOE and Ecology identified the alternatives to be analyzed in the EIS. DOE and Ecology's preferred alternative would meet all applicable laws and regulations. Please also refer to the response to Comment numbers 0072.52 and 0072.177.
Comment Number 0097.01
Perry, Henry
Comment Considering that the DOE is representing us, the public, and is playing with more than fire in this situation with the possibility of placing the environment of the entire Pacific Northwest at risk, can there be any question that the EIS, that it prepares, should be prepared on the basis of the worst-case scenario and certainly in accordance with the Tri-Party Agreement previously agreed to.
Response The EIS presents a bounding analysis of the reasonable alternatives. Conservative assumptions and calculation methods are used to provide the public and decision makers with an assessment of the reasonable upper limit of the potential impacts of each alternative if implemented. These assumptions and calculation methods are fully presented in the appendices. The preferred alternative is in full accordance with the Tri-Party Agreement, and in the EIS, the Summary and Volume One, Section 6.2 identify regulatory compliance issues for each alternative. The regulations (40 CFR 1500 to 1508) which implement NEPA and other NEPA implementation guidance discourage the use of "worst case" analyses because these scenarios become unrealistic and blur the differences in impacts between alternatives. The EIS was modified to include an expanded consideration of uncertainties associated with the assumptions and analysis of environmental and human health impacts. The information is presented in Volume Five, Appendix K.
Comment Number 0098.02
Pollet, Gerald
Comment Secondly, in regards to the cost issues, the EIS should clearly compare the cost of the Phased Implementation Tri-Party Agreement path against the risks and costs of the prior Tri-Party Agreement path that were in place for a short period of time before 1994. Under the prior Tri-Party Agreement path, we would retrieve and process approximately twice as much waste by the year 2010 as we will under so-called Phased Implementation. As part of that clear analysis and depiction, the State and the U.S. Department of Energy owe the public and decision makers a clear presentation of the risk each year from delay. In other words, every year you leave more waste in a tank, you have a set of risks. That is why we are hear tonight. You can not deny it. That is ... we all agree that is why we are here. So the question is, does the public deserve to see what is the risk every year from delay. What is the risk from going forward with a path that the General Accounting Office has said may fail. That the State has said is likely to fail. Because of the Department of Energy's contracting decisions which are outside scope of this EIS, but the risks of failure are in the scope of this EIS and need to be disclosed because decision makers for the next decade sitting 3,000 miles away or in the State capital are going to look at this EIS and say, Ah, the risk of another change in the Tri-Party Agreement and another delay in vitrification of 2, 3, 4, 5, 10 years is not so great and we can not let them say that the risks are not so great.
Response The costs of the prior Tri-Party Agreement path are shown in the EIS as the Ex Situ Intermediate Separations alternative costs and the costs of the revised Tri-Party Agreement path are shown as the Phased Implementation alternative costs (without any adjustments for privatization). This information is presented in Volume One, Section 3.4 and Volume Two, Appendix B.
The Phased Implementation alternative would result in less waste being treated during the first 10 years of the project but also would result in all of the waste being treated 4 years earlier than previously required. These two factors would offset each other in terms of releases to the vadose zone before treatment. In any case, the leaks prior to completion are expected to be greatly reduced by the salt-well pumping program, which is currently underway. The Phased Implementation alternative also would decrease the potential for construction of a facility that does not function effectively and thereby reduce the potential for long program delays.
Comment Number 0101.06
Yakama Indian Nation
Comment Invalid Constraints on Scope of EIS Reflecting Lack of Systems Engineering Integration -- The lack of consideration of the impacts associated with the closure of the tank farms following removal of the bulk of the wastes and remediation of the hazardous vadose zone around the tanks is unreasonable, since an integrated systems approach to develop low impact alternatives for tank waste retrieval and tank farm decontamination and decommissioning is warranted to save financial resources and reduce worker exposure. For example, actions required to remediate vadose zones at the tank farms as part of the closure actions may greatly simplify tank waste retrieval actions, reducing costs and expediting retrieval. Cumulative impacts can only be attained when related/integrated actions are evaluated.
Response DOE and Ecology believe that there is sufficient information available to analyze alternatives for remediation of the tank waste even though a number of uncertainties exist for various aspects of the action. These uncertainties are identified in the EIS. DOE is implementing a systems engineering approach to remediation of the tank waste. The integration of tank waste remediation with tank farm closure has been difficult because there is insufficient information available on contamination in the vadose zone and past practice releases. The Notice of Intent to prepare this EIS stated that, "The impacts of closure cannot be meaningfully evaluated at this time. DOE will conduct an appropriate NEPA review, such as an EIS to support closure, in the future" (59 FR 4052).
There is a relationship between closure and tank waste remediation because certain alternatives for tank waste remediation would preclude clean closure of the tank farms. This relationship was discussed in the Draft EIS in Volume One, Section 3.3 on pages 3-18 to 3-20. In addition, a representative closure option, closure as a landfill, was included in all of the remediation alternatives to demonstrate the relationship of closure to remediation and to allow an equitable comparison of the alternatives. This does not mean that closure as a landfill will be selected as the closure alternative, but it provides an assessment of the total potential impacts for the environment. Consistent with NEPA regulations (40 CFR 1500 to 1508), the EIS has been prepared with the most current available information.
The emerging information concerning contamination in the vadose zone was mentioned in the Draft EIS in Volume One, Section 3.4, and the Final EIS has been modified to address the data, as appropriate, in Volume One, Section 4.2 and Volume Five, Appendix K. A systems engineering approach also will be taken to the development of data and engineering when DOE performs a NEPA analysis for closure.
L.3.3.2 Cesium and Strontium Capsules
No comments were submitted for this topic.
L.3.4 TANK WASTE ALTERNATIVES
L.3.4.1 Preferences for Tank Waste Alternatives
L.3.4.1.1 Specific Preferences
Comment Number 0008.06
Evett, Donald E.
Comment I consider the No Action and Long-Term Management alternatives to be unsuitable for consideration. I believe the impact study reveals significant rationale making this alternative too high of a risk, especially for many years into the future.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please also refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives, and the response to Comment number 0072.80 for issues related to the CEQ, NEPA and the 100-year administrative control period.
Comment Number 0009.07
Broderick, John J.
Comment This alternative (Ex Situ/In Situ Combination) has acceptable risks to workers and offsite public. The other alternatives do not have a significant reduction in fatalities. (About 75 in 10,000 years.) It should be kept in mind that even though statistics indicate a certain level of health effects will be experienced, Hanford will continue to reduce them. The current safety record of Hanford is much better than the national average. We must assume that the good record will continue, and in fact, we must ensure it.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. As noted, the Hanford Site does have a safety record that exceeds the national average, and DOE is committed to continuing improvement of its safety performances. Please refer to Volume One, Section 5.12 and Volume Four, Appendix E, which discuss accident risk during and after remediation. Please also refer to the response to Comment number 0009.06.
Comment Number 0009.08
Broderick, John J.
Comment This alternative (Ex Situ/In Situ Combination) is one of the lowest cost to perform. In addition, it minimizes repository costs. We do not know what the repository costs will be, but it is unlikely that they will be lower than the current estimates.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. A discussion of factors influencing the evaluation of alternatives is provided in the Summary (Section S.6), a comparison among the alternatives is provided in the Summary (Section S.7), and a summary of the environmental impacts is presented in Volume One, Section 5.14.
A reevaluation of repository costs, which accounted for the use of larger canisters in the geologic repository, led to a reduction in repository costs for some alternatives. These revised costs have been presented in the Final EIS in Volume One, Section 3.4 and Volume Two, Appendix B. The response to Comment numbers 0081.02, 0004.01, and 0008.01 extensively discuss the issues related to repository costs.
Comment Number 0009.09
Broderick, John J.
Comment This alternative (Ex Situ/In Situ Combination) will have the facilities constructed by 2007. This is faster than most of the alternatives. Speed is very important because it seems that Hanford, as time goes on loses its concentration and wants to do something else. The number of canceled projects is very large, and very expensive.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
DOE and Ecology acknowledge the risks associated with projects that take a long time to complete. However, speed of project completion is but one of many factors that influence the evaluation of alternatives. Other factors analyzed include short- and long-term risk to human health and the environment, technical uncertainty, cost, and regulatory compliance. Please refer to the response to Comment numbers 0009.08 and 0009.10.
Comment Number 0009.11
Broderick, John J.
Comment This alternative (Ex Situ/In Situ Combination) does not meet all of the regulations; however, they can be negotiated to be modified to assure that the public is adequately protected. The Tri-Party Agreement is a good place to document the negotiations.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The ability of the alternatives analyzed in the EIS to comply with Federal and State regulations is presented in the Summary (Section S.7) and discussed in detail in Volume One, Section 5.7.
Comment Number 0009.16
Broderick, John J.
Comment The Preferred Alternative is not acceptable because the cost (for the Preferred Alternative) is not the lowest that provides adequate protection of the public.
Response DOE and Ecology acknowledge the objection to selection of the Phased Implementation alternative as the preferred alternative, and this comment and other public comments will be taken into consideration when making a final decision on remediating TWRS waste. Please refer to the response to Comment number 0009.15. As discussed in the Summary (Section S.6), there are a number of factors that influence the evaluation of the alternatives. Cost was one factor analyzed for each alternative. The results of the impacts analysis are presented in the EIS in an objective, nonvalue-laden (e.g., less or more cost is preferable) manner for careful consideration by the public and decision makers. Cost comparison of the alternatives was never conducted in the absence of all other factors, which included risk to human health and the environment, long-term land use restrictions, and regulatory compliance. Furthermore, for the final EIS cost impacts associated with HLW storage at the proposed geologic repository have been presented separate from costs associated with the waste management, retrieval, treatment, and disposal or disposal onsite. For example in comparing the Ex Situ/In Situ Combination 1 alternative to the Phased Implementation alternative, the cost of long-term land use restrictions and risk to human health and the environment, as well as cost, monetary or other, of not complying with current regulatory requirements were analyzed equally. Please refer to the response to Comment number 0081.02 for discussions of cost issues related to the alternatives.
Miscellaneous Preferences
Comment Number 0001.01
Bell, Robert C.
Comment There currently exists containment technology that could completely seal off the leaking nuclear contaminants from migrating through the earth and contaminating the groundwater. However, it appears that no monies have been budgeted for the containment of the leaking nuclear waste. By containing the leaking storage tanks the public along with all life would be protected from the most toxic and deadly nuclear waste. I urge you to actively support the request to the United States Congress for funds to pay for the containment of the leaking tanks at Hanford.
Response Subsurface barriers are addressed in the EIS as a containment technology that could be applied to control tank leakage. The function of the subsurface barriers would be to prevent leakage of tank waste from migrating beyond the barrier into the vadose zone, which would help minimize the volume of contaminated soil. The possible use of subsurface barriers was derived from concerns about using hydraulic sluicing for retrieval, and because some of the SSTs either are confirmed or assumed leakers. Also, a study titled Feasibility Study of Tank Leakage Mitigation Using Subsurface Barrier (Treat et al. 1995) was completed in support of a Tri-Party Agreement milestone and was one of the references used during preparation of this EIS. The feasibility study assessed the application of existing
subsurface barrier technologies and the potential of existing technologies to meet functional requirements for SST waste storage and retrieval activities. Information on subsurface barriers is included in Volume Two, Section B.9.
In addition, the current TWRS program involves a wide variety of ongoing activities that include monitoring the integrity of tanks and characterizing the vadose zone around the tank farms to detect leaks. DOE also conducts numerous activities to provide continued safe storage of the tank waste, such as the saltwell pumping program, which involves removing retrievable liquids from SSTs to minimize potential future leaks. These ongoing programs are described in Volume One, Section 3.2.
This EIS addresses the full range of reasonable alternatives. This includes 10 tank waste alternatives ranging from no action to extensive retrieval. Risk to human health and the environment was among the factors considered by DOE and Ecology in identifying the preferred alternative, Phased Implementation (a discussion of factors that influence the evaluation of alternatives is presented in the Summary, Section S.6). Volume One, Section 5.13 (Cumulative Impacts) addresses actions at other DOE sites, programmatic actions, and actions at the Hanford Site that could impact the TWRS actions, including the Hanford Remedial Action Program. The proposed TWRS activities would be carried out against the baseline of overall Hanford Site operations. Volume One, Section 5.11 and Volume Three, Appendix D detail the anticipated risk for each alternative.
DOE and Ecology acknowledge the recommendation expressed in the comment regarding funding. However, Congressional funding issues are not included in the scope of this EIS.
Comment Number 0040.01
Rogers, Gordon J.
Comment The In Situ Fill and Cap alternative is clearly the best choice. The cost is low enough to have some real chance of being funded by Congress. It reaches a reasonable stage of completion in the shortest time. The short-term impacts are trivial. The long-term impacts appear likely to be small and acceptable providing that onsite use of groundwater is prohibited; and further than onsite farming and irrigation is prohibited.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Short- and long-term environmental impacts, uncertainties, and regulatory compliance are among the factors influencing the evaluation of alternatives. A discussion of these and other factors influencing the evaluation of alternatives is provided in the Summary, Section S.6, a comparison among the alternatives is presented in the Summary, Section S.7, and a summary of environmental impacts is provided in Volume One, Section 5.14.
NEPA requires that all reasonable alternatives be evaluated, regardless of cost, although Congressional funding issues associated with implementation of the alternatives were not included in the scope of the EIS. Please refer to the discussion contained in the response to cost concerns related to a comparison of the alternatives contained in Comment number 0081.02.
Comment Number 0072.11
CTUIR
Comment Of the alternatives presented, the CTUIR SSRP technical staff prefers Ex Situ with Extensive Separations because the cost is comparable, the volume of waste is comparable, the technical uncertainty is no higher than the other ex situ alternatives, and the activity of the LAW would be substantially lower than with less extensive separations. The phased approach will not be practical since substantially more land is required for two sets of vitrification facilities rather than the one set required for the non-phased options.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Multiple factors, including land-use commitments, influence the evaluation of alternatives. Among the factors are short- and long-term environmental impacts, regulatory compliance and uncertainties. These factors are addressed in the EIS in the Summary, Section S.6. In the Summary, Section S.7 contains a comparison of the alternatives based on various evaluation factors and Volume One, Section 5.14 provides a summary comparison of all of the environmental impacts addressed in the various sections of Volume One, Section 5.0 and the supporting appendices. The response to Comment number 0081.02 contains a discussion of the comparison impact of separating repository costs from retrieval and treatment costs of the ex situ alternatives.
Land use commitment impacts were analyzed in detail in Volume One, Section 5.7. Based on that analysis, Volume One, Section 5.19 identifies potential land use restrictions as a potential environmental justice concern for affected Tribal Nations. Volume One, Section 5.20 identifies potential mitigation measures that could be implemented to address the land use impacts identified in Section 5.19. For the Final EIS, these sections of the Draft EIS were revised to reflect technical information unavailable at the time the Draft EIS was published.
Comment Number 0085.02
Klein, Robin
Comment While it is true that a clearly proven, good solution does not exist, it is also true that the liquid wastes must not remain in these tanks. The leaking tanks are the greatest source of waste contaminations to the soils. Contaminated waste originating from the tanks are moving toward groundwater. Groundwater contaminated with Hanford pollutants already in the soils is now in communication with the Columbia River. Cleaning up waste once in the soils will take heroic efforts. Once they get into the river, the long lived contaminants are practically irretrievable. The single most affective measure we can take to protect the river in the long run is to stop the driving force that enables rapid migration of the wastes offsite, get the waste out of the leaking tanks soon. So it is important to have an aggressive plan in place.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. DOE and Ecology are committed to protecting the Columbia River. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
Comment Number 0088.03
Porter, Lynn
Comment There's an article in the Oregonian Sunday March 17th, that raised a whole lot of questions. This was a large article beginning on the front page quoting a panel of scientists from the National Research Council, whoever that is, I probably should know, but I don't. And they're saying just leave the stuff in the tanks. They quote some DOE engineers saying yes we can do it. And one of the points that puzzled me was they're saying in this article, the National Research Council says that before you can sluice out these tanks you have to seal the ground underneath them. I didn't find anything about that in the summary of the Draft EIS, except for the ISV option. So I don't know where this comes from, but their point seems to be that if you're going to have to seal the ground anyway, you might as well leave the stuff in the tanks. That's something I would have like to of heard discussed.
I think the problem is that this kind of thing keeps coming up. And so of course we wonder where's it coming from. There seems to be a lot of energy behind this idea we'll just leave the stuff in the tanks and put it cap on it and walk away. I'm glad to hear that isn't the feeling at the top. But since it keeps coming up in such volume, we wonder what's going on, like is this a trial balloon. If it is, I'd like to shoot it down. I just think leaving the stuff in the tanks is a completely unacceptable alternative. And I wish someone would take this idea out and bury it and drive a stake through it's heart.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The National Research Council, in the cited article, advocated an alternative that evaluated the impact of not removing waste from selected tanks. This alternative, which corresponds to the Ex Situ/In Situ Combination 1 and Ex Situ/In Situ Combination 2 alternatives evaluated in the EIS, is not the preferred approach endorsed by DOE and Ecology. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives and Comment number 0001.01, which discusses subsurface barriers as this issue relates to leak containment.
Specific Preference for Ex Situ/In Situ Combination Alternative
Comment Number 0009.05
Broderick, John J.
Comment The above reasoning has lead me to recommend you select the following remediation alternative: Ex Situ/In Situ Combination. I believe the Preferred Alternative is doomed to be not completed because it is trying to avoid leaving waste in place, will take too long to construct, and will cost too much. In addition, there is a possibility that the whole issue will again be revisited at the beginning of the second phase. This will be another opportunity to change the remediation approach.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0009.06 for a description of revisions to the alternatives in the Final EIS, 0009.08 for a description of the factors considered when evaluating alternatives, and 0009.09 for a description of the time required to implement alternatives.
Comment Number 0009.06
Broderick, John J.
Comment This alternative (Ex Situ/In Situ Combination) selects the actions based on long term health effects, rather than a "one size fits all" approach.
Response The ex situ/in situ combination alternatives are based on reduction of human health risk and different tanks having much different contents, therefore representing differing potential long-term impacts to human health. For the Final EIS, two ex situ/in situ combination alternatives are analyzed in detail. Volume One, Section 3.4 and Volume Two, Appendix B provide a description of the two alternatives and the potential impacts associated with each alternative are analyzed in Volume One, Section 5.0 and associated appendices.
Comment Number 0009.10
Broderick, John J.
Comment This alternative (Ex Situ/In Situ Combination) will deal with more waste faster than other, more extensive alternatives. Thus there will be less effort expended in just managing the waste.
Response DOE and Ecology acknowledge the risks associated with projects that take a long time to complete. However, speed of completion of the project was one of many factors that influence the evaluation of alternatives (please refer to the response to Comment number 0009.08). Duration of construction and remediation is directly proportional to the nature and volume of tank waste, as well as the complexity of the tank farms as a whole (i.e., vadose zone contamination, groundwater migration, and closure). The preferred alternative, using a phased approach, would allow evaluation and optimization of the technologies used to treat the waste form and nature to be retrieved, which would enable the Agencies to apply "best fit" for the waste type. A summary of the environmental impacts of all alternatives analyzed in the EIS is presented in Volume One, Section 5.14 and a comparison of the alternatives is presented in the Summary (Section S.7).
Comment Number 0009.12
Broderick, John J.
Comment This alternative (Ex Situ/In Situ Combination) will provide means so the waste will not migrate from its disposal location. Still, there will be waste present, so there must be a continuing program to restrict farming, groundwater use, and intrusion. This program will be much less expensive and less complicated than removing all waste from Hanford.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. For purposes of analysis in the EIS, institutional controls for this and other alternatives would end 100 years following the end of remediation. Thus, the long-term impacts assume unrestricted use of the Site for farming and potential use of groundwater as well as intrusion into the waste disposal onsite. Therefore, while the cost, technical complexity, and short-term impacts of the combination alternatives are less than that of the ex situ alternative; long-term impacts tend to be higher. For a comparison of the alternatives, please refer to the Summary, Section in 5.7.
Comment Number 0009.15
Broderick, John J.
Comment The Preferred Alternative is not acceptable because the extra effort (for the Preferred Alternative) does not significantly reduce the fatalities expected, even though all the waste is removed.
Response DOE and Ecology acknowledge the preference expressed in the comment, but have identified the Phased Implementation alternative as the preferred alternative for the reasons described in the Summary (Section S.7). As discussed in Section S.6, there are a number of factors that influence the evaluation of the alternatives including short-term and long-term impacts, uncertainties, and compliance with laws and regulations. Please also refer to the response to Comment number 0098.06 for more information about risk calculation. Reduction in fatalities is one method of comparing alternatives; however, other issues such as regulatory compliance, long-term reduction in potential risks to human health and the environment, and implementability in light of technical uncertainty must also be considered.
Comment Number 0009.17
Broderick, John J.
Comment The Preferred Alternative is not acceptable because there will be significant repository costs (for the Preferred Alternative). The costs are uncertain now because we do not have a repository.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The repository cost for each alternative was calculated to provide the public and decision makers with information associated with the total potential costs of the various alternatives. Based on new information made available since the publication of the Draft EIS, repository costs have been substantially revised for the Final EIS (Volume One, Section 3.4 and Volume Two, Appendix B). A discussion of the methodology used to calculate repository costs, the cost associated with each alternative, cost formulas, and canister size issues, is contained in the response to Comment numbers 0081.02, 0004.01, and 0008.01.
Comment Number 0009.18
Broderick, John J.
Comment The preferred alternative is not acceptable because the construction of facilities will not be completed until 2012 (for the preferred alternative). This is way too long, our experience is that long duration projects often do not reach the operational phase.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Phase 1 of this alternative (construction and operations) would be completed in 2007. Phase 2 construction would be completed in approximately 2011. DOE and Ecology acknowledge the risks associated with projects that take a long time to complete. However, speed of completion of the project is but one of many factors that influence the evaluation of alternatives. Please refer to response to Comment numbers 0009.09, 0009.10, and 0098.02, which discusses issues related to construction starts and duration and the impact of the phased approach on the volume of waste treated.
Comment Number 0009.19
Broderick, John J.
Comment The Preferred Alternative is not acceptable because the phased approach is not needed. We can build the facilities with existing technology. As our knowledge and experience increase over the next 45 years, we can modify the facilities. We will need to do that anyway to keep up with technology and safety requirements.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The preferred alternative, Phased Implementation, represents near-term use of currently available technologies to the extent possible. Phase 1, also known as the demonstration period, will assess the capability and effectiveness of existing technologies to retrieve and treat the waste and provide DOE with information on retrieval efficiencies, blending practices, separation efficiencies, vitrification techniques, and costs prior to constructing and operating full-scale facilities. This will result in more efficiently designed and operated facilities for Phase 2. The implementation schedule for the preferred alternative is consistent with Tri-Party Agreement milestones, as well as concurrent with other programmatic and systems activities currently conducted at the Site. Because the phased approach is designed to implement "learn as you go" improvements, system optimization and cost savings are expected. This approach and resulting benefits may be less likely with a fixed, less flexible technology or implementation of full-scale facilities without a demonstration phase. For a discussion of the phased approach to alternative implementation, see Volume One, Section 3.4 and Volume Two, Appendix B. Please refer to the response to Comment number 0098.02 for a discussion of schedule and treatment volume estimates associated with the preferred alternative.
Comment Number 0029.01
Bartholomew, Dale C.
Comment I believe that the Ex Situ/In Situ Combination alternative offers the best balance between risk and benefit of the proposed alternatives and should be selected as the preferred alternative for the following reasons:
It offers the highest real value. It provides a level of safety to the public commensurate with other sub-surface contamination immediately adjacent to some of the tanks, adjacent to the 242-S evaporator, and sites such as cribs throughout the 200 Areas as well as other contaminated areas adjacent to the 200 Areas such as BC Crib. If my understanding is correct, no further action is planned on these other sites. Therefore, totally uncontrolled access by the public would be unacceptable, and I recommend that a waiver be obtained for relief for tank wastes from the regulations. This may be politically incorrect, but makes the most sense in the context of a balanced total system.
Retrieval of wastes from all SSTs, DSTs, and MUSTs is a huge waste of money if the soil contamination sites outside the tanks are not also ameliorated.
I also believe retrieval of wastes from all tanks creates a higher-than-projected exposure of working personnel to both occupational and radiological accidents and injuries. I have no data to support this. However, my experience suggests that the input data for the calculations may not be realistic.
The Summary Table indicates that the Ex Situ/In Situ Combination alternative and the preferred alternative are both rated "moderate" with respect to Technical Uncertainty. I believe the degree of technical uncertainty associated with the Ex Situ/In Situ Combination is less than the preferred alternative because only one-half of the waste volumes would be vitrified and sent to the repository with the Ex Situ/In Situ Combination alternative, (50 percent of the tanks would be filled and capped). It should have received a lower Technical Uncertainty rating because of scaled-down throughput requirements.
I suspect when wastes from all of the tanks are retrieved, there will be several SSTs thought to be non-leakers that will be found to be leakers. That will only add to existing soil contamination during sluicing.
I noticed where the U-238, Tc-99, C-14, and I-129 isotopes were to be retrieved. I fully support this action. I may have read the document too quickly, but I did not notice any reference to TRU wastes. Obviously, these must also be removed and vitrified.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
The following responses are in the same order as the comments.
Short-term and long-term impacts to human health and the environment, managing the uncertainties associated with the waste characteristics and treatment technologies, cost, and compliance with laws, regulations, and policies are among the factors considered when evaluating the alternatives (please refer to the response to Comment number 0009.08). No decision has been made regarding remediation of subsurface contamination adjacent to the tanks or in the other areas referred to in the comment. Contamination from past tank leaks is beyond the scope of this EIS (see Volume One, Section 3.3 and the response to Comment number 0072.08). Other contamination of soils in the 200 Areas is the subject of the Hanford Remedial Action EIS and subsequent Comprehensive Environmental Response, Comprehensive Environmental Response Compensation and Liability Act (CERCLA) decisions. The TWRS EIS presents the cumulative impacts of the tank waste alternatives and the 200 Areas contamination in Volume One, Section 5.3).
The retrieval of wastes from the SSTs, DSTs, and MUSTs and their subsequent remediation is considered in this EIS. Tank waste retrieval and treatment is the first step in remediation of the tank farms. The remediation of soil contaminated sites outside the tanks will be considered in other environmental documentation, such as the Hanford Remedial Action EIS. The EIS analyzes a range of alternatives from no waste retrieval to extensive waste retrieval. Each of the alternatives presents differing trade-offs among short-term and long-term environmental impacts, technical uncertainty, and regulating compliance. Additionally, alternatives that involve no retrieval or partial retrieval, such as the ex situ/in situ combination alternatives would influence the closure actions that could be implemented, as discussed in Volume One, Section 3.3. Implementation of these alternatives would limit or potentially increase the cost and complexity of the future closure actions such as remediation of contaminated soils. Extensive retrieval alternatives would provide the least complications and cost impacts on future closure actions.
The risks to the workers during construction and operation of the retrieval and transfer facilities for the ex situ alternatives have been analyzed for all the alternatives. The results of this analysis are given in Volume Four, Appendix E and in Volume One, Section 5.12. In general, risks to the workers are less when less retrieval and transfer are conducted. Regardless of the alternative selected, DOE would complete a detailed safety analysis of the alternative to determine additional safety measures for implementation. Please refer to the response to Comment number 0098.06 for risk calculation information.
The technical uncertainty of an alternative is a compilation of numerous factors, such as similarity to other like operations, the history of demonstrated performance of the technology, the ability to construct and operate the alternative given the conditions at the Site, and others. However, if two technologies are operating at roughly the same scale and production rate, the technical uncertainty is not a direct function of the throughput requirement. The ability to design, construct, and operate the Phased Implementation alternative and the ex situ/in situ combination alternatives are approximately the same. Both alternatives have approximately the same degree of process development, consequently, the two processes will be rated about equal in their technical uncertainty.
To account for leakage from the SSTs during retrieval, the EIS assumes an average of 4,000 gallons of leakage from each tank (see Volume One, Section 5.2 and Volume Four, Appendix F). It is not expected that all SSTs will leak this amount. Some SSTs will not leak during retrieval, and as the comment suggests, some SSTs will develop unexpected leaks. It has been assumed in the EIS that the total leakage divided by the number of tanks will be bounded by the 4,000-gallon figure. For tanks that are known leakers or that develop leaks during retrieval, the EIS presents technology options to sluicing, such as robotic arm-based retrieval, that would involve substantially lower volumes of liquids (see Volume One, Section 3.4 and Volume Two, Appendix B).
The purpose is to retrieve the radionuclides that are the chief contributors to long-term risk (i.e., uranium-238, technetium-99, carbon-14, and iodine-129). Neptunium-237, a TRU isotope, is also a contributor to long-term risk, and this alternative shows a calculated retrieval of approximately 93 percent for this isotope. There is a large calculated proportion of other TRU elements that would be retrieved, but do not move quickly enough in the vadose zone and groundwater to contribute to risk within 10,000 years.
Specific Preference for the Phased Implementation Alternative
Comment Number 0012.01
ODOE
Comment Governor Kitzhaber and Oregon strongly support the preferred alternative in the environmental impact statement (EIS). This alternative calls for a retrieval of all of the tank wastes technically possible (estimated at 99 percent of the wastes) and vitrifying the wastes. While the vitrified wastes will still be radioactive, they will be safer to store and not susceptible to leakage pending ultimate disposal.
Although we support the preferred alternative, it will not resolve all the issues related to the high-level wastes at Hanford. We believe there will continue to be the need for ongoing monitoring, characterization, and pumping and treating of groundwater contamination caused by waste which has leaked and migrated from the tanks.
Response DOE and Ecology acknowledge the preference of the State of Oregon for the preferred alternative, and will take this preference and other public comments into consideration when selecting the final action for TWRS waste. The issues identified were among the factors considered by DOE and Ecology in identifying the preferred alternative.
The Hanford Site will require ongoing monitoring and characterization relative to past tank leaks and the migration resulting from those leaks into the surrounding environment. The characterization and monitoring programs are discussed in the response to Comment numbers 0072.61, 0072.63, 0072.67, and 0072.70. Each of the alternatives includes continuation of existing programs to characterize vadose zone and groundwater contamination and long-term monitoring programs that extend beyond the completion of the tank waste action (Volume One, Section 3.4 and Volume Two, Appendix B). As more information becomes available regarding the environmental consequences of past leaks and the nature of residual waste remaining in the tanks following retrieval, DOE will be able to address actions associated with tank farm closure, including the potential for pumping and treating groundwater contamination beneath the 200 Areas (see Volume One, Section 3.3 for a discussion of closure). It is because of the lack of adequate data regarding these issues that the closure of the tank farms is not included in the scope of this EIS. Please refer to the response to Comment number 0072.08.
Comment Number 0012.03
ODOE
Comment Leaving wastes in the tanks poses huge risks. The tanks are corroding and failing. As they fail, the radioactive waste is released to the soil and ultimately to the groundwater and to the Columbia River. Vitrifying the tank waste makes it far more stable and greatly reduces the threat to the public and the environment. While the cost of the preferred alternative is substantial, it is the only alternative which satisfactorily deals with the dangers presented by these wastes as quickly as practical. The phased approach allows USDOE to get on with cleanup while allowing for possible development of better approaches which remove all tank wastes.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The issues identified were among the factors considered by DOE and Ecology in identifying the preferred alternative, Phased Implementation. Please refer to the response to Comment number 0009.19 for reasons the Phased Implementation was identified as the preferred alternative.
Comment Number 0012.07
ODOE
Comment The preferred alternative relies on proven technology and a phased approach. This allows a "learn as you go approach" which should identify problems earlier and at a smaller economic and environmental cost.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The issues identified were among the factors that influence the evaluation of alternatives. Please refer to the Summary, Section S.6 and S.7 and the response to Comment numbers 0009.08 and 0009.19.
Comment Number 0012.09
ODOE
Comment The current risk modeling and analysis are too simplistic to allow detailed decisions which call for leaving part of the wastes in place and still protect human health and the environment. We believe the risk assessment in this EIS is sufficient to support the proposed alternative and to conclude that the risks are too large to allow any of the tank waste to remain in the tanks at the end of cleanup.
Response The risk modeling and assessment performed for this EIS used the best available data, state-of-the-art models, and industry standard approaches and techniques and is both comprehensive and detailed. The data generated by the modeling and assessment provided for a balanced and equitable comparison among the alternatives and as such, provided results that were useful in comparing the potential short-term and long-term human health and environmental impacts. To the extent that the risk assessment provided sufficient data to evaluate the preferred alternative, it also provided equally valid data to support the evaluation of all alternatives, including alternatives involving leaving some or all of the waste in place. For the Final EIS, an appendix (Volume Five, Appendix K) was added to the EIS to provide a basis for understanding uncertainties associated with the risk assessment, as well as other areas of uncertainties.
Comment Number 0022.03
Sims, Lynn
Comment We know millions of gallons of waste have already leaked from the tanks and migrated towards groundwater. This relentless assault upon the environment will not cease without intervention. We are not certain of the environmental and human health damage which has and will result from leaking tanks, but forecasts are ominous. The only responsible alternative is the preferred alternative which removes as much waste as possible and isolates them from the environment by vitrification.
Response DOE and Ecology acknowledge the preference expressed in this comment and will take into consideration this preference and other public comments when selecting the final action for TWRS waste. DOE has implemented a program to remove as much of the liquids as practicable from the SSTs to reduce the likelihood of future leaks. A discussion of this program is provided in Volume One, Section 3.4 and Volume Two, Appendix B. An analysis of potential cumulative impacts, including past leaks is presented in Volume One, Section 5.13 and new information regarding the extent of migration of past leaks to the vadose zone and groundwater has been included in Volume Five, Appendix K. The ongoing characterization and monitoring program is discussed in the response to Comment numbers 0072.61, 0072.63, 0072.67, and 0072.70.
Comment Number 0032.04
Heacock, Harold
Comment We support the Department's preferred alternative of phased implementation of an ex situ intermediate separations process, which provides for the greatest protection of the environment, including protection of the groundwater consistent with a reasonable projected cost, the disposal of the vitrified high-level waste at a national waste repository, and an acceptable degree of risk.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Pleaser refer to the response to Comment number 0009.19 for a discussion of the reasons Phased Implementation is the preferred alternative.
Comment Number 0035.08
Martin, Todd
Comment I would like to address what I think is good in the EIS. We support the pretreatment selection in the preferred alternative.
Intermediate separations is appropriate. HEAL would vigorously oppose any movement towards extensive separations pretreatment process.
The stakeholder community in the Northwest has made it very clear that intermediate separations is responsive to our values. It is available relatively, and it will reduce the waste volume by a satisfactory amount.
Secondly I support the assumption that 99 percent of the waste will be retrieved. The risks in the EIS show very clearly that the only responsible alternative is to retrieve all of the waste.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0005.38 for a discussion of issues related to pretreatment. The response to Comment number 0012.19 contains a detailed discussion of the extent to which the public has made a positive impact on this document.
Comment Number 0036.10
HEAL
Comment HEAL supports the full retrieval of Hanford's tank wastes. The preferred alternative's retrieval scenario is responsive to the stakeholder values. It has always been assumed that Hanford's tank wastes post a great risk to future generations. This EIS confirms the assumption. The EIS shows that future risk is directly correlated to the amount of waste left behind. The impact of leaving only a small portion of contamination behind is evidenced by the difference in long-term risk for the preferred alternative where 1 percent of the waste is left and the Ex Situ/In Situ alternative where 10 percent of the waste is left behind. By leaving 9 percent more waste behind, the risk for residential farmer at 5,000 years would increase by a factor of 10. These high risks clearly show that the only responsible solution is to retrieve all of the waste.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Impact to the public welfare, including residential farmers, was a factor analyzed for all alternatives. Please refer to the response to Comment number 0009.05. The environmental impacts of all the alternatives analyzed in the EIS are summarized in Volume One, Section 5.14. Potential long-term health effects are summarized for each alternative in the Summary, Section S.7.
Comment Number 0038.03
Reeves, Merilyn
Comment Now, the board supports the full retrieval from Hanford tank waste. The preferred alternative retrieval scenario is responsive to the board's value.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0009.19 for a discussion of the reasons the Phased Implementation alternative is the preferred alternative.
Comment Number 0038.05
Reeves, Merilyn
Comment The Board supports the preferred alternative's pretreatment process. And again, we go back to the Tank Waste Task Force, which stated the high cost and uncertainty of high tech pretreatment and R and D threatens funding for higher performance low level waste form vitrification and cleanup.
Use the more practical, timely, available technology while leaving room for future innovations. Keep a folio of technology options and make strategic investments over time to support the limited number of promising options. Give up further research on unlikely options. Again a statement from 1993.
The intermediate separations case is responsive to this value although the difficult challenge of technetium removal in the Phased Implementation alternative is a concern to the Board.
And the Board would strongly oppose any movement towards extensive separations pretreatment technology.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0072.05 for a description of how the alternatives analyzed in the EIS were identified and methods for analyzing technology options in the EIS.
Implementing Phase 1 of the preferred alternative would allow evaluation of existing technologies while moving forward on retrieval and treatment goals. As the demonstration phase progresses, the efficiencies and effectiveness of the retrieval and treatment technologies, including technetium separation, can be evaluated and optimized. Technetium removal could be implemented during Phase 1 using established separations technology or emerging technologies that show promise in keeping with recommendations of the board. One way of removing technetium-99 from alkaline waste solutions is to selectively sorb the isotope, as TcO4, using a strong-base organic ion-exchanger (WHC 1995a).
Comment Number 0042.01
EPA
Comment The EIS addresses the treatment, storage, and disposal of Hanford Tank Waste to meet the requirements of the Hanford Federal Facility Agreement and Consent Order and the Resource Conservation and Recovery Act as amended by the Hazardous and Solid Waste Amendments of 1984. As a signatory to the Agreement and Consent Order, EPA has endorsed the approach identified in the Draft EIS as the preferred alternative.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0072.05 and 0005.07.
Comment Number 0043.02
Hanford Communities
Comment In its selection of an alternative for the cleanup of tank wastes, we believe that the Department of Energy must comply with State and Federal laws and must also comply with its commitments under the Tri-Party Agreement. We believe that the Department should proceed with an ex situ process of extensive waste retrieval with phased implementation. This process appears to have the strongest backing of people in this area and provides the best long-term environmental solution.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. DOE and Ecology intend to comply with all Federal, State, and local regulations and ordinances applicable to tank waste remediation. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
Comment Number 0076.01
Blazek, Mary Lou
Comment I had passed out a comment, or a formal comment that I would like to have read into the record. I won't do that now, it would be lengthy. I just like want to say on the record that Governor Kitzhaber and the Oregon Department of Energy strongly support the proposed alternative in this Environmental Impact Statement. The retrieval for all the tank waste that are technically possible, up to 99 percent we think is critical that occur. The need for this undertaking is compelling in our minds. The potential impact to the Columbia River cannot be impacted in this way.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. DOE and Ecology remain committed to protecting the Columbia River and the analysis of potential impacts of TWRS alternatives includes impacts to the River as presented in Volume One, Section 5.2 and Volume Four, Appendix F. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
Comment Number 0076.02
Blazek, Mary Lou
Comment The other alternatives under consideration leave most, or all of the waste in the tanks, with the exception of the in situ vitrification, which is an immature and unproven technology. Other alternatives do little to remove the hazards posed by the waste. The major criteria that must be applied to any decision is the protection of public health and safety and the environment. This criteria eliminates all of the alternatives, which leave all or part of the waste in the tanks, except in situ vitrification. The EIS claims a lower risk for in situ vitrification, although it's an immature and unproven technology. Because the in situ vitrification technology is uncertain, we oppose all of the alternatives, which leaves the waste in Hanford tanks.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives and 0005.18, which discusses tank waste residuals.
Comment Number 0077.03
ODOE
Comment Sacrificing Hanford in this way does not adequately reduce the harm and risks to the environment or to future generations. For these alternatives, the risk analyses in the EIS show massive plumes of radioactive material slowly moving across the Hanford site and into the Columbia River for hundreds to thousands of years.
Cost should not be the sole or even predominant criteria used to select among the alternatives. The first criteria that must be applied is protection of public health and safety and the environment. This criteria eliminates all of the alternatives which leave all or part of the waste in the tanks, except in situ vitrification. The EIS claims a lower risk for in situ vitrification, although it is an immature and unproven technology for tank waste. Because in situ vitrification technology is uncertain, the potential for failure is unacceptably high. We strongly oppose all of the alternatives which leave the waste in Hanford's tanks.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Removing, treating, and disposing of the tank waste would be the first step in providing protection to the vadose zone, groundwater, and the Columbia River. Please refer to the response to Comment numbers 0076.02, 0040.01 and 0005.18 for more information. The response to Comment number 0009.16 contains a discussion of the analysis of cost alternatives.
Specific Preference for Vitrification
Comment Number 0047.01
Ahouse, Loretta
Comment The wastes that are in the tank farms at Hanford must be dealt with at all costs. My preference is to see that all of the tank waste be removed and vitrified, regardless of whether or not the vitrified logs are ever moved to Yucca Mountain, Nevada.
It is an undisputed fact that the tanks at Hanford have leaked, although there appears to be a question of how far and how fast. Despite this, we do know that the tanks leak and may pose a potential danger to the groundwater under the Hanford site, and ultimately the Columbia River. For this reason, all of the waste that is technically feasible to remove, must be removed and immobilized in a safe manner. This should not be an issue of costs.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. As more information becomes available from the ongoing vadose zone and groundwater monitoring and characterization program, DOE will be able to address issues related to tank farm closure. The EIS has been modified to include information on vadose zone contamination in Volume One, Sections 4.2 and 5.13 and in Volume Five, Appendix K. Vadose zone contamination is also discussed in the response to Comment number 0012.15.
Comment Number 0047.02
Ahouse, Loretta
Comment I do not agree with any plans which would leave a portion of the waste behind in the underground tanks.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
The preferred alternative assumes 99 percent retrieval of the tank waste. In a separate NEPA review, DOE intends to consider alternatives to tank farm closure. The EIS analysis addresses a range of alternatives that includes leaving all or a portion of HLW onsite, as well as alternatives that retrieve from the tanks as much waste as practicable (assumed to be 99 percent). Decisions associated with the
extent of retrieval will be supported by the TWRS EIS; however, the decisions on closure are not within the scope of the TWRS EIS. Please refer to the response to Comment numbers 0005.18 (assumption used in analysis of alternatives), 0072.08 (a discussion of closure), and 0072.05 (NEPA requirements for analysis of alternatives).
Comment Number 0079.02
Knight, Page
Comment One of the proposal alternatives is to take wastes from only from the double-shell tanks which are not yet leaking, vitrify them, and fill the single-shell tanks with sand and in effect walk away. This would possibly push the liquid waste deeper into the ground, hastening the contamination flow to the groundwater, and thus to the Columbia River. Presently, at the T tank farm, plutonium has become bound up in chemicals of the tank waste, and is moving rapidly toward groundwater. This is an inkling of what is to come in the next 100 years if the waste is left in the tanks. This is thus, an unacceptable alternative.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. The TWRS EIS addresses the management, retrieval, treatment, and disposal of the tank waste and does not address closure of tank farm residuals, equipment, or soil contamination. For the purposes of this EIS, closure as a landfill was assumed, but this closure assumption contained in the EIS will not be used to identify a closure alternative in the TWRS ROD. Closure will be addressed in future NEPA documents. Please refer to response to Comment number 0072.05 for additional closure information.
DOE and Ecology remain committed to protecting the groundwater beneath the Hanford Site and the Columbia River. The EIS analyzes the impacts to groundwater associated with each of the alternatives in Volume One, Section 5.2 and Appendix F. The Final EIS has been modified to include a discussion of emerging data on vadose zone contamination beneath the tank farms. This discussion is provided in Volume Five, Appendix K. Please refer to the response to Comment number 0076.02.
L.3.4.1.2 General Preferences
Miscellaneous Preferences Related to Remediation
Comment Number 0009.03
Broderick, John J.
Comment Over the past decade, Hanford has demonstrated that it can not complete a project that takes a long time to construct. Grout, the new tank farm and HWVP come to mind in this regard, but there are many others. The many canceled projects have spent hundreds of millions of dollars with nothing to show for the effort. Each time there seems to be a good reason to cancel - but the percentage of canceled projects is very high. For this reason, the remediation of the tank waste must be done in facilities that can be constructed in a short period of time.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Volume One, Section 3.4 and Volume Two, Appendix B contain the implementation and completion schedule for each alternative. The Preferred Alternative identified in the EIS is consistent with the proposed remedy contained in the Tri-Party Agreement and the remediation schedule milestones in the Tri-Party Agreement. In addition, the existing schedule has been accelerated by approximately two years as a result of concurrent TWRS activities. Please refer to the response to Comment numbers 0009.10 and 0009.18 for a discussion of issues related to implementation of the preferred alternative, including projected construction completion dates. Please also refer to the response to Comment numbers 0055.06 and 0009.16 for a discussion of issues related to the consideration of cost in the alternatives analysis and the applicability of the HWVP to the preferred alternative.
Comment Number 0009.04
Broderick, John J.
Comment The National debt is increasing every year. There are strong pressures to reduce the deficit, and the debt itself. We have already seen the DOE budget drop substantially; and there are pressures to cut it even more. For this reason, the remediation of the tank waste must be done at the lowest possible price.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. DOE and Ecology believe that there is a potential to reduce the cost for tank waste remediation by allowing the market place to establish, through the competitive bidding process, the cost for waste treatment. Please refer to the response to Comment number 0036.15 for more information. The environmental impact of all factors analyzed during the evaluation of each alternative included in the EIS is presented in Volume One, Table 5.14.1.
Comment Number 0014.03
Bullington, Darryl C.
Comment Further proposals of hazardous chemical processes based upon unproven technology using insupportable assumptions such as a ninety-nine percent retrievability of sludge to generate so much high-level waste that it can not be safely contained in existing repositories continues to erode any credibility that may yet exist between the DOE and the public. Such reports not only wasted resources, they assure continued inaction and indecision.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. For each of the alternatives, technical uncertainties were addressed in Volume One, Section 3.4 and Volume Two, Appendix B. For the Final EIS, Volume Five, Appendix K was added to the EIS to consolidate discussion of uncertainties associated with the analysis of environmental and human health impacts. The EIS also analyzes alternatives involving retrieval of less than 99 percent of the tank waste. These alternatives include the in situ alternatives which would involve minimal waste retrieval and the ex situ/in situ combination alternatives which would involve partial waste retrieval. For more information regarding the 99 percent retrieval assumption, please refer to the response to Comment numbers 0005.18 and 0089.07. Please also refer to response to Comment numbers 0069.04 and 0037.03 for issues related to regulatory compliance requirements associated with disposal of tank waste and geologic repository availability.
Comment Number 0021.01
Shilling, Fred E.
Comment Our concerns regarding the storage of nuclear wastes at Hanford: some of the stuff is leaking and it was not supposed to; some of it presents the threat of explosion, and it was not supposed to; some sort of omnibus cleanup was supposed to be under way by now but it is not; all the while the costs keep escalating while axe grinders argue for use of the plutonium for fuel for their profit and our disposal problem. And there is still no safe disposal.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The TWRS EIS was initiated because DOE needs to manage and dispose of tank waste to "reduce existing and future risk to the public, Site workers, and the environment" (Draft TWRS EIS, Section 2.0). The EIS addresses the DOE proposed action to manage and dispose of tank waste, as well as a range of reasonable alternatives. The use of plutonium for fuel is beyond the scope of this EIS. For each alternative, the EIS analyzes potential impacts to the human and natural environment including potential impacts from future releases to groundwater in Volume One, Section 5.2, releases to the air in Section 5.3, impacts to ecological and biological resources in Section 5.4, impacts to human health in Section 5.11, and impacts from explosions and other accidents in Section 5.12. Each of the alternatives, except No Action and Long-Term Management identify how tank waste would be disposed of. For HLW retrieval from the tanks, disposal would be offsite in the proposed geologic repository. For discussion of waste disposal under each alternative see Volume One, Section 3.4, and Appendix B.
Comment Number 0026.01
Blazek, Mary Lou
Comment I see three long-term strategic hazards that must be considered:
- prevention of dispersal into the environment
- prevention of direct human exposure (i.e., Site workers, etc.)
- prevention of misappropriation by terrorist/criminal groups.
These concerns are not limited to high-grade plutonium.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please also refer to the response to Comment number 0021.01 for a discussion of EIS analysis regarding disposal of water into the environment. Prevention of direct human exposure is addressed for each alternative in Volume One, Section 3.4, and Appendix B. All alternatives would provide for appropriate security to minimize the risk of misappropriation.
Comment Number 0026.02
Blazek, Mary Lou
Comment I believe there are reasons to select a variety of processes in management. Some elements will be best served by vitrification, and others by simple long-term storage. I see no reason why at least a portion of the waste should not be stored at ground level, where it can be adequately monitored for leakage or casket deterioration and repackaged as indicated.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The bounding approach to the evaluation of reasonable alternatives provides the option for the decision makers to select a variety of processes in the ROD. The EIS range of alternatives included retrieval from zero to 99 percent of the waste, as well as a discussion of those technologies currently available for retrieval, separations, and immobilization. In addition, the EIS addresses four alternatives (i.e., ISV, In Situ Fill and Cap, and Ex Situ/In Situ Combinations 1 and 2) that include storage and/or disposal of all or part of the waste near surface onsite.
Risks to human health associated with transportation of HLW to the proposed geologic repository were analyzed and compared for each alternative in the accident scenarios discussed in Volume One, Section 5.12, and Volume Four, Appendix E. This analysis in conjunction with the analysis of risks associated with onsite disposal versus offsite disposal of HLW, supports the comparison of alternatives. Long-term risk to human health and the environment specific to onsite and offsite storage and risks in general were discussed in Volume One, Section 5.11 and Volume Three, Appendix D. All ex situ alternatives, except for the Ex Situ No Separations alternative, specify that the LAW be stored onsite in a near surface vault and that the remaining HLW be stored onsite pending disposal at the proposed geologic repository. The Ex Situ No Separations alternative would result in offsite disposal of the tank waste. Please refer to the response to Comment numbers 0026.01 and 0072.05.
Comment Number 0026.03
Blazek, Mary Lou
Comment In general I do not favor transfer to other sites. I believe the actual transfer would often times be hazardous, I see no advantage to deep burial over surface interment, and it is generally viewed as a means of "getting it out of my backyard" with all the political overtones and delays involved.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0026.01 for discussion of the analysis of impacts in the EIS, and 0026.02 for a discussion of a comparison of alternatives relative to onsite verses offsite disposal.
Comment Number 0026.04
Blazek, Mary Lou
Comment I see a need for use of a variety of separation/purification techniques, a variety of storage techniques, and a sense of urgency to start the process. We have spent far too long on looking for a single perfect solution and site. Technology will change over the next 50-100 years, and we can neither wait for that to happen nor insist on locking ourselves into a single process.
Response Please refer to the response to Comment numbers 0026.01, and 0026.02 for a discussion of the range options available for the decision makers based on the EIS analysis and the response to Comment number 0072.05 for discussion of NEPA requirements for analysis of a range of alternatives. The response to Comment number 0076.03 addresses modification to technologies over time, and the response to Comment number 0009.01 discusses technology optimization and the urgency associated with tank waste remediation.
Comment Number 0032.02
Heacock, Harold
Comment The continued management and minimum waste retrieval alternatives are not acceptable solutions to a major environmental problem since they do not include the retrieval of waste from the single-shell tanks.
We believe that any tank waste remediation program must include removal and processing the waste to an acceptable solid in order to eliminate the environmental threats resulting from any retention of the waste in tanks of questionable integrity and lifetime.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
The EIS analysis presents data to support a comparison of the potential environmental impacts form retention of waste in the tanks (No Action and Long-Term Management alternatives) verses various waste management and disposal strategies represented by the other alternatives analyzed in the EIS. Please refer to the response to Comment numbers 0026.01 and 0026.02 for more information.
Comment Number 0034.02
Belsey, Richard
Comment So there are real compelling reasons to do the one thing that will most increase the safety and health issues for workers, people, and the environment. And that is this material needs to be stabilized so it does not and cannot move.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please refer to response to Comment numbers 0026.01, 0026.02, and 0072.05 for a discussion of the range of alternatives addressed in the EIS, including alternatives involving immobilization of all or portions of the waste.
Comment Number 0034.03
Belsey, Richard
Comment Waste management side there are compelling reasons too. Interestingly they are dollars. The cost of sitting or baby-sitting these tanks is the most frustrating thing that I can think of.
It costs -- has costs anywhere from 200 to 300 million dollars a year. Finally, the people in the Tank Waste Remediation System are beginning to bring this mortgage down by a variety of techniques, but it is still the largest single overhead -- and I put it in as overhead because it does not produce any cleanup.
It does not produce any movement. Those resources are needed to do actual cleanup work. And the meter is running. As we sit here, the meter runs every single day.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Reduction in mortgage costs associated with continued management of tank waste was accounted for in the cost estimates for each alternative analyzed in the EIS. The No Action alternative cost estimate represents the 100-year mortgage for tank waste management. Please refer to the response to Comment number 0009.16, which discusses the methods by which cost was incorporated into the alternative analyses.
Comment Number 0034.04
Belsey, Richard
Comment And these were because people knew or had learned about the problems in the tanks, and they wanted to do something about it. This was an intense five or six-month period. And the Tank Waste Task Force came out and said we have to change what we were doing. We need to put both the high-low-level activity fractions into glass, different kinds of glass.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. The approach to tank waste identified in the Comment is represented in the EIS in the various ex situ alternatives presented in Volume One, Section 3.4. The ex situ alternatives provide for varying Volumes of low-activity verses HLW to be vitrified based on the level of separations (i.e., from separations to extensive separations).
Comment Number 0034.06
Belsey, Richard
Comment And I say all of this because -- as background to the fact that the committee and the board now has supported the alternative path as the one that is most likely to meet the needs of the Tri-Party Agreement, not the milestones.
The milestones are just indicators of how you are working on health and safety issues, moving toward the ultimate first step, the biggest step, which is taking it from being in a soluble form which can migrate into the ground, into the groundwater, into the Columbia River, and stabilizing that so it will keep in place for thousands of years.
Response DOE and Ecology acknowledge the concern expressed in the comment. DOE and Ecology are fully committed to the intent, as well as the milestone requirements in the 1994 Tri-Party Agreement and amendments to the Tri-Party Agreement.
Comment Number 0074.01
Sims, Lynn
Comment I think one of the issues here is that this project that we're talking about is probably the largest civil works project, the most expensive, and the most dangerous project ever attempted by mankind in history. And we're all very concerned about it and want to do the best we can to make it work. And that's, everybody is emotionally involved with this, and there might not be any good solutions, except to try to keep it out of the water, out of the Columbia River.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives and the response to Comment number 0026.02 for a discussion of impacts analyzed in the EIS, including impacts to groundwater and the Columbia River.
Preferences Related to Tank Waste Removal
Comment Number 0012.02
ODOE
Comment Oregonians oppose all tank waste options which leave significant amounts of waste in Hanford tanks. The cumulative impacts from all of the past activities at Hanford on public health and safety, the environment and the Columbia River make it inappropriate to consider leaving any of the tank wastes in place. The Northwest has shouldered more than a fair share of the cold war burden and its legacy. Hanford's cleanup mission must proceed.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Cumulative impacts from the TWRS alternatives and other proposed or reasonably foreseeable related actions are presented in Volume One, Section 5.13.
Comment Number 0012.04
ODOE
Comment The other alternatives under consideration leave most or all of the wastes in the tanks. With the exception of in situ vitrification, which is an undeveloped and unproven technology, other alternatives do little to remove the hazards posed by the wastes. To reduce the risks to people, these alternatives would require permanent closure of Hanford lands to other uses. Sacrificing Hanford in this way does not adequately reduce the harm and risks to the environment or to future generations. For these alternatives, the risk analyses in the EIS show massive plumes of radioactive material slowly moving across the Hanford site and into the Columbia River for hundreds to thousands of years.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Technical uncertainty of undeveloped or unproven technology, and the long-term risk associated with the various alternatives were factors analyzed by DOE and Ecology for each alternative. This information is presented in Volume One, Section 5.4. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. As stated in Volume One, Section 3.3, decision on closure of the tank farms will be made in the future. Additional analysis will be performed at that time concerning any additional measures that need to be taken to protect the groundwater and its future potential users. The TWRS EIS addresses the management, retrieval, treatment, storage, and disposal of the tank waste and does not address final remediation of the tank farm residuals, equipment, or soil contamination. For more information on closure, please refer to the response to Comment number 0072.08.
Comment Number 0012.05
ODOE
Comment Cost should not be the sole or even predominant criteria used to select among the alternatives. The first criteria that must be applied is protection of public health and safety and the environment. This criteria eliminates all of the alternatives which leave all or part of the waste in the tanks, except in situ vitrification. The EIS claims a lower risk for in situ vitrification, but because in situ vitrification technology is uncertain, the potential for failure is unacceptably high. We strongly oppose all of the alternatives which leave the waste in Hanford's tanks.
Also, the cost analyses do not include the lost value of the lands or the costs from harm to future generations or the environment. Ultimately, the costs of these alternatives would prove to be much greater than removing and cleaning up the wastes, as called for by the preferred alternative.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Volume One, Section 5.12 contains discussions of accident risk for each alternative. The EIS discusses long-term loss of land use and immediate and potential future risks to human health impacts. Neither is analyzed in terms of cost because a dollar value to human life and the land cannot be assumed.
Cost and risk to human health and the environment were several factors analyzed by DOE and Ecology for each alternative. Assessing the economic impact due to lost land value or harm to future generations other than health impacts or the environment were beyond the scope of this EIS and were not considered. Each impact was analyzed using a consistent methodology. The results were objectively presented in the EIS for the public and the decision makers. DOE and Ecology are committed to the Tri-Party Agreement requirement that no residual volume greater than 1 percent remain in the given tank, unless this requirement is not technically achievable.
Comment Number 0037.01
Eldredge, Maureen
Comment The risks in this EIS show clearly that the only responsible option is retrieving all the waste. This needs to start happening now.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0021.01.
Comment Number 0073.01
Yazzolino, Brad
Comment I simply wanted to put this in perspective, in the sense that I'm in the art world. The art world is basically lasts for thousands of years in the same sense that the radioactivity does. And I've been immersed in the geology of the Hanford area for the last year or so, and some other aspects about the river. And basically you need to remove the radioactive material from its proximity to the river because in fact that river valley has been there for about 21 million years. And it's going to persist in that area, and it's going to eventually wash your radioactivity to the sea, and spread it all over the river valley if you leave it there. It needs to be removed.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The long-term impacts associated with tank waste alternatives, including impacts for alternatives that would leave all or part of the waste in place in the tanks and others that would retrieve the greatest extent of waste practicable, were among the factors analyzed in the EIS. This analysis included human health and groundwater impacts that were calculated to 10,000 years in the future, as well as impacts associated with climate changes that potentially would result in the situation described in the comment. The response to Comment numbers 0012.01 and 0012.15 discusses the impact of past tank leaks and current efforts to determine the extent to which these leaks have impacted the area beneath the tanks.
Comment Number 0090.04
Postcard
Comment Please listen to us say no:
to leaving High-Level Nuclear Waste in our ground.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0026.02 for a discussion of the extent to which each of the alternatives would result in onsite disposal of HLW.
Comment Number 0091.02
Dyson, Jessica
Comment It is time to stop being in denial and start making public safety your utmost concern. In doing so, you must follow the Tri-Party Agreement and vitrify all the waste in the tank and it is not acceptable to leave any waste in the tank because that could pose a danger to the public in the future.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The DOE and Ecology preferred alternative, Phased Implementation, would comply with the requirement of the Tri-Party Agreement. As indicated in Volume One, Section 2.0, the underlying need for action is to "reduce existing and potential future risk to the public, Site workers, and the environment." DOE also must take action to "ensure compliance with Federal and Washington State laws regulating the management and disposal" of the tank waste and the cesium and strontium capsules. These underlying needs for the proposed action are also the basis for the continued management of the tank waste by the TWRS program, as described in Volume One, Section 3.2. Please refer to the response to Comment number 0026.02 for a discussion of the extent to which each alternative would retrieve waste from the tanks.
Preferences Related to Privatization
Comment Number 0014.04
Bullington, Darryl C.
Comment If Congress is really serious about containing existing hazardous wastes along with adequate monitoring and emergency planning it should set aside funds in separate easily identified accounts which are not subject to whatever political whim that comes along to be used exclusively to:
- Identify the size of all waste streams from all anticipated future sources and then establish a final repository sufficiently large to accommodate the demand for storage as required.
- Monitor the integrity of all existing tanks and establish plans and funds to reduce the danger of further leakage including emergency plans should further leakage occur.
- Reduce the options for safely confining stored wastes to several that can be achieved in the time frame established using existing technology and involving a minimum of time consuming and costly research and development. Chosen methods should have a high probability of accomplishing all milestones with the least risk to the public and the workers involved. Funds should also be set aside for insurance purposes should accidents occur. Safety of the public and the environment should take precedence over providing jobs or solving other social needs. These few alternatives, assuming that all the 50,000 curies of plutonium can be excluded from the biosphere, should then be contrasted with the do-nothing alternative. The report should show the costs and consequences of each alternative including a discussion of accidents that may occur along the entire pathway until confinement.
Response The purpose of this EIS is to present and analyze the range of reasonable alternatives that are available to remediate the tank waste at Hanford. Please refer to the response to Comment number 0072.05. DOE Richland Operations Office prepares a budget each year, which includes requests for funds used for cleanup; however, only Congress has the authority to appropriate funds. Congressional funding issues were not included in the scope of this EIS.
There are several ongoing activities involved with collecting and analyzing data on tank contents. Tank inventory data are presented in Volume Two, Appendix A (Tables A.2.1.1, A.2.1.2, and A.2.1.3), and waste projections for future tank waste additions are shown in Table A.2.4.1. Please refer to the response to Comment numbers 0012.14 and 0072.07 for a discussion of the tank waste inventory and characterization methods planned or currently under way.
Establishing a final repository is not included in the scope of this EIS; however, for the purposes of analyzing the alternatives presented in this EIS, a potential geologic repository candidate site at Yucca Mountain, Nevada was assumed to be the final disposal site. A discussion of the requirement for HLW disposal in a geologic repository is provided in Volume One, Section 6.2.
The TWRS program also includes monitoring the integrity of tanks and characterizing the vadose zone around the tank farms to detect leaks. DOE also conducts numerous activities to provide continued safe storage of the tank waste, and emergency plans have been developed and are in place. Descriptions of ongoing programs and tank safety issues are presented in Volume One, Section 3.2 and Volume Two, Appendix B, respectively. All monitoring and safety programs (Section 3.4) would continue through remediation. DOE is required to mitigate all accidents involving releases to the environment and Volume One, Section 5.20 identifies potential mitigation measures that could be implemented to alleviate the environmental impacts of the alternatives.
A range of reasonable alternatives was analyzed for the TWRS EIS, including the No Action alternative and alternatives involving extensive retrieval. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. The purpose of the EIS is to present the results of impact analyses in the most objective manner possible. These results will also be used by the decision makers to select an alternative and prepare the ROD. Volume One, Section 3.7 and Volume Two, Appendix B contain summary discussions of the alternatives comparisons. The Summary, Section S.7 contains an alternatives comparison, based on impact type and Volume One, Section 5.14 summarizes the environmental impacts of each alternative.
Comment Number 0017.01
Fisk, Charles P.
Comment Given Westinghouse's, Battelle's, etc. dismal performances, I certainly would not recommend privatization! Government created the mess and government should accept cost of remediation, not some for-profit corporation.
Response DOE and Ecology acknowledge the recommendation expressed in the comment. Although the contracting strategy known as privatization is not addressed in the EIS, the discussion of the Phased Implementation alternative does address the technical strategy of an incremental approach to tank waste remediation. Please refer to Volume One, Sections 3.3 and 3.4 of the EIS for more information on alternatives implementation and the Phased Implementation alternative.
Comment Number 0017.02
Fisk, Charles P.
Comment The "preferred alternative" is full of holes, as HEAL has persuasively analyzed far better than I can.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives and the response to Comment number 0009.19 for reasons Phased Implementation is the identified preferred alternative.
Comment Number 0017.03
Fisk, Charles P.
Comment The entire amount of waste needs to be vitrified, not just 25 percent of it, regardless of the cost. If, as Republicans propose, we could afford a continuation of "Star Wars", we can be assuredly cancel that wasteful idea and put the money into a completed and thorough clean up of the mess.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Cost was one factor analyzed by DOE and Ecology for each of the alternatives. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. For a discussion of the extent to which each alternative would result in waste retrieval and/or treatment please refer to the response to Comment number 0026.02. DOE and Ecology note that the preferred alternative would result in remediation of all waste practicably or no less than 99 percent.
Comment Number 0017.04
Fisk, Charles P.
Comment We have the technology for vitrification; now get with it and DO IT! The Columbia River deserves maximum protection as soon as possible.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. DOE and Ecology are committed to protecting the Columbia River. The response to Comment number 0012.01 addresses groundwater contamination and vadose zone characterization and monitoring. Please also refer to the response to Comment number 0072.05 for discussion of the approach to analyzing alternatives and technologies in the EIS.
Comment Number 0060.01
Davenport, Leslie C.
Comment I support the preferred Phased Implementation alternative, but with some changes; primarily that only one separations/LAW/HLW processing facility be built by a private contractor during Phase 1. The primary reason for this choice is that it can meet the Tri-Party Agreement and yet result in the minimization of overall costs and ultimately facilities needing decontamination and disposal. Whether additional separations should remove technetium, cesium, strontium, and TRU elements should be left to engineering judgement, dependent primarily on meeting required LAW product specifications for disposal onsite in near-surface retrievable disposal vaults. The other primary consideration would be to ensure that interim and final disposition methods for TRU elements always are critically safe.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. DOE and Ecology remain committed to compliance with the Tri-Party Agreement under which the general requirements for the preferred alternative were renegotiated in 1994. Specific separations technologies will be evaluated during the detailed design phase that will follow the final remedy selection and the ROD. Separation technologies, along with removal and immobilization technologies, will be tested during the demonstration phase (Phase 1).
Comment Number 0078.07
ODOE
Comment USDOE must move forward with cleanup as quickly as possible. USDOE must commit to remove all the waste from the tanks and convert it to a durable and stable waste form. The privatization alternative is the only alternative of the four acceptable alternatives that can be done soon. All of the others will involve extensive delays.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0072.05, 0076.03, and 0009.19.
Miscellaneous Preferences Related to the Alternatives
Comment Number 0032.03
Heacock, Harold
Comment We also do not believe the technical feasibility of several of the in situ treatment processes has been demonstrated adequately to seriously consider them as viable alternatives.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. ISV is a relatively new process that has not been tried at this scale previously, but was considered a potentially viable alternative. Implementability issues for each of the alternatives are discussed in Volume One, Section 3.4 and Volume Two, Appendix B. Please refer to response to Comment numbers 0072.10 and 0072.80 for information on NEPA requirement to consider reasonable alternatives in the EIS.
Comment Number 0035.02
Martin, Todd
Comment It continues to debate issues that have long been laid to rest, such as what is the waste form that we will use at Hanford. The preferred alternative does not mandate the glasses used. It does not mandate vitrification. It should. We have made that decision. Let's go forward.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Vitrification and glass-types were analyzed for the HLW disposal; however, DOE and Ecology have identified the treatment process for the LAW as immobilization rather than vitrification for the Phased Implementation alternative. As identified in Volume One, Section 3.4 and Volume Two, Section B.3 of the EIS, LAW would be processed using a technology that would meet LAW specifications. These specifications would be performance based, using vitrification as a benchmark, and would have specific requirements for size, chemical composition limits, isotopic content, and physical parameters. Even though the Tri-Party Agreement suggests that certain decisions have been made, NEPA requires an objective analysis of all reasonable alternatives. Please refer to the response to Comment numbers 0060.02, 0005.07, and 0034.05.
This approach to LAW treatment is consistent with the Tank Waste Task Force (HWTF 1993) recommendation to use the most practicable, timely, available technology, while leaving room for future innovation. All HLW removed from the tanks and that remains after separations will be vitrified under the preferred alternative. Please refer to the response to Comment number 0009.19 for a discussion of the reasons Phased Implementation is identified as the preferred alternative.
Comment Number 0036.09
HEAL
Comment HEAL supports the preferred alternative's pretreatment process.
The TWRS Task Force values on pretreatment are explicit and strongly held. According to the TWRS Task Force Final Report:
The high cost and uncertainty of high-tech pretreatment and R&D threatens funding for higher performance low-level waste forms, vitrification, and cleanup. Use the most practicable, timely, available technology, while leaving room for future innovation. Keep a folio of technological options and make strategic investments over time to support a limited number of promising options. Give up further research on unlikely options (TWTF p. 11)
The intermediate separations case is response to this value (although the difficult challenge of technetium removal in the Phased Implementation alternative is a concern). HEAL strongly opposes any movement toward an extensive separations pretreatment technology.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0098.02.
Comment Number 0046.04
DiGirolamo, Linda Raye
Comment Yes, encase in glass and bury this "CRUD" and more importantly... Stop all future plutonium fuel rod production at once. New Age Energy must be embarked upon at once to save man and the earth.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
Comment Number 0059.01
James Jordan Associates
Comment JJA recommends that the Environmental Impact Statement include in its analysis an alternative concept invented by Drs. Morris Reich, James Powell, and Robert Barletta of Brookhaven National Laboratory for the safe immobilization and isolation from-the-environment radioactive waste. This novel concept has the potential of being the safest, least costly, and most expeditious method for the disposal of the various radioactive wastes currently stored in the underground storage tanks at Hanford, including, if desired, the vitrification of the cesium and strontium capsules located at the Hanford Site.
This system which uses modular canisters with integral vitrification capability does not require an upgrade to the tank farm waste transfer system. This system will not require the construction of extensive buried transfer lines that is included in all of the alternatives except the No Action alternative. Indeed, the elimination of the complex tank farm waste transfer system significantly reduces the potential for short-term impacts of human health and the environment. Using modular canisters with integral vitrification provides for a dramatic reduction in the risk of long-term impacts on the public health and the environment in that the system does not have a large central vitrification facility to deactivate and dispose of at the end of the vitrification campaign. Compared to a conventional vitrifier, the in-can vitrifier does not require the pouring of molten radioactive glass.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The Draft EIS addressed the full range of reasonable alternatives. The alternative identified in the comment is bounded by the alternatives addressed in the Draft EIS. DOE and Ecology therefore believe that including the requested alternative would not provide valuable additional information to the public or decision makers. Please refer to the response to Comment numbers 0072.05, 0072.79, and 0097.01.
Comment Number 0060.02
Davenport, Leslie C.
Comment Both continued management alternatives are unacceptable for the long term.
The Minimal Waste Retrieval (In Situ) alternatives do not meet waste disposal laws, regulations, and policies and I feel are unacceptable in the long term. The In Situ Fill and Cap would not immobilize the wastes, only fill the tanks with gravel (creating more contaminated waste) and keep it all onsite in a form that would eventually leach to the groundwater. The In Situ Vitrification alternative is interesting and perhaps could be used on some of the small Multiple Underground Storage Tanks (MUSTs) that contain lower amounts of radioactivity, but the degree of technical uncertainty is too high to consider application to an entire tank farm of up to 20 tanks at once. Verifying that all tanks are completely vitrified down to 60 ft below the ground surface is nearly impossible, and there is no way to immobilize radionuclide plumes below the leaking SSTs.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. NEPA requires that an EIS address the full range of reasonable alternatives, including alternatives that would not comply with laws and regulations. The TWRS EIS addresses 10 alternatives for tank waste, ranging from No Action to extensive retrieval, and four alternatives for the cesium and strontium capsules. Please refer to the response to Comment numbers 0072.80 and 0072.10 for a discussion of the NEPA requirement to include a No Action alternative in the EIS analyses.
Comment Number 0060.03
Davenport, Leslie C.
Comment The partial waste retrieval alternatives do not meet waste disposal laws, regulations, and policies because they would retrieve only 90 percent or less of the radionuclides. I feel they will be deemed unacceptable in the future, thereby necessitating additional future operations to finish the job.
Response DOE and Ecology acknowledge the concerns presented in the comment. DOE and Ecology remain committed to compliance with the Tri-Party Agreement, which requires removal of all technically achievable waste or no less than 99 percent of the waste from each tank. Please refer to the response to Comment number 0060.02 and for discussions of the NEPA requirement to address a range of alternatives including alternatives that do not comply with regulations. Refer to the response to Comment numbers 0072.80 and 0072.10.
Comment Number 0060.04
Davenport, Leslie C.
Comment The extensive waste retrieval (ex situ) alternatives appear to be the only acceptable methods to deal with the approximately 200 MCi of radionuclides. However, the Ex Situ No Separations alternative appears to be too expensive because all tank wastes would be vitrified and/or calcined, resulting in too many high-level waste packages to ship to and store in a waste repository. The Ex Situ Intermediate and Extensive Separations alternatives are difficult to choose between, because the efficiency of the sludge washing, ion exchange, and multiple complex chemical separations processes are not fully known for the various types of tank wastes. Hence, those two alternatives should be compared in a pilot plant using a Phased Implementation (possibly along with the In Situ Vitrification alternative applied selectively, particularly for MUSTs, and SSTs that have not leaked).
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
Technical evaluation, categorization of tank waste, and application of appropriate technology would be conducted during Phase 1 (demonstration phase) of Phased Implementation and during the detailed design phase of any alternative analyzed in the EIS. Volume One, Section 3.4 includes descriptions of the processes, cost, and Implementability for each tank waste alternative. Volume One, Section 5.14 provides a summary of the environmental impacts for each tank waste alternative. The EIS provides
the basis for comparison among the alternatives identified. DOE and Ecology believe sufficient differentiation exists between the alternatives to support a decision on the alternative to be implemented; therefore, a demonstration phase comparison of the two alternatives would postpone remediation.
Comment Number 0072.10
CTUIR
Comment The Tri-Party Agreement mandates full retrieval as the goal; only if this is not practicable on a tank-by-tank basis can lower retrieval goals be negotiated. Therefore, the in situ alternatives are not allowed and did not have to be evaluated.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
As required by the CEQ, the TWRS Draft EIS identifies and analyzes a range of reasonable alternatives for the proposed action, including those that are "not within the jurisdiction" of the agency (40 CFR 1502.14). DOE guidance on NEPA requires that EIS alternatives be addressed even if there is "conflict with lawfully established requirements" (DOE 1993d). However, the Agency is required to identify the laws and regulations that apply to each alternative and indicate if the alternative, if selected for implementation, would comply with applicable laws and regulations. This information must be provided to the public and the decision makers. Therefore, the failure to comply with the Tri-Party Agreement is not sufficient basis for excluding an alternative from detailed analysis in the EIS (40 CFR 1502.2d). A discussion of the methods used to develop the alternatives in compliance with NEPA requirements is presented in the response to Comment number 0072.05. Please refer to the response to Comment numbers 0072.80 and 0072.52.
Comment Number 0072.16
CTUIR
Comment In situ alternatives were not necessary since they are not allowed under the Tri-Party Agreement.
Response Please refer to the response to Comment numbers 0072.10 , 0072.52, and 0072.80.
Comment Number 0076.03
Blazek, Mary Lou
Comment The preferred alternative relies on using proven technology, and using a phased approach. We think a learn as you go approach makes sense, given the history of Hanford. And that should identify problems earlier, and at smaller economic and environmental cost.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The Preferred Alternative would allow DOE to proceed with tank waste remediation. System modifications would be evaluated as waste inventory, removal method, separations, and disposal data are collected and analyzed during the Phase 1 demonstration. This continuous improvement is the cornerstone of the "learn and improve while doing" approach cited in the comment. Please refer to the response to Comment numbers 0060.04, 0060.02, and 0009.19 for more information on the preferred alternative.
Comment Number 0077.02
ODOE
Comment Leaving wastes in the tanks poses huge risks. The tanks are corroding and failing. As they fail, the radioactive waste is released to the soil and ultimately to the groundwater and to the Columbia River. Vitrifying the tank waste makes it far more stable and greatly reduces the threat to the public and the environment. While the cost of the preferred alternative is substantial, it is the only alternative which satisfactorily deals with the dangers presented by these wastes as quickly as practical. The phased approach allows USDOE to get on with cleanup while allowing for possible development of better approaches which remove all tank wastes.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please also refer to the response to Comment numbers 0076.03 and 0060.04. The response to Comment number 0091.01 addresses protection of the Columbia River in relation to the preferred alternative.
Comment Number 0078.02
ODOE
Comment Unacceptable Alternatives
The EIS evaluates the alternatives USDOE believes are available for the tank waste. Four alternatives are unacceptable because they could allow exposures to the environment and the public at levels higher than allowed. These include:
- Two alternatives manage the waste as is; in failing tanks,
- Two alternatives leave all or most of the tank waste in the tanks covered with sand and a complex barrier to keep rain water out,
- One alternative proposed vitrifying all of the waste in the tanks in place.
A sixth alternative was added as the EIS went to print. This alternative is included in the cover letter for the EIS and is not analyzed in depth in the EIS. It would leave most of the waste in the SSTs, fill the tanks with sand and cover them with a barrier.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. NEPA requires an EIS address a comprehensive range of reasonable alternatives. The TWRS EIS fully addresses 10 alternatives for tank waste, which includes no action, long-term management, in situ, ex situ, and combination alternatives. NEPA also requires that these alternatives be analyzed regardless of regulatory compliance to allow an even-handed analysis of all factors, as discussed in the response to Comment number 0072.80. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
Comment Number 0078.03
ODOE
Comment
Unacceptable Alternatives
The EIS includes four alternatives which meet legal requirements. These are:
- Retrieve all of the waste, glassify it and sent it to a national high-level nuclear waste repository,
- Retrieve all of the waste, use extensive chemical processes to separate the nonradioactive portions from the radioactive portions, glassify them and send the glass to a national high-level nuclear waste repository,
- Retrieve all of the waste, use less extensive separations of the waste into high-activity and low-activity fractions, glassify, both, bury the low-activity fraction at Hanford and send the high-activity fraction to a national high-level waste repository (Government owned and contractor operated),
- Do the same as three, but do it in phases using private companies to build and operate the plants. (This is the preferred alternatives in the EIS).
If privatization fails, the Tri-Party Agreement requires USDOE to revert to government owned and operated vitrification plants.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please also refer to the response to Comment number 0072.80 for a discussion of the NEPA requirements to analyze a full range of alternatives in an EIS regardless of regulatory compliance.
Comment Number 0079.01
Knight, Paige
Comment Hanford Watch supports the phased implementation plan, not because it's so great, but because it gets the waste out of the tanks. It is our conviction that waste must be removed from the tanks and put in a stable form. If this new preferred alternative reaches a point of failure, you must be prepared to turn back immediately to the path outlined in the Tri-Party Agreement, and follow the advice given by the Tank Waste Task Force, in the summer and fall of 1993. That advice can be summed up in the words get on with cleanup. The public has stated time and time again that the DOE must get on with it. Hear us. Do not change paths again.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0072.05 and 0076.03. Please also refer to the response to Comment numbers 0009.19 and 0060.02 for more information on the reasons Phased Implementation was identified as the preferred alternative.
Comment Number 0079.03
Knight, Paige
Comment The alternative of long-term management also is unacceptable because according to the TWRS EIS that document will end in, that management will end in 100 years. This possibility the amount of time previous to the waste plumes becoming a severe health risk to the public and the environment.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please refer to the response to Comment number 0040.02 and 0101.01 for a discussion of the 100-year administrative control period.
Comment Number 0079.04
Knight, Paige
Comment The in situ alternative is also unreasonable, because again no protection of the groundwater is offered, and security and external control will end in 100 years. And that's when the contamination, theoretically, is going to become a real problem for the health and environment, health of people and environment. Further, the use of riprap basalt is suggested. And we fear that this material will be taken from sites at Hanford, that are sacred to the Indian tribes.
In short, any plan to leave this deadly brew of wastes in the tanks is totally unacceptable, and will meet with the resounding opposition from the citizens of the region. Water is sacred, and must be protected at all costs.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please refer to the response to Comment numbers 0091.01 and 0012.01 for discussions of groundwater issues related to current and planned monitoring programs and protection of the Columbia River.
Volume One, Section 5.7 describes the land-use impacts of the various alternatives, including impacts to potential borrow sites. Volume One, Section 5.5 describes the cultural resources impacts, including prehistoric and historic sites, and issues of potential concern to Native Americans. DOE and Ecology remain committed to protecting the groundwater beneath the Hanford Site and the Columbia River and impacts to groundwater and the Columbia River are addressed in Volume One, Section 5.2 and Volume Four, Appendix F. Please see the response to Comment number 0019.03 for a discussion of borrow site issues. Please refer to the response to Comment number 0040.02 and 0101.01 for a discussion of the 100-year administrative control period. Response to Comment numbers 0091.01 and 0012.01 discuss groundwater issues related to current and planned monitoring programs and protection of the Columbia River.
Comment Number 0085.01
Klein, Robin
Comment Except to say that the no action alternatives, including long-term management are unacceptable options. They are not within the range of reasonable alternatives as the Draft EIS states. But are imprudent, hazardous, and in violation of the Tri-Party Agreement.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please also refer to the response to Comment numbers 0072.52, 0072.05, 0078.02 and 0072.80.
Comment Number 0087.04
Tewksbury, Ross
Comment And I think that they should do the extensive waste retrieval and vitrify all, or nearly all of it, and whether it's stored on the site, or off the site is not really the major thing. The major thing is to get it in a form where it's not able to leak out into the groundwater and soil and the river, and everything else, and to do that as fast and as safely as possible. And I think that you should not really be concentrating on this waste separation idea that you were going over tonight, except what's absolutely necessary for the technical, chemical, and safety purposes. Because all of it has to be taken care of for hundreds, if not thousands of years. Thank you.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0072.05 and 0078.02. The phased approach to the alternative implementation is discussed in the response to Comment numbers 0060.04 and 0076.03. Groundwater protection issues are discussed in the response to Comment numbers 0091.01 and 0012.01.
Comment Number 0088.01
Porter, Lynn
Comment I guess I support the preferred alternative because it sounds better than the others.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0014.04, 0072.05, 0078.02, 0009.19, and 0060.02 for a discussion of the reasons Phase Implementation has been identified as the preferred alternative.
Comment Number 0089.01
Nez Perce Tribe ERWM
Comment The Nez Perce Tribe ERWM favors protection of the Columbia River and its ecosystem through removal and disposal of tank wastes from 200 Area tanks as supported by the EIS. ERWM believes groundwater and the Columbia River are at risk from potential radionuclide or toxic chemical releases from the tanks. We endorse the alternative calling for removal of tanks wastes through one of the Ex Situ Separations alternatives or Phased Implementation.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0014.04, 0072.05, and 0078.02.
DOE and Ecology remain committed to protecting the groundwater beneath the Hanford Site and the Columbia River and its ecosystem. An analysis of impacts to groundwater and the Columbia River are provided in Volume One, Section 5.2 and Volume Four, Appendix F. Discussions related to groundwater and protection of the Columbia River are contained in the response to Comment numbers 0091.01 and 0012.01.
Comment Number 0093.02
Devoy, Tiffany
Comment I also would like to say that I do think the Tri-Party Agreement should be followed in this case and actually in most cases and it seems odd that there is always someone trying to get out of it. It was signed and I think it should be followed. I think that they need to vitrify as much waste as possible and to leave as little waste behind as possible and I do not think that is an unrealistic expectation. There are 177 tanks and I do not even remember what was quoted to me as to how many gallons each those tanks were but it is pretty amazing and to think of all that waste concentrated and to just leave it there, I know that is not your preferred alternative, but I think some of your alternatives are not that much better. So vitrify it as much as possible, leave as little behind as possible, and follow the Tri-Party Agreement. That is about it.
Response DOE and Ecology acknowledge the preference for extensive waste retrieval, treatment, and disposal within the context of the Tri-Party Agreement expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating TWRS waste. The inclusion of alternatives in the EIS that do not comply with the Tri-Party Agreement complies with the NEPA, which is the Federal law requiring the preparation of this EIS. Please refer to the response to Comment numbers 0072.10 and 0072.80 for a discussion on requirements for inclusion of alternatives in an EIS analysis.
L.3.4.2 Elements Common to Tank Waste Alternatives
Comment Number 0098.03
Pollet, Gerald
Comment The public deserves to know how much money is going to be taken out of the authorization for Hanford clean up for the so-called privatization reserve. This process is a sham so long as an undisclosed amount of your Hanford clean up dollars are being removed in the future. Let us face it, basically the President and Congress have said you are going to have less money for Hanford clean up, we know what the President's projection is, it is seriously less than it used to be, and out of that a future chunk is going to privatization in a liability reserve but you and I can not see what it is. At the same time, the Department of Energy has target budgets now through the year 1998 which fail to fully fund essential safety and Tri-Party Agreement activities such as characterizing the wastes in these tanks. As the General Accounting Office has said, If you fail to properly characterize, you can not expect the contractors to be able to vitrify and, in fact, anyone can see down the road that the contractors are liable to say, You did not characterize properly, therefore, you owe us the full cost we put out for building the plant and our anticipated profit, we will take that 1.4 whatever billion dollar reserve it is, put it in our corporate pockets, the government will be out that money, you will have a plant that will not work because wastes were not characterized. Currently, the Department of Energy is planning in its budgets to be at least 3 years behind the Tri-Party Agreement requirement for characterizing the wastes. This can not be allowed to go forward.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The privatization contracting strategy and the budgetary process for funding the alternative selected are outside the scope of this EIS. DOE Richland Operations office prepares a budget each year, which includes funds required for cleanup; however, only Congress has the authority to appropriate funds. Please refer to the response to Comment numbers 0012.14 and 0072.14 for discussions of issues related to the tank waste inventory and ongoing efforts to characterize the tank waste.
Comment Number 0101.01
Yakama Indian Nation
Comment Unrealistic Assumptions Regarding Institutional Controls Restricting Future Human Actions --Design basis assumptions associated with the disposal of waste at Hanford optimistically assume protective conditions will exist in the future in connection with the estimation of impacts to the public
health and safety and the environment. Specifically, we consider the assumption of institutional controls restricting intruder actions or inadvertent intruder actions beyond about 130 years hence is invalid.
Response DOE and Ecology concur that intruder or trespasser activities could not be monitored or restricted beyond 100 years. The 100-year administrative control period is a bounding assumption used during the analysis of the alternatives. For all alternatives analyzed in the EIS, post-remediation risks assume that institutional controls would not exist beyond 100 years. Please refer to the response to Comment numbers 0040.02 and 0040.03 for more information regarding administrative controls. Because the information contained in the text was correct, no change was made to the document.
Comment Number 0101.04
Yakama Indian Nation
Comment Consideration of Low-Impact Waste Management Alternatives--Alternatives which evaluate impacts associated with the minimization of the volume of waste retaining a long-lived hazard (hazardous for 130 years or more) and large cask storage of stabilized wastes was not accomplished. We believe such options which were addressed in preliminary impact analyses, should be presented in the impact statement to allow full assessment of options. We consider that DOE (OCRWM) actions in preparation of the EIS to require consideration of small casks with no apparent technical or economic basis is unwarranted and capricious.
For example, the use of 10 cubic meter capacity (m3) (360-cubic foot [ft3] casks for storage and/or disposal of stabilized high-level radioactive wastes should be evaluated. Furthermore, consistent with evaluating alternatives which minimize the volume of waste for disposal, the option of using waste processes that would purify sodium salts (making up about 85% of the solids in the tanks) to a specific activity and hazard equivalent to Class A low-level radioactive waste with the calcination of the remaining high-level radioactive waste stream should also be specifically compared with processing options that produce larger volumes of long-lived hazardous wastes.
We note that the an additional benefit of removing sodium is the added stability of potential high-level radioactive waste forms without significant sodium, making this processing option desirable for disposal performance assessments.
Response The Ex Situ No Separations Vitrification and Ex Situ No Separations Calcination alternatives have been revised for the Final EIS to use a 10-m3 (360-ft3) canister for HLW storage and disposal. The size assumptions are presented in Volume One, Section 3.4 and Volume Two, Appendix B. These canister sizes have been used for impact analysis presented in Volume One, Section 5.0, Volume Three, Appendix D, Volume Four, Appendices E and F, and Volume Five, Appendices G and H. Please refer to the response to Comment number 0081.02 for related information.
The use of crystallization to remove sodium salts from the waste stream is included in the Ex Situ Extensive Separations alternative as a technology that could potentially reduce the LAW volume. This technology was not included as a primary treatment technology because it was not sufficiently mature to allow detailed evaluation. The focus of the EIS was to evaluate alternatives, rather than specific technologies, to allow sufficient flexibility to evaluate and implement emerging technologies in the future. Please refer to the response to Comment number 0072.05 for information on NEPA alternatives analysis requirements.
DOE and Ecology agree that removal of the sodium from the waste stream prior to immobilization potentially would reduce the volume of HLW for the Ex Situ No Separations Vitrification alternative and LAW for the ex situ alternatives that include separating the HLW and LAW for treatment. It would be expected that removal of the sodium would result in increasing the waste loading such that either waste form would meet waste form performance criteria. Please refer to the response to Comment numbers 0027.11 and 0008.01 for more information related to waste loading and the response to Comment numbers 0008.01 and 0009.08 for more information regarding consideration of canister (cask) size in the Draft and Final EIS.
Comment Number 0101.07
Yakama Indian Nation
Comment On another scale the impacts associated with the disposal of waste streams generated by the actions being considered must also be considered in a integrated manner. The issue associated with waste minimization and waste package sizing greatly affects disposal costs and other impacts, particularly those associated with the high-level radioactive waste deep repository at Yucca Mountain. Integration of the disposal facilities under the office of Civilian Waste Management (OCRWM) and the TWRS in DOE's overall environmental management actions should be evaluated and assessed from a systems engineering approach to resolve this issue.
We consider large savings (several billion dollars) are possible if valid systems integrations are accomplished compared to the base-line alternatives currently being pursued by DOE. These estimates stem from cost evaluations accomplished by the authors of the subject EIS.
Response Large canisters have been addressed in the Final EIS.
Please refer to the response to the following comments for more information:
- Comment numbers 0004.01 and 0081.02 - coordination with Office of Civilian Radioactive Waste Management (OCRWM) and revisions to repository cost calculations
- Comment number 0008.01 - canister size re-evaluation decision
- Comment number 0027.02 - systems engineering approach to the alternatives evaluation
- Comment number 0037.04 - relationship of the TWRS EIS to other Sitewide NEPA and programmatic documents.
The cost estimates in the EIS include contingency and a range of uncertainty based on the conceptual nature of the alternatives and standard industry practice for large capital projects. DOE expects that as detail design progresses, progress in technology optimization will result in cost savings. Please refer to response to Comment numbers 0052.04 and 0081.03.
L.3.4.2.1 Issues Related to Disposal Costs Calculations and Repository
Comment Number 0004.01
Boldt, A.L.
Comment References:
- DOE, 1996, Draft Environmental Impact Statement for the Tank Waste Remediation System, DOE/EIS-0189D, U.S. Department of Energy, Richland, Washington and Washington State Department of Ecology, Olympia, Washington, April, 1996.
- DOE, 1995, Analysis of the Total System Life Cycle Cost of the Civilian Radioactive Waste Management Program, DOE/RW-0479, U.S. Department of Energy, Washington D.C., September, 1995.
- Nuclear Waste Policy Amendments Act of 1987, Public Law 100-203, December 22, 1987, 42 USC 10101 et seq.
- Federal Register Notice, Civilian Radioactive Waste Management; Calculating Nuclear Waste Disposal Fees for Department of Energy Defense Program Waste, pp. 31508-31524, Vol. 52, No 161, August 20, 1987.
- TRW, 1995, Assessment of Pre-Closure System Cost and Health and Safety Impacts of Hanford HLW Vitrification Options on the Civilian Radioactive Waste Management System, A00000000-01717-5705-00003, Rev. 0, TRW Environmental Safety Systems, Inc., Vienna, Virginia, April 27, 1995.
The geologic disposal costs presented in section B.3.0.8 of the draft TWRS EIS (ref 1) are based on a linear extrapolation of the unit container disposal costs provided by reference 2 for a specific scenario. The linear extrapolation of the unit container disposal cost from reference 2 to all the TWRS alternatives does not meet the requirements of the Nuclear Waste Policy Amendments Act (ref 3) and Federal Register Notice 52-161 (ref 4).
Federal Register Notice 52-161 identifies, in detail, the method to be used in estimating the disposal fees for the Department of Energy defense program HLW (HLW) share of total Civilian Radioactive Waste Management System (CRWMS) costs. Federal Register Notice 52-161 cost allocation is based on the concept of full cost recovery with sharing formulas applied to all fixed and variable system cost components.
The assumption of linear extrapolation of unit container disposal costs in the draft TWRS EIS greatly underestimates the disposal costs of the extensive separations alternative and greatly overestimates the disposal costs of the no separations alternative. Example disposal cost variability for alternate HLW container sizes and HLW volumes resulting from no separations, intermediate separations, and extensive separations using the methodology specified in Federal Register Notice 52-161 are provided in reference 5.
I am requesting that the draft TWRS EIS be revised to incorporate HLW disposal costs calculated with the methodology specified by Federal Register Notice 52-161.
Response As stated in Volume One, Section 3.4, the repository fees are based on the 1995 Analysis of the Total System Life Cycle Cost (1995 TSLCC) of the Civilian Radioactive Waste Management Program. The Draft EIS also acknowledges that the 1995 TSLCC was based on a single scenario and one repository. It is acknowledged that there is uncertainty in identifying a disposal fee prior to the final licensing of a national repository. Additional uncertainty results from analyzing various options considered in the EIS as the number of canisters varies from the baseline. However, DOE will comply with the provisions of the Nuclear Waste Policy Act requiring full cost recovery. The purpose of the cost analysis is to provide a basis for comparison among the alternatives (TWRS Draft EIS, Volume Two, Appendix B, page B-40).
In response to public comment, for the Final EIS, DOE and Ecology have reevaluated the estimate of disposal costs presented in the Draft EIS, using the 1987 methodology to more accurately reflect possible costs associated with disposal for the various canister options presented. This effort was coordinated through the OCRWM. Please refer to the response to Comment numbers 0081.02 and 0008.01 for additional information.
Comment Number 0005.44
Swanson, John L.
Comment I do not get the point of the sentence on page 3-37 "The use of a standard-sized canister does not consider waste loading, which ranges from 113,000 curies per canister to about 300-."
Response The use of the term "waste loading" here certainly could be confusing as it also refers to the waste loading of the glass with respect to percent sodium or waste oxides. Individual chemical entities such as sodium were considered in the "waste loading" of the glass. The quantity of radioisotopes and curie content was not limited in the glass formulations because the maximum heat load per canister was below the limit of 1,500 watts set for the repository.
The Final EIS was revised to include larger HLW canisters, which eliminates the need for the subject discussion in Volume One, Section 3.4. Please refer to the response to Comment numbers 0008.01 and 0081.02 for more information.
Comment Number 0008.01
Evett, Donald E.
Comment First, Current planning also assumes that this waste could be contained in approximately 18,000 standard-sized canisters. Also, there is insufficient capacity in the first repository to accept all Hanford Site -high-level waste under almost every alternative. Your study states that an estimated $360,000 cost per canister disposed of at the repository. The report alludes to the feasibility of using much larger canisters whereby the repository fees could be substantially reduced. In my opinion, I would think that the Department of Energy would vigorously pursue the much larger canisters.
Response Larger HLW canisters result in fewer waste packages for disposal at the geologic repository and offer substantial cost savings over the use of standard-sized HLW canisters. DOE is pursuing the use of HLW canisters that are larger than the standard-sized canister currently defined in the repository Waste Acceptance Systems Requirements Document (DOE 1994g). Since the Draft EIS was published, DOE-RW has acknowledged the technical feasibility of a larger canister for HLW and an independent technical review team convened to review the waste loading and blending assumptions used in the Draft EIS. The recommendations of the independent technical review team, along with the larger HLW canister specifications, have been incorporated into the ex situ alternatives for the Final EIS. The use of larger canisters and revised estimates for HLW volumes have been incorporated into the repository fee estimates shown in the Summary, Volume One, Section 3.0, and Volume Two, Appendix B. Section 3.4 describes the common assumptions for canister size and waste loading and additional detail is provided in Appendix B. Please refer to the response to Comment number 0081.02.
Comment Number 0008.02
Evett, Donald E.
Comment What happens if the Yucca Mountain project is defeated? What happens next and where will the canisters be disposed? If the year 2015 is the earliest date for acceptance of the high-level waste in canisters, where will the canisters be stored until this time? It is assumed that the use of canisters can commence much earlier than the year 2015.
Response DOE fully intends to comply with the Nuclear Waste Policy Act of 1982 as amended, which requires development of sites suitable for long-term disposal of spent nuclear fuel and HLW, and with DOE Order 5820.2A, which requires that HLW be processed and disposed of in a geologic repository. Therefore, disposal of HLW in a geologic repository was assumed and used as the basis for all alternatives involving HLW retrieval. The in situ and combination alternatives would result in onsite HLW disposal and the EIS analyzes the impacts associated with those actions. See Volume One, Section 6.0 for a discussion of the regulatory requirements and Volume One, Section 3.4 for assumptions associated with the geologic repository included in the EIS. Onsite storage at the Hanford Site for the HLW under the ex situ alternatives for up to 50 years is analyzed in the EIS. If longer-term storage is required due to delays in opening the geologic repository for disposal, appropriate NEPA analyses will be conducted.
Comment Number 0012.06
ODOE
Comment A large part of the cost shown for the vitrification alternatives included charges to dispose of the waste to the national high-level waste repository. These charges should not be used to decide whether to put the waste in a stable and durable form.
Several alternatives call for removal of all wastes from the tanks and vitrification. They differ in the methods used, complexity, speed and cost. The repository charges should be used as one criteria in deciding among these alternatives.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The cost estimates developed for each ex situ alternative presented in Volume One, Section 3.4 list the treatment cost, the estimated repository fee, and a total alternative cost range that combines treatment cost and estimated repository fee. The estimated repository fees, as acknowledged in the Draft EIS, have a high degree of uncertainty. Please refer to the response to Comment numbers 0004.01, 0008.02, and 0081.02 for more information concerning repository costs, canister size, and related uncertainties.
Comment Number 0027.02
Roecker, John H.
Comment Technical Data Manipulation
In Chapter 3 (page 3-33) DOE discusses the wide range of HLW canisters that could be produced and it makes reference to a WHC document for the low end of the range and a DOE document for the high end. The WHC document is an engineering document containing factual technical data and the DOE document is a set of comments on the TWRS System Requirement Document, which are not supported by technical data. This is another example of DOE Headquarters continuing to manipulate the technical data to support and satisfy their agenda rather than letting facts tell the story openly and honestly. Incidentally, the TWRS System Requirements Document has not yet been approved, to my knowledge, but yet here we are reviewing EIS alternatives which are supposed to be based on systems engineering. More on that later. I would request that in the Final EIS such manipulations of the technical data be eliminated and that all data be presented in accordance with standard systems engineering techniques and principles.
Response Because the alternatives evaluated in the EIS are conceptual at this time, engineering feasibility is limited to an Implementability review for each alternative. This is consistent with CEQ guidance that NEPA analysis occur as early in the decision making process as possible and always before irreversible and irretrievable commitments of resources have been made (40 CFR 1500). Following the publication of the Final EIS and approval of the TWRS ROD, a systems engineering and safety analysis of the preferred alternative will continue during the detailed design phase of the demonstration facilities. DOE intends to continue using systems engineering as a method for evaluation and implementation of the TWRS mission. It is anticipated that the detailed design of the waste retrieval, transfer, treatment, and storage demonstration facilities will be conducted using the system engineering and safety requirements currently being developed for TWRS (and concurrently with the TWRS Draft EIS).
The EIS presents an unbiased evaluation of each of the alternatives using the best available information. More information on canister assumptions and revisions to the EIS in response to revised information on canister size can be found in the response to Comment number 0008.01
Comment Number 0027.05
Roecker, John H.
Comment Repository Cost
I am not a lawyer, but in my reading of the Nuclear Waste Policy Act (NWPA) of 1982 as amended in 1987 and the Federal Register Notice 52-161 I believe it is quite clear on how the repository fee for disposal of HLW should be calculated. The use of linear extrapolation of a unit container cost for a specific disposal scenario to calculate the repository fee for all alternatives is completely wrong, misleading and totally obscures the real cost of each alternative. The use of a linear extrapolation of unit container cost greatly understates the cost of disposal for the extensive separations alternative and greatly overstates the cost for the No Separations alternative. This is a blatant example of data manipulation to make a particular alternative look attractive and misleads both the public and decision makers.
Response Please refer to the response to Comment numbers 0004.01, 0008.01, and 0081.02.
Comment Number 0027.07
Roecker, John H.
Comment Use of 0.62 m3 HLW Canister
Requiring Hanford to use the 0.62 m3 canister is overly restrictive and ridiculous particularly in light of the fact that a larger canister will be required for spent nuclear fuel. A larger HLW canister is a significant advantage for Hanford waste disposal and should be utilized.
Response DOE and Ecology recognize the potential benefits of using a larger canister for HLW. The use of larger HLW canisters has been included in the Final EIS. The size assumptions are presented in Volume One, Section 3.4 and Volume Two, Appendix B. These canister sizes have been used for impact analysis presented in Volume One, Section 5.0 and Appendices D, E, F, G, and H. Please also refer to the response to Comment number 0008.01 for more information on canister size and related impact on repository costs.
Comment Number 0035.04
Martin, Todd
Comment A clear stakeholder value has been that Yucca Mountain should not drive decision. We have said that the best waste form should determine which waste form is used, not the site, nor size, nor cost of a speculated national repository.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Repository considerations associated with the size, location, and cost of the potential repository did not drive the EIS analysis of waste form. The waste forms analyzed in the EIS are discussed relative to their ability to comply with existing waste acceptance criteria at the proposed repository; however, the analysis shows that the only waste form acceptable at the proposed repository is the one presently identified in the Tri-Party Agreement. This waste form is a borosilicate glass. Further, the information regarding timing is presented to provide a base case plan for analysis of impacts as required under NEPA. Information regarding the size of the repository is presented to inform decision makers and the public of the potential impact of TWRS waste on planning for the repository and the potential need for a second repository. In all cases, the EIS assumes, for purposes of impact analysis, that the waste would be stored on an interim basis at the Hanford Site and ultimately shipped for disposal at a geologic repository. The Final EIS has been revised to provide for up to 50 years of interim storage onsite. Each ex situ alternative includes interim onsite storage large enough to hold all HLW produced. This allows the waste treatment program to move forward with out relying on the geologic repository. The interim storage method provides for shielded storage of the immobilized HLW, protective of human health and the environment.
This is consistent with the Tank Waste Task Force value that DOE "accept the fact that interim storage, at least, of the waste in an environmentally safe form will occur for some time at Hanford" (HWTF 1993). Later in the Tank Waste Task Force report when addressing waste storage, a discussion is included that advises DOE to "assume temporary storage will occur at Hanford but don't assume that all radionuclides should be here forever." Please refer to the response to Comment numbers 0008.02, 0004.01, 0038.10, 0052.01, 0035.04, 0012.11, and 0055.03 for all issues related to tank waste disposal and the TWTF.
Comment Number 0035.05
Martin, Todd
Comment I would like to address the cost estimates and how they effect the TWRS EIS, particularly in regards to Yucca Mountain.
If you look at some of the simple technical assumptions that are made in the EIS, such as waste loading, the amount of waste that gets into the glass, it dramatically affects cost.
The waste loading has been altered by a mere factor of a little bit more than 10 percent over the last couple of months. Some of the blending assumptions have been changed.
What does that do to cost? If you look at the preferred alternative, it changes the repository cost from four billion dollars all the way up to 12 billion dollars. That is a big impact for such a small change.
The no separations options, change the canister size. What does that do to the cost? It changes the repository cost from about 13 billion all the way up to over 250 billion dollars.
These overly conservative assumptions and the uncertainty with the repository are driving the costs that we see in this EIS. That is inappropriate, and the stakeholders have made that clear in the past.
Response The repository fees presented in the Draft EIS for the ex situ alternatives were overly conservative, but consistent with the published information DOE had at the time the Draft EIS was published. The Final EIS has been modified based on new guidance from the repository and an independent technical review of the Draft EIS. Please refer to the response to Comment numbers 0004.01 (repository fees and associated uncertainty), 0008.01 (canister size assumptions and associated changes in repository costs), 0027.11 (HLW waste loading), 0035.04 (comprehensive repository issues), and 0081.02 (separation of respository costs from alternative costs).
Comment Number 0036.01
HEAL
Comment Unfortunately, the repository plays an important role in the cost analysis of EIS alternatives. The EIS does include the speculated repository cost as a separate cost item, allowing the careful reader to see the role the repository plays in cost. This is an improvement. But many will not read beyond the Summary -- where the total cost is the only number available. The EIS itself makes a very good case for removing the repository cost numbers:
(The estimate of repository disposal costs)"... is an estimate based on numerous assumptions. Nor should the assumptions used in the analysis be interpreted as final DOE policy. The program is in the early stages of development and design concepts for items such as the repository surface facility, underground layouts, and waste packages are very preliminary. The techniques used to estimate the total system cost were appropriate to the limited level of design development and entail a corresponding level of uncertainty ... There is a high degree of uncertainty in using a fixed cost per canister for geologic disposal over the wide range in the number of canisters that would be produced for the TWRS alternatives." (p. 3-37)
In other words, there is almost no basis for the repository disposal costs and they should not be trusted.
The continued high-profile role of the speculated repository is unacceptable. It goes against past stakeholder values and common sense. Further, the EIS itself says that DOE will bring the program to a safely stored state at Hanford, regardless of the repository's existence. Each of the ex situ alternatives will include onsite storage sufficient for ALL the waste. According to the EIS, "This would allow each of the alternatives to operate independent of the acceptance schedule for the potential geologic repository" (p. 3-38). The Final EIS must be rewritten in such a way as to clearly put the repository in perspective and dramatically reduce the role the repository plays in the document.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The Final EIS has been revised to discuss HLW disposal at the geologic repository
and the associated cost separately. See Volume One, Section 3.7 and Volume Two, Section B.9 for the revised discussion of HLW disposal at the geologic repository. Please refer to the response to Comment numbers 0004.01, 0008.02, 0035.04, and 0081.02.
Comment Number 0036.02
HEAL
Comment The EIS is biased to maximize the cost impact of the national repository.
Over the last few months, changes in waste loading, blending, and canister assumptions have maximized repository costs. The assumption changes are a radical departure from past TWRS assumptions and are not based on any evident engineering data.
Assuming waste loadings similar to those in Tri-Party Agreement studies results in the following repository fees:
- about $4 billion dollars for the "Phased Implementation" alternative.
- about $13 billion for the "no separations" alternative.
After the assumptions were changed, the "Phased Implementation" repository fee rose to about $12 billion and the "no separations" skyrocketed to over $250 billion. Meanwhile, the repository fee for extensive separations stayed relatively constant.
These assumptions may seem minor, but obviously have a large -- and inappropriate -- impact.
Response DOE and Ecology acknowledge that the repository fees presented in the Draft EIS for the ex situ alternatives were overly conservative. The data to support the TWRS EIS assumptions, analysis, and calculations were cited in the Draft EIS and engineering data packages, and calculations were provided for public review in DOE Reading Rooms and Information Repositories. The Final EIS has been modified based on new guidance from the repository and an independent review of the Draft EIS. Please refer to the response to Comment numbers 0004.01, 0008.02, 0035.04, and 0081.02.
Comment Number 0037.03
Eldredge, Maureen
Comment I am concerned about the cost estimates in the program, particularly including repository costs. It does not make any sense. It is ludicrous. We do not have a repository. DOE needs to wake up to that fact.
We are not going to get a repository any time soon, not by 2015. It is just not going to happen. We do not know what the repository, if we ever get one, will look like. We do not know what its loading requirements will be. We do not know what its technical capabilities will be. We do not know what its size will be.
Any predictions of cost for a repository are highly speculative. Even if Yucca Mountain by some chance happened to open in any kind of reasonable time frame, the first people in line are the commercial nuclear utilities.
And believe me, they are going to make sure they keep their place first in line. And they are going to make sure all of their waste gets into the facility before any defense waste gets a chance.
Even if defense waste gets in the door, only 10 percent of the repository is slated to be for defense high-level waste. And I am afraid that we are going to run out of space at Yucca Mountain at least very soon, if it opens at all.
Then we are looking at a really fun option of going for a second repository. It is just not going to happen. And it is time to start making plans and start looking at the future with more reasonable expectations.
Response The siting, design, and licensing of a geologic repository to isolate spent nuclear fuel and HLW for long-term protection of public health and safety of the environment is a highly technical and complex process. As stated in Volume One, Section 6.2, the current program planning assumption is that any DOE material qualified and selected for emplacement in the first repository would be disposed of beginning in the year 2015.
As stated in the EIS, current national policy calls for the disposal of spent nuclear fuel and HLW in a geologic repository. The ex situ alternatives presented in the TWRS EIS were developed to be consistent with this policy. Current projections for commercial spent nuclear fuel and defense HLW exceed the statutory limit of 70,000 equivalent metric ton heavy metal (MTHM) in the first repository. The need for a second repository will not be addressed until between January 1, 2007 and January 1, 2010 when the Secretary of Energy is required to report to the President and Congress under the Nuclear Waste Policy Act. Please refer to the response to Comment numbers 0004.01, 0008.02, 0012.20, 0035.04, and 0069.04 for additional information.
Comment Number 0038.10
Reeves, Merilyn
Comment The cost of the national repository, which you have heard about tonight, it should be removed from the EIS. The hypothetical, national repository has been a driver for the tank waste treatment and disposal decisions. And this is not in the best interest of cleanup at Hanford.
The Tank Waste Task Force of 1993 was very clear, quote, let the ultimate best form for the waste drive decisions, not the size, nor the timing of the national repository.
The repository costs are not broken out in the summary, misleading the reader by not communicating the importance of repository costs for each option. And the speculated cost of repository should be removed from the EIS.
Response The presentation of the cost estimates has been revised for the Final EIS by separating the cost and discussion regarding HLW disposal. See Volume One, Section 3.7 and Volume Two, Section B.9 for HLW disposal costs. There are real costs associated with disposal of HLW at the geologic repository, and removal of these cost estimates from the EIS would not allow for an equitable comparison among the alternatives as required under the NEPA process. It is necessary to show these costs in the EIS to fully inform the public and the decision makers of the total cost of the alternatives. Please refer to the response to Comment numbers 0004.01, 0008.01, 0035.04, 0052.01, 0069.04 and 0081.02 for additional information on issues related to cost estimates, the geologic repository, waste loading and waste forms, and interim onsite storage.
Comment Number 0050.01
Boldt, A.L.
Comment I have a comment on the Draft EIS disposal cost. The geologic disposal cost presented in the Draft EIS are based on the linear extrapolation of the average container disposal cost provided by the document from DORW0479 referenced in the EIS, Analysis of Total System Life Cycle Cost of the Civilian Radioactive Waste Management Program. This analysis cost in this document was for a specific scenario of waste in a number of canisters. The linear extrapolation of this average container cost - disposal cost from this previous reference to all the TWRS alternatives does not meet the requirements of the Nuclear Waste Policy Amendments Act of 1987 and the Federal Register Notice 52161, the Civilian Radioactive Waste Management Calculating Nuclear Waste Disposal Fees for the Department of Energy Defense Program Waste.
Federal Register Notice 52161 identifies, in detail, the method to be used in estimating the disposal fees for the Department of Energy Defense Program HLW share of the Civilian Radioactive Waste Management System costs. The Federal Register Notice 52161 cost allocation is based on the concept of full cost recovery with sharing formula supplied to all fixed and variable cost system or system cost components. The assumption of the linear extrapolation of average container disposal cost in the Draft EIS, greatly under estimates the disposal cost for the Extensive Separations alternative and greatly over estimates the disposal cost of the No Separations alternative. Example, disposal cost variability for alternate HLW container sizes and high-level waste volumes resulting from No Separations, intermediate separations, and extensive separations using the methodology of the Federal Register Notice 52161 are provided in a document by TRW for Environmental Safety Systems and it has long numbers on the copy I will give you but it is assessed on the pre-closure system cost health and safety in facts of Hanford high-level vitrification options on the civilian radioactive waste management system. This document is dated April 27, 1995.
I am requesting with the Draft TWRS EIS be revised to incorporate high-level waste disposal costs calculated with methodology specified in Federal Register Notice 52161.
Response Please refer to the response to Comment numbers 0004.01 (repository costs related to canisters) and 0081.02 (separation of repository, retrieval, and treatment costs).
Comment Number 0052.02
Pollet, Gerald
Comment What we need to remove from your total cost estimates is the entire set of repository fees. It is not sufficient to say that we broke out the repository fee in the details because you are still presenting a total range of cost estimates that the public and media and the decision makers are actually going to look at and they're going to say by gosh, that No Separations alternative costs a quarter trillion dollars. What kind of lunatic wanted No Separations? And what the decision makers, public, and media will not know is that, in fact, No Separation alternative actually has a rather reasonable price tag of below 30 billion dollars and that 211 billion dollars is a hypothetical repository fee for a hypothetical repository. A fee charged by the department to itself for repository which it admits in the EIS will never have the capacity for this. So it is a hypothetical fee for a hypothetical repository that the one certainty is does not have the capacity for it ever opened. There is something wrong with that picture and presenting it to decision makers, the public, and the media, it is apparent to the casual observer that someone is trying to skew the results.
Response DOE and Ecology have revised the Final EIS in response to public comment and put the costs of the repository into a separate presentation. The estimated costs for disposal of the HLW at the potential geologic repository are included in the Final EIS because there would be real costs associated with packaging, transport, and placement of HLW in a geologic repository. Eliminating the repository fees from the cost estimates presented in the EIS would not provide all of the costs associated with the alternatives and would bias presentation of the alternatives. Please refer to the response to Comment numbers 0038.10 and 0081.02 for discussion of repository costs as these issues relate to the alternatives analysis and the response to Comment numbers 0037.03 and 0008.02 for a discussion of the proposed geologic repository availability and statutory capacity.
Comment Number 0052.05
Pollet, Gerald
Comment One last closing thought for our comments tonight which is if you have a hypothetical repository fee for the hypothetical space at a hypothetical repository and the hypothetical land, then for the very real cost to the three tribes to the future generations of this region why isn't there assigned a cost for the permanent use of land in the leave it in place alternatives that are clearly being shown a preference through out all the cost estimates in this EIS. You need to consider internalizing the externalities and I would say that is less hypothetical and I think that the public could provide you and the tribes some very real cost estimates for creating a sacrifice found under the leave it there scenarios.
Response The cost estimates for the in situ or ex situ alternatives do not include cost associated with permanent land commitment, or land use restrictions associated with groundwater contamination. The amount of land committed to waste management and disposal was estimated for each of the alternatives, as was the extent of a groundwater contamination and associated human health impacts. The costs associated with long-term loss of land use or groundwater use can be understood within the overall context of the relative difference among various alternatives land use and groundwater use restrictions. The more land or groundwater is restricted the higher the cost. So while absolute dollar estimates are not provided the EIS does provide an appropriate level of analysis to support the comparison of alternatives. Land use issues related to Tribal Nation concerns are described in Volume One, Sections 5.5 and 5.19. Please also refer to the response to Comment numbers 0072.26, 0072.22, and 0036.18.
Comment Number 0055.04
Martin, Todd
Comment A third point would be that the repository should not be driving decision making at Hanford.
Response DOE and Ecology acknowledge the concern expressed in the comment. NEPA requires that all reasonable alternatives be evaluated. Consideration of geologic repository availability was included in the evaluation of the ex situ treatment alternatives in the EIS to the extent that availability was assumed; a limit would be placed on the accepted volume, type, and final waste form of Hanford materials, and the interim storage facilities would include a 50-year design life to provide sufficient time for availability. Data that support the impact analysis of each alternative are presented in an objective and unbiased format for comparison by the decision makers and the public during the comment period. Please refer to the response to Comment numbers 0008.02, 0035.04, 0037.03, 0038.10, and 0052.01.
Comment Number 0055.05
Martin, Todd
Comment I want to address cost estimates in Yucca Mountain. I think people have heard that several times but I want to address some of the specifics. In looking at the numbers, you change a few assumptions here and there and it is amazing what it does to those cost numbers. For example in Phased Implementation when we look at the repository cost. You shift the waste loading, the amount of waste that goes into the glass by a mere 10 percent into essentially a percentage that is much lower than I have ever seen in any documents. What does that do to the repository cost for that option. Moves from 4 billion dollars to 12 billions dollars. Just a little assumption like that. Let us look at the no separation option. You take a fairly large canister, your repository cost is about 13 billion dollars. Shrink that canister down a bit and it jumps to 252 billion dollars. These are the kind of assumptions that I think that Mr. Pollet pointed out appeared to have been skewed to maximum the impact of the Yucca Mountain on the EIS. And I would agree with that assertion.
Response The changes in repository cost were a result of changes to the waste loading, HLW canister size, and use of a blending factor to account for uncertainties in the ability of the retrieval operations to deliver a uniformly blended waste feed stream to the treatment facilities. The variation in estimated repository cost based on waste loading and canister size is included in the cost ranges presented in the EIS. Please refer to the response to Comment numbers 0035.04. 0038.10, and 0081.02.
Comment Number 0057.04
Garfield, John
Comment The logic of the repository cost for example in the intermediate separations adding up to $12 billion dollars does not make sense from even the simplest technical that any member of the public can understand. The Hanford contribution to the repository in total is about 1 percent of the total radionuclides if all the high-level wastes goes to the repository and about 1 percent of the heat. Whether or not content into the small number of canisters or leave it in a large number of canisters will not significantly drive the repository costs. That is a fairly straight forward and simple approach or way of thinking about that problem that everyone can understand. Attributing $12 billion dollars to that repository or $211 billion dollars for the No Separations case does not stand up to the simplest scrutiny.
Response The amount of HLW that ultimately could be accepted at a national repository is a function of available subsurface area and emplacement constraints among HLW and spent nuclear fuel (SNF) within this area. In addition, there is a statutory limit on emplacement of HLW and SNF in a first repository (70,000 MTHM) until a second repository is in operations. As a planning basis, the Department has allocated 10 percent of that statutory capacity of the first repository for defense SNF and HLW.
The physical amount of available subsurface area for HLW and SNF disposal, and the associated number of packages of HLW and SNF, would be defined through repository design and performance assessment activities, based on information collected during repository scientific investigations. Neither of these activities are completed. However, for planning purposes, the repository Advanced Conceptual Design assumes that 12,900 canisters of defense HLW, each containing 0.5 MTHM, can be accommodated within the statutory limit.
A number of factors are important in estimating disposal costs including number and size of canisters handled, number of waste packages, operation and capital costs, and number of shipments to a repository. In addition, there are common costs that must be allocated among waste generators, such as development and evaluation costs, to ensure full cost recovery. Using radionuclide inventory of Hanford HLW relative to other wastes would not provide an equitable basis for cost estimating. For more information on this issue, refer to the response to Comment number 0005.08.
A number of factors go into the repository cost estimate including heat load, canister size, waste package design, and number of waste packages. Looking at Hanford contribution of the repository cost solely from the standpoint of radionuclide contribution to the repository would not provide a straightforward and understandable basis for cost estimating. Please refer to the response to Comment numbers 0004.01, 0008.01, and 0081.02 for additional information on repository cost estimates.
Comment Number 0062.05
Longmeyer, Richard
Comment One of the things that would need to be re-looked at is if the Yucca Mountain facility is not going to become a reality, how would that affect the prioritization of these different plans. And my guess is that the Yucca Mountain facility, or any national repository for nuclear wastes, will never receive any nuclear wastes from across state lines in my lifetime, and probably not in the lifetime of my children. And so that means that we need to re-look at this, and prioritize them again. Doing so would probably leave us with three options. The in situ vitrification, the ex situ vitrification with onsite storage, and the Phased Implementation, which you have now with onsite storage. And so, those would be the three that I would recommend we look at more closely.
Response Current national policy calls for disposal of spent nuclear fuel and HLW in a geologic repository. DOE and Ecology developed the ex situ alternatives in accordance with this policy. In response to concerns regarding the timing and availability of the geologic repository to accept HLW from the Hanford Site, the Final EIS has been revised in Volume One, Section 3.4 and Volume Two, Appendix B to include the impacts associated with onsite interim storage of treated HLW for 50 years. The environmental impacts associated with the in situ alternatives identified in the comment are provided in the EIS in Volume One, Section 5.0 and associated appendices. Volume One, Section 5.12, and Volume Three, Appendix D contain discussions of the transportation risk associated with offsite disposal. Please refer to the response to Comment numbers 0008.02 (repository availability and related uncertainties) and 0037.03 (statutory limits), and 0052.01 (interim HLW onsite storage) for more information.
Comment Number 0072.84
CTUIR
Comment P3-28: PP 5: Does this mean you are only going to use one multi-purpose canister? Please explain in more detail in order for the readers to grasp how many and how much.
Response One type of multi-purpose canister was assumed as an overpack used for handling and interim onsite storage. This multi-purpose canister is referred to as a Hanford Multi-Purpose Canister (HMPC) throughout the document. The text has been revised in Volume One, Section 3.4 to discuss the relationship between the primary HLW canisters and the HMPC.
Comment Number 0077.05
ODOE
Comment A large part of the cost shown for the vitrification alternatives included charges to dispose of the waste to the national high-level waste repository. These charges should not be used to decide whether to put the waste in a stable and durable form.
Several alternatives call for removal of all wastes from the tanks and vitrification. They differ in the methods used, complexity, speed, and cost. The repository charges should be used as one criteria in deciding among these alternatives.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please also refer to the response to Comment numbers 0004.01, 0035.04, 0052.01, and 0081.02 for more information regarding disposal costs, assumptions, and presentation in the Final EIS.
Comment Number 0079.05
Knight, Paige
Comment Repository costs must not be included in the total cost of any plan implemented. Cleanup dollars must go first towards stabilizing waste in a quality form that is not water soluble. Repository room must be considered. If Yucca Mountain is ever a viable option, it will only hold a small portion of Hanford waste. So the form of the waste must be not only stable, but retrievable. My reasoning there is that more than likely the waste in any kind of form is going to be sitting at Hanford for at least 40 years, and I would suspect much more than that.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0008.01, 0038.10, and 0081.02.
Comment Number 0081.05
Pollet, Gerald
Comment More importantly is the next bullet in our advice. Accept the fact that interim storage at least, at least, of the waste in an environmentally safe form will occur for some time at Hanford. Select a waste form that will ensure safe interim storage of this waste. The message was, Hanford is going to be the home for the high-level nuclear waste. Select the best form, and don't even put into the mix the theoretical cost of the repository, which the Department will charge itself, nor the theoretical capacity of it, because it doesn't have the capacity to handle it anyway, under any scenario here. We request that this advice be addressed, and placed in the front of this EIS. And it be addressed in the summary and throughout. We request that the repository costs be relegated to an appendix, and the total cost summaries be redone to show the total cost without the theoretical hypothetical self-dealing charge for replacing waste in the repository. When that is done, we should examine carefully the no separation versus the extensive separation scenarios. And we should see how much we pay for unproven technology under extensive separation, versus no separation and intermediate separation.
Response The storage of the HLW at the Hanford Site for 50 years has been included in the ex situ alternatives. Please refer to the response to Comment number 0089.18. Current national policy calls for the disposal of spent nuclear fuel and HLW in a geologic repository and the ex situ alternatives were developed to be consistent with this policy. DOE and Ecology have revised the presentation of the cost estimates for HLW disposal for the Final EIS in Volume One, Section 3.4 and Volume Two, Appendix B. This will allow the reader to readily compare the estimated cost for waste treatment among the alternatives. There are real costs associated with packaging, transport, and placement of canistered HLW into a geologic repository, and failure of the EIS to present these costs would provide an incomplete picture for the decision makers and public. Please refer to the response to Comment numbers 0004.01, 0035.04, 0038.10, and 0069.04.
The EIS presents in Volume One, Section 3.4 and Volume Two, Appendix B, alternatives that are based on 99 percent retrieval with no separations (the Ex Situ No Separations alternative), intermediate separations (the Ex Situ Intermediate Separations alternative), and extensive separations (the Ex Situ Extensive Separations alternative). A summary comparison of these alternatives is provided in the Summary and a summary of the environmental impacts of each alternative is presented in Volume One, Section 5.14.
Comment Number 0089.18
Nez Perce Tribe ERWM
Comment Since the possibility exists that Yucca Mountain repository may not open, the design life of the onsite facility storing the vitrified high-level waste must be sufficient for the permitting and construction of an alternate high-level waste repository.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Volume One, Section 3.4, the Summary, and Volume Two, Appendix B.3 have been revised to include reference to the 50-year design life for the interim HLW storage facilities, which is based on a conservative estimate for approval and availability of the geologic repository. Please refer to the response to Comment numbers 0008.02, 0035.04, and 0052.11.
L.3.4.2.2 Alternatives Costs
Comment Number 0005.12
Swanson, John L.
Comment I applaud you for giving cost RANGES in comparing the different alternatives, but I am very surprised that you did not include the (large) uncertainties in HLW repository disposal costs in many of these ranges. In recent years, there have been reports of attainable cost savings through the use of higher waste loadings in HLW glass and the use of larger canisters; such savings could give estimated repository disposal costs only one-fourth as large as the values you give.
Response DOE and Ecology considered HLW disposal fees in the total cost range (treatment cost + repository fee) for the ex situ alternatives presented in the EIS. For example, when comparing the treatment cost range to the total cost range, the total cost range is not the sum of the treatment cost range and the repository fee. This methodology addressed only TWRS-specific parameters, mainly waste loading and canister size, in the cost uncertainty analysis. Uncertainties in the repository program are not within the scope of the EIS. However, 50 years of storage of the HLW is included in the ex situ alternatives to account for the uncertainty of when a repository may be available to accept waste for disposal. Please refer to the response to Comment numbers 0081.02, 0072.80, and 0008.01 for further discussions of repository and canister issues.
Comment Number 0005.13
Swanson, John L.
Comment Because of the large uncertainty in HLW repository disposal costs, I feel that it would be a more fair comparison of the costs of the alternatives in the Summary if you split out those estimates-something like "The cost of this alternative, exclusive of the HLW repository fee, is estimated to be in the range of ___ to ___. Based on the assumptions adopted for this EIS, the HLW repository fee for this alternative is estimated to be __; the use of other assumptions regarding higher waste loading in glass and the use of larger canisters could lower this estimated fee to ___."
Response DOE and Ecology recognize the concern regarding the cost uncertainty associated with the repository. The Final EIS has been revised to discuss HLW disposal at the geologic repository, the associated cost separately, and potential impacts (e.g., accidents during transportation). The Summary, Section S.8, Volume One, Sections 3.7 and 6.0, and Volume Two, Section B.9 contain a discussion of HLW disposal at the geologic repository. Please also refer to the response to Comment numbers 0081.02, 0008.01 and 0005.12 for further information regarding repository availability, cost estimate methodology, and assumptions.
Comment Number 0005.14
Swanson, John L.
Comment The more I look into your cost ranges, the more confused I become. For example; a) Footnote (3) to Table S.7.6 says that the relatively large ranges in costs for three of the alternatives is primarily a result of assumptions made for repository fee, but two of the three alternatives identified in this footnote do not fit this situation. b) Tables 3.4.13 and 3.4.14 contain footnotes indicating that the cost ranges are dependent on the canister size used, but the tables themselves give only individual values for the repository fees. Why aren't the repository fee ranges used given in the tables? Also, if the cost ranges resulting from canister size increase are given for this/these alternative(s), why aren't they given for the other alternatives as well? The way you have it is a mixture of "apples and oranges." c) Section B.8.3 ("Cost Uncertainty") does not do anything to help me, either-except to emphasize that "assumptions drive conclusions."
Response The footnote in question (footnote number 3 of Table S.7.6) is intended to provide the reader a summary-level explanation of why the cost ranges vary widely for the ex situ alternatives. The difference between the high and low cost range for the Ex Situ No Separations (Vitrification) alternative is $184 billion, the range for the Ex Situ No Separations (Calcination) alternative is $47 billion, and the range for Ex Situ Intermediate Separations and Phased Implementation alternatives is approximately $10 billion. The ranges estimated for these alternatives are greater than the other alternatives mainly because of repository fee assumptions. Technical assumptions regarding the HLW canister sizing have been revised for the Final EIS, which reduce the large cost ranges associated with the ex situ alternatives that produce large volumes of HLW. Additional detail on how the cost uncertainty and ranges were estimated is provided in Volume Two, Appendix B. Please refer to the responses to Comment numbers 0081.02 and 0005.03 for more information on uncertainty.
The Volume Two, Appendix B discussion on cost uncertainty is intended to provide an overview of the methodology and the analysis results. The detail input output data are included in the technical backup data that is publicly available as part of the TWRS EIS Administrative Record.
As noted in the response to Comment number 0005.12, the uncertainty in HLW disposal fees that would result from a variation in the number of HLW packages is included in the total cost range for each ex situ alternative. This allows for an equitable comparison among alternatives.
Comment Number 0052.03
Pollet, Gerald
Comment The costs have some other strange anomalies. For instance, some of the cost estimates for vitrification alternatives today are basable upon some market considerations in terms of what vendors are saying they believe they will be able to bid.
Response None of the cost estimates for the alternatives presented in the Draft EIS were based on privatization of the tank waste treatment. Privatization is an implementation strategy and as such was not addressed in the EIS. For a discussion of this, see Volume One, Section 3.3. All of the cost estimates were developed using the same methodology to provide an equitable comparison among the alternatives. Privatization issues are discussed in the response to Comment number 0060.01.
Comment Number 0052.04
Pollet, Gerald
Comment But what is kind of incredible in this EIS is continuing the historic practice at this site of having a capital contingency built into all the cost estimates of not just 30 percent here but 30 to 50 percent. It is really hard to talk about how the TWRS program is reaming in its costs when its capital cost estimates have a contingency added in of 30 to 50 percent. It is very disturbing and from point of view of how this is then presented to Congress, what we have is a set of alternatives that may emerge that are the ones that are necessary to meet the legal requirements of removal, retrieval, and treatment which are inflated because of their capital considerations by 50 percent and which are inflated by up to $211 billion dollars by a hypothetical repository fee and then we wonder why Congress may not want to fund vitrification.
Response The use of contingencies in cost estimates is standard practice throughout the public and private sector. This is especially true of conceptual estimates for any large construction projects. The use of a contingency in the capital cost estimates is a means to quantify the uncertainty inherent with conceptual designs. The use of contingencies is appropriate for all construction projects, especially projects involving the complexity of the TWRS program. Cost estimates associated with the repository are provided in response to Comment numbers 0004.01 and 0081.02. Capital construction costs are discussed in the response to Comment numbers 0055.06 and 0081.03. DOE-Richland Operations Office (DOE-RL) prepares an annual budget, which would include the budget required for the TWRS cleanup for that year. However, only Congress has the authority to appropriate funds.
Comment Number 0055.06
Martin, Todd
Comment On the costs more generally, I trust the costs in this document about as far as I can throw this document which needless to say without doubt is not very far. Most of the people in this room remember the Hanford Waste Vitrification Plant. This was a 1-ton a day high-level waste vitrification facility. This was the cornerstone of Hanford cleanup that as I recall is supposed to be running in about 3 years but we canceled the program. That was projected to cost about 1.3 billion dollars. Pretty hefty. I look at this EIS and I see that a low-level waste facility (vitrification facility) it is 20 mt per day. Twenty times the throughput is going to be built for 248 million dollars. I do not get it. I do not see the basis for those costs and I simply do not buy it. Further, to compare more of an apples to apples, we look at the high-level waste vitrification facility that is in the EIS. This a 1 metric ton a day facility, it is essentially HWVP. The 1.3 billion dollar facility. What is it in this EIS? 232 million dollars. I can not imagine that it can be built for that. In other words, total for the Phased Implementation alternative, DOE is going to built two low-level waste vitrification facilities with an agent pre-treatment on both of those and one high-level waste facility for 1.4 billion dollars. Essentially the cost of HWVP. I say no way. If that is true, why are we doing privatization? We can take the budget authority that has been given about 2 years and we have got the full cost of one of these facilities. This does not assume any efficiencies from privatization. These are government-owned, contractor-operated facilities, built under a traditional contracting mechanism. Essentially, until a formal credible data package has been done to support the Phased Implementation, the preferred alternative in this EIS, this EIS should go forward no further. Should go no further.
Response DOE and Ecology acknowledge this concern regarding the cost estimates and have reviewed and revised the Phased Implementation cost estimate as appropriate for the Final EIS. These revised cost estimates are shown in Volume One, Section 3.4 and Volume Two, Appendix B and are reflected in the Summary. The Hanford Waste Vitrification Plant (HWVP) cost estimate is not directly comparable to the capital cost estimate for the Phase 1 HLW facility because it includes support facilities and infrastructure that are estimated as separate components for Phased Implementation.
The Phased Implementation alternative was developed by scaling appropriate components from the Ex Situ Intermediate and Extensive Separations alternative. The capital cost was estimated using the "six-tenths rule" and the relative plant capacities for Phased Implementation were estimated in the absence of more definitive data. DOE and Ecology acknowledge that there is uncertainty introduced into the cost estimates by scaling and this is captured in the cost uncertainty analysis. The cost uncertainty analysis results in a cost range within which the final cost would be expected to fall. Total capacity cost breakdowns for a combined separations LAW facility and a detached HLW treatment facility are generally 35 percent equipment, 20 percent material, and 45 percent labor (WHC 1995j).
The cost estimates input data, methodology, and calculations are available in the reference documents included in the EIS and available for public review in DOE Reading Rooms and Information Repositories.
Comment Number 0057.06
Garfield, John
Comment There are a few other less important comments that I will make. One is with regard to the cost estimates for the combination case and to some degree the Phased Implementation case. Parsons has used 6/10ths power rule to arrive at those costs for lack of any conceptual design basis to make those estimates. That rule is applicable in the commercial industry for chemical processes because those plants are largely equipment-driven. 50 to 85 percent of those plant costs are equipment and when you vary the capacity that the capital cost of the facility does, as a rule, from varied by the 6/10ths power rule. Nuclear facility equipment costs only amounts to 10 to 20 percent of the total capital cost. That same 6/10ths power rule can not be used for a shielded nuclear processing facility. It makes no sense to do that and the cost have been skewed for using that. That adjustment should be made and can be made fairly easily.
Response The Phased Implementation alternative and combination alternatives were developed by scaling appropriate components from the Ex Situ Intermediate Separations and Ex Situ Extensive Separations alternatives. The capital cost was estimated using the "six-tenths rule" and the relative plant capacities for the Phased Implementation alternative in the absence of more substantive data. Some uncertainty is introduced into the cost estimates by scaling and this is captured in the cost uncertainty analysis presented in Volume Two, Appendix B. The cost uncertainty analysis results in a cost range within which the final cost would be expected to fall. Total capital cost breakdowns for a combined separations LAW facility and a detached HLW treatment facility estimated for the Ex Situ Intermediate Separations alternative are 35 percent equipment, 20 percent material, and 45 percent labor (WHC 1995j).
The cost estimating methodology has been reviewed and revised cost estimates have been completed for the Phased Implementation and combination alternatives, and for other alternatives as appropriate. These revised costs are shown in Volume One, Section 3.4 and in Volume Two, Appendix B.
Comment Number 0069.04
Pollet, Gerald
Comment The TWRS EIS skews the costs of the alternatives as well. This, coupled with the risks, presents a very biased picture in the EIS of the alternatives. First off, you see this is how their rank ordered in the EIS, as it will be presented to decision makers, and is being presented to you, the public. Leaving waste behind has a cost range of 23 to 28 billion. Extensive separation comes in close behind it, 27 to 36 billion. This is the Tri-Party Agreement path, called Phased Implementation, 32 to 42 billion, building just one plant basically with multiple melters, and calling it all high-level waste, glassifying it all, this astonishingly high price tag. Anyone rational would throw it out.
The repository fee, once it's removed ... excuse me, what I was saying was, the Nuclear Waste Policy Act does, indeed say how you should calculate a repository fee if your going to use it here.
It is not the way it is calculated here. Secondly, it should not be used at all because this waste will never fit into the proposed hypothetical repository at Yucca Mountain. So what is the fee for? It's a hypothetical fee the Department charges itself for a hypothetical repository that will not have room.
So all of a sudden, we have a drastic change in the order of the alternatives. In fact, what we get is, let me just present the conclusion, the Ex Situ/In Situ Combination goes from being least cost by 4 to 8 billion, to only being 1 to 7 billion dollar lower cost then getting all the waste out of there. The Extensive Separations goes from number 2 to number 4 and number 5. It goes from having a cost advantage of 5 to 6 billion dollars over the Tri-Party Agreement, to having a 5.4 to 6.4 billion dollar disadvantage over the Tri-Party Agreement path. It is an effort to skew the data here, and present it in a skew manner to decision makers. And the No Separations alternative, which gets wastes out of tanks fastest, with least research and development, actually shows up as having potentially the lowest range costs. Thank you.
Response The Phased Implementation alternative involves building two separations and LAW treatment facilities and one HLW vitrification facility during Phase 1 to demonstrate the treatment technologies. Following Phase 1, Phase 2 would be implemented, which would involve building full-scale treatment plants to treat the remainder of the tank waste. For a description of the Phased Implementation alternative, please refer to Volume One, Section 3.4.
The purpose of the Nuclear Waste Policy Act is to: 1) establish a schedule for the siting, construction, and operation of repositories that will provide a reasonable assurance that the public and the environment will be adequately protected from the hazards posed by high-level radioactive waste and such spent nuclear fuel as may be disposed of in a repository; 2) establish the Federal responsibility, and a definite Federal policy, for the disposal of such waste and spent fuel; 3) define the relationship between the Federal Government, State and affected Indian Tribal governments with respect to the disposal of such waste and spent fuel; and 4) establish a Nuclear Waste Fund, composed of payment made by the generators and owners of such waste and spent fuel, that will ensure that the costs of carrying out activities related to the disposal of such waste and spent fuel will be borne by the persons responsible for generating such waste and spent fuel. The Nuclear Waste Policy Act does not provide a methodology for calculating the repository fee for disposal of HLW in a geologic repository. For the Final EIS, repository fees were recalculated. For more information, please refer to the response to Comment numbers 0004.01 and 0036.01.
Current national policy calls for the disposal of spent nuclear fuel and HLW in a geologic repository. The current inventory of commercial spent nuclear fuel and defense HLW exceeds the statutory limit for the first repository. The disposal of all commercial spent nuclear fuel and defense HLW will require increasing the limit of the first repository or constructing a second repository. DOE is currently characterizing one site, Yucca Mountain, Nevada, for a geologic repository. The law requires that the Secretary of Energy report to the President on or after January 1, 2007, but not later than, January 1, 2010, on the need for a second repository. Within this context, none of the alternatives addressed in the TWRS Draft EIS exceed the capacity for geologic disposal, even though many of the alternatives would generate more canisters of HLW than the repository program is currently using for planning purposes. Based on revised canister size and other recalculations completed for the Final EIS, the EIS has been revised in Volume One, Sections 3.4 and 6.0, and Volume Two, Appendix B, to address the repository capacity issue relative to TWRS alternatives.
Failure to recognize that each of the ex situ alternatives would have cost impacts associated with HLW disposal would provide unequal information for the reader. Please see the response to Comment numbers 0081.01, 0081.02, and 0035.04.
Comment Number 0072.92
CTUIR
Comment P 3-36: PP 4: S 2: By what factor? Or by a factor of what?
Response Capital cost contingencies were included in the alternative cost estimates as described in Volume One, Section 3.4 and Volume Two, Appendix B. These contingencies are included to account for the uncertainty associated with the conceptual-level designs developed for analysis in the TWRS EIS. The contingency factors used ranged from 25 to 50 percent with a typical value of 40 percent. The higher contingencies were applied to the more conceptual facilities and the lower contingencies were applied to the more defined facilities. This is consistent with industry standards and practice. Please refer to the response to Comment numbers 0052.04, 0055.06, and 0057.06 for related information on the use of contingencies in cost estimating.
Comment Number 0072.93
CTUIR
Comment P 3-36: PP 6: Please explain how the R&D cost is to be assumed for the phased alternative.
Response Because Phase 1 would be a demonstration process, the research and development cost for the treatment process was assumed to be an integral part of the Phase 1 operating cost. The research and development cost associated with the waste retrieval and transfer function was included at the same level as the other ex situ alternatives. There are development programs currently ongoing at the Hanford Site that are covered under the TWRS program or other programs.
Comment Number 0077.04
ODOE
Comment Also, the cost analyses do not include the lost value of the lands or the costs from harm to future generations or the environment. Ultimately, the costs of these alternatives would prove to be much greater than removing and cleaning up the wastes, as called for by the preferred alternatives.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Analyzing the harm to future generations from an economic standpoint is not included in the EIS; however, lost habitat, health risks, health consequences, and probabilities of accidents to future generations were among the impacts analyzed by DOE and Ecology. Land use commitments are addressed in Volume One, Section 5.7, anticipated health effects in Section 5.11, and comparison of potential consequences from accidents in Section 5.12. For the Final EIS, a Native American scenario was added to the analysis presented in Volume One, Section 5.11. Please refer to the response to Comment numbers 0036.18, 0052.05, 0072.22, 0072.55, 0072.198, 0072.225, and 0072.34 for related discussions..
The information requested in the comment represents a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0081.01
Pollet, Gerald
Comment We are concerned that the Department of Energy falsely inflated the costs of waste removal and glassification options to justify leaving waste in the tanks. We are also concerned that the rate the costs have been presented would erroneously lead policy makers to the conclusion, when combined with the use of erroneous assumptions as to risk, lead to the conclusion that in fact it would be cost affected to leave waste behind.
Response The cost estimates are an equal analysis of the total life-cycle costs of each alternative and reflect the best available cost information given that the engineering is still at a conceptual stage. The estimates are available for inspection by the public in the TWRS EIS Administrative Record. Please refer to the response to Comment number 0081.02 for a discussion of how the repository costs were recalculated for the Final EIS. For responses to specific comments regarding risk assumptions, please refer to the response to Comment numbers 0069.08, 0069.09, 0069.03, 0069.06, 0069.07, 0081.07, and 0069.11.
Comment Number 0081.03
Pollet, Gerald
Comment And what is interesting is it has the least technical question. And the EIS is based, in terms of these costs, costs include a 30 to 50 percent capital cost contingency. This is pretty bazaar. We're spending 10's of millions of dollars on research development design phased approach.
We are spending 10's of millions of dollars on design, which ought to drive down contingencies. 30 to 50 percent contingency is the way Hanford has done business with capital construction projects in the past. It is sinful. It is not going to be able to continue. If we eliminate, and we use different factors for contingency, take a look at the fact that a no separation alternative means you build one plant with the simplest technology, vitrification. You vitrify everything. You don't try to separate. You just vitrify. You do not have to build a multi-billion dollar separation plant. You do not have to build separate low activity and high activity vitrification plants. You could, and this EIS fails to consider the alternative which was eliminated earlier in this process, of having a very simple separation of low activity and high activity, in terms of which melter waste is directed too, at the front-end of such a plant. If we look at the cost issue alone, the no separation option actually drives down into the cost range, and perhaps will compare more favorably than the Ex Situ/In Situ Combination even.
The cost assumptions, as with all other assumptions, are critical. Building in 30 to 50 percent contingencies for one set of options is not acceptable for this type of policy decision making. And we can't afford to continue with 30 to 50 percent contingencies for capital costs at Hanford.
Response As noted in the response to Comment number 0052.04, the use of contingencies in capital cost estimates is standard practice throughout the public and private sector. All of the alternatives presented in the EIS include contingencies in the capital cost estimates. During design development for the alternative selected, the cost estimate would be refined and the contingency reduced. The cost estimate for a large facility would typically have some contingency remaining at the start of construction. The capital cost estimate as well as the contingency estimated for the Ex Situ No Separations alternative is smaller than the Ex Situ Intermediate and Extensive Separations alternatives because one treatment facility is constructed instead of two. The contingency factor for the Ex Situ No Separations alternatives provides an equal presentation to the public and the decision makers. Capital construction costs are also discussed in the response to Comment numbers 0055.06, 0057.06, and 0081.03.
A single facility designed to vitrify both HLW and LAW would not be precluded by the EIS for any of the alternatives that include separation of the HLW and LAW. The impacts associated with a single treatment facility would be bounded by the alternatives presented in the EIS. The separations processes included in the EIS cover a reasonable range of representative technologies. The separation of the waste into HLW and LAW streams is bounded with no separations on the low end, extensive separations on the high end, and intermediate separations in the middle.
The Draft EIS addressed the full range of reasonable alternatives. As the alternative identified in the comment is bounded by the alternatives addressed in the Draft EIS, DOE and Ecology believe that including the requested alternative would not provide valuable additional information to the public or decision makers. Please also refer to the response to Comment number 0072.05 for a discussion of the development of the alternatives for analysis in the EIS.
Comment Number 0089.04
Nez Perce Tribe ERWM
Comment Purification and removal of sodium nitrate and other major wastes from tanks prior to segregation of LAW and HLW should be considered for volume reduction and cost savings. Possible removal of sodium nitrate for industrial or certain agricultural use should be considered. Another option may be reacting the sodium nitrate with an organic reducing agent to produce sodium carbonate, nitrogen, ammonia and water, greatly facilitating waste reduction. Options such as these need to be considered to reduce vitrification volumes.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Volume reduction measures for the waste have been considered, including calcination and the clean salt process. These measures are addressed in Volume Two, Appendix B, Section B.3. Removal of sodium nitrate, such that this compound would be safe and suitable for industrial or agricultural uses would be limited because complete radionuclide removal to form a purified waste would be extremely difficult.
The Draft EIS addressed the full range of reasonable alternatives. As the alternative identified in the comment is bounded by the alternatives addressed in the Draft EIS, DOE and Ecology believe that including the requested alternative would not provide valuable additional information to the public or decision makers. Please refer to the response to Comment number 0072.05 for related discussion.
Comment Number 0090.01
Postcard
Comment Please listen to us say no:
to falsely inflating the cost of glassifying Hanford's High-Level Nuclear Wastes by $211 billion.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Please refer to the response to Comment numbers 0004.01, 0009.04, 0008.01, 0038.10, 0081.01, and 0081.02, for discussions regarding how repository costs were calculated and presented in the EIS..
Comment Number 0092.01
Hanson, Mary
Comment I certainly feel that as a lay person, I have every right to the most conservative principles being used in this situation and I certainly, personally and I think I stand for others here, do not consider cost to be important. Money can be made, the environment can not be remade. Now the total defense budget for this country is somewhere around 260 billion dollars per year. That is a lot of waste. In my opinion, that it is throwing money at defense. Most of it. Playing games, testing this and that and so forth. This is a real problem. This is a real security problem and if it were up to me I would put probably half the defense budget on it. So I do not consider money to be something that you can quote, "balance against health." I do not think money is something you balance against the environment. You can not balance a nonrenewable resource like the environment against a renewable resource like money. So I am very strongly in favor that this be done in the economic, in a conservative manner, economically speaking but I certainly feel that if the public really was as aware as everyone in this room is of what the issues are, they would vote very high amounts of money to deal with this threat to our security.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Cost estimates presented in the Draft EIS have been reviewed and revised, as appropriate in the Final EIS.
The alternatives and impact analysis presented in the EIS were based on conservative principles, consistent with the requirements of NEPA to bound the potential impacts and to address a range of reasonable alternatives. For more information on this topic, please refer to response to Comment number 0072.05 or in the EIS Volume One, Section 3.3. Please also refer to the response to Comment number 0081.01 for a discussion of issues related to the presentation of costs.
Comment Number 0098.01
Pollet, Gerald
Comment The Department of Energy's presentation tonight and at prior meetings and in these materials show ... say ... claim that this unproven technology of so-called in situ vitrification, sticking electrodes into the ground and melting the ground into glass. The presentation said that this would comply with Washington State law. Nothing could be further from the truth. Washington State first off has in the model toxic control act and our dangerous waste regulations a presumption that we will favor removal. That is the law. Leaving it in place when you have an alternative of removal and retrieval is never allowable under Washington State law. We have a set of priorities for dealing with waste. Hanford does not get to make an exception for itself although it sure does try most of the time.
Response The disposal of HLW by ISV would comply with Washington State law if the hazardous waste components are adequately treated to remove the hazardous characteristics or immobilize the hazardous components. The treatment and disposal would be subject to review and permitting by Ecology. Washington State law does not apply to disposal of the radioactive components of the HLW. For a discussion of regulations applicable to the HLW, see Volume One, Section 6.1. For related discussion regarding technical uncertainty, please refer to the response to Comment number 0012.04. Because the information contained in the Draft EIS is correct, no change to the text was made.
L.3.4.2.3 Assumptions
Comment Number 0005.39
Swanson, John L.
Comment The paragraph beginning at the bottom of page 3-31 is interesting. It starts out by saying that the residual contaminants would be insoluble, and then goes on to make the conservative assumption that 1 percent of the water-soluble contaminants would also be present. This conservative assumption drives conclusions, as discussed in (18) above [Comment number 0005.18].
Response DOE and Ecology recognize the concern expressed in the comment regarding conservative assumptions used in the impact analysis and the extent to which these assumptions affect the calculated risk values. The analysis performed for the Draft EIS assumed, for the ex situ alternatives, that 1 percent of the original inventory would remain in the tanks as residual waste that could not be retrieved. This assumption is bounding (e.g., provides a reasonable upper limit) with respect to the impact analysis, because it includes 1 percent of the water soluble contaminants. The Final EIS has been revised to include Volume Five, Appendix K, which will provide a nominal case analysis using best estimate assumptions. The nominal case analysis was based on 1 percent residual volume that was modified to reduce the inventory of soluble constituents. Using this assumption will result in a risk range and will enable the reader to see the variation in the long-term risk as a function of nominal and bounding assumptions. Please refer to the response to Comment numbers 0072.59, 0072.51, and 0072.05.
Comment Number 0005.40
Swanson, John L.
Comment On page 3-34 it is said that the assumption of cullet in a matrix material as the waste form for onsite LAW disposal "--provides a conservative analysis of the long-term impacts--." This statement is true only if conservative assumptions were made regarding the performance of the matrix materials. Were those assumptions conservative? Are they spelled out somewhere? (Page 3-66 contains a statement in opposition to the one on page 3-34; "The potential benefits of a matrix material and glass cullet combination as a disposal form are reduced contaminant release rates and--." Thus, the assumption of cullet in a matrix material does NOT provide a conservative analysis of the long term impacts, as is stated on 3-34).
Response In order to bound the impacts associated with the LAW disposal vaults, the releases from the LAW vaults were calculated under the assumption that the matrix material provided no reduction in the release rates from the LAW disposal vaults. DOE and Ecology believe that using a matrix material with glass cullet would reduce the release rates from the LAW disposal system. The two statements do not conflict with each other. Cullet, as opposed to monolithic pours, would be more easily leached; therefore, cullet is considered the more bounding (higher) approach in the environmental impacts analysis. Assumptions associated with release rates and associated impacts to groundwater are discussed in Volume Four, Appendix F.
Comment Number 0005.42
Swanson, John L.
Comment The last sentence on page 3-35 says that it has been determined that a bleed stream would be required to avoid a continuous buildup of Tc-99 in the vitrification off-gas stream. I do not believe that is necessarily true, and wonder who made that determination (and on what basis). The data I have seen indicate that some melters can retain a significant fraction of the Tc in the glass; thus, Tc in the off-gas from such melters would stop building up when that in the feed plus recycle equals that in the glass.
Response DOE and Ecology acknowledge the concern regarding the constituents that would require the use of a bleed stream for the off-gas recycle system. The EIS discussion includes technetium-99 and mercury as representative examples of the type of volatile constituents that could build up in the off-gas recycle streams. The LAW vitrification processes addressed in the EIS are based on a combustion fired melter. This melter type raised the concern regarding retention of volatiles and semivolatiles in the glass during technical review of the Preliminary Draft EIS. The requirements for a bleed stream were noted and included in the EIS.
As indicated in the comment, a bleed stream may not be necessary to avoid a continuous buildup of technetium-99 in the off-gas recycle stream, but based on available information, it appears probable that a bleed stream would be required. The functional requirements and sizing of the off-gas recycle system would be developed during the detailed design phase following selection of an alternative.
Comment Number 0012.20
ODOE
Comment Vitrification of the wastes greatly reduces the risk to the public and the environment. Even the least capable glass waste forms represent a dramatic improvement over the current conditions. Wise selection of pretreatment and segregation options and glass specifications may greatly reduce the long-term costs and risks to the public. These should not however delay decisions to proceed with cleanup and vitrification of Hanford's tank wastes.
There is no assurance that any of the vitrified waste will leave Hanford. As a consequence, it is essential that the vitrified waste contain all of the radioactive wastes for so long as they remain hazardous.
The vitrification alternatives do not specify the physical or chemical properties or requirements for the glass products. There is no specification for how durable the glass waste form must be, or for how long the glass must contain the radioactive wastes. Specifications must require the product glass be durable enough to contain the radioactive components for as long as they remain hazardous. This requirement is relatively easy to meet for short half-life isotopes such as strontium-90 and cesium-137. It is more difficult for long half-life isotopes which easily migrate in water, such as cesium-135, iodine-129, technetium-99, and neptunium-237. These isotopes are volatile and are difficult to incorporate into glass. Additionally, the long lived actinides also must be retained until they are no longer hazardous.
The common glasses used for the immobilization of high-level nuclear waste are not durable enough to contain these materials for the times needed. The borate content of these glasses is often controlled at high levels to reduce the melt temperature of the glass and to lower its viscosity. As the borate content is increased, the durability of the glass decreases. Glasses are attacked by organic acids such as humic and fulvic acids from the decay of vegetation which are often found in surface waters. Because the repository is expected to be deep underground, the water which may reach the repository is unlikely to contain large amounts of organic acids. Accordingly, the performance and durability studies of waste glasses for disposal to a national high-level nuclear waste repository have not analyzed the impact of organic acid corrosion on glass wastes, however this is particularly important if the glass waste remains at Hanford and may be subject to corrosion by surface waters.
If the durability of the glass cannot be assured and other barriers provide inadequate protection for the glassified wastes which may remain at Hanford, the radioactive isotopes with half-lives over one thousand years should be removed from the water soluble fraction of the wastes. These should be incorporated into better waste forms, or blended and glassified with the waste which will be sent to the national high-level nuclear waste repository. These isotopes include cesium-135, iodine-129, technetium-99, neptunium-237, and all long half-life actinides.
The durability requirements for glassified wastes to be sent to the proposed national high-level nuclear waste repository are not sufficient to assure protection of human health and the environment at Hanford. The physical conditions onsite are vastly different, and the geologic isolation provided by a deep repository is not available. The EIS must consider changing climate conditions. Hanford cannot be assumed to remain an arid area for as long as these wastes remain hazardous.
As the geologic barrier is not present at Hanford, and the glass wastes may exhibit more rapid corrosion from surface water, additional barriers to contain the waste should be included. The containers for the glass should be of sufficient chemical resistance and durability to protect the glass from the environment for as long as the wastes remain hazardous. The containers should be resistant to corrosive attack and embrittlement from exposure to the glassified wastes. Welding or other sealing of the containers should be done in such a manner as to avoid creating brittle areas in the container. Embrittled containers are likely to fail far more quickly.
Type 309 and 304L stainless steels have been proposed for use at Savannah River and West Valley, New York for containing glassified waste. High-carbon 309 stainless steel is easily embrittled by chloride ions. It should not be used. Low-carbon 304L stainless steel has insufficient molybdenum content to allow long term corrosion protection from the waste. If corrosion resistant stainless steel is used, it should contain at least three weight percent molybdenum to minimize corrosion from chloride and fluoride. It should also be very low carbon steel. Other high resistance alloys should be considered.
Response The alternatives presented in the Draft EIS provide a range of treatment, including disposal of HLW onsite as part of the in situ and combination alternatives. To be consistent with current national policy, all ex situ alternatives that include retrieval and treatment of the tank wastes are based on the assumption that the HLW would be disposed of in a geologic repository. The EIS does analyze permanent near-surface disposal of LAW under the ex situ and combination alternatives and disposal of HLW in place under various in situ and combination alternatives. To address public concerns with the availability of the geologic repository, all ex situ alternatives have been revised in Volume One, Section 3.4 to include interim onsite storage of the immobilized HLW for 50 years.
The ex situ alternatives that produce borosilicate HLW glass comply with the DOE OCRWM Waste Acceptance Systems Requirements document, which requires that the waste form meet performance criteria. The alternatives that do not produce a borosilicate HLW glass are identified as non-conforming to the geologic repository and are potentially not as acceptable and require resolution to make them acceptable which would make them subject to delayed acceptance.
Alloy specification for the HLW canisters would be accomplished during final design of the waste package. Embrittlement, corrosion, and material incompatibility are issues that will be evaluated during canister design and material selection. However, please note that the HLW canister presently has no long-term disposal function. This function is allocated primarily to the waste package disposal container.
DOE and Ecology acknowledge that technical issues requiring evaluation remain before the long-term impacts associated with permanent near-surface disposal of canistered HLW can be assessed. Please refer to the response to Comment numbers 0008.01 and 0008.02.
Comment Number 0019.04
WDFW
Comment The author states that "for the analysis performed in this EIS, a Hanford barrier was used to bound impacts." At this point in time, a cursory effort to bound impacts (resources) of a Hanford barrier should only require volume of soil needed and/or potential acreage impacted. A supplemental EIS can discuss borrow sites and alternatives.
Response DOE and Ecology acknowledge the concern expressed in the comment. However, the Hanford Barrier is the most extensive system for a surface barrier proposed for use on the Hanford Site. The assumption to apply this multi-layered barrier technology serves as the basis for comparison of the impact of changes within an alternatives, as well as between alternatives. The selection of borrow sites is an issue that would be addressed for tank farm closure which will be the subject of a future NEPA analysis. Please refer to the response to Comment number 0019.03. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0027.11
Roecker, John H.
Comment Waste Oxide Loading
The use of a 20 percent waste oxide loading is overly conservative and biases the alternatives analysis. A waste oxide loading of 25 percent has normally been used for design and analysis purposes. Studies are also underway for loadings in the 30-35 percent range.
Response The TWRS EIS uses bounding assumptions for HLW oxide loadings for all ex situ alternatives to provide a comparable and bounding analysis in the absence of definitive information. DOE and Ecology are aware that higher HLW oxide loadings have been used for process design and acknowledge, in Volume One, Section 3.4 of the EIS, that current development work may result in higher waste loading factors. Given the uncertainty associated with the characterization data and assumptions made for separations efficiencies, DOE and Ecology believe that a 20 weight percent waste oxide loading is a reasonable assumption for the purpose of calculating impacts. Waste loading is also discussed in the response to Comment numbers 0035.04 and 0027.11. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0040.02
Rogers, Gordon J.
Comment The 100-year limit for retaining administrative control is ridiculous, and is not applied to any other human activity.
Response Federal regulations (40 CFR 191) state that to provide the confidence needed for long-term compliance with the requirements for the disposal of HLW, active institutional controls over disposal sites should be maintained for as long as is practical. However, institutional controls are limited to 100 years when considering the isolation of the wastes from the accessible environment. As is stated in Volume One, Sections 3.4.2 and 3.4.3, the 100-year period is an assumption that has been applied to all alternatives analyzed in EIS to provide an equitable basis for comparison of impacts among alternatives. As required by the regulations, the administrative controls would be maintained by DOE and Ecology as agencies of the Federal and state governments. For related discussions, please refer to the response to Comment numbers 0101.01 and 0040.03. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0052.01
Pollet, Gerald
Comment Going to start tonight by asking that a little more attention be paid in the materials and the Final EIS through the advice of the Tank Waste Remediation System Task Force. The Task Force urged the three agencies from our putting together this EIS to explicitly not utilize a hypothetical repository in assessing costs and it is nice to go right after someone else whose commented on the same issue.
The TWRS Task Force said we have to assume canisters stay at Hanford. That is not only a reasonable alternative, unfortunately it is the realistic alternative, and it is not appropriately considered in the EIS. So what we need to see is - what are the long-terms costs and impacts from having canister storage here at Hanford.
Response The Tank Waste Task Force report recommended that DOE "accept the fact that interim storage, at least, of the waste in an environmental safe form will occur for some time at Hanford." The report also directed DOE to "assume temporary storage will occur at Hanford but did not assume that all radionuclides should be here forever" (HWTF 1993). The EIS, for all ex situ alternatives, assumes interim storage at the Hanford Site in an environmentally safe manner for up to 50 years and ultimate disposal of HLW offsite at the potential repository. If HLW storage extended beyond 50 years, appropriate NEPA review would be required. Please also refer to the response to Comment numbers 0035.04, 0081.02, 0038.10, 0008.02, and 0004.01 for related information.
Comment Number 0062.03
Longmeyer, Richard
Comment We've talked a little bit about the new tanks that are being filled with wastes from current tanks that are leaking. That also raises a safety concern in that, as was stated, this sludge that remains behind in the single-shell tanks that did leak, actually becomes more dangerous than when there was water in the tank. Dangerous in terms of the material itself, and danger of actual exposure to the outside from explosions, and so forth. So that is a concern.
Response A description of the saltwell pumping program, which is a required action under the Tri-Party Agreement, is provided in Volume One, Section 3.4 and Volume Two, Appendix B. An analysis of safety issues is performed prior to removing liquids to ensure that removal can be performed safely. The SSTs in question that have been pumped have been included in the accident and consequence analysis presented in Volume One, Section 5.12 and Volume Four, Appendix E. The unit liter doses from these tanks were compared with the unit liter doses from the rest of the SSTs and all of the DSTs. The bounding unit liter doses were used to calculate the consequences to bound the analysis.
Comment Number 0064.01
Roecker, John H.
Comment The second point I'd like to bring out is what I call data manipulation. There are examples throughout the EIS where data has been, what I call, manipulated to present a specific case, or to present certain agendas. I can give you some examples, in fact I will give you written comments on the ones that I have found. But as an example, where you talk about the high-end and the low-end of the number of canisters for the two different processes. The low-end you reference a Westinghouse document, and for the high-end you reference a DOE document. Being a little suspicious, and having a little experience with what was going on, I went back to look at those specific documents. The Westinghouse document is an engineering document, which has some pretty good estimates in it. The DOE document is a review of a systems requirements document of DOE that had a high number in it to make some very specific points. To use those numbers in the EIS, I think, is misleading. Because they do not accurately represent the engineering and technical data that is available.
Response The EIS presents an unbiased assessment of the potential impacts associated with each alternative. Please refer to the response to Comment number 0027.02 for a discussion of this same issue and Comment numbers 0081.02, 0008.01, 0069.04, 0035.04, and 0038.10 for a discussion of cost estimates.
Comment Number 0072.85
CTUIR
Comment P3-31: PP1: It should be assumed that there will be leaks and more leaks from the SSTs and DSTs during the administrative control.
Response DOE and Ecology realize that it is difficult to accurately predict the number or severity of tank leaks that will occur in the future. There are factors that will increase the number of leaking tanks, primary of which is the age of the tanks. As the tanks get older, the probability of a leak increases. There also are factors that will decrease the number of leaking tanks. The primary factor in decreasing leaks is the interim stabilization of the tanks by removal of the free liquid from the pore space and other voids in the tank solids; sealing the entrances to the tanks to prevent fresh liquid from accidentally entering the tanks; and placing covers over the tanks to inhibit the infiltration of precipitation. Once these measures are in place, leaks from the tanks would be very small. Because there was no inherently accurate method of determining future leaks, the assumption was made that at some predetermined time in the future (after the loss of administrative control), all the tanks of a given type would leak. This assumption allows an equitable comparison of the long-term environmental impacts of the various proposed alternatives. Please refer to the response to Comment numbers 0005.37, 0029.01, and 0072.70 for related information.
Comment Number 0072.86
CTUIR
Comment P 3-31: PP: Is the required depth to ground water, in the case of leaking tanks, at the minimum to the bottom of the leakage? Or is the required depth from the bottom of the tank? Please explain this with a description of the reasoning involved.
Response Releases for the tanks, whether from in situ or ex situ alternatives, are assumed to be from the bottom of the tank. This is a bounding assumption that results in the highest predicted contaminant concentration in groundwater.
Comment Number 0072.88
CTUIR
Comment P 3-31: PP 6: The efficiency goal should state no more than 1 percent of the solid-dry tank inventory would remain as a residual and no more than .1 percent liquid tank inventory remain as a residual following waste retrieval activities.
Response The Tri-Party Agreement (Ecology et al. 1994) includes a milestone that directly impacts the TWRS program. Milestone M-45-00 requires tank residues not exceeding 10.2 m3 (360 ft3) in each 100 series tank, and tank residues not exceeding 0.85 m3 (30 ft3) in each 200 series tank. This milestone provides the basis for the TWRS EIS assumption of 99 percent removal for ex situ alternatives. An overview of retrieval and transfer from the tanks is provided in Volume Two, Section B.3.5.3. Further evaluation of the residual inventory would be performed in a future NEPA analysis on closure of the tank farms. Please refer to the response to Comment number 0089.03, 0089.07, and 0005.18 for related residual waste information. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0072.89
CTUIR
Comment P 3-34: PP 7: Assuming that a LAW activity waste cullet provides the basis of conservatism is wrong. The technical staff of the SSRP suggests that all LAW waste be vitrified into glass and poured into canisters for the lowest risk levels.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
The referenced language in Volume One, Section 3.4 is a discussion of waste composition for the various alternatives. A disadvantage of cullet is its high surface to volume ratio, which results in lower long-term performance. Therefore, the calculations of leach rates are higher (more bounding from an impact assessment standpoint) for cullet than for other glass forms. In the area of long-term environmental impacts, this lower long-term performance manifests itself as greater amounts of contaminants leaching from the cullet. Changing to another waste form that would have potentially better long-term performance may be achieved during the final design of the alternative selected. Because the information contained in the Draft EIS is correct, no change to the text was made. Please refer to the response to Comment number 0005.40.
Comment Number 0072.90
CTUIR
Comment P3-3: PP 8: The public has stated numerous times that grout for use as a way of stabilizing tank waste in any form is unacceptable.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Grouting liquid waste streams is included in Volume Two, Appendix B as a reasonable immobilization technology in the EIS; however, it is not a technology included in the preferred alternative. For a discussion of NEPA requirements to analyze reasonable technologies, please refer to the response to Comment number 0072.05. Grout is discussed in the response to Comment numbers 0005.18, 0009.03, and 0072.179.
Comment Number 0072.178
CTUIR
Comment P B-37: Sect.B.3.0.6: Please explain how soda lime glass can be upgraded to the standards of the only standard HLW form, borosilicate glass in terms of leachability, thermal-breakdown, expansion, and ability to capture and isolate radionuclides.
Response Soda-lime glass would have different characteristics than borosilicate glass in terms of leachability, thermal expansion, and physical processing parameters. As stated in Volume Two, Section B.3, borosilicate glass currently is identified as the only standard HLW form to be accepted at the potential geologic repository. Other types of glass could be selected for the vitrification of HLW or LAW; however, they would have to meet the NRC waste form requirements and support the repositories ability to meet long-term performance requirements.
Under the Ex Situ No Separations alternative, all of the sodium present in the tank waste would be included in the vitrified waste stream. Because of this, the glass more closely approximates a soda-lime glass. The repository Waste Acceptance Systems Requirements Document currently includes only borosilicate glass as an acceptable glass composition; however, it identifies that other waste forms may be addressed in the future. The acceptability of alternative glass compositions would be based on waste form performance testing. Please refer to response to Comment numbers 0012.20, 0012.11, and 0035.04 for a related discussion.
Comment Number 0072.179
CTUIR
Comment P B-38: The use of grout is unacceptable and has been thoroughly denounced by the public. The grouting of LAW which will contain discrete particles of hi-activity radionuclides is unacceptable.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0072.90, which addresses the consideration of grout as a waste form in the EIS.
Comment Number 0072.194
CTUIR
Comment P B-157: Sect. B.5.0: The information on how closure activities would affect remediating the tank waste should include carrying all of the listed closure options through the alternatives process in order to adequately present the information. Simply choosing a single representative approach to tank closure (closure as a landfill) is insufficient and in the light of the importance of this retrieval EIS. The closure options presented must indicate whether they do or do not preclude one or more of the alternatives. Additionally the closure options must necessarily conform to the law ALARA conditions for the purposes of reducing risks to future generations. This information is simply not here and raises doubt that the representative approach is truly representative.
Response Please refer to the response to Comment number 0072.08 for a discussion of the reasons closure alternatives cannot be assessed at this time and 0072.50 for information on alternatives that would preclude closure options. Closure of the tank farms will be addressed in a future NEPA analysis when sufficient information is available on past practice releases, releases during retrieval, and tank
residuals. Please refer to the response to Comment number 0101.06 for a discussion of issues related to analysis that would be required to support closure alternatives analysis. Because the analysis requested in the comment is not within the scope of the EIS, no modification to the document is warranted.
Comment Number 0072.195
CTUIR
Comment P B-158: Sect. B.6.0: The inclusion of the Hanford Barrier and the exclusion of all other closure activities may preclude adequate justification of the alternative section due to the fact that providing one option is not providing a choice of options. Please insert the other closure activities options or remove section B.5.0 tank closure because it is not within the scope of this EIS.
Response Closure is not included in the scope of this EIS because there is insufficient information concerning the amount of contamination to be remediated. However, Volume One, Section 3.3 and Volume Two, Section B.5 address how tank waste remediation and closure are interrelated because some of the decisions made regarding how to treat and dispose of tank waste may impact future decisions on closure. To provide information on how closure activities would be affected by remediating the tank waste, a representative approach to tank closure (closure as a landfill) has been included in each of the TWRS alternatives to allow an equitable comparison of the alternatives. The Hanford Barrier described in Volume Two, Section B.6 is included as a representative approach to tank closure. Please refer to the response to Comment numbers 0101.06, 0019.03, 0019.04, 0052.01, 0072.50, and 0101.05 for related discussions. Because the analysis requested in the comment is not within the scope of the EIS, no modification to the document is warranted.
Comment Number 0081.04
Pollet, Gerald
Comment The Tank Waste Task Force, convened by the Department of Energy, U.S. EPA, and Washington Department of Ecology, urged that the Department of Energy abandon making decision making on the basis of high-level nuclear waste canisters, and their theoretical costs for being placed into a repository. Our advice was, now I need to turn to the appropriate page, on page 11 of the Task Force Report under Values, under Waste Form and Storage. Let the ultimate best form for the waste drive decisions, not the size or timing of the national repository. This EIS has failed to consider that advice.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0081.02, 0008.02, 0035.04, 0038.10, and 0052.01 for a discussion regarding task force advice.
Comment Number 0089.03
Nez Perce Tribe ERWM
Comment Listed below are our general statements regarding the EIS.
Some necessary topics are not properly considered in the EIS. An example is the proposal to leave 1 percent of the waste in the tanks. We believe that with the technology currently proposed, if 99 percent of the waste can be removed, then it is also possible to remove much of the remaining 1 percent of the tanks wastes. This question will definitely be pursued by ERWM during soil and groundwater remediation, which are not part of the EIS. For proper soil remediation, beneath the tanks following closure or tank removal, it is imperative that no waste be left in the tanks.
Response The amount of residual waste that ultimately remains after retrieval will depend on the effectiveness of the retrieval technology. For the purposes of NEPA analysis, the assumption that 1 percent of the waste would remain in the tanks was assumed in the EIS analysis. For a discussion of this issue, please see the response to Comment numbers 0005.18 and 0089.07. Further experience with waste retrieval will be required before the issue of the extent of retrieval can be fully resolved. Please refer to the response to Comment numbers 0101.06, 0072.08, and 0072.88 for related information concerning tank waste residuals, soil and groundwater contamination, and closure.
L.3.4.2.4 Miscellaneous Issues
Comment Number 0005.41
Swanson, John L.
Comment The word "grouting" at the start of the last paragraph on page 3-34 appears to be out of place, and appears to belong instead at the start of the first paragraph on the next page.
Response "Grouting" does belong with the paragraph at top of page 3-35 of the Draft EIS. The two sentences following the word "grouting" are out of place. The text of the Final EIS has been corrected.
Comment Number 0005.43
Swanson, John L.
Comment On page 3-36 is discussed the use of sodium from the FFTF to make sodium hydroxide for use during enhanced sludge washing. Is this really worthy of mention? Was the cost of conversion of sodium to sodium hydroxide (which has some safety problems) included in the cost estimates?
Response Fast-Flux Test Facility (FFTF) sodium disposal is worthy of mention because of the potential amount of material that may require disposal considerations in the near future. A cost analysis of the conversion facility and the process safety issues were not performed and would need to be addressed before a decision was made to use FFTF sodium as a source of material for separations chemicals. The use of sodium from FFTF was included in the EIS as an example of Sitewide waste minimization activities that could be considered.
Comment Number 0008.04
Evett, Donald E.
Comment On the subject of groundwater, I believe the method of retrieval using the articulated arm to reach into the tanks and recover waste would be an excellent method and it would reduce the amount of leakage, which is of paramount importance.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. As indicated in Volume One, Section 3.4, the articulated arm retrieval method would be used in situations where conventional technology is not effective or inefficient for the particular tank waste type or form. Using the articulated arm technique and others is also key to removing as much of the tank waste as possible to minimize or eliminate any materials that could be released to the environment. DOE and Ecology will analyze the data collected during the demonstration phase to select the most effective removal method for the tank and tank waste type.
Comment Number 0068.03
Martin, Todd
Comment The last point I want to make is that a clear lesson that we've learned from Hanford and from the nuclear weapons complex is that postponements and delays lead to greatly increased obligations in the future. We've learned that in spades, at least I hope we've learned that. And I'm not sure that the Federal government has learned that. The American people are certain of that. That means we need to get on with it now, otherwise it's going to cost that much more in the future.
Response DOE and Ecology share the desire to proceed with remediation at the earliest possible date. Delays can be costly. DOE intends to allow sufficient time to design adequate actions that are supported by factual information, that incur a reasonably acceptable level of technical risk (i.e., high probability that the action will work and accomplish the desired result), and that are implemented in a managed and cost-effective way. Please refer to the response to Comment numbers 0009.19, 0060.02, 0098.02 and 0078.07.
Comment Number 0072.82
CTUIR
Comment P 3-27: Sect. 3.4.1.1: First bullet: What exactly is "managing operations" and are these the operations included in the 1997 RDS for fail-safe management?
Response Managing operations, as listed in the first bullet in Volume One, Section 3.4, includes the activities listed in the bullets that follow as well as tank farms and associated facilities management (as a program), and the relationship of the TWRS program to the Hanford Site Operations system. Consequently, the management issues relevant to each activity (e.g., personnel, safety, quality, and milestone status) are relevant on a programmatic level across Tank Farm Operations. Tank farms management is one operation described in the 1997 Risk Data Sheet (RDS) for fail-safe management. The 1997 RDS was prepared for the Hanford Site as a single operation.
Comment Number 0072.83
CTUIR
Comment P 3-28: PP 4: how much exactly will these controls increase the cost of maintenance and monitoring activities.
Response The operating cost and schedule impacts associated with placing all 177 tanks under flammable gas controls (if this were to occur) is not fully known at this time. One of the factors that will influence the cost and schedule impacts would be resolution of the flammable gas safety issue for the tanks.
Comment Number 0072.87
CTUIR
Comment P 3-31: PP 4: How can you fill a tank full of liquid with rocks and not have liquid overflow?
Response As discussed in the description of the alternatives in Volume One, Section 3.4 and Volume Two, Appendix B, for the In Situ Fill and Cap alternative, as much water as possible would be removed from the liquid waste streams through evaporation at the 242-A Evaporator. The amount of water that can be removed from a liquid waste stream at the evaporator is limited by the saturation concentration of the evaporated waste stream. Following transfer of the evaporated liquids back to the tank, salt-cake formation would begin in the DSTs similar to what has already happened with the DSTs. This would allow for additional evaporation of the liquids. If the In Situ Fill and Cap alternative were selected for implementation, further analysis may indicate a need for additional evaporation using in-tank technologies for selected tanks.
Comment Number 0072.91
CTUIR
Comment P 3-36: PP 1: Exactly what is "some low temperature process"? How much will this process cost? Is this process figured in the privatization process, and what are the risks associated with this? How much extra waste is going to be generated with this process? What will this waste be classified as?
Response Calculations performed for the Ex Situ Intermediate Separations alternative off-gas recycle bleed stream resulted in an estimate of 3,500 m3 (930,000 gallons) of liquid waste. This waste stream would be dilute and the volume could be reduced by evaporation. The stabilization of this waste stream would require a low-temperature stabilization and treatment technology such as encapsulation, hydraulic cements, or organic polymers to immobilize the waste and limit further volatilization. The development and selection of this process would occur during the detailed design phase. An individual cost estimate for this process was not included in the alternative cost estimates developed for the EIS. The cost would be minor compared to the total alternative cost and would be well within the estimated cost range.
Each of the alternatives that involve high temperature waste treatment technologies, such as vitrification, would have to deal with the volatile chemical and radionuclide emissions in the off-gas system. The risks during remediation are included in the analysis performed for each of the alternatives in Volume One, Section 5.11 for health impacts during remediation. The post-remediation risks that would result from disposal of the stabilized off-gas recycle bleed stream is assessed in the Performance Assessment for the Disposal of Low-Level Waste in the 200 West Area Burial Grounds.
An estimate for the total volume of immobilized waste that would be generated has not been made for the alternatives. A volume estimate would be made during the detail design phase when the characteristics of the bleed stream were developed and the immobilization technologies were evaluated.
Following stabilization, this waste stream would be classified as LAW. The classification and handling of this waste stream would be consistent with established Hanford Site solid waste disposal practices.
Comment Number 0072.180
CTUIR
Comment P B-39: S 2: Please explain how the amount of tertiary waste generated would be primarily a function of the number of operating personnel.
Response The primary component of tertiary waste is personal protective equipment. Therefore, because the number of operating personnel required to wear personal protective equipment when the potential exists for contact with hazardous or radioactive substances is higher for the alternatives that include the more complex remediation activities, the amount of tertiary waste generated also would be higher.
Comment Number 0089.05
Nez Perce Tribe ERWM
Comment Offsite disposal of LAW should be considered in the EIS.
Response DOE and Ecology acknowledge the recommendation expressed in the comment. Offsite disposal of all waste at the potential geologic repository is addressed in the EIS under the Ex Situ No Separations alternative. Offsite disposal of the LAW was not considered to be a reasonable alternative because of the cost and human health impacts of transporting the waste and because there would be no compensating benefits to offsite disposal. Please refer to the response to Comment number 0005.03 for a discussion of the assumptions used in the alternative analyses.
Comment Number 0089.11
Nez Perce Tribe ERWM
Comment Page B-72, Paragraph 1
We have some questions about the plan for the cross-site transfer line. Apparently this line will be sloped to at least 0.25 percent grade to preclude accumulation of solids. ERWM questions the thought behind those plans, the elevations at 200 West and 200 East are nearly the same but 5 miles apart. How will the line be constructed and this slope engineered?
Response Specifications for the cross-site transfer line are not included in the scope of this EIS; however, the SIS Final EIS addresses the cross-site transfer line in detail (DOE 1995i). The SIS EIS was referenced during preparation of the TWRS EIS. According to the SIS EIS, the line would slope up from the 200 West Area to a midpoint, and then down to the 200 East Area to ensure that the line will drain.
L.3.4.3 No Action Alternative (Tank Waste)
Comment Number 0072.94
CTUIR
Comment P 3-40: Sect 3.4.2: No Action Alternative: Technical staff of the CTUIR do not agree that this alternative is a responsible action, given that the contents have half lives that number in the thousands.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives.
NEPA requires that all reasonable alternatives be evaluated, regardless of cost, compliance to existing regulations, potential risk, or any other factor used in the analysis of alternatives. Furthermore, the CEQ requires that the TWRS Draft EIS identify and analyze a range of reasonable alternatives for the proposed action, as well as for the No Action alternative. All data that support the cost and impact analysis of each alternative are presented in an objective and unbiased format for comparison by the decision makers and the public during the comment period. Please refer to the response to Comment numbers 0072.80 and 0072.10 for more information concerning the No Action alternative and NEPA requirements for reasonable alternative analysis.
Comment Number 0072.181
CTUIR
Comment P B-41: Sect. B.3.1: A one hundred year administrative control period does little to protect human health and environmental impacts from long lived (>10,000 year 1/2 life radionuclides).
Response Although DOE has no plans to abandon the Site after 100 years, it is not reasonable to assume that administrative controls will extend to 10,000 years. In order to show potential impacts that could occur if administrative controls were lost, a 100-year administrative control period was assumed. This assumption is consistent with standard impact assessment methods for hazardous and radioactive waste sites. Please refer to the response to Comment numbers 0072.80, 0040.02, and 0101.01 for discussions related to DOE assumptions associated with the 100-year administrative control period and the analysis of long-term impacts resulting from the loss of institutional controls.
Comment Number 0072.182
CTUIR
Comment P B-43: Sect. B.3.1.4: Please insert the statement 'some tanks may not last fifty years'.
Response Volume Two, Appendix B addresses actions that would be taken in the event that a tank leaks within the estimated design life of 50 years, as well as the integrity testing to be conducted within any applicable 50-year design life. "Continued management would include maintaining spare DST space to accommodate leak recovery in the event of a DST leak. Tank conditions would be continually monitored, and those tanks determined to be leaking would require recovery of the leakage from the tank annulus." Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted.
L.3.4.4 Long-Term Management Alternative
Comment Number 0038.01
Reeves, Merilyn
Comment I would like to point out that one of the things that the Hanford Advisory Board did was to commission a special report, a report to look at whether or not we should build six new massive tanks, double-shelled to hold waste because we were not looking at any other end point.
A report was prepared by Dr. Glen Paulsen, Dr Frank Parker, and Dr. Michael Cavanaugh, noted experts in the field.
And from this report it became clear that they recommended that no new monies be spent for the construction of new tanks to store the tank waste at Hanford.
The Board adopted this. This is a savings of approximately 300 to 400 million depending on which report you look at.
I think that this also puts in place the Long-Term Management alternative in the EIS that would have required replacement of all the double-shelled tanks in the year 2035, and again in the year 2085.
And so I believe that our consensus advice, which was listed as consensus advice number 22 in which we endorsed the recommendations of this report should put to rest whether or not we should embark on any scheme to just continue to build double-shell tank for storage of these wastes.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
NEPA requires DOE and Ecology to examine a full range of alternatives in the EIS. The range of alternatives must include a No Action alternative and then may include other reasonable alternatives to allow an analysis of a full range of alternatives. Within the range of considered alternatives is the Long-Term Management alternative, which contains the provision for building two sets of DSTs at 50 and 100 years in the future. Including this alternative in the EIS serves a useful purpose, because while it does not contain provisions for immobilizing the tank waste, it does contain provisions for maintaining the SSTs in a relatively dry condition and for retanking the wetter DST wastes on a periodic basis. Please refer to the response to Comment number 0072.05 for a discussion of how the alternatives were developed to comply with NEPA requirements to analyze a range of reasonable alternatives.
Comment Number 0072.95
CTUIR
Comment P 3-43: PP: The argument for long term management seems poor given that a large amount of SST waste has already leaked to the ground, and that the transfer of tank waste simply for maintenance reasons has inherent risks that are unacceptable.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
NEPA requires that all reasonable alternatives be evaluated, regardless of cost, compliance to existing regulations, potential risk, or any other factor used in the alternatives evaluation process, which would include the Long-Term Management alternative evaluated in the EIS. Please refer to the response to Comment numbers 0072.05 and 0038.01 for related discussions. All data that support the cost and impact analysis of each alternative are presented in an objective and unbiased format for comparison by the decision makers and by the public during the comment period. DOE and Ecology are aware that the vadose zone has been contaminated beneath the tanks. Existing contamination is presented in Volume One, Section 4.2, and cumulative impacts of existing contamination, TWRS alternatives and other Hanford Site actions are presented in Volume One, Section 5.13. The potential risks associated with moving waste from one tank to another one are analyzed in the EIS in Volume One, Section 5.11 and Volume Three, Appendix D for routine operations during remediation and Volume One, Section 5.12 and Volume Four, Appendix E for accident risks.
Comment Number 0072.96
CTUIR
Comment P 3-45: Sect. 3.4.3.5: Post Remediation: this section needs to have an account of the remediation of the extra ground used.
Response This comment refers to the post remediation section for the Long-Term Management alternative. The extra ground would be the surface area overlaying the 26 new DSTs that would be constructed as part of this alternative. As explained in Volume One, Section 3.4.3.1, this alternative is similar to the No Action alternative in that administrative controls over the Hanford Site are assumed to be maintained for 100 years. No remediation activities would be performed. The consequence is stated in Section 3.4.3.5 that there would be no post-remediation activities associated with the Long-Term Management alternative. Because there is no remediation of the extra ground, no account of this activity has been provided in the EIS.
Comment Number 0072.183
CTUIR
Comment P B-44: Is there a sludge well pumping operation ongoing?
Response DOE and Ecology believe that the comment is referring to saltwell pumping. Saltwell pumping of the SSTs to remove interstitial liquids is an ongoing operation that is scheduled to be completed in the year 2000. Saltwell pumping is an activity that would be a part of continued operations under all alternatives as indicated throughout Volume One, Section 3.4.
L.3.4.5 In Situ Fill and Cap Alternative
Comment Number 0072.184
CTUIR
Comment P B-48: Sect. B.3.3: This alternative is unacceptable as are all in situ alternatives. Language clearly defining that in situ alternatives are against the law must be inserted here.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The Summary, Section S.7, discusses regulatory compliance for each alternative and indicates which alternatives would fail to comply with applicable laws and regulations. Regulatory compliance also is addressed in Volume One, Sections 3.4 and 6.2 and Volume Two, Appendix B. In each of the sections cited, it is clearly stated that this alternative would not comply with certain laws and regulations. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted.
L.3.4.6 In Situ Vitrification Alternative
Comment Number 0014.01
Bullington, Darryl C.
Comment It is impossible to take seriously any document that includes a proposal to spend 16 to 23.8 billion dollars and use one-quarter of the available electricity of the Washington Public Power Supply System to vitrify 73 million curies of hazardous radioactive solids and surrounding soils contaminated with thousands of gallons of cesium-137 containing liquid (a volume of over 20,180 cubic yards per tank) to a depth of sixty feet by inserting electrodes and heating to 2,600 to 2,900 F. Before I would even waste the paper to evaluate such a scheme I would have to see some demonstration using noncontaminated materials at a place and in a way that would not be a hazard to the public and people involved. To design any system that could contain all of the gases that would be suddenly released from such an event or a heat shield needed to protect the operating deck above the tanks, and enclosed, should melting such a mass even be possible, is beyond all imagination. To perform such a full-scale demonstration for $70 million is also highly suspect.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. ISV is a commercially available technology that has been successfully demonstrated on a smaller scale and is a reasonable alternative for analysis in the TWRS EIS. The EIS does discuss the technical uncertainties associated with implementing this alternative in the Summary, Section S.7, Volume One, Section 3.4, and Volume Two, Appendix B. Please refer to the response to Comment numbers 0072.80 and 0072.05 for discussion of NEPA requirements for reasonable alternatives analysis.
Comment Number 0023.01
Geosafe
Comment The ISV alternative should provide an objective evaluation for selecting the size of the tank farm containment facility. The confinement facility as shown in Figure 3.4.5, which encloses an entire tank farm, may have some distinct advantages but it poses significant design and construction difficulties. A smaller containment facility could be more easily constructed that encloses only one tank at a time. The smaller facility could be moved into position using a crawler system similar in design to that proposed for the decommissioning of the 100 Area Reactors (WHC MLW-SVV-037106). Two sets of crawlers could be used to move multiple containment facilities. Although not stated in the EIS, it is presumed the need to enclose an entire tank farm was based on the premise that a structural load could not be supported by the dome structure of the tanks and would result in their collapse. For the ISV alternative, the void spaces in the tanks will be filled with sand or other material and can be made suitable for load bearing. The smaller confinement facility would be significantly easier to construct, maintain and decontaminate after project completion. In addition, the smaller facility should significantly reduce the degree of technical difficulty in implementing the ISV alternative and potentially lower its cost as well.
Response Alternative configurations for the tank farm confinement facility for ISV are possible. The configuration proposed in the comment is smaller than the facility depicted in the TWRS EIS. This proposed size reduction ultimately could result in a confinement facility that would be mobile, and could be moved from tank to tank within a tank farm. A large facility would not impose a bearing load on the individual tanks because its perimeter would lie outside of the tank farm. Because a smaller confinement facility potentially would impose a bearing load on adjacent tanks, a design solution to this problem would have to be formulated before the smaller confinement facility could be considered practicable. Filling the adjacent tanks with sand would be among those considered.
One potential problem area not discussed in the comment is the off-gas collection and treatment equipment and facilities. With a large confinement facility, the off-gas would be ducted to stationary treatment facilities. With the smaller, mobile confinement facility, the solution might be to move the off-gas treatment facility when the confinement facility is moved, or alternately, to re-route the off-gas ducting when the confinement facility is moved. This is one of a number of areas where further detailed study potentially could result in an improved process. In these areas of potential improvement, the configuration selected for inclusion in the EIS represented a bounding condition, which would result in environmental impacts that were likewise bounding. These bounding impacts are those presented to the decision makers.
The Draft EIS addressed the full range of reasonable alternatives. The alternative is bounded by the alternatives addressed in the Draft EIS, and DOE and Ecology believe that including the requested alternative would not provide valuable additional information to the public or decision makers. For a discussion of the approach used in the EIS to develop and analyze alternatives, please see Volume One, Section 3.3 and refer to the response to Comment number 0072.05.
Comment Number 0023.02
Geosafe
Comment An objective evaluation should be provided for selecting the size of the ISV equipment. The evaluation should discuss the advantages and disadvantages of using a large ISV system versus using a smaller system more closely resembling commercially available equipment.
The concept of treating a tank with extremely large melts significantly increases the difficulty and the technical Implementability of the ISV alternative. The ISV system proposed in the EIS is 40 times larger (4 Mw vs. 160 Mw) than existing equipment and is capable of treating a tank in one setting. Geosafe believes treating tanks in large settings may pose significant operational problems. We believe a more workable approach is to treat tanks with smaller multiple ISV settings so as to have better control on the release of vapors from in and around the tank.
Another factor to consider with a large-scale ISV systems is power level fluctuations caused by startup or shut down. It is envisioned that power line fluctuations caused by a 160 Mw system may be unacceptable for the regional power grid unless special arrangements are provided.
In summary, smaller ISV units that treat tanks in multiple settings would greatly increase the technical Implementability of the ISV alternative and potentially reduce costs. Schedule requirements could be maintained by using multiple ISV systems operating simultaneously at various tank farms. In addition, the research and development time required for the smaller ISV unit would be significantly shorter than the 160 MW unit.
Response Alternative configurations for the power supply facility for ISV are possible. The configuration proposed in the comment is smaller than the facility depicted in the EIS. A large facility potentially could impose load fluctuations on the regional power grid, although with proper planning these fluctuations could be effectively managed. Because a smaller power supply facility potentially would melt only a portion of a tank and its contents, a solution to this problem would need to be formulated before the smaller power supply facility could be considered practicable. Using multiple power supply units would be one solution among those considered. That multiple smaller power supply units potentially would reduce costs may be premature. For the majority of process equipment, purchasing a single large unit rather than multiple smaller units is generally more economical. To state that the research and development time required for the smaller power supply facility would be significantly shorter than for the larger unit also may be premature. Using multiple ISV settings would allow better control on the release of vapors from in and around the tank also would be considered premature until further studies have been completed. These are a number of areas where further detailed study potentially could result in an improved process. In these areas of potential improvement, the configuration selected for inclusion into the EIS represented a bounding condition, which would result in environmental impacts that were likewise bounding. These bounding impacts are those presented to the decision makers.
The Draft EIS addressed the full range of reasonable alternatives. As the alternative identified in the comment is bounded by the alternatives addressed in the Draft EIS, DOE and Ecology believe that including the requested alternative would not provide valuable additional information to the public or decision makers. Please refer to the response to Comment numbers 0023.01 and 0072.05.
Comment Number 0023.03
Geosafe
Comment Two techniques should be evaluated for reducing the processing depth of ISV which is specified in this document as 60 ft. Implementation of one or both of these techniques will decrease the technical difficulty of implementing the ISV alternative.
The first option would involve the removal of overburden to expose the dome structure of the tank. The overburden could be subsequently added to the tanks to eliminate internal void spaces. This would decrease the required processing depth of ISV to approximately 45 ft for the largest volume tanks.
The second option would involve the intentional lowering of the tank dome structure into the tank to reduce the effective processing depth from 45 ft to 33 ft for the largest tanks. This would be accomplished by first covering the contents of the tanks with an adequate depth of soil to provide radiation shielding. Next the center portion of the tank would be cut into pieces and lowered into the tank on to the soil. Following the removal of the dome structure, additional soil would be placed in the tank to provide a level surface to begin ISV operations. It is recognized that cutting into a tank will present some added risk that will need to be evaluated.
Response Further research and investigation associated with ISV is possible. This particular comment deals with potential solutions to the problem of having ISV operate at depths of approximately 60 feet. The suggestions for using the tank overburden to reduce tank voids; and subsequently lowering the tank dome into the tank before vitrification are examples of areas where further investigation may prove to be of value; however, substantial safety considerations would need to be overcome. Added risk from exposing and cutting into the tanks has not been evaluated. These are several areas where further detailed study could potentially result in an improved process. To address this issue, the cost estimate includes additional costs for technology development for this alternative. In these areas of potential improvement, the configuration selected for inclusion into the EIS represented a bounding condition, which would result in environmental impacts that were likewise bounding. These bounding impacts are those presented to the decision makers. Please refer to the response to Comment number 0023.01.
Comment Number 0023.04
Geosafe
Comment Following treatment of the tanks with ISV, there is no need for the tanks to be capped with the Hanford barrier. A simpler and less expensive cover to minimize the downward percolation of water could be used. The Hanford barrier is designed to provide plant, animal and human intrusion into a waste zone using a thick zone of crushed rock and to prevent the downward percolation of water. Since the ISV monolith is already a rock "cap" of considerable structural strength the need for a biointrusion zone is unnecessary.
Response ISV will leave the tank contents in a form unique to that alternative. However, the remaining waste form is still radioactive and some means must be employed to prevent access by humans, animals, and plants. The Hanford Barrier was used for this purpose as a potential form of closure, which is applicable to all the alternatives. Closure or dispositioning of the tanks is further discussed in Volume One, Section 3.3 and in Volume Two, Section B.5.0 of the EIS. Tank waste remediation and tank farm closure issues cannot be separated; therefore, an assumption common to all alternatives was included in the alternatives evaluation, but not evaluated as a single, specific action. Because the information contained in the Draft EIS is correct, no change to the text was made. Please also refer to the response to Comment number 0019.04 for a discussion of the Hanford Barrier.
Comment Number 0023.05
Geosafe
Comment The ISV cost estimate should discuss the following costing assumptions: (a) are individual tank depths being taken into consideration for estimating treatment volumes, e.g. the 500,000 gal tanks are 18 ft deep and the million gal tanks are 32.5 ft deep, (b) is the area between tanks being vitrified and (c) is soil beneath the tanks being treated.
Response DOE and Ecology have presented life-cycle cost estimates for each alternative. These estimates are based on conceptual designs for the alternatives. Because of the conceptual nature of the alternatives, there is a level of uncertainty associated with the life-cycle cost estimates. To account for the variations cited in the comment, such as variations in tank sizes and variability of the volume of treated material, an uncertainty analysis has been completed for the tank waste alternatives. The resultant cost range for each alternative is shown in Volume Two, Section B.8.0 of the EIS. Other information on the cost estimates is contained in Volume One, Section 3.4.1.7 and Volume Two, Section B.3.0.8 of the EIS. Only the contaminated soil between the tanks and immediately around and below the tanks is assumed to be vitrified. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.06
Geosafe
Comment Page 3-52, 4th par. "Each vitrification system ... consuming 160 Mw of power." Power consumption rates should be discussed for all alternatives and not be specifically limited to the ISV alternative. ISV is an extremely efficient vitrification technology. On average ISV consumes 800 Kw-hrs of electricity to vitrify a ton of material which is considerably lower than other vitrification technologies. The power consumption rates as listed in Table B.11.0.3 for the ISV alternative is 7,690 Gwh, which is less than the "ex situ no separation" alternative (8,800 Gwh) and the "ex situ extensive separation" alternative (41,600 Gwh).
Response The preliminary calculations used in the EIS show that ISV has a power consumption lower than other alternatives. To provide a side-by-side comparison of the resource consumption of the alternatives, DOE and Ecology have presented the material in summary form in Volume Two, Table B.11.0.3. To provide a complete narrative description in Volume One, Section 3.0, the EIS presents the information for each alternative under six headings: Process Description; Construction; Operation; Post Remediation; Schedule, Sequence and Costs; and Implementability. The Process Description for each alternative describes the major pieces of equipment for each process, giving a description of some of the major equipment used in the process. The section to which the comment refers is the Process Description for ISV, and the power supply was described as one of the major equipment items of this process. For other alternatives, the major equipment items will be different because the process is different. Because this section is a process description, it should not be interpreted as attempting to portray ISV as having obvious advantages or disadvantages. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.07
Geosafe
Comment Implementability: 1st bullet, The degree of uncertainty of the ISV alternative will be significantly reduced by using smaller ISV units as discussed above.
Response The concept of treating tank waste with large-volume melts may have more technical issues associated with the implementability of the ISV alternative. The configuration proposed in Comment number 0023.01 is smaller in size than the facility depicted in the EIS. This is one of a number of areas where further detailed study potentially could result in an improved process with fewer issues regarding technical implementability. In these areas of potential improvement, the configuration selected for inclusion into the EIS represented a bounding condition, which would result in environmental impacts that were likewise bounding.
Comment Number 0023.08
Geosafe
Comment Implementability: 2nd bullet, We agree that substantial research and development activities would be required to implement the 160 MW ISV system and for this reason have recommended using smaller ISV units closer to the scale of our commercial 4 MW system. Geosafe has already proposed a concept to DOE for treating the single shell and double shell storage tanks using our 4 MW ISV system (see attached white paper dated December 1995). The 60 ft depth limitation for processing the large volume tanks can be reduced by implementing the techniques discussed in comment A 3. [Comment number 0023.03]
Response Alternative configurations for the power supply facility for ISV are possible. The configuration proposed in the comment is smaller than the facility depicted in the EIS. It should not be inferred that the use of a smaller power supply is a feature of any particular vendor or that the use of a smaller power supply constitutes an endorsement by DOE or Ecology. Because a smaller power supply facility would potentially melt only a portion of a tank and its contents, a solution to this problem would have to be formulated before the smaller power supply facility could be considered to be practicable, and substantial research, development, and demonstration activities still would be required. There are a number of areas where further detailed study potentially could result in an improved process. In these areas of potential improvement, the configuration selected for inclusion into the EIS represented a bounding condition, which would result in environmental impacts presented to the decision makers as bounding. The EIS analysis bounds the information suggested by the commentor. For a discussion of the technique of reducing the depths of the tanks, please refer to Comment number 0023.03. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.09
Geosafe
Comment Implementability: 3rd, bullet, The possibility of an uncontrolled reaction occurring in a tank is mainly limited to 38 tanks containing organics or ferrocyanide material. The DOE Radioactive Tank Waste Remediation Focus Area is currently evaluating the explosive issue concern. Potentially, ISV treatability testing will be required to fully address this concern.
Response Further treatability testing will be required to fully address the concern of uncontrolled reactions in the tanks if the contents were vitrified. There may be answers to the situation that are inherent with ISV, which is that extensive mixing of contents of different tanks to mitigate potential uncontrolled reactions is not included in the process. At present, the testing of the heating of tank contents has been limited, and it may be premature to state that the problem is mainly limited to 38 tanks containing organics or ferrocyanide material. Until further investigations have been completed, DOE and Ecology believe that the statement in the EIS that further analysis is required remains correct. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.10
Geosafe
Comment Implementability: 4th bullet, We agree that the tank farm containment facility is highly conceptual and recommend that it be scaled down in size from the proposed 500 ft wide by 600 ft long facility to an approximately 120 ft square facility which covers only one tank. The technical difficulties of constructing the smaller facility are minimal.
Response The large tank farm confinement facility is highly conceptual in nature. The area discussed at this point is that further development would be required before any confinement facility, regardless of size, would be expected to comply with current DOE facility design requirements. A confinement facility that is 120 feet on a side is still sufficiently large that additional design study would be required. The technical difficulties that may be expected in designing and constructing the smaller confinement facility would be less than those expected in designing and constructing a much larger confinement facility. It may be optimistic to state that these technical difficulties would be minimal. This is one of a number of areas where further study potentially could result in a process with fewer issues regarding technical implementability. In these areas, the configuration selected for inclusion into the EIS represented a bounding condition, which would result in environmental impacts that were likewise bounding. These bounding impacts are those presented to the decision makers. The EIS bounds the information suggested in the comment. Please refer to the response to Comment number 0023.01 regarding the use of smaller ISV units.
Comment Number 0023.11
Geosafe
Comment Implementability: 5th bullet, The use of a smaller tank containment facility will eliminate most of the construction difficulties. Using a smaller mobile containment facility will allow construction activities to take place in a clean area, thereby eliminating the risks and added expense of working in or around a tank farm exclusion zone.
Response The large tank farm confinement facility may be more difficult to construct. The area being discussed in the EIS at this point is the atypical nature of the design of the large confinement facility and restrictions associated with working in and around the tank farms. While a smaller confinement facility could be constructed adjacent to the tank farms and then moved into position to assume that this will eliminate the risks and added expense of working around the tank farms would be considered premature. This is one of several areas where additional design study potentially could result in process improvements and potentially could result in a process with fewer issues regarding technical implementability. In these areas, the configuration used in the EIS represented a bounding condition, resulting in environmental impacts that also were bounding. Please refer to the response to Comment number 0023.01 regarding the use of smaller ISV units.
Comment Number 0023.12
Geosafe
Comment Implementability: 6th bullet, Inspection of the final waste form can be done by core drilling through the vitrified monolith after a period of cooling. Core drilling is routinely performed on commercial ISV projects to verify waste treatment for project closure. In the past, core drilling has been used to sample untreated tank wastes and should be easily adaptable to sampling a vitrified waste form which is easier to handle. Secondary wastes generated from the drilling can be recycled to future melts. If a core sample fails to meet waste acceptance testing, the area from which it was taken can be retreated by ISV.
Response Methods exist for the sampling of the in situ vitrified product. Many cores would likely be necessary for each tank and the cuttings from the core would require special handling and disposal. While the secondary wastes generated can be returned to the untreated tanks, other problems may be encountered during the development and operating phases of the core drilling system. The core drilling of vitrified HLW is an area that would require additional research and development to investigate further and determine its workability. If core drilling becomes an accepted technique for determining the acceptability of the waste form, the design of the confinement facility would include provision for equipment to accomplish the core drilling. Inspection and potential pretreatment of the final waste form are implementability problems that remain to be solved.
Comment Number 0023.13
Geosafe
Comment Implementability: 7th bullet, Use of the proposed smaller tank confinement facilities will be significantly reduce decontamination and decommissioning problems.
Response The large tank farm confinement facility may be difficult to decontaminate and decommission and these difficulties should be fewer for a smaller facility. Further study could result in an improved process. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0023.14
Geosafe
Comment B-53, 3rd par., last sent., A reference should be provided for the current research which is addressing depth-enhancement techniques.
Response A reference has been added to the last sentence of the referenced paragraph in Volume Two, Appendix B.
Comment Number 0023.15
Geosafe
Comment B-53, 4th par., Elimination of interstitial spaces between soil particles is not the only mechanism for volume reduction. During ISV treatment a significant volume of tank wastes will be vaporized due to the decomposition of nitrates, nitrites, carbonates and sulfates. This will result in a volume reduction that is expected to exceed 50 percent by volume. In addition, the ISV process will not produce significant quantities of Nox that require special off-gas treatment. The high operating temperature of the ISV melt and its reducing environment will decompose nitrate and nitrite into N2 and O2 gas.
Response Elimination of interstitial spaces between soil particles is not the only mechanism for volume reduction. A reduction in volume due to decomposition of the tank wastes will occur. However, at this time, no ISV facilities have been designed for use at the Hanford Site. Until design and testing have been completed, to consider that the ISV process will not produce significant quantities of nitrogen oxides requiring special off-gas treatment is premature. ISV most closely resembles a batch process, where the nature of the reacting materials and the reaction products change as a function of time. Temperature also changes with time during ISV, starting with the cool tank wastes and glass formers and ending with molten glass at a very high temperature. Therefore, while extremely high temperatures will enhance the dissociation of nitrate and nitrate, nitrogen oxides will be produced until those temperatures are reached, and the off-gas treatment system must be able to treat all of the vapors evolved. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0023.16
Geosafe
Comment B-56, Figure B3.4.3., The NO2 burner is configured as a lime spray dryer.
Response The essential function of the nitrogen oxide burner is correctly depicted on the flow diagram in Volume Two, Appendix B. The streams entering and leaving the unit are shown correctly. Because the essential function of the unit has been depicted, no changes to the EIS have been made.
Comment Number 0023.17
Geosafe
Comment B-57, 1st par., Treating the area between the tanks unfairly increases the cost of the ISV alternative and should not be included unless other alternatives address this concern. Potentially, an ISV option could be included which addresses the treatment of contamination below and around the tanks.
Response The inclusion of extra material in the zone of vitrified material is unique to the ISV alternative. Treating the area between the tanks would occur as a consequence of the nature of the ISV process, and doing so would not unfairly increase the cost of the ISV alternative. Because of the in situ nature of the process, ISV must have a vitrified zone that extends beyond the tank dimensions to ensure that the tank and its contents have been vitrified. This zone would not exist for the ex situ alternatives, for which retrieval activities will be performed that would be bounded by the tank walls. Because of the technical uncertainty in determining the dimensions of the zone of vitrified material during the melting operation, the preparers of the engineering data package (WHC 1995f) made the assumption to extend the dimensions of the vitrified zone beyond the tank dimensions to include the extent of the tank farms. Using this assumption ensured that the preconceptual costs, energy consumptions, and glass former usages were reasonable. For use in the EIS, these conservative assumptions and resulting calculations form a bounding condition. The use of this bounding condition will result in environmental impacts that are likewise bounding. NEPA requires that bounding conditions be equally compared for the environmental impacts that potentially may result from all alternatives evaluated. Please refer to the response to Comment numbers 0023.01 and 0001.01 for other discussions of subsurface barriers.
Comment Number 0023.18
Geosafe
Comment B-63, last par., The ISV flow diagram (Figure B.3.4.3) does not show a water quench system, venturi scrubber, solids separator, chiller or mist eliminator, which are the standard ISV off-gas treatment system components.
Response Figure B.3.4.3 depicts the major features of the ISV process. At the point when further engineering design potentially would be done, an expanded set of process flow diagrams would be developed. Because the description of the process in Section 3.4.3 of Appendix B refers to the water quench, scrubber, solids separator, chiller, and mist eliminator, no changes to the EIS have been made. These treatment systems were included in the design for the process, but were considered too much detail for presentation in the EIS. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0023.19
Geosafe
Comment B-64, 3rd par., The degree to which organics and ferrocyanides present an explosive issue in the tanks is presently unknown and is currently being researched by DOE. At most an estimated 38 tanks potentially contain high enough concentrations of these contaminants to be of concern (PNL 10773).
Response The degree to which organics and ferrocyanides present an explosive issue currently is under investigation. There may be answers to the situation that are inherent with ISV, which is that extensive mixing of the contents of different tanks to mitigate potential uncontrolled reactions is not included in the process. At present, the testing of the heating of tank contents has been limited, and it may be premature to state that the problem mainly is limited to 38 tanks of organics or ferrocyanide material. Until further investigations have been completed, the statement in the EIS that safely treating reactive materials requires further analysis is correct. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.20
Geosafe
Comment 1st bullet, Geosafe agrees that the proposed ISV alternative is more conceptual in design than the ex situ vitrification alternative but has made the following recommendations to significantly decrease the degree of uncertainty associated with cost, schedule and resource requirements.
- Use smaller ISV equipment and multiple melts to treat tanks
- Use a smaller moveable tank containment building
- Reduce tank effective height to lower treatment depth and volume.
Response Additional areas for further research and investigation associated with ISV are possible. Using smaller ISV equipment and multiple melts, smaller, moveable confinement facility, and tank overburden to fill voids and lowering the tank dome into the tank are areas where further investigation may be valuable. The configuration selected for inclusion into the EIS represented a bounding condition, which would result in environmental impacts that also were bounding. These bounding impacts were presented to the decision makers. Please refer to the response to Comment numbers 0023.01, 0023.03, and 0023.11. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.21
Geosafe
Comment 2nd bullet, The degree of uncertainty for the ISV alternative can be reduced by using smaller equipment which is considered highly feasible given the current understanding of the technology.
Response Alternative configurations for the tank farm confinement facility for ISV are possible. The configuration proposed in Comment number 0023.01 includes a confinement facility that is 120 feet on a side. The area under discussion in the EIS is the higher degree of uncertainty for the exact equipment required for ISV versus ex situ alternatives. The 120-foot confinement facility is still several times larger than that used in current development work for ISV. To state that this configuration is highly feasible could be considered premature. Comment number 0023.01 discusses concerns related to the movement of a smaller confinement facility and its off-gas facilities. Because these concerns remain as issues and problems to be resolved, the EIS is correct in referring to the degree of uncertainty involved. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.22
Geosafe
Comment 3rd bullet, Implementing the recommendation to use a smaller containment facility will eliminate all these concerns except for the need to characterize the tanks. Tank waste characterization is a generic concern that is applicable to all treatment alternatives and is not limited to the ISV alternative.
Response Vitrifying one tank at a time will not require the characterization of an entire tank farm if a smaller, mobile confinement facility were to be used. ISV by its very nature does not retrieve the tank contents. Consequently, there is no opportunity to advantageously blend the tank contents, as would be the case if several tanks were retrieved at the same time as in the ex situ alternatives. To consider the smaller confinement facility will eliminate all these concerns except the need to characterize the tanks would be premature. Still, ISV is basically a batch process (or potentially a semi-continuous process). One characteristic of a batch process is the changing nature of the reactants and products as a function of time. The system must be able to process the expected products, and this requirement does not change with the size of the confinement facility. Further detailed study would result in an improved process; however, no changes to the information presented in the EIS are required. Please refer to the response to Comment number 0023.01.
Comment Number 0023.23
Geosafe
Comment 4th bullet, An estimated 20 tanks potentially contain organics at concentrations that may represent an explosive concern. Research on treating these problem tanks could be conducted while other non-effected tanks are being processed.
Response The degree to which organics present an explosive issue is currently under investigation. Extensive mixing of waste from different tanks to mitigate potential uncontrolled reactions is not included in the process. At present, the testing of the heating of tank contents has been very limited, and it may be premature to state that the problem mainly is limited to 20 tanks containing organics. Concurrent research and testing on treating these problem tanks could be conducted while other non-affected tanks are being processed. This research must be successfully completed before this method could be used to remediate tanks that may present an explosive concern. Until further investigations have been completed, the statement in the EIS that the safety of drying some waste types is uncertain remains correct, and as a result, no changes to the EIS have been made. The potential for fires and explosions in the tanks is addressed in Volume One, Section 5.12 and Volume Four, Appendix E. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0023.24
Geosafe
Comment 5th bullet, Geosafe recommends using smaller ISV units which should significantly reduce the uncertainties associated with off-gas treatment. The high operating temperature of ISV has been demonstrated to effectively decompose nitrogen compounds without the formation of NOxS and greatly reduces off-gas treatment concerns. The calcium sulfate waste stream should not be recycled because the sulfates will be reintroduced back into the off-gas.
Response There is the potential for the production of a secondary waste stream of potentially contaminated calcium sulfate from ISV. This waste stream should not be recycled because the sulfates may not be incorporated into the melt and may be reintroduced into the off-gas. However, at this time, no ISV facilities have been designed for use at the Hanford Site and none have been designed of the size needed to vitrify the tank waste anywhere in the world. Numerous ISV facilities have had problems with off-gas treatment and fires. Until development work has been completed, to state that the high operating temperature of the ISV process would effectively decompose nitrogen compounds without the formation of nitrogen oxides and greatly reduce off-gas treatment concerns would be considered premature. ISV most closely resembles a batch process, where the nature of the reacting materials and the reaction products change as a function of time. Temperature changes also occur with time during ISV, starting with the cool tank wastes and glass formers and ending with molten glass at a very high temperature. So while extremely high temperatures will enhance the dissociation of nitrate and nitrate, nitrogen oxides will be produced until those temperatures are reached. The off-gas treatment system must be able to treat all of the vapors that are evolved. Because these uncertainties will remain regardless of the size of the ISV units, no changes to the EIS have been made. Please also refer to the response to Comment number 0023.01 for a discussion of smaller ISV units.
Comment Number 0023.25
Geosafe
Comment 6th bullet, The 60 ft depth limitation is overly conservative and can be reduced by removing overburden from the tanks and lowering the effective height of the tank as discussed in comment A 3. [Comment number 0023.03]
Response Please refer to the response to Comment numbers 0023.03 and 0023.08.
Comment Number 0023.26
Geosafe
Comment 7th bullet, The use of the proposed smaller tank containment facility (120 ft by 120 ft) will eliminate structural design and costing uncertainties.
Response The EIS addresses only the uncertainty that remains in the design of the large (i.e., 500- by 600-foot) confinement facility. At this time, no ISV facilities have been designed for use at the Hanford Site. Until additional technology development has been completed, it would be considered premature to state that the use of the smaller confinement facility will eliminate structural design and costing uncertainties. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0023.27
Geosafe
Comment 8th bullet, Verification of the ISV monolith can be performed by core sampling which is a well demonstrated technology. Allowances will have to be made for coring of a radioactive glass monolith but it is feasible given an enclosed system and sufficient concern for safety issues. Secondary wastes generated from coring can be directly recycled to future melts thus eliminating waste disposal concerns.
Response DOE and Ecology agree with the comment that methods exist for the sampling of the in situ vitrified product. The core drilling of vitrified HLW is an area that would require additional research and development to determine its workability. If core drilling becomes an accepted technique for determining the acceptability of the waste form, the design of the confinement facility would include provision for equipment to accomplish the core drilling. While the comment is correct in stating that the secondary wastes generated can be returned to the untreated tanks, it is possible that other problems will be encountered during the development and operating phases of the core drilling system. The text referred to in the comment discusses the fact that inspection and potential pretreatment of the final waste form are problems of implementability that remain to be solved. Despite the fact that methods are available for sampling the vitrified waste form, the technical problems associated with this issue remain to be solved. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0023.28
Geosafe
Comment 9th bullet, The use of the smaller ISV system will eliminate concerns regarding movement of the off-gas system.
Response The EIS addresses the uncertainty that remains in the design of the off-gas treatment facilities. Until additional technology development has been completed, to state that the use of the smaller ISV system will eliminate concerns regarding movement of the off-gas system would be considered premature. Please refer to the response to Comment number 0023.24. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0023.29
Geosafe
Comment 10th bullet, The use of a smaller ISV system will greatly reduce the time needed to retreat a specific area in a tank if it fails to meet the treatment criteria.
Response The EIS addresses the uncertainty that would occur in the operations schedule if an area as large as a complete tank has to be retreated as a result of unsuccessful ISV. Until additional technology development has been completed, to state that the use of the smaller ISV system will greatly reduce the time needed to retreat a specific area in a tank if it fails to meet the treatment criteria would be considered premature. The time required to retreat a tank is not a function of the size of the confinement facility. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0023.30
Geosafe
Comment 11th bullet, The concern of mixing fluxants into deep zones of the tank can be reduced by implementing the treatment depth reduction techniques recommended in comment A 3 (See Comment number 0023.03). Geosafe has already demonstrated the mixing of fluxants at full scale with excellent results.
Response Thermal mixing is well known in conventional electric furnaces and should work well for ISV. Because thermal mixing in electric furnaces is a natural phenomena, its presence does not constitute an endorsement of the application of a particular technique or equipment. The statement in the EIS refers to further development work that may be required. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0072.97
CTUIR
Comment P 3-48: Sect. 3.4.5: In Situ Vitrification Alternative: this section does not adequately discuss how all of the vitrified ground and waste is to be verified for vitrification, and how this verification process will include leakage, migration, below the area of impact. This process has not been adequately explained for the purposes of this EIS.
Response Further technology development regarding the implementation of the ISV alternative may be required. Volume One, Section 3.4.5.7 and Volume Two, Section B.3.4.4 discuss the issues applicable to the implementability of this alternative including inspection of the final waste form to confirm that all of the waste is stabilized and the waste form is acceptable. One possible method of verification would be drilling through the vitrified mass to ensure that vitrification was complete, but these drill holes would not necessarily confirm any potential migration that may exist below the vitrified mass. Migration in the vicinity of the vitrified mass could be verified by drilling additional boreholes near each tank farm when ISV had been completed. Please refer to a related discussion on verification in the response to Comment number 0023.12.
Comment Number 0072.98
CTUIR
Comment P 3-54: Sect. 3.4.5.7: Implementability: How is excess melting going to be addressed, Please describe the fractionation process of the melt? What are the anticipated cooling times, and how have these times been calculated, are they based on the fractionation process? If the times are not based on the fractionation process what exactly are they based on? What is the verification process for the vitrification, the fractionation, the cooling, the immobilization?
Response Many crucial questions must be answered before the ISV alternative can be implemented. Volume One, Section 3.4.5.7 contains discussions of the substantial research, development, and demonstration activities that would be required. Inspection of the final waste form to confirm stabilization of the waste is one area requiring more information. The implementability of this alternative is not known at this time. To account for these uncertainties, additional technology development time and costs were incorporated into the analysis of these alternatives. The information requested is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives. Implementability was one factor analyzed for the technologies included in the alternatives analysis.
Comment Number 0072.99
CTUIR
Comment P 3-54: The technical uncertainties associated with this process are just as great for the MUSTs because the contents of the MUSTs have been inadequately described within this EIS.
Response As is explained in Volume Two, Section A.2.3, definitive characterization data do not currently exist for the inactive MUSTs. Because they received the same waste products that are contained in the tanks, the concentration of constituents is expected to be approximately the same. Volume Two Table A.2.3.1 lists the current estimated waste volumes for the MUSTs and briefly comments on the use of each tank. ISV of the small MUSTs may present less of a technical challenge because the size of the melt more closely conforms with previously demonstrated vitrification processes. Please refer to the response to Comment numbers 0012.14, 0072.169, 0029.01, and 0060.02 for a discussion related to MUST contents.
Comment Number 0072.185
CTUIR
Comment P B-53: Sect. B.3.4: Same comment as above. [Please refer to the response to Comment number 0072.195.]
Response Please refer to the response to Comment number 0072.195.
Comment Number 0102.01
Eister, Warren
Comment The Draft Environmental Impact Statement for the Hanford Site Tank Waste Remediation System - Summary (DOE/EIS-0189D) seems to suggest the choice system would be In Situ Vitrification (Figure S.6.2 along with Tables S.7.2 and S.7.3).
It is very reassuring that decisions made more than twenty years ago continue to be re-evaluated. Unfortunately those decisions have been extremely difficult to implement.
However, in spite of the continuing unresolved difficulties, this EIS Summary reports that DOE has already adopted the Phased Implementation System which is dependent on potential geologic repositories and involves extensive process and transportation activities.
Is the In Situ Vitrification technology being developed with the same level of effort as the Phased Implementation?
Would this In Situ Vitrification System be applicable to the:
- Savannah River site?
- Spent fuel from the nuclear power reactor program?
- TRU waste?
- Low-level wastes?
Are there other technologies being sought that would allow the spent fuel from the nuclear power program to remain in the vicinities of the current power plant sites?
Response The preferred alternative for tank waste identified in the Draft EIS and Final EIS is Phased Implementation not ISV. DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0072.05 regarding NEPA requirements for the analysis of alternatives and Comment numbers 0055.03 and 0005.07 for a discussion of the role of the EIS in the decision making process. Repository costs and uncertainties analysis results for each alternative have been included in Volume Two, Appendix B and Volume Five, Appendix K, respectively, in the Final EIS.
The TWRS EIS focused on tank waste remediation alternatives. Technology evaluation was limited to those technologies currently available or for which sufficient development information was available. DOE is not currently developing any remedial technologies. Potentially-applicable ISV technologies are under commercial development. Technologies development and/or evaluation would be conducted during the detailed design and demonstration phases of the preferred alternative. Issues related to ISV technology applicability at other DOE sites, for commercial nuclear power programs, or to other radioactive waste types beyond those required for the alternatives evaluation were not considered because they are beyond the scope of the EIS.
Please refer to the response to Comment number 0037.03 for more information concerning interim onsite storage of HLW and compliance issues related to the Nuclear Waste Policy Act.
L.3.4.7 Ex Situ Intermediate Separations Alternative
Comment Number 0005.45
Swanson, John L.
Comment Page 3-59 contains a sentence regarding the Tri-Party Agreement requiring the retrieval function to remove waste to an extent based on volume or as much as is technically possible, WHICHEVER IS LESS. I believe you mean to say remove the MOST, leaving the LEAST - but that is not what the sentence says.
Response The cited text has been revised as follows, "The Tri-Party Agreement (i.e., Milestone M- 45-00) requires that the removal function remove waste to the extent that SST waste residuals meet specific volume requirements based on tank type, or that as much waste is removed as technically possible, whichever action results in the least residual waste volume" (Ecology et al. 1994).
Comment Number 0005.46
Swanson, John L.
Comment Page 3-67 defines an off-gas stream from a vitrifier as a "gaseous air stream containing combustion gases." This is true for a combustion-fired melter, but how about a joule-heated melter?
Response Volume One, Section 3.4.6.2 states that fuel-fixed melters have been included for analysis in the EIS. It is further stated that future evolution may result in another melter configuration. With either the joule-heated or fuel-fixed melter, a large quantity of off-gas with contaminants such as SOx and NOx must be treated. The total volume of gas with a fuel-fixed melter would be greater with the use of kerosene and oxygen for the fuel, but the total amounts of SOx and NOx would not differ greatly. The fuel-fired melters considered provide a more conservative analysis in the design and treatment of the off-gas for discharge to the environment. Please refer to the response to Comment numbers 0005.42, 0072.91, 0023.01, 0023.15, 0023.24, 0023.28, and 0072.101 for discussions of issues related to off-gassing. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0005.47
Swanson, John L.
Comment Page 3-67, last paragraph of 3.4.6.2 ("Driving heavy equipment--") seems to be out of place. This same paragraph appears in similar locations for other alternatives too; the same comment applies in those sections as well.
Response Because this is an issue common to many of the alternatives, a better location for a one-time entry to the section has been determined. This discussion on mitigating a potential accident has been moved to a discussion of elements common to the alternatives in Volume One, Section 3.4 and Volume Two, Appendix B. This statement of concern appears on several pages within Volume One, Section 3.0 and Volume Two, Appendix B.
Comment Number 0027.10
Roecker, John H.
Comment Technical Uncertainty
To state that the technical uncertainty of the intermediate and extensive separations alternatives are both moderate is erroneous and misleading to those who are not familiar with the technologies involved. Intermediate separations requires three technologies, all of which have been demonstrated, while extensive separations requires at least ten, most of which have not been demonstrated. This misleading information needs to be corrected.
Response The degree of technical uncertainty provided in the Summary assigns a high, medium, or low ranking for the entire remediation alternative. DOE and Ecology acknowledge that there is a higher level of technical uncertainty with extensive separations than with intermediate separations. However, overall, both alternatives fall into the moderate category. Additional discussion regarding technical uncertainty is provided in Volume One, Section 3.4 and Volume Two, Appendix B and the response to Comment number 0005.03.
Comment Number 0036.16
HEAL
Comment The EIS states that intermediate separations would reduce the waste going to the repository. It adds, "The other goal of separations would be to limit the generation of additional waste during the separations processes" (p. 3-65). What does this passage mean?
Response Limiting the generation of additional waste during the separations process means that design and implementation of the HLW/LAW separations processes would consider the volume of LAW along with the volume of HLW that would be generated. One means of accomplishing this would be to limit the introduction of sodium hydroxide during the enhanced sludge washing process, which would limit the overall amount of sodium in the resulting LAW form.
Comment Number 0057.03
Garfield, John
Comment With respect to primarily the cost, the EIS references the document from '94 Boomer et al. That document compares two alternatives that are nearly identical to intermediate separations, then extensive separations is called clean and enhanced sludge washing in that document. It shows a cost penalty for using clean of $7 billion dollars compared to enhanced sludge washing. Those same alternatives show a $3 billion dollar advantage in the Environmental Impact Statement Draft. That is a $10 billion dollar swing. That deserves investigation. The repository comments convey part of that. The rest relates back to my earlier remarks about the headquarters influence.
Response The cost estimates were reviewed and revised for the Final EIS. The waste loading and blending assumptions that impact the volume of HLW have been revised to reflect the recommendations of an independent technical review team. The size of the HLW canisters has been revised to reflect recent DOE-RW findings that a longer canister for Hanford HLW is technically feasible. These changes, as well as the resulting cost impacts, were revised and are included in Volume One, Section 3.4 and Volume Two, Appendix B. For more information on issues relating to HLW canisters and repository costs, please refer to the response to Comment numbers 0081.02 and 0008.01.
Comment Number 0057.05
Garfield, John
Comment The next comment I would like to make is that the chosen case built around the extensive sep..or excuse me the intermediate separations data of without repository cost shows it $30 billion dollars. That estimate assumes a stand-alone high-level waste treatment facility which would cost in the vicinity of $1 to $2 billion dollars and add another equivalent amount in operating costs. There is some recent data developed using a single facility but which can be - its mission can be modified both in terms of scope and capacity to accommodate both low-level treatment at a smaller scale through the 200-ton per day capacity 1 to 200-ton per day capacity for the full scale low-level treatment and then can be converted for high-level treatment. That is the only sane approach to this problem. Building three demonstration plants and two full-scale plants is a lunacy that will cost us $30 billion dollars. A simpler facility approach that I just described would cut those costs in approximately half and, in fact, the studies release from the DOE reading room suggests that cost is about $16 to $18 billion dollars. That should be the basis for the EIS intermediate separations case.
Response DOE and Ecology recognize that there are opportunities for optimizing the costs estimated for each of the alternatives addressed in the EIS. As discussed in the EIS, the alternatives were developed to bound the impacts associated with remediating the tank waste. Process and facility design optimization would not be precluded with the selection of any of the alternatives presented in the EIS. For more information on the topic, please refer to response to the Comment number 0072.05.
The Draft EIS addressed the full range of reasonable alternatives. The alternative identified is bounded by the alternatives addressed in the Draft EIS, and DOE and Ecology believe that including the requested alternative would not provide valuable additional information to the public or decision makers.
Comment Number 0072.100
CTUIR
Comment P 3-56: Sect. 3.4.6: Ex Situ Intermediate Separations Alternative: The separation of the Waste streams into HLW and low activity waste seems confusing. Low activity waste is waste that is a subset of HLW? What are the legal requirements for classifying waste as LAW? Have the Affected Tribes been consulted regarding this?
Response LAW is the waste remaining after removal of as much of the radioactivity from HLW as practicable. The definition of LAW is provided in Volume One, Section 1.0. DOE and the NRC have had formal discussions on tank waste classification and LAW regulation; however, DOE would need to formally solicit an opinion from the NRC regarding the classification of LAW. Volume One, Section 6.2 provides additional information on tank waste classification and the results of the discussions between DOE and the NRC. Criteria must be formalized as to the extent to which the HLW in the tanks must be separated for the residual waste to meet requirements for incidental waste, LAW, as well as the DOE and Washington State definitions of LLW and hazardous waste requirements of the State of Washington. Design specifications for HLW and LAW treatment will require that waste forms meet applicable criteria for disposal in the potential geologic repository or as LAW for onsite disposal, respectively.
DOE plans for onsite near-surface disposal of LAW date back to the 1988 Hanford Defense Waste EIS ROD (DOE 1987). That NEPA process, as well as subsequent consideration of onsite disposal of LAW during the 1989 and 1994 Tri-Party Agreement negotiations, and the Tank Waste Task Force process (HWTF 1993), provided interested parties as well as Tribal Nations with the opportunity to comment on the planned onsite disposal of LAW. The TWRS EIS and the public involvement process for Tri-Party Agreement amendments associated with the privatization initiative provided additional opportunities for Tribal Nation input into the decision-making process related to this issue. The Tribal Nation consultation process is discussed in the response to Comment number 0072.149.
Comment Number 0072.101
CTUIR
Comment P 3-56: PP 3: The LAW is to be quenched into a 'cullet', this indicates that there is going to be an additional secondary waste stream generated from the reaction of molten silicates, nitrates, hydroxides, oxides, metals and water. What will be done with this waste stream. Will this waste stream be classified as High level liquid waste? The off gasses that are produced are supposedly going to be treated in some fashion, please explain how this is to be accomplished including feed rates, volume of off gas produced, filter failure rates, retrievable useable material, and indicate where this process has been proven including references.
Response The technical data that served as a basis for developing the Ex Situ Intermediate Separations alternative are referenced in the EIS (WHC 1995 n, j, i and Jacobs 1996) and are available for review as part of the TWRS EIS Administrative Record and in DOE Reading Rooms and Information Repositories.
Quench water is a secondary waste stream that would contain contaminants as a result of quenching the molten LAW glass in order to produce the cullet. This quench water would be recycled extensively either as quench water or back to the front of the process to be added to the LAW stream for vitrification. This liquid waste stream would not be expected to be classified as HLW.
The amount of secondary waste generated during operations of the Ex Situ Intermediate Separations alternative would consist primarily of off-gas and liquid effluent emissions identified in Volume Two, Table B.11.05. The off-gas and liquid effluents would be treated to remove contaminants to the maximum extent possible before being discharged. The HLW vitrification process would result in gas flows out the stack of approximately 3,500,000 metric tons (mt) over the life of the facility. The radiological and chemical concentrations to be released from the stack were calculated and used in the routine risk assessment. The liquid effluent from the HLW vitrification facility was estimated to be 1,200,000 mt (before recycle) based on material balance calculations. Volume Two, Section B.3 describes the liquid effluent processing of secondary radioactive waste streams for all alternatives. In addition to these emissions, secondary waste consisting of contaminated filters and spent ion exchange resins would be generated during treatment operations.
The generation of off-gas during the vitrification process would result from the evaporation of water, thermal destruction of chemical compounds, evolution of volatile compounds, and the entrainment of particulates in the off-gas stream. A detailed description of the off-gas system is provided in Volume Two, Section B.3. Control technologies that would be employed to reduce emissions include: quench towers, venturi scrubbers, chillers, demisters, high-efficiency particulate air (HEPA) filtration, sulfur recovery, and NOx destruction. The off-gas emissions from the vitrification plants are included in the risk assessment. The off-gas treatment processes that would be used are the same technologies that have been successfully used in commercial and defense nuclear industry as well as the chemical processing industry.
Comment Number 0072.102
CTUIR
Comment P 3-56: PP 5: What is the amount of secondary waste generated from this process? Will there be material that can be recycled? Will the secondary waste stream have to be reprocessed for additional radionuclide removal?
Response Secondary waste streams will include treatment for removal of radionuclide and chemical contaminants to the maximum extent possible before discharge. Off-gas streams will include various technologies to treat chemical and radionuclide emissions during operations. Liquid effluents would be collected and sent to the onsite Liquid Effluent Treatment Facility for treatment. Please refer to the response to Comment numbers 0072.101 and 0072.109.
Comment Number 0072.103
CTUIR
Comment P 3-59: top of the page: Where does the strontium end up with this process, in the liquid or the solids phase?
Response The strontium will be mainly in the HLW solid phase during the enhanced sludge washing process used for the Ex Situ Intermediate Separations alternative. A small amount, approximately 6 percent of the strontium and decay product activity, would end up in the LAW.
Comment Number 0072.104
CTUIR
Comment P 3-59: Sect. 3.4.6.2: What was the process for determining the average feed stream, and what are the expected ranges for this feed stock in relation to the glass content and characteristics? What will be the process for determining what to do, in the case of 'out of operating' mode? Will this process entail stocking waste from the other tanks in order to blend the feed mixture? If this is the case, has this information been costed out to show how many and how large these out of ground tanks will be?
Response The technical data that served as a basis for developing the Ex Situ Intermediate Separations alternative is referenced in the EIS (WHC 1995i, j, n and Jacobs 1996) and available for review as part of the TWRS EIS Administrative Record and in DOE Reading Rooms and Information Repositories. Additional details regarding the facility layout, including the melter feed system and associated tankage, are provided in Volume Two, Section B.3.
The average feedstream was developed by taking the average overall chemical and radiological inventory including dilution water that would be added during waste retrieval operations. The material balance calculations assumed that the tank waste would be adjusted to 5 molar soluble sodium during retrieval and transfer. It is expected that there will be some variation in the feed stream composition during the waste treatment process. Compositional limits for waste feed would be established during the detail design phase and would take into consideration the affect of variability in the waste feed on the vitrification process, the acceptability of the glass, as well as safety concerns. Blending of the waste during retrieval and the ability to sample and blend waste in the lag storage area would minimize the variance in the waste feed. The lag storage and melter feed system would provide further opportunity for waste feed conditioning. The engineering data developed include the necessary equipment and processes to blend the waste feed and no additional out of ground tanks are required.
Comment Number 0072.105
CTUIR
Comment P 3-61: Sect. 3.4.6.2:. PP 3: S 1: The figure 3.4.9, depicts a sluicing module at the end of the end effector. If sluicing has to be discontinued because of tank leakage, please describe this sluicing module, and why it is depicted.
Response The sluicing module referred to in the comment would minimize the amount of water introduced to the tank during retrieval as compared to articulated arm method of sluicing. The articulated arm would be deployed when there was concern about the integrity of the tank or a potential for tank leakage. Other types of engineered modules, such as mechanical end effectors, could be used for selected retrieval operations with the articulated arm. Please refer to the response to Comment number 0029.01 for additional information concerning sluicing.
Comment Number 0072.106
CTUIR
Comment P 3-66: PP 1: S 7: Within this sentence there is a reference that silica is sand. Silica is not sand. Sand can consist of many things, including silicon dioxide.
Response Sand is commonly defined as loose, fine particles of disintegrated rock. The sentence that is referred to in the comment is describing glass formers, some of which may be either silica or sand (depending on the desired composition of the glass).
Comment Number 0072.107
CTUIR
Comment P 3-66 PP 2: S 1: Quenching molten glass will not necessarily make gravel sized pieces, in addition the pieces formed will have a high percentage of fractures, and necessarily a very large surface area, please explain how these cullets are better at resisting aging, and weathering, and where are the references for this process?
Response The treatment facilities that would produce glass cullet as a waste form would have equipment in place to produce uniform-sized cullet. Glass fines would be screened and recycled back to the melter and oversized cullet would pass through a roll crusher to produce cullet of acceptable size for handling. Glass cullet would have a larger surface area-to-volume ratio as compared to monolithic pours of glass (e.g., glass logs) in canisters. This discussion is included in Volume Two, Section B.3 of the EIS. Glass cullet would have higher leach rates than monolithic pours of glass due to the higher surface area-to-volume ratio. The acceptability of HLW glass cullet produced under the Ex Situ No Separations alternative is identified in Volume One, Sections 3.4 and 6.2 and Volume Two,
Appendix B. The increased leaching for cullet was taken into account when the impacts associated with the immobilized LAW were analyzed in the EIS in Volume One, Section 5.2 and Volume Four, Appendix F. Please refer to the response to Comment numbers 0035.04, 0012.11, and 0052.11 for a discussion of waste form and storage issues.
Comment Number 0072.108
CTUIR
Comment P 3-67: PP 2: What does partial recycle of off gas mean? Does this mean that there is going to be a substantial amount of off gas released to the environment? Has this been incorporated into the risk section? Have the impacts of this off gas been assessed as to their affects to Native Americans?
Response Each tank waste alternative that uses high-temperature processing (vitrification or calcination) would make extensive use of recycle streams to recycle back into the treatment process volatile radionuclide and chemical constituents captured in the off-gas system. These recycle streams would minimize the generation of secondary waste. It has been determined that a bleed stream would be required for each alternative to avoid a continuous buildup of certain volatile radionuclides and chemical constituents, namely technetium and mercury, in these recycle streams. Complete recycle of the more volatile constituents is not possible. The off-gas emissions estimates used for risk assessment were developed considering volatility and the ability of the off-gas treatment system to capture and recycle individual constituents.
Please refer to the response to Comment numbers 0072.207 and 0072.91 for discussions on assessment of Native American risk resulting from routine air emissions during remediation. The Tribal consultation process is discussed in Comment number 0072.149.
Comment Number 0072.109
CTUIR
Comment P 3-68: PP 4: Bottom of the Page: One 22 metric ton per day HLW does not seem like enough, especially since there is going to be down times for change outs, plugging, melt inconsistencies, spills, and other process related problems. Wouldnt it be more prudent to plan for additional melt capacity above and beyond the 20 mt as allowances for capacity needs? Additionally, what is the total amount of secondary waste generated with his process? How will this compare to the global vitrification process already in use in France, and the United Kingdom? What are the expected off gases, and what are the treatment process being proposed? Are these gasses being addressed in the risk portion of this document?
Response The 20 mt (22 ton) melter capacity for HLW vitrification under the Ex Situ Intermediate Separations alternative was calculated using a 60 percent overall operating efficiency along with a 13-year operating duration. The 60 percent overall operating efficiency takes into account down time due to process-related problems.
The amount of secondary waste generated during operations of the Ex Situ Intermediate Separations alternative would consist primarily of off-gas and liquid effluent emissions identified in Volume Two, Section B.11, Tables B.11.05 (radiological) and B.11.06 (nonradiological) The off-gas and liquid effluents would be treated to remove contaminants to the maximum extent possible before being discharged. The HLW vitrification process would result in gas flows out the stack of approximately 230,000 mt over the life of the facility. The radiological and chemical concentrations that would be released from the stack were calculated and used in the routine risk assessment. The liquid effluent from the HLW vitrification facility was estimated to be 72,000 mt based on material balance calculations. Volume Two, Section B.3 describes the liquid effluent processing of secondary radioactive waste streams for all of the alternatives. In addition to these emissions, secondary waste consisting of contaminated filters and spent ion exchange resins would be generated during treatment operations.
A discussion of foreign vitrification technologies can be found in Volume Two, Section B.9. A comparison of secondary waste generation at foreign vitrification facilities was not made; however, the generation of gaseous and liquid effluent streams would be expected to be the same for similar waste types and processing rates. Regulatory requirements for gaseous and liquid discharges would control the number and type of treatment technologies employed to reduce the risks to human health and environment. These requirements would be different in foreign countries. The Hanford Waste Vitrification Plant Foreign Alternatives Feasibility Study indicated that plants operating in foreign countries would require additional process equipment for treating melter off-gas and other effluents to meet United States environmental requirements.
The generation of off-gas during the vitrification process would result from the evaporation of water, thermal destruction of chemical compounds, evolution of volatile compounds, and entrainment of particulates in the off-gas stream. A detailed description of the off-gas system is provided in Volume Two, Section B.3. Control technologies that would be employed to reduce emissions include: quench towers, venturi scrubbers, chillers, demisters, HEPA filtration, sulfur removal, and NOx destruction. The off-gas emissions from the vitrification plants are included in the risk assessment.
Comment Number 0072.110
CTUIR
Comment P 3-70: Sect. 3.4.6.5: Post Remediation: this section has to be, either removed or changed to reflect the clean closure option. Additionally during closure, the tanks are not supposed to have residual equal to 1 percent but should be less than 1 percent. The MUSTs, pump pits, valve boxes, and diversion boxes, final disposition has not been firmly established within this EIS. If these ancillary equipment are to be dealt with under clean closure conditions then they need further definement in terms of their contents, their extent of contamination and their disposal.
Response Closure is not included in the scope of this EIS because there is insufficient information concerning the amount of contamination to be remediated. However, Volume One, Section 3.3 addresses how tank waste remediation and closure are interrelated because some of the decisions made regarding how to treat and dispose of tank waste may impact future decisions on closure. There are three representative types of closure addressed. These include clean closure, modified closure, and closure as a landfill. The referenced paragraphs are included in Volume One, Section 3.4 to illustrate the type of activities following remediation rather than specifying the type of closure. The value of, "... a residual equal to no more than 1 percent ...," was used to bound the impacts from the tank residuals. Closure of ancillary equipment also is not included in the scope of this EIS. Issues related to tank farm closure are discussed in Comment number 0072.08. Please refer to the response to Comment numbers 0012.14, 0072.50, and 0101.06 for MUST characterization and issues related to closure. Because the analysis requested in the comment is not within the scope of the EIS, no modification to the document is warranted.
Comment Number 0072.111
CTUIR
Comment P3-72: Sect. 3.4.6.7: Implementability: bullets 3,6: If Low Activity Waste has not been thoroughly described, and permitted, how does this EIS propose to deal with the enormous amount of uncertainty involved throughout all the process stages? This is not the easiest way of dealing with the waste. Because the Nuclear Regulatory Commission has not finished with the negotiations, why in Section 3.4.6.5., does it mention that this LAW be buried under the Hanford Barrier? Burying this waste in a cullet form under the Hanford Barrier is the same as saying DOE made the waste, used their contractors to partially treat it, buried it and then walked away leaving the Affected Tribes to deal with the consequences. This is not acceptable. The ex situ intermediate separations alternative therefore is not acceptable. Changes made to this alternative, such as determining the LAW disposal criteria will necessarily need CTUIR input.
Response DOE and Ecology acknowledge the concerns regarding uncertainty expressed in the comment. To develop engineering data required to perform impact analyses for each of the alternatives, assumptions were made regarding the technologies that have been configured to create a remediation alternative, including process stages and waste form. Also, for the purposes of comparing alternatives, a single and consistent method of closure was assumed for all of the alternatives. Closure as a landfill covered by a Hanford Barrier was chosen as the representative closure method for analysis. This does not mean that closure as a landfill is proposed or necessarily would be selected in the future. Please refer to the response to Comment number 0072.08 for more information regarding closure. Although these assumptions were based on best information available, applications of a similar technology, or engineering judgement, there are uncertainties associated with each of the alternatives. Major assumptions and uncertainties are addressed in Volume One, Section 3.4. Additional uncertainty analyses were completed for the Final EIS, and are included in Volume Five, Appendix K.
DOE and Ecology acknowledge the concerns regarding LAW expressed in the comment. LAW is the waste remaining after removal of as much of the radioactivity from HLW as practicable. DOE and the NRC had formal discussions on the way tank waste is classified and how the LAW portion might be regulated in the context of the previously planned grouted LAW. 58 FR 12344, March 1993, states that disposal of residual waste from the DST waste would only be a small fraction of the reprocessing wastes originally generated at the Site; residual waste material should be classified as incidental waste, since they are wastes incidental to the process of recovering HLW; the residual activity of these incidental wastes would be below the concentration limits for Class C wastes under the criteria of 10 CFR part 61; and the disposal of the residual would not be subject to NRC licensing. Section 6.2 provides additional information on tank waste classification, and the results of the discussions between DOE and the NRC. However, criteria must be formalized as to the extent to which the HLW in the tanks must be separated for the residual waste to meet requirements for incidental waste (LAW) as well as the DOE definition of LLW and State of Washington definition of hazardous waste. Design specifications for HLW and LAW treatment will require that waste forms meet applicable criteria for disposal in the potential geologic repository, or as LAW for onsite disposal.
LAW disposal in onsite near-surface vaults was incorporated into the Ex Situ Intermediate Separations alternative, as well as all other ex situ alternatives except Ex Situ No Separations, because that is the current planning basis for the TWRS program as represented in the Tri-Party Agreement. The planning basis assumes that LAW will be vitrified and disposed of onsite in near-surface vaults. Further, it assumes that LAW will meet NRC criteria for incidental waste based on the extent of separations of LAW from HLW during the pretreatment process.
The disposal criteria for incidental waste is determined by the NRC and is well-established criteria. For the TWRS program, the issue at hand is whether the LAW waste stream, when vitrified, will be classified as incidental waste on the waste specifications. In the requests for proposals for Phase 1 of the privatization initiative, DOE defined the waste specifications for LAW that contractors would be required to meet. The waste specification was prepared to produce a waste that would be classified as incidental waste. DOE will consult with NRC to ensure that the waste meets applicable standards for incidental waste.
DOE and Ecology acknowledge the concerns regarding burial of vitrified cullet expressed in the comment. Cullet has a high surface area-to-volume ratio which results in lower long-term performance, including susceptibility to leaching. However, assuming vitrified LAW in cullet form for all of the ex situ alternatives provides a conservative analysis of the long-term impacts resulting from onsite retrievable disposal of LAW in near-surface vaults. Risks associated with retrievable disposal of LAW in vaults have been analyzed and these are presented in Appendix D.5. In addition, a Native American Scenario has been added to the Final EIS in Volume One, Section 5.11 and Appendix D. DOE and Ecology acknowledge the recommendation regarding consultation with Tribal Nations in determining LAW disposal criteria. Please refer to the response to Comment numbers 0035.04, 0012.11, and 0052.11 for related information.
Comment Number 0072.186
CTUIR
Comment P B-66: Sect. B.3.5: LLW is not the same as LAW, yet it appears that these terms are being used interchangeably. Because of this short time period for the review of this particular EIS. Please check for additional similar situations and correct them as is appropriate.
Response LLW is not the same as LAW. LAW is the waste remaining after removing as much radioactivity as practicable from HLW. The definition of LAW is provided in Volume One, Section 1.0, and addressed in more detail in Section 6.2. The term LAW used in Volume Two, Appendix B on page B-66 describes the waste stream after removal of the HLW components. The term is used correctly so no change to the EIS is warranted. Please refer to the response to Comment numbers 0005.25, 0072.118, 0072.117, and 0072.100 for issues related to regulatory definitions of Hanford tank wastes.
Comment Number 0072.187
CTUIR
Comment P B-95: PP 2: How will the insoluble sludges be suspended in the solution of soluble waste? How much volume of additional chemicals must be added? Will this be done in tank or in a receiving tank?
Response Following retrieval, where the sludges will be mobilized and suspended, the insoluble sludge particles will remain in suspension in the aqueous solution as long as the sludge particles have sufficient velocity. This velocity can be produced by such mechanical devices as pumps and mixers. The additional volume of chemicals to be added and the location of the addition point will be determined during the testing phase for this alternative.
Comment Number 0072.188
CTUIR
Comment P B-95: PP3: Why is it assumed that Cs is the only soluble radionuclide to be removed?
Response The engineering data package used in developing this alternative (WHC 1995j) assumed that only well-documented technologies would be used in developing the Ex Situ Intermediate Separations alternative. Cesium recovery by ion exchange is at present the sole technology that is well-documented for the recovery of soluble radionuclides. This assumption was then carried forward into the EIS. Removal of additional soluble radionuclides was included in the Phased Implementation and Ex Situ Extensive Separations alternatives.
Comment Number 0072.189
CTUIR
Comment P B-107: Sect. B.3.6: Calcining tank waste will result in a form not acceptable at the permanent waste repository.
Response The calcined HLW form would not meet the standard waste form (i.e., borosilicate glass) specified in the current waste acceptance requirements for the potential geologic repository. NEPA requires that an EIS address the full range of reasonable alternatives, including alternatives that would not be in compliance with laws and regulations. Please refer to the response to Comment number 0072.80 for a discussion of the NEPA requirement to consider reasonable alternatives regardless of their ability to comply with regulations. Volume One, Sections 3.4 and 6.2 and Volume Two, Section B.3 address regulatory compliance issues related to each of the alternatives. Please refer to the response to Comment number 0012.20 for a discussion of glass types and regulatory licensing issues.
Comment Number 0089.09
Nez Perce Tribe ERWM
Comment Page 3-66, Paragraph 2
It states that, with ex situ vitrification, LAW will be melted and flow into a water bath to break the glass formed into cullets, later the cullets will be bonded in a matrix material before onsite disposal. The EIS does not indicate what matrix material will be used to hold the cullets together. It is a concern that the matrix may not be as resistant to degradation as the vitrified glass allowing breakdown and waste surface area to increase. Whatever the matrix material is it will than also become LAW along with the glassformers used to create the product. Why not leave the LAW as a full size molded product rather than increasing the surface area for chemical breakdown by forming cullets. Surely a suitable configuration can be found for the molded LAW, that will not require forming cullets.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Matrix material composition and final waste form would be evaluated during the detailed design phase that would follow selection of this specific remedy, if this selection occurs. Volume One, Section 3.4 addresses waste composition and the reasons for assuming a vitrified low-activity cullet form. Cullet would provide processing and material handling advantages for high-capacity processing facilities; however, cullet has a high surface area-to-volume ratio, which results in lower long-term performance. Please see the response to Comment numbers 0005.40 and 0072.89 for a discussion of how the cullet waste form provides a bounding impact analysis. The response to Comment numbers 0035.04, 0052.11, and 0012.11 contain discussions concerning waste form.
L.3.4.8 Ex Situ No Separations Alternative
Comment Number 0005.48
Swanson, John L.
Comment The second paragraph under "Vitrification Process" on page 3-74 appears to be garbled. On balance, it appears to be addressing LAW vitrification, but it specifically says HLW glass.
Response The second paragraph under Vitrification Process on the referenced page may appear to discuss LAW vitrification, but the section heading is Ex Situ No Separations alternative, meaning that all of the glass waste produced is HLW. The first paragraph under Vitrification Process states that the HLW facility capacity is provided by two melters operating in parallel. The paragraph identifies HLW glass because this paragraph discusses only the HLW process as the only applicable process for discussion under this alternative. The text has been revised to clarify the discussion regarding vitrification under the Ex Situ No Separations alternative in Volume One, Section 3.4.
Comment Number 0057.07
Garfield, John
Comment Other things like the calcination case mentioned two calciners at a processing rate of 200 tons per day. You may be able to accomplish a solidified moltent sodium process at those rates but drying the waste to a calcine form would require something on the order of 20 to 40 calciners. The physics are not there to do it at a 100 tons per calciner. That is a technical error that should also be fixed.
Response A more detailed description of the conceptual calciner is discussed in Volume Two, Section B.3. The discussion in Volume One, Section 3.4 is a summary level discussion. The calciner design is modeled after available laboratory data. Additional details including mass and energy balances for the calcining process are available for review in the TWRS EIS Administrative Record and in DOE Reading Rooms and Information Repositories. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0072.112
CTUIR
Comment P 3-73: Sect.3.4.7: PP 4: Because this is a retrieval EIS not a closure EIS, this paragraph should be removed, or the language strengthened to indicate that there are several closure options.
Response Cost estimates for the removal and treatment alternatives included several Site closure assumptions (e.g., the Hanford Barrier), which are discussed in Volume One, Section 3.4.1.4, Major Assumptions and Uncertainties to provide an equal basis of comparison among alternatives. The text is considered appropriate within the context of the section and therefore no revisions to the text are required. For an extensive discussion of all issues related to closure, please refer to the response to Comment numbers 0072.08, 0019.03, 0019.04, and 0101.06.
Comment Number 0072.113
CTUIR
Comment P 3-74: Calcination Process: This process results in an unacceptable waste form for the permanent repository and thus this section should be removed or edited to clearly state the consequences of producing an unstable waste form that will spread to the environment.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The information requested in the comment is in the EIS. The Summary, Section S.7.1, Volume One, Section 3.4.7.7, and Volume Two, Section B.3.6.4 discuss the fact that the calcined waste form would not meet the current waste acceptance criteria for the potential geologic repository. NEPA requires that an EIS address the full range of reasonable alternatives, including alternatives that would not be in compliance with laws and regulations. For a discussion of this requirement, see the response to Comment number 0072.80. Volume One, Section 6.2 and Volume Two, Appendix B.3 also address regulatory compliance issues related to each of the alternatives. The radiological impacts of transporting the calcined HLW are analyzed in Volume Four, Section E.7.4.1.1.
Comment Number 0072.114
CTUIR
Comment P 3-76: PP 2: This paragraph relates to a process that produces a product that is unacceptable for the permanent waste facility, this paragraph should be removed or edited to clearly state the consequences.
Response Please refer to the response to Comment number 0072.113.
Comment Number 0072.115
CTUIR
Comment P 3-76: PP 3: S 2: This sentence refers to the closure process which is not within the scope of this EIS and should be removed or edited to clearly state the reasoning and the consequences and additional closure alternatives associated with this action.
Response Please refer to the response to Comment numbers 0072.112 and 0072.08.
Comment Number 0072.116
CTUIR
Comment P 3-77: Sect. 3.4.7.5: This section refers to the closure process and should either be removed or edited to reflect additional closure options such as the clean closure option of removing the tanks and the contaminated underlying soils as not to preclude all closure options.
Response Please refer to the response to Comment numbers 0072.112 and 0072.08.
L.3.4.9 Ex Situ Extensive Separations Alternative
Comment Number 0005.49
Swanson, John L.
Comment The first paragraph on page 3-80 refers to "--multiple complex chemical separations--." It appears to me that the use of the word "complex" is editorializing, and that word should be deleted. The last sentence of that paragraph says "--fewer radioactive contaminants--"; a more accurate statement would be "--lower concentrations of radioactive contaminants--"
Response It is true that the term "fewer radioactive contaminants" would mean less radioactive isotopes in the LAW and "lower concentrations of the radioactive contaminants in the LAW." The text in Volume One, Section 3.4 has been revised to reflect lower concentrations of radioactive contaminants in the LAW.
The term "complex" is intended to give the reader a feeling for the number, complexity, and level of development for the multiple separations processes used for the Ex Situ Extensive Separations alternative; therefore, the term conveys accurate and useful information.
Comment Number 0005.50
Swanson, John L.
Comment The second paragraph on page 3-80 includes Jacobs Engineering as a Site M&O contractor, which is incorrect.
Response The cited statement references information obtained from the Site Management and Operations contractor documents, one of which was prepared by Jacobs Engineering Group Inc. (i.e., Jacobs 1996), and does not state, nor is meant to imply, that Jacobs is the Site Management and Operations contractor. Therefore, the statement has not been revised.
Comment Number 0036.13
HEAL
Comment The EIS is inaccurate in addressing technical risk.
As noted above, DOE has conducted many analyses of the alternatives for treating and disposing Hanford tank wastes. Compared with many of these analyses, the EIS is relatively useless in communicating varying degrees of technical risk.
For example, following is a quote from the EIS on the technical risk involved with the intermediate separations technology: "Performance of key processes (e.g., solid liquid separation) has been assumed in the absence of substantive data" (p. 3-72). Next is a quote addressing the technical risk involved with extensive separations: "The key implementability issue associated with this alternative is that the performance of key separations processes has been assumed in the absence of substantive data" (p. 3-85).
The two above quotes say exactly the same thing: There is no qualitative difference between the technical risk involved in intermediate separations and the technical risk involved in extensive separations. Extensive separations is a complex, essentially science fiction technology that has little chance of becoming practical for use on tank waste. It has not been utilized except on a laboratory scale. Intermediate separations, on the other hand, has been used in several places and is relatively simple. The key concern is whether intermediate separations will work on the scale that it must to be useful to the tank program. The list of concerns with extensive separations is almost as long as the TWRS EIS. The approach in the EIS is tantamount to saying that building a car that can go 250 miles per hour involves the same amount of technical risk as building one that can go 2,500 miles per hour.
The position of the Northwest's stakeholders on this issue is clear: The TWRS Task Force stated:
The high cost and uncertainty of high-tech pretreatment and R&D threatens funding for higher performance low-level waste form, vitrification, and cleanup. Use the most practicable, timely, available technology, while leaving room for future innovation. Keep a folio of technological options and make strategic investments over time to support a limited number of promising options. Give up further research on unlikely options.
The lack of honest, frank text concerning technical risk seriously misleads the public and decision makers and unfairly prejudices judgement on the separations issue.
Response In response to the issue of assessment of technical risk; the EIS discusses the ability to implement the alternatives to provide additional information to decision makers. The implementability of a remedial alternative is a function of its history of demonstrated performance and its ability to be constructed and operated. In the case of both the Ex Situ Intermediate Separations and Ex Situ Extensive Separations alternatives, there is no history of demonstrated performance on the Hanford tank wastes. Bench-scale testing is currently underway for the Ex Situ Intermediate Separations alternative. No testing is underway for the Ex Situ Extensive Separations alternative at the Hanford Site; however, a process that is similar to the Intermediate Separations alternative is being used on the tank wastes at the Savannah River Site. It would be premature to state that intermediate separations has been used in several places and is relatively simple, especially with the operation problems that have occurred at the Savannah River Site. To provide the engineering information required for the EIS, the engineering data packages for both alternatives (WHC 1995e and WHC 1995j) assumed the performance of key processes in the absence of substantive data, leading to the same essential statement in the EIS. The inclusion of both the Ex Situ Intermediate Separations and Ex Situ Extensive Separations alternatives is the result of providing a range of reasonable alternatives to the decision makers, and no change has been made to the EIS. DOE and Ecology believes that the uncertainties are expressed in an unbiased and accurate manner.
Regarding the issue of alternatives that should or should not be considered in the EIS, NEPA requires DOE and Ecology to examine a full range of alternatives in the EIS. This range of alternatives must include a No Action alternative, and may then include other reasonable alternatives to allow an analysis of a full range of alternatives. Among the four major categories of alternatives examined in the EIS was a category involving extensive retrieval of the wastes from the tanks. Following retrieval, the HLW is separated from the LAW. The degrees of separation of these two types of wastes may range from no separations, to intermediate separations, to extensive separations. For more information on how the EIS developed alternatives consistent with the recommendation of the Tank Waste Task Force, see the response to Comment numbers 0072.05 and 0038.05. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0055.09
Martin, Todd
Comment The EIS is somewhat inaccurate in addressing technical risk for pretreatment. If you look at the language addressing the intermediate separations essentially sludge washing which we have a pretty good idea of how to do and the extensive separations which I have often characterized as science-fiction technology, the language is almost identical. It basically says there is uncertainty here because these are first of the time processes. I agree with that but one is much more technically uncertain the extensive separations than the other and I think the EIS should reflect that.
Response Please refer to the response to Comment number 0036.13.
Comment Number 0072.117
CTUIR
Comment P 3-81: PP 2-5: the LAW form as described here, is not an acceptable form because it does not meet the regulatory criteria, and the process results in a waste form that is very susceptible to leaching of high activity components. This section also needs to be redone to assume a glass form as the final waste product.
Response The Ex Situ Extensive Separations alternative would meet the requirements for disposal of HLW and LLW. However, residuals left in tanks would not meet the water protection standards if additional closure is not performed. Closure is not included in the scope of this EIS; however, closure for the tanks and residuals would be addressed in a future closure plan. The EPA is considering a rule to further regulate LLW disposal facilities; and the final design of the onsite LAW disposal facility may be impacted by EPA rule 40 CFR 193. A discussion of the ability of each tank waste alternative to enable DOE to comply with Federal and State regulations is included in Volume One, Section 6.2. Specifics of the matrix material and waste form would be final design issues. Volume One, Section 3.4 addresses waste composition and the reasons for assuming a vitrified LAW cullet form.
Please refer to the response to Comment numbers 0005.40, 0072.89, and 0072.107 for discussions of the cullet waste form and how cullet provides a basis for a conservative analysis of long-term impacts. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0072.118
CTUIR
Comment P 3-83: Sect. 3.4.8.4: Operation: The LAW description needs to be edited, removing the last two bullets.
Response Specifics of the matrix material and waste form would be final design issues; however, for the purposes of analyzing the ex situ alternatives in this EIS, LAW was assumed to be produced in vitrified cullet form. The referenced text correctly describes the operations involved in producing this type of waste form. Volume One, Section 3.4 addresses waste composition and the reasons for assuming a vitrified LAW cullet form. Cullet would provide processing and material handling advantages for high-capacity processing facilities; however, cullet has a high surface area-to-volume ratio, which results in lower long-term performance. Assuming vitrified LAW in cullet form for all of the ex situ alternatives provides a conservative analysis of the long-term impacts resulting from onsite disposal of LAW. No change to Volume One, Section 3.4 is required.
For a discussion of regulatory requirements for onsite disposal of LAW please refer to the response to Comment number 0072.111.
Risks associated with retrievable disposal of LAW in vaults have been analyzed and these are presented in Volume Three, Appendix D.5. In addition, a Native American Scenario has been added to the Final EIS in Volume One, Section 5.11 and Appendix D.
Please refer to the response to Comment numbers 0005.40, 0012.11, 0072.11, 0035.04, 0052.01, 0072.89, 0072.107, and 0072.117 for related information. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0072.119
CTUIR
Comment P 3-84: Sect 3.4.8.5: Post Remediation: second and third paragraphs: these two paragraphs need to be removed because this EIS is a retrieval EIS and closure options are not within the scope. If closure options were within the scope of this EIS then the option would necessarily be clean closure and removal of the tanks, underlying soil contamination, ancillary equipment, and MUSTs as not to prejudice future options for closure.
Response Please refer to the response to Comment numbers 0072.08 and 0072.112.
Comment Number 0072.190
CTUIR
Comment P B-115: Sect. B.3.7: The definition of LAW indicates that there will be a HLW component. This is unacceptable in terms of long term risk.
Response Volume Two, Section B.3.7.1 describes the extent to which the treatment processes are used to separate HLW from the tanks waste. LAW is the waste remaining after removing as much of the radioactivity as practicable. The definition of LAW is provided in Volume One, Section 1.0, and tank waste classification (e.g., Class A, B, C) is addressed in more detail in Section 6.2. NRC Class A waste contains the least amount of radioactivity. Long-term risk has been analyzed for each of the alternatives and waste forms, and this is presented in Volume One, Section 5.11, and addressed in more detail in Volume Three, Appendix D.4.7. Because the information contained in the Draft EIS is correct, no change to the text was made.
For more information on LAW, LLW, and HLW definitions, please refer to the discussions contained in the response to Comment numbers 0072.100, 0072.111, 0072.117, and 0072.118.
Comment Number 0072.191
CTUIR
Comment P B-119: Fig. B.3.7.2: This figure, to be acceptable, should have LLW exchanged for LAW and interim on site storage exchanged for on site disposal.
Response Figure B.3.7.2 accurately depicts the process flow of the Ex Situ Extensive Separations alternative described in Volume Two, Appendix B, Section B.3.7. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted.
L.3.4.10 Ex Situ/In Situ Combination 1 Alternative
Comment Number 0005.09
Swanson, John L.
Comment The two combined ex situ/in situ alternatives discussed in the EIS speak of remediating a large fraction of the risk while remediating only a small fraction of the tanks. Such statements imply a knowledge of tank-by-tank inventory data that is much better than that given in the EIS. What data (or assumptions) were used for these alternatives? What accuracy do they have? Without evaluation of these factors, it is not possible to evaluate whether these combined alternatives are worth considering. Thus I feel that the current presentation of these combined alternatives is very biased in their favor.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The TWRS EIS addresses many potential criteria that could be used to develop a selection process and acknowledges that additional waste characterization and analysis would be required to implement this alternative (Volume Two, Appendix B, page B-127). Please also refer to the response to Comment number 0072.192. The data used for tank-by-tank analysis were based on SST and DST inventory data presented in summary form in Volume Two, Appendix A. DOE and Ecology believe that the existing historical data, laboratory data, and characterization reports, which provide the basis for the tank waste inventory used in the EIS, are adequate for detailed evaluation of impacts. The EIS acknowledges the uncertainties associated with the tank waste inventory, and accordingly uses a bounding approach to impacts assessment based on the available data.
The ex situ/in situ alternatives were developed to assess the impacts of combining two or more of the tank waste alternatives. Recognizing that tank waste differs greatly in the physical, chemical, and radiological characteristics, it may be appropriate to implement different alternatives for different tanks. These alternatives were developed to bound the impacts that could result from a combination of alternatives and are intended to represent a variety of potential alternative combinations that could be developed to remediate the tank waste. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted. Please refer to the response to Comment number 0005.03 for a discussion of assumptions and uncertainty ranges used in the alternatives analyses.
Comment Number 0072.120
CTUIR
Comment P 3-86: Ex Situ/In Situ Combination Alternative: Technical staff agree that it may be necessary to implement an alternative treatment process for Tank wastes due to their varied contents, but the alternative of in situ treatment is unacceptable. The people of the CTUIR have been made involuntarily responsible for the waste DOE produced on CTUIR ceded land, and do not and should not, have to bear the responsibility of the enormous excess risk from in situ process. Therefore this alternative is unacceptable both in idea and in implementation.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
NEPA requires DOE and Ecology to examine a full range of alternatives in the EIS. The Ex Situ/In Situ Combination alternative was developed to assess the impacts that would result if a combination of two or more of the tank waste alternatives were selected for implementation. Because the tank waste differs greatly in its characteristics, it may be appropriate to implement different alternatives for different tanks. The Ex Situ/In Situ Combination alternative represents a combination of the In Situ Fill and Cap and Ex Situ Intermediate Separations alternatives, and as such can be considered as one of the reasonable alternatives for evaluation. It is intended to represent a variety of potential alternative combinations that could be developed to remediate tank waste. Because this alternative is one of the full range of alternatives developed in the EIS, the document has not been changed. For the Final EIS, a second combination alternative that was presented in the Draft EIS, has been fully described and impacts have been analyzed. This alternative is described in Volume One, Section 3.4 and impacts of the alternative are described in Volume One, Section 5.0 and associated appendices.
Comment Number 0072.192
CTUIR
Comment P B-126: Sect. B.3.8: This alternative is unacceptable in that there is an illegal in situ component. Additionally the characterization process has not adequately justified that they know where 90 percent of the contaminants that contribute to long term risk are located, or how to get at them for treatment.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
The Ex Situ/In Situ Combination alternative was developed to represent a variety of potential alternative combinations that could be developed to remediate the tank waste. Existing uncertainty associated with the tank waste inventory data must be resolved and additional tank characterization is required before final design of any alternative. Please refer to the response to Comment number 0005.09. Several activities that involve collecting and analyzing data on tank contents are ongoing, including the Tank Characterization program. Data obtained from this program would be used for refining remediation process design. Please refer to the response to Comment numbers 0012.14 and 0072.07 for discussions on characterization of tank inventory. Volume Two, Appendix A,
Section A.3 and Volume Two, Appendix B, Section B.1 address tank inventory data and ongoing waste characterization programs, and Volume Three, Appendices D and Volume Four, Appendix E address anticipated risk and accidents. Volume Five, Appendix K addresses the uncertainties associated with human health risks associated with this and other alternatives.
L.3.4.11 Phased Implementation Alternative
Comment Number 0005.51
Swanson, John L.
Comment Page 3-94 says "Separations prior to LAW processing--." I believe that the word IMMOBILIZATION or VITRIFICATION should be substituted for the word PROCESSING.
Response The Phased Implementation alternative description has been revised as follows, "Separations prior to LAW immobilization would be performed to remove the cesium, strontium, technetium, TRU elements, and entrained sludge particles from the waste stream to the extent required to meet LAW product specifications."
Comment Number 0005.52
Swanson, John L.
Comment The first two paragraphs on page 3-99 appear to be "lifted" from a privatization write-up, in that they talk of what functions are to be performed by DOE. This EIS assumes that all the functions will be performed by DOE.
Response Volume One, Section 3.4 has been revised as follows for the Phased Implementation alternative, "The waste (mainly DST liquid waste) would be retrieved and transferred to receiver tanks for LAW treatment." The cited text in Volume One has been revised as follows, "Separated cesium and technetium radionuclides would be stored at the treatment facilities or packaged for interim onsite storage at the Canister Storage Building."
Comment Number 0005.53
Swanson, John L.
Comment On page 3-99 it is stated that Phase 2 sludge washing will be performed in-tank. Is that really the intent?
Response The text regarding sludge washing has been revised in Volume One, Section 3.4 to remove the reference to in-tank sludge washing.
Comment Number 0005.54
Swanson, John L.
Comment I do not understand how the Phased Implementation approach can have R&D costs of only $190,000,000 (page 3-100) when those costs are $820,000,000 (page 3-71) for the intermediate separations alternative, which involves fewer pretreatment steps. Can you explain this?
Response Because Phase 1 of the Phased Implementation alternative would be a demonstration process, the research and development cost for the treatment process was assumed to be part of the Phase 1 cost. Research and development cost associated with the waste retrieval and transfer function was included at the same level as the other ex situ alternatives. Development programs currently are ongoing at the Site that are covered under the TWRS program or under other programs.
Comment Number 0032.05
Heacock, Harold
Comment In regard to the Department's currently planned method of implementing this program which is based upon the privatization of the work performance, we are not addressing that issue at this time. However, we have previously supported the privatization concept in other statements.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Comment numbers 0032.06, 0043.04, and 0060.01 contain information concerning privatization and associated issues related to privatization.
Comment Number 0032.06
Heacock, Harold
Comment Funding of the privatization program through the proposed budgeting set-aside at the expense of other Hanford Site cleanup programs and the concurrent failure to meet all Tri-Party Agreement commitments is not acceptable.
Response Changes to the TWRS program were incorporated into the Phased Implementation alternative, as required by the proposed 1996 Tri-Party Agreement amendments; therefore, Phased Implementation would not deviate from the Tri-Party Agreement or any other applicable regulation. DOE and Ecology intend to comply with all Federal, State, and local regulations and ordinances applicable to tank waste remediation. Funding for privatization is outside the scope of the TWRS EIS. The response to Comment number 0043.04 contains a discussion of privatization issues.
Comment Number 0035.06
Martin, Todd
Comment More specifically, I do not trust the costs just in general in the EIS. For example, the EIS assumes that for about 250 million dollars, the DOE can build a 20-ton a day low-level vitrification facility.
Everybody who has been in Hanford circles for years remembers that the Hanford waste vitrification plant, a one to three metric ton a day facility was going to cost one point three billion dollars.
What does the EIS say DOE can build essentially the same facility now for? About 232 million, about one-fifth the cost.
In totality, in the preferred alternative for phase one the EIS says that the two 20-ton a day vitrification facilities, two pretreatment facilities tied onto the side, and one HLW vitrification facility, in total five facilities, can be built for about one point four billion.
Again, I refer back to the one relatively small vitrification facility that DOE said that it would take one point three billion to build. I say no way can DOE build these facilities for that cost.
Are these costs due to privatization savings? The answer to that is no. The EIS does not deal with privatization. It assumes that these are traditional DOE facilities.
Further, if these costs are actually correct, there is not a need for privatization. The privatization set-aside account that everybody has been wrangling over the last couple of months has more than enough money in it right now to start building these facilities and get on with cleanup.
Either these numbers need to be changed, or we need to switch paths and start building vitrification facilities.
Response Please refer to the response to Comment numbers 0055,06 and 0057.06 for a discussion of the approach used to develop the cost estimate for this alternative.
The HWVP capital cost estimate is not directly comparable to the capital cost estimated for the Phase 1 HLW facility because it includes support facilities and infrastructure that are estimated as separate components for Phased Implementation.
The cost estimating methodology has been reviewed and revised cost estimates have been completed for the Phased Implementation and combination alternatives. These revised costs are shown in Volume One, Section 3.4 and in Volume Two, Appendix B.
Comment Number 0035.07
Martin, Todd
Comment Just in my cursory look at some of the other costs in the EIS things jump out at me. For instance, in the preferred alternative, phase one, basically DOE has to retrieve about 36 tanks to vitrify in that phase.
How much does the EIS say this will cost? Zero dollars. Not a penny. I think there are some retrieval costs there. There must be.
Response During Phase 1, readily retrievable and well-characterized DST waste would be retrieved and transferred to two DSTs used as receiver tanks for the demonstration facilities. This retrieval effort was assumed to be accomplished by using the existing tank farm work force and infrastructure, in the same manner that wastes currently are transferred. The cost associated with DST waste retrieval during Phase 1 was assumed to fall within continued operations. Continued operations costs of $1.58 billion, including 10,000 person-years of labor, were included in the cost estimate for Phased Implementation. The Draft EIS also states that selected SST wastes could be processed during Phase 1. It was assumed that wastes retrieved under retrieval demonstrations (e.g., tank 106-C) could be transferred to the demonstration facilities. Because the cost associated with these retrieval demonstrations is included in other programs, it is not included in the estimate for Phase 1, but is accounted for in the estimate for continued operations of the tank farms. The cost involved would be small in comparison to the overall project costs.
The Phased Implementation alternative identified in the TWRS Draft EIS would produce, during Phase 1, approximately 11 percent of the total LAW volume. Waste retrieval would not be required from 36 tanks during Phase 1.
DOE and Ecology have reviewed and revised the cost estimates for the Phased Implementation alternative for the Final EIS. These revisions are shown in Volume One, Section 3.4 and Volume Two, Appendix B, and are reflected in the Summary.
Comment Number 0036.03
HEAL
Comment The costs in the EIS are incredible and must be redone. The EIS should not be finalized until a formal, credible data package for the preferred alternative is completed.
The EIS assumes the following for Phase 1 of the preferred alternative:
- The cost of a 100 metric ton per day vitrification facility is half the cost of a 200 ton per day facility. There is no engineering data to support this assumption. In fact, there is data to refute it. About 15 percent of the cost of a vitrification facility is dependent upon its throughput (the rate at which it makes glass). Therefore, the cost of a 100 metric ton per day facility would be less than a 200 ton per day facility -- but not much less -- and certainly not 50 percent less.
- The "six tenths rule" is an engineering rule used for extrapolating the cost differences between chemical facilities of different sizes. The EIS uses this to determine the costs of vitrification facilities of different sizes. This is a wholly inappropriate use of the rule. Again, it applies for facilities where about 85 percent of the facility cost is dependent upon processing equipment -- primarily chemical facilities. Vitrification facilities only have about 15 percent of their cost dependent on processing equipment. Therefore, vitrification facility costs are not particularly sensitive to sizing differences -- which means use of the "six tenths rule" results in grossly underestimated costs.
These two assumptions have resulted in grossly underestimated costs for the preferred alternative. The EIS estimates the cost of the Phase 1 facilities as follows:
- A 20 metric ton per day LAW vitrification facility can be built for $248 million.
- A 1 ton per day HLW vitrification facility can be built for $232 million.
Comparing these numbers to much more rigorously developed cost estimates we can see exactly how far off the EIS's numbers are. The Hanford Waste Vitrification Plant, which was designed to produce between 1 and 3 tons per day of glass, was estimated to cost $1.3 billion. This is almost exactly the same facility that the EIS says DOE can build for $232 million.
The EIS claims that for Phase 1 the total capital cost will be $1.4 billion. In other words, DOE is going to build two 20 ton per day LAW vitrification facilities, a one ton a day HLW vitrification facility and two pretreatment facilities for about the same cost as the one ton per day Hanford Waste Vitrification Plant!
Response Please refer to the response to Comment numbers 0035.04, 0035.06, 0055.06, and 0057.06.
Comment Number 0036.04
HEAL
Comment If the costs in the EIS are indeed accurate, there is no need for privatization.
If DOE's cost estimates are accurate, there is no need to take the extra risks of privatization. All of DOE's cries that there is not enough money to build vitrification facilities are false. The money DOE is currently putting in a set aside fund for privatization is more than enough to build these vitrification facilities.
Response Phased Implementation approach reduces the technical risk associated with tank waste remediation over a full implementation alternative. Phased Implementation also provides a greater opportunity to reduce overall program costs by applying lessons learned and experience gained during Phase 1 to the design and construction of the full-scale Phase 2 treatment facilities. The cost estimates developed for the TWRS EIS were developed using common assumptions. The Phased Implementation alternative cost estimate assumed the same contracting strategy, government-owned and contractor operated, as the other alternatives. As discussed in Volume One, Section 3.3, the EIS does not address the contracting strategy that would be used to privatize tank waste remediation. Please refer to the response to Comment number 0043.04 for more information.
Comment Number 0036.05
HEAL
Comment A cursory review of the cost estimates identified many other problems. Following are just a few: The EIS assumes that tank farm operation costs will be the same for both the Phased Implementation and Ex Situ Intermediate Separations alternatives. This is a faulty assumption. The Intermediate Separations alternative would begin treating waste in 2004 at a relatively high rate, resulting in tanks being emptied. This would allow DOE to dramatically reduce its tank farm operation costs. The estimate for operations for Intermediate Separations is $8.6 billion.
The operations estimate for the Phased Implementation alternative is also $8.6 billion. It should be much higher. Phased Implementation will treat waste at a much slower rate than Intermediate Separations, requiring DOE to fund operations programs for a longer period of time and thus at a higher level.
Response A difference in the rate at which the cost declined for different rates of processing is expected. Many of the factors that would control the ongoing tank farm operations cost would be the monitoring and maintenance requirements and how these requirements were reduced for individual tanks and tank farms. The monitoring and maintenance requirements for a tank farm may not be appreciably lower until all of the tanks within that tank farm are empty. The tank retrieval sequencing and blending strategy, which have not been finalized, would identify when waste retrieval from individual tanks and tank farms would be complete.
Because of the conceptual level of development, it was assumed for the purposes of the TWRS EIS that continued tank farm operations cost for Phased Implementation would be the same as for the Ex Situ Intermediate Separations alternative. In fact, the difference between level funding and the annual reductions in operating cost associated with the Ex Situ Intermediate Separations alternative for the years 2004 through 2011 totals $141 million or approximately 1.6 percent of the total $8,600 million used in the TWRS EIS for continued tank farm operations.
DOE and Ecology have reviewed and revised the cost estimates appropriately for the Phased Implementation alternative. These revised cost estimates have been presented in the Final EIS in Volume One, Section 3.4 and Volume Two, Appendix B.
Comment Number 0036.06
HEAL
Comment To support the Tri-Party Agreement, DOE must retrieve waste from 36 tanks in Phase 1 of the Phased Implementation alternative. The EIS estimates that this will cost $0. Surely there is a cost associated with retrieving the high-level waste from 36 tanks.
HEAL finds the estimates in the EIS to be utterly devoid of credibility and insists that the EIS not be finalized until a credible, formal data package for the preferred alternative is completed.
Response Please refer to the response to Comment number 0035.07 which addresses a similarly worded comment.
Comment Number 0036.11
HEAL
Comment The EIS must require vitrification as technology for tank waste treatment.
For all alternatives, except the Phased Implementation alternative, the EIS assumes vitrification will be the immobilization technology. The EIS provides no rationale as to why this alternative does not also require vitrification. Given that it is the preferred alternative, this is even more disturbing.
Vitrification has been the technology that stakeholders have found acceptable. It balances the concerns for a safe waste form with a relatively available technology that allows DOE to "get on with it." Any changes to the assumed use of vitrification must be accompanied by a compelling argument outlining any emerging technologies that better respond to stakeholder values. HEAL has not seen such an argument, and strongly doubts that one could be made.
The TWRS privatization initiative, upon which the Phased Implementation alternative was designed, also fails to require vitrification as a technology. It appears that this EIS has been designed to "fit" the decision to not require glass as a waste form in the privatization Request for Proposals.
Response Please refer to the response to Comment number 0035.02 which addresses a similarly worded comment.
Comment Number 0036.15
HEAL
Comment EIS does not show any effects of privatization.
DOE has spent over a year in an unsuccessful attempt to sell its privatization plan to the public. Cost is one of the many concerns that the public has raised with DOE. DOE has consistently held that privatization would cost 30 percent less than a traditional approach. DOE has been unable to furnish the public with any information that supports the above assertion.
The EIS continues the information void concerning the benefits of privatization. The EIS refers to privatization in the description of the Phased Implementation alternative, "under Phased Implementation, either DOE or a private contractor would design, build, and operate ... (the facilities)" (p. 3-23). As was pointed out above, DOE has held that the differences between a traditional government-owned, contractor-operated approach, and the contractor-owned and operated privatization approach were "revolutionary." Yet the EIS fails to show the different impacts of this revolutionary approach. Worse, the EIS is not explicitly clear about which approach -- privatization or traditional GOCO -- is being analyzed.
The EIS does allude to how the cost estimates for Phased Implementation were reached. It was developed by, "... combining applicable components from other ex situ alternatives and applying rations as required to account for differences in facility sizes and capacities and the degree of separations in LLW and HLW" (p. 3-99). Engineering data in the TWRS program over the years has shown that facility capacity and size do not have a large impact on facility cost.
The cost savings that DOE claims are virtually guaranteed are not evident in the EIS. The Tri-Party Agreement case is estimated to be $30-41 billion and Phased Implementation $32-42 billion. Where are the savings?
Response The EIS addresses the potential environmental impacts associated with a Phased Implementation approach to tank waste remediation. It was assumed for cost estimating purposes that the Phased Implementation alternative would use the traditional government owned-contractor operated contracting strategy. This was done to allow the reader to make an equitable comparison among the alternatives. A potential exists to reduce the cost for tank waste remediation by allowing the market place to establish, through the competitive bidding process, the cost for waste treatment. Cost savings projections that might result from privatization are not included in the EIS in an effort to maintain the competitive bidding process.
The fact that privatization is not addressed in this EIS is discussed in Volume One, Section 3.3. DOE believes that privatization will result in an overall cost savings for the project but has not published an estimate of savings that may result. The 30 percent figure identified in the comment is reasonably consistent with the cost savings resulting from other activities the federal government has privatized. Privatization is not within the scope of the EIS. Please refer to the response to Comment numbers 0036.05, 0036.04, 0055.06, and 0057.06.
Comment Number 0037.05
Elredge, Maureen
Comment Mostly I am concerned with further cost estimates throughout the EIS. They seem to be questionable. And I am particularly concerned that the preferred alternative is widely perceived as a privatization alternative which is supposed to save money, and yet this is not made evident in the document.
I want to urge you to use extreme caution both in assuming that the preferred alternative will be cheaper, and even more so in assuming that a privatization scheme will be a success.
When the cleanup program was being pummeled in Congress and the media last year, privatization was held up as the Holy Grail, sort of along the lines of please give us another chance. We will bring in corporate America. They will fix everything. We will be fine. Please give us our money.
We do not need Holy Grails. We need progress. We need action on the ground now. If privatization efforts fail it will be a disaster not only for Hanford but for the entire cleanup program. Thank you.
Response Please refer to the response to Comment number 0036.15, which addresses a similarly worded comment.
Comment Number 0038.06
Reeves, Merilyn
Comment The Board is troubled by some aspects of the preferred alternative, and where the EIS has not considered the impacts of privatization as a contractor mechanism.
Response Please refer to the response to Comment numbers 0036.15, 0036.05, 0036.04, and 0057.06 for discussions related to this issue.
Comment Number 0038.07
Reeves, Merilyn
Comment The concerns the Board has voiced have to do with liability in privatization, budget, regulatory, logistics, and public participation issues.
The Board has been dubious of DOE's ability to privatize, and has been disappointed in DOE's lack of responsiveness to the Board's concern.
Response Because the issues identified in the comment are not within the scope of the EIS, no modification to the document is warranted. Please refer to the response to Comment numbers 0036.04, 0036.05, and 0036.15.
Comment Number 0038.08
Reeves, Merilyn
Comment In regard to the specific technical approach, the Board has not been adverse to Phased Implementation. DOE has not made a case for that, privatized or not.
Response The TWRS EIS does not address privatization. The Phased Implementation alternative is based on the same common assumptions as the other alternatives to ensure comparability of the environmental impacts. However, the Phased Implementation alternative does address the technical requirements of remediating tank waste with a phased approach and impacts associated with that approach. Please refer to the response to Comment numbers 0043.04 and 0035.15, for more information.
Comment Number 0038.09
Reeves, Merilyn
Comment Phased Implementation can save money over the course of the program. The Board does remain dubious that Phased Implementation will save money, and will likely be more expensive. Again, our main concern has been with DOE's particular program of privatization.
Response The costs estimates developed for the TWRS EIS were developed using the same basis for all alternatives. The Phased Implementation alternative represents the traditional government-owned contractor-operated contracting strategy as described in Volume One, Section 3.3. Please refer to the response to Comment number 0036.15 for more information.
Comment Number 0038.11
Reeves, Merilyn
Comment The Board is concerned by the preferred alternative's effect on the Tri-Party Agreement. The Board has been and remains a staunch supporter of the Tri-Party Agreement.
The Phased Implementation approach has resulted in an unfavorable impact to the Tri-Party Agreement. The Tank Waste Task Force stated the following about the Tri-Party Agreement, quote, Tri-Party Agreement is in need of strengthening and improvement.
The Tri-Party Agreement should increase meaningful public and tribal involvement in all key Tri-Party Agreement decisions, with the public and the tribes as a partner in the goals, scope, pace, and oversight of the cleanup.
The process of the goal in the site specific advisory board and ongoing oversight of the agreement and improving pubic involvement is essential to achieving successful and satisfactory cleanup.
And our Board is trying to carry on these traditions. As we stated earlier, amendment four to the Tri-Party Agreement was judged to be very responsive to the above concerns.
Unfortunately concurrence in yet to be completed negotiations that will once again change the Tri-Party Agreement are somewhat or may be seen to be reversing the progress made in amendment four.
The Tri-Party Agreement changes that are being made in order to support the Phased Implementation alternatives are very disconcerting. The Tri-Party Agreement will go from a long list of interim and long-term enforceable milestones to only a handful of milestones, many of them not enforceable.
The changes will not increase meaningful public involvement or really involve site specific boards, the Hanford Advisory Board, in ongoing oversight of the TWRS program. And this is a step in the wrong direction.
Response The amendments referenced in the comment were based upon the privatization initiative. The Phased Implementation alternative merely bounds the technical approach of staged remediation of the tank waste and analyzes the potential impacts to support a comparison among alternatives. DOE and Ecology are cognizant of the Hanford Advisory Board's concerns regarding the remediation schedule and stakeholder and Tribal Nation participation in decision making. DOE is committed to meeting milestone commitments in the agreement and to effective and meaningful public and Tribal Nation involvement in the cleanup of the Hanford Site. Please refer to the response to Comment number 0012.19 (public involvement), 0072.149 (Tribal Nations consultation), and 0043.04 (privatization relationship to the Tri-Party Agreement).
Comment Number 0055.08
Martin, Todd
Comment Secondly, I think that the chart that Carolyn showed that had to do with the technical uncertainty of the various options was misleading on Phased Implementation. The rationale is that the technical uncertainty for this alternative is low because we are starting small and we are building. We will be able to employ learning. I think that is a very subjective call and I do not buy it. That option includes pretreatment processes have never been done before. Technetium removal. That is not low on the technical uncertainty scale.
Response The phased approach allows information to be collected and analyzed concerning retrieval, separations, and vitrification technologies before constructing full-scale plants. Lessons learned from the demonstration phase would be applied to the full-scale phase, which should improve the efficiency of operations of the second phase. This may reduce construction and operating costs during the second phase. The process of building demonstration plants to verify that technologies function effectively before building full-scale plants is a standard practice used in many industries where new technologies are being used. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0057.02
Garfield, John
Comment With respect to the summary slide, Todd made this same comment, the high-waste complex separations and treatment processes involved uncertainties that will be reduced by implementing the phased approach. I concur with the basic finding of the EIS in terms of the alternative chosen, however, instead of emphasizing the need to demonstrate technology, the emphasis should be on spreading early capital dollars and using a single facility to accomplish the mission. That should be the emphasis more than demonstration. There is no technical justification for demonstration philosophy with this process. The functions of sludge washing, cesium removal, and vitrification are not unknown technologies and any uncertainty with them can be demonstrated either radioactively hot at a laboratory scale or at large-scale cold with simulants much more efficiently than two low-level demos and one high-level demo. That will set the program back 5 to 10 years treated under 5 percent of the waste and cost something on the order of $3 billion dollars. That is a waste.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The demonstration process provides the opportunity to reduce overall program costs while completing remediation of the tank wastes within Tri-Party Agreement requirements, especially considering the uncertainty associated with the tank waste inventory. The lessons learned and process knowledge gained during Phase 1 would be incorporated into the design and operation of the full-scale treatment facilities during Phase 2. Please refer to the response to Comment number 0055.08.
Comment Number 0068.02
Martin, Todd
Comment Further, another one that is very easy for anybody to understand is you look at the EIS, and you see in Phase 1 they need to retrieve and vitrify the waste from about 36 tanks. How much would that cost? How much would it cost to pump the nuclear waste out of this auditorium if it were full? According to the EIS, zero dollars. Won't cost a penny. Surely there's a cost there. But the EIS doesn't reflect it. Again, the costs need to be fixed.
Response Please refer to the response to Comment number 0035.07 which addresses a similarly worded comment.
Comment Number 0072.121
CTUIR
Comment P 3-92: Sect. 3.4.10: This alternative is unacceptable if the implementation consists of decommissioning any process that produces waste acceptable to the HLW permanent repository, the added push of continuing to operate the test facility will reduce the time it take to finish the job.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Decommissioning of facilities for this alternative is addressed in Volume One, Section 3.4.
Comment Number 0072.122
CTUIR
Comment P 3-92: Phase 1: The selection of the SST waste is an integral component and effort has to be taken that this section include language reflecting that waste from all SSTs be test reacted as to ensure complete acceptability.
Response The waste processed during Phase 1 could include selected SST waste. As explained in Volume One, Section 3.4, the retrieval and treatment of the remaining DST and SST waste will be completed in the following stages of the alternative (Phase 2) following completion of the demonstration phase (Phase 1). Before any waste is retrieved it would be characterized and analyzed to ensure compatibility. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted.
Comment Number 0072.193
CTUIR
Comment P B-132: Sect. B.3.9: This alternative, while good for a conservative industry approach does not take into account the uncertainties associated with the characterization program. Unless the demonstration phase proved beyond a doubt it could handle waste forms from all the tanks.
Response Considerable uncertainty associated with the tank waste inventory data remains, and additional tank characterization is required before final design of any alternative. Please refer to the response to Comment numbers 0012.14, and 0072.07 for discussions of characterization of tank inventory and characterization in programs. Phase 1 of the Phased Implementation alternative would include technical evaluation, demonstration, and detailed design for the separations and immobilization processes for various categories of waste feed. Following the successful implementation of Phase 1, Phase 2 would be implemented to complete the tank waste remediation according to the technical approach most appropriate to the tank waste categories. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0088.05
Porter, Lynn
Comment One of my concerns about the preferred alternative and privatization is who decides when it's a success or not. Is this strictly going to be the DOE deciding, or will the Tri-Parties together decide on this? And there need to be enough milestones in this, spaced closely enough together that the public interest groups can track this and know whether it's succeeding or failing, whether it's on track where it should be. Because otherwise this could go on for years, and all of a sudden, as it has before, all of a sudden we find out hey it's not working and we have to start over.
Response Privatization is a contracting mechanism that is not within the scope of the EIS. DOE and Ecology have agreed on a set of criteria that will be used in making a decision on whether privatization is achieving its intended goals or failing, which would cause a change from the primary path to the alternate path. Under this agreement, should Ecology determine that compliance with the primary path is unlikely, it will inform DOE of such an opinion. DOE will respond within 30 days whether a change from the primary to the alternate path is necessary. If DOE determines that a change is not necessary, it will provide Ecology with a written rational for continuing with the primary path. Ecology will have the authority at any time to require DOE to evaluate the viability of the primary path. These activities will be among the issues routinely statused, discussed, and reviewed by the Hanford Advisory Board and its Health Safety and Waste Management Committee. Additional review, input, and comment by Tribal Nation regulator and stakeholder representatives is encouraged. Because the analysis requested in the comment is not within the scope of the EIS, no modification to the document is warranted.
L.3.4.12 Ex Situ/In Situ Combination 2 Alternative
Comment Number 0005.05
Swanson, John L.
Comment As an example of some of my concerns related to (3) and (4), I cite the "last minute" addition of the "Variation of the Ex Situ/In Situ Combination alternative." I do not see that this is a bounding case at all, and I see no evidence that it is based on anything more than some assumed characterization data (perhaps on computer predictions based on a set of assumptions). Thus, I feel that you got carried away by even proposing this as a separate variation; wouldn't it be better to discuss it in the context of being in the "noise level" of the very uncertain characterization data on which I am assuming the original ex situ/in situ alternative was based? (I am assuming this because you do not tell me the source of the "currently available characterization data" that you are basing this on, and I am not aware of any sound data bank that would allow this alternative to be factually based). (See Comment 0005.09).
Response The variation of the Ex Situ/In Situ Combination alternative (known as the Ex Situ/ In Situ Combination 2 alternative in the Final EIS) referenced in the comment was added to provide a range of alternatives that includes a combination of the in situ and ex situ alternatives. Without this alternative, there would have been only one alternative to represent partial retrieval, and it is important to show the public and the decision makers the relationship between environmental impacts and the extent of retrieval. This alternative provides one more alternative on the continuum from no retrieval to minimal retrieval to partial retrieval to extensive retrieval.
The variation of the Ex Situ/In Situ Combination alternative presented in the TWRS Draft EIS was based on limited data analysis and was therefore included in a brief preface to the Draft EIS, which provided general information on the levels of impacts that would occur as a result of implementing the alternative. This alternative has been developed and analyzed to the same extent as the other alternatives in this Final EIS. The variation is known as Ex Situ/In Situ Combination 2 alternative in the Final EIS. The information is presented in Summary, Sections S.5, S.6, and S.7; in Volume One, Section 3.4, and throughout Section 5.0. More detailed information on the alternative may be found in Volume Two, Appendix B.
Comment Number 0012.08
ODOE
Comment The EIS includes an attachment which describes a variation of the Ex Situ/In Situ Combination alternative. This alternative was not analyzed in the EIS and should be excluded from consideration for that reason.
Response The variation of the Ex Situ/In Situ Combination alternative analyzed in the Draft EIS was identified very late in the process of preparing the Draft EIS. DOE and Ecology choose to include a brief summary of this alternative as an attachment to the EIS. This alternative has been fully developed and incorporated into the Final EIS. DOE and Ecology believe the Ex Situ/In Situ Combination 2 alternative provides another alternative between the no retrieval and extensive retrieval, and, as a result provides useful information to the public and decision makers. Please refer to the response to Comment number 0005.05 for more information.
Comment Number 0047.04
Ahouse, Lorretta
Comment I am very concerned that an "attachment variation of the Ex Situ/In Situ Combination alternative" was added at the last moment to the Draft EIS. As I understand, this alternative would only remove 26 percent of the total tank waste volume and would not meet the Tri-Party Agreement. This is not acceptable to me as a citizen of Washington State. Why was this alternative even added so late in the process if its does not meet the Tri-Party Agreement? Does the Department of Energy have any plans to seek an exemption from the Tri-Party Agreement? Why are we wasting taxpayers dollars to examine alternatives that are not legally acceptable? Please, just get on with the cleanup.
Response Please refer to the response to Comment numbers 0005.05 and 0012.08 which address similarity worded comments. Please refer to the response to Comment number 0072.80 for a discussion of the NEPA requirement to analyze reasonable alternatives, even when they do not comply with regulations. In the Final EIS the Summary, Section S.7 and Volume One, Section 6.2 address the ability of the alternative to comply with Federal and State regulations and the Tri-Party Agreement.
L.3.4.13 Miscellaneous
Comment Number 0005.11
Swanson, John L.
Comment I am quite sure that the alternatives involving in situ disposal will require more extensive/costly characterization activities than the other alternatives, but I do not see that reflected in the cost comparisons. Isn't that a bias in their favor? (I learned at the May 2 hearing that characterization is not included in this EIS, but my statement re biasing of comparisons stands. Also, shouldn't the omission of characterization from this EIS be highlighted, along with the omission of closure, so that it will be clear how limited in scope this EIS really is?)
Response Additional characterization requirements for in situ alternatives have been considered. Volume One, Section 3.4 acknowledges that additional characterization would be required for the in situ alternatives have been considered. The cost estimates completed in support of the Draft EIS included an additional $903 million for the in situ alternatives to cover additional characterization activities. These cost estimates are available for review in the TWRS EIS Administrative Record and DOE Reading Rooms and Information Repositories The relationship between closure and the alternative is presented in the Summary and Volume One, Section 3.3 and the impact in Section 5.0. For a discussion of the closure issues, please refer to response to Comment numbers 0072.08, 0101.06, and 0072.50.
Comment Number 0035.09
Martin, Todd
Comment Lastly, I would like to address the issue of mortgage reduction. This is something at Hanford that we have been dealing with for two years.
It has been a very high priority, and it has to do with putting money into old facilities for the purpose of closing them down in such a way that we could free that money up for real cleanup.
The tanks are the greatest mortgage reduction opportunity at Hanford we have. If we get the waste out of the tanks, we will reduce the budget by, as Dick said, about 300 million dollars. It is time to get on with it. It is time to do the job.
Response Cost associated with continued monitoring and maintenance activities at the tank farms would be reduced as the number of tanks containing waste was reduced. Remediation of Hanford tank waste is a needed investment to environmental well-being of the Hanford area and is required to protect human health and the environment.
L.3.5 CESIUM AND STRONTIUM CAPSULE ALTERNATIVES
L.3.5.1 Preferences for Capsule Alternatives
L.3.5.1.1 Specific Preferences
Comment Number 0006.01
Skyes, Megan
Comment As a scientist involved in biomedical research in the area of bone marrow transplantation, I am writing to express my support for the production of Cs-137 sources at the Hanford Reservation. It is my understanding that this is the only world producer of large Cs-137 sources other than the Russian laboratories at Mayak. In view of the high prices of Cs-137 sources that results from the existing monopoly, it will be nearly impossible to purchase sources in the future, as funding for biomedical research is becoming more and more limited. Therefore, the production of Cs-137 sources (at a lower cost) would be a major benefit to the biomedical research community. There are numerous other investigators, not only in the field of bone marrow transplantation, but in immunology who are dependent upon the availability of these irradiators in order to carry out their research. I hope that it will be possible for the Department of Energy to deal with the existing Cs-137 at Hanford in a cost-effective manner and in so doing to serve a vital need for the medical research community.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. For the Final EIS, DOE has identified the No Action alternative as the preferred alternative and has modified the Summary Volume One, Section 1.3 accordingly.
The TWRS EIS addresses alternatives for management and disposal of encapsulated cesium and strontium. The encapsulated cesium and strontium are included in the EIS primarily because they were originally extracted from the stored high-level tank waste to reduce the thermal heat generation in the tanks and would be considered HLW for purposes of disposal. DOE is actively seeking commercial interest in the beneficial applications for the encapsulated cesium and strontium, and DOE remains committed to pursuing any viable commercial or other beneficial uses; at this time, the preferred alternative is No Action. These uses would not be without substantial cost for reprocessing and repackaging since the current encapsulation was designed principally for storage purposes. If viable commercial or beneficial uses are not implemented, the capsules would be designated as waste at some point in the future and would be disposed of using methods consistent with one of the alternatives identified in the EIS or a new NEPA analysis would be completed. Under no action, the capsules will be stored and maintained under current operations at the WESF, which includes a comprehensive monitoring program. This program is described in Volume One, Section 3.2.
Comment Number 0008.03
Evett, Donald E.
Comment Secondly, S.5.2 Cesium and Strontium Capsule Alternatives: I personally would prefer to select alternative (4) physically mixing the capsule contents with the high-level tank waste, which would then be vitrified and disposed of at a potential geologic repository.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium waste and strontium capsules.
Comment Number 0029.02
Bartholomew, Dale C.
Comment I believe that cesium capsules should be left in a condition for possible future commercial irradiation. At the public hearing on May 2, 1996, we were advised that only one capsule leaked, but no one at the hearing was able to identify the mode of failure. If the mode of failure was a bad weld, I believe that it is premature to dispose of all capsules, because there still may still be some interest in commercial irradiation. It would be imprudent to waste all of the previous time, effort, and cost that went into the separation and concentration of the cesium-137 and strontium-90 isotopes.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. For the Final EIS, DOE has identified the No Action alternative as the preferred alternative and has modified the Summary and Volume One, Section 1.3 accordingly. Please refer to the response to Comment number 0006.01.
Comment Number 0032.07
Heacock, Harold
Comment A secondary issue addressed in the Draft EIS is the disposal of the cesium and strontium capsules currently stored in the WESF facility at the B Plant.
We believe that any action to dispose of the capsules should be deferred at this time, so long as an adequate degree of environmental protection is maintained in their storage.
These capsules represent a resource that may have significant future use in irradiation programs. Pending the determination of their potential future utilization, we believe this potential asset should be retained.
This position is consistent with the Draft EIS since the high-level waste ex situ vitrification plant operation is at least 10 years away.
Ultimate disposal of these capsules with the other high-level waste is the preferred solution to the disposal of the capsules.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. Please refer to the response to Comment number 0006.01.
Comment Number 0040.05
Rogers, Gordon J.
Comment The cesium and strontium capsules should be transferred into air-cooled storage in the facility now being built for the Spent Nuclear Fuel project. In the meantime serious efforts should be made to see if there is a market for commercial use as radiation sources. Permanent disposal plans can wait.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. Please refer to the response to Comment number 0006.01.
Comment Number 0043.05
Hanford Communities
Comment The Hanford Communities would also like to comment on the plans for disposition of the cesium and strontium capsules currently stored in the B Plant. We believe that any action to dispose of the capsules should be deferred at this time. These capsules represent a resource that may have significant value. Rather than pay to dispose of these materials, the Department should actively explore opportunities for commercial use and sale.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. Please refer to the response to Comment number 0006.01.
L.3.5.1.2 General Preferences
Comment Number 0012.13
ODOE
Comment The second issue addressed by the EIS is what to do with the cesium and strontium capsules stored at Hanford. The cesium capsules contain cesium-135 and cesium-137. These two isotopes present different hazards. Cesium is very soluble in water. Cesium-135 has a long half-life. If it is disposed at Hanford, it presents an unacceptably large risk to public safety and health and the environment. Oregon supports disposal of the cesium and strontium from capsules in a suitable form to the national high-level nuclear waste repository. The waste form selected should ensure that cesium-135 will not endanger public health and safety or the environment.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. Please refer to the response to Comment number 0006.01.
Comment Number 0060.05
Davenport, Leslie C.
Comment I do not feel that a final choice can be made between the proposed alternatives yet. The No Action alternative of continued storage in WESF is acceptable during the next 10 years while DOE selects an alternate storage method for the capsules or determines if there is a use for them. I do not like the Onsite Disposal alternative because I feel that the capsules, if discarded, belong in the proposed geologic repository. Similarly, it makes little difference other than cost if the capsules are Overpacked and Shipped, or Vitrified with Tank Waste if a HLW vitrification facility is operational at Hanford.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. Please refer to the response to Comment number 0006.01.
Comment Number 0089.02
Nez Perce Tribe ERWM
Comment ERWM endorses the Overpack and Ship alternative for the strontium and cesium capsules.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on the cesium and strontium capsules. Please refer to the response to Comment number 0006.01.
L.3.5.2 No Action Alternative (Capsules)
No comments were submitted for this topic.
L.3.5.3 Onsite Disposal Alternative
No comments were submitted for this topic.
L.3.5.4 Overpack and Ship Alternative
No comments were submitted for this topic.
L.3.5.5 Vitrify with Tank Waste Alternative
No comments were submitted for this topic.
L.3.6 BORROW SITE SUMMARY
Comment Number 0019.03
WDFW
Comment WDFW is concerned by stating specific (potential) borrow sites in this document future decisions will be steered by the mentioning of such locations now. Statements are made in this document without the word "potential" even mentioned. Example, section B.6.1, paragraph discussing first and second layers, last sentence, which states "The proposed topsoil would be obtained from the McGee Ranch quarry site of the Hanford Site." This document appears to be trying to steer future decisions prior to exploring alternatives for borrow sites.
Throughout the document, the author states "future NEPA documentation will specifically address in detail impacts and mitigation of post-remediation tank closure where, for example most impacts of borrow site activities would occur" (page 5-258). The summary states "The impacts of closure cannot be meaningfully evaluated at this time. U.S. Department of Energy (USDOE) will conduct an appropriate NEPA review, such as an EIS, to support tank closure in the future." Since a meaningful analysis of impacts to potential borrow sites for post-remediation activities is not being undertaken by this EIS, WDFW requests all references to potential post-remediation borrow sites be deleted from the document (i.e., figures, tables, and text).
Response The TWRS EIS frequently states that the final selection for the borrow sites must be evaluated in the document for waste site and tank farm closure. The Summary states that, "The impacts of closure cannot be meaningfully evaluated at this time. DOE will conduct an appropriate NEPA review, such as an EIS, to support tank closure in the future." This question was also contained within the Notice of Intent to prepare the TWRS EIS.
Volume One, Section 3.6, states that, "The final selection of borrow sites for earthen material has not been made; however, the locations indicated represent potential borrow sites that would support each of the alternatives in both volume and location. Future borrow site decisions will be made in the ROD for the Hanford Remedial Action EIS."
Volume One, Section 4.5, states that, "The potential Vernita Quarry and McGee Ranch borrow sites have potential for both historic and prehistoric materials. Surveys have identified prehistoric or historic sites at both Vernita and McGee Ranch. The McGee Ranch area has been determined to be eligible for nomination to the National Register of Historic Places as the McGee Ranch/Cold Creek District. No prehistoric sites are known at the potential Pit 30 borrow site, although one structure from the homestead era is located at Pit 30." These statements are reiterated in Section 5.5 where it is stated that, "Archaeological surveys of the three potential borrow sites have identified a variety of prehistoric or historic artifacts and sites at the Vernita Quarry and McGee Ranch. The likelihood of disturbing additional archaeological sites in these areas is considered high." In addition, the archaeological importance of historic and prehistoric sites is reiterated in Volume One, Sections 5.5.1, 5.5.2, and 5.5.3.
Volume One, Section 5.17 identifies the potential Vernita Quarry and McGee Ranch borrow sites as undeveloped areas on the Hanford Site Development Plan's Future Land-Use Map. Further, using the potential Vernita Quarry site would involve expanding an existing quarry, while using the potential McGee Ranch borrow site would essentially be a newly developed site (though a small, old borrow area does exist). It is further stated that, "Planning for possible borrow sites for the TWRS program is still in its early stages and the CLUP and Hanford Remedial Action EIS address future land uses for the Site as a whole." Section 5.5.3 explains that any disturbance of the land surface, such as would occur in borrow site activity, is not compatible with the relationship between the Native Americans and the land.
Volume One, Section 5.20.1 states that, "Although much of the area proposed for the remedial activities is in areas currently disturbed, activities in some areas [primarily the Vernita and McGee Ranch borrow sites] have the potential to impact historic, prehistoric, or cultural sites. These areas have not been fully surveyed because they are potential borrow sites subject to change during final design. The final selection of borrow sites would be made through the Site Comprehensive Land Use Plan."
The discussion of alternatives uses these borrow sites as example locations for the materials that may be required for closure. Certainly, gravel and sand sources are required for construction of the facilities required for the various alternatives. In WHC-SD-WM-EV-103 and WHC-SD-WM-EV-104, Tables 6-12 and 9-12, respectively, state the assumption that an onsite gravel plant would provide crushed aggregate for concrete construction at a location 5 kilometers (km) (3 miles [mi]) from the construction site, the potential borrow site known as Pit 30.
Considering the earlier discussion, which states that the decisions for the borrow sites will be made elsewhere, that the prehistoric, historic, and cultural significance must be thoroughly evaluated, and the undeveloped status given to portions of the area land relationship with the Native Americans, DOE and Ecology do not believe that including these potential borrow sites alternatives for borrow sites. Using these named potential borrow sites provides only a basis to more completely discuss the potential impact of each of the alternatives covered in the TWRS Final EIS in terms of potential for traffic accidents with distance traveled, construction and operation emissions to the environment, a comparison between the alternatives, and an interrelated closure discussion for each of the various alternatives.
Comment Number 0019.07
WDFW
Comment Page 3-116, Tables 3.6.1, 3.6.2, and 3.6.3 If I were to open this EIS to this page, I would conclude from the titles of thee tables that a decision has been made on borrow site locations when in fact this document does not perform adequate NEPA analysis, i.e., a range of alternatives, for sources of different material types needed. WDFW requests all references to borrow site locations be deleted from the document since the impacts to borrow sites will require NEPA review.
Response Please refer to the response to Comment numbers 0019.03, 0072.08, and 0101.06. The EIS has been reviewed and revised as appropriate to clarify the assumed borrow sites as "potential" sites.
Comment Number 0072.123
CTUIR
Comment P 3-116: Tables 3.6.2. and 3.6.3.: These tables present figures that are for closure options. Because this EIS is a RETRIEVAL EIS, the tables are inappropriate and should be removed, or all of the closure options be equally presented.
Response The tables identified in the comment represent borrow materials required for the assumed closure scenario presented in the EIS. For more information on the closure assumption, please refer to the response to Comment numbers 0072.08 and 0019.03. As identified in the Draft EIS in Volume One, Section 3.3 closure is not within the scope of this EIS because there is insufficient information concerning the amount of contamination to be remediated. The amount and type of waste that remains in the tanks after remediation also may affect closure decisions. Closure as a landfill was included in all of the alternatives except the No Action and Long-Term Management alternatives so the alternatives could be meaningfully compared. This does not mean that closure as a landfill has been proposed or would be selected for final tank closure. Because the information contained in the Draft EIS is correct, no change to the text was made.
L.3.7 COMPARISON OF ACTIVITIES ASSOCIATED WITH ALTERNATIVES
Comment Number 0005.15
Swanson, John L.
Comment I find it strange that system costs is the only metric included in the summary description of each alternative in Section 3.0 ("Description and Comparison of Alternatives"). People are certainly interested in the costs, but the major concern on the part of the public appears to me to be in the perceived risk to their health and well-being. Couldn't/shouldn't summary data of some sort in that area be included in this section along with the cost data? If this is not done, I feel that you should change the title of this section to "Description and COST Comparison of Alternatives."
Response Volume One, Section 3.0 provides a description and comparison of the alternatives based on the characteristics of the alternatives themselves. These characteristics include cost. However, the section also provides a comparison of the processes inherent to each alternative; construction, operations, and post-remediation features of each alternative; the schedule, sequence of activities, and costs of each alternative; the amount of waste to be retrieved from the tanks, treated, and disposed of onsite verses offsite for each alternative. The potential environmental impacts associated with each of the alternatives are presented in Volume One, Section 5.0. In Volume One, Section 5.14, a summary table is provided that lists each alternative and all of the associated impacts as presented in Section 5.0. Additionally, a summary of those impacts was presented in the TWRS EIS Summary, Section S.7, which was prepared to accompany the EIS or to be read separately by individuals who did not want to read the entire EIS. The level of data and summarization of the data, as well as the presentation of the data and summary information provided the public and decision makers with the appropriate level of information in a format that was accessible considering the complexity of the proposed action and associated impacts. Because the information contained in the Draft EIS is correct, no change to the text was made.
Comment Number 0005.55
Swanson, John L.
Comment Why is the number of HLW shipments required for the Extensive Separations alternative ~50 percent as large as that for the Intermediate Separations alternative (page 5-146), when the ratio of the number of canisters is only ~10 percent as large?
Response The average rail trips per year calculated and reported in Volume One, Section 5.10, Trail Traffic Volumes, for the number of canisters generated as result of the Ex Situ Extensive Separations alternative has been modified in the Final EIS.
L.3.8 ALTERNATIVE CONSIDERED BUT DISMISSED
No comments were submitted for this topic.
L.3.9 MISCELLANEOUS
Comment Number 0005.59
Swanson, John L.
Comment Page vii of Volume Two contains incorrect definitions/descriptions of B Plant and T Plant.
Response According to two references, Hanford Tank Clean Up: A Guide to Understanding the Technical Issues (Gephart-Lundgren 1996), The Hanford Site: An Anthology of Early Histories (Gerber 1993), and T Plant (DOE 1994l), T Plant and B Plant were both constructed as plutonium removal facilities. Both facilities used the bismuth phosphate separation process. In later years, B Plant was used to remove cesium and strontium from acid waste pumped from the Plutonium-Uranium Extraction (PUREX) Plant. T Plant is currently used as a decontamination and repair facility. According to DOE 1994l, these plants, along with Z and U plants, for example, were given alphanumeric names due to 1940's wartime secrecy. These descriptions are provided in the Volume One Glossary. B Plant and T Plant were deleted from the Acronyms and Abbreviations list in Volume Two, Appendix B.
Comment Number 0005.60
Swanson, John L.
Comment On page B-9, an incorrect date is given for the start of the PUREX plant.
Response According to two references, Hanford Tank Clean up: A Guide to Understanding the Technical Issues (PNL 1996) and The Hanford Site: An Anthology of Early Histories (WHC 1992), the correct date for the PUREX Plant hot start up was January 1956. All applicable, incorrect references have been revised.
Comment Number 0022.04
Sims, Lynn
Comment There is no argument that Cold War Clean Up is extremely expensive. But inadequate clean up will be more expensive. Choosing less expensive options now will probably result in contaminated soils and water, serious loss of quality of life and health and perhaps loss of land use, trade, and commerce. Our costs now are a result of military production. Perhaps military clean up should be built in up front in the military budget since that is the department which seems to receive more funds than requested while DOE monitoring and clean up funds are slashed.
Finally, it must always be of paramount importance to remember that bomb production was implemented to protect this nation and that to skimp on efforts to clean up puts our homeland at serous risk forever.
Response Comment noted.
Comment Number 0025.01
Heart of America
Comment A public interest group distributed a questionnaire at the Spokane and Seattle, Washington public meetings. Listed below are the questions and a tally of the totals from the 33 individuals who submitted surveys. The agency responses follow after the summary of the questionnaire. Below each question in bold is the ranking system contained in the questionnaire (using a scale of 1 to 10). In parenthesis following the rank are the number of individuals who circled the number on this questionnaire.
Please tell us the degree to which you agree or disagree with the following proposals for Hanford's high-level nuclear wastes on a scale from one to ten with #1 being Strongly Disagree; #5 No Opinion; and #10 being Strongly Agree.
1. The current Tri-Party Agreement calls for retrieving 99 percent of the wastes from all of Hanford's high-level nuclear waste tanks by the year 2028 and turning it into some form of glass (vitrification). To what degree do you agree/disagree with the Tri-Party Agreement?
Rank: 1 (3) 2 (1) 3 (1) 4 5 6 (1) 7 (1) 8 (8) 9 (3) 10 (14) . N/A (2)
2. Leaving 75 percent of the high-level nuclear waste in the tanks forever, and filling them with cement or gravel after removing the most radioactive 25 percent would cost less than retrieving and vitrifying 99 percent of the waste. This is the Ex Situ/In Situ Combination alternative.
a. The cost savings claimed by USDOE for this option justify leaving most of the high-level nuclear waste in the tanks:
Rank: 1 (23) 2 (1) 3 (3) 4 (1) 5 6 7 (1) 8 (2) 9 (1) 10 (2)
b. USDOE has fully considered in the EIS the evidence that waste from tank leaks is moving towards groundwater and the risks this may pose to the Columbia River and future exposed populations from this alternative:
Rank: 1 (18) 2 (1) 3 4 5 (2) 6 7 (4) 8 (2) 9 (2) 10 (1) N/A (4)
c. Any alternative that leaves high-level nuclear waste in the tanks and in the soil beneath the tanks poses an unacceptable risk to the Columbia River and future generations.
Rank: 1 (1) 2 3 (1) 4 5 6 7 8 (2) 9 (3) 10 (27)
d. For the same reasons that the public voted in 1986 against Hanford being an underground high-level nuclear waste dump, leaving high-level nuclear waste in tanks or threatening groundwater is NOT acceptable:
Rank: 1 (2) 2 3 (1) 4 5 6 7 8 (4) 9 (2) 10 (25)
3. USDOE's Tank Waste Task Force (public interest groups, local governments, Tribes,...) urged USDOE to base decisions assuming that the wastes, after being vitrified, will stay at Hanford for a very long time, and not to assume USDOE will move the waste to its proposed Yucca Mountain repository. Do you agree/disagree with the advice:
Rank: 1 (6) 2 (1) 3 (2) 4 5 (5) 6 7 8 (1) 9 (7) 10 (11) N/A (1)
4. a. USDOE should use conservative assumptions that tank leaks move down to groundwater in less than 40 years, instead of claiming that leaks will stay close to the tanks and not reach groundwater for over 100 years:
Rank: 1 (1) 2 (1) 3 (1) 4 (1) 5 (1) 6 (1) 7 8 (3) 9 (2) 10 (23)
b. Because this EIS assumes tank leaks do not move quickly to groundwater, the EIS wrongly creates a bias in favor of delaying retrieval of all wastes from leaking single-shell tanks:
Rank: 1 (3) 2 (1) 3 4 5 (2) 6 7 (3) 8 (3) 9 10 (22)
5. a. Should the EIS drop (not include) the "repository fee" in its presentation of costs and as a basis for decision making?
Rank: Yes (22) No (12)
b. Does the inclusion of the repository costs appear to have biased the consideration of alternatives, including how one would weigh each alternative's risk versus costs?
Rank: Yes (26) No (4) N/A (3)
c. If the cost of the No Separations alternative (make all the waste into glass logs) were in the same price range as other alternatives when the hypothetical repository fee was not added onto it, would you urge that it be considered as a reasonable alternative to building multiple vitrification and separations plants:
Rank: Yes (19) No (10) N/A (5)
Response
Comment item number 1: Please refer to the response to Comment numbers 0047.03 and 0009.01.
Comment item number 2a: Please refer to the response to Comment number 0072.05.
Comment item number 2b: Please refer to the response to Comment number 0012.15.
Comment item number 2c: Please refer to the response to Comment number 0072.08.
Comment item number 2d: Please refer to the response to Comment numbers 0072.08, 0072.100, and 0072.111.
Comment item number 3: Please refer to the response to Comment numbers 0081.02.
Comment item number 4a: Please refer to the response to Comment numbers 0012.15 and 0030.02.
Comment item number 4b: Please refer to the response to Comment numbers 0012.15 and 0030.02.
Comment item number 5a: Please refer to the response to Comment numbers 0081.02 and 0004.01.
Comment item number 5b: Please refer to the response to Comment numbers 0081.02 and 0004.01.
Comment item number 5c: DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment numbers 0081.01 and 0004.01.
Comment Number 0027.03
Roecker, John H.
Comment Systems Engineering
In 1993 DOE proudly and loudly stated that it was going to use systems engineering to establish the requirements for both TWRS and also the Hanford Site. To my knowledge that has not been done in either case, yet here we are reviewing the EIS for implementing a very specific TWRS action. Looks to me as if the systems engineering commitment lasted about as long as the January 1994 Tri-Party Agreement. Two fundamental systems engineering actions are required to correct this situation. First, a top down requirements allocation from the site level to the program level is needed. Secondly, the TWRS Functions and Requirements Document, along with an integrated alternatives systems analysis, must be finalized and issued. I would request that issuance of the Final TWRS EIS be deferred until such systems engineering and analysis has been completed. Without such one cannot be sure that the right work is being performed or that the best alternative has been selected.
Response Since 1993, two systems engineering documents, TWRS Functions and Requirements (DOE/RL-92-60) and TWRS Systems Engineering Management Plan (DOE/RL-93-106) have been prepared. DOE conducted an independent Systems Requirements Review (SRR), submitted in November 1994, to validate the TWRS Functional Requirements Baseline. The SRR evaluated selected representative TWRS activities and identified the need for improvement in the implementation of systems engineering, quality of supporting documentation, and timeliness of testing assumed solutions and competitive alternatives. In response to the SRR, the TWRS System Requirements Review Action Plan (DOE/RL-95-74) was prepared, which addressed the findings presented in the SRR and presented the methodology for revising the Functional Requirements Baseline and developing the infrastructure required to support the functional requirements. Because the EIS and the TWRS Functions and Requirements have been developed concurrently, the conclusions of the TWRS Functional Requirements are anticipated to be consistent with the recommended alternative presented in the Final EIS. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives. Please refer to the response to Comment number 0101.07 for further discussion of systems engineering.
Comment Number 0027.04
Roecker, John H.
Comment Technical Balance
I wish I was more interested in the projected cost of housing in the Tri-Cities in the year 2040 because there sure is plenty of computer printout data on that and other similar items, but I am just not. Instead, I would like to see more of the technical data that supports such items as operating efficiency, number of canisters, process design, alternative costs, etc. I would like to request that the reams of computer printout data and modeling contained in the appendices be restrained a little and more of the basic technical data that really establishes how an alternative is going to perform be put into the EIS.
Response The technical data that support the areas of interest indicated (i.e., operating efficiency, number of canisters, process design, and alternative costs) are contained in the TWRS Administrative Record and are available for review. The data to support the performance capability of the recommended alternative will be contained in the detailed design document for that alternative, which will be prepared following the Final EIS. The evaluation criteria used in the EIS are defined by NEPA and are confined to impacts to the environment only. As such, the requested evaluation of alternative performance data is beyond the scope of this EIS, but will be contained in future documents.
Comment Number 0027.06
Roecker, John H.
Comment Use of Non-Optimized Alternatives
The alternatives described in the EIS represent first cut approaches and do not represent optimized alternatives that have been tuned utilizing good engineering principles. More recent optimized process design flowsheet and facility design data is available and should be used in the Final EIS. This optimized design will significantly reduce the estimated cost.
Response The purpose of the EIS is to examine bounding alternatives, including a No Action alternative. It is anticipated that the optimized process design flowsheet will be used during the detailed design of the waste retrieval, transfer, treatment, and storage facilities conducted during the demonstration phase of the preferred alternative. The TWRS baseline flowsheet is continually updated and optimized. In order to support the EIS schedule, the baseline data used for development of the Draft EIS was frozen in May 1995. NEPA requires the alternatives be compared on an equitable basis. The Draft EIS presents conceptual alternatives that were developed using common bases that allow equitable comparison. Please refer to the response to Comment number 0072.05.
Comment Number 0027.08
Roecker, John H.
Comment Cost Estimates
In this day of tight budgets the cost estimate for an alternative is a very critical item. It is impossible to understand the basis for any of the cost estimates with the information contained within the EIS itself. It is necessary to look up several reference documents. This is not the easiest task if you do not live in the Tri-Cities. It would be helpful if the backup information for the life cycle cost estimates could be included in an appendix. There are several of the existing appendices that could be greatly reduced to make room for this information. As an example, the over 50 pages devoted to socioeconomic impact could be reduced to approximately 10 pages. The endless tables representing computer modeling printout could be put in a reference document.
Response As stated in Volume One, Section 1.0, the EIS fulfills the requirement for an analysis of potential environmental impacts in the decision-making process. NEPA and The Washington State Environmental Policy Act (SEPA) provide decision makers with an analysis of environmental impacts (both positive and negative) of proposed actions for consideration during decision making. This EIS presents the impacts of the proposed action and its reasonable alternatives for review and comment by the public and interested parties. Because of the magnitude of the cost required to implement any of the alternatives, it was determined that cost estimates would be included in the EIS. The development and presentation of alternative cost estimates is not the primary purpose or major focus of an EIS. The development of bounding alternatives for the EIS would indicate the need to develop additional cost data for the decision-making process.
The technical data used to develop the alternatives presented in the EIS are contained in the TWRS EIS Administrative Record and DOE Reading Rooms and Information Repositories. The Administrative Record contains additional cost estimate detail. As indicated in the front of Volume One, EIS technical reports, background data, materials incorporated by reference, and other related documents are available at Seattle, Spokane, and Richland, Washington; Portland, Oregon; and Washington, D.C.
The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0027.09
Roecker, John H.
Comment My understanding of the capital cost estimates for the down sized facilities in the combination and Phased Implementation alternatives is that the sixth-tenths power rule was used. That is an absolute error. The sixth-tenth power rule does not work for these types of facilities. These facilities have a significant portion of their capital cost attributable to basic facility systems which are essentially independent of facility size. The sixth-tenth power rule works for facilities in which processing equipment makes up most of the capital cost. That is not the case with these waste processing facilities. That is something that must be fixed in the Final EIS. Conceptual cost estimates for the size facilities included in the EIS have been made. Why not use the available existing data which has backup rather than include erroneous data?
Response The cost estimating methodology has been reviewed for the Final EIS and revised cost estimates were completed for the Phased Implementation and combination alternatives. These revised costs are shown in Volume One, Section 3.4 and Volume Two, Appendix B. Please refer to the response to Comment numbers 0055.06, 0057.06, and 0035.06.
Comment Number 0030.01
Krieg, Ronald K.
Comment I am also disappointed in the limited scope that the inclusion of subsurface barrier technology in this Draft EIS was only as a potentially viable component to remediation alternatives, and am dissatisfied in Appendix B's level of analysis and conclusions of subsurface barrier technology. My other areas of concern involve the focus being on future impacts and conditions of alternatives alone with no regard to current or past practices. If the DOE is to develop a systematic approach to actually solving some problems in a truly cost effective manner with the least environmental impact, all aspects and pertinent details of all alternatives should be included in this EIS.
Response Subsurface barrier technology is discussed in Volume Two, Appendix B. Subsurface barriers are a potentially viable technology available to the decision makers. The EIS incorporates by reference (Treat et al. 1995) a detailed engineering feasibility study on subsurface barriers. Subsurface barriers were added as a potential mitigation measure in Volume One, Section 5.20 in the Final EIS. Please refer to the response to Comment number 0001.01.
All of the alternatives' future potential impacts are based upon an analysis of the potential impact of the alternatives themselves, without consideration of past or current practices, as appropriate. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0030.04
Krieg, Ronald K.
Comment The Hanford Federal Facility Agreement and Consent Order set a goal for the SSTs that no more than 1 percent of the tank inventory would remain as a residual following waste retrieval activities (3-31, Vol. 1). Many times it is stated that this retrieval criteria of 99 percent may not be achieved (3-101, Vol. 1). Residuals left in tanks would not meet the water protection requirements if additional closure action is not taken (6-30, Vol. 1), with these residuals having low solubility because substantial quantities of liquid was used in the attempt to dissolve or suspend wastes during retrieval (3-31, Vol. 1). Furthermore, performance of key alternative processes have been assumed in absence of substantive data. Cost estimates may have a high degree of uncertainty because some of the processes are unproven (3-100, Vol. 1).
The Tri-Party Agreement calls for total waste removal from Hanford's single- and double-shell tanks for processing and storage offsite, unless technically unfeasible. Throughout the EIS the word "uncertainties" is used regarding costs, COC inventories and volumes, technology performance, actual risks, and SST leakage quantities. It would be a shame to see uncertainty translate to unfeasibility. The time has come to eliminate uncertainty through a systematic, cost and risk effective remedial approach with the least long-term impacts to our future populace's health and environment.
Response As required by the CEQ, the TWRS Draft EIS identifies and analyzes the range of reasonable alternatives for the proposed action, which also includes a No Action alternative. All data that support the cost and impact analysis of each alternative are presented in an objective format for comparison by the decision makers and by the public during the comment period. However, the EIS is limited to the TWRS and evaluation of reasonable tank waste remedies. Under the Tri-Party Agreement, DOE and Ecology are bound to complete specific milestones related to tank waste remediation, and given the uncertainties listed in the comment, the Agencies have selected the Phased Implementation as the preferred alternative.
Identification and presentation of the many existing uncertainties was the method chosen by DOE and Ecology to complete the evaluations and publish the EIS. To consider and resolve all uncertainties before publication of the EIS would result in inordinate delay and failure to comply with the Tri-Party Agreement. Please refer to the response to Comment numbers 0005.03, 0072.05, and 0072.80 for discussions regarding regulatory requirements for bounding alternative analyses.
Comment Number 0030.05
Krieg, Ronald K.
Comment A recent report prepared by the National Research Council regarding containment-in-place technologies acknowledges subsurface barriers as an imperative use during remediation efforts and as a feasible interim solution to hazardous substance migration at Hanford and other Department of Energy sites. The committee's comparison of costs found retrieving and processing wastes costs $15 billion more (17.5 vs. $2.4 billion) than the alternative of in situ stabilization and isolation. I do not believe the Feasibility Study of Tank Leakage Mitigation Using Subsurface Barriers (WHC-SD-WM-ES-300) fully analyzed subsurface barrier technology and recommend what the National Research Council has; that containment-in-place technology be re-evaluated on its technical, fiscal, environmental, and public health merits as a possible short- or long-term alternative for radioactive waste management and inclusion as such in this EIS.
Another problematic issue is in Appendix B's level of analysis and conclusions of subsurface barrier technology, which failed to include information from the Feasibility Study of Tank Leakage Mitigation Using Subsurface Barriers regarding subsurface barriers' cost effectiveness when supporting clean closure activities. Although closure decision are not a part of this EIS, they are stated to be interrelated with the decisions made concerning remediation of tank wastes.
The conclusion I am referring to is stated: "The most cost effective individual action is adding a close-coupled subsurface barrier to support clean-closure. This result is lowering both risk and HI and the overall cost of the alternative. This apparent anomaly arises from the substantial reduction in contaminated soil and recovered contaminants requiring treatment when a subsurface barrier is used. The resulting cost savings more than offset the cost of installing the barrier (WHC-SD-WM-ES-300 Rev. 0, pg. 8-3). Information such as this must not be overlooked, forgotten, or excluded from this EIS.
A reduction in the financial risk involved with contaminant migration and the technical uncertainties of the ex situ technologies is possible and available now. The potential cost savings to TWRS could be in the $5-7 billion range if a 10-year delay in remediation costs could be attained through effective deployment of subsurface barrier technology. This principle would carry over to many other situations throughout the DOE complex. Mitigated through the use of effective subsurface barriers under the tanks a delay in start up could save money in two ways: 1) identical real budgets have lesser present value as they are postponed farther into the future, and 2) technology productivity improvements occur as time passes, further reducing real costs. This approach would allow the DOE to improve the design, construction, and operations of initial and full scale remedial operations to the SSTs.
Barriers for confinement-in-place of buried waste have been effectively used in many environmental remediation activities. Subsurface barriers provide a cost effective option for resolving the 200 Areas' management and remediation problems either as a short or long-term approach. With their continued development, cost efficient subsurface barrier technology providing the highest containment performance standards must be retained and given serious consideration on its technical fiscal, environmental, and public health merits for inclusion in this Draft EIS.
Response The subject report by the National Research Council, titled The Potential Role of Containment-in-Place an Integrated Approach to the Hanford Reservation Site Environmental Remediation, recommended that containment-in-place technology be considered and evaluated on its technical, fiscal, environmental, and public health merits as a possible short- or long-term alternative for radioactive waste management. Such analysis should be conducted on a site-specific basis.
For analysis in the EIS, alternatives that bound the full range of reasonable alternatives were developed. In order to bound the impacts associated with in situ disposal of the tank waste or tank leakage during waste retrieval activities, subsurface barriers were not assumed to be used. This does not preclude the use of subsurface barriers during remediation activities but provides an upper bound on the expected environmental impacts. Subsurface barriers would be beneficial for retrieval of wastes from known or suspected leaking tanks. This technology would be evaluated for tank-specific application. Subsurface barriers were added as a potential mitigation measure in Volume One, Section 5.20 in the Final EIS. Please refer to the response to Comment numbers 0001.01 and 0030.01.
Comment Number 0046.03
DiGirolamo, Linda Raye
Comment We ought to convert the WHOLE NUCLEAR INDUSTRY by forming a commission name NEW AGE ENERGY - touched upon by Mr. Browning - This NAE would begin research and development at Hanford while the DOE cleans up its awful mess...beginning immediately!
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste.
Comment Number 0054.01
Belsey, Richard
Comment Grout did not work because we had so many processes going on. At Savannah River, they are today using grout because they were able with relatively simple separations to clean out 99.99 percent of the high activity fraction. But Hanford kept on, the Hanford's performance assessment kept on bouncing back over, over, strung out over time saying give us more information, your I-129 releases from the grout are still rising at 10,000 years. You at least have to model it out to know where it is going to turn the corner. I raise this question because we have re-opened all of those issues almost like re-opening a wound and looking at an infection again and saying why are we doing this and I would council that in fact you all list other stabilization forms (grout and ceramics) in this Draft EIS. How did we come to glass. There has been both a rich scientific literature about stabilizing radionuclides in glass going back 20 or 30 years and whereas with other substances there is spotty science and particularly with ceramics and grout there are highly variable reactivity. You go down to Savannah River it is almost like a witches brew. They stir it up and they have to use this particular kind of stone or else the whole thing does not gel and same thing with ceramic. So from my perspective, science wise we have to be careful about changing the stabilized waste form and we also now have about a 20-year, nearly a 20-year experience, not our own, but with other people using glass particularly for the high-level wastes. So I think that we should clearly not make any change in the waste form because of the inherent delay that will come about and the one thing we can not afford to do is to delay. The delays have cost nearly a billion dollars now and every year we delay costs that much more with by and large no real value so we got to get on with it. So state clearly that you are not going to consider anything except glass and glass from whoever gets to do the job of cleaning this up. I will leave that for now. Thank you very much.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. NEPA requires that a full range of alternatives be examined in the EIS. This range of alternatives must include a No Action alternative, and may include other reasonable alternatives to allow analysis of a full range of alternatives. Some alternatives do not produce a glass waste form. Consequently, the EIS cannot omit glass from analysis as the waste form for a given alternative. It should be emphasized that for the ex situ alternatives, glass was the primary waste form to be produced. Similarly, the EIS also discusses alternate immobilization technologies to allow their analysis. These technologies were not included in the alternatives developed for impact analysis, but may serve as potential components of a remediation alternative. The discussion of alternate technologies, including grout, will be found in Volume Two, Section B.9.0. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted. Please refer to the response to Comment numbers 0005.40, 0005.18, 0072.179, and 0009.08 for a discussion of issues related to grout.
Comment Number 0058.01
Swanson, John L.
Comment I have heard tonight different people give their biases. They blame somebody else for subjective judgement while they are drawing their own. In recent years have used a saying many times that I will repeat here. It applies to these costs analyses and comparisons of alternatives and that is the assumptions drive the conclusions.
Response When assumptions were made in the EIS, every effort was taken to ensure that these assumptions were applied equitably among the alternatives to ensure comparability. Please refer to the response to Comment number 0005.03.
Comment Number 0059.02
James Jordan Associates
Comment A brief white paper entitled, A Comparison of BNL's Small Modular HLW Treatment System with a Large Central Melter System is attached in support of JJA's request to include the BNL concept in the EIS analysis. Finally, an economic analysis of the estimated costs of producing high-level radioactive glass using the Small Module Inductively Loaded Energy concept invented by BNL is attached to this request. JJA has formally requested that the BNL concept be developed for possible use at Hanford and other DOE sites.
Response Alternatives were developed that bound the full range of reasonable alternatives and reflect the results of the public scoping process for the EIS and discussed in Volume One, Section 1.2. Representative alternatives that incorporate the range of cost, human and ecological health risk, and technologies have been developed for analysis in the EIS. The alternatives in the EIS have been developed to bound the applicable alternative technologies, including the one proposed by the commentor. Because the EIS contains bounding alternatives that will be presented to the decision makers, no change has been made to the EIS. Please refer to the response to Comment numbers 0072.05 and 0072.79.
Comment Number 0062.02
Longmeyer, Richard
Comment My second comment is with regard to the privatization. I have some concerns with regard to safety issues, as well as issues such as water quality issues. Both groundwater, and the Columbia River. The question is will the private contractors treat groundwater and the Columbia River with the same care that the government has been mandated to treat it, under the Tri-Party Agreement? Will they hold to the same safety guidelines, or perhaps better guidelines, that would be something that I would be interested to know.
Response Privatization is not within the scope of the EIS, as discussed in Volume One, Section 3.3 on page 3-13 of the Draft EIS, because it is a contracting mechanism. Under this concept, DOE would competitively bid a portion of the remediation work instead of having the Site Management and Operations contractor perform the work. Equivalent requirements for retrieval, treatment, and disposal of the waste, as well as quality and performance verification, would apply regardless of how DOE contracts to perform the remediation. Please refer to the response to Comment numbers 0009.19, 0060.02, and 0076.03.
Comment Number 0072.15
CTUIR
Comment It is difficult to follow the constituents through the various processes and into the environment. A mass balance showing distribution of the constituents for the tanks into various waste forms, effluents, and the environment would be helpful.
Response The detailed technical data developed to assess the environmental impacts of the alternatives addressed in the EIS are contained in referenced technical documents and calculations. The technical data are available for public review as a part of the TWRS EIS Administrative Record and in DOE Reading Rooms and Information Repositories. A mass balance for each of the waste treatment alternatives was completed in order to estimate the off-gas and liquid effluents. These off-gas and effluents streams then were used as sources in the risk assessment analysis. The human and ecological health effects from these off-gas and effluent streams are addressed in Volume One, Section 5.11. The TWRS EIS is a lengthy document and the inclusion of the detailed conceptual engineering information into the EIS would greatly lengthen the document. DOE and Ecology must balance the need to present relevant supporting data against the need to have a manageable and understandable document. The information requested in the comment is a level of detail that DOE and Ecology believe is not necessary for meaningful discrimination among the alternatives.
Comment Number 0072.196
CTUIR
Comment P B-166: Sect. B.7.1: It is noted that the evaluation for potential sites does not indicate that the affected Tribes were not notified or consulted with. If they were, please produce references, if they were not, please contact technical representatives of the affected Tribes.
Response The Draft EIS identifies in Volume Two, Section B.7 that the final site selection for the facilities associated with the ex situ alternatives has not been made. The potential site locations indicated in the EIS were taken from Hanford Site studies that examined potential site locations for the treatment facilities required for tank waste remediation and are included as examples for calculation of environmental impacts. The identification of these sites, within the 200 Area Waste Operations areas, is consistent with the Hanford Site Development Plan and the recommendations of the Hanford Tank Waste Task Force. As indicated in Volume One, Section 5.20, before to any ground disturbance activities, consultations would be conducted with the DOE Richland Operations Office Historic Preservation Officer, the Hanford Cultural Resource Laboratory, Washington State Historic Preservation Officer, and concerned Native American Tribal groups and governments. Consultation with Tribal Nations groups and governments would be performed early in the planning process to determine areas or topics of importance to these groups such as religious areas and potential resources of medicinal plants. Please refer to the response to Comment number 0072.149 for a discussion of the Tribal Nation consultation process for the TWRS EIS. Please refer to the response to Comment numbers 0019.03, 0072.235, 0072.50, and 0101.06 for related borrow site and closure information.
Comment Number 0072.236
CTUIR
Comment P E-202: Sect. E.10.2: Although not clearly stated, this appears to be the preferred alternative. Please confirm. Additionally, it appears that the only alternative for MUSTs involves filling them with grout (sand, gravel and cement). As we have stated on several prior occasions, the selection of an alternative that results in irretrievable waste forms may be unacceptable.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. There has been no attempt in the accident analyses or at the location referenced in the comment to identify any alternative as the preferred alternative. The preferred alternative is identified in the Summary, Section S.7 and Volume One, Section 3.4. For the ex situ alternatives, the MUST waste would be retrieved and only the residual left in the tanks would be grouted. Grouting of the MUST was included in the analysis to facilitate a balanced comparison of the alternatives. Closure of the MUSTS, like closure of the tank farms, will be the subject of future NEPA analysis. For each of the alternatives presented in Volume One, Section 3.4 and Volume Two, Appendix B, remedial actions for MUST waste are described. Because the information requested in the comment was included in the Draft EIS, no modification to the document is warranted.
Comment Number 0083.01
Pollet, Gerald
Comment Hanford's Dangerous Nuclear Waste Tanks
They can explode! They do leak! Leaked waste will poison the Columbia River! So why does the U.S. Department of Energy want to consider leaving 75 percent of the waste in the tanks forever? Is this your idea of clean-up?
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. The EIS includes an analysis of potential accidents, including explosions, in Volume One, Section 5.12 and Volume Four, Appendix E. Past tank leaks are discussed in Volume One, Section 5.4.2. A discussion of the potential cumulative impacts of past tank leaks and the TWRS alternatives is provided in Volume One, Section 5.13 and Volume Four, Appendix F. The regulations (40 CFR 1500 to 1508) that implement NEPA requirements that an EIS address the full range of reasonable alternatives. For the TWRS EIS, the full range of reasonable alternatives was determined to range from leaving all of the waste in the tanks to retrieving as much of the waste as practicable (assumed to be 99 percent) and alternatives that fall between these two extremes. The DOE and Ecology preferred alternative is to retrieve 99 percent of the waste to the extent technically practicable. Please refer to the response to Comment numbers 0072.05 and 0009.01.
Comment Number 0085.03
Klein, Robin
Comment In the mean time we're calling for funding to develop real solutions. Not just for Hanford tank wastes, but to address soundly the global problem of disposing of dangerous radioactive materials worldwide. At the same time we're being asked to comment on TWRS. I'm going on a slight tangent here on purpose. We're also being asked to comment on the PEIS for disposition of weapons usable fissile materials nation wide. There we are faced with the ominous alternative, possibility of processing the worlds stores and reactors, with the likelihood that this could occur at Hanford. I hope that in parallel, with comments on what to do with the tank wastes, we don't lose sight of the pressure mounting to fire up reactors once again along the Columbia River. This is a non-solution to a problem, for which there is no good solution. Maybe if just a fraction of the dollars that were spent on developing those horrific weapons were spent on coming up with a permanent real solution, funding those great minds at the labs in Los Alamos Sandia, we'd probably stand a chance, and I believe we would. After all, that stuff's going to be around a while one way or another. But don't revive a failing nuclear industry at the price of health and safety of our futures.
Response DOE and Ecology acknowledge the preference expressed in the comment and will take this preference and other public comments into consideration when making a final decision on remediating the TWRS waste. Please refer to the response to Comment number 0040.01 for a discussion of factors influencing the evaluation of alternatives. Congressional funding issues are not included in the scope of this EIS. However, Volume One, Section 5.13 (Cumulative Impacts) addresses actions at other DOE sites and programmatic actions that could impact the Hanford Site, actions adjacent to the Hanford Site, and planned or reasonably foreseeable DOE actions at the Hanford Site.
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