[Federal Register Volume 62, Number 38 (Wednesday, February 26, 1997)]
[Notices]
[Pages 8693-8704]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 97-4696]
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DEPARTMENT OF ENERGY
Record of Decision for the Tank Waste Remediation System, Hanford
Site, Richland, WA
AGENCY: Department of Energy.
ACTION: Record of decision.
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SUMMARY: This Record of Decision addresses actions by the U.S.
Department of Energy (DOE) to manage and dispose of radioactive,
hazardous, and mixed waste within the Tank Waste Remediation System
(TWRS) program at the Hanford Site in southeastern Washington State.
DOE, in cooperation with the Washington State Department of Ecology
(Ecology), issued a Final Environmental Impact Statement (EIS) entitled
``Tank Waste Remediation System, Hanford Site, Richland, Washington,
Final Environmental Impact Statement'' (TWRS EIS) (DOE/EIS-0189, August
1996). The Final EIS evaluates alternatives for the management and
disposal of mixed, radioactive, and hazardous waste currently stored or
projected to be stored in 177 underground storage tanks and
approximately 60 active and inactive miscellaneous underground storage
tanks associated with the Hanford Site's tank farm operations, as well
as the management and disposal of approximately 1,930 cesium and
strontium capsules currently stored at the Hanford Site.
Based on the environmental impact analysis of the Final EIS and
after evaluating costs, regulatory compliance requirements, technical
uncertainties, worker and public health and safety, and public, agency,
National Research Council, and Tribal Nation comments, DOE has decided
to implement the preferred alternative identified in the Final EIS for
retrieval, treatment, and disposal of tank waste the, ``Phased
Implementation alternative'' and to defer the decision on disposition
of cesium and strontium capsules.
The Phased Implementation alternative was selected because it
provides a balance among short-and long-term environmental impacts,
meets all regulatory requirements, addresses the technical
uncertainties associated with remediation, and provides the flexibility
necessary to accommodate future changes in the remediation plans in
response to new information and technology development.
While carrying out this decision, DOE will continually evaluate new
information relative to the tank waste remediation program. DOE will
also conduct periodic independent scientific and technical expert
reviews, which DOE believes are essential to the success of the TWRS
program. Further, DOE intends to conduct formal evaluations of new
information relevant to the tank waste remediation program at three key
points over the next eight years under its National Environmental
Policy Act (NEPA) regulations (10 CFR 1021.314), with an appropriate
level of public involvement, to ensure that DOE stays on a correct
course for managing and remediating the tank waste. Various informal
reviews also will be conducted during this period.
DOE has decided to defer action on the cesium and strontium
capsules to further evaluate potential beneficial uses of the capsules
and study potential long-term environmental impacts. The capsules will
continue to be managed in the Hanford Site Waste Encapsulation and
Storage Facility. DOE will complete an evaluation for potential future
uses of the capsules within two years and will issue a Cesium and
Strontium Management Plan that will address alternatives for beneficial
uses. If no future uses are found and DOE determines that the capsules
should be disposed of, DOE will select an alternative for disposal of
the capsules and supplement this Record of Decision.
ADDRESSES: Addresses of DOE Public Reading Rooms and Information
Repositories where the Final EIS, Record of Decision, and other
relevant information are available for public review are listed at the
end of this Record of Decision. The Final EIS and Record of Decision
are also available for review on the Internet at www.hanford.gov/eis/
twrseis.htm and on the DOE NEPA Web page (http://tis-nt.eh.doe.gov/
nepa).
FOR FURTHER INFORMATION: Requests for copies of the Record of Decision
or further information on the Final EIS or Record of Decision should be
directed to Carolyn Haass, DOE Tank Waste Remediation System EIS NEPA
Document Manager, U.S. Department of Energy, Richland Operations
Office, P.O. Box 1249, Richland, WA 99352. Ms. Haass may be contacted
by telephone at (509) 372-2731. Information on the DOE NEPA process may
be requested from Carol M. Borgstrom, Director, Office of NEPA Policy
and Assistance (EH-42), U.S. Department of Energy, 1000 Independence
Avenue S.W., Washington, D.C. 20585. Ms. Borgstrom may be contacted by
telephone at (202) 586-4600, or by leaving a message at (800) 472-2756.
[[Page 8694]]
SUPPLEMENTARY AGENCY INFORMATION:
Purpose and Need for Action
This Record of Decision addresses actions by DOE to manage and
dispose of radioactive, hazardous, and mixed waste within the Tank
Waste Remediation System (TWRS) program at the Hanford Site in
southeastern Washington State. The waste includes approximately 212
million liters (56 million gallons) of waste stored or to be stored in
underground storage tanks at the Hanford Site. DOE also will manage the
cesium and strontium salts contained in approximately 1,930 capsules
currently stored at the Site and, if they are determined to be waste,
will dispose of the capsules. The tank waste and cesium and strontium
capsules currently pose a low short-term risk to human health and the
environment; however, storage costs are high, and the potential for an
accident resulting in large releases of radioactive and chemical
contaminants will increase as the facilities age.
DOE must implement long-term actions to safely manage and dispose
of the tank waste, associated miscellaneous underground storage tanks,
and the cesium and strontium capsules (if the cesium and strontium are
determined to be waste) to permanently reduce potential risk to human
health and the environment. These actions also are needed to ensure
compliance with all applicable Federal and Washington State
requirements regarding the management and disposal of radioactive,
hazardous, and mixed waste.
Alternatives Considered in the Final EIS
The following describes the alternatives considered in the Final
EIS and a discussion of their advantages and disadvantages.
In order to compare the alternatives for both the high- and low-
activity fractions of the waste, vitrification was used as a
representative technology to conduct the EIS analysis. DOE currently
plans to implement parts of the Phased Implementation alternative
through a privatization initiative whereby private companies will
perform certain aspects of the remediation in an effort to use
competition within the marketplace to bring new ideas and concepts to
waste remediation and reduce project costs. Under current plans, the
selected private companies will have the responsibility to treat the
high-level waste using vitrification, and will have the option to
immobilize the low-activity waste by either vitrification or other
similar immobilization methods provided that the final waste form meets
regulatory requirements. (DOE has issued contracts to two companies to
design tank waste treatment facilities--both companies had proposed
vitrifying low-activity waste.)
Tank Waste Alternatives Considered
Phased Implementation (Preferred Alternative)
The Phased Implementation alternative was identified in the Final
EIS as the Preferred Alternative. Under the Phased Implementation
alternative, the tank waste would continue to be safely stored until
the waste is retrieved from the tanks for treatment and disposal by
implementing a demonstration phase (Phase I) to verify that the
treatment processes will function effectively and then by implementing
a full-scale production phase (Phase II).
During Phases I and II, continued operations of the tank farm
system and actions to address safety and regulatory compliance issues
would be performed and would include:
Upgrading tank farm infrastructure, including waste
transfer, instrumentation, ventilation, and electrical systems;
Monitoring tanks and equipment to support waste management
and regulatory compliance requirements;
Combining compatible waste types, interim stabilization of
single-shell tank waste, continuing waste characterization, removing
pumpable liquid from single-shell tanks, transferring newly generated
waste from ongoing Site activities to double-shell tanks, operating the
242-A Evaporator and the Effluent Treatment Facility, and performing
mitigative actions to resolve tank safety issues;
Using rail or tanker truck systems to transport waste to
the tank farms;
Completing construction of and operating the new
replacement cross-site transfer system to facilitate regulatory
compliant waste transfers from 200 West to 200 East Area and continue
operating the existing transfer pipeline system until the replacement
system is operational; and
Installing and operating an initial tank waste retrieval
system to improve the capacity to consolidate double-shell tank waste
and support mitigation of safety issues.
Phase I activities (Part A, development activities; Part B
demonstration) activities would last for approximately 10 years and
would include:
Constructing demonstration-scale facilities to produce
vitrified low-activity waste and vitrified high-level waste for future
disposal;
Installing and operating tank retrieval systems to
retrieve selected waste (primarily liquid waste) for separations and
immobilization, and selected tank waste for high-level waste
vitrification;
Transferring liquid waste to receiver tanks and
transferring selected waste for high-level waste processing directly to
the high-level waste facility;
Performing separations to remove selected radionuclides
(e.g., cesium) from the low-activity waste stream;
Storing separated high-level waste at the treatment
facilities or in the Canister Storage Building pending future high-
level waste treatment;
Returning a portion of the sludge, strontium, and
transuranic waste from separations processes to the double-shell tanks
for future retrieval and treatment during Phase II;
Vitrifying the low-activity waste and high-level waste;
and
Transporting the low and high activity wastes to onsite
interim storage facilities.
Phase II (full-scale production) activities would begin after
completion of Phase I, last for approximately 30 years and would
include:
Constructing full-scale facilities to vitrify low-activity
waste and vitrify high-level waste;
Installing and operating tank retrieval systems to
retrieve waste from all single-shell tanks, double-shell tanks, and
miscellaneous underground storage tanks;
Pretreating the waste by sludge washing and enhanced
sludge washing followed by separations of the liquid and solids;
Performing separations to remove selected radionuclides
from the low-activity waste feed stream and transferring the waste to
the high-level waste vitrification facility;
Vitrifying the high-level waste stream and the low-
activity waste stream;
Packaging the high-level waste in canisters for onsite
interim storage and future shipment to a national geologic repository;
and
Placing the immobilized low-activity waste in containers
and placing the containers in onsite near-surface disposal facilities.
DOE also would continue to characterize the tank waste and perform
technology development activities to reduce uncertainties associated
with remediation, evaluate emerging technologies, and resolve
regulatory compliance issues.
The principal advantages of the Phased Implementation alternative
are
[[Page 8695]]
that it provides for retrieval of the waste, separation of the high-
and low-activity waste constituents and immobilization of the waste.
Separations processes would reduce the volume of high-level waste and
eliminate the bulk of the contaminants in the low-activity waste
stream. This alternative would permanently isolate the wastes from
humans and the environment to the greatest extent practicable and
provide for protection of public health and the environment by
disposing of the bulk of the radionuclides offsite in a national
geologic repository and isolating the low-activity waste through
immobilization and disposal in onsite facilities. By using a phased
approach, DOE will obtain additional information concerning the
uncertainties associated with waste characteristics and the
effectiveness of the retrieval, separations, and treatment technologies
prior to constructing and operating full-scale facilities. Lessons
learned from the demonstration phase, ongoing waste characterization,
and technology development activities would be applied to Phase II,
which may substantially improve the operating efficiency of the second
phase and reduce construction and operating costs.
The principal disadvantage of this alternative is that it would
involve slightly higher short-term impacts than the in situ and
combination alternatives, though lower than the continued management
alternatives. Short-term impacts include potential health impacts
during Phases I and II from occupational, operational, and
transportation accidents and radiation exposures to workers during
normal operations. In addition, this alternative would disturb shrub-
steppe habitat and may cause a short-term strain on public services
during construction activities. This alternative would also cost more
than the in situ alternatives.
Other Tank Waste Alternatives Considered
The Final EIS analyzed nine other alternatives for the tank waste.
All of the alternatives considered include continuing the current tank
farm operations to maintain the tanks and associated facilities until
they are no longer needed for waste management. All of the alternatives
(except No Action) include upgrading tank farm systems as identified
for the Phased Implementation alternative. The following are the other
alternatives addressed.
1. No Action
Perform minimum activities required for safe and secure management
of the Hanford Site's tank waste with the current tank farm
configuration during a 100-year period. This alternative would provide
for continued storage and monitoring of tank waste. No construction or
remediation activities would be performed under the No Action
alternative.
The principal advantage of this alternative is that the short-term
environmental impacts would be lower than other alternatives analyzed
(except operational accidents which would be high due to the assumed
100-year operating period). The cost estimated for this alternative
would be lower than most other alternatives. The degree of technical
uncertainty associated with this alternative is low because it is a
continuation of ongoing activities. Selection of this alternative would
also allow time to develop new waste remediation technologies.
The principal disadvantage of this alternative is that it would
result in the highest long-term environmental impacts. Because no
action would be taken to immobilize or isolate the waste, the
contaminants in the waste would migrate to the groundwater in a
relatively short period of time, resulting in contamination of the
groundwater far above accepted safe levels and drinking water
standards. Persons consuming this contaminated groundwater would have a
significant risk of contracting cancer. In addition, this alternative
would not meet waste disposal laws, regulations, and policies. This
alternative eventually would result in continued deterioration of the
structural integrity of the tanks and an increased risk that an
earthquake would cause a catastrophic release of tank contents to the
environment and the potential for a large number of fatalities. Because
all of the waste would remain in the tanks in an unstabilized form,
there would be a significant human health risk to inadvertent intruders
into the waste after any loss of administrative control of the Site.
2. Long-Term Management
Perform minimum activities required for safe and secure management
of the Hanford Site's tank waste during the 100-year administrative
control period. This alternative is similar to the No Action
alternative, except that the waste transfer system would be upgraded
and the double-shell tanks would be replaced twice during the assumed
100-year administrative control period to prevent the potential leakage
of large volumes of liquid to the environment from the double-shell
tanks. No waste remediation would be performed under this alternative.
The principal advantage of this alternative is the same as for the
No Action alternative except that leaching of contaminants into the
groundwater from the double-shell tanks would be delayed by 100 years
due to the tank replacement program.
The principal disadvantages of this alternative are the same as for
the No Action alternative except that the long-term impacts to the
groundwater would be slightly lower than the No Action alternative.
3. In Situ Fill and Cap
Retrieve and evaporate liquid waste from the double-shell tanks,
fill single-and double-shell tanks with gravel, fill miscellaneous
tanks and ancillary equipment with grout, and cover the tank farms with
a low permeability earthen surface barrier, disposing of all tank waste
onsite.
The principal advantages of this alternative are that the short-
term environmental impacts (accident fatalities, radiation exposures,
and shrub-steppe habitat disturbance) would be low and the estimated
cost would be lower than for all other alternatives. The degree of
technical uncertainty associated with this alternative is low because
it involves applying common technology, which has a high probability of
achieving its projected level of effectiveness for most tanks.
The principal disadvantages of this alternative are that it would
have relatively high long-term environmental impacts due to
contaminants leaching into the groundwater where they could expose
persons who might consume the groundwater, and it would not meet waste
disposal laws, regulations, or policies. Because the actions taken for
this alternative involve isolation but not immobilization of the waste,
the contaminants would migrate to the groundwater over a long period of
time and result in significant long-term impacts on public health and
the environment. In addition, this alternative may not be feasible for
those tanks that generate high levels of flammable gases because of the
potential for sparks causing a fire in the tanks while filling with
gravel. Other types of fill material may be necessary for these tanks.
Because all of the waste except the liquid waste in the double-shell
tanks would remain in the tanks in an unstabilized form, there would be
a significant human health risk to inadvertent intruders into the waste
[[Page 8696]]
after any loss of administrative control of the Site.
4. In Situ Vitrification
Retrieve and evaporate liquid waste from the double-shell tanks,
fill the tanks with sand, vitrify (melt to form glass) all of the tanks
in place, and cover all of the tank farms with an earthen surface
barrier to dispose of all tank waste onsite. This alternative would
involve constructing tank farm confinement facilities to contain and
collect the off-gasses generated during the vitrification process. The
waste, tanks, and soil surrounding the tanks (including miscellaneous
underground storage tanks) would be vitrified by using electricity to
melt the soil and waste, which would solidify into a glass when cooled.
The principal advantages of this alternative are that the short-
and long-term impacts would be relatively low. The short-term impacts
such as occupational, operational, and transportation accidents would
be lower because fewer personnel would be required to construct and
operate the in situ vitrification systems. The long-term impacts would
be low because the contaminants would be immobilized in glass, which
would limit the leaching of contaminants to the groundwater.
The principal disadvantages of this alternative are that there is a
high degree of technical uncertainty that the alternative would
function as intended, and that, even if technically successful, would
not produce a final waste form that would meet waste disposal laws,
regulations, or policies. In situ vitrification has been performed on
contaminated soil, but has not been used on the tank waste or at the
scale needed to vitrify the large tanks.
5. Ex Situ No Separations
Retrieve waste from the single-shell, double-shell, and
miscellaneous underground storage tanks, either vitrify or calcine
(heat to temperatures below the melting point) the waste, and package
the treated waste for interim onsite storage and eventual offsite
disposal at a national geologic repository.
The principal advantages of this alternative are that the
vitrification option would meet all regulatory requirements and both
the vitrification and calcination options would result in disposal of
all retrieved waste offsite at a national geologic repository. Because
this alternative does not involve separations, the technical
uncertainties are fewer than those associated with other ex situ
alternatives that involve intermediate or extensive separations.
The principal disadvantages of this alternative are that the waste
form (either soda-lime glass for vitrification or compacted powder for
calcination) may not meet the current waste acceptance criteria at a
national geologic repository and the volume of waste to be disposed of
at a national geologic repository would be very large and would likely
exceed the capacity of the first repository. The costs associated with
disposing of all the waste at a national geologic repository make this
the most expensive alternative.
6. Ex Situ Intermediate Separations
Retrieve waste from the single-shell, double-shell, and
miscellaneous underground storage tanks and separate the waste into
high-level and low-activity waste streams using sludge washing,
enhanced sludge washing, and ion exchange, then vitrify the waste
streams in separate facilities. Dispose of the low-activity waste
onsite and the high-level waste offsite at a national geologic
repository.
The principal advantages of this alternative are that it would meet
all regulatory requirements and result in relatively low long-term
impacts because the high-level waste would be disposed of offsite in a
national geologic repository and the low-activity waste onsite would be
immobilized and isolated in onsite disposal facilities covered with an
earthen barrier.
The principal disadvantage of this alternative is that it involves
a moderate level of technical uncertainty because the alternative would
involve construction and operation of treatment facilities where some
of the proposed technologies are first-of-a-kind or have not been
demonstrated on Hanford Site tank waste. This alternative would involve
a potential for higher short-term impacts than the in situ alternatives
because of the nature and extent of the activities required for
construction and operation of the full-scale waste treatment
facilities. These impacts would include potential health impacts from
occupational, operational, and transportation accidents and radiation
exposures during normal operations.
7. Ex Situ Extensive Separations
Retrieve waste from the single-shell, double-shell, and
miscellaneous underground storage tank waste and use a large number of
complex chemical separations processes to separate the high-level waste
components from the recovered tank waste. Vitrify the waste streams in
separate facilities and dispose of the low-activity waste onsite and
the high-level waste offsite at a national geologic repository.
The principal advantages of this alternative are that it would meet
all regulatory requirements and, due to the extensive separations
processes, would result in the smallest volume of high-level waste for
offsite disposal. Due to the extent of the separations processes, the
low-activity waste that would remain onsite would have lower
radioactive contaminant concentrations than the other ex situ
alternatives.
The principal disadvantages of this alternative are that it
involves the highest degree of technical uncertainty and highest
treatment cost among the ex situ alternatives because of the numerous
complex separations processes. This alternative would involve slightly
higher short-term impacts than the in situ and combination
alternatives, though lower short-term impacts than the continued
management alternatives. These impacts include potential health impacts
from occupational, operational, and transportation accidents and
radiation exposures during normal operations.
8. and 9. Ex Situ/In Situ Combination 1 (Alternative 8) Ex Situ/In Situ
Combination 2 (Alternative 9)
Retrieve tank waste (approximately 50 percent of the waste volume
for the Combination 1 alternative and 30 percent for the Combination 2
alternative based on long-term risks the contents of the various tanks
pose to human health and the environment); separate the retrieved waste
into high-level and low-activity waste streams using an intermediate
level of separations; then vitrify the waste streams in separate
facilities. Dispose of the low-activity waste onsite and the high-level
waste at an offsite national geologic repository. Waste in tanks not
selected for retrieval would be remediated identical to the In Situ
Fill and Cap alternative.
The principal advantage of these alternatives is that they offer
the opportunity to lower the remediation cost by remediating the waste
in selected tanks based on waste characteristics and contribution to
post-remediation risk. The waste that provides the greatest long-term
potential human health risks would be remediated. The Combination 2
alternative would have lower remediation costs than the Combination 1
alternative because a smaller volume of waste would be processed. These
alternatives would result in short-term impacts (occupational,
operational, and transportation accidents and shrub-steppe habitat
disturbance) that are generally lower than those for the ex situ
alternatives because smaller
[[Page 8697]]
facilities and fewer personnel would be required to process a smaller
volume of waste.
The principal disadvantages of these alternatives are that they
would not meet waste disposal laws, regulations, and policies. The ex
situ portion of these alternatives would have the same technical
uncertainties as the Ex Situ Intermediate Separations alternative. The
in situ portion of these alternatives would result in higher long-term
impacts than the ex situ alternatives because the waste disposed of in
situ would leach contaminants into the groundwater over a long period
of time and expose persons who might consume the groundwater. The
Combination 2 alternative would leave more waste disposed of in situ
and result in higher long-term impacts than the Combination 1
alternative.
Environmentally Preferable Alternative--Tank Waste
Identifying environmental preferences among alternatives for the
tank waste remediation program requires consideration of the short-term
human health and environmental impacts, long-term human health and
environmental impacts, and the associated uncertainties in the impact
assessment process, including technology performance. There are
alternatives that would result in low short-term impacts but relatively
high long-term impacts, and identifying the environmentally preferable
alternative(s) requires judgment concerning these impacts. Comparing
short-term human health impacts with long-term human health impacts is
complicated by the fact that short-term impacts can be estimated with a
greater degree of certainty than long-term human health risks.
In making these comparisons, DOE considered that most estimated
short-term impacts involve risks to workers during remediation that are
voluntary and can be reduced by applying appropriate worker protection
measures. In contrast, the estimated long-term impacts are involuntary
in nature because they would result from inadvertent exposure of future
populations to contaminant releases.
The In Situ Vitrification alternative would have lower human health
and environmental impacts than the other alternatives, if this
technology functioned adequately. This alternative would result in the
lowest potential short-term human health impacts, other than the In
Situ Fill and Cap alternative, and the lowest long-term human health
and environmental impacts. However, in situ vitrification has never
been performed at the scale necessary to remediate the Hanford tank
waste and there is a high degree of technical uncertainty associated
with this alternative. Even with extensive technology research and
testing, it may not be feasible to develop this technology to the
extent that it would function adequately. If this alternative did not
function as designed, the long-term impacts on groundwater and future
users of the groundwater would be higher. While the In Situ Fill and
Cap alternative would result in the lowest short-term impacts, it also
would have significant long-term impacts on the groundwater and future
users of the groundwater.
On balance, the ex situ alternatives are environmentally preferable
to in situ alternatives because they provide for the permanent
isolation of contaminants from the human environment. Among the ex situ
alternatives, Phased Implementation is environmentally preferable
because it offers the best potential to reduce technology risks and
uncertainties relevant to both short-term and long-term impacts, while
also providing for treatment and disposal of tank wastes to the
greatest extent technically and economically practicable.
Cesium and Strontium Capsules Alternatives Considered
For the purposes of analyzing impacts in the TWRS EIS, it was
assumed that the cesium and strontium capsules will remain in the Waste
Encapsulation and Storage Facility at the Hanford Site until ready for
final disposition. The Waste Encapsulation and Storage Facility is
being isolated from B Plant, which previously provided waste handling
and utility support. B Plant is scheduled for deactivation.
No Action
No Action was identified in the Final EIS as the preferred
alternative and includes the continued storage of the capsules in the
Hanford Site Waste Encapsulation and Storage Facility for 10 years. The
cesium and strontium capsules are currently classified as byproduct
material and are therefore available for beneficial uses. If beneficial
uses cannot be found, the capsules may be subject to management and
disposal actions as high-level waste.
The principal advantage of the No Action alternative is that it
allows DOE to evaluate potential commercial and medical uses for the
cesium and strontium capsules rather than foreclosing these options by
implementing a disposal alternative. This alternative also provides an
opportunity for further study of long-term environmental impacts. DOE
would reevaluate the preferred alternative after a determination is
made on the potential for future use of cesium and strontium capsules.
The principal disadvantage of this alternative is that it would not
result in the near-term disposal of the capsules. The high costs of
storing the capsules would continue. The cost and impacts of disposal
would be delayed until some time in the future, if appropriate uses for
the capsules are not developed.
Onsite Disposal
Overpack the cesium and strontium capsules in canisters and dispose
of them onsite in a newly constructed shallow drywell disposal
facility.
The principal advantage of this alternative is that it is the only
alternative that would allow near-term disposal of the capsules because
it would not rely on the construction of a national geologic high-level
waste repository, which may not be available until after the year 2015.
The principal disadvantage of this alternative is that it would not
meet the requirements of the Resource Conservation and Recovery Act for
hazardous waste or DOE policy for disposal of readily retrievable high-
level waste. The capsules would be disposed of in a near-surface
facility where they would be more accessible to inadvertent human
intrusion until the cesium and strontium decayed to non-radioactive
elements.
Overpack and Ship
Overpack the cesium and strontium capsules into canisters, place
the canisters into Hanford Multi-Purpose Canisters for interim storage,
and store the packaged capsules onsite pending offsite disposal at a
national geologic repository.
The principal advantage of this alternative is that it would
provide for offsite disposal of the capsules in compliance with all
regulatory requirements.
The principal disadvantage of this alternative is that the capsules
may not meet waste acceptance criteria at a national geologic
repository.
Vitrify With Tank Waste
Remove capsule contents, vitrify with the high-level tank waste,
and dispose of offsite at a national geologic repository.
The principal advantages of this alternative are that it would meet
all regulatory requirements and the currently planned waste acceptance
requirements for a national geologic repository. This alternative is
dependent
[[Page 8698]]
on selecting one of the tank waste alternatives that includes a high-
level waste vitrification facility, which would be used to vitrify the
cesium and strontium.
Environmentally Preferable Alternative--Cesium and Strontium Capsules
All of the alternatives for remediation of the cesium and strontium
capsules are estimated to result in low environmental impacts. There
would be no occupational fatalities or increased incidences of cancer
or fatal chemical exposures associated with normal operations. There
would be no or low adverse impacts on surface waters or groundwater,
soils, air quality, transportation networks, noise levels, visual
resources, socioeconomic conditions, resource availability, or land
use. The No Action, Overpack and Ship, and Vitrify with Tank Waste
alternatives would have slightly lower impacts on shrub-steppe habitats
than the Onsite Disposal alternative and a slightly lower risk of a
fatal accident. Assuming that the capsules would meet waste acceptance
criteria at a national geologic repository the Overpack and Ship
alternative would result in slightly lower impacts than the other
alternatives and is therefore the environmentally preferable
alternative.
Decision
Tank Waste
Description of Alternative Selected
DOE has decided to implement the Phased Implementation alternative
for the tank waste. The Phased Implementation alternative strikes an
appropriate balance among potential short- and long-term environmental
impacts, stakeholder interests, regulatory requirements and agreements,
costs, managing technical uncertainties, and the recommendations
received from other interested parties.
While carrying out this decision, DOE will continually evaluate new
information relative to the tank waste remediation program. DOE also
intends to conduct formal evaluations of new information relative to
the tank waste remediation program at three key points over the next
eight years under its NEPA regulations (10 CFR 1021.314), with an
appropriate level of public involvement, to ensure that DOE stays on a
correct course for managing and remediating the waste.
As remediation proceeds in the coming years, DOE will learn more
about management and remediation of the tank waste and ways to protect
public and worker health and the environment. Within this time frame,
DOE will obtain additional information on the effectiveness of
retrieval technologies, characteristics of the tank wastes,
effectiveness of waste separation and immobilization techniques, and
more definitive data on the costs of retrieval, separations, and
immobilization of the waste. Formal reevaluations will incorporate the
latest information on these topics. DOE will conduct these formal
evaluations of the entire TWRS program at the following stages: (1)
before proceeding into Privatization Phase I Part B (scheduled for May
1998); (2) prior to the start of hot operations of Privatization Phase
I Part B (scheduled for December 2002/December 2003); and (3) before
deciding to proceed with Privatization Phase II (scheduled for December
2005). In conducting these reviews, DOE will seek the advice of
independent experts from the scientific and financial community, such
as the National Academy of Sciences which will focus on the expected
performance and the costs of waste treatment. DOE has established a
TWRS Privatization Review Board consisting of Senior DOE
representatives to provide on-going assistance and interactive
oversight of the review of Part A deliverables and discussions with the
contractors.
Informal evaluations also will be conducted as the information
warrants. These formal and informal evaluations will help DOE to
determine whether previous decisions need to be changed.
The Phased Implementation approach allows DOE to start remediating
waste earlier than previously planned. With this approach, retrieval
and processing of waste will begin on a small scale so that systems can
be improved as knowledge is gained. This approach also permits DOE to
continue research and development in critical areas, such as improved
robotic retrieval systems, that may result in improved methods to
reduce tank leaks during retrieval, and methods to remove residual
waste that is difficult to retrieve.
The components of the demonstration phase (Phase I) will include:
(1) continuing to safely manage the tank waste; (2) constructing and
operating demonstration facilities; (3) collecting additional
information through tank waste and vadose zone characterization; and
(4) performing demonstrations of technologies that have the potential
to reduce uncertainties associated with the TWRS program.
Continuing to safely manage the tank farms includes replacement of
certain waste transfer piping and routine maintenance activities for
tank farm instrumentation, ventilation, and electrical systems. Ongoing
activities will include conducting environmental and safety related
monitoring, removing pumpable liquids from the single-shell tanks,
mitigating flammable gas safety hazards, and transferring currently
stored waste and newly generated waste using the replacement cross-site
transfer system, rail cars, and tanker trucks. DOE also plans to
upgrade certain instrumentation, tank ventilation, and electrical
system to upgrade the regulatory compliance status of the current
facilities. The environmental impacts of these actions were not
assessed in the TWRS EIS because the activities to be performed had not
been sufficiently defined. DOE will evaluate the impacts of these
actions in future NEPA analyses.
The demonstration phase, which will last approximately 10 years,
includes the retrieval and treatment of a portion of the waste from the
double-shell and single-shell tanks. The waste will be separated into
low-activity waste and high-level waste through physical and chemical
processes and then treated in demonstration-scale facilities. Vitrified
high-level waste will be placed in interim storage at the Canister
Storage Building pending future disposal at a national geologic
repository. Immobilized low-activity waste will be prepared for future
onsite disposal in existing grout vaults and similarly designed
disposal facilities.
During the demonstration phase, DOE will conduct many activities to
reduce the uncertainties associated with certain aspects of the
project. For example, DOE will obtain extensive operational and cost
data on a variety of issues by retrieving waste for treatment and
constructing and operating the demonstration-scale facilities. DOE also
will obtain more detailed information on the characteristics of the
tank waste and potential impacts on groundwater by continuing to
collect data through the existing tank waste and vadose zone
characterization programs. Further, DOE will conduct a project known as
the Hanford Tanks Initiative that will provide data on single-shell
tank residual characteristics, single-shell tank retrieval
technologies, tank residual removal technologies, and tank closure
technologies. In addition, DOE will further investigate technologies
that have the potential to reduce the uncertainties of the TWRS
project, including evaluating alternative tank fill material for use
during closure, demonstrating the effectiveness and efficiency of waste
retrieval with sluicing technology, and evaluating a variety of other
technologies through DOE's complex-wide technology
[[Page 8699]]
development programs. DOE also will prepare appropriate further NEPA
documentation before making decisions on closure of the tank farms.
This documentation will address the final disposition of the tanks,
associated equipment, soils, and groundwater, and will integrate tank
farm closure with tank waste remediation and other remedial action
activities.
Phase II of the Phased Implementation alternative will begin after
Phase I and will last approximately 30 years. Phase II will consist of
continuing to safely manage the tank waste and constructing and
operating full-scale facilities to treat the remainder of the tank
waste. The tank waste will be retrieved and separated into low-activity
waste and high-level waste. The low-activity waste will be immobilized
and disposed of onsite in near-surface disposal facilities. The high-
level waste will be vitrified, temporarily stored onsite, and
transported offsite for disposal in a national geologic repository. DOE
will use the lessons learned from the demonstration phase and the
information obtained from further characterization and technology
development activities to optimize operating efficiencies during Phase
II and reduce construction and operating costs. DOE will continue to
evaluate the path forward for the tank waste remediation program as
additional data and technology development activities provide
information relative to key technical and regulatory issues.
DOE currently plans to implement parts of this alternative through
a privatization initiative whereby private companies will perform
certain aspects of the remediation in an effort to use competition
within the marketplace to bring new ideas and concepts to waste
remediation and reduce project costs. The goal of privatization is to
streamline the TWRS mission, transfer a share of the responsibility,
accountability, and liability for successful performance to industry,
improve performance, and reduce costs without sacrificing worker and
public safety or environmental protection. On September 25, 1996, DOE
issued contracts to two companies to initiate the design process for
Phase I, Part A. Any of the contractors authorized to proceed to start
Part B is anticipated to follow the same general approach described in
the EIS for Phase I, Part B of the Phased Implementation alternative,
including separating the waste into low-activity waste and high-level
waste streams, vitrifying the high-level waste, and using high-
temperature processes to immobilize low-activity waste. Both
contractors' current plans include vitrifying low-activity waste upon
approval to proceed with Phase I, Part B.
Before issuing these contracts DOE independently evaluated the
environmental data and analyses submitted by the contractors and
prepared a confidential environmental critique of the potential
environmental impacts in accordance with DOE NEPA regulation 10 CFR
1021.216. After issuing the contracts, DOE prepared a publicly
available environmental synopsis, based on the critique, to document
the consideration given to environmental factors and to record that the
relevant environmental consequences of reasonable alternatives have
been evaluated in the selection process. This evaluation showed that
the two proposals would have similar overall environmental impacts and
that the impacts would be less than or approximately the same as the
impacts described for Phase I of the Phased Implementation alternative.
The environmental synopsis has been filed with the Environmental
Protection Agency and is available at the DOE Public Reading Rooms and
Information Repositories listed at the end of this Record of Decision.
DOE will require the selected contractors to submit further
environmental information and analysis and will use the additional
information, as appropriate, to assist in the NEPA compliance process,
including a determination under 10 CFR 1021.314 of the potential need
for future NEPA analysis.
Basis for Selection
DOE has determined that through the many years of research and
development throughout the DOE complex and specific studies on Hanford
Site tank waste remediation, the technical uncertainties have been
reduced to a manageable level. DOE has determined that the risks
associated with proceeding with remediation are less than the risks of
future releases of contaminants to the groundwater and of accidents in
unremediated tanks that are deteriorating structurally. The cost of
continuing to manage the unremediated tank waste facilities is high.
DOE has determined that it is necessary to retrieve the waste from
the tanks to meet regulatory requirements, avoid future long-term
releases to the groundwater that would threaten human health and the
environment, and reduce health impacts to potential inadvertent
intruders into the waste if administrative control of the Site were
lost. An intermediate level of separating the waste into low-activity
waste and high-level waste was selected because of the high disposal
costs of alternatives with low levels of separation and the high degree
of technical uncertainty associated with alternatives with extensive
levels of separations. To address the remaining technical uncertainties
that exist with the tank waste remediation program, the phased
implementation approach was selected to provide the flexibility
necessary to make midcourse adjustments to the remediation plans based
on future characterization data, technology development, and technical
and cost data developed during Phase I.
The Phased Implementation alternative provides for the permanent
isolation of the waste from humans and the environment to the greatest
extent practicable and protection of public health and the environment.
A high percentage of the radionuclides will be disposed of offsite in a
national geologic repository, which provides a high degree of permanent
isolation of the most hazardous waste. Releases of contaminants to the
groundwater at the Hanford Site will be reduced to the greatest extent
practicable. The waste disposed of onsite will be isolated from humans
and the environment by immobilizing the low-activity waste and placing
it in near-surface disposal facilities covered with an earthen surface
barrier.
The Phased Implementation alternative provides a balance among key
factors that influenced the evaluation of the alternatives; short-term
impacts to human health and the environment, long-term impacts to human
health and the environment, managing the uncertainties associated with
the waste characteristics and treatment technologies, costs, and
compliance with regulatory requirements. It also provides a balance
between the need to proceed with remediation and the potential
advantages of delaying remediation to incorporate future technology
developments. This alternative allows DOE to meet all regulatory
requirements and reflects the values and concerns of many stakeholders.
Mitigation Measures
This decision adopts all practicable measures to avoid or minimize
adverse environmental impacts that may result from the Phased
Implementation alternative. These measures many of which are routine,
include the following.
All DOE nuclear facilities will be designed, constructed,
and operated in compliance with the comprehensive set of DOE or
commercial requirements that have been established to protect public
health and the environment. These
[[Page 8700]]
requirements encompass a wide variety of areas, including radiation
protection, facility design criteria, fire protection, emergency
preparedness and response, and operational safety requirements;
Measures will be taken to protect construction and
operations personnel from occupational hazards and minimize
occupational exposures to radioactive and chemical hazards;
Emergency response plans will be developed to allow rapid
response to potentially dangerous unplanned events;
Water and other surface sprays will be used to control
dust emissions, especially at borrow sites, gravel or dirt haul roads,
and during construction earthwork;
Areas for new facilities will be selected to minimize
environmental impacts to the extent practicable;
Pollution control or treatment will be used to reduce or
eliminate releases of contaminants to the environment and meet
regulatory standards;
Extensive environmental monitoring systems will be
implemented to continually monitor potential releases to the
environment;
All newly disturbed areas will be recontoured to conform
with the surrounding terrain and revegetated with locally derived
native plant species consistent with Sitewide biological mitigation
plans;
Historic, prehistoric, and cultural resource surveys will
be performed for any undisturbed areas to be impacted;
Potential impacts to shrub-steppe habitat and cultural
resources will be among the factors considered in a NEPA analysis to
support the site selection process for facilities and earthen borrow
sites; and
Consultation with Tribal Nations and government agencies
will be performed throughout the planning process to address potential
impacts to shrub-steppe habitat, religious sites, natural resources,
and medicinal plants.
Mitigation measures will be refined and presented in the Tank Waste
Remediation Mitigation Action Plan. Tribal Nations and agencies will be
consulted, as appropriate, during preparation of the Mitigation Action
Plan.
Cesium and Strontium Capsules
DOE has decided to defer the decision on the disposition of the
cesium and strontium capsules for up to two years. In effect, DOE will
implement the No Action alternative until a final disposition decision
is made and implemented. The encapsulated cesium and strontium have
potential value as commercial and medical irradiation or heat sources,
and implementing disposal alternatives would foreclose options for
these applications. DOE is evaluating the potential for commercial and
medical uses. In addition, DOE is considering mixing the cesium with
surplus plutonium; the cesium would serve as a radiation barrier and be
immobilized with the plutonium. Mixing the cesium with the plutonium
would enhance nuclear materials security by making future use of the
plutonium by unauthorized persons very hazardous and difficult. DOE
will reevaluate the decision on the disposition of the capsules after
determinations are made on the potential for future use of cesium and
strontium. DOE is preparing a Cesium and Strontium Management Plan that
will address alternatives for beneficial uses of the capsules prior to
final disposition. If DOE decides not to use the cesium and strontium
for any of these purposes, one of the alternatives for permanent
disposal of the capsules will be selected and DOE will supplement this
Record of Decision. Before making such a decision, DOE intends to
further study disposal alternatives to resolve uncertainties and better
understand long-term impacts, as recommended by the National Research
Council (see Appendix).
Comments on the Draft EIS and Agency Responses
DOE and Ecology received comments on the Draft EIS from 102
individuals, organizations, agencies, or Tribal Nations including the
Washington State Department of Wildlife, Oregon State Department of
Energy, Nez Perce Tribe, Yakama Indian Nation, and the Confederated
Tribes of the Umatilla Indian Reservation. All comments received were
addressed in the Final EIS, Volume Six, Appendix L, and revisions to
the Final EIS were made, as appropriate, to address applicable
comments. A complete copy of all comments received on the Draft EIS is
available in each of the DOE Public Reading Rooms and Information
Repositories at the locations listed at the end of this Record of
Decision.
Comments Received After Publication of the Final EIS and DOE
Responses
DOE received comments from the Washington State Department of Fish
and Wildlife on the Final EIS and comments from the National Research
Council on the Draft EIS after publication of the Final EIS. A summary
of these comments and DOE's responses is attached as an appendix to
this Record of Decision. These comments were considered in the
preparation of this Record of Decision.
DOE Public Reading Rooms and Information Repositories
University of Washington, Suzzallo Library, Government
Publications Room, Seattle, WA 98185. (206) 685-9855, Monday-Thursday,
9 a.m. to 8 p.m.; Friday and Saturday, 9 a.m. to 5 p.m.
Gonzaga University, Foley Center, E. 502 Boone, Spokane,
WA 99258. (509) 328-4220 ext. 3829, Monday-Thursday, 8 a.m. to
midnight, Friday, 8 a.m. to 9 p.m.; Saturday, 9 a.m. to 9 p.m.; Sunday,
11 a.m. to midnight.
U.S. Department of Energy Reading Room, Washington State
University, Tri-Cities Campus, 100 Sprout Road, Room 130W, Richland, WA
99352, (509) 376-8583, Monday-Friday, 10 a.m. to 4 p.m.
Portland State University, Bradford Price Millar Library,
Science and Engineering Floor, SW Harrison and Park, Portland, OR
97207, (503) 725-3690, Monday-Friday, 8 a.m. to 10 p.m.; Saturday, 10
a.m. to 10 p.m.; Sunday, 11 a.m. to 10 p.m.
U.S. Department of Energy, Headquarters, Freedom of
Information Public Reading Room, 1E-190 Forrestal Building, 1000
Independence Avenue, SW., Washington, DC 20585, (202) 586-6020, Monday-
Friday, 9 a.m. to 4 p.m.
A copy of the Record of Decision is also available via the Internet
at www.hanford.gov/eis/twrseis.htm and http://tis-nt.eh.doe.gov/nepa.
Issued in Washington, DC, this day, February 20, 1997.
Alvin Alm,
Assistant Secretary for Environmental Management.
Appendix--Comments Received After Publication of the Final EIS
The U.S. Department of Energy (DOE) received comments and
recommendations from the National Research Council and the Washington
State Department of Fish and Wildlife after publication of the Final
Environmental Impact Statement (EIS). The following is a summary of
these comments and DOE's responses.
National Research Council Comments
On March 4, 1996, DOE requested that the National Research Council
(Council), Committee on Remediation of Buried and Tank Waste, review
the Tank Waste Remediation System (TWRS) Draft EIS. DOE received the
Council's comments and recommendations regarding the Draft EIS on
September 6, 1996 (after the Final EIS had been published) in a report
entitled ``The Hanford Tanks:
[[Page 8701]]
Environmental Impacts and Policy Choices''. Although this report was
issued too late to be considered in the Final EIS, DOE did consider the
Council's comments in the preparation of this Record of Decision.
DOE generally agrees with the comments and recommendations made by
the Council. Because several other commentors on the Draft EIS
identified similar concerns, many of the Council's comments and
recommendations were incorporated in the Final EIS prior to receipt of
the Council's report. DOE believes the Record of Decision reflects
stakeholder values regarding the need for action, provides a balance
among short- and long-term environmental impacts, meets regulatory
requirements and agreements, and addresses technical uncertainties,
while also accommodating, to the extent possible, the underlying
concern of the Council regarding the need for phased decision making.
The following is a summary of the National Research Council's
comments and DOE's responses.
Comment 1: Uncertainties, both stated and unstated, concerning the
Hanford wastes, the environment, and the remediation processes are
found throughout the DEIS. Significant uncertainties exist in the areas
of technology, costs, performance, regulatory environment, future land
use, and health and environmental risks. Among the issues that remain
uncertain are:
Effectiveness in practice of technologies to remove and
treat waste from tanks,
Costs of operations and offsite waste disposal,
Future policy and regulatory environment,
Characterization of tank wastes,
Relation between tank waste removal, remediation of the
surrounding environment, and ultimate land use at the site, and
Long-term risks associated with various alternatives for
treating and processing the tank wastes, both in relation to residues
left on site and risks transferred offsite when processed wastes are
moved to a national geologic repository.
The preferred Phased Implementation alternative presented in the
DEIS does not adequately address all of the uncertainties that make it
difficult to decide how to complete remediation of the tanks. During
Phase I, cesium and technetium, the most troublesome elements in a
vitrifier, are to be removed from the high-level waste that is sent to
the pilot vitrification plant, potentially limiting the value of
information obtained from the pilot plant operations. This may also
delay a decision on the final waste form for these elements.
Plans for building a pilot plant should proceed, but in the context
of a phased decision strategy that does not preclude processing of
wastes other than the double-shell tank supernatant or producing waste
forms other than the glass currently planned.
Response 1: DOE agrees with the Council that there are substantial
uncertainties associated with the tank waste remediation program. In
response to similar comments, DOE revised the EIS to enhance the
discussion of uncertainties, including the relevance of the
uncertainties in the evaluation of alternatives. The Final EIS provides
an extensive discussion on uncertainties in Appendix K, which includes
DOE's detailed evaluation of the uncertainties and impacts associated
with the tank waste remediation program alternatives. In light of the
uncertainties related to the remediation of tank waste, DOE has
committed to reevaluate the program as DOE continues to learn from
these activities to ensure that DOE will stay on a correct course for
managing the tank wastes.
The Council placed particular emphasis on recommending the use of a
``phased decision strategy'' because of the technical uncertainties in
tank waste management. DOE has decided to implement the Phased
Implementation alternative, which DOE believes will achieve many of the
goals of the phased decision strategy recommended by the Council. DOE
believes that the many years of technology evaluations throughout the
DOE Complex have reduced the uncertainties to a manageable level, and
the risks of proceeding with remediation are less than the risks of
further releases of contaminants from the tanks and the potential for
accidents in unremediated tanks. In addition, the cost of continuing to
manage the tank waste in facilities that have exceeded their design
life are high. DOE believes the Phased Implementation alternative
provides adequate flexibility to accommodate changes in the tank waste
remediation program as additional information is developed. Responses
to the Council's other comments, below, provide additional detail on
how DOE intends to reduce the technical uncertainties while proceeding
with the Phased Implementation alternative.
Phase I of the Phased Implementation alternative includes both low-
activity and high-level waste treatment and immobilization. Any
radionuclides separated from the low-activity waste feed stream,
including cesium and technetium, will be vitrified in the high-level
waste facility. This will provide important information on the
performance of the separations process and of vitrification of
troublesome elements like cesium and technetium.
By performing Phase I of the Phased Implementation alternative and
proceeding with other technology development projects and tank waste
characterization, the uncertainties associated with the tank waste
program will be reduced further. Initiatives that DOE is pursuing to
reduce uncertainties in support of the TWRS program include:
The Hanford Tanks Initiative, which will provide data on
characterization of tank residuals, technologies for waste retrieval,
technologies for removing tank residuals, and criteria for closing
tanks;
Completion of the tank waste characterization program,
which will provide data relative to tank waste safety issues and the
contents of the tanks;
Determination of the level of contamination in the vadose
zone;
Development of a comprehensive plan to integrate tank
waste remediation with tank farm closure and other remediation
activities related with the TWRS program;
Integration of TWRS program implementation with the plans
for developing a national geologic repository for high-level waste;
Demonstrations of the efficiency and effectiveness of
retrieval sluicing technology to support the tank waste remediation
activities; and
Demonstrations of various tank waste separations and
treatment processes.
Comment 2: The DEIS surveyed a wide range of remediation options,
including strategies in which tanks with varying contents are treated
differently. However, the committee believes that additional
alternatives for management of the tank wastes need to be explored in
parallel, using a phased decision strategy like the one outlined in
this report. Such a strategy would provide flexibility in the event
that specific, preferred technologies or management approaches do not
perform as anticipated or that innovative waste management and
remediation technologies emerge. Among additional options that should
be analyzed are (1) in-tank waste stabilization methods that are
intermediate between in situ vitrification and filling of the tanks
with gravel, (2) subsurface barriers that could contain leakage from
tanks, and (3) selective partial removal of wastes from tanks, with
subsequent stabilization of
[[Page 8702]]
residues, using the same range of treatment technologies as in the
alternatives involving complete removal of wastes.
When funding is constrained, it is more difficult to devote
resources to the continued development of backup options. However,
considering the uncertainty in the cost and performances of the
technologies required for the preferred alternative, a time period
during which funding is constrained is precisely the wrong time to drop
work on alternatives that might achieve satisfactory results at a
significantly lower cost. Having such alternatives available could
allow remediation to proceed expeditiously, even if funding constraints
prevent timely implementation of the currently preferred alternative.
Response 2: As discussed in the response to comment 1, DOE agrees
that significant uncertainties exist in the tank waste remediation
program and that the strategy selected needs to be flexible to respond
to new information and the results of research and development efforts.
Additional alternatives and refinements of alternatives need to be
developed and evaluated.
The Council's report recommends a ``phased decision strategy,''
while DOE's preferred alternative is the ``Phased Implementation
alternative.'' There are important similarities and differences between
these two approaches. Under the Council's phased decision strategy, the
first phase would identify and develop alternative approaches to
remediate the tank waste. Decisions on alternatives for subsequent
phases would be deferred until information from the first phase is
evaluated. This approach has the advantage of not prematurely
foreclosing options enabling DOE to further study and develop
technologies and that might reduce cost and/or risk. It has the
disadvantage of leaving the total cost, schedule, and final outcome
highly uncertain. Under DOE's Phased Implementation alternative, the
complete path forward for tank waste remediation has been determined,
while recognizing that the path can be modified as new information
becomes available. However, DOE has committed to conduct formal and
informal reviews with the intent to mitigate the concern of making
long-term decisions in the near-term.
The DOE Phased Implementation decision addresses current regulatory
requirements and cleanup commitments while maintaining the flexibility
necessary to modify the TWRS program if emerging information (e.g., new
characterization data, technology breakthroughs, etc.) indicates there
is a need to change the direction of the program. At the same time,
technology development activities, such as the Hanford Tanks
Initiative, will continue, in order to provide alternative paths if
preferred technologies do not perform as anticipated. In addition to
current programs, the Conference Report for the Energy and Water
Development Appropriations Act, 1997 recommends up to $15 million in
technology development activities to support the tank waste program.
Other activities, which are critical to the overall TWRS program,
will be conducted by DOE throughout Phase I. These activities include
single-shell tank waste retrieval, developing methods for quantifying
and characterizing the waste residuals left in the tanks following
retrieval, and studying the leakage rate of tank wastes during the
retrieval process. Contractors will have access to technologies being
developed by other DOE programs and will be able to use these
technologies if appropriate.
The Final EIS evaluated possible alternatives for remediating the
tank waste. There are, as the Council noted, a great number of
variations or combinations of alternatives; DOE could not evaluate all
such combinations in the EIS. Rather, DOE evaluated a complete range of
reasonable tank waste management options, and thereby obtained adequate
information for the strategic choice of direction made in this ROD. The
use of alternate fill material for tank closure was not evaluated
directly, but such alternatives are qualitatively within the range of
alternatives analyzed in detail, and DOE was adequately informed about
them for the purposes of this EIS. These alternatives will be addressed
more directly in future NEPA analysis on tank closure. In this EIS, DOE
considered the use of subsurface barriers as a potential mitigation
measure during tank waste retrieval. Subsurface barriers were also
evaluated in a Feasibility Study completed in 1995. Additional
development work is being performed by DOE, and if promising new
developments occur, DOE will reconsider the application of subsurface
barriers for the tanks. Two alternatives for partial retrieval of the
wastes that were similar to the selective partial retrieval alternative
that the Council recommended be analyzed were included in the
alternatives analyzed. DOE will continue to reevaluate these and other
alternatives as more information becomes available.
In situ disposal of single-shell tank wastes and in-tank
stabilization of tanks with residuals (not removed by retrieval) have
been the subject of previous studies and were evaluated as part of the
Systems Engineering Study for the Closure of Single-Shell Tanks.
Alternatives for closing tanks with residual waste were evaluated in
the Engineering Study of Tank Fill Alternatives for Closure of Single-
Shell Tanks released in September 1996. Additional studies supporting
stabilization of tanks with residual waste remaining following
completion of retrieval operations are planned during Fiscal Year 1997
and Fiscal Year 1998 as part of the Hanford Tanks Initiative.
In addition to the two ex situ/in situ tank waste disposal
alternatives that were evaluated in the TWRS EIS, selective partial
removal of wastes from tanks, using a risk-based approach, was
evaluated in the study entitled ``Remediation and Cleanout Levels for
Hanford Site Single-Shell Tanks'' (Westinghouse Hanford Company, 1995,
WHC-SD-WM-TI-711).
This Record of Decision adopts a long-term strategy that will focus
efforts on achieving the ultimate TWRS remediation goals while
continuing to characterize tank wastes, evaluate new technologies and
improve risk assessments. DOE believes that its past studies have
reduced the uncertainties enough to enable DOE to make a decision on a
long-term tank waste remediation strategy. Although this approach
differs from the phased decision strategy recommended by the Council,
DOE intends to implement its decision in a manner that is flexible
enough to accommodate appropriate mid-course corrections in the tank
waste remediation strategy, based on lessons learned in the pilot
studies or from other new information.
Comment 3: The scope of the DEIS also has significant limitations.
Because the DEIS does not address remediation of the tanks themselves
and associated environmental contamination, the alternatives it
considers for tank waste remediation are not defined well enough. In
addition, the connections between tank remediation alternatives and
other cleanup activities at the Hanford Site are not taken into
account. Because tank waste remediation alternatives are analyzed and
evaluated in isolation from other geographically-related contamination
at the Hanford Site, information about risks and costs in the DEIS is
difficult to place in a proper perspective.
Response 3: DOE agrees with the Council's observation that there is
a
[[Page 8703]]
need to integrate remediation of the tank waste with future tank
closure decisions and other geographically related remedial actions at
the Hanford Site. The Final EIS addresses tank farm closure and other
geographically related contamination and remediation activities to the
extent possible with current information and to the extent necessary
for DOE to make decisions concerning tank waste remediation. The EIS
presents (1) information relative to closure to provide the public and
decision makers with information on how decisions made now may affect
future decisions on closure; (2) information on which alternatives
would preclude the future selection of clean closure for the tank
farms; and (3) information on cumulative impacts, including the effects
of other site activities. This information provides a context for
understanding the strategic decisions, now ripe, that are the focus of
this EIS. To support the analysis, DOE used closure of a landfill as a
representative closure scenario for each alternative, thus providing
for a meaningful comparison of the alternatives. DOE intends to prepare
a comprehensive plan to integrate tank waste remediation with tank farm
closure activities and other Hanford Site remediation programs.
Comment 4: Decisions regarding tank remediation must consider risk,
cost, and technical feasibility. Where risks are involved, care should
be taken to present a range of potential risks, including expected or
most likely estimates as well as the upper-bound estimates presented in
the DEIS. While upper-bound estimates may give confidence that actual
impacts will not exceed those presented in the DEIS from a worst-case
perspective, the inherent uncertainties in risk assessments can distort
the comparison of alternatives. This is of particular concern when the
upper-bound estimates are derived from a cascade of parameters, much of
which was also derived on an upper-bound basis.
While the committee recognizes the utility of quantitative risk
assessment in the comparison of remedial alternatives, the limitations
of analysis must be underscored. Given the complexity of the Hanford
tank farms, many of the potential uncertainties cannot be measured,
quantified, or expressed through statistically derived estimates.
According to the 1996 National Research Council report Understanding
Risk, the 1996 U.S. Environmental Protection Agency report Proposed
Guidelines for Carcinogen Risk Assessment, and a recent draft report by
the Commission on Risk Assessment and Risk Management, characterization
of risk should be both qualitative and quantitative. In this case,
qualitative information should include a range of informed views on the
risks and the evidence that supports them, the risk likelihood, and the
magnitude of uncertainty. Such evaluations of risk should be based on
deliberative scientific processes that clarify the concerns of
interested and affected parties to prevent avoidable errors, provide a
balanced understanding of the state of knowledge, and ensure broad
participation in the decision-making process.
Response 4: DOE agrees with these comments and has modified the EIS
accordingly in response to similar comments on the Draft EIS received
during the public comment period. For example, DOE believes that
characterization of the risk should be quantitative when possible and
qualitative when parameters are uncertain by more than an order of
magnitude. The Final EIS presents the ``expected'', or ``nominal''
ranges of risk and upper-bound estimates, and includes (in Appendix E)
detailed analysis of uncertainties.
Comment 5: It should be expected that the environmental regulations
governing the tank wastes, and the Hanford Site in general, will change
over the time during which waste management and environmental
remediation occur. DOE should work with the appropriate entities to
ensure that future regulatory changes and the future selection of tank
remediation approaches are on convergent paths. The development,
testing, and analysis of alternatives during the first phase should
continue unconstrained by current regulatory requirements and should
examine currently untested technologies.
Response 5: DOE agrees that ongoing dialogue with the regulators is
necessary to making sound tank waste management decisions. DOE
continues to work with the Federal and State regulatory authorities and
with the stakeholders to share evolving information regarding impacts
and technologies. Toward that end, DOE developed the reasonable
alternatives to be analyzed in the EIS on a scientific and engineering
basis, then evaluated the alternatives for compliance with regulations.
Only four of the ten alternatives addressed in the EIS could be
implemented consistent with existing Federal and State regulations. The
Record of Decision, however, selects a compliant approach.
Comment 6: Concerning the management and disposal of the cesium and
strontium capsules and of the miscellaneous underground storage tanks,
the committee found that the DEIS lacks enough substantive information
for an evaluation of the proposed remediation strategies. Over 99
percent of the tank wastes is in the single-shell and double-shell
tanks, and that is where the greatest potential for health and
environmental risk exists. However, the extremely high concentration of
radioactivity and the nature of the materials in the capsules
necessitate a more thorough discussion of their treatment, disposal,
and environmental impact. There are serious deficiencies in the
attention given to the long-term changes in the chemical and isotopic
composition of the cesium and strontium capsules. The large number and
wide distribution of the miscellaneous underground storage tanks make a
more complete discussion of their management necessary.
Response 6: DOE agrees with the Council that there is not enough
substantive information regarding the cesium and strontium capsules to
make a long-term decision on their final disposition. DOE also wants to
evaluate potential beneficial uses of the capsules and has decided to
defer any disposition of the capsules. In the meanwhile, a Cesium and
Strontium Management Plan is currently being prepared by DOE that will
address alternatives for beneficial uses of the capsules prior to final
disposition. As part of the plan, DOE will continue to collect and
analyze information regarding the capsules to reduce uncertainties and
better understand long-term impacts, and to ensure that the long-term
decision is appropriate.
With regard to the miscellaneous underground storage tanks, DOE
believes, based on currently available information, that the waste
contained in the miscellaneous underground storage tanks is similar to
the waste contained in the single-shell tanks. Because the
miscellaneous underground storage tanks represent a small percentage
(0.5 percent) of the overall waste volume, the potential long-term
impacts posed by the miscellaneous underground storage tanks are within
the range of impacts calculated for the single-shell tanks and double-
shell tanks. The short-term and long-term impacts associated with the
miscellaneous underground storage tanks for activities such as waste
retrieval and transfer were analyzed in the EIS.
Comment 7: The proper approach to decision making for tank farm
cleanup is to use a phased decision strategy in which some cleanup
activities would proceed in the first phase while
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important information gaps are filled concurrently to define identified
remediation alternatives more clearly, and possibly to identify new and
better ones. As part of this strategy, periodic independent scientific
and technical expert reviews should be conducted so that deficiencies
may be recognized and midcourse corrections be made in the operational
program.
Response 7: DOE agrees with the Council that periodic independent
scientific and technical expert reviews are essential to the success of
the TWRS program. While carrying out the current decisions, DOE will
continually evaluate new information relative to the tank waste
remediation program. DOE also intends to conduct formal evaluations of
new information relative to the tank waste remediation program at three
key points over the next eight years under its NEPA regulations (10 CFR
1021.314), with an appropriate level of public involvement, to ensure
that DOE will stay on a correct course for managing and remediating the
waste. As remediation proceeds in the coming years, DOE will learn more
about management and remediation of the tank waste and ways to protect
public and worker health and the environment. Within this time frame,
DOE will obtain additional information on the effectiveness of
retrieval technologies, characteristics of the tank wastes,
effectiveness of waste separation and immobilization techniques, and
more definitive data on the costs of retrieval, separations, and
immobilization of the waste. These formal reevaluations will
incorporate the latest information on these topics. DOE will conduct
these formal evaluations of the entire TWRS program at the following
stages: (1) before proceeding into Privatization Phase I Part B
(scheduled for May 1998); (2) prior to the start of hot operations of
Privatization Phase I Part B (scheduled for December 2002/December
2003); and (3) before deciding to proceed with Privatization Phase II
(scheduled for December 2005). In conducting these reviews, DOE will
seek the advice of independent experts from the scientific and
financial community, such as the National Academy of Sciences which
will focus on performance criteria and the costs of waste treatment.
DOE has established a TWRS Privatization Review Board consisting of
Senior DOE representatives to provide on-going assistance and
interactive oversight of the review of Part A deliverables and
discussions with the contractors.
Informal evaluations also will be conducted as the information
warrants. These formal and informal evaluations will help DOE to
determine whether previous decisions need to be changed.
Washington State Department of Fish and Wildlife Comment
Comment: The Washington State Department of Fish and Wildlife
recommends that the following language be included in the Record of
Decision:
``The site selection of the precise location of remediation
facilities for the selected alternative shall be subject to future
supplemental NEPA analysis. This supplemental NEPA analysis shall
commit to a supplemental Mitigation Action Plan. The Mitigation Action
Plan and supplemental Mitigation Action Plan will be prepared in
consultation with the Washington State Department of Fish and Wildlife
and the U.S. Fish and Wildlife Service, with input from the Hanford
Site's Natural Resource Trustee Council.''
``Impacts to State priority shrub-steppe habitat would be one of
the evaluation criteria used in site selection. The site selection
process would include the following hierarchy of measures:
Avoid priority shrub-steppe habitat to the extent feasible
by locating or configuring project elements in pre-existing disturbed
areas.
Minimize project impacts to the extent feasible by
modifying facility layouts and/or altering construction timing.''
``Compensatory mitigation measures for the loss of shrub-steppe
habitat shall be identified and implemented in the supplemental NEPA
analysis and Mitigation Action Plan.''
Response: DOE believes that the following approach satisfies the
substance of these comments.
The EIS (Section 5.20) describes both mitigation measures that are
integral parts of all of the alternatives (Section 5.20.1) and further
mitigation measures that could be implemented when indicated or
appropriate (Section 5.20.2). In selecting the preferred alternative
DOE has committed to all of the mitigation measures in Section 5.20.1,
which include measures to restore newly disturbed areas. As the State
requested, the Record of Decision commits to conducting NEPA analysis
for site selection of facilities.
DOE intends to implement those further measures described in
Section 5.20.2 as may be necessary to mitigate potential impacts on
priority shrub-steppe habitat, and will consider the potential for such
impacts as a factor in the site selection process for TWRS facilities.
The site selection process will include the following hierarchy of
measures: (1) avoid undisturbed shrub-steppe areas to the extent
feasible; (2) minimize impacts to the extent feasible; (3) restore
temporarily disturbed areas; (4) compensate for unavoidable impacts by
replacing habitat; and (5) manage critical habitat on a Sitewide basis.
DOE believes that mitigation of impacts to habitats of special
importance to the ecological health of the region is most effective
when planned and implemented on a sitewide basis. Recognizing this, DOE
is preparing a sitewide biological management plan to protect these
resources. Under this sitewide approach, the potential impacts of all
projects would be evaluated and appropriate mitigation would be
developed based on the cumulative impacts to the ecosystem. Mitigation
to reduce the ecological impacts from TWRS remediation would be
performed in compliance with the sitewide biological management plan.
Mitigation would focus on disturbance of contiguous, mature sagebrush-
dominated shrub-steppe habitat. Compensation (habitat replacement)
would occur where DOE deems appropriate. Specific mitigation ratios,
sites, and planting strategies (e.g., plant size, number, and density)
for TWRS facilities and operations would be defined in the TWRS
Mitigation Action Plan, which would be revised for each specific TWRS
facility siting decision. The Mitigation Action Plan would be prepared
in consultation with the Washington State Department of Fish and
Wildlife, the U.S. Fish and Wildlife Service, and Tribal Nations, with
input from the Hanford Site's Natural Resources Trustees Council. DOE
will make the Mitigation Action Plan publicly available before taking
action that is the subject of a mitigation commitment.
[FR Doc. 97-4696 Filed 2-25-97; 8:45 am]
BILLING CODE 6450-01-P