State Calls for More Milestones Tied to WTP; Creation of New Double-Shell Tank Capacity
Mike Nartker
WC Monitor
4/04/2014
With the schedule for completion of the Hanford Waste Treatment Plant still unclear, how should the cleanup of Hanford’s underground waste tanks be governed going forward? It’s a question to which the Department of Energy and Washington state offered significantly different answers this week. While the two agree on a DOE proposal to begin operations of the WTP’s Low Activity Waste Facility ahead of the rest of the vit plant, they differ as to when such operations would occur. And while DOE is proposing to wait on setting firm schedules for completing the rest of the WTP and getting the plant in operation until technical issues at the project are fully resolved, Washington state is calling for a significant increase now in enforceable milestones tied to making progress on the WTP, along with the creation of millions of gallons of new double-shell tank waste storage capability and other interim stabilization measures to help reduce the risks posed by the aging tanks.
DOE and Washington state each put forward this week proposals to modify the 2010 consent decree that governs the cleanup of Hanford’s waste tanks. Currently, the consent decree requires operations to begin at the WTP in 2019, with full plant operations to get underway by 2022. All waste would be retrieved from Hanford’s single-shell tanks by 2040, with all tank waste treatment to be completed by 2047. DOE and Washington state have been in talks on modifying the consent decree, though, after the Department warned the state that it is at risk of missing the remainder of the WTP-related milestones in the consent decree, as well as some milestones tied to waste retrieval from Hanford’s single-shell tanks. “I believe that thoughtful decision-making and actions in the near-term will build the foundation for a stronger and sustainable path forward for the tank waste cleanup mission at Hanford. The Department is committed to moving forward as expeditiously as possible to begin immobilizing tank waste, as reflected in our proposal, and will continue to work closely with the State of Washington and key stakeholders to accomplish this important goal. We will review the State’s proposal and look ahead to further discussions as we continue working together on a path forward,” Secretary of Energy Ernest Moniz said in a statement.
During a press conference this week, though, Washington Governor Jay Inslee (D) emphasized the need for what he described as a more “comprehensive” approach than what DOE has put forward. “We’ve been clear from the beginning that a new path forward at Hanford must be comprehensive and must have a clear schedule for all tank waste retrieval and treatment requirements,” Inslee said. “Our proposal provides a viable, staged approach for meeting the existing 2040 deadline for the retrieval of waste from the single-shell tanks and the existing 2047 deadline for treatment of all tank waste.” He added, “The federal government owes it to the people of the Northwest to do everything within its power to avoid any possible delays in meeting all of its legal and moral obligations to protect the health of our residents and the Columbia River.” DOE and Washington state have until April 15 to reach an agreement on a proposal to modify the consent decree, and if an agreement is not reached by then, the two will then enter into a 40-day dispute resolution process.
When Can LAW Facility Go Into Operation?
The one area where DOE and Washington state appear to have the most agreement is on the Department’s proposal to establish a direct feed capability for the WTP’s Low Activity Waste Facility and initiate operations there while progress is made on the remainder of the vit plant. The LAW Facility, along with the WTP’s Analytical Laboratory and other support facilities (collectively known as ‘LBL’), does not have the same technical issues that have slowed progress on the other main portions of the vit plant—the Pretreatment and High-Level Waste facilities. DOE’s consent decree proposal would have the LAW Facility begin operation “no later” than the end of 2022, with an interim pretreatment capability necessary to prepare the waste for the facility. “DOE believes it has sufficient information about the facility and the technologies available (e.g., ion exchange columns and solids filtration systems that are commonly used throughout the chemical processing industry) to project a completion date,” the Department’s proposal says.
In contrast, Washington state is calling in its proposal for the LAW Facility to begin operation in 2019, and for the facility to “achieve treatment of various percentages of low activity tank waste by specified deadlines.” Concerning the direct feed to the LAW Facility proposal, Inslee said this week, “It’s a creative solution to some of the technological challenges we have. There’s some benefit of actually producing vitrified product on an early basis. But we can’t have one step forward and two steps back, which is the federal government’s proposal to us right now. That may be a step forward technologically, but it’s a step backwards, one in removing our deadlines that the state of Washington depends on to actually enforce these commitments and two, reducing the protection of leaking tanks, which are an obvious problem right now.”
DOE Says Proposal Reflects WTP ‘Unpredictability’
DOE’s proposal also contains a small set of proposed milestones tied to resolving some of the remaining technical issues at the Pretreatment and High-Level Waste facilities. “All of these milestones contain commitments that DOE, based on present knowledge, is confident it can achieve with the goal of eventually achieving initial plant operations for WTP, albeit on a revised timeframe.” The Department’s proposal, however, does not include milestones for construction, commissioning and operation of the Pretreatment and High-Level Waste facilities; or construction and commissioning of a proposed Tank Waste Characterization and Staging Facility also intended to help resolve the WTP’s remaining technical issues. Instead, DOE is proposing to “establish future milestones on a rolling basis, with specific timeframes, once technical issues are resolved and sufficient information is available on which to base milestones pursuant to the DOE Order 413.3B process and through development of new and revised performance baselines and contracts where necessary.”
DOE said its proposal “reflects the substantial level of unpredictability associated with these unique facilities that pose significant technical obstacles, with nuclear safety implications, at a time of fiscal uncertainty and constraint,” adding, “It commits DOE to establishing new and realistic milestones while resolving technical issues needed to achieve WTP operations and advancing the overall mission by directly feeding and vitrifying supernate as soon as practicable. DOE’s proposal also recognizes that this path forward will require new facilities that must undergo critical planning, design, and decision procedures, before DOE can reasonably develop accurate construction budget and schedules.”
Explaining DOE’s reluctance to set new milestones for the whole of the WTP at this time, a Department official told WC Monitor this week, “Until we go out and do some vessel testing, we don’t know what the results are going to be of that testing or what design modifications we’re going to have to make based on the resolution of those technical issues. What we understand is the path forward for resolving them, but we don’t know what the implications are of the testing and the resolution and the design modifications that are going to be necessary.”
State Proposes Specific WTP Milestones
Washington state’s proposal, though, would establish a significant amount of new milestones to track the progress of the various WTP facilities, such as:
- Achieving full “hot start” of the vit plant by 2027;
- Achieving full WTP operations by 2028;
- Complete resolution of technical issues at the HLW Facility by 2015, construction by 2023, hot commissioning and initial operations by 2026;
- Complete construction of the proposed TWCS Facility by 2023, hot commissioning and initial operations by 2026; and
- Complete resolution of the technical issues at the Pretreatment Facility by 2018, construction by 2024, hot commissioning by 2027, initial operations by 2028.
The state also is seeking new milestones for waste retrieval from Hanford’s single-shell tanks to ensure all waste retrievals are completed by 2040. With a total of 27 million gallons of waste expected to be remaining by 2022, the state’s proposal would require DOE to decrease the amount of remaining waste to 23 million gallons by 2025, 18 million gallons by 2028, 14 million gallons by 2031, 9 million gallons by 2034 and 5 million gallons by 2037.
At this week’s press conference, Inslee said Washington state’s proposal provides “a realistic schedule for completing the cleanup mission at Hanford in a timely manner to avoid a more costly cleanup and the possibility of leaked waste,” When asked if Washington state’s proposed milestones are realistic, the DOE official said, “We’re reviewing their proposal right now and trying to understand how they got to their dates.” The official added, “Our proposal gets to the same end point because we’ve laid out a process to get there with certainty in our dates.”
Are New Tanks Necessary?
Washington state also wants to set requirements for the creation of new double-shell tank storage capacity that the state says is necessary to keep waste retrieval operations on track. Under the state’s proposal, DOE would be required to establish 8 million gallons of new double-shell tank capacity—4 million gallons by 2022 and the remainder by 2024. DOE may also be responsible for establishing further double-shell tank capacity beyond the initial 8 million gallons if seen as necessary to keep tank waste retrievals on track under the state’s proposed schedule. DOE would also be required to perform “additional interim stabilization measures” for a set of 24 single-shell tanks by 2028, such as removing supernate liquid and total liquid; and would be required to construct interim barriers over a set of seven tank farms and one specific tank, T-111.
DOE has not yet made a determination as to whether or not new double-shell tank capacity is needed, the Department official said. “We’re just reviewing the proposal and evaluating that in the Department,” the official said. “It’s in the current Tri-Party Agreement to evaluate the need for new tanks as we go through the system plan milestones,” the official added.
Washington State Wants More Reports
In addition, Washington state’s proposal also includes a set of new reporting requirements. For example, DOE would have to provide quarterly reports to the state on the status of compliance with all requirements. If DOE provided any warning that a milestone may be at risk of being missed, the Department would have to provide within 45 days a “recovery plan” for addressing such risks. Explaining why such new reporting requirements are needed, Washington state’s proposal says, “Since the 2010 Settlement was finalized, Washington has not seen evidence that Energy has taken the necessary steps to do everything within its power to meet the legal obligations contained in the Consent Decree and TPA [Tri-Party Agreement]. We have not seen evidence of Energy exercising reasonable diligence to identify and respond to technical issues, performing effective project management, exercising strong oversight of its contractors, or seeking sufficient funds or reprogramming funds to meet its obligations.”
