Staff Reports
WC Monitor
11/20/2015
The Department of Energy is proposing to have all parts of the Hanford Site Waste Treatment Plant operating by 2039, but also wants a system to allow extensions for that and other milestones in the court-enforced consent decree on cleanup of the former plutonium production site. Nov. 13 was the deadline for Washington state and DOE to file revised milestone proposals in U.S. District Court for Eastern Washington after Judge Rosanna Malouf Peterson said those proposed by the two parties a year ago strayed too far from the work included in the 2010 consent decree. The court is considering new milestones after DOE said most of the remaining milestones in the consent decree are at serious risk of being missed. The consent decree as currently written requires the waste conversion plant to be in full operation in 2022. But even the state has eased up on the 2031 milestone it proposed a year ago for full operation of the plant , moving its proposed deadline to 2034. The new filings in the case also cover proposed milestones to retrieve waste from 12 single-shell waste storage tanks and for the conditions that would trigger a new requirement to build more double-shell tanks.
Although DOE is proposing a 17-year delay to the current deadline for full operation of the vitrification plant – including operation of the Pretreatment Facility, Low-Activity Waste Facility, and High-Level Waste Facility – it remains committed to starting to vitrify some low-activity waste as early as 2022. Both Washington state and DOE had proposed that in their initial set of consent decree amendments filed last year. Malouf Peterson declined to consider adding that to the consent decree, saying the agreement only addressed full plant operations when signed in 2010. However, DOE and the state were free to pursue that goal outside the consent decree, she said. Starting to vitrify low-activity waste while technical issues delay operation of the High-Level Waste Facility and Pretreatment Facility would reduce the stockpile of waste to be treated and free up needed space in double-shell tanks, which are being used to hold waste emptied from leak-prone single-shell tanks until it can be vitrified for disposal. DOE “continues to believe a sequenced approach to completing and commissioning the WTP facilities is the appropriate, practical and safest solution to Hanford’s tank waste treatment mission and remains dedicated to the direct feed low-activity waste initiative, which will allow waste treatment to begin as early as practicable,” the department said in a statement. “DOE has committed significant resources to advancing the construction and design of the components of that approach.”
DOE has been reluctant to set firm dates for much of the vitrification plant construction, commissioning, and start of operations until major technical issues that involve high-level radioactive waste at the Pretreatment Facility and High-Level Waste Facility are resolved. Pressed by the judge to deliver a concrete amended schedule, it proposed new milestones but countered the court’s demand with what it called “narrow modification mechanisms in consideration of the remaining uncertainties associated with the WTP.”At the vitrification plant an extension to milestones would automatically be triggered if technical issues were not resolved by a newly announced date of June 30, 2019. Delays caused by redesign work needed because of the resolution of technical issues or to develop a new baseline and contract changes also would trigger automatic extensions to milestones. The federal agency proposed a process under which the state and DOE would negotiate the length of extensions. If they could not reach agreement, DOE could set the length and the state could challenge it with the court. The state said in its filing that a milestone of 2034 to have the vitrification plant fully operating gives DOE sufficient time to resolve technical issues and deal with other uncertainties. The state also significantly revamped its proposal to more closely follow the sorts of milestones included originally in the consent decree. It deleted 64 proposed deadlines related to the vitrification plant. Its final proposal has 35 vitrification plant deadlines covering step-by-step construction, commissioning, and start-up of operation of different parts of the facility, culminating in full operation in 2034.
DOE is proposing that milestones be extended for retrieving waste from 12 single-shell tanks covered by the consent decree that still hold waste to address funding constraints and because of new requirements that workers wear self-contained breathing apparatus, or SCBA, for most work in the Hanford tank farms. The SCBA significantly slows work, according to DOE. It is proposing having the nine tanks in the A and AX tank farms emptied to regulatory requirements by March 2024 rather than September 2022, the current deadline. If workers continue to use SCBA past September 2016 because better ways have not been found to protect them from tank vapors, DOE proposed an extension of one year for every additional two years of work on SCBA. The state, which has filed a separate federal court case over chemical vapor protection, has said DOE has not provided convincing data for extra time required for SCBA use. It wants to retain the September 2022 deadline for the A and AX tank farms. DOE also has missed the September 2014 deadline to complete operations in the C Tank Farm, with waste retrieval not considered complete in three tanks. One tank is essentially emptied to regulatory standards with paperwork yet to be completed. A second should have waste retrieved by April 2016, according to DOE. The department is considering retrieval technology for some difficult-to-remove waste in the final C Farm tank. It proposes a deadline for that tank no later than 2022, but would set a date between now and 2022 when it settles on a retrieval method. The state wants all C Farm tanks emptied by September 2017.
DOE and the state also disagreed over what should trigger a requirement that four new double-shell tanks be built. DOE has opposed building new tanks, saying money could be better spent emptying tanks and treating the waste. It puts the cost of a 1-million-gallon tank at $85 million to $150 million. Operation of the 242-A Evaporator plant could remove enough liquid waste from double-shell tanks to create sufficient space to hold the waste from the 12 remaining single-shell tanks covered by the consent decree, it said. If the evaporator falls behind the waste reduction schedule DOE proposed in new court documents, changes or increases in evaporation operations should be considered before new tanks are required, it said. The state wants new tanks required if the evaporation work falls 2 million gallons behind its proposed schedule. It is asking the court to require DOE to start the planning and permitting work on the tanks so that if they are needed, they could be built in four years. The state and DOE next will be given a chance to respond to the other side’s proposal.
