Record of Decision for the Tank Waste Remediation System, Hanford Site, Richland, WA

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.

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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