Grouting Hanford tank waste is a hot topic these days, so we want to get some information out on where Hanford Challenge currently stands.
It is true, we do not endorse grouting Hanford tank waste. We want tank waste to be immobilized in glass (vitrified). We continue to support the long-standing litmus test of “as-good-as-glass” for any alternative tank waste immobilization technology.
Our position on grout has recently been misunderstood as being against shipping Hanford waste off site and against grout. Neither are true. We want tank waste treatment and disposal done right, without cutting corners. This post gets into the specifics of our concerns about grouting tank waste and sending it off site.
We do care about:
What radionuclides and chemicals are in the final grouted waste form.
Where the waste is treated.
How technical issues are addressed, like grout formulas, nitrates, nitrites, Technetium-99, and Iodine-129 leaching out of the grout.
How cost savings and schedule projections have been calculated.
What major assumptions have been made.
How systemic issues have been addressed to prevent another large-scale government project to treat tank waste from going off the rails.
How consent has been achieved for disposal facility siting and transportation routes.
How the public has been meaningfully involved in reviewing and providing input on a complete and thorough plan that describes grouted tank waste aspirations.
How high-level waste is reclassified.
What would we endorse? If Hanford was able to pre-treat the tank waste liquids to meet Class-A waste requirements, then we would probably give the plan a thumbs up. But, as we understand it, that is not the current plan.
As we wrote two years ago, in response to the DOE report to Congress claiming 80%+ of Hanford’s tank waste could be grouted with fantastic cost and schedule savings: “This is bureaucratic speak for, ‘Free Beer Tomorrow.’ Once research and development and design engineering are completed to support transparent, credible cost, and schedule estimates, we will certainly find out grout is much more difficult, expensive, and time consuming than advertised. Don’t rush to the pub tomorrow unless you’ve got beer money—it won’t be free.”
Despite our warning that “Congress, the State of Washington, and all Hanford cleanup stakeholders should not fall for DOE’s latest ‘Free Beer Tomorrow’ campaign[,]” it seems like many have.
Since the DOE grout report to Congress came out in December 2020, there have been more reports that add pieces to the grout-is-the-answer narrative, but still fail to provide a clear and comprehensive picture of what is being proposed.
Hanford Challenge is frustrated by the get on board or get out of the way attitude that is taking hold around grout. We believe that critical discourse is essential to get cleanup decisions that will work in the long run. Let’s talk about it, but not get swept away by big promises that don’t have the analysis to fully back them up.
There needs to be a clear, thorough, technically sound, fiscally defensible, and publicly vetted plan for: how grouting tank waste at Hanford would work, what the final grouted waste form would contain, and where that quadruple volumed waste package would be disposed. There are pieces of plans, behind-the-scenes conversations, and lots of dreamy scenarios for how this could work. But there isn’t a clear, thorough, technically sound, and fiscally defensible plan. There could be one in the future. But right now, it’s piecemeal. We’re not jumping to conclusions before we have the full picture.
In 2021, we put together a timeline Why Grout Failed at Hanford: Chronology of the Failed Grout Program. Critical questions about what has changed since then have not been answered. It seems like we are setting ourselves up to repeat this history.
We do not buy into the popular narrative that grout is the faster, better, and cheaper solution. Grout proponents sing the praises of cost savings and expediency, while underselling technical and cost-saving uncertainties and failing to adequately address the health and safety risks of a less protective waste form. Previous work has suggested that each batch of waste must be tested to develop the correct grout recipe. This could end up being an expensive, time-consuming process—not the fast and cheap solution that is being sold. Finally, grouting radioactive tank waste does not provide "as-good-as-glass" long-term protection of human health and the environment because radionuclides do not remain immobilized in grout over time and can leach out into the environment. Vitrification is still the best option.
We also want to be crystal clear that mismanagement is at the heart of most of the problems. Given the challenging nature of immobilizing tank waste, any technology will inevitably face significant technical issues that must be managed to produce technical solutions. However, the tank waste project has been plagued by mismanagement that consistently leads to cost increases and delays. This is true of vitrification and it’s true of grout. Until these mismanagement systemic issues are addressed, delays and cost overruns are inevitable—regardless of the technical ability to immobilize Hanford tank waste. Stated another way, no solution is faster and cheaper at Hanford without big tradeoffs. Hanford is a big site with a lot of money flowing into it (the President just proposed $3B for Hanford alone in FY2024).
Specific systemic issues we are concerned with include: suppression of safety and technical concerns, especially when profits and careers are on the line; overly controlled information sharing with the public and regulators; and fraud. All of these issues have historically resulted in preventable delays, cost overruns, and have put workers in harm's way. What has changed to prevent those same issues from derailing the next “greatest thing”—grout?
We are interested in the details and context in which this grouted tank waste future plays out. When we lay out the information at hand, the promised grout shortcuts are not that clear. Our specific issues include: technical issues, the how and where of grouting, disposal concerns, and selective urgency.
Scenarios for Grouting Tank Waste
We want to be clear about what we mean when we say grouting Hanford tank waste. In this instance, we are talking about proposals to treat Hanford’s high-level tank waste to meet low-activity waste criteria and immobilize it in grout.
The following scenarios to grout Hanford’s tank waste are being considered, and our brief thoughts on each are below.
Tank Closure: We are advocating for delaying the closure of the C-Farm Tanks. We think more waste should be removed before the tanks are filled with grout, the farm is capped with a barrier, and we walk away from the leaked waste beneath the tanks. Some are saying it is urgent to close C-Farm to prevent more water intrusion into tanks that could drive leaks from the tanks to the soil. We disagree that this is a top priority. Once the tanks are grouted and the area is capped with a barrier, cleanup is done. They aren’t going back to clean up more waste later. This is the first of Hanford’s tank farms that will be closed and it will set precedent for future tank farm closure. We want that precedent to be more waste removed and a plan for getting at the leaked waste in the soil under the tanks.
Test Bed Initiative: We are concerned about the precedent that will be set by proceeding with Phase Two Test Bed Initiative. The plan is to send 2,000 gallons of tank waste liquids to Perma-Fix Northwest (PFNW) for grouting and then ship the grouted waste to Texas or Utah for disposal. We want more clarity about the pre-treatment plan for this waste; technical issues related to grout formulas, nitrites, nitrates, Technetium-99, and Iodine-129 addressed; and real, representative data about the radionuclides and chemicals that would be in the final grouted waste form. Due to PFNW’s documented history of environmental violations and suspect safety history, any treatment of Hanford waste should be conducted on the Hanford site.
Supplemental Low Activity Waste: This is the yet-to-be-made decision about what to do with the portion of Hanford tank waste that the current Waste Treatment Plant was never designed to handle. A national group called the Federally Funded Research and Development Committee (FFRDC) has finalized a report, that is being reviewed by the National Academy of Sciences, looking at grout as an option for this waste. The FFRDC is saying grout is the answer, but when you look closer there are still a lot of issues to be addressed. Hanford Challenge thinks we can wait on this decision and instead focus on vitrification. Some experts have indicated that we may not need Supplemental Low Activity Waste at all if they are able to increase the amount of waste they can get in the glass (waste loading).
Urgency: We are noticing what we will call a selective use of urgency to back up the need to start grouting tank waste now. Leaked and leaking tank waste is a problem, and it has been for a long time. We are noticing that tank leaks are now being used as a rallying cry for grouting waste now. For more than a decade, we have advocated for building new tanks as the answer to leaking tanks. We know how to build new tanks. We do not believe building new tanks is a death sentence for tank waste treatment, but rather a preventative measure that protects the environment and buys us more time—which is something we need no matter what.
Just Grout Tank Waste and Send it to Texas: Once again, where is the plan? This is the vaguest concept that we encounter the most in meetings. It seems to have started with the DOE report to Congress in December 2020 claiming 80%+ of tank waste can be grouted and shipped to Texas. The claims are piecemeal and evoke some magic thinking to bypass real issues that have yet to be solved. We also reiterate our concerns about the ability of the federal government to pull off big projects that actualize their faster, cheaper selling points. We don’t want to see the grout fanaticism derail progress on glassifying tank waste. We want the investment of time, energy, and money to be in vitrification not grout.
Specific Issues with Grout
Hanford Challenge is open to talking about grout, but we do not think it is the magic bullet solution for Hanford’s tank waste. We know glass is the most protective waste form for tank waste and want to see it through.
Technical Uncertainties
Now, we’re going to get into more specific issues. Let’s start with the technical uncertainties as we understand them. It matters to us what is in the final waste form.
Long-lived radionuclides, like Technetium-99 and Iodine-129, leach out of the grouted waste form. We want these “bad actors” to stay immobilized and ideally for them to end up in the high-level waste glass.
Past studies of grout show that nitrates and nitrites also leach out of the grouted waste form, while they aren’t an issue in glass because the heat destroys them.
Hanford tank waste has a varied and complex chemistry and may require a different grout formula for each batch of waste. Developing a unique grout recipe for each batch of waste could be an expensive, time-consuming, and difficult process—not the fast and cheap solution that is being sold. Due to the highly complex chemistry of Hanford tank waste, a chemical engineer with expertise in Hanford waste chemistry should be involved in reviewing any and all grout proposals.
If the solution to the complex chemistry is to increase the grout to waste ratio (more grout, less waste), how does this impact total grouted waste volumes, which are already significantly more compared to a glassified waste form?
More information needs to be provided about characterization and sampling of tank waste in general and specifically after pre-treatment to clarify what radionuclides, chemicals, and total curie content would be in the final grouted waste form and ensure that the waste meets Waste Acceptance Criteria.
How and Where
We also have concerns about the how and where of grouting Hanford tank waste. This is related to the issues above because we care about what is in the final waste form and we also care about where the waste is treated. We don’t like the current options on the table.
The amount of pre-treatment for the tank waste imagined for grouting is unclear and shifting. In a document related to Phase 2 of the Test Bed Initiative to grout tank waste, there was no pre-treatment mentioned. Just some inadequate (in our opinion) explanations of grab sampling of the liquid waste that would be shipped off site. In other documents released in the past month, the use of a cesium removal treatment similar to what is being used for the Low-Activity Waste vitrification process is mentioned. Once again, there isn’t a clear, thorough, technically defensible, and publicly vetted plan for how this would work. To reiterate our point above, we would prefer long-lived radionuclides to be removed and glassified in the high-level waste stream.
Right now, Perma-Fix Northwest (PFNW) is the only real contender for grouting treated tank waste. We wrote a report uncovering a myriad of safety concerns with PFNW and do not believe it should be used for treating Hanford tank waste. Here are some of the top issues with PFNW:
Risk to Residents: It is located in a growing residential community with a daycare center less than a mile away.
Tank Waste on Public Roads: Liquid tank waste would be transported on public roads to get to PFNW.
Safety Hazards: PFNW had serious worker over-exposures to radiation in the past and two fires in 2019, both unreported in the press. One was deemed "a near catastrophe" by a state inspector as fire alarms were inoperable at the time.
Better at Hanford: We have issues with DOE to be sure, but there is better oversight, worker training, and clearer regulatory authority on the Hanford site than at a commercial facility.
Transportation risks seem too high to ship liquid tank waste off site for grouting (Tennessee and Texas are stated as potential places for liquid waste treatment in some documents).
Since we are against using Perma-Fix Northwest for treatment, proceeding with grout would require building onsite treatment facilities, which would take time, extra cleanup funding, and distract from work on the Waste Treatment Plant. The funding to build a new grout plant would be above and beyond the increased annual funding referenced in the 2022 Lifecycle Report, which starts at $5B in FY25 as a low estimate and keeps going up, until it drops back down to $2B in 2070. All of this is to say—we need a lot more money than we are currently getting, even above the amount that the President just proposed for FY24 that would bump the Hanford budget up to an historic high of $3B. It still isn’t enough to keep the existing work on track.
Disposal
Our final concern is a big one—disposal. Where is this grouted waste going to end up? Proponents of grout are convinced that grouted low-level waste will end up off site. We care about where this waste ends up and how it is disposed.
Grouting tank waste significantly increases the volume of waste that needs to be disposed. The figures we have seen show up to four times the waste volume. This matters if the final resting place is not a certainty.
Disposal at the commercial low-activity waste landfills in Texas or in Utah is the plan, but it isn’t certain. Hanford Challenge would like to see evidence of a consent-based siting process that involves broad-based, full, free, prior, and informed consent. We’re uneasy with the not-my-problem-anymore vibe that accompanies the off-site disposal story. It matters to us if long-lived radionuclides, like Technetium-99 and Iodine-129, leach out of the grouted waste form and have the potential to hurt people in other states.
Along the same lines as a consent-based siting process for the disposal facility, a consent process that involves broad-based, full, free, prior, and informed consent should be implemented with the stakeholders along transportation routes.
Because it is not a guarantee that this waste ends up out of state, it also is concerning to imagine a scenario where this quadruple volume of waste ends up bouncing back to the Hanford site, and ends up being disposed onsite.
And a big uncertainty is still what is in the final grouted waste form. We don’t know and this is very important to Hanford Challenge. We want long-lived radionuclides removed. For anyone wondering how to get a yes from Hanford Challenge, we would be ok if the tank waste was pre-treated to Class A standards prior to being grouted, but that is not the plan as we understand it.
We also want more information about the process that would be used to ensure that grouted waste meets the Waste Acceptance Criteria at off site facilities and what happens when the waste fails to meet that criteria. Where does that waste go? We are concerned with grouted waste bouncing back to Hanford.
We are also concerned about future access to this waste, both health and safety impacts and proliferation risks. Disposing of long-lived radionuclides in shallow land burial would make it easier to unintentionally or intentionally dig up the waste in the future.
Reclassification
We also care about how high-level waste is reclassified. More information on our position can be found here. To summarize our main points, we are ok with reclassification if:
There is a presumption that high-level waste (which include long-lived radionuclides and chemicals) will be vitrified and buried in a deep, geological repository;
There is an agreed-upon understanding that long-lived radionuclides presumptively require disposal in a geological repository;
The use of reclassification is used in “special and unusual” circumstances – not wholesale to reclassify substantial portions of high-level waste and never for expediency or economic cost-savings reasons;
The high-level waste has been treated and key radionuclides have been removed;
An independent entity (such as a new agency or commission created for the purpose of nuclear waste disposition) makes the determination to reclassify the waste;
There has been an open, transparent, and inclusive process involving interested stakeholders;
The State of Washington and the affected tribal nations concur;
There is a comprehensive report specifying what waste volumes/concentrations are being left at Hanford, for how long, and why;
An assessment of the cumulative impact on the environment and future generations is prepared and made publicly available; and
There is a judicial process available for aggrieved parties to challenge a determination in federal court.
So, to restate our main point, we need more information and analysis. The promise of free beer tomorrow still doesn’t hold up. So for now, we’ll keep asking questions and voicing our concerns. We want tank waste treatment that protects people and the planet. We should learn from past mistakes and take the time to do it right.
Previous Hanford Challenge papers on grout:
[This post may be updated. Last updated March 24, 2023]