The Department of Energy is proposing having the Hanford vitrification plant fully operating in 2039, a delay of 17 years from the current schedule, after a federal judge pressed it for a concrete deadline proposal.
The state of Washington also appears resigned to the plant needing significantly more time to start full operations, proposing a deadline of September 2034.
DOE has been reluctant to propose new deadlines for the vitrification plant as it works to resolve technical issues at the massive and complex plant. It is being built to turn up to 56 million gallons of radioactive waste into a stable glass form for disposal.
Committing to deadlines when it is unclear what work needs to be done and at what cost leads to missed deadlines, DOE has said.
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However, U.S. Judge Rosanna Malouf Peterson ordered DOE and the state of Washington to submit new proposed deadlines by Friday consistent with the work covered in the 2010 consent decree, including a deadline for having all parts of the vit plant operating.
DOE hedged its new proposed deadlines, laying out a plan to extend them if its work falls behind schedule for different reasons. Those would include not having technical issues resolved by a newly announced date of June 30, 2019.
Uncertainty reflects the scarcity of necessary information, but not the absence of adequate expertise.
DOE in federal court documents
DOE’s 2039 start-up date is proposed for having all major facilities at the plant operating simultaneously.
But DOE remains committed to starting up part of the plant as soon as 2022 to glassify low-activity radioactive waste. The major unresolved technical issues at the plant, including the remote possibility of an unplanned nuclear reaction or buildup of flammable gases, involve only high-level radioactive waste.
A year ago, the state of Washington had proposed having all parts of the vitrification plant fully operating in September 2031, but revised its proposal to allow three more years, according to documents it submitted Friday. The extra time gives DOE an additional buffer because of the uncertainty related to technical issues, the state said in court documents.
New deadlines are being set by the federal court after court-enforced deadlines agreed to in 2010 to resolve a state lawsuit are at serious risk of being missed. The proposals submitted Friday replace those both parties submitted a year ago. The judge found the initial submissions veered too far from the original consent decree on some matters.
The proposals filed Friday address not only the vitrification plant, but when 12 single-shell tanks must be emptied of waste. They also address what would trigger a requirement that DOE build new double-shell tanks to provide additional stable storage space until the waste can be treated for disposal.
Vitrification plant proposals
DOE described its proposal to allow extensions to the deadlines it is proposing for building and operating the vitrification plant as being “narrow modification mechanisms.”
It cannot “reasonably or responsibly” commit to dates for facilities with technical issues without an extension process, it said in court documents.
The deadlines cover steps such as completing construction of parts of the plant and testing its operations.
The state has reasonably accounted for the uncertainties associated with technical issue resolution and facility redesign in establishing these deadlines.
Washington state in federal court documents
Extensions for the vitrification plant deadlines would be triggered initially by a delay in resolving key technical issues. Further delays in redesign work required because of the technical issues and then work to develop a new cost and schedule and revise contracts also would be covered by the deadline extensions.
The state says allowing DOE until 2034 to have all facilities of the vitrification plant operating together gives DOE a sufficient buffer to deal with uncertainties at the vitrification plant, including delays related to technical issues.
The state significantly scaled back its proposal to the court.
It deleted 64 proposed deadlines related to the vitrification plant after the judge said that she would only consider proposed new deadlines that closely reflected the work covered by the original. The state’s new proposal has 35 vitrification plant deadlines covering step-by-step the construction and operation of the plant.
The state and DOE agree that an early start to treating low activity waste is a good idea. The judge has declined to include that in the consent decree, saying it is beyond the scope of the original consent decree.
However, both parties say they remain committed to pursuing treatment of low activity waste as soon as 2022.
Not only would a 2022 start make progress in reducing the stockpile of untreated waste, but it would free up needed space in double-shell tanks. Double-shell tanks are being used to hold waste emptied from leak-prone, single-shell tanks until the waste can be treated for disposal.
Proposals for emptying tanks
DOE and the state disagree on whether DOE should be given more time to empty tanks because of the requirement for workers to wear protective, but cumbersome, supplied air respirators for much of the work.
DOE had until fall 2014 to finish emptying waste from all 16 of the underground tanks in the group called the C Tank Farm. But increased worker protection from chemical vapors and delays in receiving federal money have slowed required tank farm work, according to court documents.
Now DOE says it can have the 14th of those tanks emptied yet this year, with just the paperwork left to go. But it wants until April 2016 to empty the 15th tank, and then would have the last tank in the series emptied no later than 2022. A date would be set between now and 2022 after DOE settles on a plan to empty some difficult waste from that tank.
The consent decree also covers the next group of nine tanks to be emptied, from the total remaining 132 single-shell tanks that still will have waste after C Farm work is completed.
DOE says it can complete that work by March 2024, which includes an extension because of issues related to chemical vapors from the tanks. Tank farm workers are wearing supplied air respirators now for much of the work in the tank farms until better ways are implemented to protect them from breathing the vapors.
If workers are still using supplied air respirators after September 2016, DOE will want that proposed 2024 deadline extended at the rate of one extra year for each two years workers wear the respirators.
The state is wholly committed to worker safety at the Hanford site and fully supports the use of supplied air or other measures to minimize tank vapor exposures.
Washington state in federal court documents
The state, which has a separate lawsuit in federal court over chemical vapor protection, argues that DOE has produced no convincing information to show the need for the delay.
It wants all C Farm tanks emptied by September 2017 and the next nine tanks emptied by September 2022, the date currently in the consent decree.
Proposals for new storage tanks
The state is proposing that DOE be required to start planning and permitting work now to build new double-shell tanks, in case they are needed.
DOE has adamantly opposed building additional waste storage tanks, saying money could better be used toward the end goal of getting waste treated for disposal. It puts the cost of each 1-million gallon tank at $85 million to $150 million.
“New double-shell tanks would shatter the bargain agreed to by the parties,” DOE said in court documents.
New double-shell tanks would shatter the bargain agreed to by the parties.
DOE in federal court documents
The state has proposed that DOE build up to 12 new double-shell tanks to hold more of the waste from older leak-prone tanks until it can be treated for disposal because of delays in getting the vitrification plant operating.
Malouf Peterson said she would consider requirements that would trigger up to four new 1 million-gallon tanks initially.
DOE has said it would have enough remaining space in its 27 usable double-shell tanks to continue waste retrieval from single-shell tanks on schedule by using its evaporator plant to reduce the liquid volume of the waste.
However, as instructed by the judge, it proposed a set of annual requirements for the amount of waste that must be evaporated. If those goals are missed, the issue should be first addressed by steps such as increasing evaporation operations rather than building new tanks, it said.
The state wants construction of new storage tanks to be triggered if DOE falls 2 million gallons behind on a proposed schedule to reduce waste volumes through operation of the evaporator. But because work from planning to building the tanks could take a decade, it wants DOE to be ready to start construction. Construction would take four years, according to the state.