Appendix BAlternative Selection Process

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TABLE OF CONTENTSSection Page

Appendix B Alternative Selection Process B-1B.1 Introduction B-1B.2 Purpose B-1B.3 Identification of Candidate Alternatives B-2

B.3.1 Analysis of Previous INEEL and other HLW DOE Studies B-2B.3.2 Consideration of Public Comments B-4

B.3.2.1 Overall Public Concerns B-4B.3.2.2 Public Comments Applied to Alternative

Development B-4B.3.3 Candidate Alternatives B-5

B.3.3.1 Alternatives Considered for Initial Analysis B-5B.3.3.2 Alternatives Not Considered for Init ial

Analysis B-6B.4 Evaluation of Candidate Alternatives B-6

B.4.1 Evaluation Methodology B-6B.4.2 Evaluation Criteria B-8B.4.3 Application of Criteria to Candidate Alternatives B-8

B.4.3.1 Program Mission B-8B.4.3.2 Cost Factors B-9B.4.3.3 Technical Feasibility B-9B.4.3.4 Environment, Safety, and Health B-10B.4.3.5 Public Concerns B-10B.4.3.6 Program Flexibility B-11

B.5 Evaluation Summary and Results B-11B.6 Refinement of Draft EIS Alternatives B-12

B.6.1 Draft EIS Alternatives Refin ement (Phase I) B-12B.6.2 EIS Advisory Group (EAG) Review B-16B.6.3 Alternative Refinement (Phase II) B-16B.6.4 State of Idaho Review B-17

B.7 Final List of Draft EIS Alternatives B-17B.8 Additional Alternatives/Options and Technologies Identified

during the Public Comment Process B-18B.8.1 Introduction and Purpose B-18B.8.2 Alternatives/Options Evaluated After the Draft EIS

was Issued B-18B.8.2.1 Steam Reforming B-18B.8.2.2 Grout-In-Place B-19

B.8.3 Treatment Technologies Evaluated Afterthe Draft EIS was Issued B-20B.8.3.1 Treatment Technologies Suggested

by the National Academy of Sciences B-20B.8.3.2 Treatment Technologies Identified

from Public Comment B-21

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Appendix B

TABLE OF CONTENTS(continued)

Section Page

B.8.3.3 Evaluation of Treatm ent Technologies andOptions During the PreferredAlternative Identification Process B-22

B.9 Process Used to Identify the Preferred Alternatives B-26B.9.1 Background B-26B.9.2 Approach B-27

B.9.2.1 Waste Processing Alternative Evaluation B-27B.9.2.2 Facility Disposition Alternative Evaluation B-31

B.9.3 Preferred Alternatives B-32B.9.3.1 Decision Management Team's Recommended

Preferred Alternative B-32B.9.3.1.1 Waste Processing B-32B.9.3.1.2 Facility Disposition B-33

B.9.3.2 DOE's Preferred Alternative B-34B.9.3.3 State of Idaho's Preferred Alternative B-36

B.9.3.3.1 Waste Processing B-36B.9.3.3.2 Facility Disposition B-36

B.10 Final List of Final EIS Alternatives B-36References B-38

LIST OF FIGURESFigure Page

B-1 Organization of teams for identifying the Preferred Alternative. B-28B-2 Overview of Decision Management Team. B-29

LIST OF TABLESTable Page

B-1 Candidate alternatives. B-7B-2 Total rating of candidate alternatives. B-12B-3 Summary of the Phase I Alternative Ref inement Meeting. B-13B-4 Goals and associated criteria used by the Decision Management Team

to score mixed transuranic waste/SBW processing technologies. B-32

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Appendix BAlternativeSelection ProcessThis appendix is a summary of the process usedto identify the alternatives found in this EIS.Of particular importance is Section B.9.Sections B.9.1 and B.9.2 describe the processused to identify the Decision ManagementTeam’s recommended preferred alternative.Section B.9.3 describes the DecisionManagement Team’s recommended alternative,DOE’s preferred alternative, and the State ofIdaho’s preferred alternative.

B.1 Introduction

The U.S. Department of Energy (DOE) ispreparing the Idaho High-Level Waste andFacilities Disposition Environmental ImpactStatement (Idaho HLW & FD EIS), in accor-dance with the National Environmental PolicyAct (NEPA), to support the HLW decision-mak-ing process at the Idaho National Engineeringand Environmental Laboratory (INEEL) for-merly called the Idaho National EngineeringLaboratory or INEL. Under NEPA in 40 CFR1502.14(a), an EIS must "rigorously explore andobjectively evaluate all reasonable alternatives,and for alternatives which were eliminated fromdetailed study, briefly discuss the reasons fortheir having been eliminated."

The Notice of Intent for the Idaho HLW & FDEIS (62 FR 49209; September 19, 1997) identi-fied three initial alternatives for managing theHLW at INEEL: the Proposed Action orSeparations Alternative, No Action Alternative,and Non-Separations Alternative. Since theissuance of the Notice of Intent and in thecourse of public scoping and review of publiccomments that include Tribal issues, privatesector industry, State of Idaho, and agencycomments on the Draft Idaho HLW & FD EIS,DOE has added a number of alternatives oroptions.

B.2 PurposeThe purpose of this appendix is to describe theselection process that DOE employed to identify arange of reasonable waste processing alternativesfor the Idaho HLW & FD EIS, including the iden-tification and application of the criteria for assess-ing the validity of candidate alternatives.

The Council on Environmental Quality regulationsdirect all Federal agencies to use the NEPA processto identify and assess the reasonable alternatives toproposed actions that would avoid or minimizeadverse effects of these actions upon the quality ofthe human environment [40 CFR 1500.2(e)].These regulations further state that "reasonablealternatives include those that are practical or fea-sible from a common sense, technical, or economicstandpoint. The number of reasonable alternativesconsidered in detail should represent the full spec-trum of alternatives meeting the agency's purposeand need; but an EIS need not discuss every uniquealternative, when an unmanageable number isinvolved."

The primary steps of the alternative selection pro-cess are:

• Review previous HLW management studies,DOE EISs, technical literature, industry rec-ommendations, and stakeholder comments

• Identify an initial list of candidate alterna-tives

• Review engineering studies and public input

• Revise initial set of candidate alternativesbased on recent studies and public input fol-lowing the Notice of Intent and scopingmeetings

• Identify screening criteria to evaluate thecandidate alternatives

• Describe criteria that were used to assesseach alternative

• Apply the screening criteria to each candi-date alternative

• Select the recommended set of candidatealternatives

B.3 Identification ofCandidate Alternatives

B.3.1 ANALYSIS OF PREVIOUS INEELAND OTHER HLW DOE STUDIES

"Historical Fuel Reprocessing andHLW Management in Idaho"( Knecht et al. 1997)

A summary of historical fuel reprocessing andwaste management at the Idaho NuclearTechnology and Engineering Center (INTEC)(formerly called the Idaho Chemical ProcessingPlant or ICPP) appeared in Radwaste Magazine(Knecht et al. 1997). The article outlines someof the early technology development work atINTEC and includes 40 references related towaste forms produced from calcine, such asmetal spray coating, grout matrix, metal matrix,glass, and ceramic. Early studies were also car-ried out in calcine retrieval, calcine dissolution,calcine stabilization, and transuranic elementseparation. In many cases, results of early tech-nology development work were used to developpre-conceptual design and costs. The designinformation supported the INEEL portion of anumber of complex-wide defense waste manage-ment studies under the Atomic EnergyCommission and the Energy Research andDevelopment Administration, predecessors toDOE.

Alternatives for Long-Term Managementof Defense High-Level Waste, IdahoChemical Processing Plant, ERDA 77-43(ERDA 1977)

This INTEC report evaluated and provided costand risk estimates for three alternatives: (1)retain the waste at INTEC in retrievable storagefacilities; (2) ship the waste to a geologic repos-itory; and (3) remove (separate) the actinides,ship the actinides to a geologic repository, andstore the remaining waste at INTEC. Wasteform options under these alternatives includedcalcine pelletization, metal matrix, and sinteredglass ceramic to span the range of calcine, con-crete, metal, glass and ceramic waste forms.

Environmental Evaluation of Alternativesfor Long-Term Management of DefenseHigh-Level Radioactive Waste at the ICPP,IDO-10105 (DOE 1982a)

The subject evaluation considered four alterna-tives: (1) calcine all waste and leave calcine inplace (no action); (2) retrieve, modify the cal-cine, and dispose of modified calcine at INEEL;(3) retrieve, separate the actinides, dispose of theactinides offsite, and dispose of the remainingwaste at INEEL; (4) delay retrieval, modify thecalcine, and dispose of the calcine offsite. In thisstudy the waste form options included calcine,glass or pelletized calcine, glass or stabilized cal-cine, glass for actinides, and calcine for onsitedisposal.

Long-Term Management of Defense High-Level Radioactive Wastes [Research andDevelopment Program for Immobilization],Savannah River Plant, DOE/EIS-0023(DOE 1979)

From 1970 to 1983 events outside of INEEL,such as waste-form research at DOE's SavannahRiver Site (SRS) influenced the INEEL HLWresearch and development program. As a result,DOE HLW management became focused ontreating wastes first at SRS, then Hanford Site,and finally Idaho. In 1977, DOE issued thelong-term management EIS for HLW immobi-lization research and development. That EISevaluated a number of potential HLW forms, anda follow-on environmental assessment selectedborosilicate glass as the preferred form (DOE1982b).

The Defense Waste Management Plan,DOE/DP-0015 (DOE 1983)

This plan established a schedule for waste treat-ment and assumed that the Savannah River Siteand Hanford Site would vitrify their HLW.INEEL was assumed to construct a new facilityto immobilize newly generated liquid waste aswell as calcined HLW with annual production ofapproximately 500 HLW canisters. This planprovided estimates of HLW volumes to be gen-

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Appendix B

erated through 2015. Subsequently, the DOE-Idaho Operations Office completed the study(DOE 1983) in 1983 to evaluate reducing wastevolumes by more efficient fuel processing meth-ods.

ICPP Tank Farm System Analysis(WINCO-1192) (WINCO 1994)

This Tank Farm study proposed 14 variations ofHLW separations alternatives. These alterna-tives differ with respect to the start of separationsand immobilization operations, the number ofcalcining campaigns required, and various cal-cine pretreatment and treatment technologies.The conclusion was that the separations varia-tions produced significant differences in calcineprocessing rates, bin set storage requirements,and final waste forms. This study underscoredthe advantages of a separations alternative andbrought out the possibility of HLW calcine vitri-fication as a viable non-separations option.

SBW Treatment Study,WBP-8-95/ALO-3-95 (LITCO 1995a)

This study evaluated options for meeting theNotice of Noncompliance Consent Order tocease use of the INTEC pillar and panel tanksand the remaining tanks in the Tank Farm. Thestudy addressed 15 separations and non-separa-tions alternatives. The separations alternativesused an evaporation precipitation technique toreduce the sodium content of the SBW prior tocalcining; the separations options also includedcesium, strontium, and transuranic extractionmethods for separating the high-activity fractionfrom the low-activity fraction. The non-separa-tions alternatives focused on improving the cal-cine process by high-temperature operation orusing additives such as aluminum nitrate, silica,and sugar to reduce the SBW volume. The study

also included an alternative to ship all the con-centrated SBW to Hanford for interim storageand processing.

ICPP Radioactive Liquid and Calcine WasteTechnologies Evaluation Technical Reportand Recommendation, INEL-94/0019(LITCO 1995b)

The purpose of this evaluation was to supportDOE in developing a strategic plan to manageINTEC radioactive liquid and calcined waste bypresenting performance data for candidate alter-natives. The study addressed 27 alternatives forwaste treatment including both separations andnon-separations techniques. These alternativesvaried with respect to facilities, SBW treatment,calciner operations, and calcine treatment.Screening against six criteria led to radionuclidepartitioning as one of the top options to be con-sidered. The report recommended a two-phasedimplementation of a high-activity waste immobi-lization plant to spread the funding requirementsover a longer time period.

HLW Alternatives Evaluation,WBP-29-96 (LMITCO 1996)

This study reviewed calcination and separationsto determine the best path forward for INTECHLW management. Both approaches wouldmeet the Settlement Agreement/Consent Orderand are technically feasible; the primary dis-criminator is cost. These approaches weredeveloped into three basic options: (1) calcina-tion of HLW until June 1998 and SBW until2012; (2) calciner shutdown in 2001, radionu-clide separation/grouting beginning in 2010, andcalcine retrieval, dissolution, and separationcommencing in 2015; and (3) separations andshipping of the high-activity waste offsite forimmobilization and storage.

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Appendix B

Regulatory Analysis and Proposed PathForward for the Idaho National EngineeringLaboratory High-Level Waste Program,DOE/ID-10544 (DOE 1996)

This report is a HLW regulatory analysis of theradionuclide constituents, identification ofResource Conservation and Recovery Act(RCRA) hazardous constituents, and plans forclosure of the INTEC Tank Farm and bin sets.The report offered four major alternatives forconsideration: no action, planning basis (DOE1998), full treatment (separations), and limitedvitrification.

B.3.2 CONSIDERATION OF PUBLICCOMMENTS

DOE conducted public scoping workshops onthe Idaho HLW & FD EIS on October 16, 1997in Idaho Falls, Idaho and on October 23, 1997 inBoise, Idaho. These public workshops and writ-ten scoping comments provided DOE publicinput about issues and potential alternatives thatshould be addressed in the Idaho HLW & FDEIS.

DOE also received scoping comments from theState of Idaho INEEL Oversight Program(Trever 1997), the State of Nevada NuclearWaste Project Office (Loux 1997), and theINEEL Citizens Advisory Board (Rice 1997).All public comments were considered in devel-oping the candidate alternatives for the IdahoHLW & FD EIS. A summary of the major pub-lic concerns appears in the next section; a list ofnew or modified alternatives obtained from thepublic inputs is shown later in this appendix.

B.3.2.1 Overall Public Concerns

Treatment Criteria - At this time, there is con-siderable uncertainty regarding the proposedrepository at Yucca Mountain and the final tech-nical standards for wastes to be disposed ofthere. Given those uncertainties, determine whatcriteria DOE should use to establish that thewaste form(s) produced are suitable for disposalin a geologic repository outside the State ofIdaho (i.e., that a "road-ready" waste form hasbeen achieved).

Disposal - If a geologic repository is not avail-able, determine what other disposal options existfor HLW outside the State of Idaho.

Storage/Disposal in Idaho - Clearly examineand explain any proposal to store or dispose oftreated waste over the Snake River PlainAquifer, including performance-based or landfillclosure of the Tank Farm as opposed to cleanclosure.

Hazardous Constituents - Develop a strategyfor dealing with RCRA-regulated hazardousconstituents.

Technical Viability/Privatization - Demonstratein advance that the alternative selected willwork.

Cost-risk Benefits - The alternative selectedshould reduce health and safety risks enough tojustify the cost of treatment and any additionalrisk to workers posed by the treatment activities.

Funding - Cleanup of the INEEL site is impor-tant, and the Federal government should seekadequate funding to honor its commitments to doso.

Compliance Concerns - Numerous, and in somecases conflicting, compliance requirements existfor INEEL HLW management and facilities dis-position activities. These conflicts should beclarified, and the compliance factors prioritized.

B.3.2.2 Public Comments Applied toAlternative Development

The following comments relate to new or modi-fied alternatives resulting from public input.DOE considered these comments when prepar-ing the list of Idaho HLW & FD EIS candidatealternatives.

• Include a true no action alternative-i.e.lock up and walk away.

• Postpone any action until waste decays tonon-harmful levels, better technologies aredeveloped, or disposal sites are identified.

• Calcine now, store the calcine onsite, andtreat the calcine later when DOE disposalsites are available.

• Fully review options for disposing ofINEEL HLW onsite in Idaho.

• Dispose of high-activity and low-activitywaste offsite, such as in a new repository.

• Provide long-term storage of both high-activity and low-activity waste onsite.

• Remove the transuranics from the HLW,dispose of TRU at the Waste Isolation PilotPlant, and dispose of the high-activityfraction at INEEL.

• Identify alternatives for bin set and TankFarm closure including clean closure ofHLW tanks.

• Consider a wide range of separations tech-nologies.

• Vitrify all HLW before or after calcination.

• Consider technologies from other sites andcountries.

• Ship HLW elsewhere for treatment andlong-term storage such as the Nevada TestSite in Nevada.

• Explore volume reduction, filtration, andencapsulation technologies.

• Modify the No Action Alternative toinclude placement of calcine in closedINTEC tanks.

• Analyze treatment and disposal alterna-tives separately.

• Develop alternatives for facility disposi-tion.

• Analyze all waste in all bin sets and tanksto determine all hazardous constituents.

• Use the same process the Hanford Site isusing for waste immobilization.

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• Don't let Yucca Mountain waste volumerestrictions drive technology development;the Yucca Mountain repository may neveropen.

B.3.3 CANDIDATE ALTERNATIVES

DOE's first step in conducting the candidatealternative selection process was to review pre-vious DOE and INTEC HLW studies asdescribed earlier in this appendix. The reviewincluded five major INTEC waste treatmentstudies conducted between January 1994 andSeptember 1997 and helped to ensure that DOEconsidered all reasonable and viable alterna-tives. Potential alternatives were then identifiedthrough a systematic, iterative process that usedseveral sources including: (1) previous INTECHLW studies, (2) value engineering sessions,and (3) public comments received during theIdaho HLW & FD EIS scoping process.

B.3.3.1 Alternatives Considered forInitial Analysis

This process resulted in an initial set of potentialcandidate alternatives for consideration in theIdaho HLW & FD EIS. The candidate alterna-tives include waste processing, interim storage,transportation, and final disposal options. It isimportant to note that each candidate alternativeis composed of individual process stages (e.g.,HLW treatment, interim storage, and/or disposalof low-activity grout) that are independent.Therefore, each candidate alternative is a combi-nation of possible process stages that may bemodified. This modular approach will allowDOE greater programmatic flexibility in imple-menting the HLW alternatives and coordinatingprograms and technologies from other DOEsites. DOE identified the following waste pro-cessing alternatives and options for initial EISscreening, analysis, and evaluation.

1. No Action Alternative (as described in theNotice of Intent)

2. Separations Alternatives

A. Full Separations

B. 2006 Plan

C. Transuranic Separations/Class AGrout

D. Transuranic Separations/Class CGrout

3. Non-Separations Alternatives

A. Vitrified Waste

B. Hot Isostatic Pressed Waste

C. Cement-Ceramic Waste

D. Direct Cement Waste

Additional information concerning these candi-date alternatives considered for initial analysis isprovided in DOE (1999a).

B.3.3.2 Alternatives Not Consideredfor Initial Analysis

Several candidate alternatives were eliminatedfrom initial EIS analysis. These alternativeswere not considered for one or more of the fol-lowing reasons: (1) did not meet the purposeand need of the EIS, (2) required significantlymore development work to achieve technicalmaturity, (3) was very similar to or was boundedby other alternatives, or (4) was judged to beimpractical or too costly for consideration.

Alternatives Rejected for Technological Reasons

• In situ vitrification

• Upgrading tanks for long-term storage

• Use of Hanford crystalline silicotitanatetechnology

• Storage of wastes in long-lasting concretecontainers

• Homogenization and mixing of variouswastes (i.e., slurry)

• Use of small solid units to fill tanks versuspoured liquids

Alternatives Rejected That Do Not Support theEIS Purpose and Need

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Appendix B

• Treatment of Argonne NationalLaboratory-West spent nuclear fuel atINTEC

• Burning of HLW in a reactor such as theIntegral Fast Reactor

• Importing other sites' HLW to INEEL fortreatment and interim storage

• Use of old INTEC facilities as a secondHLW repository

B.4 Evaluation ofCandidate Alternatives

The primary purpose of this preliminary EISalternative evaluation was to evaluate the candi-date alternatives identified in Section B.3 andidentify a reasonable set of alternatives for theIdaho HLW & FD EIS. The secondary purposeof this alternative evaluation was to provide asound, traceable, and defensible process to sup-port the final selection of Idaho HLW & FD EISalternatives. These alternatives provided for thetreatment, storage, and disposition of HLW andSBW currently managed at the INTEC.

B.4.1 EVALUATION METHODOLOGY

The methodology for the identification of thecandidate alternatives was based upon a compre-hensive evaluation of all potential alternativeswith respect to six essential Idaho HLW & FDEIS criteria (see next section). A DOE team ofexperienced personnel, who qualitativelyassessed each alternative against the criteria,performed the evaluation. The DOE Team wasasked to recommend reasonable candidate alter-natives with high potential to meet the criteria.

Prior to the evaluation of the candidate alterna-tives, DOE reviewed the studies listed inSection B.3.1. The team focused on identifyingimportant program considerations, public sensi-tivities, and related waste management data thatwould help evaluate potential alternatives withrespect to each criterion.

The DOE Team then systematically applied thecriteria to all candidate alternatives to assesshow well each alternative met the program goalsand public concerns. The assessment of eachalternative with respect to each criterion wasdone on a qualitative basis. Each alternative wasgiven one of three ratings for each criterion asshown in Table B-1.

After reviewing the reference materials and con-ducting a structured assessment, the DOE Teamrated all candidate alternatives with respect toeach of the six evaluation criteria. Then the teamdetermined an overall rating for the alternativeswith respect to each criterion. The teamaddressed each criterion in turn to ensure that allessential elements of each criterion wereassessed and that the final qualitative ratings rep-resented a team consensus.

The DOE Team completed the final analyses todetermine which alternatives were considered

reasonable and retained as an EIS candidatealternative. The team made a diligent effort toinclude a range of reasonable alternatives withpotential to satisfy DOE program requirementsand public concerns.

The DOE Team also identified potential newalternatives that were not included in the initialset of candidate alternatives. The team accom-plished this by reviewing the processes involvedin selecting the initial set of candidate alterna-tives, then applying their knowledge of HLWmanagement technologies. This process resultedin the identification of the following additionalalternatives for evaluation: (1) a No ActionOrderly Shutdown Alternative, and (2) an EarlyVitrification Option under the Non-SeparationsAlternative. The team then evaluated these twoadditional alternatives against the evaluation cri-teria described below.

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Table B-1. Candidate alternatives.Candidate alternative Rating

Mission CostTechnicalFeasibility ES&H

PublicConcerns

ProgramFlexibility

1. No Action1A Notice of Intent – 0 + 0 – +1B Orderly Shutdown – + + – – –

2. Separations2A Full Separations + 0 + 0 0 02B 2006 Plan + – + – 0 02C Transuranic

Separations/Class A Grout

+ 0 + 0 0 0

2D TransuranicSeparations/Class C Grout

+ 0 + 0 + 0

3. Non-Separations3A Vitrified Waste + – + 0 + –3B Hot Isostatic

Pressed Waste0 0 + – 0 –

3C Cement-Ceramic 0 0 – – 0 –3D Direct Cement 0 0 + 0 0 –3E Early Vitrification + – 0 0 + –

Plus (+) = Expected to satisfy the criteria with minor deficiencies or concernsZero (0) = Expected to satisfy the criteria with some deficiencies or concernsMinus (–) = Expected to satisfy the criteria with major deficiencies or concerns

B.4.2 EVALUATION CRITERIA

A major step of the evaluation methodology wasto develop selection criteria. DOE developed thescreening criteria to be used for selecting the setof alternatives. First, DOE determined the crite-ria should have the following attributes:

• Defensible, and clear to all parties

• Appropriate for waste processing alterna-tive evaluation

• Limited to major program considerationsand public concerns

• Easily evaluated by qualitative methodsand analysis

• Inclusive of all major areas of concern andprogram viability

DOE then reviewed the selection criteria used inprevious HLW studies and two recent DOEEnvironmental Impact Statements: theDepartment of Energy Programmatic SpentNuclear Fuel Management and Idaho NationalEngineering Laboratory EnvironmentalRestoration and Waste Management ProgramsEnvironmental Impact Statement (SNF & INELEIS) (DOE 1995) and the Final WasteManagement Programmatic EnvironmentalImpact Statement for Managing Treatment,Storage, and Disposal of Radioactive andHazardous Waste (DOE 1997a). As a result,DOE developed the following criteria:

• Program Mission

• Cost Factors

• Technical Feasibility

• Environment, Safety, and Health

• Public Concerns

• Program Flexibility

B.4.3 APPLICATION OF CRITERIA TOCANDIDATE ALTERNATIVES

B.4.3.1 Program Mission

The Program Mission criterion is essential toassessing capability of the alternatives to meetDOE complex-wide and INEEL HLW programobjectives, major regulatory milestones, andlegal obligations. Table B-1 presents the ratingsof the candidate alternatives against this crite-rion.

For the Program Mission criterion, both optionsunder the No Action Alternative were assessedminus (-) ratings. These alternatives do not meetthe Settlement Agreement/Consent Orderrequirement to have all HLW road ready by2035, and they do not address the long-termissue of removing all HLW from the State ofIdaho, nor does the Orderly Shutdown Optionmeet the requirement to complete calcination ofliquid SBW by 2012.

All four separations alternatives were assessed aplus (+) rating with minor deficiencies or con-cerns. Since the separations concept was drivenby program mission requirements to reduceHLW disposal volume, the high ratings wereexpected. The separations options may lowerthe HLW volume for repository disposal to min-imize transportation risk and cost, and they areconsistent with DOE planning documents suchas the Environmental Management ContractorReport (EMI 1997), Accelerating Cleanup:Paths to Closure (DOE 1998), and NEPARecords of Decision (RODs), with minor excep-tions.

Under the Non-Separations Alternative, theVitrified Waste and Early Vitrification Optionswere assessed a plus (+) rating because bothwould meet the essential requirements of theSettlement Agreement/Consent Order and pro-duce a final waste form (borosilicate glass) thathas a high probability of acceptance at a geo-logic repository. The other three options underthe Non-Separations Alternative were assessed azero (0) rating with some deficiencies or con-cerns. All three options would require a deter-mination of equivalency by the U.S.Environmental Protection Agency (EPA).

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Appendix B

B.4.3.2 Cost Factors

Inclusion of the Cost Factors criterion was con-sidered essential because this EIS proposes aDOE Federal project that would be supported byCongressional appropriations. This cost crite-rion includes consideration of life-cycle costs,ten-year costs, peak funding requirements, andthe results of an independent risk-based coststudy. The cost estimates of the risk-based studyare contained in Section 5.0 of DOE (1999a).Table B-1 presents the ratings of the candidatealternatives against this criterion.

All the candidate options, except OrderlyShutdown, 2006 Plan, Vitrified Waste, and EarlyVitrification, were deemed equivalent withrespect to cost and received the zero (0) ratingwith some deficiencies or concerns. No costestimates were available for the OrderlyShutdown Option, but it was given a plus (+) rat-ing because of the obvious minimal costs for anorderly shutdown of INTEC facilities. The 2006Plan Option under the Separations Alternativewas considered more expensive than the otherseparations options and assigned a minus (-)rating to reflect the potential cost due to the cal-cination of both HLW and SBW and the subse-quent calcine dissolving, separating, andprocessing the waste fractions into final wasteforms.

With respect to the Non-SeparationsAlternatives, the Vitrified Waste Option wasjudged to have a higher life-cycle cost due to thehigh cost of a vitrification facility, the greatervolume of material to be vitrified, and the greateramount of vitrified HLW to be transported to ageologic repository. No cost estimates wereavailable for the Early Vitrification Option sinceit was a late entry to the candidate list. However,the Early Vitrification Option was assessed asmore costly and assigned a minus (-) rating toreflect the potential cost of a vitrification facilityand greater volumes of HLW compared to theSeparations Alternative.

B.4.3.3 Technical Feasibility

Technical Feasibility or technical risk is a pri-mary criterion to assess the capability of an alter-native to meet the planned HLW program goalsand milestones. Some alternatives may be more

easily implemented due to use of proven tech-nologies or the availability of well-developedprocesses. For alternatives that require new,unproven technologies, the team assessed thestate of development (i.e., research and develop-ment, advanced development, or full-scale test-ing) and whether or not the proposed processwould require a technical breakthrough or fur-ther testing and modification. Table B-1 pre-sents the ratings of the candidate alternativesagainst this criterion.

The DOE Team concluded that both optionsunder the No Action Alternative should receive aplus (+) rating because they rely solely on facil-ities and processes that are currently operationaland require no major high-risk modifications.Therefore, the technical risk associated withthese alternatives should be very low.

The team also noted that all four options underthe Separations Alternative use the same provendissolution, separations, vitrification, and grout-ing technologies. All these separations treatmenttechnologies are well developed and have beensuccessfully demonstrated throughout the DOEcomplex and industry. The current DOE HLWtreatment at the Savannah River Site DefenseWaste Processing Facility and at the West ValleyDemonstration Project evidences the technicalmaturity of the vitrification process. Becausethe Separations Alternative includes vitrifica-tion as an option, which is technically mature,it received a plus (+) rating.

Under the Non-Separations Alternative, theVitrified Waste, Hot Isostatic Pressed Waste, andDirect Cement Waste Options all received a plus(+) rating due to incorporation of well devel-oped, demonstrated technologies at INEEL. TheEarly Vitrification Option was assessed a zero(0) rating because of the unknowns associatedwith the vitrification of SBW.

The Cement-Ceramic Option received a minus (-) rating due to the high-risk treatment process,(i.e., calcination of SBW/calcine slurry in theNew Waste Calcining Facility). The New WasteCalcining Facility, designed to process a liquidfeed, would have to undergo major modifica-tions to process the slurry mixture. No researchand development work has been done to demon-strate the feasibility of calcining this slurry feedin the New Waste Calcining Facility.

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B.4.3.4 Environment, Safety,and Health

The Environment, Safety, and Health criterionfocuses on the risk of radioactive and hazardousmaterials emissions, potential migration into theSnake River Plain Aquifer, waste volume pro-duced, potential worker exposure during opera-tions, and complex process hazards. Table B-1presents the ratings of the candidate alternativesagainst this criterion.

Based on preliminary worker risk data (DOE1997b), the Orderly Shutdown, 2006 Plan, HotIsostatic Pressed Waste, and Cement-CeramicOptions were considered least acceptable due toincreased worker risk as compared to the otheralternatives and received a minus rating. Theincreased worker risk for the 2006 Plan, HotIsostatic Pressed Waste, and Cement-CeramicAlternatives was attributed to longer periods ofhazardous activity and more complex and higherrisk processes. In the case of the OrderlyShutdown Alternative, the liquid SBW in theTank Farm and the HLW calcine in the bin sets,to be left indefinitely at the INTEC, increasedworker and environmental risk. For these rea-sons these options were all assessed a minus (-)rating.

Based on the limited amount of definitive infor-mation (only worker risk data) available to theteam, the remaining alternatives received a zero(0) rating because of minimal worker risk andinsufficient information to rank the alternativesin the other sub-elements of Environment,Safety, and Health.

B.4.3.5 Public Concerns

Considerations for the Public Concerns criterionwere obtained from comments received by DOEduring the EIS scoping period. The sub-ele-ments of the Public Concerns criterion includefinal HLW form, disposal sites, aquifer impacts,waste acceptance criteria at the proposed geo-logic repository, definition of SBW, equity withrespect to other DOE sites, HLW transportation,and tribal cultural and historic resources. TableB-1 presents the ratings of the candidate alterna-tives against this criterion.

The DOE Team assigned a minus (-) rating toboth options under the No Action Alternativebecause neither alternative addresses thewidespread opposition to long-term storage ordisposal of HLW above the Snake River PlainAquifer. Also, the alternatives do not meet theSettlement Agreement/Consent Order require-ment to have all INEEL HLW road ready by2035.

Under the Separations Alternative, the teamassigned the Full Separations, 2006 Plan, andTransuranic Separations/Class A Grout Optionsa zero (0) rating because of several concerns.These concerns include the long time estimatedfor the treatment processes, possible transporta-tion for offsite treatment, health and safety ofworkers, and potential lack of a disposal facilitythat would accept INEEL HLW.

The Transuranic Separations/Class C GroutOption was given a plus (+) rating due to thepossibility of eliminating the need for disposal ofthe HLW at the geologic repository. This is dueto the planned classification of the high-activityfraction as transuranic waste, which would beeligible for disposal at the Waste Isolation PilotPlant. Also, this option addresses the publicconcern of meeting the SettlementAgreement/Consent Order milestones. BothTransuranic Separations options would requirean "incidental waste" determination.

Under the Non-Separations Alternative, the teamgave the Vitrified Waste and Early VitrificationOptions a plus (+) rating. These options respondto concerns of reducing worker risk (no separa-tions activities) and expediting vitrification,which produces the acceptable waste form fordisposal in a geologic repository.

The team gave zero (0) ratings to the HotIsostatic Pressed Waste, Cement-Ceramic, andDirect Cement Waste Options to reflect the con-cerns for technical complexity of the treatmentprocesses and their capability to meet the wasteacceptance criteria at the disposal site.Moreover, these options would require addi-tional research and development before the EPAcould determine waste form equivalency toborosilicate glass.

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Appendix B

B.4.3.6 Program Flexibility

Program Flexibility is an attribute of programmanagement that allows critical funding deci-sions to be made in a logical, phased approach.Thus, critical decisions to implement costly pro-grams could be done in a serial, time-phasedmanner to assess results of the initial phases or toallow time for technical maturity. The key toprogram flexibility is to minimize the number ofirrevocable funding commitments at the earlystages of a program. Table B-1 presents theresults of the team's ratings of the candidatealternatives against this criterion.

The No Action Alternative published in theNotice of Intent was assessed a plus (+) ratingwith minor deficiencies because it is a shortterm, business-as-usual alternative with no sig-nificant changes in operations and requires nonew facilities. Therefore, this option has highprogram flexibility with respect to cost andschedule because no processes or facilities thatrequire early funding commitments would beneeded.

All four options under the SeparationsAlternative were assigned a zero (0) rating withsome deficiencies or concerns. These separa-tions options require early funding commitmentsfor the new separations facility, which reducesprogram flexibility in the near-term. However,the options under the Separations Alternativehave high program flexibility in the long-termbecause the HLW is separated into high-activityand low-activity waste fractions that allow sev-eral immobilization and disposal options to beconsidered at later stages of the program.

The five options under the Non-SeparationsAlternative were considered to be relativelyinflexible compared to the No Action andSeparations Alternatives. These five optionswere assessed a minus (-) rating with major defi-ciencies or concerns. These concerns relate tothe early program commitments to SBW calci-nation, SBW and calcine retrieval, HLW immo-bilization, HLW interim storage, and thepotential need to construct a new vitrificationfacility at INEEL.

B.5 Evaluation Summaryand Results

Based on the preliminary criteria ratings, theDOE Team completed the final analyses to deter-mine which options were considered reasonableand worthy of being retained on the Draft IdahoHLW & FD EIS Candidate Alternative List.Options with all pluses (+) would be top candi-dates. Options with pluses and zeroes were alsoconsidered candidates. However, options withmore zeroes than pluses triggered additionalanalysis to ensure the zero ratings were not indi-cations of inherent weaknesses. Options ratedwith one or more minuses were re-evaluated todetermine if the minus ratings were significantenough to eliminate them. If the minus ratingsindicated large areas of uncertainty, the evalua-tors reduced the uncertainty by obtaining andreviewing additional data.

The team made a diligent effort to include arange of reasonable options with the potential tosatisfy DOE program requirements and concernsof the public.

Table B-2 shows the total criteria ratingsachieved by all the candidate alternatives duringthe alternative evaluation discussed in the previ-ous section. As shown in the table, theTransuranic Separations/Class C Grout Optionunder the Separations Alternative was assessedthe highest total rating of +3 and the Cement-Ceramic Option under the Non-SeparationsAlternative was assessed the lowest total ratingof -3. Since the total rating spread (lowest tohighest total rating) was only 6 points and thelowest alternative was only a -3 rating, theEvaluation Team recommended that none of theinitial candidate alternatives be rejected at thistime. Moreover, the team analysis confirmedthat none of the minus ratings indicated areas ofserious or inherent weakness.

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B.6 Refinement of DraftEIS Alternatives

Following the evaluation of candidate alterna-tives described in the previous section, severalevents occurred that affected the selection ofalternatives for the Idaho HLW & FD EIS.These events include consideration of shippingstabilized HLW (or calcine or separated high-activity waste) to the Hanford Site for process-ing, use of the proposed INEEL AdvancedMixed Waste Treatment Project for processingcertain HLW-related waste streams, and use of acesium ion exchange process for treatment ofliquid SBW and newly generated liquid waste.These events led DOE to further refine the IdahoHLW & FD EIS alternative selection process.Additional information for this refinement pro-cess are contained in DOE (1999a) and are sum-marized below.

B.6.1 DRAFT EIS ALTERNATIVESREFINEMENT (PHASE I)

DOE convened an Alternative RefinementMeeting on May 21, 1998 to evaluate the list ofEIS alternatives considering the events describedabove. The following comparison factors (elim-ination criteria) were used by DOE personnelduring the meeting:

• Two or more alternatives share commonprocess characteristics, but one presents:

- A bounding case for environment,safety, and health impacts

- Substantially reduced cost

- Substantially reduced waste handlingrisks

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Table B-2. Total rating of candidate alternatives.

AlternativeProgrammission Cost

Technicalfeasibility ES&H

PublicConcerns

Programflexibility

Totalrating

1. No Action1A Notice of Intent – 0 + 0a – + 0a

1B Orderly Shutdown – + + – – – –22. Separations

2A Full Separations + 0 + 0 0 0 +22B 2006 Plan + – + – 0 0 02C Transuranic

Separations/Class A Grout

+ 0 + 0 0 0 +2

2D TransuranicSeparations/Class C Grout.

+ 0 + 0 + 0 +3

3. Non-Separations3A Vitrified Waste + – + 0 + – +13B Hot Isostatic

Pressed Waste0 0 + –a 0 – –1a

3C Cement-Ceramic 0 0 – –a 0 – –3a

3D Direct Cement 0 0 + 0 0 – 03E Early Vitrification + – 0 0 + – 0

a. After the initial DOE Team evaluation and recommendation, these ratings were re-evaluated based on additional informationreceived by the team. The re-evaluation did not change the team’s recommended final ratings.

tors," as discussed previously. The rationale forthese conclusions is described below.

No Action Alternative - Orderly ShutdownOption - This option would not meet any of theSettlement Agreement/Consent Order and otherrequirements and does not tier off the SNF &INEL EIS decision to continue to operate theNew Waste Calcining Facility (DOE 1999a).Under this option, the decision to shut down theNew Waste Calcining Facility would be made inFiscal Year 2000, and none of the INTEC HLWmanagement facilities, including the Tank Farm,would be closed. The process vessels would beemptied of waste solutions, and some decontam-ination rinses would be performed. The OrderlyShutdown Option would stop the operation ofthe Process Equipment Waste Evaporator systemand the Liquid Effluent Treatment and DisposalFacility, and would not empty or close the TankFarm. The shutdown facilities would be left in asafe condition but would not be monitored.DOE concluded that the No Action OrderlyShutdown Option was not an environmentallyresponsible alternative and would not be aneffective basis of comparison of the actionalternatives. Thus, this option was eliminatedfrom further consideration.

Separations Alternative - 2006 Plan Option -The 2006 Plan Option is identical to the FullSeparations Option except that the SBW wouldnot be processed (separated) directly but would

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- Similar impacts, but with an increasedchance for public and/or regulatoracceptance

• An implementation alternative presents aprocess that would likely result in:

- Lack of expected regulator/DOEapproval

- Lack of ability to construct or operatefacilities in the required time period

- Significantly higher volume of wastefor disposal

- Significantly higher worker risk

- Unreasonably higher cost to treat asmall volume of waste

- Unreasonably higher worker risk toprocess a small volume of waste

- Creation of an intermediate waste formthat cannot be transformed into anacceptable final waste form for dis-posal

DOE identified the following alternatives inTable B-3 as "alternatives considered but notanalyzed" and "alternatives identified for furtherDEIS analysis with use of the comparison fac-

Table B-3. Summary of the Phase I Alternative Refinement Meeting.Alternatives considered but not analyzed Alternatives identified for further analysis

No Action Alternative No Action Notice of Intent (per Notice of Intent)No Action Orderly Shutdown Option Separation Alternative

Separations Alternative Full Separations Option2006 Plan Option Transuranic Separations/Class C Grout OptionTransuranic Separations/Class A Grout Option Non-Separations AlternativeOffsite Disposal of Class C Grout Option underthe Transuranic Separations Option

Hot Isostatic Pressed Waste Option

Non-Separations Alternative Direct Cement Waste OptionVitrified Waste Option Early Vitrification Option

Minimum INEEL Processing Alternative Minimum INEEL Processing AlternativeAdvanced Mixed Waste Treatment FacilityOption

Full Transport Option

Full Transport with Alternate SBW TreatmentOption

be calcined in the New Waste Calcining Facilityby 2012 before dissolution and separation.

Thus, the 2006 Plan Option would require threemajor processing facilities (i.e., New WasteCalcining Facility with high-temperature andMaximum Achievable Control Technologyupgrades, Calcine Dissolution and SeparationsFacility, and a HLW Vitrification Facility). Theproposed 2006 Plan Option waste form wouldrequire redissolution of calcine with potentialhigher life cycle costs and worker risks thanother separation options. For these reasons andfor the additional processing and storage facili-ties required, it is apparent that this option offersno advantages over the Full Separations Option.It was also predicted to cost considerably morethan the Full Separations Option. Therefore, itwas determined that it be eliminated from thealternative list.

Non-Separations Alternative - Vitrified WasteOption - The calcining of SBW and newly gen-erated liquid waste is the only action that differ-entiates the Vitrified Waste Option from theEarly Vitrification Option. This option not onlycreates an additional waste form (SBW calcine)to be vitrified with the HLW calcine but alsowould not maintain the beneficial segregation ofthe SBW calcine from the HLW calcine.Because of this potential co-mingling, thisoption could result in a larger quantity of HLWbeing shipped to a geologic repository for dis-posal with the attendant higher disposal costsand would require greater facility costs for vitri-fication and storage. Therefore, there are noadvantages for this option over the EarlyVitrification Option that otherwise contains thesame treatment concepts. For these reasons, itwas concluded that the Vitrified Waste Optionshould be eliminated from further EIS consider-ation.

Offsite Low-Activity Waste Disposal - Thegroup determined that offsite disposal of Class Agrout should be retained. Initially, Hanford wasselected to be a representative offsite location forClass A grout disposal. However, disposal atHanford has been eliminated from considerationbecause previous evaluations of low-activitygrout disposal at Hanford have indicated that thelong-term (beyond 1,000 years) impacts of low-activity grout disposal could exceed regulatorystandards for groundwater protection. Also, at

the time, Hanford's HLW management strategycalled for vitrifying the low-activity waste priorto onsite disposal and it was unlikely thatHanford would accept grouted INEEL low-activity waste for disposal. The group then rec-ommended that the Envirocare facility in Utahbe considered as a representative offsite disposalfacility because it is a commercial facility that islimited only by its waste acceptance criteria.

Notice of Intent version of the No ActionAlternative - This Option was re-aligned by thegroup to include the following requirements tomeet the Notice of Noncompliance ConsentOrder:

• Run the New Waste Calcining Facilityuntil June 2000.

• Place the New Waste Calcining Facility instandby and perform the high temperatureand Maximum Achievable ControlTechnology upgrades.

• Run the High-Level Liquid WasteEvaporator until 2003 while the NewWaste Calcining Facility is beingupgraded.

• Complete the New Waste CalciningFacility permitting and upgrades by 2010.

• Run the New Waste Calcining Facility atan accelerated schedule to calcine theSBW by 2014.

Separations Alternative - Full Separationswith Hanford Vitrification - This option is iden-tical to the Full Separations Option except forthe suboption to perform high-activity waste vit-rification at the Hanford Site instead of atINEEL. In this option, the high-activity wastefraction would be solidified, packaged, andshipped to the Hanford Site for vitrification. Theresulting HLW canisters would be returned toINEEL for interim storage awaiting shipment toa geologic repository. DOE concluded that theIdaho HLW & FD EIS will include "HanfordVitrification" as an independent transportationanalysis that will be covered in this EIS. The at-Hanford impacts would be discussed in a sepa-rate section of the EIS. This would allow thepublic to isolate the "at-INEEL" and "at-Hanford" impacts.

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Separations Alternative - TransuranicSeparations/Class A Grout Option - Thisoption is similar to the Full Separations Option,except the separation process under this optionwould result in three waste products:

• Transuranic waste

• Fission products (primarilystrontium/cesium)

• Class A grout

In the Transuranic Separations/Class A GroutOption, the liquid SBW would be sent directly tothe Separations Facility for processing into high-activity and low-activity waste streams. Afterthe SBW is processed, the HLW calcine wouldbe retrieved from the bin sets, dissolved, andprocessed in the Separations Facility. Ionexchange columns would be used to remove thecesium from the waste stream. The resultingeffluent would undergo the transuranic extrac-tion process to remove the transuranic elementsfor eventual shipment to the Waste IsolationPilot Plant. Then strontium would be removedfrom the transuranic extraction effluent streamvia the strontium extraction process. The cesiumand strontium would be combined to produce ahigh-activity waste stream that would be vitri-fied into borosilicate glass. This glass would bestored in an interim storage facility before ship-ment to a geologic repository. The TransuranicSeparations waste would be dried and denitratedto produce a granular solid waste, and the low-activity waste would be denitrated and groutedto form Class A grout.

The Transuranic Separations/Class C GroutOption process would create only two wastestreams: (1) solidified transuranic waste for dis-posal at the Waste Isolation Pilot Plant and (2) alow-activity waste stream to form Class C groutfor onsite disposal. The TransuranicSeparations/Class A Grout Option would involvemore separations steps than the TransuranicSeparations/Class C Grout Option and wouldrequire a larger Waste Separations Facility.Also, this option would require a separate High-Activity Waste Treatment (Vitrification) Facilityand a High-Level Waste Interim Storage Facilitythat have an estimated cost substantially greaterthan the Transuranic Separations (Class C Grout)Option.

The estimated total discounted cost for theTransuranic Separations/Class A Grout Option is$3.29 billion, which would be 80 percent greaterthan the estimated total discounted cost of $1.82billion for the Transuranic Separations (Class CGrout) Option. Thus, the TransuranicSeparations/Class C Grout Option is similar, hasless complex separations processing, and is morecost-effective than the TransuranicSeparations/Class A Option. Moreover, theimpacts of this option are expected to bebounded by the remaining two options under theSeparations Alternative. For these reasons, theTransuranic Separations/Class A Option waseliminated from further consideration.

Non-Separations Alternative - Cement-Ceramic Waste Option - The Cement-CeramicWaste Option under the Non-SeparationsAlternative is similar to the Direct Cement WasteOption except the liquid SBW would not be cal-cined directly but would be mixed with the exist-ing calcine to form a slurry. In this option, allcalcine would be retrieved and combined withthe liquid SBW. The combined slurry would berecalcined in the New Waste Calcining Facilitywith the resulting calcine mixed into a concrete-like material. The concrete waste product wouldthen be poured into drums, autoclaved (curing ina pressurized oven), and stored in an interimstorage facility before shipment to a geologicrepository. An estimated 16,000 concrete canis-ters would be produced. This option wouldrequire a calcine retrieval system, a major modi-fication to the New Waste Calcining Facility toallow slurry calcination and the upgrade forcompliance with the Maximum AchievableControl Technology rule, and a Grout Facilitywith autoclave. The final product would requirean equivalency determination by EPA.

The rationale for initially considering theCement-Ceramic Waste Option in the EIS wasthe potential for significant cost savings in usinga greater confinement facility (such as at theNevada Test Site) as the final repository for theresulting product. A basis for this assumptionwas that the cementitious waste form and thealluvial soil at the greater confinement facilitywere chemically compatible, and the cementwaste form would be the least likely to migratein the surrounding soil. However, the greaterconfinement facility for HLW disposal has notbeen constructed, nor has DOE approved the

project for construction at this date. Moreover,DOE experiences at the Waste Isolation PilotPlant and Yucca Mountain suggest that thedevelopment of a repository is a lengthy, costly,and high-risk undertaking. In addition, if INEELwere the only site disposing HLW at a greaterconfinement facility, INEEL would bear all costsassociated with the development of the reposi-tory (e.g., site characterization and performanceassessments associated with U.S. NuclearRegulatory Commission licensing and EPA cer-tification of compliance). Therefore, it isunlikely that significant cost savings at a greaterconfinement facility could be realized over ageologic repository where INEEL would pay aprorated share of the development and opera-tional costs based on its share of the waste dis-posed of.

The Cement-Ceramic Waste Option is based oncalcination of SBW/calcine slurry in the NewWaste Calcining Facility, which is currently con-figured to process a liquid feed. To reconfigurethe New Waste Calcining Facility to process anSBW/calcine slurry would be costly. Even if theNew Waste Calcining Facility were modified toaccept the slurry feed, no prior research anddevelopment work has been conducted to verifythe feasibility of calcining the slurry. Even if theCement-Ceramic Waste Option had a highpotential to reduce life cycle costs, the fact thatDOE has included the Direct Cement WasteOption, which has lower technical risk than theCement-Ceramic Waste Option, negates theneed to include the Cement-Ceramic WasteOption in the EIS analysis.

Minimum INEEL Processing Alternative - Thegroup concluded that an additional alternative,entitled the "Minimum INEEL ProcessingAlternative," should be analyzed in the IdahoHLW & FD EIS. This alternative would havetwo options: (1) the Full Transport Option and(2) the Full Transport with Alternate SBW

Treatment Option. Under either option in thisalternative, DOE would perform only the mini-mum activities necessary to prepare the calcinefor shipment to the Hanford Site for treatment.In the Full Transport Option, DOE would alsosolidify and package the SBW for transport toHanford. In the Full Transport with AlternateSBW Processing Option, DOE would not shipthe SBW to Hanford but would instead processthe SBW through an ion-exchange column toremove the cesium and grout to create a contact-handled transuranic waste that DOE would shipto the Waste Isolation Pilot Plant.

B.6.2 EIS ADVISORY GROUP (EAG) REVIEW

Subsequent to the Alternatives RefinementMeeting, DOE convened the Idaho HLW & FDEIS Advisory Group Meeting on June 30 andJuly 1, 1998. The purpose of the EIS AdvisoryGroup was to provide a forum to assess the res-olution of issues related to preparation andreview of this EIS. The EIS Advisory Groupconcluded that the alternatives resulting from thePhase I Alternatives Refinement Meeting wereacceptable except that the No Action Alternativeshould be revised so it does not include calcina-tion or construction of new storage tanks. DOEsubsequently decided that the alternative previ-ously entitled the No Action Alternative wouldbe retained but would be retitled the "ContinuedCurrent Operations" Alternative.

B.6.3 ALTERNATIVE REFINEMENT(PHASE II)

A second alternative refinement meeting washeld on September 16, 1998. The intent of thissecond meeting was to discuss the potentialHanford alternatives for treatment of INEELHLW and SBW. The DOE Evaluation Team

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concentrated on evaluating the physical charac-teristics of the Hanford alternatives and the tim-ing for potential shipments of waste to Hanfordfor treatment. Timing of shipments is criticalsince it affects the treatment processes atINTEC, which would supply the waste forHanford treatment.

The DOE Evaluation Team evaluated severaloptions for treatment of INTEC wastes atHanford, including (1) direct vitrification of cal-cine, (2) direct vitrification of separated high-activity waste, (3) calcine separations, and (4)shipping SBW/newly generated liquid waste tothe Hanford Site for treatment. The DOEEvaluation Team concluded that only Option 3,"calcine separations," should be evaluated in theEIS. DOE's rationale for eliminating the otheroptions is explained in DOE (1999a) and Section3.3 of this EIS.

Therefore, the Minimum INEEL ProcessingAlternative would entail shipping calcine fromINEEL to Hanford, separation of this calcine atHanford into high-activity and low-activitystreams, and vitrification of both waste streamsat Hanford. The vitrified high-activity wastewould be shipped back to INEEL for interimstorage pending shipment to a geologic reposi-tory, while the vitrified low-activity waste wouldbe shipped back to INEEL for disposal. Theexisting liquid SBW and newly generated liquidwastes would be retrieved and transported to anion exchange facility, where it would be filteredand processed through an ion exchange column.The filtered solids would be dried and disposedof at the Waste Isolation Pilot Plant as remote-handled transuranic waste. The loaded ionexchange resin would be temporarily stored atINEEL, dried and containerized, and transportedto Hanford for vitrification. After ion exchange,the liquid waste would be grouted to produce acontact-handled transuranic waste for disposal atthe Waste Isolation Pilot Plant.

B.6.4 STATE OF IDAHO REVIEW

As described in Section 2.3, the State of Idahoserved as a "Cooperating Agency" in the prepa-ration of this EIS. In fulfilling this responsibil-ity, the State reviewed the list of wasteprocessing alternatives. The State's review con-cluded that the 2006 Plan Option comes the clos-est to fulfilling the SettlementAgreement/Consent Order and should be ana-lyzed in the EIS. DOE incorporated the State'srecommendation and evaluated this option in theEIS but retitled it the "Planning Basis Option."

B.7 Final List of Draft EISAlternatives

Therefore, as a result of all the activities dis-cussed in this Appendix, the Draft Idaho HLW &FD EIS analyzed the following waste processingalternatives and options:

1. No Action Alternative

2. Continued Current OperationsAlternative

3. Separations Alternative

A. Full Separations Option

B. Planning Basis Option

C. Transuranic Separations Option

4. Non-Separations Alternative

A. Hot Isostatic Pressed Waste Option

B. Direct Cement Waste Option

C. Early Vitrification Option

5. Minimum INEEL Processing Alternative

B.8 AdditionalAlternatives/Optionsand TechnologiesIdentified during thePublic CommentProcess

B.8.1 INTRODUCTION AND PURPOSE

The Notice of Availability of the Draft EIS wasissued in 65 FR 3432 on January 21, 2000.Additional alternatives for the treatment and dis-posal of mixed transuranic waste/SBW andmixed HLW calcine were proposed by the pub-lic during the public comment period. Publiccomments, along with other relevant factors,such as information received after the Draft EISwas approved, had a bearing on the developmentof the Preferred Alternatives. This section iden-tifies and describes the new alternatives andtreatment technologies and their disposition.The new alternatives (Steam Reforming andGrout-in-Place) were identified from publiccomment on the Draft EIS. The additional treat-ment technologies described here include thoseidentified by:

• The National Academy of Sciences(NAS 1999)

• The public comment process, and

• HLW treatment experts during thePreferred Alternative identification pro-cess

The evaluation criteria for the alternatives andtechnologies included environment, safety, andhealth impacts; treatment process effectivenessfor both mixed transuranic waste/SBW andmixed HLW calcine; technical maturity of treat-ment technologies and risk of failure; publiccomment; ability to meet legal commitments fortreating and preparing mixed transuranicwaste/SBW and mixed HLW calcine to meet theSettlement Agreement/Consent Order andNotice of Noncompliance Consent Orderrequirements; agency concerns; adherence toDOE's mission and policies; uncertainties;schedule risk; project and operational costs; finalwaste form shipping and disposal costs; and

maximizing the potential for early disposal ofthe final waste form.

B.8.2 ALTERNATIVES/OPTIONSEVALUATED AFTER THE DRAFTEIS WAS ISSUED

Waste processing methods were identified andevaluated during the review of public commentson the Draft EIS, from other reports, and duringDOE internal review. Most of these methods,including Steam Reforming, were variations onthe waste processing alternatives presented inthe Draft EIS. However, application of SteamReforming and Grout-In-Place as proposedwaste treatment alternatives was identified dur-ing public comment and considered in the FinalEIS alternative identification process. Theseproposed alternatives are described in the fol-lowing subsections.

B.8.2.1 Steam Reforming

The steam reforming process proposed for pro-cessing mixed transuranic waste/SBW involvesreaction of the waste in a fluidized bed withsteam and certain reductants and additives, toproduce a small volume of inorganic residueessentially free of nitrates and organic materials.The mixed transuranic waste/SBW, after mixingwith sucrose, would be fed to the reactor. Solidcarbon would be fed separately as a reactant inthe steam-reforming process. Additional addi-tives may also be used to alter the physical andchemical properties of the final product. Waterin the waste would be vaporized to superheatedsteam. Additional energy would be supplied tothe bed by injecting oxygen to react with the car-bon sources. Organic compounds in the wastewould be broken down through thermal pro-cesses (pyrolysis) and through reaction with hotnitrates, steam, and oxygen.

The fine solid-waste products, including smallamounts of fixed carbon and alumina fines fromthe bed, would be separated from the largersemi-permanent fluid-bed particles in a cyclonewithin the reactor. The resultant vapor streamwould be passed through ceramic candle filterswhere the solids would be separated from thevapors. The filter candles periodically would bebackpulsed with nitrogen to recover the solids,

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which would then be packaged for disposal.These solids would be combined with larger par-ticles that occasionally would be dischargedfrom the bottom of the fluid bed reactor.Together these solids would make up the pri-mary steam-reformed product.

The vapor stream exiting the ceramic candle fil-ters would be processed through a quencherwhere acid gases would be neutralized. Thevapor from the dryer would be combined withthe building air exhaust before high-efficiencyparticulate air filtration. The water vapor fromthe scrubber would be condensed and cooled.The gases exiting the condenser would passthrough a demister and bag house before beingtreated with air in a thermal converter. Thevapors exiting the thermal converter would bepassed through a high-efficiency particulate airfilter and a cooler before being discharged to theatmosphere through a monitored vent stack.

A DOE-sponsored Tanks Focus Area sub-teamevaluated the steam reforming technology forprocessing mixed transuranic waste/SBW (TFA2001). The sub-team concluded that there wasno strong technical incentive to pursue steamreforming but the technology may be useful as avitrification pretreatment or offgas treatmentmethod. The sub-team also concluded that DOEshould not pursue the steam reforming technol-ogy as a means to treat the mixed transuranicwaste/SBW. The recommendation was basedprimarily on process technical concerns and con-cerns about long-term storage of the resultingproduct (hydration and radiolysis). The steamreforming process is similar to the ContinuedCurrent Operations Alternative analyzed in thisEIS, except the resultant waste produced wouldbe shipped offsite rather than stored indefinitelyin the bin sets. This is similar to NAS Option 6.Subsequently, DOE management requested anassessment of the steam reforming technology totreat the mixed transuranic waste/SBW. Theassessment resulted in a Steam ReformingOption being added to the EIS in response topublic and agency comments. The optionincludes containerizing the mixed HLW calcineand shipping it to the geologic repository. Inaddition, transportation of both waste streams tothe respective disposal sites has been added.

B.8.2.2 Grout-In-Place

As part of the public comment process on theDraft EIS, the INEEL Citizens Advisory Boardproposed a new alternative for evaluation (CAB2000). This new alternative, Grout-in Place orEntombment, would leave the mixed transuranicwaste/SBW in the tanks and the calcine in thebin sets and add grout to immobilize the waste inplace. For the mixed transuranic waste/SBW,the grout/SBW mixture would be entombeddirectly in the tanks. The calcine would either bemixed with grout and entombed in the bin sets,or the vaults surrounding the bin sets could befilled with clean grout. This alternative wasevaluated, but was eliminated from detailedanalysis for the following reasons:

• Transformation of the mixed transuranicwaste/SBW into a stable solid form mayrequire removal of the waste from thetanks and addition of neutralizing andstabilizing materials that would result ina substantial volume increase. Althoughadding a grout mixture to the waste inthe tanks may not exceed the capacity ofthe existing tanks (assuming a 30 per-cent waste loading and all 11 tanks filledto capacity), there are technical uncer-tainties related to the solidification in atank to entomb the liquid mixedtransuranic waste/SBW. For the calcine,there is insufficient capacity in the binsets to grout the calcine in place. If thecalcine were encased in clean groutaround the bin sets, the potential long-term impacts would be similar to theContinued Current Operations and NoAction Alternatives. For long-termimpact analysis (Section 5.3.5.2 of thisEIS), DOE assumed that any structurewas vulnerable to degradation failureafter 500 years in accordance with theU.S. Nuclear Regulatory Commission(NRC) position for long-term storagefacilities (NRC 1994).

• Under NEPA, agencies may consideralternatives that are not consistent withapplicable laws, regulations, andenforceable agreements. However,DOE does not regard disposal of themixed transuranic waste/SBW in thetanks or calcine in the bin sets to be rea-

- New Information -

sonable. This alternative would violatethe Notice of Noncompliance ConsentOrder and SettlementAgreement/Consent Order, and wouldnot meet RCRA regulatory requirementsfor a disposal facility for mixed waste.

B.8.3 TREATMENT TECHNOLOGIESEVALUATED AFTER THE DRAFTEIS WAS ISSUED

Following publication of the Draft EIS, newwaste processing technologies and variations ofpreviously studied treatment options were sug-gested by the public, the NAS, and subject mat-ter experts. These options were evaluated andeventually eliminated from detailed analysis.This section includes a summary of the wasteprocessing options considered and evaluated aspart of the alternative review process and pro-vides an abbreviated discussion as to why theywere eliminated from detailed evaluation. Thetreatment technologies are grouped here by com-mentor, waste type, and by treatment type.

B.8.3.1 Treatment TechnologiesSuggested by the NationalAcademy of Sciences

The following technologies for treating mixedtransuranic waste/SBW were suggested by theNAS in Alternative High-Level WasteTreatments at the Idaho National Engineeringand Environmental Laboratory (NAS 1999). Inaddition to the NAS report, the NAS team pro-vided an extensive briefing on their findings andconclusions.

• NAS Option 1, Two-Stage Low-Temperature Evaporation and Ship tothe Waste Isolation Pilot Plant - Thisoption would use a first stage evaporatorto heat the liquid mixed transuranicwaste/SBW and produce a concentratedliquid, that would be sent to a secondstage evaporator for further drying. Thissecond stage could be a wiped filmevaporator, a pot evaporator, or a rotarydrier. Following the second stage evap-oration, the concentrated liquid wouldbe sent to a container filling operation

where the liquid would be allowed tosolidify upon cooling. The solidifiedproduct, a relatively large volume (1,300cubic meters), would be sent to theWaste Isolation Pilot Plant as remote-handled transuranic waste. This optionwas eliminated from detailed evaluationbecause, in general, the process scoredrelatively low against the criteria listedin Section B.8.1. There were significantissues on technical maturity and technol-ogy for this option, and issues regardingremote maintenance requirements andcontainerization of product.

• NAS Option 2, Hydroxide Precipitationwithout Separation - In this process,excess acid in the mixed transuranicwaste/SBW would be destroyed in anevaporator step. The concentrate wouldbe neutralized with sodium hydroxide toa pH of 8 to 10, precipitating most of themetals. The slurry would be evaporatedand solidified for disposition as in NASOption 1. This process would produceadditional remote-handled transuranicwaste because acid neutralization addswaste volume. Precipitation of the con-centrated mixed transuranic waste/SBWby caustic would introduce processingdifficulties due to the gel-like substancesproduced. This option was eliminatedfrom further evaluation because it wouldgenerate about 30 percent more remote-handled transuranic waste than NASOption 1 above, and it is technicallyenveloped by that option.

• NAS Option 3, Hydroxide Precipitationw/Separation - This treatment option issimilar to NAS Option 2, but requiresadditional processing steps. Excess acidwould be destroyed and the waste wouldbe evaporated and neutralized producinggelatinous slurry. Sulfide would beadded to the slurry to treat for metals. Asolid/liquid separator would then beused to separate the gelatinous material.This technology is considered to be verydifficult and require significant technicaldevelopment with no advantage com-pared to NAS Option 2.

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B-21 DOE/EIS-0287

Idaho HLW & FD EIS

• NAS Option 4, Modified HydroxidePrecipitation - This treatment process issimilar to NAS Option 3 except twoadditional solid/liquid separation stepsadd technical complexity. The processis based on the Hanford EnhancedSludge Leaching Process which operateson basic waste, not acidic waste, andwould require the addition of causticmaterials to increase the pH. Thisoption would reduce the amount ofremote-handled transuranic waste pro-duced but would produce over 3,000cubic meters of remote-handled low-level waste. No advantage was dis-cerned over NAS Option 3.

• NAS Option 5, Lanthanum FluoridePrecipitation - In this option, multiplelanthanum fluoride scavengers wouldprecipitate a transuranic waste fractionas an insoluble fluoride. This technol-ogy was eliminated from detailed evalu-ation because it has previously beeninvestigated for application to theINTEC mixed transuranic waste/SBWand was shown to be an unsuccessfultechnology (Olsen et al. 1993).

• NAS Option 6, Calcination withMaximum Achievable ControlTechnology (MACT) Upgrade and ShipProcess Waste to the Waste IsolationPilot Plant - This option would calcinethe mixed transuranic waste/SBW in theNew Waste Calcining Facility followinga MACT upgrade. The mixedtransuranic waste/SBW calcine wouldbe placed in RCRA compliant containersand sent to the Waste Isolation PilotPlant. This option is similar to theContinued Current OperationsAlternative analyzed in this EIS, exceptthat the resultant waste produced wouldbe shipped offsite rather than storedindefinitely in the bin sets.

B.8.3.2 Treatment TechnologiesIdentified from PublicComment

This section briefly discusses options or treat-ment technologies suggested by the public dur-ing the public comment period on the Draft EIS.

• Savannah River and/or West Valleytreatment of Idaho waste - This optionwould involve shipping mixedtransuranic waste/SBW and mixed HLWcalcine to Savannah River or WestValley for treatment. This option wasevaluated for the Draft EIS, and consid-ered again during preparation of theFinal EIS. There was no additionalinformation that would change the out-come of the initial evaluation. For thereasons identified in Section 3.3.5 of thisEIS, this option was eliminated fromdetailed analysis.

• "Formed Under Elevated Temperatureand Pressure (FUETAP)" technologydeveloped at Oak Ridge - This technol-ogy was developed at Oak Ridge andwas considered during the preparation ofthe Draft EIS. The technology is similarto the Hot Isostatic Pressed Waste andDirect Cement Waste treatment options.Its primary disadvantages are lack oftechnical maturity with an increase intechnical risk. It would have an applica-tion to both mixed transuranicwaste/SBW and mixed HLW calcine.The FUETAP option was not evaluatedfurther for mixed HLW calcine treat-ment because it would produce about thesame amount of HLW (13,000 cubicmeters) as the less technically demand-ing Direct Cement Waste Option, wouldat present produce an unqualified wasteform for the potential geologic reposi-tory, and would require considerabletechnology development.

- New Information -

• Liquid waste treatment technologiesused at other DOE sites - Treatmenttechnologies developed or being consid-ered at other sites were examined as partof the alternative selection process.

• Steam reforming process - This tech-nology has been added to the Final EIS.See Section B.8.2.1 for description.

• Silicon ingots - This process is consid-ered equivalent to vitrification, wherewaste and frit are added to the melter toform glass. Since it is enveloped by theEarly Vitrification Option, it was notfurther evaluated as a stand-alone alter-native.

• Dry-pack process for mixed HLW - Thisprocess is similar to the two-stage evap-orator process evaluated (see SectionB.8.3.1, NAS Option 1) and was elimi-nated from detailed evaluation for thesame reasons.

• Cold crucible vitrification process fortreating calcine - This process wasidentified during the Draft EIS publiccomment period by a company calledCOGEMA. This process is under eval-uation by the HLW program and couldbe chosen for mixed transuranicwaste/SBW and mixed HLW calcine vit-rification. This technology is similar tothat evaluated under the EarlyVitrification Option and the Vitrificationwith or without Calcine Separations,therefore further evaluation of the pro-cess was not performed.

• Advanced Vitrification System (AVS) -The Radioactive Isolation ConsortiumAVS technology involves vitrification ofHLW in the same canister in which itwould be disposed of. This technologycurrently has maturity and technologydevelopment issues that DOE is study-ing. Depending on the results of thestudies, this technology may be consid-ered for waste treatment at the INEEL.This technology is similar to that evalu-ated under the Early Vitrification Optionand the Vitrification with or withoutCalcine Separations, therefore further

evaluation of the process was not per-formed.

• Mixed HLW calcine encapsulation in ametal matrix - Early research at INTECshowed that surrogate calcined HLWcould be melted directly into an alu-minum matrix potentially making thehandling and transport of the calcinedwaste safer and easier. The option wasdropped from further considerationbecause of the lack of technical maturityand it offers no advantage for disposal ina national geologic repository.Additionally, the process has no applica-tion to the treatment of mixedtransuranic waste/SBW unless the liquidwaste was first calcined.

• Mixed HLW calcine entombed in situand mixed transuranic waste/SBWsolidified and entombed in tanks - Thisoption is discussed in Section B.8.2.2.

• Other waste disposal options - Duringpublic comment, several comments sug-gested various methods of disposing ofINTEC waste. These included suchideas as disposing of waste in the GreatSalt Lake Desert, Sahara Desert, outerspace, other countries, etc. These alter-natives were dropped from further con-sideration based on costs, transportationrisk, environmental justice, managerialrisk (political acceptability), and tech-nology issues.

B.8.3.3 Evaluation of TreatmentTechnologies and OptionsDuring the PreferredAlternative IdentificationProcess

The following treatment technologies were iden-tified during the Preferred Alternative identifica-tion process by subject matter experts, fromreference materials and other sources.

Calcine Options for Mixed TransuranicWaste/SBW Treatment - Options involving cal-cination of the mixed transuranic waste/SBWwere generally eliminated from detailed evalua-tion during the Preferred Alternative identifica-

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Appendix B - New Information -

tion process because they 1) would not meet theSettlement Agreement/Consent Order require-ments, 2) upgrades to the New Waste CalciningFacility would require restart after a prolongedshutdown of an old facility, 3) expected diffi-culty in obtaining approvals for partial upgradesfrom the State of Idaho and the U.S.Environmental Protection Agency, 4) calcinationwithout offsite shipment would not close thewaste disposal loop, 5) calcination involves athermal treatment which received significantnegative public comment after the Draft EIS wasreleased, and 6) major modifications to the 20year old New Waste Calcining Facility could betechnologically difficult. For these reasons,options that required calcination of the mixedtransuranic waste/SBW were evaluated andeliminated from further analysis as candidatesfor the preferred treatment alternative. These arelisted below.

• Calcine with MACT Upgrade with cal-cine to Bin Sets

• Calcine without MACT Upgrade withProject XL (eXcellence andLeadership), and Shipment of theProduct to the Waste Isolation PilotPlant (similar to NAS Option 6) (SeeSection B.8.3.1.)

• Calcine with Partial MACT Compliance

• Risk-Based Calcination to Bin Set

• Calcine under Interim Status withRCRA Upgrades

• Calcine with Propane in place ofKerosene

• Calcination with Sugar at 500oC withMACT Upgrade and shipment to theWaste Isolation Pilot Plant

• Calcine with a Surrogate Raffinate

Calciner under Interim Status - The option ofoperating the calciner in its interim status con-figuration was not included in the detailed anal-ysis of the Draft EIS because it was analyzed inthe SNF & INEL EIS. For purposes of the FinalEIS, DOE has determined that it is not a reason-

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Idaho HLW & FD EIS

able alternative based on programmatic consid-erations, including those discussed above.

Evaporation Methods for Treatment of MixedTransuranic Waste/SBW - In addition to NASOption 1, Two-Stage Low-TemperatureEvaporation (see Section B.8.3.1), two addi-tional evaporation methods were evaluated forthe treatment of mixed transuranic waste/SBW:Direct Evaporation in the Shipping Cask, andHigh-Temperature Evaporation with a RotaryKiln (with MACT) and shipment of processwaste to the Waste Isolation Pilot Plant. DirectEvaporation in the Shipping Cask was elimi-nated from detailed evaluation because of con-tainer integrity concerns and significantmaterials development and investigation.Treatment of mixed transuranic waste/SBWusing High-Temperature Evaporation with aRotary Kiln was eliminated because 1) it isexpected to cost significantly more than calcina-tion, 2) it has no significant technical or scheduleadvantages, and 3) it is a thermal process, wouldproduce considerable air emissions, and wouldrequire MACT.

Separations Options for Treatment of MixedTransuranic Waste/SBW - Various optionsinvolving separation of the mixed transuranicwaste/SBW were evaluated during the PreferredAlternative identification process. Theseoptions, and the reasons they were eliminatedfrom detailed evaluation, are listed below.

• Cesium Ion Exchange with TransuranicWaste Grout Treatment - This technol-ogy uses a sorbent in an ion exchangecolumn to extract cesium from themixed transuranic waste/SBW. Theremaining waste product would begrouted and shipped to the WasteIsolation Pilot Plant. At the time of thisevaluation, the cesium-loaded resinwould be grouted and sent directly toHanford or the Nevada Test Site for dis-posal as remote-handled low-levelwaste. This process has some technol-ogy development questions concerningcesium ion-exchange column perfor-mance that would need to be resolved touse for mixed transuranic waste/SBW.In addition, this process has develop-ment questions that would require sig-

- New Information -

nificant added functions and technologydevelopment in order to treat calcinedwaste, which would require dissolutionprior to separations. This process waseliminated for further evaluation since itis not directly applicable to the treatmentof mixed HLW calcine without signifi-cant further technology development.However, if calcine separations wereconsidered it could be reconsidered.

• Cesium Ion Exchange with TransuranicExtractions - This option involves theuse of cesium ion exchange, asdescribed above, followed bytransuranic extraction through the use ofsolvent technology and centrifugal con-tactors. The process is more complexthan Cesium Ion Exchange withTransuranic Waste Grout, requiring sev-eral additional processes for thetransuranic extraction cycle. The pro-cess has a low technical maturity, andwould be more expensive than CesiumIon Exchange or TransuranicExtractions alone.

• Transuranic Extractions with Class C-Type Grout or Class A-Type Grout -This option is similar to that describedabove and uses a solvent and centrifugalcontactors to separate high activity andtransuranic radionuclides from themixed transuranic waste/SBW. Becausecesium is not separated out of the wastestream at the front of the process, theprocess would produce transuranicwastes as well as remote-handled lowactivity waste for disposal at Hanford.The flow sheets for these options aremore complex than either UniversalExtractions (described below) or theCesium Ion Exchange with TransuranicWaste Grout Treatment (describedabove), have low technical maturity andno perceived technical advantage overother mixed transuranic waste/SBWtreatment options.

• Universal Extractions and ModifiedUniversal Extractions - UniversalExtractions technology uses solventsand centrifugal contactors to separate

the high-activity and transuranicradionuclides from the mixedtransuranic waste/SBW. The ModifiedUniversal Extraction Option differs inthat the low-activity transuranic wastewould stay with the low-activity wastestream to create 5,000 cubic meters ofcontact-handled transuranic grout. Bothextraction technologies would produceabout 400 cubic meters of remote-han-dled transuranic waste. In general,Universal Extractions is not as mature atechnology as Cesium Ion Exchange,and has a relatively complicated flowsheet, which would require significanttechnology development. Currently,solvent procurement questions existwith this technology since most technol-ogy development has been performed inforeign countries. Since these alterna-tives have no advantage over other sep-aration processes, they were droppedfrom further evaluation.

Separations by Precipitation for MixedTransuranic Waste/SBW - In addition to the fourprecipitation technologies proposed by the NAS(NAS Options 2-5, Section B.8.3.1), two addi-tional precipitation methods were evaluated:Low-Temperature Precipitation and High-Temperature Evaporation and Precipitation.

• Low-Temperature Precipitation - Low-Temperature Precipitation removes theheat from mixed transuranic waste/SBWby refrigeration, causing at least onecomponent of the waste to solidify assalt crystals, which can then be sepa-rated off. The concentrated liquid con-tains most of the fission and transuranicelements, and the precipitate would con-tain approximately 60 percent of thesodium. The precipitated salt cakewould be grouted. This treatment tech-nology is complex, in particular attempt-ing to separate crystals out of the liquidmixed transuranic waste/SBW is viewedas difficult and perhaps impossible. Alarge amount of technology develop-ment would be required in order todetermine if this process would work.There was no perceived advantage ofthis technology over more mature sepa-

DOE/EIS-0287 B-24

Appendix B - New Information -

B-25 DOE/EIS-0287

Idaho HLW & FD EIS

rations technologies and the technologi-cal risk was higher. Consequently, itwas dropped from further evaluation.

• High-Temperature Evaporation andPrecipitation - This option would evap-orate mixed transuranic waste/SBW atless than 150oC to a specific gravity of1.3, then collect the precipitate as thebatch cools. The remaining liquidwould be direct grouted, and the remote-handled grout would be shipped theWaste Isolation Pilot Plant. The precip-itate would be low-level waste. There isno technical advantage of this technol-ogy over Low-TemperaturePrecipitation. It would produce moreremote-handled transuranic waste andoffgases compared to Low-TemperaturePrecipitation. There is significant tech-nological uncertainty associated withthis alternative, in particular there is apotential hazard of unplanned cool downwith precipitate depositing and solidify-ing in process lines.

Direct Immobilization of Mixed TransuranicWaste/SBW - In addition to the waste immobi-lization options evaluated in the Draft EIS, threeadditional direct immobilization options wereevaluated: Polymer Encapsulation, DirectAbsorbent, and Silica Gel. Steam Reforming,also a direct immobilization alternative, was dis-cussed in Section B.8.2.1.

• Polymer Encapsulation - This optionwould use a mix of 40 percent mixedtransuranic waste/SBW and 60 percentpolymer. The polymer is mixed with themixed transuranic waste/SBW andforms a solid block directly in the can.This option was eliminated becausewaste volumes of remote-handledtransuranic waste would be large (6,100cubic meters), and the polymer is expen-sive. Although this technology has beendemonstrated for low-level waste, themanufacturer does not recommend thistreatment alternative for mixedtransuranic waste/SBW. Consequently,it was dropped from further evaluation.

• Direct Absorbent (similar to kitty lit-ter) - A clay material such as kitty litter

or Ultra Sorb would be used to absorbmixed transuranic waste/SBW and elim-inate the free liquids associated with thewaste. This option was eliminated fromdetailed evaluation because of the largequantity of remote-handled transuranicwaste that would be produced by thistreatment alternative (12,500 cubicmeters). This quantity of waste couldexceed the Waste Isolation Pilot Plantcapacity for remote-handled transuran-ics, and there are technical uncertaintiesregarding the dissociation of water in thecontainers.

• Silica Gel - In this option, a clay materialwould be added directly to the mixedtransuranic waste/SBW and eliminatefree liquid. The adsorbed waste wouldthen be sent to Hanford for vitrification.The volume of remote-handledtransuranic waste could exceed thecapacity of the Waste Isolation PilotPlant, significant development workcould be required to initiate this alterna-tive, and there is no perceived advantageover the Direct Cement Waste Option(evaluated in the Draft EIS) where theprocess is simpler.

HLW Calcine Technologies - For calcine treat-ment technologies, both separations and non-separations technologies were evaluated duringthe Preferred Alternative identification process.Calcine separations technologies were not elimi-nated from detailed evaluation, rather the finaldecision was postponed until at least 2007 afteradditional technology development. The tech-nologies listed below are essentially the same asfor mixed transuranic waste/SBW with somemodifications to handle the calcine. In additionto the technologies listed below, separated high-activity waste could be sent to Hanford for vitri-fication.

• Polymer Encapsulation - In addition tothe non-separations options evaluated inthe Draft EIS, Polymer Encapsulation ofmixed HLW calcine was also evaluated.The technology is described above formixed transuranic waste/SBW. PolymerEncapsulation was eliminated fromdetailed evaluation because it wouldproduce twice as much HLW as the Hot

- New Information -

Isostatic Pressed Waste Option evalu-ated in the Draft EIS. Additionally, thevendor has indicated it is probably notapplicable for calcine treatment.

• Cesium Ion Exchange with TransuranicGrout Treatment - This process wouldbe the same as for mixed transuranicwaste/SBW, except for an added disso-lution step for the mixed HLW calcine.For the calcine, cesium represents 99percent of the gamma radiation associ-ated with the dissolved calcine. Thisoption removes the cesium in a down-stream operation that allows the rest ofthe process to operate with less shield-ing. This separation technology for cal-cine has advantages of a simple flowsheet, small waste volumes of remote-handled low-level and transuranicwastes, and it is a non-thermal treat-ment. Disadvantages include leavingkey nuclides in the low-activity stream,some technology development questionsexist concerning the operation of thecesium ion exchange column, and itwould require a waste incidental toreprocessing determination for disposalat the Waste Isolation Pilot Plant. If adecision were to be made in the future toseparate mixed HLW calcine and pro-cess the waste, this option could be eval-uated as a part of that process.

• Cesium Ion Exchange with TransuranicExtractions - This alternative is similarto the mixed transuranic waste/SBWtreatment alternative except it wouldinclude the retrieval and dissolution ofmixed HLW calcine prior to treatment.For calcine, cesium represents 99 per-cent of the gamma radiation associatedwith the dissolved calcine. This optionremoves the cesium in a downstreamoperation that allows the rest of the pro-cess to operate with less shielding. Mostof the waste could go to Hanford as low-activity waste, it is a non-thermal pro-cess, and it maintains the flexibility tosend high-activity waste to Hanford forvitrification. Disadvantages include lowtechnical maturity, and it is more com-plicated than either Cesium Ion

Exchange or Transuranic Extractionsalone.

• Transuranic Extractions with Class C-Type or Class A-Type Grout - Both ofthese options have the advantage of non-thermal processes and were describedfor mixed transuranic waste/SBW pro-cessing. The same disadvantages dis-cussed for mixed transuranicwaste/SBW would apply to the process-ing of mixed HLW calcine and theseoptions were dropped from further eval-uation for the separations and treatmentof calcine.

• Universal Extractions and ModifiedUniversal Extractions - These processesare described above for mixedtransuranic waste/SBW. These optionsare non-thermal and less complicatedthan Transuranic Extractions.Separations for calcine have not beeneliminated, and this option could beevaluated as a backup to Cesium IonExchange with Transuranic Grout ifneeded.

B.9 Process Used toIdentify the PreferredAlternatives

The purpose of this section is to provide adescription of the activities undertaken by DOEand, as a cooperating agency, the State of Idaho(the State) to evaluate available data and reachconsensus on recommended PreferredAlternatives for this EIS. This section summa-rizes the Preferred Alternatives identificationprocess undertaken after the Draft EIS wasissued in December 1999.

B.9.1 BACKGROUND

In 1995, DOE and the State entered into aSettlement Agreement/Consent Order which, inpart, set enforceable milestones for the treatmentof approximately 4,400 cubic meters of solid

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Appendix B - New Information -

mixed HLW calcine and 1 million gallons of liq-uid mixed transuranic waste/SBW stored at theINTEC. In order to meet the milestones, variouswaste processing alternatives needed to be eval-uated and programmatic decisions made relativeto identifying the best path forward.Subsequently, DOE filed a Notice of Intent in1997 to complete an EIS in accordance withNEPA to evaluate the environmental impacts ofalternatives for treating calcine and mixedtransuranic waste/SBW (as well as newly gener-ated liquid waste), and the alternatives for thedisposition of related HLW management facili-ties at INTEC. The State agreed to participate asa cooperating agency in the development of theEIS as a means to support the SettlementAgreement/Consent Order, provide State inputinto the decision process, and to facilitate theEIS review process.

During the alternative selection process for theDraft EIS, DOE identified and evaluated over100 potential treatment technologies for calcine,mixed transuranic waste/SBW and newly gener-ated liquid waste. The potential environmentalimpacts of the identified alternatives were ana-lyzed in the Draft EIS. The extensive effort toidentify the alternatives for the Draft EIS wasdocumented in the report entitled Process forIdentifying Potential Alternatives for the IdahoHigh-Level Waste and Facilities DispositionDraft EIS (DOE 1999a).

In January 2000, DOE issued the Draft EIS, butdid not identify a Preferred Alternative to allowconsideration of all public comment on the DraftEIS as a part of the Preferred Alternative identi-fication process. After the Draft EIS was issued,data gathering and evaluation of potential wasteprocessing technologies began, and continueduntil a Preferred Alternative was identified inOctober 2000.

B.9.2 APPROACH

This section provides an overview of the processfor identifying the preferred waste processingalternatives for treating mixed transuranicwaste/SBW, newly generated liquid waste, andcalcine, and the Preferred Alternative for the dis-position of HLW management facilities atINTEC.

B.9.2.1 Waste ProcessingAlternative Evaluation

The preferred waste processing alternative iden-tification process commenced with the develop-ment of a Decision Management Plan thatdefined a structured approach. Key to thisapproach was the establishment of a DecisionManagement Team assigned the responsibilityfor overseeing the evaluation of relevant data,reaching consensus, and recommending aPreferred Alternative to senior DOE manage-ment. The plan also defined the roles andresponsibilities of the three teams supporting theDecision Management Team, and includeddirections for incorporating public input andindependent reviews. The process for identify-ing the preferred facility disposition alternativeis discussed in Section B.9.2.2.

Figure B-1 shows the general organization of theteams supporting the identification of theDecision Management Team PreferredAlternative. The DOE Assistant Secretary forEnvironmental Management provided manage-ment guidance and direction to the DecisionManagement Team. Senior State of Idaho man-agement were also involved through representa-tives on the team. The Decision ManagementTeam consisted of a multidisciplinary group ofexperienced personnel from the State of Idaho’sINEEL Oversight Program and Department ofEnvironmental Quality and within the DOEcomplex (DOE Headquarters, DOE IdahoOperations, DOE Carlsbad Area Office, DOEOffice of River Protection, and DOE SavannahRiver). The Public Involvement Team, thePerformance Management Team, and theDecision Support Team provided input to theDecision Management Team for their considera-tion in identifying a Preferred Alternative.

In January 2000, the Decision Support Teambegan collecting and evaluating data to supportthe decision process. The Decision SupportTeam was comprised of four subteams. Teammembers were identified for specific expertiseneeded for each subteam and represented DOE,the State, and contractor staffs. The subteamsand their areas of responsibility were:

• Technology and Cost Subteam -technology and costs

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• Environmental Subteam - estimatedenvironmental impacts

• Facility Disposition Subteam - facilitydisposition impacts and approaches

• Combined Subteam - agency concerns,mission, policy, and uncertainties.

However, for simplicity, the individual subteamswill be referred to here solely as the DecisionSupport Team.

Figure B-2 depicts the overall decision process.As shown in Figure B-2, the process began witha methodical search for reasonable waste pro-cessing technologies. Over sixty reference doc-uments were evaluated, along with input frominterviews, presentations, and agency and publiccomment. The technology identification processresource database included:

• The Draft EIS alternatives identificationreport (DOE 1999a) to identify tech-nologies and alternatives warranting re-evaluation

• The NAS report, Alternative High LevelWaste Treatments at the Idaho NationalEngineering and EnvironmentalLaboratory (NAS 1999)

• A mixed transuranic waste/SBW pro-cessing analysis conducted by the man-agement and operating contractor(Murphy et al. 2000) and detailed talkswith authors

• Presentations by, and discussions with,waste processing subject matter experts

• Recommendations by the INEELCitizens Advisory Board (CAB 2000)

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Appendix B - New Information -

FIGURE B-1.Organization of teams for identifying the Preferred Alternative.

DOE Assistant Secretary forEnvironmental Management

(DOE/EM-1)

Tanks Focus AreaPeer Review Group

Decision ManagementTeam

Decision SupportTeam

PerformanceManagement Team

Public InvolvementTeam

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INPUT

Support teams provide additional information

Tanks Focus Area peer review (June - July 2000) and evaluation of steam reforming process (August - September 2000)

Draft EISNational Academy of Sciences report

BBWI alternative evaluationPublic comment

INEEL Citizens Advisory BoardDraft EIS alternatives report

Literature searchSubject matter experts

49 potential waste processing technologiesidentified for mixed transuranic waste/SBWand calcine. Selection process resulted in14 technologies recommended for furtherevaluation by the Decision Management Team

Decision Management Team/TanksFocus Area Conference CallSeptember 22, 2000

- Discussion of steam reforming. No changes to Preferred Alternative.

DOE - Environmental ManagementConcurrence MeetingOctober 20, 2000

- Preferred Alternative approved for Final EIS

First Decision Management Team MeetingMay 8-9, 2000

- Support teams presented study results- Review and endorsement of technical review results and preliminary narrowed list of waste processing technologies- Confirmed evaluation and selection process- Adopted criteria for mission, policy objectives, uncertainties, and agency concerns- Additional information needs identified

Third Decision Management Team MeetingAugust 1-3, 2000

- Discussed updated technology, cost and budget information- Discussed Tanks Focus Area peer review, waste incidental to reprocessing evaluation issue, briefings, staff input- State of Idaho concerns reviewed- Re-examined decision criteria- Scoring analysis for mixed transuranic waste/SBW- Consensus on recommended Preferred Alternatives for mixed transuranic waste/SBW, calcine, and facility disposition

FIGURE B-2.Overview of Decision Management Team.

Second Decision Management Team MeetingMay 30 - June 1, 2000

- Support teams presentations- Discussion of issues impacting decisions- Agreement on scoring process- Agreement on approach for facility disposition alternatives- Agreement on not to score calcine- Mixed transuranic waste/SBW processing technologies evaluated- Agreement on Tanks Focus Area peer review approach- Additional information needs identified

DOE/EIS-0287 B-30

Appendix B

• Input from the public from scopingactivities, public involvement activities,and the Draft EIS public comment pro-cess

• Draft EIS alternative descriptions

Using this input and a structured alternativesidentification process, the Decision SupportTeam identified 34 potential mixed transuranicwaste/SBW treatment technologies and 15potential calcine treatment technologies. Thepotential mixed transuranic waste/SBW treat-ment technologies were also applicable to newlygenerated liquid waste. The Decision SupportTeam then developed screening criteria. Thesecriteria were eventually incorporated into onecomprehensive list. Go/no-go criteria were alsodeveloped and used to screen out technologies.If a technology failed to meet this criteria, it wasnot scored. The go/no-go criteria were:

• Judged to be reasonable and satisfies"purpose and need" for this EIS

• Meets INTEC objectives of ultimate dis-position of DOE radioactive liquidwaste, calcine, and contaminated mixeddebris according to regulatory require-ments

• All the liquid in the 300,000 gallonunderground tanks and all calcine in thebin sets is treated and made ready toleave Idaho by 2035

This process eliminated most of the technolo-gies, leaving the most promising for furtherreview.

The Decision Management Team was taskedwith reviewing the technical data provided onvarious waste processing technologies, anddetermining if the data presented were suitableto support the identification process and if allreasonable technologies had been considered.

In addition, the Decision Management Teamconsidered public and agency comments on theDraft EIS. The 15 key issues expressed from thecomment period on the Draft EIS are listedbelow:

• Treatment alternatives

• Continued public involvement

• Meeting agreements/requirements ver-sus making sound technical decisions

• Federal government obligations toStates/Tribes versus funding constraints

• Scope of EIS (cost, technical viability)

• Continued calcine operations

• Treat liquids (mixed transuranicwaste/SBW) first

• Protection of air and water

• Concern over the capability to fundalternatives

• DOE credibility

• Reclassification of waste

• Long-term stewardship of the land

• Issues affecting disposal

• Maintaining agreements with tribes

• Opposition to waste incineration

The Decision Management Team considered thisinformation as it developed the goals and criteriaused for evaluating, narrowing, and scoring themixed transuranic waste/SBW technologies. Forinstance, the public preferences for no separa-tions treatments and no incineration-type treat-ments were considered and discussed as thetechnologies were scored. These considerationsand all other public issues identified were foldedinto appropriate criteria for scoring and were dis-cussed as each technology was scored by theDecision Management Team. The DecisionManagement Team also periodically briefed andreceived guidance/direction from seniorDOE/EM management on the nature of the pub-lic comments received, and the team’s processfor factoring the consideration of public com-ments into its deliberations.

- New Information -

The Decision Management Team also decidedthat an independent peer review team would betasked with reviewing and evaluating the ade-quacy of the Preferred Alternative identificationprocess and making independent recommenda-tions. The requested independent review wasconducted by the DOE Tanks Focus Area PeerReview Team. This team included experts in thefield of HLW processing from Hanford, theSavannah River Site, Los Alamos NationalLaboratory, Oak Ridge National Laboratory,Syracuse University, and a consulting company.The Tanks Focus Area Peer Review Team issueda report in July 2000 (TFA 2000). The team con-cluded "DOE-ID and contractor staff haveimplemented a technology identification processand path forward planning approach that is verylikely to succeed." (TFA 2000)

For mixed transuranic waste/SBW processing,the Tanks Focus Area Peer Review Team recom-mended adoption of direct vitrification as thebaseline Preferred Alternative, with cesium ionexchange as a backup process. For treatment ofcalcine, the team recommended that DOE con-tinue to develop direct vitrification and separa-tions options and make final processingdecisions consistent with plans to meet the 2035"road-ready" compliance date specified by theSettlement Agreement/Consent Order.Additional recommendations include detailedtechnology road mapping with adequateresources made available to support evaluationsand development of technologies.

The Tanks Focus Area Peer Review Team wasalso asked to participate in the evaluation of thesteam reforming process, an alternative sug-gested as a result of public review of the DraftEIS. The team concluded that steam reformingof liquid mixed transuranic waste/SBW wouldnot generate a waste form that can be directlydisposed in a repository.

The Decision Management Team's goals andfinal screening criteria that were used to scorethe mixed transuranic waste/SBW processingtechnologies incorporated criteria from the areasof technology, costs, environmental impacts,public concerns, mission, agency concerns,uncertainties, and policy. Overall goals and indi-vidual criteria measuring the success of the goalswere established by the Decision ManagementTeam (Table B-4).

The Decision Management Team met threetimes and had one conference call over a periodof five months to discuss and evaluate the pro-posed waste processing technologies. Theresults of the meetings are summarized in FigureB-2. The narrowed set of potential mixedtransuranic waste/SBW processing technologieswere scored by the Decision Management Teamat the final meeting in August 2000.

The Decision Management Team also decidedagainst scoring the calcine processing technolo-gies because DOE lacked information regardingcalcine retrievability and the potential impact ofcalcine characterization on the success of sepa-rations and immobilization technologies. TheDecision Management Team determined thatthese knowledge gaps warranted further technol-ogy development as part of the overall decisionprocess on a Preferred Alternative for calcine.

B.9.2.2 Facility DispositionAlternative Evaluation

As the list of waste processing technologies wasnarrowed, the Decision Support Team evaluatedthe various technologies and determined whichfacilities would need to be disposed that are cur-rently part of the HLW program or that would beconstructed to support the preferred waste pro-cessing alternative. The facility dispositionalternatives evaluated were those identified inthe Draft EIS, namely:

• Clean closure, with no hazardous orradiological contamination detectableabove background

• Performance-based closure, withcleanup and closure conducted on acase-by-case basis based on risk to theworkers and public

• Landfill closure, with cleanup con-ducted to meet standards for landfills

Consistent with the objectives and requirementsof DOE Order 430.1A, Life Cycle Management,and DOE Manual 435.1-1, Radioactive WasteManagement Manual, all newly constructedfacilities implementing the preferred waste pro-cessing alternative would be designed and con-

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Appendix B

structed consistent with the measures that facili-tate clean closure methods.

The team reviewed the list of existing HLWProgram facilities for accuracy and developed alist of new facilities anticipated for each wasteprocessing technology. The team determinedthat there were three measurable parametersimpacting facility disposition decisions: (a) sizeof the new facility, (b) complexity of facilityoperations, and (c) volume of the waste streamsgenerated during facility disposition. Using therelative waste volumes, size of facility, and ajudgment of process complexity, the team partic-ipated in an evaluation process that assigned aranking score for each of the individual treat-ment technologies as it related to the require-ments and activities associated with facilitydisposition.

The primary conclusion made by the DecisionManagement Team was that there were no facil-ity disposition discriminators that would affectthe team’s decisions related to the preferredwaste processing alternative. The team also con-

cluded that the total environmental impact tomeet facility disposition requirements for theEIS is considerably less significant when com-pared with the total environmental impacts asso-ciated with waste processing activities.

B.9.3 PREFERRED ALTERNATIVES

B.9.3.1 Decision Management Team’sRecommended PreferredAlternative

This section summarizes the DecisionManagement Team’s recommended PreferredAlternative.

B.9.3.1.1 Waste Processing

Mixed Transuranic Waste/SBW TreatmentPreferred Alternative - Direct vitrification wasrecommended by the Decision ManagementTeam because it has the advantage of being a

- New Information -

Table B-4. Goals and associated criteria used by the Decision Management Teamto score mixed transuranic waste/SBW processing technologies.

Goal and Definition CriteriaMaximize Meeting Schedule Commitments -Meet the 2012 and 2035 SettlementAgreement/Consent Order and Notice ofNoncompliance Consent Order milestones.

1. Schedule risk2. Liquid mixed transuranic waste/SBW

road-ready date

Minimize Cost - Minimize the near-term costs aswell as the life-cycle costs. Disposal cost includespackaging and transportation.

3. Projects and operational costs4. Disposal cost

Minimize Technical Risk - Minimize the potential forselection of a technically nonviable wasteprocessing technology.

5. Technical maturity6. Risk of technical failure

Minimize Environment, Safety, and HealthImpacts -Minimize (a) impact to workers during theconstruction and operation of the facilities,(b) public risk from transportation doses andaccidents, and (c) risk to the environment fromreleases to the air, soil, and water.

7. Safety and health (worker)8. Public risk9. Environmental risk

Maximize Utilization by Other Wastes - Get themost from the technology in terms of processingnewly generated liquid waste, tank heel solids, andcalcine.

10. Newly generated liquid waste mission11. Calcine mission12. Heel solids mission

Maximize Ability to Dispose - Make a waste thatcan be disposed of as quickly as possible.

13. Maximizes early disposal

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mature technology with a lower risk of technicalfailure, and the final waste form (borosilicateglass) is the EPA's approved form for disposal inthe HLW national geologic repository.Converting the mixed transuranic waste/SBW toglass would allow the waste to go to either theWaste Isolation Pilot Plant or the HLW geologicrepository. Vitrification also has the advantageof being able to treat both mixed transuranicwaste/SBW and calcine, although some modifi-cations to the treatment process would berequired for the treatment of calcined waste. Useof vitrification for both waste types enables theprorating of facility and processing costs,thereby reducing the overall cost for mixedtransuranic waste/SBW processing.

The final disposal for vitrified SBW woulddepend on the outcome of the Waste Incidentalto Reprocessing determination required by DOEOrder 435.1 (DOE 1999b). The WasteIncidental to Reprocessing process is being usedto determine whether the SBW at INTEC can bemanaged as mixed transuranic waste. The des-ignation of the vitrified SBW as HLW wouldrequire disposal of the waste in a HLW nationalgeologic repository (assumed to be YuccaMountain). If the vitrified SBW were designatedas transuranic waste, it would be disposed of atthe Waste Isolation Pilot Plant. Disposing thevitrified SBW at the Waste Isolation Pilot Planthas the advantages of lower disposal costs,schedule compatibility with INEEL proposedprocessing times, a final waste form that wouldmeet the Waste Isolation Pilot Plant waste accep-tance criteria, and adequate disposal space tohandle INEEL waste.

The HLW national geologic repository has notdeveloped a final waste acceptance criteria, theschedule for opening the proposed YuccaMountain facility (the only site currently beingstudied for a HLW geologic repository) is uncer-tain, and there are concerns on the adequacy ofcapacity available to accommodate DOE HLW.However, regardless of which location the finalwaste form is disposed of, it will be protective ofhuman health and the environment.

Calcine Treatment Preferred Alternative - TheDecision Management Team’s recommendedPreferred Alternative for calcine was to retrievethe calcine presently stored in the six bin sets atINTEC, vitrify it, and place it in a form to enable

compliance with the current legal and regulatoryrequirement to have HLW road ready by a targetdate of December 31, 2035. Concurrent with theprogram to design, construct, and operate the vit-rification facility for mixed transuranicwaste/SBW, DOE would initiate a program tocharacterize the calcine, and develop methods toconstruct and install the necessary equipment toretrieve calcine from the bin sets. DOE wouldfocus technology development on the preferredcalcine treatment technology of vitrification, andthe feasibility and merits of performing calcineseparations as well as refine cost and engineer-ing design. Conditioned on the outcome offuture technology development and resultingtreatment decisions, DOE could design and con-struct the appropriate calcine separations capa-bility at INEEL. For treatment of separatedmixed HLW fractions, DOE would also evaluatethe use of Hanford vitrification capabilities asthey are developed. A final treatment decisionon the specific waste processing method wouldbe anticipated after 2007 when technologydevelopment would be completed.

Newly Generated Liquid Waste TreatmentPreferred Alternative - In 2005, DOE intends toredirect all newly generated liquid waste to tanksthat meet state and federal ResourceConservation and Recovery Act regulations, ortreat the waste directly. Under the DecisionManagement Team’s Preferred Alternative, thenewly generated liquid waste stream would becompletely segregated from the mixed HLW cal-cine and mixed transuranic waste/SBW streamsand would contain no fraction requiring manage-ment as HLW. Newly generated liquid wastecould be grouted in containers and disposed of aslow-level waste or transuranic waste, dependingon its characteristics.

B.9.3.1.2 Facility Disposition

Consistent with the objectives and requirementsof DOE Order 430.1A, Life Cycle Management,and DOE Manual 435.1-1, Radioactive WasteManagement Manual, all newly constructedfacilities implementing the preferred waste pro-cessing alternative would be designed and con-structed consistent with the measures thatfacilitate clean closure methods. For existingHLW facilities, the Decision ManagementTeam’s Preferred Alternative was to apply, on a

- New Information -

case-by-case basis, the most viable closureoptions, that would provide a systematic reduc-tion of risks due to residual wastes and contami-nants. These remaining residual wastes wouldbe immobilized by methods such as grouting anddisposed of in-place and monitored in accor-dance with the applicable requirements ofRCRA and Idaho Hazardous Waste ManagementAct. Closure would be performed to levels eco-nomically, practically, and technically feasiblesuch that satisfactory protection of the environ-ment and the public is achieved in accordancewith applicable regulations.

The Decision Management Team’s PreferredAlternatives for mixed transuranic waste/SBWprocessing, newly generated liquid waste, cal-cine processing, and facility disposition wereidentified for recommendation to DOE/EM.Final approval of the alternatives recommendedby the Decision Management Team wasobtained from the DOE Assistant Secretary forEnvironmental Management on October 20,2000.

After DOE and the State of Idaho identified thealternative of vitrification with or without cal-cine separations, it was decided to use the term"direct vitrification" in reference to the broaderalternative with "vitrification without calcineseparations" and "vitrification with calcine sepa-rations" to distinguish options. The new alterna-tive referred to in this EIS as Direct Vitrificationis described in Section 3.1.6.

B.9.3.2 DOE’s Preferred Alternative

As discussed in the previous section, DOE andthe State of Idaho identified vitrification of themixed transuranic waste/SBW and calcine withor without separations as the PreferredAlternative in October 2000. In September2001, DOE conducted an assessment of the alter-natives and options using the following assump-tions:

• Sodium bearing waste is mixedtransuranic waste

• Treated SBW can be disposed of atWIPP

• Calcine is an acceptable final wasteform for disposal at the geologic reposi-tory

• Steam reforming is an acceptable treat-ment technology for the SBW

• The liquid mixed transuranicwaste/SBW can be grouted in place

• The calciner can be operated in its pre-sent interim status configuration.

With these assumptions as a basis, and also inconsideration of public comment on the DraftEIS, DOE decided on a performance basedrather than a technology based PreferredAlternative for waste processing. DOE'sPreferred Alternative for facility disposition isthe same as that identified by DOE and the Stateof Idaho in October 2000.

The revised Preferred Alternative for waste pro-cessing focuses on the removal and stabilizationof the remaining liquids, without specifying astabilization technology. There is a range oftechnologies, analyzed in the EIS that meet thisperformance objective.

With respect to the alternative of continued cal-cination of the remaining liquids, the currentanalysis regarding operation of the calciner withmodifications to comply with environmentalregulations would be maintained. Operating thecalciner in its present interim status configura-tion was evaluated and eliminated from detailedanalysis in the Final EIS based on programmaticconsiderations.

The alternative of disposing of the grouted liquidwaste in situ was re-evaluated and eliminatedfrom detailed analysis considering the complex-ity of the stabilization process and regulatoryobstacles involved. Based on the re-evaluation itis included in the Final EIS as an alternative con-sidered but eliminated from detailed analysis.

An additional option called Steam Reforminghas been added to the Non-SeparationsAlternative. This option analyzes the use of asteam reforming technology to treat the mixed

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transuranic waste/SBW, and incorporatesupdated information received since the TanksFocus Area report was issued that recommendedsteam reforming as an offgas treatment. In addi-tion, this option includes the analysis for placingthe HLW calcine in containers and sending itdirectly to a repository. This option is structuredsimilar to the alternatives/options analyzed in theEIS for comparison purposes.

DOE has decided to identify a PreferredAlternative that meets performance objectivesrather than a single technology. Thus, DOE’sPreferred Alternative is to implement a slightlyrevised version of the Proposed Action presentedin Chapter 1 of this EIS. The PreferredAlternative is a performance-based rather thantechnology-based approach to fulfilling theDepartment's statutory mission and responsibili-ties. The performance objectives could beaccomplished through implementing technolo-gies and actions representative of those analyzedin the EIS. The Proposed Action and the perfor-mance objectives of the Preferred Alternative arepresented below:

• Develop appropriate technologies andconstruct facilities necessary to pre-pare INTEC mixed transuranicwaste/SBW for shipment to WIPP -DOE would treat all mixed transuranicwaste/SBW stored in the INTEC TankFarm and ship the product waste toWIPP for disposal. A range of potentialtreatment technologies representative ofthose that could be used is analyzed inthis EIS. The Department's objective isto treat the mixed transuranicwaste/SBW such that this waste wouldbe ready for shipment to WIPP byDecember 31, 2012.

• Prepare the mixed HLW calcine so thatit will be suitable for disposal in arepository - DOE would place all mixedHLW calcine in a form suitable for dis-posal in a repository. This may includeany of the treatment technologies ana-lyzed in this EIS in addition to shipmentto a repository without treatment as ana-lyzed in this final EIS. The

Department's objective is to place themixed HLW calcine in a form such thatthis waste would be ready for shipmentout of Idaho by December 2035.

• Treat and dispose of associatedradioactive wastes - DOE would treatand dispose of all wastes associated withthe treatment and management of HLWand mixed transuranic waste at INTEC.This includes the treatment and disposalof newly generated liquid waste. Arange of the potential treatment tech-nologies that could be used is analyzedin this EIS.

• Provide safe storage of HLW destinedfor a repository - DOE will continue tostore mixed HLW calcine in the INTECcalcine bin sets until the calcine isretrieved for treatment or placed in con-tainers for shipment to a repository.

• Provide for the disposition of INTECHLW management facilities when theirmissions are completed - DOE willdisposition existing INTEC HLW man-agement facilities in accordance withperformance based closure standards.All newly constructed facilities neces-sary to implement the ProposedAction/Preferred Alternative would bedesigned and constructed consistentwith measures that facilitate clean clo-sure.

Selection and implementation of spe-cific technologies would be based on abalance of optimum treatment and costeffectiveness with reduction of risk tohuman health and the environment.The range of potential environmentalimpacts and risk to human health,including cumulative impacts, under anyof the currently available technologies ischaracterized by the analysis in this EIS.The alternatives are composed of modu-lar options and projects that may becombined and configured as needed toimplement the ProposedAction/Preferred Alternative.

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B.9.3.3 State of Idaho’sPreferred Alternative

The State of Idaho has elected to keep thePreferred Alternative recommended by theDecision Management Team as the State ofIdaho's Preferred Alternative. The State is will-ing to reconsider its preference if further devel-opment of other technologies or analysis ofrepository and transportation requirements indi-cates another alternative meets the following cri-teria:

• The alternative meets transportation andrepository waste acceptance require-ments to enable DOE to ship all HLWand mixed transuranic waste/SBW andany fraction thereof out of Idaho;

• The alternative has environmentalimpacts comparable or less than those ofthe State's Preferred Alternative;

• The alternative can be completed in acomparable or shorter timeframe; and

• The alternative is of comparable orlower cost.

B.9.3.3.1 Waste Processing

The State of Idaho's Preferred Alternative forwaste processing is the Direct VitrificationAlternative described in Section 3.1.6. Thisalternative includes vitrification of mixedtransuranic waste/SBW and vitrification of theHLW calcine with or without separations.

Under the option to vitrify the mixed transuranicwaste/SBW and calcine without separations, themixed transuranic waste/SBW would beretrieved from the INTEC Tank Farm and vitri-fied. Calcine would be retrieved from the binsets and vitrified. In both cases, the vitrifiedproduct would be stored at INTEC pending dis-posal in a geologic repository.

The option to vitrify the mixed transuranicwaste/SBW and vitrify the HLW fraction aftercalcine separations would be selected if separa-tions were shown to be technically and econom-ically practical. Mixed transuranic waste/SBW

would be retrieved from the INTEC Tank Farmand vitrified. Calcine would be retrieved fromthe bin sets and chemically separated into aHLW fraction and transuranic or low-level wastefractions, depending on the characteristics of thewaste fractions. The HLW fraction would be vit-rified. In both cases, the vitrified product wouldbe stored at INTEC pending disposal in a geo-logic repository. The transuranic or low-levelwaste fractions would be disposed of at anappropriate disposal facility outside of Idaho.

In addition, under the Direct VitrificationAlternative, newly generated liquid waste couldbe vitrified in the same facility as the mixedtransuranic waste/SBW, or DOE could constructa separate treatment facility for newly generatedliquid waste.

B.9.3.3.2 Facility Disposition

The State of Idaho’s Preferred Alternative forfacility disposition is the same as that recom-mended by the Decision Management Team.DOE would disposition existing INTEC HLWmanagement facilities in accordance with perfor-mance based closure standards. All newly con-structed facilities necessary to implement thePreferred Alternative would be designed andconstructed consistent with measures that facili-tate clean closure.

B.10 Final List of Final EISAlternatives

Therefore, as a result of all the activities dis-cussed in this Appendix, the Final Idaho HLW &FD EIS analyzed the following waste processingalternatives and options:

1. No Action Alternative

2. Continued Current OperationsAlternative

3. Separations Alternative

A. Full Separations Option

- New Information -

B. Planning Basis Option

C. Transuranic Separations Option

4. Non-Separations Alternative

A. Hot Isostatic Pressed Waste Option

B. Direct Cement Waste Option

C. Early Vitrification Option

D. Steam Reforming Option

5. Minimum INEEL Processing Alternative

6. Direct Vitrification Alternative

A. Vitrification without CalcineSeparations Option

B. Vitrification with CalcineSeparations Option

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Appendix B

Appendix B References

CAB (INEEL Citizens Advisory Board), 2000, Idaho High-Level Waste and Facilities Disposition DraftEnvironmental Impact Statement, Recommendation #73, March 22, in April 7, 2000 letter (00-CAB-030) from Stanley Hobson, Interim Chair INEEL CAB to Tom Wichman, U.S. Department ofEnergy, Idaho Operations.

DOE (U.S. Department of Energy), 1979, Environmental Impact Statement for the Long-TermManagement of Defense High-Level Radiation Waste Research and Development Program ofImmobilization at the Savannah River Site, DOE/EIS-0023, Savannah River Plant, Aiken, SouthCarolina, November.

DOE (U.S. Department of Energy), 1982a, Environmental Evaluation of Alternatives for Long-TermManagement of Defense High-Level Radioactive Waste at the ICPP, IDO-10105, September.

DOE (U.S. Department of Energy), 1982b, Environmental Assessment, Waste Form Selection forSavannah River Plant High-Level Waste, DOE/EA-0179, Savannah River Plant, Aiken, SouthCarolina.

DOE (U.S. Department of Energy), 1983, The Defense Waste Management Plan, DOE/DP-0015, U.S.Department of Energy, Assistant Secretary for Defense Programs, June.

DOE (U.S. Department of Energy), 1995, Department of Energy Programmatic Spent Nuclear FuelManagement and Idaho National Engineering Laboratory Environmental Restoration and WasteManagement Programs Environmental Impact Statement, DOE/EIS-0203-F, Idaho Operations Office,Idaho Falls, Idaho, April.

DOE (U.S. Department of Energy), 1996, Regulatory Analysis and Proposed Path Forward for the IdahoNational Engineering Laboratory High-Level Waste Program, DOE/ID-10544, Idaho OperationsOffice, Idaho Falls, Idaho, October.

DOE (U.S. Department of Energy), 1997a, Final Waste Management Programmatic Environmental ImpactStatement for Managing Treatment, Storage, and Disposal of Radioactive and Hazardous Waste,DOE/EIS-0200-F, Office of Environmental Management, Washington, D.C., May.

DOE (U.S. Department of Energy), 1997b, A Risk-Based Study of Potential NEPA Alternatives forManagement of High-Level Waste at INEEL, Idaho Operations Office, Idaho Falls, Idaho, September.

DOE (U.S. Department of Energy), 1998, Accelerating Cleanup: Paths to Closure, DOE/EM-0362, Officeof Environmental Management, Washington, D.C., June.

DOE (U.S. Department of Energy), 1999a, Process for Identifying Potential Alternatives for the IdahoHigh-Level Waste and Facilities Disposition Draft Environmental Impact Statement, DOE-ID 10627,Rev. 1, Idaho Operations Office, Idaho Falls, Idaho, March 2.

DOE (U.S. Department of Energy), 1999b, Radioactive Waste Management, DOE O 435.1 andM 435.1-1, Office of Environmental Management, Washington, D.C., July 9.

EMI (Environmental Management Integration), 1997, A Contractor Report to the Department of Energyon Environmental Management Baseline Programs and Integration Opportunities (Discussion Draft),Complex-Wide Integration Team, May.

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ERDA (Energy Research and Development Agency), 1977, Alternatives for Long-Term Management ofDefense High-Level Waste, Idaho Chemical Processing Plant, ERDA 77-43, September.

Knecht, D. M., M. D. Staiger, J. D. Christian, C. L. Bendixson, G. W. Hogg, and J. R. Bereth, 1997,"Historical Fuel Reprocessing and HLW Management in Idaho," Radwaste Magazine, pp. 35-45, May.

LITCO (Lockheed Idaho Technologies Company), 1995a, SBW Treatment Study, WBP-8-95/ALO-3-95,Idaho Falls, Idaho, February 20.

LITCO (Lockheed Idaho Technologies Company), 1995b, ICPP Radioactive Liquid and Calcine WasteTechnologies Evaluation Technical Report and Recommendation, INEL-94/0019, Idaho Falls, Idaho,April.

LMITCO (Lockheed Idaho Technologies Company), 1996, HLW Alternatives Evaluation, WBP-29-96,Idaho Falls, Idaho, August 16.

Loux, R. R., 1997, letter from the State of Nevada Agency for Nuclear Projects, Nuclear Waste ProjectOffice to T. L. Wichmann, U.S. Department of Energy, Idaho Operations Office, “Re: Notice of Intentto Prepare a High-Level Waste and Facilities Disposition Environmental Impact Statement, IdahoFalls. Idaho,” November 24.

Murphy, J., B. Palmer, and K. Perry, 2000, Sodium Bearing Waste Processing Alternatives Analysis,INEEL/EXT 2000-00361, Idaho National Engineering and Environmental Laboratory, IdahoFalls, Idaho, December 18.

NAS (National Academy of Sciences), 1999, Alternative High Level Waste Treatments for the IdahoNational Engineering and Environmental Laboratory, National Academy Press, Washington D.C.,December.

NRC (U.S. Nuclear Regulatory Commission), 1994, Branch Technical Position on PerformanceAssessment for Low-Level Disposal Facilities, Washington, D.C.

Olsen, A.L., W.W. Schulz, L.A. Burchfield, C.D. Carlson, J.L. Swanson, and M.C. Thompson, 1993,Evaluation and Selection of Aqueous-Based Technology for Partitioning Radionuclides from ICPPCalcine, WINCO-1171, Westinghouse Idaho Nuclear Company, Inc., Idaho National EngineeringLaboratory, Idaho Falls, Idaho, February.

Rice, C. M., 1997, "Citizens Advisory Board Recommendation on the High-Level Waste and FacilitiesDisposition Environmental Impact Statement," letter to J. W. Wilcynski, U.S. Department of Energy,Idaho Operations Office, Idaho Falls, Idaho, November 24.

TFA (Tanks Focus Area), 2000, Assessment of Selected Technologies for the Treatment of Idaho TankWaste and Calcine, PNNL-13268, Pacific Northwest National Laboratory, Richland, Washington,July.

TFA (Tanks Focus Area), 2001, Technical Review of the Applicability of the Studsvik, Inc. Thorsm

Process to INEEL SBW, TFA-0101, Pacific Northwest National Laboratory, Richland, Washington,March.

Trever, K. E., 1997, State of Idaho Oversight Program, Boise, Idaho, "Comments on Idaho HLW EIS," let-ter to T. L. Wichmann, U.S. Department of Energy, Idaho Operations Office, Idaho Falls, Idaho,November 24.

WINCO (Westinghouse Idaho Nuclear Company), 1994, ICPP Tank Farm System Analysis, WINCO-1192, Idaho Falls, Idaho, January.

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