Current Issues and Actions

D. G. Black

Progress has been made toward achieving full regulatory compliance at the Hanford Site. Ongoing compliance self-assessments, implementation of the Tri-Party Agreement, and public meetings continue to identify environmental compliance issues. These issues are discussed openly with the regulatory agencies and with the public to ensure that all environmental compliance issues are addressed.

Hanford Federal Facility Agreement and Consent Order (Tri-Party Agreement)

Eighty-six milestones scheduled for 1994 were completed. Included in these completed milestones were the activities below. The following were submitted to the regulators (Ecology and/or EPA):

One closure plan for Hanford treatment, storage, and disposal facilities
One remedial investigation report and plan
Five limited field investigations
Seven focused feasibility study reports
Five interim remedial measures proposed plans
200 Area validated chemical and radiological data
The 100-B Area burial ground test plan was submitted and field work was begun.

In 1994, the following activities were begun:

Pilot-scale pump and treat operations for 100-HR-3 operable unit
Analyses of core samples from single-shell tanks
Operation of the 300 Area Treated Effluent Disposal Facility.

At the end of 1994, a total of 378 enforceable Tri-Party Agreement milestones (including 1989 through 1994) had been completed on or ahead of schedule. Two milestones were missed and two were completed later than scheduled.

Hanford Site cleanup began in 1989 with the signing of the Tri-Party Agreement. The Agreement laid out a blueprint for the cleanup of the Hanford Site over a 30-year period. Over the past 5 years, the Agreement has been changed as additional information has been acquired about the cleanup problems. The last major changes occurred in January 1994, and focused primarily on the waste tanks at Hanford. As part of those changes, the agencies agreed to take a comprehensive look at the environmental restoration program and the future of unused facilities at Hanford.

A package of new negotiated changes to the Tri-Party Agreement was developed in January 1995. The new requirements will establish 65 new enforceable milestones and 32 new unenforceable target dates.

A summary of the significant changes follows.

Environmental Restoration Proposed Changes

One of the strongest messages voiced by the public over the past several years has been to focus on cleanup efforts along the Columbia River. To do this, the agencies need to redirect resources and funding to waste sites near the Columbia River. The agencies are proposing to accelerate investigations and cleanup in the 100 and 300 Areas and defer investigation of many waste sites in the 200 Area. The 200 Area waste sites are located on the central plateau, which is farther from the Columbia River than the 100 and 300 Areas. The agencies will continue to address contaminated ground water throughout the Hanford Site.

In addition, the proposed changes seek to streamline regulatory processes at Hanford. Various waste sites in a given geographic area would be cleaned up by coordinating regulatory requirements instead of using multiple processes, which is the current method.

Specific Changes Proposed:

Milestone M-13-00 requires the preparation and submittal of six remedial investigations/feasibility studies each year. The sequence and types of submittals under this milestone will be modified to better coordinate regulatory requirements and support the application of resources to the 100 and 300 National Priorities List Areas.
The 100-N Area will be used as a pilot project to ensure coordinated cleanup efforts. This cleanup will reduce current and potential near-term impacts to human health and the environment from 100-N Area facilities.
The remedial investigation/feasibility study effort will be refocused to speed progress in achieving stakeholders values, which includes protecting the Columbia River, implementing aggressive remedial actions, and making land available for other uses.
The completion of remediation of all operable units by September 2018 will be redefined to exclude the six tank farm operable units. Remediation of these six units will be completed in the year 2024. The remediation definition will be expanded to include the decontamination and decommissioning (final disposition) of all facilities and structures excluding the 100 Area reactor buildings.
The requirement for Part B RCRA permit applications and closure plans for certain RCRA treatment, storage, or disposal units will be rewritten to optimize the efficiency of Site characterization and cleanup activities.

Facility Transition Proposed Changes

When a facility will no longer be used for its original purpose, it will be brought into a safe and secure condition that will minimize maintenance and surveillance expenses. This is facility transition. Transition is the first phase of a three-step process called facility decommissioning. Phase I, transition, will include the deactivation and stabilization of plant equipment and systems. Phase II, surveillance and maintenance, will be the bridge period. Phase III, disposition, will be final closure and disposal of a facility. Any time before disposition, a facility may be transferred to another useful purpose.

Until recently, the Tri-Party Agreement primarily addressed the cleanup of contaminated waste sites. In January 1994, DOE agreed to include in the Tri-Party Agreement the disposition of key production and other large Hanford facilities. The Tri-Party signatories began negotiations in July 1994 to set schedules and milestones for cleanup at the PUREX and Uranium-TriOxide plants and the FFTF. The negotiations also addressed the clean out of the Plutonium Finishing Plant and the 324 Building radiochemical engineering cells and vault tanks.

A tentative agreement between DOE, EPA, and Ecology to proceed with facility transition and cleanup actions under the Tri-Party Agreement was reached in January 1995 for all facilities except those in the 324 Building, which are still being negotiated.

Specific Changes Proposed:

Establish a safe and environmentally secure configuration for the PUREX and Uranium-TriOxide plants to achieve necessary preclosure actions and transition the facilities to the surveillance and maintenance phase.
Establish a safe and environmentally secure configuration for the Fast Flux Test Facility to achieve necessary preclosure actions and transition the facilities to the surveillance and maintenance phase.
Stabilize the previous process areas within the Plutonium Finishing Plant, including the Plutonium Reclamation Facility and Remote Mechanical "C" Line. This will establish a safe and environmentally secure configuration in these areas of the facility.
Revise the necessary permitting, closure, or preclosure actions related to transition efforts for the PUREX Plant, FFTF, and Plutonium Finishing Plant.

Other Proposed Modifications to the Tri-Party Agreement

Language will be added in Section 10 of the Tri-Party Agreement Action Plan that commits DOE to submit key documents to the involved Native American tribes at the same time as they are submitted to Ecology and EPA. New language is proposed in Sections 3, 5, 6, 7, and 9 of the Action Plan to support integration of closure, past practice, and facility decommissioning activities. A number of terms will be added and other definitions modified under Appendix A, Definition of Terms.

A new section, 14, will be added to the Action Plan to detail the facility decommissioning process. It will include planning and action paths for all three decommissioning phases and will address regulatory integration.

Hanford Summit II

More than 700 people attended Hanford Summit II, which was held in Pasco, Washington in June 1994. The day-long event was a follow-up to the first Hanford Summit held in September 1993. The Secretary of Energy's response to the Summit II initiatives was issued after extensive consultation and dialogue with Summit participants.

Secretary of Energy Hazel O'Leary endorsed 26 Hanford Summit II initiatives to facilitate cleanup of the Hanford Site. The initiatives cover such areas as regulatory reform, openness, training, public involvement, and economic and technology development. The initiatives are also intended to create a sustainable economic future for the Mid-Columbia region. The centerpiece of the Secretary's endorsement is a "demonstration zone" to be established by the DOE, the EPA, and Ecology to integrate the various recommendations. Secretary O'Leary said that the demonstration zone "will help display new ideas, new ways of doing business, and new possibilities" for the nation's largest nuclear waste cleanup effort. Noting that the demonstration zone complements Hanford's designation as a "laboratory" for reinventing government, the Secretary encouraged the Richland Operations Office to begin implementation as soon as possible. Ideas proven to make cleanup better, faster, safer, and more cost-effective would be applied across the Hanford Site, throughout the DOE complex, and in some cases, to the commercial marketplace.

Other initiatives supported by the Secretary of Energy include:

Streamlining regulations without compromising public safety, public involvement, or legal intent
Maximizing public access to Hanford information
Expediting declassification and release of documents from past DOE operations
Continuing support of employee rights initiatives
Working to increase stakeholder participation in the Hanford decision-making process
Demonstrating and using new technologies
Designing and constructing the Hazardous Materials Management and Emergency Response Center, subject to Congressional line item funding
Developing partnerships and other innovative practices. For example, in addition to a recent $987,000 grant for an Entrepreneurship/Small Business Partnership, DOE will establish an Environmental Business Enterprise Center and an Entrepreneurs Advisory Board, as well as specific relationships for technology transfer. DOE endorsed school-to-work partnerships and other education initiatives, subject to funding by the states or private sector.

Hanford Advisory Board

The Hanford Advisory Board was created in January 1994 to advise DOE on major Hanford cleanup policy questions. The Board is one of 15 such advisory groups created by DOE at weapons production cleanup sites across the complex. The Board comprises 33 members that represent a broad cross section of interests: environmental, economic development, tribes and other governments, and the public. Each board member has at least one alternate. Merilyn Reeves, of Amity, Oregon, is the chairperson.

The Board has six committees: 1) Dollars and Sense, which deals with DOE budget issues, 2) Public Involvement, 3) Health, Safety, and Waste Management, 4) Environmental Restoration, 5) Cultural and Socioeconomic Impacts, and 6) the Board's internal budget committee. Committees study issues and develop policy recommendations for Board action.

Early on, the Board adopted and affirmed values developed by two predecessor groups: The Hanford Future Site Use Working Group and the Tank Waste Task Force. The groups advised DOE and Hanford Site cleanup regulators to 1) protect the Columbia River and 2) get on with cleanup. Board members have submitted advice to DOE on a range of issues including budget priorities, environmental restoration, ground-water monitoring and remediation, releases to the Columbia River via the N Springs, worker health and safety, local economic transition issues, and public involvement.

Environmental and Molecular Science Laboratory

In 1994, ground was broken for the construction of the Environmental and Molecular Science Laboratory (EMSL). When finished, the

(

) EMSL will accommodate up to 270 permanent staff, visiting scientists, postdoctoral researchers, and students who will work to develop the science and technology needed to clean up environmental problems at government and industrial sites across the country. Research conducted at this national user facility is also expected to lead to advancements in energy, new materials, health and medicine, and agriculture.

100-K Area Fuel Storage Basins

In February 1994, the Spent Nuclear Fuel Project was established. The project mission is to provide safe, economic, and environmentally sound management of Hanford spent nuclear fuel in a manner that stages it to final disposition.

The Hanford Site spent nuclear fuel inventory constitutes about 80% of the inventory currently stored in the DOE complex. The majority of Hanford's inventory consists of about 2,100 metric tons (2,300 tons) of irradiated N Reactor fuel stored in the 105 K-East and 105 K-West Fuel Storage Basins.

In 1994, working closely with stakeholders and local Native American tribes, decisions were made that support a strategy for near-term and interim fuel storage of the K Basin inventory. This strategy supports removal of the fuel and sludge from the K Basins before December 2002, as stipulated in the Tri-Party Agreement. The Spent Nuclear Fuel Project is now in the process of implementing the strategy for acceleration of fuel and sludge removal from the K Basins.

A project was started in 1994 to install isolation barriers in the basins. These barriers will isolate the spent fuel from a vulnerable construction joint in the discharge chute of the basins to prevent the shielding water from draining from the basins in the event of a major earthquake and releasing contaminated water to the ground and radioactive contamination to the air. The project is expected to be complete in April 1995.

Plutonium Uranium Extraction and Uranium-TriOxide Plants

The function of the PUREX Plant was to treat irradiated reactor fuel elements to recover uranium and plutonium-bearing solutions. In December 1992, DOE Headquarters directed the Richland Operations Office to proceed with deactivation of the PUREX Plant. In September 1993, PUREX Plant management submitted a project management plan to the Richland Operations Office for transition of the PUREX Plant to a minimum surveillance mode, awaiting final decontamination and decommissioning. The transition is expected to take approximately 5 years.

The Uranium-TriOxide Plant completed its final campaign in June 1993. During this campaign, 757,000 L (200,000 gal) of liquid uranyl nitrate hexahydrate that had been in storage at the PUREX and Uranium-TriOxide Plants were converted to approximately 199 metric tons (219 tons) of uranium-oxide powder. The powder is being stored at the plant pending transfer to a vendor. In July 1993, 378,000 L (100,000 gal) of recovered nitric acid were shipped back to the PUREX Plant. Flushing of residual process solutions from the Uranium-TriOxide Plant piping and tanks was completed as part of the transition to deactivation. This transition is expected to be complete by June 1995.

Plutonium Finishing Plant

The function of the Plutonium Finishing Plant (PFP) was to extract plutonium from plutonium-bearing chemical solutions and convert it into metal and oxide. The PFP was first used in 1951, and the production processes operated until May 1989. Although processing has ended, plutonium-bearing materials remain in the plant.

In July 1993, DOE started discussions with citizens groups about plans to operate the PFP processes. DOE intended to run processes within the PFP, the Plutonium Reclamation Facility, and portions of the Remote Mechanical "C" Line to stabilize some plutonium-bearing materials. The Plutonium Reclamation Facility would have purified plutonium solutions that would have been converted to plutonium dioxide in the Remote Mechanical "C" Line. That operation would have involved release of 28-37 kg (60-80 lb) per day of carbon tetrachloride to the air. DOE initiated efforts to prepare an environmental assessment to evaluate the action.

A series of public meetings regarding the proposed environmental assessment resulted in significant public comment, demands for an EIS, and consideration of alternate methods of plutonium stabilization. Based on these comments, DOE began preparing an EIS and approved a proposal to initiate several interim actions to reduce safety risks in the facility while waiting for the EIS. These interim actions were selected because they do not result in the production of a purified plutonium product, do not release carbon tetrachloride to the air or discharge liquids to the ground, and create a much smaller amount of waste to be sent to Hanford's double-shell tanks. Several of the interim actions have already been completed including downloading solutions from the Plutonium Reclamation Facility for disposal, decontaminating portions of the PFP, and removing plutonium-contaminated ducts and piping from the 232-Z incinerator building. Two interim actions are ongoing:

Sludge Stabilization--Much of the plutonium-bearing sludge stored in PFP gloveboxes can be heated and converted to an impure stable solid and stored safely in PFP's vaults. An environmental assessment was prepared to review potential impacts from this operation. The process uses two new small laboratory furnaces to heat the sludge to about 1,0005C (1,8005F) over several hours. This process converts the plutonium compounds to plutonium oxide and drives off the moisture, resulting in a stable oxide powder. Other chemicals not driven off by the heating process remain as stable solids. Processing was initiated in November 1994.
Solutions in Storage Containers known as "10-Ls"--Some storage containers contain plutonium-bearing chloride and fluoride solutions that pose special corrosion concerns. These solutions will be put in new, safe storage containers. Some or all of the solutions will be used in the development laboratory to test future processing options to support the EIS. Downloading these solutions is expected to start in early 1995.

Waste Vitrification

Approximately

(

) of radioactive and hazardous wastes accumulated from over 40 years of plutonium production operations are stored in 149 underground single-shell tanks and 28 underground double-shell tanks. Current plans are to pretreat the waste and then solidify it into a glass matrix. Pretreatment will separate the waste into a low-radioactivity fraction, and a high-radioactivity and transuranic fraction. The bulk of the radionuclides will then be in the high-radioactivity and transuranic fraction. In separate facilities, both fractions will be vitrified, a process that will destroy or extract organic constituents, neutralize or deactivate dangerous waste characteristics, and immobilize toxic metals. The vitrified low-radioactivity fraction will be disposed of in a near-surface facility on the Hanford Site in a retrievable form. The vitrified high-radioactivity fraction will be stored onsite until a geologic repository is available offsite for permanent disposal. Tri-Party Agreement milestones specify December 2028 for completion of pretreatment and vitrification of the tank wastes.

Waste Receiving and Processing Facility

During 1994, construction was started on the first major solid waste processing facility associated with cleanup of the Hanford Site. Scheduled to begin operations in March 1997, the Waste Receiving and Processing Facility Module 1 will be staffed to analyze, and prepare for disposal, drums and boxes of waste resulting from plutonium operations at Hanford. The Tri-Party Agreement mandates construction and operation of this module. Wastes destined for this module include Hanford's current inventory of more than 37,000 drums of stored waste, as well as materials generated by future site cleanup activities. Consisting primarily of clothing, gloves, face masks, small tools, and dirt suspected of being contaminated with plutonium, wastes in the

(55 gal) drums may also contain other radioactive materials and hazardous components. Some of the materials processed will qualify as low-level waste suitable for disposal directly at the Hanford Site. The remaining wastes will be certified and packaged for eventual shipment to the Waste Isolation Pilot Plant in New Mexico. Materials requiring further processing to meet disposal criteria will be retained at Hanford pending treatment.

The () facility will begin operations in 1997 near the Central Waste Complex in the 200-West Area. The 200-West Area is located on the central plateau that the public and Tri-Party agencies have designated for waste processing and long-term waste storage. The facility is designed to process 6,800 drums of waste annually for 30 years.

Waste Tank Safety Issues

The Waste Tank Safety Program (WTSP) was established in 1990 to address the hazards associated with storage of radioactive mixed waste in the 177 large underground storage tanks at the Hanford Site. The WTSP serves as the focal point for identification and resolution of selected high-priority waste tank safety issues, with resolution being completed in priority order. Tanks with the highest risk will be evaluated and mitigated first. The tasks to resolve the safety issue are planned and implemented in the following logic sequences: 1) evaluate and define the associated safety issue, 2) identify and close any associated unreviewed safety question (DOE 1991), 3) mitigate any hazardous condition to ensure safe storage of the waste, 4) store and monitor waste conditions, and 5) resolve the respective safety issue. Each of these steps has supporting functions of some combination of monitoring, mathematical analyses, laboratory studies, and in-tank sampling or testing. The path followed is ultimately a function of whether the waste requires treatment and where the treatment will take place.

The WTSP is currently focusing on resolution of ferrocyanide, flammable gas, organic, high-heat, noxious vapor, and criticality safety issues as described below. The tanks of concern are placed on a Watch List by safety issue. At the end of 1994, there were 54 tanks on the Watch List: 18 ferrocyanide tanks, 25 flammable gas tanks, 20 organic tanks, and one high-heat tank. Some of the tanks are included under more than one category. These tanks were identified in accordance with Public Law 101-510, Section 3137 (1990), Safety Measures for Waste Tanks at Hanford Nuclear Reservation (the Wyden Amendment).

Watch List Tanks

In 1990, all Hanford Site high-level waste tanks were evaluated and organized into four categories of watch list tanks to ensure increased attention and monitoring. Tanks were classified as ferrocyanide, flammable gas, high-heat, and organic watch list tanks. Two other safety concerns that involve some or all of the tanks include criticality and noxious vapor safety issues.

Ferrocyanide. The ferrocyanide safety issue involves the potential for uncontrolled exothermic reactions of ferrocyanide and nitrate/nitrite mixtures (Postma et al. 1994a). Laboratory studies show that temperatures must exceed 2505C for a reaction to propagate. The hottest ferrocyanide tank temperature is 5305C and decreasing. In October 1990, an unreviewed safety question was declared because safety was not adequately defined by then existing analyses. However, the unreviewed safety question was closed by DOE in March 1994, as a result of significant knowledge gained from simulant studies, conservative theoretical analyses, and analyses of actual waste samples that allowed bounding safety criteria to be defined and applied to each tank (Postma et al. 1994a). Of the original 24 ferrocyanide tanks, 18 are now on the watch list. Four were removed in 1993 and two were removed in 1994. The remaining tanks will be taken off the watch list as core samples are obtained and analytical analyses confirm that the ferrocyanide has decreased in fuel content from hydrolysis and radiolysis ("aging") to acceptable low levels (Lilga et al. 1994, Meacham et al. 1995).

Flammable Gas. The flammable gas tanks safety issue involves the potential release of flammable gases from wastes in selected tanks. In prior years, work controls were instituted to prevent introduction of spark sources in these tanks, and evaluations were completed to ensure that installed equipment was intrinsically safe. The worst-case tank, 241-SY-101, was successfully mitigated in 1994 with the insertion of a mixing pump. The pump is operated up to three times a week to mix the waste and release gases that accumulate in the waste. Hydrogen monitors are being installed on all 25 flammable gas tanks. These monitors, called standard hydrogen monitoring systems, consist of a cabinet equipped with piping and instrumentation that support an on-line hydrogen detector and a "grab sampler." Documentation to close the unreviewed safety question in the 241-SY tank farm is being prepared and will be submitted to DOE early in 1995 for closure action.

High-Heat Tank. This safety issue concerns tank 241-C-106, a single-shell tank that requires water additions and forced ventilation for evaporative cooling. Without the water additions, which would be discontinued in the event of a tank leak, the tank could exceed structural temperature limits, resulting in potential concrete degradation and possible tank collapse. This tank is on an accelerated program for early retrieval and transfer of waste to a double-shell tank. Double-shell tanks are designed to handle heat-bearing materials better than single-shell tanks. A process test and considerable thermal analyses were completed in 1994 on tank 241-C-106 to evaluate alternative cooling approaches (Eyler 1994, Thurgood et al. 1995). The studies concluded that the tank could be adequately cooled using refrigerated air chillers.

Organic Tanks. The organic tanks safety issue involves the potential for uncontrolled exothermic reactions of organic chemicals and nitrates/nitrites and for vapors from semivolatile organics entrained in the waste to exceed the flammability limits. Recent laboratory tests showed that fuel concentrations and temperatures required to support propagating exothermic reactions are comparable to those for ferrocyanide. In addition, moisture levels above 20% will prevent reactions from propagating regardless of fuel concentrations.

Work controls were implemented in 1990 to prevent the introduction of ignition sources to these tanks. In May 1994, vapor sampling and safety analyses were completed that provided the technical basis for closing the unreviewed safety question on the flammability of the floating organic layer in tank 241-C-103 (Postma et al. 1994b). Ten tanks that contained organic complexants were added to the organic tanks watch list following a review of sampling data and waste transfer records (Hanlon 1994).

Other work indicates that aging processes have also destroyed or significantly lowered the energy content of the organic tanks (Ashby et al. 1994). In addition, work by Barney (1994) shows that the more energetic complexants and the primary degradation products of tributyl phosphate (TBP) are water soluble in saturated nitrate-nitrite salt solutions. Thus, a high percentage of organic chemicals were removed from the single-shell tanks when their pumpable liquid supernatant was pumped out as part of the interim stabilization process for the single-shell tanks.

Criticality. The unreviewed safety question on the potential for criticality in the high-level waste tanks was closed in 1994 by completing additional analyses, strengthening tank criticality prevention controls, and improving administrative procedures and training (Braun and Szendre 1994). The analyses showed that criticality is highly unlikely during storage. All of the single- and double-shell tanks at the Hanford Site contain sufficient neutron absorbers to ensure safe storage; however, additional sampling and controls will be required for retrieval and pretreatment-related activities.

Noxious Vapor. Some of the Hanford Site tanks contain chemicals that release toxic vapors to the environment. These vapors pose a potential health risk to Hanford Site employees who work in the tank farms. The safety issue stems from an insufficient understanding of the causes of reported exposures of personnel to unacceptable levels of noxious vapors and the concern that, until the vapors in the tanks are well characterized, the risks to worker health and safety cannot be determined or controlled (Osborne 1994, Huckaby and Babad 1994). In prior years, worker protection controls were instituted to prevent worker exposures, and a program was implemented for routine workspace air monitoring and personnel dosimetry.

In-tank vapor sampling equipment was developed and tested in 1994. Two methods are now used to collect vapor samples from the waste tanks (Huckaby 1994). The primary method involves drawing air, gases, and vapors out of the waste tanks. This method was designed to collect representative samples from warm, moist tanks, even if a fog exists in the tank headspace. A second method employs in situ sampling. Rather than transferring the air, gases, and vapors to be sampled to a remote location, the sampling devices themselves (specifically, sorbent traps) are lowered into the tank headspace. Through 1994, 18 high-level waste tanks were vapor sampled using these two methods.

Waste Tank Status

The status of the 177 waste tanks as of December 1994 is reported in WHC-EP-0182-81, Waste Tank Summary for Month Ending December 31, 1994 (Hanlon 1995). This report is published monthly; the December report provided the following:

Number of waste tanks
- 149 single-shell tanks
- 28 double-shell tanks
Number of tanks listed as "assumed leaker" tanks
- 67 single-shell tanks
- 0 double-shell tanks
Chronology of single-shell tank leaks
- 1956: First tank reported as suspected of leaking (Tank 241-U-104)
- 1973: Largest estimated leak reported (Tank 241-T-106; 435,000 L [115,000 gal])
- 1988: Tanks 241-AX-102, -C-201, -C-202, -C-204, and -SX-104 reported as confirmed leakers
- 1992: Latest tank (241-T-101) added to assumed leaker list, bringing total to 67 single-shell tanks
- 1994: Tank 241-T-111 declared an assumed re-leaker
Number of ferrocyanide tanks on watch list
- 18 single-shell tanks(a) (two tanks [241-BX-102 and -BX-106] were removed from the watch list in December 1994)
Number of flammable gas tanks on watch list
- 19 single-shell tanks(b)
- 6 double-shell tanks
Number of organic tanks on watch list
- 20 single-shell tanks

So far, 106 single-shell tanks have been stabilized, with the program to be completed in 2000. At the end of 1994, 98 single-shell tanks had intrusion prevention devices completed, and 51 single-shell tanks were partial interim isolated.

The total estimated volume of radioactive waste leakage from single-shell tanks is 2,270,000 to 3,410,000 L (600,000 to 900,000 gal).

During 1994, two single-shell tanks identified as assumed re-leaker tanks were pumped as discussed below.

Tank 241-BX-111. This tank was declared an assumed re-leaker in April 1993. Pumping of the tank commenced in October 1993, and was completed in April 1994. Pumping was restarted in May to remove additional pumpable liquid after review of in-tank photos. A total of 436,000 L (115,000 gal) were pumped from the tank in 1994 with completion of interim stabilization expected in 1995.

Tank 241-T-111. The surface level showed a steady decrease after the automatic waste surface level measurement device was repaired in August 1993. The surface level measurement after the repair was 4.11 m (13.5 ft) and continued to decrease to 4.09 m (13.4 ft) through January 1994. An off-normal occurrence report was issued in February 1994, and the tank was declared an assumed re-leaker. Pumping began in May 1994, completing a Tri-Party Agreement milestone for the start of emergency pumping. A total of 29,900 L (7,900 gal) was pumped from the tank in 1994 with completion of interim stabilization expected in 1995.

During 1994, pumping occurred in eight single-shell tanks. In addition to the two tanks listed above, tanks 241-BX-110, 241-BY-102, 241-BY-109, 241-C-102, 241-C-107, and 241-C-110 were also pumped. In 1994, the total liquid volume removed from the eight tanks was 490,000 L (129,000 gal).

Pollution Prevention Program

The Hanford Site Pollution Prevention Program (formerly Waste Minimization) is an organized, comprehensive, and continual effort to systematically reduce the quantity and toxicity of hazardous, radioactive, mixed, and sanitary wastes; conserve resources and energy; reduce hazardous substance use; and prevent or minimize pollutant releases to all environmental media from all operations and Site cleanup activities.

It is designed to satisfy DOE requirements, recent presidential executive orders, and other state and federal regulations and requirements. In accordance with sound environmental management, preventing pollution through source reduction is the first priority in the Hanford Site's Pollution Prevention Program, and the second priority is environmentally safe recycling. Waste treatment to reduce the quantity, toxicity, or mobility (or a combination of these) will be considered only when prevention or recycling are not possible or practical. Environmentally safe disposal is the last option.

By incorporating this hierarchy into Hanford environmental management activities, the following successes in minimizing waste were accomplished:

Hanford Site pollution prevention efforts in 1994 helped to prevent the generation of () of radioactive mixed waste, 133 metric tons (147 tons) of RCRA waste, and 17,700 metric tons (19,500 tons) of sanitary waste with a cost savings of approximately $4 million.
Two separate modifications in liquid scintillation measurement techniques accounted for a () reduction in radioactive mixed waste. The use of a microscintillation counter allowed a 99% reduction in materials used for some sample measurements, and the substitution of a nonregulated scintillation cocktail reduced the waste classification from radioactive mixed to low-level radioactive waste.
The Hazardous Materials Reduction Initiative avoided the purchase of 900 kg (2000 lb) of hazardous products, recycled more than 10 metric tons (11 tons) of surplus materials, and eliminated the use of more than 2.5 metric tons (1.7 tons) of products containing Class I ozone depleting substances.
During 1994, the Hanford Site recycled offsite 610 metric tons (670 tons) of office paper; 1,800 metric tons (2000 tons) of scrap metal; 59 metric tons (65 tons) of lead; 9,500 toner cartridges for computer printers, and 8,300 L (2200 gal) and 50 metric tons (55 tons) of surplus chemical products.

Besides these sitewide programs, numerous generator-specific initiatives were put into place. These initiatives are specific to a particular area or process and, in most cases, were thought of and implemented by the onsite people who handle the waste daily. To celebrate these pollution prevention activities, the "Pollution Prevention Accomplishments Book" (Betsch 1994) was published in October covering activities in 1994. This book outlines 33 significant initiatives that were implemented and are now in use at locations throughout the Hanford Site. A few of these initiatives are:

Replaced alkaline and NiCd batteries with rechargeable alkaline batteries
Avoided mixed waste by diverting rainwater away from areas where it would become contaminated
Eliminated custodial services' use of all hazardous cleaning products, thereby avoiding the resulting regulated waste
Recycled radiological signs into plastic pipe.

These activities, plus 29 others, resulted in significant reductions in hazardous waste, radioactive waste, and solid sanitary waste, and promoted resource conservation and technology transfer. Most of the ideas were simple improvements in processes enacted by changing the methods of remediation or disposal. The focus was on generating less waste in the first place and reusing or recycling the waste that was generated.

Although not all the waste savings from these generator-specific ideas were quantifiable, those that were resulted in the following reductions:

8,730 million L (2,310 million gal) of bulk liquid
() of solid waste
kilojoules ( kilowatt-hours) of energy.

These reductions are estimated for all of 1994. In addition to these and the nonquantifiable waste reductions, numerous other benefits were realized, including significant cost savings of more than $43 million, reduced worker exposure, improved public relations, and an overall improvement in quality of operations.

242-A Evaporator Status

The 242-A Evaporator was restarted as scheduled in April 1994 and completed two waste reduction campaigns. Each campaign processed the low-level mixed waste contents of six double-shell tanks. The evaporator process resulted in an average waste reduction of 85% in tank waste volume. The process condensate from the evaporator operation is stored in the Liquid Effluent Retention Facility and is awaiting final disposal through the 200 Area Effluent Treatment Facility. Future campaigns have been scheduled for 1995 and 1996.

Liquid Effluent Activities

Liquid Effluent Retention Facility

The start-up activities for the Liquid Effluent Retention Facility were completed on time to support the 242-A Evaporator campaigns in 1994. As a result of these campaigns, 25,000,000 L (6,600,000 gal) of evaporator process condensate are stored in the Liquid Effluent Retention Basins awaiting final processing through the 200 Area Effluent Treatment Facility. The Liquid Effluent Retention Facilities consist of three separate

(

) storage basins (surface impoundments). Two are used for normal operation, and the third is used as a contingency in the event a leak should develop in an operational basin.

Ecology requested that the 242-A Evaporator, the Liquid Effluent Retention Facility, and the 200 Area Effluent Treatment Facility RCRA Part B permit applications be integrated into one permit application. The Richland Operations Office concurred with Ecology's request.

200 Area Effluent Treatment Facility, Project C-018H

The 242-A Evaporator/PUREX Plant Process Condensate Treatment Facility (200 Area Effluent Treatment Facility) is being constructed to provide effluent treatment and disposal capability required to restart the 242-A Evaporator. The facility will provide for effluent collection, a treatment system to reduce the concentration of radioactive and hazardous waste constituents in the effluent streams to acceptable levels, tanks to allow verification of treated effluent characteristics before discharge, and a state-approved land disposal structure for effluents.

Secondary waste generated by the treatment facility will be concentrated and packaged to meet state requirements for storage and/or disposal of solid waste.

Acceptance testing of the facility began in late 1994 and is expected to be completed in March 1995. The facility is expected to begin operations in October 1995. All regulatory permit applications required for the facility and disposal site have been submitted to the regulators as required in the Tri-Party Agreement and Ecology Liquid Effluent Consent Order (No. DE 91NM-177). Because process condensate was not available for waste characterization, the Federal Delisting Petition, the State Waste-water Discharge Permit, and the RCRA Dangerous Waste Permit applications were based on a surrogate solution. This surrogate was developed and tested under pilot-scale conditions to determine a list of constituents that the facility can successfully treat.

200 Area Treated Effluent Disposal Facility, Project W-049H

The 200 Area Treated Effluent Disposal Facility will be a permitted system for the collection, sampling, and disposal of 13 effluent streams in the 200-East and 200-West Areas. Based on data derived in preparing the Washington Administrative Code 173-240-130 Engineering Report required by the State Waste-Water Discharge Permit program, it has been determined that the best available technology and all known and reasonable methods of prevention, control, and treatment will be implemented at each waste-water generating facility. Effluents will meet the requirements of best available technology before being discharged to the collection and disposal system. The construction of the collection system began in April 1993 and is now complete: final testing of the system is ongoing. The disposal facility design is complete.

300 Area Treated Effluent Disposal Facility

The 300 Area Treated Effluent Disposal Facility was completed and in operation in December 1994, ahead of schedule and under budget. It satisfied Tri-Party Agreement milestone M-17-09 for ceasing the discharge of untreated 300 Area process sewer effluent to the soil column at the 300 Area Process Trenches. A National Pollutant Discharge Elimination System permit has been issued by EPA Region 10 that allows the facility to discharge treated effluents to the Columbia River. The permit contains a reopener clause such that, after one year of operation, permit conditions may be renegotiated.

The 300 Area Treated Effluent Disposal Facility has a 1200 L/min (320 gal/min) treatment capacity. The facility, operated 24 hrs, is largely computer automated, with the capability for full manual operation.

After its collection, the process waste water is treated for metals, suspended solids, residual mercury and heavy metals, organics, nitrite, sulfides, cyanide, and pH before discharge via a subsurface river diffuser in the Columbia River near Johnson Island. Sludge from the process is packaged in drums, and disposed of in a landfill.

340 Facility

The 340 Facility collects radionuclides and mixed wastes from the 300 Area for transportation to tank farms via rail car. Radioactive mixed liquid wastes that are collected originate at Pacific Northwest National Laboratories and are critical to tank waste safety, tank characterization, and Site remediation. The 340 Facility tanks are currently operated as less than 90-day accumulation tanks under the requirements of the Dangerous Waste Regulations, WAC 173-303.

Phase II Effluent Streams

As part of the October 1991 negotiations to supplement the Tri-Party Agreement and to create the Consent Order (No. DE 91NM-177), the Richland Operations Office committed by October 1997, to implement the best available technology and all known and reasonable methods of prevention, control, and treatment (BAT/AKART) for the remaining nine Phase II streams, and to permit the streams under the WAC 173-216 State Waste-Water Discharge Permit Program. A WAC 173-240-130 Engineering Report was submitted to Ecology in September 1992.

One stream, the 241-AY/AZ Steam Condensate, is discharged to the Tank Farms and is not planned for discharge to the ground. Another stream, the 183-D Filter Backwash, was eliminated in June 1994. A State Waste-Water Discharge Permit application for 400 Area Secondary Cooling Water was submitted to Ecology in December 1992. The permit is expected to be issued in 1995.

The scope of the BAT/AKART for the 200 Area Phase II Streams is to eliminate, minimize, or treat effluents currently being discharged to the 216-B-3 Expansion Ponds. The facilities involved include the 241-A Tank, the 242-A Evaporator, the 244-AR Vault, B Plant, and the 284-E Powerhouse. The conceptual design report was completed in June 1993. Advanced conceptual design was completed in January 1995, with definitive design starting in February 1995. A State Waste-Water Discharge Permit application for these streams was submitted to Ecology in December 1993.

Miscellaneous Streams

In accordance with Ecology Consent Order (No. DE 91NM-177), the DOE Richland Operations Office committed to submit State Waste-Water Discharge Permit applications for eleven miscellaneous streams. A decision was made to instead obtain a National Pollutant Discharge Elimination System permit for two of these streams for discharge to the Columbia River (300 Area Powerhouse Ash Waste Water, and Filter Backwash). Other changes included the decision to connect the 300 Area Sanitary Sewer to the City of Richland Publically Owned Treatment Works, and the decision to connect the 234-5Z Ventilation Steam Condensate/Dry Air Compressor Cooling Water to the 200 Area Treated Effluent Disposal Facility. The 209-E Building Steam Condensate stream was eliminated. State Waste-Water Discharge Permit applications were submitted to Ecology in June 1994 for the remaining six miscellaneous streams.

The DOE Richland Operations Office also agreed to inventory the remaining miscellaneous streams and to develop a plan and schedule for the disposition of those streams. An inventory of all effluent streams was developed that identified more than 500 small discharges. These discharges were evaluated against criteria developed to determine if they had any potential to cause harm to the environment or ground water. This inventory and these criteria were used to develop the final overall plan and schedule for regulatory compliance, which was submitted to Ecology in December 1994.

Submarine Reactor Compartments

Eight defueled submarine reactor compartment disposal packages were received and placed in Trench 94 in the 200-East Area during 1994. This brings the total number received to 43.

The reactor compartment disposal packages are being regulated by Ecology as dangerous waste because of the presence of lead used as shielding and by EPA because of the presence of small amounts of PCBs bound within the matrix of nonmetallic materials such as thermal insulation, electrical cables, and some synthetic rubber items.

Revegetation

The U.S. Army Corps of Engineers is currently working with the Natural Resources Trustee Council, PNL, and the Nature Conservancy on the preparation of a habitat/revegetation plan for the Hanford Site. Revegetation of selected sites is expected to occur in 1995.

Self-Assessments

During 1994, 249 environmental compliance self-assessments were completed by WHC. Approximately a third of these self-assessments identified compliance deficiencies such as deficiencies with hazardous waste management and effluent monitoring. Corrective actions for each of these deficiencies were also identified for completion.

PNL completed 36 environmental compliance self-assessments in 1994. Unsatisfactory conditions were identified in 14 of the assessments. The conditions all dealt with hazardous waste management issues. The majority of the conditions have been rectified, and corrective action is in progress for the remainder.

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(a) Two ferrocyanide tanks are also listed as organic tanks.

(b) Eight flammable gas tanks are also listed as organic tanks.