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Hanford’s Leaking �High-Level Nuclear Waste Tank B-109:�Worse than announced…�What can and should be done?

Presented by Heart of America Northwest

September 20, 2021

Prepared by Heart of America Northwest Tribal & Environmental Law Externs

Mary Bent, Alex Goldman, Kylee McGill, Henry Mueting (Seattle U Law JD candidates); Dirk Dunning, HoANW Board; Gerry Pollet, JD; Executive Director & Adjunct Professor of Law

This product is funded through a Public Participation Grant from the Department of Ecology. The content was reviewed for grant consistency but is not necessarily endorsed by the agency.

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Hanford meetings �should start with a �land acknowledgement

Treaties of 1855 RESERVED the rights to the lands and resources which USDOE has contaminated:

“the exclusive right of taking fish in the streams running through and bordering said reservation

is hereby secured to said Indians, and at all other usual and accustomed stations in common with citizens of the United States, and of erecting suitable buildings for curing the same; the privilege of hunting, gathering roots and berries and pasturing their stock on unclaimed lands in common with citizens, is also secured to them” (Umatilla, Cayuse and Walla Walla)

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Agenda

B-109 Background and Current Status
USDOE’s publicly statements that it does not intend to take action to address B-109 and mitigate risks
DOE ignored its own monitoring data showing leak and for calculating amount leaked – slide 10
DOE did not share with public Gamma borehole logging showing leak very serious – slide 17
USDOE Approach is Unacceptable to Stakeholders and Native American Tribes – slide 19
Regulatory Framework Establishes Mitigation Requirements – slide 20
A proposed, workable approach to mitigate B-109 harm and remove liquid – slide 23

In-tank waste retrieval, pretreatment, post treatment and off-site disposal
Regulatory Approach
Cost, Schedule and Benefits

Proposed Policy Level Hanford Advisory Board (HAB) advice being considered this week – slide 37
What Should be Done? What Can You Do? Slide 39
Questions/Answers
Updated: slides 45, 46 respond to USDOE claims made at Hanford Advisory Board meeting Sept. 21, 2021
Backup slides on In-Tank Pretreatment System Slides 40 on

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April 29, 2021 USDOE announces that another High-Level Nuclear Waste Tank (B-109) is leaking

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Leaking Tank B-109

123,000 gallons of High-Level Nuclear Waste with an estimated 15,000 of pumpable liquids

USDOE says: “no increased health or safety risk,” so NO effort to remove waste to stop the leak

USDOE erroneously says pumping and treating groundwater after the contamination moves through the soil column will prevent any harm.
Contamination likely to start reaching groundwater in around 25 years, and would keep contaminating it for thousands of years

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The text below is from USDOE’s official report of the leak from Tank B-109 and public statements.

URGENT - Action Needed To Prevent Further Leaks from Tank B-109

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Washington Governor Inslee had announced a “Zero Tolerance Policy” for Leaks, but NO Action Planned More Than 2 Years After the Leak Was Obvious

8 years ago, when the US Department of Energy admitted other tanks were leaking, Governor Inslee said: “Washington state has a zero tolerance policy on radioactive leakage. We will not tolerate any leaks of this material into the environment.”

B-109 much closer to Columbia River than tanks in 200 West (T Farm) and leaking more

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Now, another tank is leaking – 8 years ago, Governor Inslee announced a “Zero Tolerance” policy for leaking tanks at Hanford

Leaks from Tank B-109 will begin to reach groundwater in as little as 20-25 years. The groundwater flows to the Columbia River. Tank leaks will recontaminate groundwater and the River over and over for thousands of years. Where’s the urgency and action from Washington’s “Zero Tolerance Policy”?
USDOE’s Brian Vance: USDOE not planning to do anything but let the tank leak – called it “small” compared to past dumping
Federal and state hazardous waste laws require emptying a leaking tank immediately or as soon as feasible*
Resources essential to culture and health from groundwater to plants to River, which are protected by Treaty rights, are irreversibly harmed.

Bullet 1 recontaminate groundwater shown by TCWMEIS for numerous contaminants in soil in tank farms.

Mary and Kylee:

At a public meeting in June DOE was asked directly about their approach to address the leaking B-109 tank

ORP Program Manager and Deputy Program Manager stated:

The leak is minor
B farm is highly contaminated, this leak is not adding significantly to the contaminated soil inventory
There is no significant risk to human health or the environment
If it gets to the ground water, DOE will use pump and treat to remediate ground water contamination

Ecology representative did not push back and stated Ecology was waiting for DOE’s action plan

* . “A tank system… from which there has been a leak or spill… must be removed from service immediately.” WAC 173-303-640(7) (2021). The provision goes on, “[i]f the release was from the tank system, the owner/operator must, within twenty-four hours after detection of the leak or, if the owner/operator demonstrates that it is not possible, at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment.” WAC173-303-640(7)(b)(i).

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With a Zero Tolerance Policy for Leaks from High-Level Nuclear Waste Tanks, What Action?

April 29, 2021: USDOE announced that another Single Shell Tank is leaking. B-109 is in 200 East. USDOE estimated it is leaking about 1,300 gallons a year – more than the tanks in 200 West.
B-109 and 200 East are much closer to the Columbia River.
Contamination may reach groundwater in 20-25 years, and flow to the River. It would continue to contaminate the groundwter flowing to the River for 10,000 years.

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The precipitous drop in Interstitial liquid level from December 2018 to March 2019 required USDOE to report the evidence of this leak immediately to EPA & Ecology and removal of waste. Loss of 4.09 gallons / day, > 120 gallons/month.
USDOE reported 4-29-21
Drop in liquid level March 2016 should have triggered review if not report of suspected leak

Failure to Report the Leak: USDOE’s monitoring of Interstitial liquid level showed clear evidence of leak

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Federal and State Hazardous Waste Laws Require Immediate Reporting of Leak and Removal of Waste to Reduce Harm

DOE has known about the B-109 leak for over two years - A leak was likely seen in early 2017; early 2019 precipitous drop required report
Delay in reporting = Delay in Action = Irreversible Harm

“[a]ny release to the environment must be reported to the department and other authorities immediately.” Wash. Admin. Code.173-303-640(7)(d)
Federal law similarly requires that the owners and operators of tanks must, within 24 hours, “[r]eport the release to the implementing agency.” 40 C.F.R. § 280.61.

No action has been taken or is planned for removing the interstitial liquid/supernatant waste from the tank
This is a clear violation of the duty to “remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment.” Wash. Admin. Code.173-303-640(7)(b)(i).

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Failure to Report or Even Start Assessing the Leak:

In July 2020, the USDOE started their Formal Leak Assessment (FLA) after a 17-month sharp decrease in Interstitial Liquid.
Leak Assessment Team took another three months before holding a second meeting. Met only 3 times in seven months.

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USDOE’s issued its formal notice and completion of their FLA in April 2021. The report also estimated only 3,100 gallons leaked. HoANW calculates that the amount of waste leaked is 180% to three times greater = from 5,750 to 10,000 gallons.
USDOE’s own monitoring data shows they knew or should have known of the B-109 leak by March 2019, at the latest. Should have known started assessments 2017 or 12-18.
Formal Leak Assessment began 17 months after USDOE had clear evidence of a leak. It was not completed until April 29th, 2021 - two years late.

Leak Obvious for Over 2 Years Prior to Reporting

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USDOE Misrepresented the liquid level inside tank B-109

Much more waste has leaked from B-109 than reported

USDOE reported the same level of DIL during this 15-year span in the Waste Tank Summary reports, despite a clear increase in liquid level.
If there were no leaks the level would likely be up at 43.5 inches.
B-109 will keep gaining liquid because of the nature of the High-Level waste’s chemical properties. This waste is hygroscopic – it attracts and entrains moisture.
USDOE reported in 2014 that water was also entering the tank = “intrusion.”

15-year span

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Misrepresentations of Liquid in Tank and Ignoring Regular Gain of Liquid Led to Greatly Underreporting the Leak (Continued)

The Waste Tank Summary Reports fail to accurately report increasing levels of DIL for over 15 years prior to the leak.

USDOE reported only 3,100 gallons leaked. Considering the increase in liquid leads to calculation that the total waste leaked from Tank B-109 is at least 5,750 gallons, and as much as 10,000 gallons.

USDOE only measured loss from the measured December 2018 level – disregarding how much liquid is entrained every month and clear evidence of leakage prior to 12-2018*

15-year span

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Big Picture

USDOE’s issued its formal leak notice and its Leak Assessment on April 29, 2021. The report estimated 3,100 gallons leaked. Taking into account the increase in liquid prior to the leak leads to estimates that 5,750 to 10,000 gallons has already leaked.
In March 2019, USDOE should have reported evidence of a leak immediately to Ecology and EPA to begin the process of removing leakable waste.
In July 2020, the USDOE started their FLA after a 17-month sharp decrease in DIL.
USDOE reported the same level of DIL during this 15-year span in the Waste Tank Summary reports, despite a clear increase in liquid level.

15-Year Span

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What’s Happened to Liquid Level Since April 29 Leak Report?

14 year steady increase until early 2016

Drop from Dec 2018 to March 2019 exceeded lower specification – trigger for knowing of leak

Leak officially reported 4-29-21

New Low May 21, 2021

Latest reported reading Aug 14, 2021 of 39.348 is .7 inch lower than June and July

The May 25 CERCLA report update should have been based on a loss down to 39.82 inches of ILL as measured and verified on April 20 and again May 21, 2021 rather than a level of 40.21 inches.
.39 inch of loss using the USDOE’s prior .24 liquid adjustment would be an additional loss of 1,074 gallons without porosity; and 257 gallon loss with porosity factor! That’s an 8% increase in leak compared to USDOE’s report of April 29, 2021.
2753 gallons in one inch of all liquid in a 75 foot diameter tank. USDOE uses .24 porosity factor.
.7 inch loss with porosity factor applied = 462..5 gallons lost since USDOE’s April 29 report.
despite the monitoring data, USDOE's calculation document says "note that this assumes no liquid lost from 2/11/14 to 12/3/18."
USDOE’s Leak Assessment Report ignored the clearly visible evidence of leakage prior to December 2018, and only examined the “decreasing trend since late 2018.” Leak Assessment Report at 5-4.
Conservatively, considering the rate of increase prior to 2018 (using lower increase intervals), the ILL baseline to measure from would be 45.188 inches. As of August 14, 2021, the level is 39.348. This would represent a leak of 3,858 gallons if USDOE’s porosity factor is applied to the entire loss. This does not represent what the full loss would be because it still reflects a static measure instead of loss of regained liquids.
USDOE also used the level of liquid around the salt well screen in its calculations. USDOE reported in the Leak Assessment that the liquid level around the salt well screen dropped 2.38 inches from February 2014 to February 2021. Leak Assessment Report at Section 5.4 page 5-8.
The salt well is essentially a space clear of sludge and solids. Thus, if the liquid level in the salt well dropped 2.38 inches, it is appropriate to apply a straight volumetric loss of 2,754 gallons per inch. This would be 6,554.52 gallons of liquid lost.
However, it is important to add the amount of replacement liquid from new entrainment of moisture (measured between 68 and 380 gallons per month) and supernatant draining into the solids and becoming interstitial liquid as those 6,554 gallons were lost. The loss calculation should be liquid level drop x gallons/inch + replacement liquid.
Thus, 6,554 gallons of lost liquid as measured in the salt well level plus 3,543 gallons of liquid added via entrainment and intrusion based on the increased trend line of the ILL readings prior to the leaks yields a total loss of over 10,000 gallons (interestingly, this tracks the decrease in DILL which USDOE applied to B-109 in Monthly Tank Summary Reports without documentation in 2019, based on a report that was not available in the administrative record from 2017).
The most important point of review of USDOE’s report and calculations is this:
There is no place in USDOE’s calculation where USDOE includes even a conservative figure for the documented increase in liquid every month that would have occurred but for the leak. USDOE applies its calculations as if the level of liquid measured in 2017 was a steady baseline. However, the evidence is indisputable that the tank entrains between 68 and 380 gallons a month (range is more typically over 130 gallons).
There is significant uncertainty in the reported liquid level loss around the salt well – especially prior to the most recent visual observations. The estimates are averages based on poor photographs.
The minutes and presentation to the B-109 Tank Leak Assessment team showed ILL levels beginning in November 2017. This missed the clear charted data of a steadily increase in ILL levels for the prior decade. See presentation page A-10, Tank Leak Assessment Report (page 60 of pdf). This also meant that the team did not have the visual evidence that the tank likely began leaking in 2016 or earlier. Without presenting any evidence to support this, the presentation irresponsibly stated “ILL reasonably consistent from 3/3/06 to 12/3/18” WRPS Summary Slide 15 in Tank Leak Assessment Report at A-123.

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USDOE did not disclose to the public and in leak report to EPA that Gamma Borehole logging confirmed the leak

Gamma radiation logging of boreholes to definitively determine if there was a leak should have been required immediately when a leak assessment began.
Instead, it wasn’t requested till March 2021.
It confirmed very high Gamma radiation levels since last borehole logging in 2002 in borehole -06 (Southern side of tank).
Other 3 boreholes showed no increase since last logged. Leak is only reasonable explanation for the new contamination.

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USDOE did not disclose to the public and in required leak report that Gamma borehole logging shows leak serious and moving

“The gamma activity count rates at this drywell were elevated for nearly the entire length of the drywell, with peak count rates occurring at 41 ft.(~41,000 cps) and at 51.5 ft. (~21,000 cps) below the top of the casing. Between these depths, the detector was saturated, indicating count rates greater than 55,000 cps and a potential leak from Tank B-109.”
Contamination already > 50-65’ below top
Groundwater approximately 200 foot below

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DOE/Ecology Approach is Unacceptable to Stakeholders

USDOE’s acceptance of soil contamination from tank leaks is unacceptable to public, Tribes, Ecology and violates legal duty to remove waste and abate leak.
A direct afront to the Tribes whose homeland is being contaminated without voice or input
Demonstrates a lack of urgency and concern
Defies reality that USDOE can never remove all contamination from groundwater, and that contamination will move from soil to groundwater over thousands of years.
There has been no discussion with the public and Tribes about acceptability of the stated “do nothing” strategy by USDOE management
We need public meetings on what actions should be taken!

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Tank B-109 Leak Response

The State has the authority and duty to order USDOE to “remove” leakable liquid and waste in response to the B-109 leak crisis.

RCRA and State HWMA authority

This could be a CERCLA removal action per 40 C.F.R. § 270.61

When there is a release or threatened release, removal action appropriate.
Tanks are in the 200 Area Superfund (CERCLA) site, so response actions can be taken regardless of which agency is the lead regulator.
Ecology has authority to order removal of leakable liquids simiar to EPA response action.

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The Department of Ecology has the authority and duty to order the Department of Energy to immediately remove waste from B-109 to abate the “imminent” and “substantial endangerment” posed by leaking High-Level Nuclear Waste. �

“Imminent” and “substantial endangerment” includes long-term harm to health and the environment that we know occurs from a leak of High-Level Nuclear Waste.

Claims that this leak is “small” compared to past releases does not change the duty to abate the harm

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To apply available options for removing leakable liquid:

The Federal Resource and Conservation Recovery Act (RCRA) and state hazardous waste law (HWMA) allow for the Department to waive permit applications during an emergency to human health or the environment to remove waste from B-109. The leaking tanks at Hanford are a threat to both human health and the environment.

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Removal of Waste from B-109 could begin in months

The Department of Ecology has a duty to require the Department of Energy to remove drainable waste from B-109 as soon as possible.* There are available technical options using the SAFE and TBI equipment and technologies to remove the waste. Removal could begin within months.
Development and testing of the In-Tank Pretreatment System (developed for TBI) with SAFE offsite treatment proposal, using saltwell pumping with ion exchange does not need to await a permit before being used to remove liquids from a leaking tank. After testing, may proceed under an RD&D or long-term permit.

“at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment.” WAC173-303-640(7)(b)(i).

(7) Response to leaks or spills and disposition of leaking or unfit-for-use tank systems.

A tank system or secondary containment system from which there has been a leak or spill, or which is unfit for use, must be removed from service immediately, and the owner or operator must satisfy the following requirements:

(b) Removal of waste from tank system or secondary containment system.

(i) If the release was from the tank system, the owner/operator must, within twenty-four hours after detection of the leak or, if the owner/operator demonstrates that it is not possible, at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment and to allow inspection and repair of the tank system to be performed.

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Available mobile, low cost, timely option for retrieving leakable liquids from leaking Tank B-109

B-109 will continue to leak unless liquids are removed.
Liquids that leak from B-109 carry high Gamma radionuclides into soil as shown in Gamma drywell monitoring at B-109 (March 2021) with peak radiation levels 41 to 51 feet below surface.
Uses an In-Tank Pretreatment System = ITPS
Components already developed and delivered

Low cost
Ion exchange is in the assembly put into the tank.
Allows removal of Cesium, Strontium, TRU before waste exits tank.
Ion exchange similar to TSCR.
Mobile – double contained transfer lines to transport.
Demonstrate offsite treatment to RCRA standards and use as test of TBI.
Move to next leaking tank…

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A Workable, Regulatory Compliant Approach To Mitigate B-109 Leak Can Start in Months

Step 1: Install Ex-tank leak detection system

Determine baseline extent of conditions:

Characterize and report on status of contamination plume

Step 2: Removal, Treatment And Disposal of Leakable Interstitial Liquid Waste

Mitigate further leaks from water ingress

Step 3: Monitor Effectiveness of Mitigation Plan

Use in-tank and ex-tank leak detection systems and treated fluids to monitor and report on mitigation plan effectiveness

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In-tank waste retrieval, pretreatment, post treatment and off-site disposal

Little infrastructure is available at B-109 to support an intermittent waste transfer campaign

Simple, low volume modular systems required

DOE has available a tested (on simulant) In-tank Pretreatment System (ITPS) developed as part of the Test Bed Initiative program

Deployed through an existing or a new tank riser (referring to hole in tank through which equipment is inserted)
ITPS is designed to retrieve, filter and remove cesium from tank liquids at the rate of 1 GPM

It is a small-scale analog of DFLAW’s TSCR system
Can treat up to ~2000 gallons of waste before replacement

Resulting liquid exiting the ITPS can then be transported to offsite treatment to meet all LDR standards and offsite disposal. Meets same criteria as TSCR.

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Easy to install system in riser of B-109 to retrieve liquids before they leak

Approach is like the one used for interim stabilization of SSTs (i.e. removal of liquids)
USDOE has greatly improved salt well pumping capability – put pump and salt well into B-109 and can retrieve far more liquid than when tanks were interim stabilized 20+ years ago.
Leverages systems and components already developed and tested for a similar application in other tanks
Allows retrieval and pretreatment of ~2000 gallons of interstitial liquid waste before it can leak to the environment
If demonstration of first 2000 gallons of interstitial liquid waste is successful, continue to remove all interstitial liquid from B-109.
Low personnel, operations and environmental risk
Pretreatment of the liquids is done inside the tank, simplifying operational and nuclear safety evaluations
Lab analysis of retrieved waste is verified to be MLLW before treating to RCRA standards followed by out of state disposal
Big benefit – waste is not disposed in Hanford IDF landfill and is first reduction in total on-site contaminant load
Approach enables DOE to have a ready and tested means for addressing future SST tank leaks as infrastructure continues to age and more tanks leak
When ion exchange resin is expended, it gets pulled out and a new ITPS installed. Cost approximately $150,000.

Tank B-109 Waste Retrieval and Pretreatment

Key Features

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241-B-109 ITPS Key Features and Benefits

Leverages components previously deployed in high level waste applications
Enables mitigation of leak risk in Tank 241-B-109
Allows safe, cost effective retrieval and pretreatment of 2,000 gallons of mixed low-level waste (MLLW) while regaining interim stabilized status
Low personnel, operations and environmental risk
Riser extension maintains tank containment and allows for sampling – any leak gravity-drains back to tank
System is a rigid assembly installed in a single 12” riser in a single lift

IX column is in riser, simplifying operational and nuclear safety evaluations
Filtration in-line before Ion Exchange (IX ) column protects column
MLLW to delay tote for IX performance confirmation measurement then to DOT approved tote, with secondary containment shielding

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In-Tank Pretreatment �System Design

Tank B-109 Field Deployment Concept

NucFil filter for hydrogen venting contamination control
12” riser adapter with line out to transport totes and line in for backflush and venting of loaded IX column
Decontamination spray ring reduces contamination/dose in decommissioning
Ion exchange column w/CST resin separates ≈ 175 Ci Cs-137. Designed for decoupling and interim storage or disposal
Back-flushable cartridge filter to remove actinides and protect IX column
DC progressive cavity pump �feeding system �at approximately �1 gpm
Inlet strainer set �into waste

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In-Tank Pretreatment �System Design Concept

Leverages components previously deployed in high level waste applications
Allows safe, cost effective acquisition of 2,000 gallons of mixed low-level waste (MLLW) while mitigating leak potential and regaining interim stabilized status
Low personnel, operations and environmental risk
Riser extension maintains tank containment and allows for sampling – any leak gravity-drains back to tank
System is a rigid assembly installed in a single 12” riser in a single lift
Waste transfer hose with secondary containment during transfer to shipping container. Hose run expected to be less than 100 feet.
IX column is in riser, simplifying operational and nuclear safety evaluations
Filtration in-line before IX column protects column
MLLW to delay tote for IX performance confirmation measurement then to DOT approved tote, with secondary containment shielding and overflow

Tank 241-B-109 Field Deployment Concept

Key Features

NucFil filter for hydrogen venting contamination control
12” riser adapter with line out to transport totes and line in for backflush and venting of loaded IX column
Decontamination spray ring reduces contamination/dose in decommissioning
Ion exchange column w/CST resin separates ≈ 175 Ci Cs-137. Designed for decoupling and interim storage or disposal
Back-flushable cartridge filter to remove actinides and protect IX column
DC progressive cavity pump �feeding system �at approximately �1 gpm
Inlet strainer set �1-2 feet into waste

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In-tank pretreatment system in Central Riser

Delay tote allows for direct measurement of contents to confirm IX process performance

Use Portable Exhauster to ventilate tank, controlling potential tank vapors and hydrogen buildup

Waste transfer hose with secondary containment is supported and sloped for gravity drain back to tank

2,000 gallons of MLLW collected in DOT approved commercial totes with spill protection. Continue until free liquids removed mitigating leak risk

Tank 241-B-109 Plan View

Tank 241-B-109 Elevation

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ITPS in Test Stand

Tank B-109 Field Deployment Major Components

In-tank pretreatment system in existing or new riser

Delay tote allows for direct measurement of contents to confirm IX process performance

Tank B-109 is interim stabilized containing solids with interstitial water

Waste transfer hose with secondary containment is supported and sloped for gravity drain back to tank

2,000 gallons of MLLW collected in 6 DOT approved commercial totes with spill protection

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Key System Features:

NucFil filter for hydrogen venting contamination control
12” riser adapter with line out to transport totes and line in for backflush and venting of loaded IX column
Decontamination spray ring reduces contamination/dose in decommissioning
Ion exchange column w/CST resin separates ≈ 175 Ci Cs-137. Designed for decoupling and interim storage or disposal
Back-flushable cartridge filter to remove actinides and protect IX column
DC progressive cavity pump feeding system at approximately 1 gpm
Inlet strainer set into salt well in tank

Pedigree and Status:

Designed to Tank Farms Standards and Requirements
Design Approved by TOC Contractor WRPS
System successfully tested with simulants
Hardware built and delivered to WRPS in 2019
Available as part of B-109 or any SST Leak response

241-B-109 In-Tank Pretreatment �System Design Concept

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Rationale for Immediate Action

DOE reported for 15 years that the DIL in Tank B-109 was 23,000 gallons, and then reduced the amount in Monthly Summaries to 14,000 gallons despite recording increases in liquid in the quarterly readings.
When DOE finally released its formal notice of a leak coming from Tank B-109 they reported ~3,100 gallons had leaked.
DOE’s monitoring data provides basis for realistic estimate that 5,750 to 10,000 gallons have leaked.
USDOE knowingly omitted, and reported misleading, information in the formal leak notice report and the Waste Tank Summary Reports. The Reports are relied on by managers and regulators. The Summary Reports show far less Drainable Interstitial Liquid than may be in B-109. This has led some policy makers to erroneously say there is only a small amount available to leak.
Allowing Tank B-109 to leak endlessly violates Treaty rights

Bullet 1: Document justifying the reduced Drainable Interstitial Liquid was not in the administrative record and does not appear to have ever been reviewed.
Bullet 2: USDOE ignored its own monitoring data showing that the waste regularly entrains 68 to over 300 gallons a month, with typical range around 130. This entrainment and intrusion has to be added to the calculation of liquid lost using the liquid observation well for ILL. .1 inch of added liquid level between observations was typical. Between September 2010 and September 2015, the level increased .6 inch, which is 1,652 gallons in the tank. USDOE applied a porosity factor of .24, which would be a 396,6 gallon increase. However, since actual liquid in the saltwell is being measured by the neutron probe (and the ability of the probe to measure is in doubt) the appropriateness of the .24 application is not established.

Treaty rights to utilize Central Plateau resources as recognized by Treaties of 1855 require action to protect and restore:

“the exclusive right of taking fish in the streams running through and bordering said reservation is hereby secured to said Indians, and at all other usual and accustomed stations in common with citizens of the United States, and of erecting suitable buildings for curing the same; the privilege of hunting, gathering roots and berries and pasturing their stock on unclaimed lands in common with citizens, is also secured to them.”

“…the right of taking fish at all usual and accustomed places, in common with the citizens of the Territory, and of erecting temporary buildings for curing them; together with the privilege of hunting, gathering roots and berries, and pasturing their horses and cattle upon open and unclaimed land.”

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Heart of America NW urged:

Tank leaks must not be ignored. The harm caused is irreversible, which is why billions are being spent to remove and treat tank waste.
It is not acceptable for evidence of leaks to go without action for years. Borehole logging and ex-tank monitoring around suspect / high risk tanks should be required.

A new contingency plan that is transparent and includes regulators and Tribes needs adoption
If continue to use a “team” to formally determine if there is a tank leak, add WA, OR, Tribal rep to team

Leakable liquids should be removed from tanks as quickly as possible when there is evidence of leakage. Removing liquid is the best technical and required legal option.
USDOE should proceed to use the available “SAFE” technology and methods to remove leakable liquids from B-109 using equipment developed for TBI and similar to TSCR. Demonstrate use of existing “In-Tank Pretreatment System” with ion exchange to remove Cesium before leakable liquid is pumped from tank. Demonstrate offsite treatment of the removed liquid waste and offsite disposal.

This option is low cost and does not require long timelines and cost to install infrastructure in tank farm
If demonstrated successfully, order additional mobile units – may include second TSCR.
Additional mitigation or abatement such as intrusion control should be in addition to liquid removal

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Pumping to Remove Waste from leaking B-109 is the only legal and the only effective option

USDOE adopted a document for technologies to use for responding to Single Shell Tank leaks, which proposes running air over the surface of the tank waste to dry out supernatant and some of the drainable Interstitial Liquid (ILL). RPP-RPT-62098 (May 2020). The report acknowledges that this is not proven to have any long-term reduction in leakable interstitial liquid, requires constant venting until the tank is emptied, and creates air emissions with permitting challenges. RPP-RPT-59273 (2017).

Removal of waste - starting with supernatant and drainable liquid - is the only effective way to end the leak from B-109.
USDOE’s own TPA required assessment (RPP-RPT-62098) co-recommended removal of drainable liquid as preferred approach: “The recommended drainable liquid removal technology is effective for both supernatant and drainable interstitial liquids in the SSTs.” However, USDOE “preferred” ventilation based on subjective ranking without any external views, without consideration of regulatory requirements, and despite the report finding: “The effectiveness of single-pass ventilation systems in reducing drainable interstitial liquid is not known.”

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Washington State Department of Ecology should take action reflecting Washington’s “Zero Tolerance” Policy for tank leaks and the legal requirement to empty leakable liquid::

Issue an order to USDOE to immediately begin to remove drainable interstitial liquids

Implement the SAFE TBI technology on Tank B109
Removal planning must begin immediately with physical removal of supernatant and liquids

Order USDOE to include funding to respond to the leak in B-109 in the site budget and overall USDOE budget request and to provide Ecology and the public with all documentation on work costs to accomplish this and how USDOE prioritizes this work in its Budget Request.
Demand that USDOE accurately report the quarterly readings in the administrative record within the Waste Tank Summary Reports

Convene an interdisciplinary review team with Tribes to review the leakage data and responses to leaks; and, not accept the USDOE’s report selecting air ventilation as the response to leaks instead of removal.

Resume borehole logging and add monitoring for leakage around each SST that is considered at high risk
Have Ecology on formal team assessing if a tank is leaking (plus Oregon and Tribal experts to broaden team)
Refer to the Attorney General for legal action USDOE’s failure to report the leak for several years, misrepresentation of the leak quantities and failure to take action to remove wastes and abate the harm.
Hold public meetings and take comment on any proposed “agreed order” with USDOE and on the needed tank leak response plan to be included in the Hnaford Site RCRA permit.

This was in our letter to the governor
Issue an order to USDOE to immediately begin to remove drainable interstitial liquids and supernatant to abate and respond to the large leak from B-109, followed by an order to remove all remaining wastes.

The order should direct USDOE to implement the SAFE TBI technology on Tank B109 utilizing saltwell pumping and ion exchange or TSCR to remove the remaining liquid from the tank, followed by removal of solids, as required by state and federal law.
Removal planning must begin immediately with physical removal of supernatant and liquids starting no later than the start of the federal fiscal year on October 1, 2021.

Order USDOE to include funding to respond to the leak in B-109 in the site budget and overall USDOE budget request and to provide Ecology and the public with all documentation on work costs to accomplish this and how USDOE prioritizes this work in its Budget Request.

Funds should be clearly identified in the FY 2022 and 2023 budgets to remove waste from the tank utilizing the available methods and SAFE offsite treatment, which would allow this solidified and treated waste to be disposed off of Hanford and reduce the total risk at Hanford.

Demand that USDOE accurately report the quarterly readings in the administrative record within the Waste Tank Summary Reports and share all relevant documents that they rely on for calculating liquid levels inside the tanks in the administrative record.

Convene an interdisciplinary review team with Tribes, stakeholders, regulators and the Advisory Board to review the leakage data and responses to leaks; and, not accept the USDOE’s report selecting air ventilation as the response to leaks instead of removal.

Add external borehole based gamma detection and/or electroresistivity and similar monitoring for leakage around each SST, starting with the tanks that have shown reductions in ILL and supernatant.
• Refer to the Attorney General for legal action USDOE’s failure to report the leak for several years (including failure to report when there was a dramatic drop in liquid level that exceeded USDOE’s lower criteria level for action), misrepresentation of the leak quantities and failure to take action to remove wastes and abate the harm.

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Hanford Advisory Board Considering the following advice this week: you can sign up to give public comment

The Board advises the TPA agencies to address leaks from Hanford’s SSTs by removing leakable liquids as quickly as possible or feasible. The harm caused to the environment is irreversible and not acceptable.
The Board advises the TPA agencies to create a formal leak response plan for the SST System as soon as possible. This plan should be transparent and include input from regulators, the public and the Tribes. The plan could explore innovative solutions to deploying infrastructure quickly in the tank farms or the benefits of starting the process to build out infrastructure earlier than currently scheduled in tank retrieval milestones.
The Board advises the TPA agencies to develop a feasibility assessment for all potential options to respond to the B-109 leak, including interim cover, inlet air drying technologies, saltwell pumping (including with in-tank pre-treatment), full retrieval, and any others that are reasonable to consider. Action to abate the harm from the leak must not be delayed by lengthy processes. The public should be afforded a formal comment opportunity on the response options assessment.

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Hanford Advisory Board Considering the following advice this week: you can sign up to give public comment (slide 2)

4. The Board advises the agencies to develop greater agility to respond to future SST leaks. The TPA agencies should advocate for additional investment by DOE HQ in technology development focused on rapid mobile retrieval of leaking tanks. ORP should also budget for SST leak contingency funding...

5. The Board advises the TPA agencies to deploy borehole logging and ex-tank monitoring around suspect/high-risk tanks….

6. The Board advises DOE to include Ecology and potentially other non-DOE and contractor experts in the tank leak assessment process. The lead regulatory agency should be involved for any process that evaluates data to determine whether a RCRA-regulated tank has lost containment.

7. The Board advises that the TPA agencies explore innovative solutions to deploying infrastructure quickly in the tank farms and to consider starting the process to build out infrastructure earlier …

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What can YOU Do?

Write Governor Inslee and Ecology Director Laura Watson to urge that an order be issued to remove leakable liquids from B-109 asap

Oregon residents can write Governor Brown to urge Oregon to ask for immediate action
Ask your Senators and US Rep to fund removal of leakable waste from leaking tanks with demonstration of offsite treatment and disposal.
Support test to see if tank liquids can be treated and disposed offsite in permitted site with no risk to groundater – reducing the total contamination risk from USDOE’s plans for disposing of waste at Hanford.
Can use Action Link from Heart of America Northwest

Comment at Hanford Advisory Board meeting public comment on Sept 22
Urge Ecology and EPA to develop and include a tank leak response plan in the Hanford Site Dangerous Waste permit (RCRA permit) – with public comment and meetings.
Continue to follow us for updates (FB) and email. We can send supporting fact sheets. This Powerpoint will be linked from our webpage: hanfordcleanup.org
Laura.Watson@ecy.wa.gov https://www.governor.wa.gov/contact

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To join HAB meeting on September 22 and 23:�

Learn more about the Hanford cleanup mission by attending this virtual HAB meeting. The conference call information is 1 (509) 600-2010 and enter conference code 425 688 348#. Join Via Microsoft Teams�https://teams.microsoft.com/dl/launcher/launcher.html?url=%2F_%23%2Fl%2Fmeetup-join%2F19%3Ameeting_YTgzYmJiMWItMzExOS00MzMwLTkyMDYtZWQzNzM5NzIyYTc3%40thread.v2%2F0%3Fcontext%3D%257b%2522Tid%2522%253a%2522bc502f9d-7fa2-4c42-a9f7-f0ce462ece84%2522%252c%2522Oid%2522%253a%25225fb5b51b-bcce-41e5-bfa8-580e816fa8a3%2522%257d%26anon%3Dtrue&type=meetup-join&deeplinkId=61d45adf-90b0-402e-b96d-7fb2fa56dcae&directDl=true&msLaunch=true&enableMobilePage=true&form=MY01SV&OCID=MY01SV&suppressPrompt=true�

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Easy to install system in riser of B-109 to retrieve liquids before they leak

Approach is like the one used for interim stabilization of SSTs (i.e. removal of liquids)
USDOE has greatly improved salt well pumping capability – put pump and salt well into B-109 and can retrieve far more liquid than when tanks were interim stabilized 20+ years ago.
Leverages systems and components already developed and tested for a similar application in other tanks
Allows retrieval and pretreatment of ~2000 gallons of interstitial liquid waste before it can leak to the environment
If demonstration of first 2000 gallons of interstitial liquid waste is successful, continue to remove all interstitial liquid from B-109.
Low personnel, operations and environmental risk
Pretreatment of the liquids is done inside the tank, simplifying operational and nuclear safety evaluations
Lab analysis of retrieved waste is verified to be MLLW before treating to RCRA standards followed by out of state disposal
Big benefit – waste is not disposed in Hanford IDF landfill and is first reduction in total on-site contaminant load
Approach enables DOE to have a ready and tested means for addressing future SST tank leaks as infrastructure continues to age and more tanks leak
When ion exchange resin is expended, it gets pulled out and a new ITPS installed. Cost approximately $150,000.

Tank B-109 Waste Retrieval and Pretreatment

Key Features – support slides

Key Features

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Easy to install system in riser of B-109 to retrieve liquids before they leak

The equipment arm for the pump and Cesium removal ion exchange capsule is too long to go in B-109: Numerous engineers scoff at this noting that the arm can simply be shortened or a sleeve added to allow it to extend above the tank. This argument also ignores:

The law requires removing leakable liquid from a leaking tank as soon as feasible.
USDOE’s own TPA required report recommended enhanced salt well pumping for future leaking Single Shell Tanks and noted that the technology is available and does not require new development
A new arm could be procured and fabricated specifically for B-109 for under $200,000 and deployed in a matter of months. If rules had been followed right after the public report of the leak (which was already delayed for 2 years) Tank B-109 could already have had leakable liquid removed by now.

Response to USDOE claims that

TBI In-Tank Pretreatment System Equipment that is on-hand

will not work for removing liquid from B-109 (claims made at

9-21-21 Hanford Advisory Board meeting)

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Easy to install system in riser of B-109 to retrieve liquids before they leak

2. USDOE claimed that the molarity (in lay terms concentration) of the salts in the liquid is too high for the ion exchange resin in the removal arm capsule to remove Cesium.

This argument circularly noted that the Cesium level is actually very low in B-109. If so, minimal Cesium removal is needed to meet criteria under DOE Order 435.1 to have key radionuclides removed to extent practicable to allow treatment and disposal in a permitted LLW disposal facility off of Hanford (where there is no groundwater at risk).
USDOE and Ecology apparently did not consult with the company that provides the Cesium Ion Exchange resin. While efficiency drops with high molarity, it will still remove Cesium (and there is less to remove in B-109 liquid)
MOST IMPORTANTLY: A SIMPLE SOLUTION EXISTS: a one gallon per minute low flow line can inject water to dilute the waste as it moves up the arm right before entering the ion exchange capsule. This is simple to insert. It does not add liquid to the waste in the tank, the line is the size and flow of a refrigerator door water line. It simply dilutes waste to the ideal molarity just before going through ion exchange.

Response to USDOE claims that

TBI In-Tank Pretreatment System Equipment that is on-hand

will not work for removing liquid from B-109 (claims made at 9-20-21 Hanford Advisory Board meeting)

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Typical Tank Elevation

B-109 has solids only

Typical Tank Plan View

In-Tank Pretreatment System

Typical Tank General Arrangement

In-tank pretreatment system in new or existing riser

Delay tote allows for direct measurement of contents to confirm IX process performance

2,000 gallons of MLLW collected in 6 DOT approved commercial totes with spill protection

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Fabricated DOT Certified Totes

Tank B-109 Commercial LLW Totes

2,000 gallons of MLLW collected in 6 DOT approved commercial totes with spill protection

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Proposed Layout on Tank B-109

Plan View

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ITPS located in central riser in B-109

-Elevation

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HRR-LDM trailer for detecting leaks on B-109

initial condition
changes during ITPS operation
Critical to assessing risk

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HRR-LDM and ITPS installed at B-109

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ITPS on B-109

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ITPS on B-109

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ITPS – in tank stack up – pump/filter/IX/containment

USDOE has this on hand. Arm can be shortened for B-109 OR it can extend out of tank with a sleeve.
When ion exchange resin is used up, the arm and column are pulled from tank. Resin and column stored along with TSCR resins.
New column can be procured and ready long before first one is full
Cost in range of $150,000, so a new arm could be fabricated specifically for B-109 within months.

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ITPS Process Totes – Staged For Characterization And Offsite Shipment