Finally I found a place where you can drop a public comment
http://wt.ecology.commentinput.com/?id=7mped
In the pre-amble to the discussion about grouting in the second tunnel at Hanford (Purex Tunnels)
We saw this
In May 2017, a 20-foot section of the roof of Tunnel 1 collapsed. The collapse caused a two-day emergency response that involved notifying the public and regulatory agencies, sheltering site employees until surveys verified no contamination was released, and filling the collapsed portion of the tunnel with soil.
It was insane to simply fill with soil. Sand would have been a much better solution as it would flow into spaces better. Oh well.
In the heat of the moment, you know that any government entity makes even lousier deicsions.
Then this
Filling the tunnels with engineered grout will help mitigate potential threats to human health and the environment, and will not preclude future remedial or final closure actions until future cleanup decisions have been reached.
Uh, it is basically a committment, that nothing ever will be done with these tunnels, they will site for 10,000 years in place. Once solid grouted, it because infinitely more difficult to "remediate", picture a giant 10' diamond saw cutting grout and steel and stuff into chunks 4' on each side. Think of the dust generated and the building and filtration needed.
-----------------------------------------
Comments on the proposed grouting
Reuel Paradis
I am opposed to filling tunnel with grout. I do not know what question the DOE put to its panel of experts but I suspect it went something like this: "What is the most economical (most inexpensive) method of stabilizing the Hanford tunnel?" If that was the question then the immediate answer is to fill the tunnel with grout. My concern lays in what happens next. Do you leave this 'radioactive
grout sausage' covered with earth in Hanford for the next one thousand years? The Tri-Cities Herald article states DOE believes the 'grout sausage' can be cut up for disposal in the future. If that is the DOE position, it is utter nonsense. What sort of machine would be able to 'cut' through the grout
and iron/steel without spreading radioactive dust all over Hanford and the surrounding area?
I belief if these tunnels require protection for the elements, then the DOE needs to build a structure over them and leave the tunnels as they are.
Thank you.
--------------------------------------------------------------------
Adele Reynolds
Hold off. Investigate. Plan. Consider half-life danger of what's in Tunnel 2--and consider the future. Numerous red flags are up with the DOE's hasty plan to fill the tunnel.
There is high level radioactivity in there! Well that's all the more reason to slow down and not do something that will make it impossible for emerging technologies to make things safe in the short future not dangerous for centuries and centuries.
Does anyone know how much radioactivity is seeping UNDER the tunnel, and how to remove that if the tunnel is grouted? Or how to EVER remove danger if it's cemented?
You're playing with fire while looking like you know how to handle sparks. Stop being bureaucratically impulsive. Pretending like you know everything.
Hold off. Investigate. Plan.
-----------------------------------------------------------------
Naomi McDermott
Recognizing, it isn't the optimal permanent solution, I support immediate treatment that would avoid the potential for tunnel collapse this winter. It seems too risky to wait.
--------------------------------------------------------------------- stock this looks like a total repeat....not good!
Rick Harlan
Please pause for a moment--a year is just a blink in time compared to the half-life danger of what's in Tunnel 2--and consider the future. Numerous red flags are up with the DOE's hasty plan to fill the tunnel. Quick-there's high level radioactivity in there! Well that's all the more reason to slow down and not do something that will make it impossible for emerging technologies to make things safe in the short future not dangerous for centuries and centuries.
Quick question--does anyone know how much radioactivity is seeping UNDER the tunnel, and how to remove that if the tunnel is grouted? Or how to EVER remove danger if it's cemented?
You're playing with fire while looking like you know how to handle sparks. Stop being bureaucratically impulsive. Pretending like you know everything. Hold off. Investigate. Plan.
--------------------------------------------------------------------
From: scot adams
To: Hanford (ECY)
Cc: McFadden, Daina (ECY)
Subject: Fw: Recommendations on PUREX Tunnel 2
Date: Tuesday, August 14, 2018 9:08:13 AM
From: scot adams <scadams@hotmail.com>
Sent: Friday, August 10, 2018 8:29 PM
To: alex.smith@ecy.wa.gov
Subject: Recommendations on PUREX Tunnel 2
To: Alexis Smith
From: Scot C. Adams
Subject: PUREX Tunnel 2
I gave oral comments in a meeting related to Tunnel 2, before the contractor prepared draft grouting documents. In the oral meeting and upon reading the Tunnel 2 draft documents, I interpreted that the contractor had selected grouting as an immediate remedy, regardless of input. Consequently, I did not submit written comments about Tunnel 2. Herein, I am submitting my personal views and recommendations for Tunnel 2.
With respect to the Washington Department of Ecology, the basic issue should be if the short term reduction of risk should be a temporary closure or a permanent closure.
I disagree with the contractor about grouting Tunnel 2 unless this is for final closure. If this is for final closure, a complete design and permit application should be expedited.
Recommendation- Short term actions should consider impacts on potential final closures and related regulator actions. Total costs could be reduced by closing Tunnel 2 in place as a final remedy, particularly if it could be closed as a low level radioactive disposal facility.
If the grouting is for a short term closure, getting back into the tunnels will be very difficult in spite of what the contractor has stated. Earlier the contractor stated that wire sawing could be used to recover the contents at a later time. I believe that wire sawing will be very difficult
especially considering the steel that is present in rails and rail cars. The wire saws will create a lot of fine materials that will a risk to workers and have the potential for dispersal as particulates.
The wire sawing will introduce a lot of free water which will be difficult to prevent from
entering the ground. An alternative using air cooling would be a significant risk for air releases to down winders.
Finally, blind sawing the grout will probably significantly increase the volume of waste to be dispositioned, because of extensive admixing of clean dirt, grout, steel, and waste; this would be the opposite of waste minimization.
Sawing of 300 Area grouted waste would be a major risk to the environment, workers, and down winders.
Use of Bentonite
The use of dry bentonite to close the tunnel would offer significant advantages over grout, whether considering short term closure or in situ permanent closure.
Most importantly, bentonite is a great sealer, as well as an expansive clay. Bentonite has the advantage of absorbing many times its weight in water, depending what type of bentonite and from where it is sourced. Wyoming sodium bentonite has a great reputation for sealing applications and is available by the train load. Washington Ecology acknowledges in WAC 173-160 the effectiveness of using bentonite to design, build, and decommissioning drinking water wells. Bentonite has been used in the
design of landfills. It should be noted that there are multiple types of bentonite clay depending upon the origin and depositional environment at the production site. The Cody Shale of Wyoming is well known for quality and quantity. Train load quantities of bentonite are readily available and have been used for major sealing projects, like mine shafts.
Bentonite could easily be removed from Tunnel 2 if that was to be part of a later closure action. It does not harden. If it is wetted for removal, it would not be a concern about air releases.
Introduction of bentonite into the tunnel would not require admixture with water, whereas introduction of grout will require the admixing of a huge quantity of water. Adding water to the tunnel very well may accelerate corrosion of waste packaging. The grout itself is corrosive even without adding water. At the N Reactor Basin, Ecology and DOE noted that grouting waste generated a lot of hydrogen gas, which slowed waste removal from the basin. It was assumed that the grout was corroding waste and the waste container to release hydrogen.
Bentonite could be removed easily from the tunnel without admixing, thus implementing waste volume minimization.
Overall, bentonite should be more protective of the air, groundwater, and waste than grout.
As a cost reduction approach, the bentonite could be admixed with locally sourced sand with no loss of performance.
Recommendation- Use bentonite to stabilize the tunnel.
Airborne Releases
Tunnel 2 is known to have airborne contamination. During a past emplacement of waste, one worker outside of the tunnel at an overhead access hole received an internal contamination.
It should be expected that addition of material to the tunnel will displace a lot of air, yielding a risk of down winder exposures from released particles.
Access Holes
There are 17 access holes in the top of the tunnel. These may have use in the design of the closure, particularly for the introduction of bentonite, as well as monitoring the closure.
Recommendation- Reactivate on an emergency basis, the existing filtered stack at the south end of the tunnel to maintain a negative air pressure and capture airborne particulates.
Waste Forms
Apparently, most of the rail cars were loaded with contaminated machinery. Once, some of the machinery was removed and reactivated for processing fuel rods. The connectors were cut off the rail cars.
However, later waste forms include waste generated from the 300 Area. On the last load of
300 Area waste, exposure to the rail engineer was minimized by the use of 14 spacer cars for distance, which implies a large field of radiation from the rail cars.
One 300 Area container, more or less unknown to DOE/RL and DOE/HQ at the time of emplacement, contained about a million curies within a gallon sized container. In the DOE Complex, high level waste is normally more formally addressed with respect to disposition than what was done for Tunnel 2. The 300 Area waste should receive special attention with respect to access and removal plans. A major mess could be generated if a later grout sawing process breached the 300 Area containers. The 300 Area waste should be a significant consideration in the disposition of the facility. Possibly a "new" major (very high radiation) waste site and release could result from sawing through waste containers. Sawing through the one million curie container could conceivably give workers short-term fatal doses.
The operating record for PUREX includes a waste inventory.
Bechtel-ERC refused to accept PUREX Tunnels into it's remediation program, because of the presence of high level waste, as determined in the Necessary and Sufficient analysis .
Robotics
A remote controlled engine, Little Toot, was used to enter the tunnel. The batteries were
removed.
Recommendation- Determine if Little Toot can be preserved for future use.
************************
My Qualifications
I have a Ph.D in Geology. I have been a CHMM for about 20 years.
I have been involved with waste facilities in various capacities since about 1983. I have experience with DOE radioactive and mixed waste as follows:
DOE Salt Repository Project- technical and regulatory aspects, seven EAs.
Yucca Mountain Project- Interagency reviews of test plans from Federal agencies, national labs, etc. and supervised generation of several contractor test plans. Nevada Test Site- Environmental site-wide plans and procedures; wrote site
DOE/NV/ERWM radioactive waste management order/manual; contributed to RCRA A and B applications for mixed and other waste; facility field studies; historical weapons testing and other literature reviews from multiple agencies. Supported non-radioactive waste management at Johnston Atoll and regulatory planning for another Pacific testing site.
Supported Corps of Engineers for FUSRAP for Down Town St Louis radioactive site remediation.
Regulatory analysis for various Hanford contractors and subcontractors
Participated in Necessary and Sufficient process for requirements analysis and flow down for PUREX and PUREX tunnels for maintenance and surveillance functions, as well as for REDOX and N Basins. I served as project/task subject matter expert for environment and waste management. (Necessary and Sufficient N&S) process was approved to use instead of SRIDs requirement analysis (now called DSA) for nuclear facilities. In this case, The scope of work was for maintenance and surveillance which was the basis for long term care of the facilities before demolition. Very large reductions in costs resulted from these M&S team analyses.)
Conducted inter-agency review of waste designations for a particular radioactive waste designation.
Contact Information-
Email- scadams@hotmail.com
Phone- 735-7130
--------------------------------------------------------------------------
Nancy McLeod
I live within 1 mile of Hanford. If one of the tunnels collapse & radioactive material is released my home & land, and my neighbors, would probably be rendered a total loss along with all belongings. I have 5 generations of family heirlooms which no amount of money can replace. This is a very
exclusive neighborhood of expensive homes. If those tunnels collapse releasing radioactive material onto us I am sure most if not all of us would file lawsuits against DOE. Stablize those tunnels
NOW, do not wait. Form would not allow me to give my email address. It is:
nancymcleod54@aol.com
---------------------------------------------------------------------------
Nancy McLeod
I live within 1 mile of Hanford. If one of the tunnels colapse & radioactive material is released my home & land, and my neighbors, would probably be rendered a total loss along with all belongings. I have 5 generations of family heirlooms which no amount of money can replace. This is a very
exclusive neighborhood of expensive homes. If those tunnels collapse releasing radioactive material onto us I am sure most if not all of us would file lawsuits against DOE. Stablize those tunnels
NOW, do not wait. Form would not allow me to give my email address. It is:
nancymcleod54@aol.com
