Challenges in Developing Notice of Construction Applications for the Integrated Disposal Facility - 21241a

The Integrated Disposal Facility (IDF) is a double-lined, near-surface disposal facility at the DOE Hanford Site for low-level waste (LLW) and mixed LLW (MLLW) Resource Conservation and Recovery Act of 1976 [1] (RCRA) wastes from various Hanford Site operations. The construction of IDF was initiated in 2004 and completed in 2006. The entire IDF site is located on 82 hectares (202 acres) and the final disposal facility at closure is assumed to have an area of approximately 21 hectares (51 acres) and volume to accommodate 900,000 m³ of waste. The IDF is anticipated to start receiving waste in 2022. The primary waste stream that IDF will receive includes the vitrified LLW/MLLW (also known as immobilized low activity waste [ILAW]) from the soon-to-be-operational Hanford Tank Waste Treatment and Immobilization Plant (WTP). Radiological and nonradiological notice of construction (NOC) application documents were developed in 2005 and licenses were issued based on very preliminary planning information. Upon review of the applications/licenses in 2019, it was determined that major revisions would be needed to both documents. Numerous challenges have been encountered including the following: - Restarting a project and ensuring that the project stay off the critical path for starting operations at the WTP - one of Hanford's (and DOE's) top priorities. - Updating the large number of waste streams that the disposal facility may accept; determining hourly, daily, and annual inventories that may emit airborne constituents; evaluating various material waste forms that may be encountered; evaluating onsite waste treatment activities; and evaluating project operational activities that may emit fugitive emissions. - Performing airborne dispersion modeling and development of the nonradiological NOC consistent with newly developed guidance agreed upon in 2020 by DOE and the Washington State Department of Ecology. - Coordination with WTP and Hanford Tank Farms of primary and secondary waste streams and their associated inventories when some waste characteristics are not yet known. It is estimated that approximately 238,000 waste containers will be disposed of at IDF over its 30-year operational lifespan. - The Covid-19 epidemic has made coordination and communication of complex technical topics amongst multiple Hanford Site contractors, DOE, and regulators challenging. Both applications are anticipated to be submitted for DOE/regulatory review/approval the first quarter of 2021 and licenses are anticipated by the end of fiscal year 2021. This paper highlights the challenges and results of restarting the application/licensing process after being idle for over a decade and numerous other challenges. (authors)