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Federal Register / Vol. 86, No. 173 / Friday, September 10, 2021 / Rules and Regulations
the ETF. A target goal with this approach was to establish a delisting framework that could consider future waste streams for which characterization data was not available at the time, but that could be managed in the future. More importantly, as Ecology and EPA noted in the 2005
delisting rulemaking since Energy could not reasonably provide detailed characterization of wastes streams that have yet to be generated, EPA proposed a waste acceptance framework based on an engineering evaluation of waste streams. This model provides a degree of confidence that treatment in the 200
Area ETF will meet delisting exclusion limits to the same degree of confidence as if detailed waste stream characterization were available, while avoiding the need to frequently revise the delisting rule itself. See 70 FR
44499, July 30, 2012.
Liquid effluents from the Waste Treatment Plant are one example of wastes that, in 2005, were expected to be generated in the future, but were not sufficiently characterized in order to be evaluated at that time. Since the 2005
modifications, the Department of Energy has made progress in both the design and operation of the planned WTP, including a detailed characterization of the liquid effluents from the WTP
through engineering design and modelling. See the engineering report and associated supporting calculation documents provided in the docket for the current delisting modifications.
From this work, Energy identified a number of constituents in WTP liquid effluent that would need to be considered in the context of the ETF
delisting. Energy has provided a request to the EPA 21ECD001774 dated June 29, 2021, available in the Hanford administrative records at www.hanford.gov to consider five of these additional constituents through a modification of Tables C1 and C2
pursuant to Condition 1b of the existing delisting. This request is consistent with the mechanism already in place under the existing delisting.
Because the June 29, 2021 request is outside the scope of this modification to the delisting rule itself, the request to add five additional constituents identified in the June 29, 2021 request are not further considered in this comment response, but will be addressed by EPAs expected future response to the June 29, 2021 request.
As documented in its request for a modification of the 200 Area ETF
delisting, Energy identified that acetonitrile exceeded the existing treatability envelope for that constituent. Based on our analysis of
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information provided by Energy for the current proposed modification, and the overall structure and content of the 2005
modifications to the delisting, EPA and Ecology have determined that with the current proposed modifications, the 200-Area ETF is fully capable of accepting reasonably expected liquid effluents from the WTP, and that there is little if any regulatory, environmental, or project risk associated with WTP
liquid effluents that would warrant future modifications of the 200 Area ETF delisting.
The commenter also raised a concern about a lack of pilot scale testing for WTP effluent. In particular the commenter states In the case of 242
A condensate, condensates had been sampled, and surrogate wastes were processed through pilot scale ETF
treatment units in order to provide an up front petition and No pilot scale processes have been conducted for the current WTP EMF effluent. There is no pilot EMF and no integrated pilot scale Direct Feed Low Activity Waste DFLAW process treatment train. The integrated WTP pilot scale equipment does not exist for DFLAW. Rather WTP
itself is being built as a full-scale pilot plant, with unknown and uncertain but certain to be expensive results.
Ecology and EPA acknowledge that the current proposed delisting rule modification changes are based on projections, not full-scale operations or demonstration testing. With respect to acetonitrile, the proposed changes to the delisting rule are specifically targeted to ensure an implementable mechanism is in place. This will allow demonstration testing as necessary, to expand the treatability envelope for acetonitrile.
Therefore, before full-scale operation of the DFLAW configuration of the WTP
begins, Energy will have performed exactly the type of direct demonstration that this comment speaks to. As discussed more fully in the 2005
delisting modification action, the current 200-Area ETF delisting is explicitly structured to accommodate new constituents where such new constituents are within the treatment capacity of ETF as reflected in the waste-stream specific waste processing strategy required by the delisting rule.
New constituents can be accepted for treatment in the 200 Area ETF without modification of the delisting. For new constituents that would require changes to a treatability envelope, the new demonstration testing mechanism in the current proposal would be applied.

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Secondary Wastes From the 200-Area ETF
The commenter raises multiple issues regarding secondary waste associated with the 200-Area ETF system. In particular the commenter states a defined secondary waste disposition path is needed for the solids/brine produced by treatment of WTP EMF hot operations effluent. And DOE has initiated an additional project to install the capability to load-out brine from the ETF STTs concentrate tanks into totes for shipment off-site. This project will mitigate brine removal issues from the STT and expand the capacity of WTP
EMF hot operations effluent treated.
Information in the proposed delisting docket notes that ETF brine could be sent off-site for further treatment. See RPPRPT62739, pages 35, 38, 39, and 108. While this may be a valid issue, secondary wastes are not within the scope of the proposed modifications to the 200-Area ETF delisting.
Addition of New Constituents The commenter notes that Energy has identified multiple additional constituents associated with liquid effluent from the WTP. In particular, the commenter states additionally, RPP
RPT60974 lists constituents in the projected WTP EMF hot operations wastewater profile that are not included in the delisting treatability envelope, including 2-hexanone, 2-butoxyethanol, acetate, glycolate, oxalate, boron, and manganese. These additional constituents and their associated limits will need to be added to the delisting approval treatability envelope. A project is underway to complete this action.
and EPA has noted that acetonitrile is difficult to destroy. Will the yet undiscovered other constituents be similarly difficult to destroy, potentially leading to more off-site promises and off-site risks?
Ecology and EPA agree that the enumerated constituents have been identified by Energy. However, the mechanism established in the 2005
revisions of the ETF delisting, specifically the treatability group concept, was established to address exactly this circumstance. See Condition 1b of the current delisting. Ecology and EPA are expecting a written request from Energy to modify Tables C1 and C2 in the existing delisting, to incorporate these additional constituents. Because treatment of these constituents is expected to be well within the treatability envelope of the associated treatability group to which they will be
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