Tru Waste Retrieval Project Richland WA

Next Generation Retrieval (Active) (EU 1327; NOC 1040)

Licensing File

Table of Contents

I) Licensing Checklist 2) Ot_herApplicable DocUI11_en_tation (En:u1_ils, report_s, c_a_lcu_l_ations, etc.) 3) Informal Draft EU License

a) Licensee Comments on [nformal Draft b) Resolution of Comments

4) -F-itml License 't!lt!7 SJ F.,,.,,. r ue,.-7""12.-

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LICENSING CHECKLIST (Rev. 2) {1-b I/

P/e"ase initial bOXes, as approprii:zte, rather tha-n placing a check mark in the box ~,oJS, /?IA 1-3.;i, _ ,JDC 'is'll4

~ ~

RAES date received -~,J-+-'f 1-~- and IM# assigned _L-_6~4~]5~\~ I

Entered into RAES Tracking/RDTT (lo - _ 153 ,Jf.,.) !;=-vi r-"5.;j 7 40

:' I Ll- ,-JOC. I/) Completeness Review due !,d_ ,.., -----~~---II To HP3 (responsi_bJe for facility) for as_signrnen_t_: --~--(/_Cv~'J~. --~-~~~----

...fjif/ To assigned HP2: k"I ( _ cpl

r,Jtf

Add draft Table of Contents and sqiarator pages to file.

Conduct completeness review using "Completeness Review Checklist" and draft "Completeness Notific_ation" l~er within 20 days of RAES date received. Discuss any concerns/issues with HP3 during this 20 day period.

Place "Completeness Review Checklist" in license file and prepare draft "Completeness Determinat_ior? letter. Letter must go out within_ 30 days of RAES date received.

• If application is incomplete,.you may need.to repeat this (and prior) step(s). • If application complete, assign NOC ID and EU ID, as appropriate. Do NOT obsolet_e 'old' NOC,

EU; etc. before the new final, approved, license is issued (you may have to exclude old from AOP for printing purposes).

Forward license file and draft "Completeness Determination" letter to HP3 for review. (If 28-day draft has already been reviewed by licensee and HPJ and is ready to go out at the 30 day mark, you may combine completeness and 28-dafdraft.)

HP3 - work with HP2 to resolve any comments then forward license file and draft "Completeness Detennination" letter to HSC for review.

HSC - work with HP3 to resolve any comments then forward draft ··completeness Detennination" letter to AA3 for finalization (HSC wiU update RAES Tracking/RDTT upon transmittal and will note the 28-Day Draft Due Date, below, upon returning file to you). You nciw have 60 days to issue the offic_ial 28-Day Draft Approval letter.

28-Day Ora.ft Du_e bate: ___ ~-- (See nex_t step, irnrnediately.)

Is i_t necessary to send the 20-Day City Notification? If yes, prepare ASAP and forward to HP3 for review (follow same process as above for letter issuance [HP3 -> HSC -> AA3]). HSC will update RAES Tracking/ROTT upon transmittal and will notify you of 20-Day Comment Due Date, below, upon returning the file to you).

• USDOE-RJ, Hanford Site is ex_empt from this requirement. • IfRAEL is part of a Materials or Waste license, the responsibility falls on them to notify the city.

We is·sue these notifications for neiv licenses or renewals only; we do not issue tl1em for modifications.

20-Day Comment Due Date: ___________ _

(see page 2)

· Page 1 of 2 All associated document templates can be found on the S: Drive at: S:\EPH\Dara\RP _A!R\RAES\Licen.sing Docs

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rf.t1J" Within 40 days-----~ of completeness determined, complete thorough review of application ~ and draft li_cense. Any EU specjfi_c cond_ition_s m_ust h_avejustifi_cation/basis documented in the

'explanation' section of the database. Discuss ariy concerns/issues with HP3 during this 40 day period. Also, have HSC do an informal review of the license for consistency before sending to the licensee.

HSC Informal License Review

Send informal draft license lo licensee for review, allowing them a week to IO days to get comments back.to you. Be.sure to include a 'due date'.

Upon receipt of response from licensee, resolve any comments/issues/concerns right away and finalize the draft license and transmittal letter (28-day Draft). At least 3-5 days before 28-Day Draft Due Date, send license file, draft transmittal letter, and draft license to HP3 for final review.

HP3 approves and forwards license file and draft letter to HSC for review. HSC reviews and forwards to AA3 for finalization (HSC will hold_ file until licensee receives 28-day draft).

Upon licensee receipt of 28,day draft, HSC will update RAES.Tracking/ROTT, verify database concurrence, and return ficense file _to HP2 with due date for iicensee response or final iss1µ111ce of license.

Final Due Date: I:),\ lq \ l\p

Once licensee has a_ccept_ed, or the 2_8 days ha_s expired (no more than 2-3 days before), obtain an approval number (AIR#) from AA3 and prepare final license and --Final Approval"' letter. Send license fi_le (be sure table of contents provides for final letterlli_cense), final transmittal letter, and final license to HP3 for final review.

HP3 approves and forwards to HSC for review. HSC forwards to AA3 for finalization.

Add final letter(s)

Update RAES Track:irig/RDTT

Verify data_base concurrenc_e

Update Licensee List

Add final file to database 'inbox' to be entered/scanned

Page 2 of 2 All associated document templates Can be found on ·rhe S: Drive at: S:\EPH\Dara\RP _A!R\RAES\Licensing Pocs

Frazier, Thomas {DOH)

From: Sent: To: Cc: Subject: Attachments:

Tom,

Faust, Eric" T < Eric.Faust@rl.doe.gov> Tuesday, September 13, 2016 8:59 AM Frazier, Thciriias (DOH) Schmidt, John W (DOH); Karschnia, Paul T; Carleo, Frank J; Engelmann, Richard H RE: Informal Drafts of Transuranic Waste Retrieval Project Licenses NOCs 1035 to 1040 NOC 1037 EU 1322 Transuranic Waste Portable Enclosure System #1 rl e_dit_s.pdf; NOC 1040 EU 1327 Transuranic Waste Next Generation Retrieval (active) rl edits.pd!

Sorry for the wait. Please see attached NOCs for 1037 and 1040. We highlighted in yellow the instan_ces where either NGR or PES should be removed from the licenses (instances ofNGR should be redacted in NOC 1037 ap.d instances of PES should be redacted in NOC 1040). Also in NOC l 040, we had questions regarding references to NOC 486. We indicated the comments in the yellow text bubble comment function in the pdf .. These were the only comments that we have.

thanks for the opportunity,

Eric 376°9607

From: Frazier, Thomas (DOH) [rnailto:Thomas.Frazier@DOH.WA.GOV] Sent: Tuesday, Affgust 30, 2016 3:01 PM

To: Fau_st, Eric T <Eric.Faust@rl.doe.gov>; Karschnia, Paul T <Paul_T_Karschnia@rl.gov> Cc: Schmidt, John <john.schmidt@doh.wa.gov>

Subject: Informal Drafts ofTransuranic Waste Retriev_al Project Licenses NOCs 1035 to 1040

Eric and Tad,

Here are informal drafts of the Licenses for the TransuranicWaste Project emission units for your review and comment.

Sincerely,

Tom 946-0774

I

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Emission Unit ID: 1327

200W 296-P-52 Next Generation Retrieval (Active) This is a MINOR. ACTIVELY Vtnlilalcd emission Unit.

TRU Waste ~-~lri_cv_al

Emission Unit Information

Stack Height: 3.00 ft. 0.91 m. Stack Diameter 0.66 ft.

Average Stack Effluent Temperature: _degrees Fahrenheit. degrees Celsius.

Average Stack ExhaustVelocity: ft/second. m/second.

Abatement Technology ALARACT WAC 246-247-040(4)

state only enforceable: WAC 246-247-010(4), 040(5), 060(5)

Zone or Area Abatement Technology Required# of Units

Con_trolled work area Prefilter

C6ntrolled work_ area l_s_t Stage I:IEPA Fi_l_ter

C_ontrolled work area 2_n_d Stage H_E_PA Fi_lter

Monitoring Requirements

0.20 m.

Additional Description

Aerosol tested annually to 99.95% removal of a particulate with a median diameter of0.7 micron.

Aerosol tested annually to 99.95% removal ofa particulate with a median di_arnete_r of O. 7 micron.

Aerosol tested annually to 99.95% removal ofa particulate with a median d_i_arnet,;r of0.7 micron.

sta_te e_nforceable: WAC 246-247-040(5), 060(5), and federally enforceable: 40 CFR 61 subpart H

Federal and State Regulatory

40 CFR 61.93(b)(4)(i) & WAC 246-247-075(2)

Monitoring aitd Testing R~<juirernents

40 CFR 61, Appendix B Method 114

Ra:dion_u_clides Requiring Me3sllre·me0:t - .

All radionuclides which could contrib_ute I 0% of the potential TEDE.

Sampiing Frequency

Once per month a"rjyt_in:ie 'it is op-~ra_t~d

Sampling Requirements Destructive Examination (DE) of the filters. Daily sampling of the access doors when exhaust system is shut down with inventory inside ·

Acldftional Requirements

Additi_onat moni_toring or·sam·Plin9 requirement~ established by this Lic·en·se will be listed in the Conditions and Limitations section. if applicable.

Operational Status Activities for the TRU retrieval project support decontamination and decommissioning operations at the Hanford Site.

This Emission Unit has 2 active Notice(s) of Construction.

Project Title '

Approval# Date Approved NOCjD Operation of the Transuranic Waste Retrieval Project (Replaces NOC 804) Not Approved I 040

Conditions (state only enforceable: WAC 246-247-040(5), 060(5) if not specified)

I) The total abated emission fimit for this Notice of Construction is limit_e_d to l .OO!o-0 l mrem/year to the

Maximally Exposed lndividual (WAC 246-247-040(5)).

2) This approval a:p-plies to those additional activities describe_d be_low. No a_ddit_ional activities or variations on

the approved activities that constitute a "modification" to the emission unit, as defined in WAC 246-247-

030(16), may be conducted.

Transuranic waste retrieval involves the processes for ·removing and dis·posit_ioning buried suspect transura_nic rnix_ed.low-level radioactive waste (hereafter called TRU waste) from Hanford Site burial trenches for storage or disposal at oth~r ~pproved locations. Dispositioning is the orderly administration and hand.ling of waste

Page 1 of 6 for EU_ID 1327

(including contaminated soil) from the low level burial grounds to place it in approved storage or disposal status. The handling includes such actions as: packaging, labeling and tracking waste; venting, assaying, arid staging waste; inspecting waste and waste staging areas; sampling/characterizing/designating waste; making arrangements for the transfer of waste; completing necessary paperwork; and performing radiological and/or industrial hygiene surveys. The containment system associated with this approval is Emi n Unit 1327, Next Generation Retrieval (NG •

<

See the following emission units for a detailed description of additional controls/conditions and limits under this approval: ~ _,,,,,_;;

EU 455 HEPA Vacuums EU 486 200 Area Diffuse/ Fugitive; Operation of the Transuranic Waste· Retrieval Project EU 755 Mobile Drum Venting System (Active Ventilation) (MDVS) EU 756 Mobile Drum Venting System (Passive Ventilation) (MDVS) EU 1181 Categorical Drum Venting System 2 (DVS2) EU 1322 · Portable Enclosure System# l (PES) 1 EU 1326 Vapor Extraction System (VES) -• OW · EU I 327 Next Generation Retrieval (NGR) ____.,.- 157'-'""" v

3) The PTE for this project as determined under WAC 246-247-030(2 l )(a-e) [as specified in the application] is 9.20E+00 mreril/year. Approved are the associated potential release rates (Curies/yea·r) of:

Am - 241 8.30E+00 Liquid/Particulate Solid Alpha release rate based on Am-241 + Progeny. It is recognized that other radionuclides may be present in very limited quantities.

Cs - 137 1.60E+00 Liquid/Particulate Solid Beta/Gamma release rate based on Cs-137 + Progeny. It is recognized that other radionuclldes·may be present in very liri1it8d quantities.

The radioactive isotopes identified for this emission unit are (no quantities specified):

Am - 241 Am - 243 Cf - 252 Cm - 244 Cs - 134

Cs - 137

Pu - 241

U- 238

Eu - 152 .

Sr- 90

Eu - 154

U -234

Pu - 23_8

U -235

Pu - 239/240

U -236

The potential release rates described in this Condition were used to determine control technologies and monitoring requirements for this approval. DOE must notify the Department of a "modification" to the emission unit, as defined in WAC 246-247-030(16). DOE must notify the Department of any changes to a NESHAP major emission unit when a specific isotope is newly identified as contributing greater than lo% of the potential TEDE to theMEl, or greater than 25% of the TEDE to the MEI after controls. (WAC 246-24 7-110{9)) DOE must notify the Department of any changes to potential release rates as required by state or federal regulations including changes that would constitute a-significant modification to the Air Operating Permit under WAC 173-401 -72_5(4). Noti_ce will be provided according tot.he particular regulation under which notification is required. lfthe applicable regulation(s) does not address manner and type of notification, DOE will provide the Department Wi_t_h advan_ce writ_ten notice by letter or elec_tronic mail but not solely by copies of documents. c,\

4) CONTAMINATION CONTROi!- NGRIPES .l!ctivities Activities done under confinement structure of PES and NGR will be considered to be diffuse and fugitive activities unless under active ventilation conditions. (WAC 246-247-040(5) and WAC 246-247-060(5))

5) CONTAMINATION CONTRO~oil temoval, 1:.ontainer _bandling Both Alpha and beta-gamma contamination field-surveys shall be performed for all removable contamination surveys, prior to and during soil removal (excluding overburden removal) and overpacking activities and when pl_acing degraded outer cont_ainer contents into replacement containers. Alpha surveys alone shall be performed for direct readings of container surfaces. Beta/gamma direct readings are influenced by container contents, so are not as useful and are not required.

1 (WAC 246-247-040(5) arid WAC 246-24.7-060(5))

6) CONTROL TECHNOLOG~gperational jOnditioris _ When operating the NGR containment system, an in-li_ne demister and in-l_ine heati_ng system must both be in operation upstream of the HEPA filters. (WAC 246-247-040(5) and WAC 246-247-060(5))

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7) PROCESS DESCRIPTICJ!l!:XCA V ATIQN AND RE I KIE~LD"F CONTAINERS) This approval applies to these additional activities described below. No additional activities or varim_ions on the approved activities that constitute a "modification" to the emission unit, as defined in WAC 246-247-030(16), may be conducted.

Work will be performed in accordance with as low as re_asoriably achievable (ALARA) requirements as determined . _tf:, by the Radiological Control organization. W --one type of configuration is a V notched trench, cont_ainers in some trenches may not have been stack~ or placed

in any orderly manner for burial. The specific steps or approach to uncovering the container~ will vary according to the configuration of the trench to be uncovered, the type of con_t_ainers to be retrieved, the proximity of nearby trenches or fences, the designated location of the spoils pile, the planned extent of the soil removal, and other considerations.

1( ~ Work to be performed within some trenches may be performed within a weather resistant structure(s) that will be re-locatable along the trench. Weather enclosures are effec_tively used for similar remediation activities at other U.S. Department of Energy (DOE) sites and in general industrial use. Experience during retrieval activities has shown that operational efficiencies can be improved if the operations are protected from impacts d_ue to weather such as wind, rain, snow, and temperature extremes. The use of a weather resistant enclosure could allow a mC\re effective

~l recovery from events involving degraded containers and potential contamination spreads. ---.Prior to and during overburden removal, subsurface surveys such as !,>round penetrating radar, electromagnetic

inductance, and magnetometer are performed. These surveys provide information regarding container depth, configuration, type, and condition. They may also identify and locate underground obstructions. ,< "--.. . The overburden soil will be removed to expose the waste containers. Excavation equipment will be chosen to effectively remove soil and retrieve the waste containers while minimizing damage to the containers. Excavation activities will be monitored to ii:lentify contamination that might be present and to implement controls to minimize em1ss10ns. The most efficient methodology for removing the uncontaminated overburden from the containers will include the maximum use of conventional methods such as excavators, backhoes, front end loaders, brooms (boom mounted), or manual digging with shovels and similar hand tools. To excavate contaminated soil, hand tools p:Ced_ominantly will be used. Remotely-operated vehicles may be used to minimize personnel exposure in areas where high radiological and/or chemical hazards are discovered or anticipated. High efficiency particulate air (HEPA) filtere_d vacuums may be used for soil excavation for this application. Spot c~nta · tion removal will be done in accordance with the HEPA filtered vacuum unit (HVU) NOC (DOE 97 50, adioactive Air Emissions No_tice of Construction for HEPA Filtered Vacuum Radioactive Air Emission ms, as amended). Within the V }Yotched trenches, it is more likely that the use of a HEPA-filtered vacuum to remove larger quantities of soil from the top surface of buried containers and soil materials in the interstices surrounding containers·will be employed. Any use

,, _ of the sitewide HVU will be performed under the NOC applicable to the unit. An estimated 300 cubic meters of soil at contamination detection levels occupies the void spaces between the

"-· ,containers buried in the trenches. Excavation activiti_e_s will be controlle_d closely. Heavy equipment, hand tools, light equipment, or HVUs will be used to complete the soil removal operations and to access and remove the plastic and plywo_od materials coverin·g

1, __!he containers. All containers will b_e inspected to verify integrity. The container inspection will c_onsis_t of a visual examination to determine if there are significant indications of corrosion, holes, dents or other visual deformities. All containers could be moved, turned, or otherwise reloc·ated (manually or with powered equipment, sfings, clamps, or

,, ~ appropriate rigging) to facilitate an adequate visual inspection. The exposed containers will also be visually inspec_ted and surveyed for contamination. Externally contaminated containers will have fixative applied or will be decontaminated. Containers may also be bagged or overpacked as needed. Overpacking means placing containers within a larger closed containe_r. Bulging or potent_ially pressurized

,, '---- containers will be vented as described in NOC 486,~ondition 16, VENTING OF CONTAINERS. Severely degraded containers will be repackaged orin-situ grouted. Repackaging means transferring the contents of a degraded container into a new container or containers. The entire contents of the container will not be sorted but will be placed into the new container or containers through the use of slings, clamshell e·xcavators, manual labor, or

\I ...___the best available method that minimizes potent_ial emissions. Repackaging may include size reduction. Size reducing, cutting or disassembling material and equipment.may be required to ensure personnel safety and/or more economical was_te packaging. The process will include mechanical cutting techniques such as low speed sawing, drilling, snipping, and shearing .. The process will also include

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bending and crimping to preclude the need for cutting operations where possible. /Containers may include but are not.limited to drums, metal boxes, concrete boxes, fibe"rglass reinforc_ed boxes,

/I culverts, and sealed gloveboxes. 1, -----In-situ grouting will involve grouting around and/or throughout the waste, such that the entire waste container can

be re.moved as a monolith. Retrieval activities will include appropriate disposition of small amounts of incidental contaminated soil (e.g., containerized or fixed in place). Larger areas of contamin·ation could be fixed and the area posted as required by the Radiological Control organization for later disposition. Bulk transfer of contaminated soils for disposal also could occur.

---Some containers will be assayed and, if they assay as TRU waste, they may be further examined to detennine whether they contain items prohibited from disposal at the Waste Isolation Pilot P·lant (WIPP). Any prohibited items will be removed at a later date. Unvented TRU waste containers may be staged for venting in the burial grounds or may be moved to the Central Waste Complex (CWC) or another treatment, storage or disposal (TSO) site for venting.

----7i. number of retrieved containers are in good condition but are not vented. Although not technically meeting t_he definition of'sealed' containers, Washington State Department of Health (WDOH) has recognized these as closed containers such that potential emissions from these non vented containe"rs nee_d not be inclu_ded so far as potential emissions specific to waste during removal from the trenches. Once vented, the containers are included for calculating release rates in NOC 486,~ondition 4.,ST AGING OF RETRIEVED CONTAINERS for staging and ha_ndling operations. An estimated annual maximum of 15,200 vented containers ofwaste will be managed during the peak years of this project. ~ .

Containers may be staged in the burial grounds pending further processing or transfer. Waste containers are considered retrieved once transferred to an approved TSO facility. (WAC 246-247-040(5) and WAC 246-247-060(5))

8) PROCESS DESCRIPT!Ot[@:xr GENERATION RETRIEVAL (NOR), This approval applies to these additional activities described below. No additional activities or variations on the approved activities that constitute a "modification" to the emission unit, as defined in WAC 246-24 7-030(16), may be conducted.

NOR activities will consist of removal of containers, primarily drums but also boxes, from the burial grounds and venting the TRU waste containers using the Dart process. Bulging drums mili'..Sf -::eQfeil!~iJl~ID'~·nio,.J -Excavation, assay, and inspection activities will be the same as described in'J:X~AVAtIDN AND'RETIUEV AL OF CONTAINERS. TRU waste containers will be separated from low-level waste (LLW) containers during the NOR retrieval and characteriiation process. NOR containers that assay as LLW will not be routinely vented. The retrieved co:l}Wi12Jf3,ln!tl' require overpack:ing or repackaging. Overpacking is expected to be perfonned as described i~ROCESS1>ESCRIPTION: EXCAVATION AND RETRIEVAL OF COl',[l:AR,JERS. Many of the containers (approximately 250/yr) are expected to be so severely degraded that they carinot be overpacked. Their contents will be repackaged, as described in PROCESS DESCRIPTION: EXCAYATJON AND RETRIEVAL OF

" ~S. Venting of containers will also occur as described in PROCESS DESCRIPTION: Vt;:_NTING OF ~~ CONTAINERS. .. ~- An exhaust system (NOR containment system or PES) may be used for NOR container retrieval activities based on

the controls established within Emission Unit 1327 Next Generation Retrieval,, (WAC 246-247-040(5) and WAC

I'

246-247-060(5)) ~::=-=----------------9) ABATEMENTTECHNOLOG'i(: E:XCA VA TION AND RETRIEVAL OF CONT AINERSl

The administrative control points set m this emission umt tor contamination, as monitored by standard radiological field _instrumentation, will be used to bound emissions based on current efficiencies of typical RadCon field contamination instruments. - --- - .

The controls listed witrun this approval apply to TRU Waste Retrieval Project open air excavation and retrieval activities. (WAC 246-247-040(5) an_d WAC 246-247-060(5))

I 0) ABATEMENTTECHNOLOG)[NGR CONT AINMENTj The controls des_cribed below will be used for NOR containment system exhaust. The greenhouse design oftrus unit will incorporate an engineered active ventilation system to reduce to acceptable levels and minimize the risk of a radionuclide airborne discharge to the orisite or offsite environment during any retrieva_l operation.

---Y,he annual average volumetric flow rate through the intennittently operated NOR containment system exhauster is 0.47 cubic meters/sec (1000 cfril) providing up to 27.8 air exchanges per how within the greenhouse. Ventilation for trus NOR containment system will include greenhouse inlet filters, pressure control flaps, an inlet demister pad with a collection sump located inside the greenhouse, a heater unit, two (2) exhaust HEPA filters (1st and 2nd

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s_tage), downstream ducting, a downstream flow control damper, and an exhaust fan. Each HEPA filter stage will provide an in-place testable ·efficiency of at least 99.95% for removal of test aerosol particula_te with a median diameter of 0. 7 micron. The exhaust duct is 8 inches in diameter and will exhaust at least 3 feet above grade. When the NGR containment system is in use (with personnel inside and working with waste) the active ventilation system will be in operat_ion. During ventilation system operation, airflow into this containment system will be through 30% efficient inlet filters. Containment tent pressure will be controlled with simple flaps that will c_over these filters. The demister and heater unit will prevent water buildup on the HEPA filters and allow operation when the humidity is above 70% relative humidity and/or when misting is used during retrieval opera_tions to control contamination spread. (WAC 246-247-040(5) and WAC 246-247-060(5))

WDOH NOTIFICATION - Implementing PES or NGR ,:.ontainment During h_igh hazard work activities, removable surface contamination is maintained less than 2,000,000 dpm/100 cm"2 alpha and/or less than 4 rad/hr/100 crn"2 beta-gamma, limited to a I ft"2 area. For an allowed increase in contaminated area footprint of 4 ft"2 the limiting condition for removable contamination will be 500,000 dpm/100 cm"2 alpha and or lrad/hr/100 cm"2 beta-gamma. Exceeding any of these contamination limits wffl require work to stop, and notification to Operation and RadCon management in accordance with the R WP. Notification to WDOH via email or the established procedures in the Environm~ntal Notification program \Viii b_e required. For work to cont_inue above any of these limiting radiological conditions, the NGR containment system or the PES and commensurate controls will be implemented .. The NGR c~mtainment or PES exhaust system will be utilized to minimize the potent_ial for contaminat_ion spreads outside of posted radiological areas. (WAC 246-247-040(5) and WAC 246-247-060(5)) 4 AL TERNATNE APPROV Aff- Destructive Examination Approval is given for alternative flow monitoring and sample extraction method for the NGR and PES. Destructive Examina_tion (DE) of the final stage HEPA filter of the PES or NGR containment, which will be performed once per calendar year any time the system is used within the calendar year. This authorization will remain in force for t_hree years from the date of issue of the license, additional extensions on the life of the system will require installation of continuous flow measurement and.sample extraction in accordance with ANSI/HPS NI 3.1-1999. (WAC 246-247-040(5), WAC 246-247-060(5), WAC 246-247-075(4))

ALARACT APROV Aiff ~ontairier ,ll.andling . The process for handling ofabnonnal or severely degraded containers as described in PROCESS DESCRIPTION: EXCA V t,J]QN AND RETRIEVAL OF CONTAINERS, for bagging, overpacking, placing degraded outer

~container contents into replacement containers or in-situ grouting is approved as meeting ALARACT, and these processes and associated records and procedures will be subject to inspection upon request by the department_. (WAC 246-247-040(5) and WAC 246-247-060(5))

>P CONTAMINATION CONTROi!- daily ~urveys When exhaust system is shut down with inventory inside the NGR or PES, radiological control technicians will perform daily radiological swipe surveys on the access doors to the PES or NGR during normal work days. (WAC 246-247-040(5) and WAC 246-2;Zt060(5)) , ...,__

COl<ITA.'V!!NATION CONfROt- daily surveys l:>t,.,p O ~ "" " ' W!Jen_exba:wt system is shat down with inventory inside the NGR or PES, radiological control technicians will perfonn daily Faaiologieal s· .. ipe-sm vcys un the access doors to the PES or NGR during normal work days. (WAC

'"2~-247-04D(S) anti WAC 246-247-060(5))

CONTAMINATION DOCUMENTATION - Exposed _Eackages During repackaging activities (i.e., when transferring tne coriterits ofa degraded container into a new container or containers) an operations log will be kept noting conditions of the transferred contents/packages.jR.adCon will generate and retain radiological records documenting air sample results and removable contamination cond_it_ions during retrieval of each container. (WAC 246-247-040(5) and WAC 246,24 7-060(5))

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i

Emission Unit ID: 1327

200W 296-P-52

Next Generation Retrieval (Active) This is a MlNOR, ACTIVELY ventilated einission unil.

TRU Waste Retrieval

Emission Unit Information

Stack Height: 3.00 ft. 0.91 m. Stack Diameter 0.66 ft.

Average Stack Effiuent Temperature: degrees Fahrenheit. degrees Celsius.

Average Stack ExhaustVelocity: ft/second. m/second.

Abatement Technology ALARACT WAC 246-247°040(4) .

state only enforceable: WAC 246-247,010(4), 040(5), 060(5)

Zone or Area Abatement Technology Required# of Units

Controlled wo.rk area Prefil_ter

Controlled work area I st Stage HEP A Filter

Controlled work area 2nd Stage HEPA Filter

Monitori_ng Requirement_s

0.20 m.

Additional Description

Aer~sol tested annually to 99.95% removal of a particlllate with a median diameter of 0.7 micron.

Aerosol tested annually to 99.95% removal of a partic_ula_t_e with a mec.fiar:i diam·e_t_e·r Of 0. 7 micron.

Aerosol tested annually to 99.95% removal of a particulate with a median diameter of 0. 7 micron.

state enforceable: WAC 246-247-040(5), 060(5), and federally enforceable:.40 CFR 61 subpart.H

Federal and State Regulatory

40 CFR 6 I.93(b)(4)(i) & WAC246-247:075(2)

Monitoring and Testing Requirements

40 CFR 61, Appendix B Method I 14

Radionuclides Requiring Measurement

All radionuclides which could contribute' 10% of the potential TEDE.

Sampling Frequency

Once per month anyti_me it is operated

Sariipling Requirfments Destruct,i\le Exa)p.i.riation (DE) of the fiJters. Daily sampling ofth~ access doors whei:i exhaust system. is sh_ut down With·inventory inside

Additional Roqulroments

Ad~ition81 n:ionitoring or s8mp_lirig r~quirEtiiients e·sta!)lished bY this" Li1?3nse ""'.ill b·e list!3d in the COnditionS an·d Limitations section, if applicable.

Operational Status Activities for the TRU retrieval project suppon decontamination and decommissioning operations at the Hanford Site.

This Emission Unit has 1 active Notice(s) of Construction.

Project Title Approval# Date Approved NOC_ID Next Generation Retrieval (Active) Operation (Replaces NOC 804) Not Approve_d

Cond_itions (state only enforceable: WAC 246~247-040(5), 060(5) if not specified)

]) The total abated emission limit for this Notice of Construction is limited to 9.40E-05 mrem/year to the Maximally Exposed Individual (WAC 246-247-040(5)).

1040

2) This approval applies to those addition·a1 activities described below. No additional activities or variations on the approved activities that constitute a "modification" to the emission unit, as defined in WAC 246-247-030( 16), may be conducted_.

Transuranic waste retrieval involves the processes for removing and dispositioning buried suspect transuranic mixed low-level radioactive waste (hereafter called TRU waste) from Hanford Sit!' burial trenches for storage or disposal at other approved locations. Dispositioning is the orderly administration and handling of waste.

Page 1 of 5 for EU_ID 1327

(inclu_ding contaminated soil) from th_e low level burial grounds to pla_ce it in approved storage or disposal_ status. The handling include h actions as: packaging, labeling and tracking waste; venting, assaying, and

t and waste staging areas; sampling/characterizing/designating waste; making fwaste; completing necessary paperwork; and performing radiological and/or

EU 755 EU 756 EU I 181 EU 1322 EU 1326 EU 1327

Mobile Drum Venting System (Active Ventilation) (MDVS) Mobile Drum Venting System (Passive Ventilation) (MDVS) Categorical. Drum Ven ting System 2 (DVS2) Portable Enclosure System # I (PES) Vapor Extraction System (VES) Next Generation Retrieval (NGR)

3) The PTE for this project as determined under WAC 246-247-030(2 l)(a-e) [as specified in the application] is l.90E­O I mrem/year. Approved are the associated potential release rates (Curies/year) of:

Am - 241 3.10E-02 Liquid/Particulate Solid Alpha release rate based on Am-241 + Progeny. It is recognized that other radionuclides may be present in very limited quantities.

Cs - 137 4:70E-01 Liquid/Particulate Solid B.eta/Gamma release ~ate based on Cs-137 + Progeny. It is recognized that olher radionudides may be present in very limited quantities.

The radioactive isotopes identified for this emission unit are (no quantities specified):

Am - 241 Am - 243 Cf - 252 Cm - 244 Cs - 134

Cs - 137

Pu - 241

U-238

Eu - 152

Sr-90

Eu - 154

U -234

Pu - 238

U_-235

Pu - 239/240

U-236

The potential release rate_s described in this Condition were used to determine control technologies and monitoring requirements for this approval. DOE rriust notify the Department of a "mo.dification" to the emission unit, as defined in WAC 246-247-030(16). DOE must notify the Department of any changes to a NESHAP major emission unit when a specific isotope is newly identified as contributing greater than 10% of the potential TEDE to the MEI, or greater than 2_5% of th_e TEDE to the MEI after controls. (WAC 246-247-110(9)) DOE must notify the Department of any changes to potential release rates as required by state or federal regulations including changes that would constitute a significant modification to the Air Operating Permit under WAC 173-401-725(4). Notice will be provided according to the particular regulation under which notification is required. lfthe applicable regulation(s) does not address manner and type of notification, DOE will provide the Department with advance written notice by letter or electronic mail but not solely by copies of documents.

4) CONTAMINATION CONTROL - NGR Activities Activities do"ne und_er confinement structure of and NGR wi[I be considered to be diffuse and fugitive activities unless under active ventilation conditiont)(W AC 246-247-040(5) and WAC 246-247-060(5))

5) CONTAMINATION CONTROL - Soil Removal, Container Handling Both Alpha and beta-gamma contami_nation field surveys shall be performed for all removable contamination surveys, prior to and during soil removal (excluding overburden removal) and overpacking activities and when pl_acing degraded outer container contents into replacement comainers. Alpha.surveys alon_e shall be performed for direct readings of container surfaces. Beta/gamma direct readings are influenced by container contents, so are not as useful and are not required. (WAC 246-247-040(5) and WAC 246-247-060(5))

6) CONTROL TECHNOLOGY - Operational Conditions When operating the NGR containment system, an in-line demister and in-line heating system must both be in operation upstream of the HEPA filters. (WAC 246-247-040(5) and WAC 246-247-060(5))

7) PROCESS DESCRIPTION - Excavation and Retrieval of Containers Page 2 of 5 for EU_ID 1327

•

This approval applies to these additional activities described below. No additional activities or variations on the approved activities that constitute a "modificatio.n" to the emiss.ion unit, as defined in WAC 246-247-030(16), may be conducted.

Work wffl be performed in accordance with as low as reasonably achievable (ALARA) requirements as determined by the Radiological Control organization. One type of configuration is a V notched trench, containers in some trenches may not have been stacked or placed in a:ny orderly manner for burial. The specific steps or approach to uncovering the containers will vary according to the configuration of the trench to be uncovered, the type of containers to be retrieved, the proximity of nearby trenches or fences, the designated.location of the spoils pile, the planned extent of the soil removal, and other considerations.

Work to be performed within some trenches may be performed within a weather resistant structure(s) that will be re­locatable along the trench. Weath_er enclosures are effectively u_sed for similar remedia.tion activities at other U.S. Department of Energy (DOE) sites and in general industrial use. Experience during retrieval activities has shown that operational efficiencies can be improved if the operations are protected from impacts due to weather such as wind, rain, snow, and temperature extremes. The Lise of a weather resis.tant e.nclosure could allow a more effective recovery from events involving degraded containers and potential contamination spreads.

Prior to and during overburden removal, subsurface surveys such as ground penetrating radar, electrom.agne.t_ic inductance, and magnetometer are performed. These surveys provide information regarding container depth, configuration, type, and condition. Th.ey may also identify and locate underground obstructions.

The overburden soil will be removed to expose the waste containers. Excavation equipment will be chosen to effect_ively remove soil and retrieve the waste containers while minimizing damage to the containers. Excavation activities will be monitored to identify contamination that might be present and to implement controls to minimize emissions.

The most efficient methodology for removing the .uncontaminated overburden from the containers will include the maximum use of conventional methods such as excavators, backhoes, front end loaders, brooms (boom mounted), or manual digging with shovels and similar hand tools. To excavate conta112inated soil, hand tools predominantly will be used .. Remotely-operated vehicles may be used to minimize personnel exposure in areas where high radiological and/or chemical hazards are discovered or anticipated. High efficiency particulate air (HEPA) filtered vacuums may be used for soil excavation for this applica · . pofeon_taminat1orn-eipoval wiil be done in · accordance with the.HEPA filtered vacuum':!).. ) NOC (DOE/RL-97-5q) Radioactive Air Emissions Notice of Construction for HEPA Filtered Vacuyni"Ra · · · · · ~ended). Within the v{flotc~~ trenches, it is more likely that the use ofa HEPA-filt<,red vacuum to rem.ave larger quantities of soil from t_h~op surface of buried containers and soil materials in the interstices surrounding containers will be employed. Any use of the sitewide HVU will be performed under the NOC applicable to the unit. ·

An estimated 300 cubic meters of soil at contamination detection levels occupies the void spaces berween the containers buried in the trenches. Excavation activities will be controlled closely. Heavy equipment, hand tools, light equipmeni: or HVUs will be used to complete the soil removal operations and to access and remove the plastic and plywood materials covering the containers.

All comainers will be inspected to verify integrity. The container inspection will consist of a visual examination to determine if there are.significant indications of corrosion, holes, dents or other visual deforrnities . .AII containers could be moved, turned, or otherwise relocated (manually or wi.th powered equipment, slings, clamps, or appropriate rigging) to facilitate an adequate visual inspection:

The expose.d containers wiB also be visually inspected and surveyed for contamination. E~temally contaminated containers will have fixative applied or will be decontaminated .. Containers may also be bagged or overpacked as needed. Overpacki_ng means placing containers within a larger closed container. Bulging or potentially pressurized

Page 3 of 5 for EU_ID 1327

containers will be vented/ Jt, ~ · , ' .(l9i ti ... N Y;,,;,. cf'v

Severely degraded containers wiH be repackaged or in-situ grouted. Repackaging means transferring the contents of a degraded container into a new container or containers. The entire contents of the container will not be sorted but will be placed into the new container or containers through the use of slings, clamshell excavators, manual labor, or the best available method that minimizes potential emissions.

Repackaging may include size reduction. Size reducing, cutting or disassembling material and equipment may be required to ensure personnel safety and/or more economical waste packaging. The process will include mechanica_l cutting techniques such as low speed sawing, drilling, snipping, and shearing. The process will also include bending and crimping to preclude the need for cutting operations where possible.

Containers may include but are not limited to drums, metal boxes, concrete boxes, fiberglass reinforced boxes, culvens, and sealed gloveboxes.

In-situ grouting will involve grouting around and/or throughout the waste, such that the entire waste container can be removed as a m:onoiith. Retrieval activities will include appropriate disposition of small amounts of incidental contaminated soil (e.g., containerized or fixed in place). Larger areas of contamination could be fixed and the area posted as required by the Radiological Control organization for later disposition. Bulk transfer of contaminated soils for d·isposal also could occur.

Some containers will be assayed and, if they assay as TRU waste, they may be further examined to detennine whether they crin_tain items prohibited from disposal at the Waste Isolation Pilot Plant (WIPP). Any prohibited items will be removed at a later date. Un vented TRU waste containers may be staged for venting in the burial grounds or may be moved to the Central Waste Complex (CWC) or another treatment, storage or disposal (TSO) site for venting.

A number of retrieved containers are in good condition but are not vented. Although not technically meeting the definiticin of'sealed' containers, Washington State Department of Health (WDOH) h_as recognized these as closed containers such· that potential emissions from these non vented containers need not be included so far as potential emissions specific to waste during removal from the trenches. Once vented, the containers are included for · calculating release rates for staging and handling ciperations. An estimated annual maxim.um of 15,200 vented containers of waste will be managed during the peak years of this project.

Containers may be staged in the burial grounds pending further processing or transfer. Waste con_tainers are considered retrieved once transferred to an approved TSO facility. (WAC 246-247-040(5) and WAC.246-247-060(5))

8) PROCESS DESCRIPTION - Next Generation Retrieval (NGR) This approval applies to thes_e additional activities described below. No additiona_l activities or variat_ioris on the approved activities that constitute a "modification" to the emission unit, as defined in WAC 246-247-030( I 6), may be conducted.

NGR activities will consist of removal of containers, primarily drums but also boxes, from the burial grounds and oS venting the TRU waste containers using the Dart process. Bulging drums may be vented using the DVS2. c,..J/1--C,..~ Excavation, assay, and inspection activities will be the same as described in £>_ndition 9, Process Description -EXCAVATION AND RFTRIFV AL OF CONTAINERS. TRU waste containers will b_e separated from low-level waste (LL W) ·containers during the NGR retrieval and characterization process. NGR containers that assay as LLW will not be routinely vented. The r~trieved containers may require overpacking or repackaging. Overpacking is . ~t l expected to be perfonned as descnbed m ~ndit10n 9, PROCESS DESCRIPTION<-EXCA VA TION AND _,,a c:z&L.~5 RETRIEV Al QF CONTAINERS. Many of the containers (approximately 250/yr) are expected to be so severely degraded that they carinot be civerpacked. Their contents will b_e repackaged, as described in PROCESS DESCRIPTION;.EXCA VA TION AND RETRIEVAL OF CONTAINER~ Venting of containers will also occur as described in PROCESS DESCRIPTI()N;..VENTING OF CONTAINERS. r,..~S"

- An exhaust system (NGR containment ·system or PES) may be used for N R comainer retrieval activities base_d on the controls established within Emission Unit 1327 Next Generation Retri"ev'$<WAC 246°247-040(5) and WAC 246-247-060(5)) ·

9) ABATEMENT TECHNOLOGY - Excav.!'tion and ~etrieval of Containers The administrative control points set in this emission unit for contamination, as monitored by standard radiological

Page 4 of 5 for EU_ID 1327

field instrumentation, will be used to bound emissions based on current efficiencies of typical RadCon field contarilination instruments. The controls listed within this approval apply to TRU Waste Retrieval Project open air excavation and retrieval activities. (WAC 246-247-040(5) and WAC 246-247-060(5))

I 0) . ABATEMENT TECHNOLOGY - NGR Containment The controls described below will be used for NGR containment system exhaust. The greenhouse design of this unit will incorporate an engineered active ventilation system to reduce to acceptable levels and minimize the risk of a radionuclide airborne discharge to the onsite or offsi_te environment during any retrieval operation.

The annual average volumetric flow rate through the intermittently operated NGR containment system exhauster is 0.47 cubic meters/sec (l000 cfm) providing up to 27.8 air exchanges per hour within the greenhouse. Ventilation for this NGR containment system will include greenhouse inlet filters, pressure control flaps, an inlet demister pad with a collection sump located inside the greenhouse, a heater unit, two (2) exhaust HEPA filters (1st and 2nd stage), downstream ducting, a downstream flow control dampe_r, and an exhaust fan. Each HEPA filter stage will · provide an in-place testable efficiency of at least 99.95% for removal of test aerosol particulate with a median diameter of 0. 7 micron. The exhaust duct is 8 inches in diameter and will exhaust at least 3 feet above grade. When the NGR containment system is in use (with personnel inside and working with waste) the active ventilation system will be in operation. During ventilation system operation, airflow into this containment system will be through 30% efficient inlet filters. Containment tent pressure will be controlled with simple flaps that will cover these filters. The demister and heater unit will prevent water buildup on the HEPA filters and allow operation when the humidity is above 70% relative humidity and/or when misting is used during retrieval operations to control cont_amination spread. (WAC 246-247-040(5) and WAC 246-247-060(5))

I I) WDOH NOTIFICATION - Implementing NGR Containment During high hazard work activities, removable surface contamination is maintained less than 2,000,000 dpm/100 cm"2 alpha and/orless than 4 rad/hr/l00 cm"2 beta-gamma, limited to a I ft"2 area. For an allowed increase in contaminated area footprint of4 ft"2 the limiting con_dition for removable contamination will be 500,o'0O dpm/100 cm"2 alpha and or lrad/hr/100 cm"2 beta-gamma. Exceeding any of these contamination limits will require work to stop, and notification to Operation and RadCon management in accordance with the RWP. Notification to WDOH via email or the established procedures in the Environmental Notification program will be required. For work to continue above any of these limiting radiological conditions, the NGR containment system or the PES and commensurate controls will be implemented. The NGR containment exhaust system will be utilized to minimize the potential for con_tamination spreads outside of posted radiological areas. (WAC 246-247-040(5) and WAC 246-247-060(5))

12) ALTERNATIVE APPROVAL - Destructive Examination Approval is given for alternative flow monitoring and sample extraction method for the NGR. Destructive Examination (DE) of the final stage HEPA filter of the NGR containment, wliich will be performed once per calendar year any time the system is used within the calendar year. This authorization will remain in force for three years from the date of issue of the license, additional extensions on the life of the system will require installation of continuous flow meas_uremen't and sample extraction in ac_cordance with ANSI/HPS NI 3.1-1999. (WAC 246-247-040(5), WAC 246-247-060(5), WAC 246-247-075(4))

13) ALARACT APROVAL - Container Handling The process for handling of abnormal or severely degraded containers as described in PROCESS DESCRIPTION,­

{'-0 ~ EXCAVATION AND RETRIEVAL OF CONTAINERS, for bagging, overpacking, placing degraded outer CJ>'\';) container contents into replacement containers or in-situ grouting is approved as meeting ALARACT, and these o:L\ processes and associated records and procedures will be subject to inspection upon request by the department.

(WAC 246-247-040(5) and WAC 246-247-060(5))

14) CONTAMINATION CONTROL- Daily Surveys When exhaust system is shut down with inventory inside the NGR, radiological control technicians will perform daily radiological swipe surveys on the access doors to the NGR during norrna_l work days. (WAC 246-247-040(5) and WAC 246-247-060(5))

15) CONTAMINATION DOCUMENTATION - Exposed Packages During repackaging activities (i.e., when transferring the contents of a degraded container imo a ryew con_tainer or containers) an operations log will be kept noting conditions of the transferred contents/packages .. RadCon will generate and retain radiological records documenting air sample results and removable contamination conditions during retrieval of each container. (WAC 246-24 7-040(5) and WAC 246-247-060(5))

Page 5 of 5 for EU_ID 1327

4

STATE OF WASHINGTON

DEPARTMENT OF HEALTH OFFICE OF RADIATION PROTECTION

309 Bratlley Blvd., Suite 201 • 1/ii:hlaij_d, Wishingto~ 99352

TDD ReLJy Service: 1-800-833-6388

November 17, 2016

CERTIFIED MAIL 7015 0640 0007 505.0 7821

Mr. Doug Shoop, Manager United States Department of Energy Richland ~tions Office · P.o: Boi_c 55,0, MSIN: A5.J4 Richland, Washington. 99352

Re: 28-i>ay Draft ApProval of Notice of Construction (NOC) I 040

L.8:#-4~_'17·

AIR 16-1109 NOC1040

Reference: ~i (LB# 4 7S I), froll). Joli:r) Sclm:tldt, (WDbH) to Multiple USDOE Staff, ''NOC Consolidation", dated June 30, 2016.

As ~ th~ ref~ce ell).a.H, we hiivi; wqr1c~ wi$ your staff to n:take changes to move the NOCs and/or Emission Units (EUs) associated with this license from a one-to-many, to a one-to-one relationship. We appreciate your cooperation and willingness to support our future database needs and to make license actions more efficient and cost effective moviilg forward.

Pursuailtto Chapter 246-247 of the W~l1.ingto1,1 A4nfuli~ve Code (WAC), the update will be approved a.cconling to tlte en_cl<>~ License for:

Nest Gen:eratioil Retrieval (Active) Operation (Replaces NOC 804) (EU 1327; NOC 1040)

The Washington State l)epartri:lent ofHeal!h (DOH) consjders tl!e conditions, e:ontrols, monitoring requirements, and limitations of the License integral to·approval of your application.

This approval shall take effect, and a fil1!ll approv~ letter is.sued, twenty-eight (28) days aji~ you receive this Jetter, unless you apply for an adjudicative proceeding, as described below.

If you accept the conditions aild limitations ofthis approval and do iiot wish to apply for. an adjwlicative proce¢ding, but wish to proce¢d.underthis approval before the 28 days have

Publ.i.c H.eaUh • Ah,,ays Working for a Safer and Healthier Washington

® . ..,., ..

Mr. Doug Sh<>0p November 17, 2016 Page 2 of3

AIRl6-1109

elaps~ please notify us in Wrttilig and the DOH will issue a final approval letter. Your nCltice should be mailed or flllCed to_: ·

DOH- Office of Radiation Protection Radioactive Air Emissions SectiCln 309 Bradley Blvd., Su.ite 20 I Ricllland, Washington 98352 FAX: (509) 946-0876

If there are concerns with the conditions and limitations of the approval,. please notify the DOH. If attempts ti> resolve the concerns fail, the DOH will deny your application and you may cCli:rtest the coildition:s and limitations of this approval, within 28 days of receipt, by filing the enc:losed Requ~ for Adju4i~tive Proceedillg or a docw:r,.ent providing substantially the same infotniation wi!l:i the D()H, Adjudicative Service Unit (ASU), in a manner that shows proof of service on the ASU. The ASU's address is:

DOH - Adjudicatiye Service Uiiit 31 0 ISl'.llel Roag $E P.O. Box 47879 Olympia, Washington 98504-7879

You must include a copy of this approval with your applicatiol)_. FIL_11'1G SJfAI;.L NOT BE DEEMED COMPLETE UNTIL THE ADJUDlCA TIVE SERVICE UNIT ACTIJALL Y RECEIVES YOUR APPLICATION. .

If.you have any questions regllidiilg ~ approval, piease coil.tact Mr. Thomas Frazier at thoinas.frazier@doh.wa.gov or by telephone~ (509) 946-0774.

Sin~ly,

w~r11;# P. Jol;ul M_artell, Manager Radioactive Air Emissions Section

En~l.osures: 1. Con~~O'lS and Liinitlltions for EU 1327 (NOC 1040) 2. Request for Adjudicative Proceedings

cc: (see next page)

Mr. Doug Shoop November 17, 20i6 Page 3 of3

cc: Ruth Allen, WRPS Mattl_lew Barni:#, PNNL Lilyann Bauder, Ecology Shawna Serven, wtx>H Lucinda Borneman, WRPS Lee Bostic, BNI Frank Carleo, CHPRC · CliffCl/ll:k, USDOE-RL Jack Donnelly, WRPS Dennis Faulk, EPA Eric Faust, USDOE-RL Tom Fi:azjer, WDOH G~ Fritz, MSJ\ Philip Gent, Ecology Daniel Heuston,.Ecology Reed Kaldor, MSA Palll ~a.J'.S!=llaja, GHPRC Ed M.l1-CA1ister; USDOE-RL Jiin McAilley, EPA Valarie Peery, Ecology JoAI1 Schmidt, Wf>OH Jeff Voogd, WRPS Pavis~~EPA Envirorui:u:n~ Portal RAES Tracking:. Line 16-153; EU 1327; NOC 1040

AIR16-1109

Eriii.ssiOQ Uni_t.II>: _1327

200W 296-P-52 Next Generation Retrieval (Active) 1ms is a MINOR. ACTIVE't Y vc:milated emission amt.

TRU ~uce .Reci;c:val

E_mlsslon Un.It lr,fom,atlon

Stack Height: 3.00 ft 0.91 m. Stack Diameter· 0.66 ft.

Av~e St~~ Effluent Tc:m~.re: dcgre:cs Faliri:l:,lieit. d~ Celsiu).

Average Stack ExhaustV~ocity: ft/second. m/sccond.

Abatement Technology ALARACT \VA<::246'247-040(4)

state only enforceable: INAC·246-247.-010(4), 040i5), 060(5)

Zone or Ana Abarement Tedmology Required # or un11s

C:O:ntrolled ,w,orlc area Prefilter

Controlled worlc area _1st Stage HEPA Filter

Controlled. worlc area 2rid Stage HEP A Filter

lillon.lt~ri.ng RequlremE1.nts

0.20 m.

Aerosol tested annually to 99.95% ~oval ofa iia.rticful.¥,C "1)h a l)!ediali di.~ctci' of 0. 7 micro:~. Aerosol tested armually to 99.95% removal of a particula!c with a =dian diameter of 0. 7 micron.

Aerosol tested annually 10

99.95.% removal.of a particulate with a median diaineter of 0. 7 micron.

state enforceable: WAC 246-247-040(5), 060(5), and federally enforce.able: 40 CFR 61 subpart H

federal ud·s1aee l\lomcortng amiTestlng Radlonucildei, Requiring !;:ampllng Regnlatory Reqlliremell.15 Measurement Freqnency

40 CFR 61.93{b)(4)(i) 40 CFR · 61, Appendix B All radionuclidcs which Otu:c.pcr month & WAC 246-247:.075(2) Method 114 could contribuie I0¾ofthe anytime it iso~~

potential TEDE.

Samj,Jl_ng Req~l5 Desfr.uct_ive E.xaJfii.riat_i!in (DE) of the ~l_ters. Qaily s;iriipling of the access doors :when ex.biiust systein. i.s sh.ut down wi_th inventory insi_c;le

Additional manltoririg or sampling requiremeri~ established tiy !his LJc:eri,;e wll(tie ll~ed In Iha ConillU?Jis ani:1 Umlljilkiris sectlcm, 11 eiii>!lca~.

Operational Status Activities for the TRU reiricval project support decontaminalion and decommissioning opcnitions at ·the Han(ord Site.

This Eml.ssloil Uti.~ ~~s 1 a~t.-e Notl.i:a(s) of Cp:ns.tructlon.

Project TIiie App_ro-val # Dale Approve_d NOC _ID Next Generalion Retrieval (Actiyc) Operation (Replaces NOC 804) N_ot Appmvcd

Conditions (state only enforcea~le: WA~ 246.247-040(~). 060(5) If not speclflec!) I) The total abated emission limit for this Notice of Constrw:_tion is iimitc:d 10 9.40E-05 mn:m/year to the

Maximally Exposed Individual (WAC.246-247-040(5)).

1040

2) This approval appl)es Ip those ,µlditional a~tjvities describt,d belcii(<'.. No additi<inal activities or variati~ns on the approved.activities that constitute·a ''modification"·to the emission unit, as defined in WAC-246-247-030( 16); may be conducted. . . . . ,· . . .. - . . . . ...

Trans~c waste retrieval invo_lves the processes for removing and dispositiorung buried suspect transuranic· mixed low-level radioactive waste (hereafter called TRU ..,aste) (mm Hanford Site bun.al trenchc:s for storage or disposal at othe,'approved locations. Dispositicining°is the orderly a_dmi,nisb1ltiol) and handling of waste

Page 1 ol 5 for EU _ID 1327

(m.~lu,dlng con~t¢ so{i) fro."1 the_ low :iev~l b!Jrl.al grounds to pl~j:e it in approved storage or disposal status. The handling includes such actions os: packaging, hibeling,and tracking waste; venting, assaying, iirid stsging waste; inspecting waste and waste staging areas;. sampling/characterizing/designating ·waste;. making arrangements for the transfer of waste; coml'leting necessary paperwork; and performing radiological and/or fodustri_al bygi_ene surveys .

.Sec. the following for a detailed description of specific corurols/conditfons for each EU associated with the Transuranic Waste Rettjeval Proj~t.: ·

EU455 EU 1440 EU 75_5 EU756 EU 118i EU 1322 EUl326 EU 1327

Hanford Sitewide w.PORTEX 007 200 Area Diffuse/ Fugitive; Operation oftlie Transuran{~ Waste Retrievai Project

Mobile Driirn Venting System (Active Ventilation) (MDVS) Mobile Drum Venting.System (Passive Ventilation) (MDVS) Categorical Dnim Venting Sys)em 2 (DVS2) Portable Enclosure System #I (PES) Vapor Extraction System (VES) Next Generation Retrieval (NGR)

3) The PT!, for this projC!'( l!S dett,n_tlll1.e,d un~ 'WAC 246-247-030(21)(~~) [as spec{fied in the ~pPl{cation] is (.90E­O I mrem/year. Approve<! are the asso_ciated potential release rates (Curies/year) of:

Am -241 ·3_.1 O.E~ U~uid/Particµla)e So_li_d Alpha release rate based on Am-241 + Pmgeny. It Is reoognlzed ttiat other radionudides riiay be piasent Iii very llmlbid <iusriUUes. . . . . . . . . .

Cs - 137 4.-70E-Cl1 Uquid/Partic:ula)e Solid Bela/Gamma release rats based en Cs-f37 + Progeny. It is rea,gnlZe<I Iha! ott,er radlonudides may be present in very limibid quantJUes.

The radioactive isotopes identified for this emission unit are (no quantities ~fied): _Am-241 Arn-243 Cl-252 Cm-244 Cs-134

Cs -137 Eu -152 Eu - 154 Pu - 238 Pu-239'240

Pu-241 Sr-9.0 U-234 U-235 U-236.

U-238

The potential release rates descn'bed in this Condition were used to determine control technologies and monitoring requirellien~ for this apl'roval_. DOE m_ust l)otify the Departmei:i~ ofa "D:iodifi<;ati<>n" t_o tlie em\ssion uni_t, as de.fined ii_i WAC 246-247-030(16). DOE m_ust notify the Depanment of any changes to a NESHAP major emission unit wh_en a specific isotope is newly identified as contributing greater than 10% ofihe,potenrial TEDE.to the MEI, or greater than 25% of the TEDE to the ME! after controls. (WA.C 246~247-110(9)) DOE m11St notify the Department of any changes to l'Otential ri:leas_e rill~ as r~uired by state or federal regulations incluaing changes that woJJld constitute a significant modification to the Air Operating Permit urukr WAC 173-401°7is(4). Notice wiU be provided according to the particular regulation under which notification is required. If the applicable regulation(s) does not address·mannerand type of l!Oli.fi_e;atiO:!!, DOE wi_ll provipc t)le OeJl.mwient wi_t)l apv81)~:e wri_\ten not.ice: by l~c:r or elecn:ot)._i_c 1)18{1 but not so_lely by coines of documents. · ·

4) CONTAMINATION CONTROL - NGR Activities Activitiesdone-urukrconfinement structure.of and NGR will be considered to be diffuse and fugitive activities uni~ un~ active veotilat_ion conditions (WA~-246-247-040(5) "!)d WAC 246-247-060(5))

5) CONT /\MINA 11ON CONT!lOL - Soil Removal, Conta'i,ner Hanciling Both Alpha and be_ta~gamma CC'nlaminarion field surveys shall be performed for all removable conrernioation surveys, prior to and during soil n:moval (excluding overburden n:movill) and overpa~king activities lind when placing <legraded outer coiitaitier c:i,titents into rcplacetiieill containers. Alpha surveys alone shall be performed for direct readings of container surfaces. Beta/gamma direct readings are influenced by container contents, so are not as usefu) a)ld are not~$.~ (WA(: 246-i47-040(5) anp WAC 246-247-060(5))

6) CONTROL TECHNOLOGY - Operational C_onditions When operat_ing the NGR containment system, an in-line demis_ter and in-line heating system must both be in operation upstream oft)).~ HEPA fXito;rs. (WAC 246-247-040(5) ~d WA_C 246-247-060(5))

7) PROCESS DE_SCRIJ'TION - Excav~tioti 81)d Retrieval of Cotitainm Pago 2:01'5 forEU_ID 1327

Th_is approval applies 10 lhe_se additioi(al activities describ~ belo"'.. N.o additional activities or ~iltioils on the approved.activities that consti_tute a "modification" to the-emission unit, as defined in WAC 246-247-030(16),may be conducted.

Work wi.111"' performed in acci>_rdance with as low as reasonably achievable (Al.ARA) requirements as determined by the Radiological Control organization. · · One type of configuration·is a V notched trench, containers in some trenches may not have been stacked or placed in lll)Y orderly ~er for buri_al. The specific steps or approach to ti!lcoverir:ig the cor:i_ta:\11~ will my acCl)rdiilg t<> the configuration of the trench to be uncovered, the type of containers to be retrie\'.Cd, the proximity of nearby trenches or fences, the designated location of the spoiis pile, the planned extent of the soil removal, and other consideJ:ati~ns.

Work to be performed within some trenches may be performed within a weather resistant strucrure(s) that will be re­locatabl!l ~ong the trc;ncl).. Wea/):ter c;n_c_losurtj ~ effectively used for similar rcin_ediatio:o ac:,tivities at oilier U.S. Department of Energy (DOE) sites and in general industrial use .. Experience dwing retrieval activities bas.shown that operational efficiencies can be improved if the operations are protected from impacts due to weather such as wind, rain, snow, ~d ~~-ex~¢&_. Tl)_e use o_f a we(ather n:sistant ~clos)ll"C co.uld allow a niori: effective ~very from events involving degraded containers and potential contamination.spreads.

Prior to and during overburden ~oval, subswfa:Ce s_1/rveys s:Uj:h as ground periet,:ating rjtda:r, el_ectro(l)agiletic inductance, and magnetometer are performed. These surveys provide-information regarding container depth, configuration, type; and condition. They may also 'identify .. and locate underground obstructions.

The overburden soil wil_l be removed to expose the waste containers. Excavation equipment will be chosen to effectively remove soil and retrieve the waste containers while minimizing damage to the containers. Excavation activities·will bc·monitored to icienti_fy·col)~inilti(in tha.t. l\l_ight.be pn;sent 14id tj> iniplemeilt control_s to miii$i_ize Cl)lissioils.

The most efficient methodology for removing the iin_con_t.~_i_na_t_ed civerln(rden from the C:ontaineis wi)I 'i_l)clude the rilaxill)um use of c.~veritional meth~ such as excavators, backhoes, front end loaders, brooms (boom mounted), or manual digging with shovels and similar hand tools. To excavate contaminated soil, hand tools predominantly will be used. Remotely-operated vehicles may be used to minimize pe_rsonnel exposure i_n iu:eas where ljjgb radiological arid/or cl:i:""8ic)ll hazards are dlsCl)vered or anticipated. High efficiency particulate air (HEPA) filtered vacuums may be used for.soil excavation for this application. Spot contamination removal will be done 'in accordance with the HEPA filtered vacuum unit (HVU) NOC (DOEIIµ.-97-50, ~oactive Air Emissio(ls Noti~ ofCo))stru<:µon for HEPA Filtered Vacuum Radioactive Air Emission Units, as amended). Within the V notched trenches, it is more likely that the use of a HEPA;filtered vacuum 10 remove larger quantities of soil from the top surface of buried cont_ainers and soi"! niateri,,_Js in the in_terstices sw:rol!D_ding containers w{ii be emp_loy~. Ally use,· of the sitewi!fe HVU :will be performed Linder the NOC applicable 10 the uniL

An estimated 300 cubic meters.of soil.at contamination detection levels occupies·the void-spaces between the containers buried ii) the tn:n~hc:s. Excava_tion activities will be controlled closely. Heavy equipment, hand tools,.light equipment, or HVUs will be· used to complete the-soil.removal operations-and to access and remove the plastic and plywood materials covering the containers.

All containers will be inspected to verify integrity. The container inspection will consist ofa visual examination to determine if there are significant indications of corrosion, holes, dents or othe.r vi_Sti!tl ¢offll_ities_. A(I contain~ could be l))oved, l)ii:iled, or otherwi_se relocated (niliilually or with powered equipment, slings, clamps, or appropriate rigging) to facilitate an adequate visual inspection. ·· · · · · ·

The ex"posed contain~ will also be visually inspected and surveyed for contamination. Externally contaminared containers will have fixative·applied or wili" be decontaminated. Containers may·aJso be ba~ or overp_acked l!S needed Ovc;rpaclµng means pl~tjng contaii(ers l#ithin a larger clos~ container. Bulging or potentially pressurized co_ntainers will be vented. · ·

Page 3 of 5 for EU_ID 1327

Severely d_egracled contain~ will be repackaged orin-si~ g,QU_ted. Rep;i_cliagil)g means traosfenjog the co_nt¢nts of· a degraded container into a new container cir containers. The entire contents of the container will not be.sorted .but will be placed into the new container OT containers through the use of slings; clamshell excavators, manual labor; OT

me best avl!ilal,l~.illediod that minimizes Pi>teritial emissions.

Repackaging may include size.reductio_n. Size reducing, cu_ttjng or disassembling,material and equipment may be required to ensure pet"S()nnel safety and/or more ei::_onomical waste packaging. Th~ procc;ss will indude m~hani~ai C)lttirig tecbi:riqu_es suc)l as low spe.ed sawitjg,.4iill~ snipping, and shearing. The process will also iriclud.e bending and crimping IO preclude the need for cuiting-operatfons where possible.

Containers may include biit are not l_irnit_ed fo drums, metal boxes, concrete ~xes, fiberglass reinforce,d boxes, culverts, and sealed gloveboxes. ·

in-situ grou$g wil.1 hivolye gi"oiiting arniJri.d and/or· throughout the waste, such that _the entire was1e container cliil be removed as a monolith..Retrieval.activities will include appropriate disposition of small:amciil:tlts of incidental contaminated-soil (e.g.-, containerized or fixed in place). Larger areas of con.ta/llinatie>n could be fixed and the area P.Oste.d as required by the Ra9i6logical Control otga',jization for latcir dispositioo. Bulk tninsfer of ~tafuated soils for dispos_al.also could occur. ·

So"ffl!l C:oiltainciil will be assayeji and, if they assay as TRU waste, they may be further exen:iiried to determine whether they contain items prohibited from disposal at the Waste Isolation Pilot Plant (WIPP). Any prohibited items·will be removed at a later date. Unventr;,d TRU waste containers lllllY be staged for venting in ihe burial gro:unds or may be moved to the Ceritral Waste Complex (CWC) or anotb_er treatment, storage or disppsal (TSO) site for venting. ·

A riuril_b_er ofret_iievc:4 CO:n.tainm aie _i,n good conilitio_n but are not verited .. Although no_t technically meeting the definition of '.sealed' containers, W ashingtcin State Department of Health (WDOH) has recognized these as closed containers such that potential emissions from these non vented con\ain~ need not be includC9 so far as potential en\is·s_iolis spetjfic to waste during rem.oval from the trenches. Once vented, the containers are.included for calculating release rates for staging and handling operations. An estimated annual maximum of 15,200 vented containers· of waste will be managed during the peak years of this project

Containers may be staged in lhe·burial grounds pending further processing or transfer. Waste containers are considered retrieved once transferred to an approved TSD facility. (WAC 246-247-040(5) and WAC 246-247-060(.S))

8) PROCESS DESCRIPTION - Next Generation Retrie-:al (NGR) This approval applies to these·additional activities described below. No additional activities or variations on the approv~ a~/_ivities that cons/i~te a "moc,ll_f,ca~_ipri" tci th~ en:i.i.s_s}on unit, 11S d~fil)ed'i_l) WAC 246-247-030(16), may be conducted.

NGR activities will consist of removal of containers, primarily drums but also boxes, from the burial grounds and venting ~ TRU was~ con_l!',iners us_ing rJ:,e D~. process. l:3u_lgiJig clruiiis ~Y bi: vented using the DVS2. Excavation, assay, and inspection activities will be lhe same as desaibed in Condition 9, PROCESS DESCRJPTION - Excavation and Retrieval of Containers. TRU waste containen wifl be separated from low-level waste (LLW) containers during !he NGR r~triev_ai and characte,j.za_tion ~oces~- NOR co_n_ta_ine,rs rJ:,a_t as_s)ly as Li. w w:i.11 l)_ot be roiitin~ly v~ted. The retrieved containers may ri:quj:re oye'rpacking o:r repackaging. Overpacking is expected.to be performed as described in Condition 9, PROCESS DESCRIPTION: Excavation and Retrieval of Containters. Many of the containers (appT9ximately 250/yr) are expected to be so severely degraded~! !hey can)l_ot be overpackc:9. Their c_o"ntents will be repackaged, as described in PRCX::ESS DESCRIPTION:.Excavation and Retreval of Containers. Venting of containers will also occur as descn"bed in PROCESS DESCRIPTION: V entii;ig of Contain~.-An exhaust system (NGR containment system or PES) may be used for NGR container retrieval activities based on lhe controls established within Emission Unit 1327 Next Generation Retrieval. (WAC 246-247-040(5) and WAC 246-247-060(5))

9) ABATEMENT TECHNOLOGY - Excavation and Reuieval of Containers The adniinistrative control points set in this emission unit for contamination, as monitored by standard radiological

Paga 4 of 5 lor EU_tD·1327

fi_eld instrumen_tation, :will be us"!! to bound einissjons liased on clirtent efficiencies of typical RadCon field contAminati_on instruments. The controls listeil within this approval·apply to TRU Waste Retrieval Project open air excavation and retrieval _a~t_ivities. (WAC 746-~47-040(5) ~d WAC 246-247--060(5))

l OJ ABATEMENT TECHNOLOGY - NGR Contaiiiinent The conirols described below will be used for NGR containment-system Cllbaust.. The·gra:nhouse design of this unit will incorporate an engineered active ventilation system to reduce to acceptable Icvels·and minimize the risk of a radi~nu~li!le airborne dis_~gc ~o Ilic orisitc O:r offsite crivironmc(t)t during lll!Y i:ettjeva) op,;ration.

The annual ·average vohanetric flow rate through the intermittently operated NGR containment system exhauster is 0.47 cubic metp-s/sec (1000 c_fm) provi_cµng µp to ~7.8 a# ex~hanges per hou)' Vlithi_t; th~ greeajiouse. Ventila_ti_on for this NGR contairiment system will include greenhouse inlet filters, pressure control flaps, an.inlet demister pad with ·a collection sump located inside the greenhouse, a heater unit, two (2) exhaust HEPA filters (1st and 2nd ~_tage), dpwnstream du~g, a 4pwnstre,1I!;l flow control damper, 11(1:4 an ~~t_ (~, ~h.$PA ~iter stage will provide an in-place testable efficiency of at least 99:95% for removal of test aerosol particulate with a median diameter ofO. 7 micron. The exhaust duct is 8'inches·in diameter and-will exhaust at Ieas_t-3 fee_t ·above grade. When th"e, NGR_ ~o,:i_tain,tnent.sY.Sl!=Dl i_s in il)le.(wi_th p~nnel insid_e @4 wO:rkjrig \viii, -..:aste) tl)_e ~ve v~tila_~on system will be in operation. During ventilation system operation, amlow into this contairiment system will be through 30% efficient inlet filters. Containment tent pressure win be controlled with simple flaps that will cover t)l!'S~ filters_. To.e d~ister $.:4 _\\~tei: wiit will p_revent wa)_er bu_ildup on the·Hl;:PA lj).t~ ;rid a_(low operaJ_i_on wh~ the humidity is above 70% relative humidity and/or when misting is used during retrieval operations to control contamination spread. (WAC 246-247--040(5) and WAC 246-247-060(5)) ·

I 1) WDOH NOTlFICA TION - Implementing NGR Containment Duril)g \}jgh \lazal'.(I work activities, remo\ra_ble surface contamination is mau:11:ained less than 2,000,000 dpm/100 cmA2 alpha and/or less than 4 rad/hr/I 00 cmA2 beta-gamma, limited ti:> a I f\".'2 area. For an allowed increase in contaminated area footprint of 4 ftA2 the.iimiting con~iticil) for remova)>le contami,n/l_ti_on will ·be 500,000 dpm/100 tjJ!A2 alpha aild or Irad/bi/100 cmA2 ~a-gaiiiina. Exceeding ariy of these contaminati_on Ii_ll)its will require work to stop, and notification to-Operation and RadCon management in accordance with the RWP .. Notification to WDOH via email or the established procedures ~ the Envirolll!lental Notification p_rogram wiiI be required. For work to c_ontiriue·above any of these limiting radiological conditions, _the NOR contiiirurierit system or .the PES and commensurate controls Will be implemented."The NGR containment exhaust system will be utili.?.ed tn niinirnize the potential for contamination spreads oµts_icieofposted ra~iological ar~. (WAC246-247-040(-5) and WAC 246-247-960(5))

I 2) ALTERNATIVE APPROVAL - Destructive l'xarnin•tion Approval is given for alternative flow monitoring-and sample extraction method for the NGR. Destructive El_<a)'.):lina/_ion (DE) of tl)c: fin_'!I stage i{i;:_PA filter of tl)l' NGR conta_inm_en_t, wl)j~)) wi(l be ·pcr:fo,:n_,.ed ~~e p,:r calendar year any time the syscem is used within the calendar year. This authorization will remain in force for three years from the date of issue of the Iicense,-additional exterisions,on the life of the system·will require installation of continliol!S flow l)ICS:Suremen!. !Uld s$,t,le _extractioit_ in acc:Orcjance wi_tli A,NSl/klPS l'JI3.)-I 999. (WAC 246-247-04()(5), WAC 246-247-060(5), WAC246-247-075(4))

I 3) ALARACT APROV AL - Conlainer Handling The process for handling·of abnormal or severely degraded containers as described in PROCESS DESCRIPTION­Ex!'3vaticil) and Re_t;ri~val of Conlajµo:r, for bagging, overpa4ing, platj_i;ig degi:aded 011:tc:r container conte,nts in)p rep_Iacemerit contaiiiers or in-sini gfu_uting is approved as meeting ALARACT, and these processes and assotjated records and procedures will be subject to inspection upon requesiby the department (WAC 246-247-040(5) and WAC 246-247-060(5))

14) CONTAMINATION CONTROL- ba,iiy SllfVeys _ When ellhaust system is shut down with inventory inside the NGR, radiological control .technicians will perform daily radiological swipe surveys on the access doors to the NGR during normal work days. (Y,/AC 246-247-040(5) and WAC 246-247-060(5))

I 5) CONTAMINATION DOCUMENT A TJON - Exposed Packages During repackaging activities (i.e,, when transferring the contents of a degraded container into a new container or containers) an operations log will be !@t noting col).ditiQns oftlie tiai;lsfen-ed "°riterits!Jiackages .. RadCpri will generate and retain radiological records documenting air sample =ults and removable contamination conditions during retrieval of each container. (Y,/ AC 246-247-040(5) and WAC 246-247-060(5))

Page 5 of 5 fci-EU_ID 1327

STATE OF WASHINGTON DEPAR.TMENT OF HEALtil

ENVIRONMENTAL BEALm PROGRAMS OFFICE OF RADIATION PROTECTION

In Re The Approval Qf: il-i>AY DRAFI' APPROVAL OF NOTICE OF'CONSTRUCTION (NOC) 1040

Approval No: AlR.16-1109

THE s:uJE qfW,'!$ffiNGTON TO:

Docket No: REQUEST FOR Al)JUDICATIVE PROCEEDING

Mr. Doug Shoop, Manager United States Department of Energy Richland Operiltioail Office . P.0 .. &1 550, MSIN: AS-14 Rlchlaad, Wasblilgton !193S2

If you wish to i'e(jile$t an adjudicat_iv~proceeding, you or yolll' atto".'!"Y !!'!'"' CO~LEW~ fILE THIS FORM OR A DOCUMENT PROVIDING SUBSTANTIALLY THEOSAME INFORMATION WITH THE DEP,'.\RTMEN.TOFHEALTI:IADJUDl¢ATivE.~ERVI~UNIT-WJTH]NTWENTY-EiGHJ:(2~)DAYSOF YOUR RECEIPT o_fthis 11.equest 'for Adjudicative Proceeding form and a copy of the Office of Radiation Protection's approval, Ani. 16-1109. · ·· · · · · · · · · · -· · · ·· · · · ·

You must file your application in a mmmer that shows proof of service on tbe:Adjudicative Service Unit, at the following·address: ·

~o,i11l)_erit of Health A_djudi~ve Servic~ Unit ·31 O Israel Rolid S.E. 'r.o. Box -iis19 · · Olympia, WA 9~504-7879

\Vith your application, you mUSl include a topy of the Office of Radiation Protection's approval.

FI°LING SHALL NOT BE DEEMED COMPLETE UNTIL THE ADnJDICATIVE SERVICE UNIT ACTIJALL Y RECEIVES YOUR APPLICATiON. .

YOl/ HA VE THE RIGHT tba formal hearing in this matter c:ondocted pumlllDI to Revised Code of Washington (RCW) 43.70.11 S, Chapter 34.0S RCW, and Chapter 246-10 of the Washington Adminis1rative Code (WAC) .. Alternatively, you may waive tru:·fonnal hearing and submit a wri!te,, siatement and supporting documeDIS setting out your position, your defenses, and any mitigating circumstances that you wish to bring to the Department's atterition. . You h!lve the right ti) be rep"""'~ by an attorney at YOIJ! own expense.

L

) I WIL_L BE represented by an attorney. His/her name, ·address, and phone number me:

Name:

Address:

Phone:.

Request.for Adjudicative Prilcecdmg Page I of4

[ l I WILL NOT BE i'epres~tcd oy an a))o):i)~y.

q after submitting ihis request, y,,u obtain atiorney representation or clitiiige at_(orilfljs, YOJI muiit n"c,_tify tlJ.e Adjudicative Service Unit.

IL

J I !)0 NOT waive (ny righ_t t~ a fol'qla) bCNi~g.

J I D(! waive !.llY r_igh~ to a f~~-~g. I understand that if I waive ll!Y right lo_ a fo'ril)al ~e_aring, ~ Depaitmem.may decide this matter solely with rcfercil_ce 1o iiifon;i:iation in the Depar1meni's possession and to such written stitetneiitS"Bild silppiirtiilg d~!mts as I l)iliy liaye submitted. ·

If you choose to waive -your right to a formal hearing, please complete the fcillo~g:

J I AM NOTsubmitting docliinerits to !lie Dejiaitjjiel)_t ii) ~tipp<!rt ofiny p_~sition.

] I AM submitting.a sworn siatement-and/or other documents to the Department in support cif i:nY position. Instructions " Piease indicate your. responses below: ·

If you are submitting documents to the Depaitmcnl, pl?ll" list a,nd t,ryi,fly identjfy ail such doi:wncnts in the space provided below and on any ad_ditional sh!:el thal_~y be oecesSBJY.

Request for A._djudicative Proceeding Page 2 of4

tn.

ADMISSION/DENlAL OF CONDmONs OR _UMITATIONS The Office of Radiation Protection's approval AIR 16-1109, dated November f7~ 2016, contains conditions and limitations sci oil! as liumb_ered p3!8graplis .. _ In die sp_aci: b!:lo~ you riiifst inciic_ate, iii good iiiiih, ,y1,~;;i you aiimn, or do noJ contest, or deny the aj_ndirions or l_imi.tati(IIIS. Con4iri_o_~ or'li~riops denied or nOI co)lte*'1 r,nay la_t~ be admittcc,1. Conditions or Wl)itatio,ns admitted or not coriteste4 sliall be coTiclusively deemed mi~ fc\r furth~

c:cedin pro • gs_.

Instructions: I admit, deny, or do nOI contest the conditions or limitations as follows (!iii in th. app,op,iate paragraph number):

Paragraph __ 12m [ l

P9 Not Contest 1

p . h aragrap -,-

Paragraph __

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Pl~as.e 1®1ch lll!Y add)tiolial sheets th.at m;iy be necessary to respond to all allegations.

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1,f you biiv,,.chosen ru,t to w_aive your rights to a formal' bearing. please stale all grounds for contesting this riilitter in the space provided below and on ariy additional·slieeis that maybe n~~swy.

Request for Adjudicative Proceeding P ·· ·3of4 . age .

IV.

You !!live tl)e right t? ail iiit~ipreter, appoin~ at no C!>S~ if you are a heaajlg impajrtjl ~nor fill)ite~ f;oglis~ speaking pers_o_il_. If ll!IY wiDl~S_S for you is a liea:rilig impaired person or a Ui_il_it~ English spca(<ing P.•rs:OtJ, an interp_reier w_i_l_l be appointed a~ your experis~.

1 [DO]/ [DO NO"TJ (ciri:le one) request an interpreter be appointed. If an intcrpn,ter is requested, please indicate, the p:e·rson or persons for whom an interpreter is iequiml and their piiin:afy language, arid/or whether. they are hearin ' ired. . .. . g mtpa .

IF YOU FAIL to FilE YOUR APPLICA TiON IN A TiMEL Y MANNER, OR IF YOU FILE YOUR APPLICA ti6N TiMEL y BUT FAIL TO APPEAR-At ANY SCHEDULED . . sifrfi.ooNi' CONFERENCE, iiREHEARiNG CONFERENCE, OR HtARiNo\v1rnouT LEAVE TO DO so, tilifDEPARTMENT MA y DECIDE THIS MATTER WITHOUT YOUR YOUR PARTICiP ATION AND WiTHOUT FURTHER NOTICE TO YOU.

DATEDthis ____ day of ________ __., ___ _

Party

Party's Rciprcseiitiuive (if.any)

WSBA#: -----,..,,-=-=~~~

Request for Adjudicative ~ding Page4of4

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!· ii COrriplete items 1, ?, arid 3. • Print your name and addl'8S·s on the reverse

so that we Can re_t~~n _th8 CB.rd to you. • Attach this card to the back of the mailplece,

or _ _on_the front If space P8rrTlits. _ --1. _A,:ticla Addressed to: _____ ~--- ___ _

Mr. Doug Shoop, Manager Unrted States D~partrn.ent of Energy Richland Operations Office PO. Box 550. MSIN: AS-14 Richland, WA 99352

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STATE OF WASHINGTON

DEPARTMENT OF HEALTH OfFICE·OF RADl,\TION Pl!OTECTION

309 Bradley 8/vcJ., Suite 201 • Richland, \-1/,1shir_1,:.:to_n 99352

TDD llday Service: 1-800-U33-63R8

December 23, 2016.

Mr .. Doug Shoop, Manager United States Department of Energy Richland Operations Office P.O. I3ox 550, MSIN: A5°14 Richland, Washington 99352

Re: Final Approval of Notice of Construction (NOC) I 040

Mr. Shoop:

AIR 16-12_25 NOC 1040

Pursuant to Chapter 246-247 of the Washington Admi11jstnl.)ive Code (WAC), your modification was approved on December 19, 2016, according to the enclosed emission unit (EU) specific license for:

Next Ge_ne_ra~io1_1 Retrieval (Active) Operation (Replaces NOC 804) (NOC 1040, EU 1327)

The cond_itiC>ns, contyol_s; monitoring requirements, and limitations of this liceiise.m:ust be observed in order for you to be in compliance with WAC 246-247. Failure to meet any provision of this license m:ay result in the revocation of approval, the i_ssuance of Notices of Violation, or other enforct:ment actions under WAC 246c247-100.

If you have any questions.regi_lTding t_i)._i_s l).pproval,pli:ase contact Tom Frazier at Thomas.Frazier@doh.wa.gov or, by Phorie, at (509) 946c0774. ·

Sincen:ly,

wJv'!l;JJ John Martell, Manager Radioactive Air Emissions· Section

Enclosure: NOC 1040 for EU 1327

cc: ( see nex~ page)

Public Hl'alth · Alw,1ys \\forking for ,1 S.1ler ,ind f-billhier \V.1~hi11glon

Mr. Doug-Shoop December 23, 2016 Page.2 of2

cc: Rµt~ Allen, WRPS Matthew Barnett, PNNL Lilyann Bauder, Ecology Shawna Berven, WDOH Lucinda Bomeiruiil, WRPS Lee Bostic, BNI Frank Carleo, CHPRC Cliff Clark, USDOE-RL Jack DonneHy, WRPS Rick Engelmann, CHPRC Dennis Faulk, EPA Tho111as Frazier; WDOH Eric Faust, USDOE-RL Gary Fritz, MSA Philip Gi:nt, Ecology Reed Kaldor, MSA Paul Karschriia, CHPRC Jim Mc.Auley, EPA John Schmidt, WDOH Jeff Voogd, WRPS Environmental Portal RAES Tracking: Line 16-153; EU 1327; NOC 1040

AIR 16-1225

Emission Unit ID: 1327

200W 296-P-52 Next Generation Retrieval (Active) This is O MINOR, AfrivE"LY' vcmiia:tcd cmisSiotl unit.

ntU Wo~!c Retrieval

Emission Unit Information

Stac.k Height: J .00 ft. 0.91 m. Stack Diameter 0.66 ft.

Average Stack Emuent Tempe_rature: degrees Fahrenhe_it. degrees Celsius.

Average Stack ExhaustVelocity: ft/second. m/second.

AbatementTechnology ALA!l.ACT WAC 246-247-040(4) state only enforceable: WAC 246-247-010(4), 040(5), 060(5)

0.20 m.

Zone or Area Abatement Tethnology Required# or Units . __ Add.itional D~scr)ption

C.oritro_l_l_ed wo·r_k area Prefiltcr

Controlled work area 1st Stage HEPA Filter

Control_lcd \\'O_~k afea 2_nd Stage HEPA Filter

Aerosol tested annually to 99.95~ removal o_fa particulate with a median diameterof0.7 micron.

Aerosol tested annually to 99.95% removal ofa particulate with a median diani.Cter of 0.7 ·miC:r~l'.1-

.Aerosol tested onnually to 99.95% removal o_fa particulate with a median diameter of 0. 7 micron.

Monitoring Requirements state enforceable: WAC.246-247-040(5), 060(5), and federally enforceable: 40 CFR 61 subpart H

Federal and State Regulatory

40 CFR 6L9J(b)(4)(i) & WAC 246-247-075(2)

Monitoring and Testing R~(fu_i.rem¢ii,S

40 CFR · 6't, Appendix B Method 114

Radioou_clides Requiring Measurement

All radionuclides which could conn:J_~ut_e I 0% of the ~tential TE.DE,

Sampling Frequency

On~. pe_r monP:t anytime it is operated

Sampling Req·uirements Destructive Examination (DE) ofihe filters .. Daily sampling of the access doors when exhaust system is .shut down with inventory inside ·

Ad_dltli::inal Req·ulromonta

AddiUonel monitoring or Sampnng re(1uirerrieil_ts e:s,tablished by this License wlll be listed in the Condltlons and Limitations section, ff applicable.

Operatlon_al S_tatus ~~_iv_i_ti~ ~o.r the TRU rctrieVal project support decontamination and decommissioning operations at the Hanford Site.

This Emission Uni"i has 1 active Notlce(s) of Construction.

Project Title Next Generation Retrieval (Active) Operation (Replaces NOC 804)

Approva_l# AIR 16-1225

Date Approved NOC _ID 12/1912016 1040

Conditions (state only enforceable: WAC 246-247-Cl4o(5), 060(5) if not specified) I) The total a.bated emission limit for this Notice of Construction is limited to 9.40E-05mrem/year to the

Maximally Exposed'lndividual {WAC 246-247-040(5)).

2) This approval applies to those additional activities described below. N_o additional activities o_r vari_ati_ons on the approved activities that constitute a "modification" to the emission unit, as defined in WAC 246-247-030( 16),niay be conducted.

Transuranic waste retrieval involves the i>rocesses fqr re_moving and dispositioning buried suspect transuranic mixed low-level radioactive waste (hereafter called TRU waste) from Ha:n_ford Site ·burial trenches for storage or disposal at other approved locations. Dispositioning is the orderly administration anci"han_cil}ng of waste

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(including contami.nated soil) from the low level burial grounds to place it in approved storage or disposal status. The handling includes such actions as: packaging, labeling and tracking waste; venting, assaying, and staging waste; inspecting waste and waste staging areas; sampling/characterizing/designating waste; making arrangements for the transfer of waste; completing necessary paperwork; and performing radiological and/or industrial hygiene.surveys.

See the following for a detailed description of specific controls/conditions for each EU associated with the Transuranic Waste Retrieval Project:

Hanford Sitewide W-PORTEX 007 EU 455 EU 1440 EU 755 EU 756 EU 1181 EU 1322 EU 1326 EU 1327

200 Area Diffuse/ Fugi.tive; Operation of the Transuranic Waste Retrieval Project Mobile Drum Venting System (Active Ve.ntilation) (MDVS) Mobile Drum Venting System (Passive Venti.lation) (MDVS) Categorical Drum Venting System 2 (DVS2) Portable Enclosure System # I (PES) Vapor Extraction System (YES) Next Generation Retrieval (NGR)

3) The PTE for this project as determined under WAC 246-247-030(2l)(a-e) [as specified in the application] is I .90E-Ol mrem/year. Approved are the associated potential release rates (Curies/year) of:

Am -241 3.10E-02 Liquid/Particulate Solid Alpha release rate l:las"ed on Am-241 + Pl'Ogeny. It Is recognized that other radlonuclides may be present In very limited quantllles. ·

Cs - 137 4.70E-01 Liquid/Particulate Solid Beta/Gamma rolcose rate based on Cs-137 + Progeny. lt Is recognlzed that other radlonuclldes may be present in very limited quantities. ·

The radioactive isotopes identified for this emission unit are (no quantities specified): Am - 241 Am· 243 Cf- 252 Cm-244 Cs-134

Cs - 137

Pu - 241

U-238

Eu· 152

Sr- 90

Eu- 154

U • 234

Pu - 238

U -235

Pu - 2391240

U-236

The poten.tial release rates described in this Condition were used to determine control technologies and monitoring requirements for this approval. DOE must notifiy the Department ofa "modification" to the emission unit, as defined in WAC 246-247-030(16). DOE m_ust notify the Department of any changes to a NESHAP major emission U:nit when a specific isotope is newly identified as contributing greater than 10% of the potential TEDE to the MEI, or greater than 25% of the TEDE·to the MEI after controls. (WAC 246-247-1 I 0(9)) DOE· must notify the Department of any changes to potential release rates as required by state or federal regulations including changes that would constitute a significant mod_i_fication to the Air Operating Permit under WAC 173.-401-725( 4). Notice will be provided according to the particular regulation under which notification is required. If the applicable regulation(s) does not address manner and type ofootification, DOE will provide the Department with advance written notice by letter or electronic mail but not solely by copies of documents.

4) CONTAMINATION CONTROL - NGR Activities Ac.tivities done under confinement structure of and NGR will be considered to be diffuse and fugitive act_ivi.t.ies unless under active venti_l.ation conditions (WAC246-247-040(5) and WAC.246-247-060(5))

5) CONTAM.INATION CONTROL - Soil Removal, Container Handling Both Alpha and beta-gamma contamination field surveys shall be performed for all removable contamination surveys, prior to and during soil removal (excluding overburden removal) and overpacking activities and when placing degraded outer container contents into replacement containers. Alpha surveys alone shall be performed for direct readings of container surfaces. Beta/gamma direct readings are influe.nced by container contents, so are not as useful and are not required. (WAC 246-247-040(5} and WAC 246-247-060(5))

6) CONTROL TECHNOLOGY - Operational Conditions When operating the NGR containment system, an in-line demister and in-line heating system must both be in operation upstream of the HEPA filters. (WAC 246-247-040(5) and WAC 246-247-060(5))

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7) PROCESS DESCRIPTION - Excavation and Retrieval of Containers This approval applies to these additional activities described below. No additional activities or variations on the approved a.ctivi_ti_es that constitute a "modification" to the emission unit, as defined in WAC 246-247-030(16), may be conduc.te.d.

Work will be performed in accordance with as low as reasonably achievable (ALARA) requi_rements as determined by the Radiological Control organization. One type of configuration is a V notched trench, containers in some trenches may not have been stacked or placed in any orderly manner for burial. The specific steps or approach to uncovering the containers will vary according to the configuration of the trench to be uncovered, the type of containers to be retrieved, the proximity of nearby trenches or fences, the designated location of the spoils pile, the planned extent of the soil removal, and other c-o_i:iside_ra~ions.

Work to be performed within some trenches may be pe_rformed withi.n a weather resistant structure(s) that will be re-locatable along the trench. Weather enclosu"res are effectively used for simiiar remediation activities at other - . . . . . ' . U.S. Department of Energy (DOE) sites and in general industrial use. Experience during retrieval activi_ties has shown that operational efficiencies can be improved if the operations are protected from impacts du.e to we;,th_e.r such as wind, rain, snow, and temperature extremes. The use ofa weather resistant enclosure could allow a more effective recovery from events involving degraded containers and potential contamination spreads.

Prio.r to and during overburden removal, subsurface surveys such as ground penetrating radar, electromagnetic inductanc:e, and magnetometer are performed. These surveys provide information regarding container depth, configuration, type, and condition. They may also iden_tify and locate underground obstructions.

The overburden soil will be removed to expose the waste containers. Excavation equipment wi_l_l be chosen to effectively remove soil and retrieve the waste containers while minimizing damage to the containers. Excayation activities will be monitored to identify contamination that might be present and to implement controls to minimize emissions.

The most efficient me_thodology for removing the uncontaminated overburden from the containers will include the maximum use of conven_tio_nal methods such as excavators, backhoes, front end loaders, brooms (boom mounted), or manual ctigging with shovels and similar hand tools. To exca_vat_e contam_inated soil, hand tools predominantly will be use<:!. Remotely-operated vehicles may be used to minimize personnel exposure in areas where high radiological and/or chemical hazards are discovered or anticipated. High efficiency particulate air (HEPA) fi.ltered vacuums may be used for soil excavation for this application. Spot contamination removal will be done i_n accordance with the HEPA filtered vacuum unit (HVU) NOC (DOE/RL-97-50, Radioactive Air Emissions Notice of Cons;ruction for HEPA Filtered Vacuum Radioactive Air Emission Units, as amended). Within the V notched tren·ches, it is more likely that the use of a HEPA-filtered vacuum to remove larger quantities of soil from the top surface of ouried containers and soil materials in the interstices surrounding containers will be employed. Any use of the sitewide HVU will be perfoniied under the NOC applicable to the unit.

An estimated 300 cubic meters of soil at contamination detection level.s oc.cupies the void spaces between the containers buried in the trenches. Excavation activities will be controlled closely. Heavy equipment, hand tools, ligh_t equip:rnent, or HVUs wil"I be used to complete the soil removal operations and to access and remove the plastic and plywood materials covering the containers.

All contai.ners will be inspected to verify integrity. The container inspection will consist ofa visual examination to determine i.ft.here are significan.t indications of corrosion, holes, dents or other visual deformities. All containers could be moved, turned, or otherwise relocated (manual_ly or with powered equipment, slings, clamps, or appropriate rigging) to facilitate an adequate visual inspection.

The exposed containers will also be visually inspected and surveyed for contamination. Externally contaminated containers will have fixative applied or will be decontaminated. Containers may also be bagged or overpacked as needed. Overpacking means placing containers within a larger closed container. Bulging or potentially pressurized containers will be vented. --- ....

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Severely degraded containers will be repackaged or in-situ grouted. R_epackaging means transferring the contents of a degraded container into a new container or containers. The entire contents of the container will not be sorted but will be placed into the new container or containers through the use of slings, clamshell excavators, manual labor, orthe best available method that minimizes potential emissions.

Repackaging may include size reduction. Size reducing, cutting or disassembling material and equipment may be required to ensure personnel safety and/or more economical waste packaging. The process will include mechanical cuttirig techniques such as low speed sawing, drilling, snipping, and shearing. The process will also include bending and crimping to preclude the need for cutting operations where possible.

Containers may include but are not limited to drums, metal boxes, concrete bo.xes, fiberglass reinforced boxes, culverts, and sealed gloveboxes.

ln-si_tu grouting wifl involve grouting around and/or throughout the waste, such that the entire waste container c_an be removed as a monofith. Retrieval activities will include appropriate disposition of small amounts of incidental contaminated soil (e.g., containedzed or fixed in place). Larger areas of contamination could be fixed and the area posted as required oy the Radiological Control organization for later disposition. Bulk transfer of contaminated soils for disposal also could occur.

Some containers will be assayed and, if they assay as TRU waste, they 111ay be further examined to determine whether they contain items prohibited from disposal at the Waste Isolation Pilot Plant (WIPP). Any prohibited items wiU be removed at a later date. Unvented TRU waste containers may be staged for venting in the burial grounds or may be moved to the Central Waste Complex (CWC) or another treatment, storage or disposal (TSD) site for venting.

A number ofretrieved containers are in good condition but are not vented. Although not technically meeting the definition of 'sealed' containers, Washington State Department of Health (WDOH) has recognized these as closed containers such that potential emissions from these non vented containers need not be included so far as potential emissions specific to waste during removal from the trenches. Once vented, the containers are included for calculating release rates for.staging and handling operations. An estimated annual maximum of 15,200 vented containers of waste will be managed during the peak years of this project.

Containers may be staged in the burial grounds pending further processing or transfer. Waste containers are considered retrieved on·ce transferred to an approved TSD facility. (WAC 246-247-040(5) and WAC246-247-060(5))

8) PROCESS DESCRiPTION - Next Generation Retrieval (NGR) This approval applies to these additional activities described below. No additional activities or variations on the approved activities that constit_ute a "modification" to the emission unit, as defined in WAC 246-247--030(16), may be con_ducted.

NGR activities will consist of removal of containers, primarily drums but also boxes, from the burial grounds and venting the TRU waste containers using the Dart process. Bulging drums may be vented using the DVS2. Excavation, assay, and inspection activities win be the same as described in Condition 9, PROCESS DESCRIPTION - Excavation and Retrieval of Conta.iners. TRU waste containers will be separated from low­level waste (LL W) containers during the NGR retrieval and characterization proc_ess. NGR containers that assay as LL W will not be routinely vented. The retrieved containers may require overpacking or repackaging. Overpacking is expected to be performed as described in Condition 9, PROCESS DESCRIPTION: Excavation and Retrieval ofContainters. Many of the containers (approximately 250/yr) are expected to be so severely degraded that they cannot be overpacked. Their contents wifl be repackaged, as described in PROCESS DESCRIPTION: Excavation and Retreval of Container's. Venting of containers will also occur as described in PROCESS DESCRIPTION: Venting of Containers. An exhaust system (NGR containment system) may be used for NGR container retrieval activities based on tI:te co.ntrols established within Emission Unit 1327 Next Generation Retrieval. (WAC 246-247-040(5) and WAC 246-247--060(5))

9) ABATEMENT TECHNOLOGY -Excavation and Retrieval of Containers The administrat_ive control points set in this emission unit for contamination, as monitored by standard radiological field instrumentat_ion, will be used to bound emissions based on current efficiencies of typical

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RadCon fi_el_d contamination instruments. The con_trols IJsted within t_his approval apply to TRU Waste Retrieval Project open air excavation and retrieval activities. (WAC 246-247-040(5) and WAC 246-247-060(5))

I 0) ABATEMENT TECHNOLOGY - NGR Containment Th_e controls described below will be used for NGR containment system exhaust. The greenhouse design of this uriit will incorpora_te an engineered active ventilation system to reduce to acceptable levels and minimize the risk of a radionuc_lide ai_rbome discharge to the onsite or offsite environment during any retrieval operation.

The annual average volumetric flow rate through th_e intermittently operated NGR containment system exhauster is 0.47 cubic meters/sec (!000 cfm) providing up to 27.8 air exchanges per hour within the greenhouse. Ventilation for this NGR containment system will include greenhouse inlet filters, pressure control flaps, an inlet demister pad with a collection sump located inside the greenhouse, a heater unit, two (2) exhaust HEPA filters (1st and 2nd stage), downstream ducting, a downstream flow control damper, and an exhaust fan. Each HEPA filter stage will provide an in-place testable efficiency of at least 99.95% for removal oftest aerosol partic_ulate with a median diameter of 0. 7 m·icron. The exhaust duct is 8 inches in diameter and will exhaust at least 3 feet above grade. When the NGR containment system is in use (with personne_l inside and working with waste) the active ventilation system will be in operation. During ventilation system operation, airflow into this containment system wi·II be through 30% efficient inlet filters. Containment tent pressure will be control.led wi_th simple flaps that will cover these filters. The demister and heater unit will prevent water buildup on the HEPA filters and allow operation when the humidity is above 70% relative humidity and/or when misting is used during retrieval operations to control contamination spread. (WAC 246-247-040(5) and WAC 246-247-060(5))

11) WDOH NOTIFICATION - Implementing NGR Containment Dudng high hazard work activities, removable surface contamination is maintained less than 2,000,000 dpm/100 cmA2 alpha and/or l_ess than 4 rad/hr/100 cmA2 beta-gamma, limited to a I ftA2 area For an allowed increase ';n contaminated area footprint of 4 ftA2 the limiting condition for removable contamination will be 500,000 dpm/100 cmA2 alpha and or l rad/hr/I 00 cmA2 beta-gamma Exceeding any of these contamination limits will require work to stop, and notification to Operation and RadCon management in accordance with the RWP. Notification to WDOH via email or the established procedures in the Environm_ental Notification program will be required. For work to continue above any of these limiting radiological conditions, the NGR containment system and commensurate controls will be implemented. The NGR containment exhaust system will be utilized to minimize the potential for contamination spreads outside of posted radiological areas. (WAC 246-247-040(5) and WAC 246-247-060(5))

12) ALTERNATIVE APPROVAL - Destructive Examination Approval is given for alternative flow monitoring and sample extraction method for the NGR. Destructive Examination (DE) of the final stage HEPA filter of the NGR containment, which will be performed once per calendar year any time the system is used within the calendar year. This authorization will remain in force for three years from the date o_fissue of the license, additional extensions on the life of the system will require installation of continuous flow measurement and sample extraction in accordance with ANSI/HPS NIJ.l-1999. (WAC.246-247-040(5), WAC 246-247--060(5), WAC 246--247--075(4))

13) ALARACT APROVAL - Container Handling The process for handling of abnonnal or severely degraded containers as described in PROCESS DESCRIPTION- Excavatio_n and Retrieval of Container, for bagging, overpacking, placing degraded outer container contents into replacement containers o_r in-situ grouting is approved as meeting ALARACT, and these processes and associated records and procedures "'ill be subject to inspection upon request by the department. (WAC 246-247-040(5) and WAC 246-247--060(5))

14) CONTAMINATION CONTROL - Daily Surveys When exhaust system is shut down with inventory i_nside the NGR, radiological control technicians will perfonn daily radiological swipe surveys on the access doors to the NGR dur_ing nonnal work days. (WAC 246-247-040(5) and WAC 246-247-060(5))

15) CONTAMINATION DOCUMENTATION - Exposed Packages During repackaging activities (i.e., when transferring the contents of a degraded co_ntainer into a new container or con_tainers) an operations log will be kept noting conditions of the transferred contents/pa_ckages .. Rad Con will generate and retain radiological records documenting air sample results and removable contamination conditions during retrieval of each container. (WAC 246-247-040(5) and WAC 246-247-060(5))

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