Licensing File - Washington · period. Also, have HSC do an informal review of the license for consistency before sending t_o the licensee. £} HSC Info~cense Review iJfJ .~V•J•

Table of Contents

I) Licensing Checklist

USDOE - Hanford Site 2706-T Building

Richland WA License FF-0 l

(EU 315; NOC 1033)

Licensing File

2) Application-WAC 246-247 Appendix A 3) Completeness Review Checklist 4) Complete_nes_s Determination Letter 5) Other Applicable Document_ation (Emails, reports, calculations, etc.) 6) Informal Draft EU License

a) Licensee Comments on Informal Draft b) Resolution of Comments

7) 28 Day Draft a) Licensee Accept_.µ1ce b) RAES response and explanation of city notification time requirement

8) Final License

LICENSING CHECKLIST (Rev. 2)

Please·initial bOXes, as appropriate,- riltlier tlian piacing a check mark in the bo:c

RAES date received 11 /+ j 1\.p and !M# assigned 9, d (p"3

Entered into RAES Tracking/ROTT llo-.;m4-. Completeness Review due ·,:;i /41 Up.

To HP3 (responsible for facility) for assignment: J.'/\J. &@,DT

To assigned HP2: :JD:M A.,A2,t 1f..-.,

Add draft Table of Contents and separator pages to file.

Conduct completeness review using "Completeness Review Checklist" arid draft "Completeness Noti_fi~ation" letter within 20 days of RAES dat_e re_ceived. Discu_ss any co~cerns/issues with HP3 during this 20 day period.

Place ''Completeness Review Checklist" in license file and prepare draft "Completeness Detenninatii:m" letter. Letter m11st go out within 30 days ofRAE°S date received.

·• IJ application is inco_mplete, you may need t_o repeat this (and prior) step(s). • If application complete, assign NOC ID and EU ID, as appropriate .. Do NOT obsolete 'old' NOC,

EU, etc. before the new final, approved, license is issued (you may have to' excl_ude old frolll 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 HP3 and is ready to go out at the 30 day mark, you may combine completeness and 28-day draft.)

HP3 - work wit_h HP2 to re.solve any co_l!lllle11ts 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 Determination" letter.:· to AA3 for finalization (HSC will update RAES Tracking/ROTT upon trans·mittal and wffl note the 2.8\,- -Day Draft Due Date, below, upon returning file to you). You now have 60 days to issue the official 28-Day Draft Approval lett_er.

28-Day Draft Due Date: I /8'tr / 11 (See next.step, immediately.) '.•;:; '

l_s it necessary to send t_he 20-Day City Not_ification? 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/RDTT upon transmit_tal and will notify you of 20-Day Comment Due Date, below, upon returriirig the file to you).

• USDOE-RL Hanford Site is exempt from this requirement. • If RAEL is part of a Materials or Waste license, the respo'nsibility falls on them to 11_ot_i_fy the city.

We issue these notifications for new licenses or renewals only; we do not issue them for modifications.

20-Day C_orrirrient Due Date: ____ .... ~,___f1:~-----(see page 2)

Page I of 2 Ail associa1ed document templates can befoimd on the S: Drive at: S:\EPH\Data\RP _AIR\RAES\licensing Docs

Within 40 days ______ of corrip)eteness detennin·ed, cO:mplete thorough review of application and draft license. Any EU specific conditions must have justification/basis docu·mented iii the 'expla_nation' section of t_h_e database. Discus_s any con_cems/issues with HP3 during this 40 day period. Also, have HSC do an informal review of the license for consistency before sending t_o the licensee. £}

HSC Info~cense Review iJfJ .~V•J•

Send informal' draft lic_ense to licensee for review, aUowing th_e_rn a week to 10 days to get comments back to you. Be sure to include a 'due date '. . -

Upon receipt of response from licensee, resoive any ccirrirrient;/issues/concems right away and finalize the draft license and transmittal letter (28-dayDraft). At least 3s5 days before 28-Day Draft Due Date, send license file, draft tratism.ittai letter, and draft license to HP3 for fi_n_al review.

HP3 approves and forwards license file an·d draft letter to HSC for review. HSC reviews and forwards to AA3 for fin_alization (HSC will'hold file until licensee receives 28-day draft).

A 1(l. I If · r2.D'1 (4-~'3). - r 9- / ;t) I I {p Upon licensee receipt of 28-day draft, HSC will update RAES TrackitigiiujTI, verify dat_abase concurrence, and return license file to HP2 with due date for licensee response or final issuance of. license.

FinalDueDate: //ct4-I~ ['7

r/24 Once license·e has accepted, or the 28 days has expired (no more than 2-3 d_ays before), obtain an <lff,1/ approval number (AIR#) from AA3 and prepare final license and "Final Approval" letter. Send hcense

file (oe sure table of contents piovides for final leuer/licei'ise), final transmittal letter, and final license to HP3 for final review.

#f HP3 approves and forwards to HSC for review. HSC forwards to AAJ for finalization.

i finalizes:

. Add final letter(s)

Update RAES Tracking/ROTT

~ ii&' ~

Verify database concurrence

Update Licensee List

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

Page 2 of 2 All associated doc,,ment templates can be found on the S: Drive at: S:\EPH\Data.\RP _A/R\R,(IES\Licen_sing DoCs

2

'·

,i

·f

PLICAT'5epartment of Energy Richland Operations Office

P.O. Box-550 Richland, Washington 99352

17-ESQ-0008 NOVO 2 2016

Mr. Donald A. Dossett, Unit Manager Stationary Source Unit U.S. Environmental Protection Agency Region 10 1200 Sixth Avenue, Suite 900, OAW-150 Seattle, Washington 9810 I

Mr. John Martell, Manager Rad_ioactive Air Emissions Section State of W as_hington Department of Health 309 Bradley Boul~vard, Suite 201 Richland, Washingto_n 99352

Ms. Alexandra K. Smith, Program Manager Nuclear Waste Program Washington S~Je Department of Ecology 3100 Port of Benton Boulevard RicWani:1, Washington 99354

Addressees:

RECEIVED

NOV - 4 2016 WA Dept of Health

Radioactive Air Emissions Section

TRANSMITTAL OF RADIOACTIVE AIR EMISSIONS LICENSE/AS LOW AS REASONABLY ACHIEV ABL_E CONTROL TECHNOLOGY REVISION REQUEST TO MODIFY THE 2706T RADIOACTIVE AIR EMISSIONS UNIT LICENSE AND NOTIFICATION OF OFF-PERMIT CHANGE, PERMIT NUMBER: 00-05-006, RENEWAL 2

This letter transmits the Radioactive Air Emissions License/ As Low As Reasonably Achievable Control Technology Revision Request (Attachment I), to modify the 2706T FF-01 license to correct Minin:mm Detectable Activity (MDA) limits to reflect the current analytical laboratory contract MDA limits, and the Notification ofOff0 Pennit Change, Permit Number: 00-05°006, Renewal.2 (Attachment 2). Both attachments have been prepared in accordance with Washington Administrative Code (WAC) 246-247 and WAC 173°401-724.

A~chment I is submitted to the Washington State Department of Health forapproval of this requested change, consistent with its authority to administer arid enforce the state Radioactive Air Emissions Regulations.

£u 315 No~ 910 U t-16# I~ -~o4--

Addressees l 7-ESQ-0008

-2- NOV O 2 2016

Attachment 2 is submi~_ed to the Washington State Department of Ecology for its administration of the Hanford Site Air Operat_i_ng Permit (AOP) and to the U.S. Environmental Protection Agency, Region IO as part of the notification process for off-permit changes as outlin_ed in the AOP.

Jfyou have any questions, please contact me, or your staffm_ay contact Jeffrey A. Frey, Assistant Man_age_r for Safety and Environment, on (509) 376-7727.

ESQ:ETF

A~chments

cc w I attachs: Dennis A. Faulk, EPA Phil M. Gent, Ecology John W. Schmidt, WDOH Davis Zhen, EPA Administrative Record Environmental Portal

cc w/o attachs: Gabriel Bohnee, NPT Frank J. Carleo, CHPRC Gary M. Fritz, MSA RU:Sseil Jim, YN Paµ! T. Karschriia, CHPRC Jeff A. Lerch, CHPRC Rod Skeen, CTUIR

Sincerely,

ATTACHMENT 2

NOTIFICATION OF OFF-PERMIT CHANGE. PERMIT NUMBER: 00-05-006, RENEW AL 2

Consisting of2 pages, including this cover page

NOTIFICATION OF OFF-PERMIT CHANGE Permit Number: 00-05-006, Renewal 2

This notification is provided to the Washington State Department of Ecology, Was_h.ington State Department of Health, a11d the U.S. Environmental Protection Agency as a notice of an off-permit chllllge descd_bed as follows.

The following changes are allowed purs.uant to WAC 173-401-724(1), WAC 173-401-724(2), and WAC 173-401-724(6): I. Change is not specifically addressed o_r prohibited by the AOP terms and condi_t,ons; 2. Change does not weaken the enf<JrceabiHty of the existing AOP conditions; 3. Change is not a Title I modification or subject to the acid rain requirements und~r Ti,tJe IV of the FCAA; 4. Change meets all applicable re_quir.ernen.ts and does not violate an existing perm.i~ t~rm or condition; 5. Change has complied with appHcable preccinstruction review requirements established pursuant to

RC:W}0.94.152.

Descrintion of the chan.,e: -

A discrepancy bet~e.en the analytical laboratory minimum d.etectable activity (MDA) and the 2706-T ficense MDA for gross alpha and gross beta (GAB) was discovered during an i.ntema_l c.ompliance audit. To align the license with the atialytical laboratory MDA, a revision to condition 9 of the 2706,Tlicense is proposed. This change will not affect the emissions reported but will accurately reflect t/Je 1.aboratory instrument sensitivity for the GAB an·alyses which is less than the current license req·uirements.

- -Date ofchanl!'e:-/To be orovidecl'in the ai!encv annroval order}

~

Upon approval of changes by the Washington State Department ofHealih

Describe the emissions resilltiiu, from the chani,e: -- - . -

This change is admi.nistrative and there is no change in em.issions

Describe the new appuc·able requirements that will ap()ly as a result of tlie change: /To be orovided in the a12encv.annroval order.)

There is n_o new requirement as this is an administrative revision of an existing requirement.

April 2013, Rev. 0

ATTACHMENT I

RADIOACTIVE AIR EMISSIONS LICENSE/ AS LOW AS REASONABLY A_C!f_lEVABLE CONTROi, TECJ{NOLOGY REVISION REQUEST

Consisting of 13 pages, including this cover page

License/ ALARACT Revision Request NOTE: Any increase to abated or unabated potential to emit (PTE) is considered a modification and requires an

Appendix A Application per Washington Administrative Code (WAC) 246-247.

Subm.ittal Date:

~ License Revision WDOH Condition Number: 9

D ALARACT Revision New ALARACT Rev. #:

D Report of Closure

PROJECT IDENTIFICATION

Project Ti!le': Operation of 2706T Building Current WDOH NOC Nuinber(s): 920 ----------------~~--~--W DOH EU ID Niimber(s): 315 -------------------~--~--C Ii rr en t WbOH Approval Letter Nuinber(s}: AIR-14-1001 ------------~------

DESCRIPTION OF CHANGE

NuitJ,_ber of A_f!ach~e_nts:· I

WDOH will provide a new approval let/er containing any new or modified conditions that result from the following proposed change.

A discrepancy between the analytical laboratory riliiiimuril detectable activity (MDA) and the 2706-T license MDA for gross alpha and gross beta (GAB) was discovered during an internal compl_il!Jlce audit To align th_e lic1ense with the ana,lytical I_aboratory MDA, a revision to condition 9 of the 2706-T license is proposed. This change will not affect the emissions reported but will accurately reflect the laboratory instrument sensitivity for the GAB analyses which is Jess than the current license requirements.

Enter original and proposed wording here:

The original wording for Emission Unit (EU) 315 Condition 9 is·:

AL_PHA/BETA M_DAs and MDCs µ£QUIRED FOR ANALYTICAL LABORATORIES

The following a_lpha/beta M_DA an_d MDC l_imits s_hall be used by the analyti_cal laboratory when analyzing the samples collected.

The Nominal Sample Volume for a single sample filter of20,000 ft3 (5.7E+08 mL) Gross Alph_a (c) MDA (a) IJE-07 µCi MDC(b) 2.0E-16 µCi/mL Gross Beta (c) MDA (a) 1.1 E-06 µCi MDC (b) l.9E-15 µCi/mL

Rev. 3 (1/20/15) Page 2 of3

To request updates to th_isform. please con_taC/ Shawna Berv'eiJ at (509) 946-0192 or [email protected]

Silver (ag) zeolite (d) Ru-106)

MDA (a) 1.9E,05 µCi (as Ru, 106) MDC (b) 3.4E-14 µCilmL (as

The Nominal Sample Volu_lll_e for a quarterly composite sample of262,000 ft3 (7.4E+09 mL) Sr-90 MDA (a) l.4E-05 µCi MDC (b) l.9E-15 µCi/mL Gamma Energy Analysis (e) MD_A (a) l.4E-05 µCi (as Cs-137) MDC (b) l.9E-15 µCi/mL (as Cs-137) l_sotopic P1.1 (i.e. Pu-238, Pu-2391240) Pu-241 Am-241

MDA (a) l .SE-06 µCi MDA (a) 7.4E-05 µCi MDA (a) l .4E-06 µCi

MDC (b) 2.0E-16 µCi/mL MDC (b) I.0E-14 µCi/mL MDC (b) 1.9E-16 µCi/mL

MDA = minimum detectable activity; M_DC = minimum detectable concentration.

(a) Actual MD As derived from sample analyses sti_all be as low as reasonably achievable and s_h_a(I not exceed the values specified in Table I provided the sample meets or excee_ds its respective nominal volume. The target MD As in Table I are derived from m_ultiplying the MDCs in Table I by the respective nominal sample volum_es shown in the table.

(b) Actual MDCs derived from sample analysis shall be as low as reasonably attainable and shall not exceed the values specified in the Table I provided the sample meets or exceeds its respective nominal volume. The target MDCs in Table I are 10% of the concentrat_ion values in Table 2 of 40 CFR 61, Appendix E.

(c) GAB emission data are oft~n used in dose calculations to substitute for the pre_sumed presence of the u_s~lly most prevalent alpha- and beta-emitting radionucl_ides having the highest dose factors, which, depending on facility source term, for alpha-emitters has mostly usually been Pu-2391240, but occasionally A_lll-241, and for beta-emitters, Sr-90, but occasion!lllY Cs-137.

(d) Silver-zeolite analysis shall be designed to primarily identify 1-129. (e) All positive gamm_a-energy analysis (GEA) results shall be reported, with the exception ofshort-lived

progeny of Rn-222 and Rn,220. At a minimum, GEA shall be designed to identify peaks of Co-60, Ru-106, Sb-125, Cs-134, Cs-137, Eu-152, Eu-154, Eu-155, and Pa-231.

The ~roposed wording for EU 315 Condition 9 is:

ALPHA/BETA MD As and MDCs REQUIRED FOR ANALYTICAL LABORA TORJES

Tf:ie following alpha/beta MDA and MDC limits sh_all be used by the analytical laboratory when a:0-alyzihg the samples collected.

The Nomin_al Sample Volume for a single sample filter of20,000 ft3 (5.7E+08 mL) Gross Alpha (c) MDA (a) 5.0E-06 µCi MDC (b) 8.SE-15 µCi/mL Gross Beta (c) MDA (a) I .0E-05 µCi MDC (b) I .8E-14 µCi/mL Silver (ag) zeolite (d) MDA (a) 1.9E-05 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-I 06)

The Nominal Sample Volume for a quarterly composite sample of262,000 ft' (7.4E+09 mL) Sr-90 MDA (a) 1.4E-05 µCi MDC (b) l .9E-15 µCi/mL Gamma Energy Analysis (e) l\iDA (a) L4E-05 µCi (as Cs-137) MDC (b) I.9E-15 µC-i/mL (as Cs-137) Isotopic Pu (i.e. Pu-238, Pu-239/240) Pu-241

Rev. 3 (l/20/iS)

MDA (a) l .5E~06 µCi MDA (a) 7.4E-05 µCi

Page 3 of3

MDC (b) 2.0E-16 µCi/mL MDC (b) l.0E-14 µCi/mL

To request updates to tl1isform, please contact Shawna Berven at (509) 946-0192 or [email protected]

Am-241 MDA (a) J .4E-06 µCi MDC (b) J.9E-l 6 µCi/mL

MDA = minimiim detectable activity; MDC = ininimum detectable concentration.

(a) A_ctual MDAs 4erived from sampl_e analyses shall be as _low as reasonably ac_hieva_ble and sb;i_ll not exceed the values specified in Table I provided tbe sample meets or exceeds its respective nonrinal volume. The target MDAs in Table I are derived from multiplying tbe MDCs in Table I by tbe respective nominal sample voliimes shown in the table.

(b) Actual MDCs derived from sample analysis shall be as low as reasonably attainable and shall not exceed the values speci_foxl in the Tab_le I provided t_he s_ample meets or exce_eds it_s respec~ive nonrinal volume. The target MDCs in Table·! are 10% of the concentration values in Table 2 of 40 CFR 6 I, Appendix E.

(c) GAB emission data are often used in dose calculations to substitute for the presumed presence of the usually most prevalent alpha- and beta-emitting radionuclides having the highest dose factors, which, depending on facility source term, for alpha-emitters has mostly usuaiiy been Pu-239/240, but occasionally Am-241, and for beta-emitters, Sr-90, but occasionally Cs0 l 37.

(d) Si_lver-zeoli_te analysis.shaB be des_ign_ed._to prilll_arily i_de_nt_ify 1-12:9. (e) All positive gamma-energy analysis (GEA) results.shall be reported, witb the exception of short-lived

progeny of Rn-222 and Rn-220. At a minimum, GEA shall be designed to identify peaks of Co-60, Ru-106, Sb-125, Cs-134, Cs-137, Eu-152, Eu-154, Eu-155, and Pa-231.

Licensee Name: Licensee Title:

Lic_ensee

Signature: Date:

Rev. ·3 (l/20/15)

SIGNATURE

United States Department of Energy- Hanford Site

Page 4 of3

To fequest updates to tlrisform, please contact Shawna Berven at (509) 946-0/92 or [email protected] - - - --

(Attachment) EU315 Redlined License Version

Emission Unit ID: 315

200W P-296T007s001 296-T-7 This is a MINO~, ACTIVELY ven_lilat~ emission unit.

T PLANT COMfLEX

Emission Unit Information

Stack Height:.28.00 ft 8.53 m. Stack Diameter 2.30 ft.

Average Stack Effluent Temperature: 78 degrees Fahfenhe.i.t_. 2_6 degrees Celsi_us_.

Average Stack Exhaust Vel_ocity: 81_._00 f_t/second, 24.69.m/second.

Abl!~emer:,t Technology ALARACT WAC 246-247-040(4)

state only enforcea_ble: WAC ?46-247-010(4), 040(5), 060(5)

0.70 m.

Zone or Area Abatement Teebnology Prefilter

Required # of Units I

Additional Description

HEPA Fan To operat_e per Cci1_1di_ti_ci1_1s and

Limitations of the hce_n_se.

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

Federal and State Regulatory

Monitoring and Testing Requirements

Radio_n_uclides Requiri_rig Measurement

Sampling Frequency

40 CFR 61.93(c)(4)(e) 40 CFR 61, Appendix B, TOTAL ALPHA TOTAL See special conditions. & WAC 246-247-075(3) Method 114(3) BETA

Sampling Re_quirentents Record Sample Additional Requirements

Addition8r monifo~ing or s~riiplin·g ~equiremer:,ts es_tablished b}' t~i~ Uce'ris_e·wm be listed in the Conditions a·nd.Limitation_s section, if applicable.

Operational Status Operational Status Activities at the 2706-T Facility involve waste management operations in suppon of decontamination and decommissioning operations·at the Hanford Site.

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

Project Title

Operation of 2706-T Building (Replaced NOC ID 829)

Approval#

AIR 14-1001

Dat_e Approved NOC_ID

10/10/2014 920

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

J) The total abated emission limit for this Notice of Construction is limited to 7.S0E-03 mrem/year to the Maximally Exposed Individual (IN AC 246-247-040(5)).

2) This approval applies only to t_hose act_ivities described below. No addi_tional activities or variations on the approved activities that constitute a "modification" to the emission uriit, as

· defined in (WAC 246-247-030(16)), may be conducted. The approved activities are limited to:

Al) PACKAGING AND REPACKAGING WASTE

Page I of9

. (Attachment) EU315 Redliiled License Version

Packaging and repackaging activities are performed for waste generated at 2706'T as well as for onsite and off site generators. The repa_ck_aging of was_te support_s waste accept_ance criteria for other TSD facilities. For example, prohibiteo items from waste packages,are removed and either staged for later handling or repackaging using remote or manual methods.

Packaging and repackaging activities are: Ala) Sorting. Alb) Segrega_ti_on. Al c) Removing prohibited items. Aid) Composfring/aggregating soiids or liquids. Ale) Adding absorbent. Alf) Size reduction [e.g., cutting (jaws, saws, torches)], bending, folding, crushing (e.g., drum crusher), shredding, compacting, or similar methods that do not have a higher extent of disruption]. Alg) Void fiiling. Alh) Pressure relief/release (e:g., aerosol cans, gas cylinders, drums, or other similar containers). A2) VERlFlC_ATlON ACTIVJTlE.S

Verification support activities·are provided for waste and other materials that are generated on or off the Hanford Site.

Verification activities are:

A2a) Physical oliservation. A2b) Nondestructive examination (NDE). A2c) Nondestructive assay (NDA). A2_d) Chemical field sc_reening. A2e) Radiological surveys. A2f) Radiological samples. A2g) Headspace gas sampling. A2h) Chemicalsampling.

A3) SAMPLING ACTIVITIES

Sampling of waste ge_n~rated by operations or by ot_h_er onsite or offsite generators is performed. The purpose of sampling is to confirm process knowledge, characterize waste, support verification, and determine land disposal requirements as applicable.

Sa_mpling activities are:

A3a) Field screening [e.g., pH paper, oxidizer, volatile organic analyses (VOAs), polychlorinated biphenyls (PCBs), or similar screening parameters]. A3b) Obtaining a sample for analysis [e.g., grab, composite, composite liquid waste sampler (COLIWASA), or other similar sampling techniques]. A3c) Shipping/transferring the samples io an approved laboratory for analysis. A3d) Disposition of sample returns (e.g., placement back into the parent container or another approved container/tank). A3e) Headspac:e gas analysis [typically in support of the Waste Isolation Pilot Plant (WWP) Project].

Page 2 of9


A4) DECONTAMINATION/REFURBISHMENT ACTNITIES Mat_eri_als, e_quipment, ancl waste can be dec_ontam_1nate:d ( e.g., free release, reduce the radiological levels, or other similar criteria) using a variety of methods. Equipment can also be repaired and refurbished within the 2706-T facility. Within 2706-T, decontamination of2706-T structural components may be performed.

Decontamination and refurbishment activities at 2706-T are: A4a) Vacuum blasting. A4b) Brushing. A4c) Abrasive tools_. A4d) Scraping. A4e) Washing (e.g., chemicals/detergents). A4f) immersion. A4g) Electro-polishing. A4h) C_utting (e_.g., removal by sawing, torch cutting more highly radioactive 1,omponents or other.similar methods). A4i) Ru_st/paint removal. A4j) Sand blasting. A4k) Vacuuming.

A5) MAINTENANCE ACTNJTIES A variety of preventative and/or repair maintenance activities·are perfonned at 2706-T. Som_e m·aintenance activities involve the temporary shutdown of the 296-T-7 exhaust stack.

Maintenance activities are:

A5a) Painting. A5b) Crane maintenance. _ A5c) Electronic systems functional checks and repairs [CAMs, personnel contamination monitors (PCMs)]. -A5d) Cal1_brations. A5e) Mechanical overhaul and rebuild. A5f) Bearing replacement. A5g) Pump and motor alignment. Maintenance may be perfonned on: A5h) Rollup doors. A5i) Heat pumps. A5j) Exhaust fans. A5k) Transfonners. A5I) Scale systems. A5n:i) Wire rope A5n) Stack systems. A5o) Forklifts.

A6) WASTE TREATMENT ACTJVITIES

2706-T"is a RCRA treatment and Storage facility permitted by th·e Washington State.Department of Ecology (Ecology).

Treatment activities are:

A6a) Macroencapsulation.

Page 3 of9

(Attachment) EU315 Recilined License Version

A6b) Absorption. A6c) Neutralization. A6d) Imrno_bilization. A6e) Encapsulation. A6t) S_ta!Jilizaticm (solidific_ation, cement_ation, grout_ing). A6g) Compaction, A6h) Amalgamation. A6i) Segregation. A6j) Shredding. A6k) Ve_nti1_1g a11d drilling. A61) Size Reduction.

A7) RECYCLING ACTIVITIE~ .

Materials are recycled whenever possible. Recycled materials are: ferrous and non-ferrous metal, l_igh_t bulbs, a~rosol cans, oi_ls, and batteries.

A8) STORAGE ACTIVITIES

270_6-T stores materials ( chemicals, or equipment, or similar materials) to support operations. Radioactive wastes may b_e stored uncontainerized or in: A8a) Containers (boxes, drums, tanker trucks/raili::ars, or large diameter containers). A8b) Tanks. A8c) Sffmps and pipes.

A9) EQUIPMEN, MATERIALS, AND WASTE MOVEMENT ACTIVITIES

The movement of materials, equipment and waste is necessary to siippcirt operations and maintenance. Movem·ent activities (using a forklift, crane, truck, dolly, personnel) are: A9a) Receiving waste (liquid, solid, semi-solid) for storage and/or treatment. A9b) M_ovement of waste (li9u_id, solid, semi-solid) and e9uipm_e_nt_. A9c) Movement ofliquids, sludges, or other waste from containers and/or tanks via transfer lines .. A9d) Waste container transfers. A9e) Placing aiid storing chemical products in flariirriable cabinets or other approved storage locations. A9t) Movemen_t of contaminated material_.

AJO) HOUSEKEEPING ACTIVITIES

House_k_eep~ng ac_tiviti~s inv(?lve 111ain_taining J706-T in a c_lean a11<l orderly condi_tiol}_.

Housekeeping activities are:

Al0a) Sweeping (brooms). Al Ob) Mopping (squeegees or mops). A I 0c) Vacuuming. A I 0d) _Dusting. Al0e) Wiping (sponges, towels). A 1 0t) Picking up debris. A I 0g) Removal of trash.

Page 4 of9


Al I) SURVEILLANCE ACTIVITIES

Surveillance activities irivolve walking down and inspecting various areas, systems, a·nd components. Surveillances typically c:Onsist of daily, weekly, and monthly inspect.ions of waste containers, tanks, buildings, or similar locations. Surveillances are subject to change (adding, deleting and/or modifying) as operations, maintenance, engineering, and radiological control dictates. Surveillances, inspections, and maintenance activities that do not have the potential to create airborne contamination can occur within the 2706-T Building when the 296-T-7 exhaust stack emission system is shutdown.

The following surveillances are performed at 2706-T:

A I I a) Container storage areas treatment.and storage tanks and ancillary equipment. A 11 b) General condition of building structures. Al I c) Cold weather surveillances (typically, between October I and March 31 ). Al Id) Inspection of equipment. A 11 e) Inspection of HEPA filtered vacuums. A 11 f} Radiological surveys.

· 2706-T: The 2706-T facility includes the 2706-T bui.lding and the 2706-TA Building. The 2706-T Building and the 2706-TA Building make up a single structure and are described briefly here. The 2706-T facility handles low-level waste, mixed low level waste, and transuranic (TRU) waste. The 2706-T Building was built in 1959 as a low-level.radiological decoiltarriination building. The original building was 66 feet long and 50 ft wide. The 2706-.T A Building was added in 1994/1995 over the concrete pad cin the west side of the 2706-T. One rollup-door and one m.an-door provide access between 2706-T and 2706-T A Building. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-T Building operations area. Waste handling and. decontamination operational areas of the 2706-T Building are open and unobstructed. The 2706-T building is a pre-engineered metal building. The foundation is concrete slab on grade throughout. The 2706-T Building includes two pits, one for deconta·min·ation and treatment of motor vehicl.es and other large equipment, and one for rail car decontamination and treatment. These pits can also b.e used to support collection of Hquids from waste handling activities.

CURRENT OPERATIONS IN 2706-T BUILDING

Include waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement activities. One egress door leads directly to the exterior of 2706-T Building. Other doors lead directly to the non-ventilated lean-to on the north side, and an air lock provides access to the 2706-TA Building operations area. The railway and auto pits have metal grating and some wooden covers to prevent falls into the pits. An epoxy floor sealant had been applied to all operational area floors. To support these operations, greenhouses are used as n.ecessary in 2706-T. Greenhouses are temporary or semi-permanent radioactive material confinement structures, and can be used for contamination control. If used, greenhou·ses shall exhau.st t.o the areas ven_tHated by the 296-T-7 ventilation system.

The atmosphere clean-up train (ACT-I) system, sprinkler system riser room, and electrical room are located in the south lean-to (non-ventilated).

2706-TA: The 2706-TA Building is an addition to the 2706-T Building installed in the 1990s as an add-on over the concrete storage pad located west of the building. The 2706-T A Building is

Page 5 of9


approximately 54 feet long, 45 ft wide, and_ 23 feet high. There are two roHup doors located at the west end of the building. The 2706-T A Building has steel primary and secondary struc_tural elements and corrugated.sheet metal exterior siding and roofing panels. Three heat pumps provide heating, ventilation, and air conditioning for the 2706- TA Building operations area. The floor is concrete slab on grade. An epoxy floor sealant had been applied to all operational area floors. Waste handling and decontamination operational areas of the 2706-TA Building are open and unobstructe_d.

CURRENT OPERATION IN 2706-TA BUILDING

Include waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement activities. To support waste activities, greenhouses are used i_f necessary. Greenhouses are temporary or semipermanent radioactive.material confinement structures, and can be used for con_tamination control. When used, greenhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation system.

Atta_ched to the south side of 2706-T A Building is a lean-to m_ade_ up of two rooms. The l_arger room houses the new ACT-2 HEPA filter system, which serves the operational areas. The ACT-I and ACT-2 systems exhaust t_hrough the 296-T-7 stack. The second room houses electronic controllers and electrical switchgear supporting operations.

Em_issions from these activities are exhausted through 296-T-7, except for emissions resulting from vented TRU containers stored within the facility, which may be released to the 200 Area diffuse and fugitive emission unit when the ventilation system is not in operation ..

3) The PTE for this project as determined under WAC.246-247-030(2l)(a-e) [as specified in the application] is 7.50£-02 mrem/year. Approved are the associat_ed potential release rates (Curies/year) of:

DE-0 l.90£-05 Contained WAC 246-247-030(2l)(a)

Any radionuclide on the chart of the nuclides could be encountered. A small contribution from the gaseous radionuclides may b.e encountCI'ed. Th_e ra.dionu_cli_des \\ft~i,n the facili_ty are con_trol1_ed by t_~_e lic_en~_ce ii:i t~s of dose-equivalent (DE) Curies. A consef'Vati\le PTE tracking method for the dem·onstration of compliance to the lfccnscd PTE limits is pro\~ded in the conditions of the license. "Contn.incd" means "within typical TRU waste containers for which a release fraction of 2E-09 has been determined to be appropriate."

DE-0 2.90E-03 Liquid/Particulate Solid WAC 246-247-030(2l)(a)

Any radionuclide on the chart of the nucfidcs could be encountered. A small connibution from the gaseous radionuclides may be encountered .. The radionuclides within the facility are known to and controlled by the li_censee in t.en:ns ci( d.ose_ ~qllival~nt (~E) Curi.es. A c·on·serv~!i_ve PTE trackin·g method for the demonstration of compliance to the licensed PTE limits is provided in the conditions of the license. This amount of DE curies is pcnnined v.ithin the facility uncontaincd in TRU waste containers as liquid/particulate for which a release fraction of I E-03 is appropriate.

H -3

Rn - 219

Rn- 220

Rn - 222

l.50E+Ol

2.00E-01

2.80E+Ol

lA7E+OO

Gas

Gas

G_as

Gas

WAC 246-247-030(2l)(a)

WAC 246-247-030(2l)(a)

WAC 246-247-030(2l)(a)

WAC 246-247-030(2l)(a)

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

H -3 Rn- 219 Rn - 220 Rn- 222

Page 6 of9

(Attachment) EU315 Red.lined License Version

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 ariy changes to a NESHAP major emission unit when a specific is_otope is newly identifj.ed as contributing greater than I 0% of the potential TEDE to the MEI, or greater than 25% of the 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 orfederal regulations·including changes that would constitute,a significant modification to the Air Operating Permit under WAC 173-401-725(4). Notice will b_e provided according to the particular regulation under which notification is required. If the applicable regulation(s) does notaddress manner and type of notification, DOE will provide the Department with advance wri_tten notice by letter or electrnnic mail but not solely by copies of documents.

4) USE OF ALARA PRINCIPLE

All activities involving potentially airborne radioactive materials in 2706-T shall be conducted in accordance with the ALARA principle. (WAC 246-247-040(5)).

5) A PTE TRACKING IN AIR SPACE VENTILATED BY 296-T-7

The PTE in the space ventilated by 296-T-7 shall be tracked for compliance to the license limit as described in this condition.

Waste Co_ntained in Typical TRU Waste Containers: PTE < 9490 DE Ci/ye_ar • 2E-09. Compliance: maintain annual total of DE Ci • 2E-09 below limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 24 I-Am].

Venting of Waste Uncontained in Typical TRU wast_e Con_t_ainers: PTE < 9490 DE Ci/ye_ar • I E-03 • 5.7E-05. Compliance: maintain annual total o(DE Ci• I E-03 • 5.7E-05 vented bel_ow limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 241-Am].

Torch cutting:.PTE< 9E-04 rirreri:i/year. Compliance: Maintain the product of inches cut and contami_nation level t_o: < 8.8 E+09 in-dpm/100 sq.cm beta/gamma and< 8.8E+6 dpm/100 sq.cm alpha. (Note: The release at the cut is assumed gaseous due to high cutting temperature, but it is also assumed that any gas·es thus formed wffl reconden·se into a particulate form by the time they reach the filters, and be subject to the standard removal efficiency oftbe HEPA filter.) [Dose contribution of this activity to license limit estimated assuming all alpha is 241-Arn, ail beta/gamma is 137-Cs.]

Gases in Waste Contained in Typical TRU Waste Containers: PTE < 7E-04 mrem/year. Compliance - maintain: tritium PTE below 15 Ci/yr; 219-Rn PTE below 0.2 Ci/yr; 220-Rn PTE below 28 Ci/yr;.222-Rn PTE below 1.47 Ci/year. These !i1J1_its apply to process-enh_anced radionuclides only, per (WAC 246°247-020(4)). [Dose contribution of this activity to license limit estimated using isotopespecific dose c_onversions factors.]

Other Processes: PTE < 4.9 E-02 mrem/year. Compliance: maintain total facility DE Ci/year (exclusive ofTRU included above)• IE-03 below 2.9 • IE-03, or1J1aintain the sum Ci(alpha) • I E-03 • 17 + Ci(beta/gamma) • IE- 03 • 0.31 below 4.9 E-02 mrem/year. [Dose contribution of this activity's PTE to license limit estimated assuming DE Curies are 241-Am].

Page 7 of9

(Attachment) EU315 RedlinedLicense Version

Residual Contamination: PTE < 7. I E-03 mrem/year. Accounts for residual contamination present in fadlity ifp<:>sting is Contamination Area or below. G_reater contami_na_tion levels result from other processes, and are accounted for in the PTE(s) associated with them. No specific compli_ance demonstration is necessary beyond the compliance with posting requirements. [Dose contribution of this activity to license limit estimated assuming all alpha is 241-Am, all beta/gamma is 137-Cs.]

The facility shall document and implement a progra·m of inspection and maintenance to ensure the continuous integrity of contamination fixative used within the facility.

That the total PTE does not exceed licensed limits shail lie routinely verified, and document_ation of that verification shall be maintained. (WAC 246,247-040(5)) (WAC 246-247-060(5))

6) CONDITIONS REQUIRING OPERATION OF VENTILATION SYSTEM

The ventilation system shall be in operation when activities involving radioactive or contaminated materials are performed within the ventilated space_. The ventilation system sha_ll be i_n operation if any part of the 2706-T Facility is posted as a high contamination area, or higher. Storage/movement ofveritilated (NucFil or vent clip) TRU containers is permitted when the ventilation system is not operating (WAC 246-247-040(5)).

7) CONDITIONS REQUIRING CONTINUOUS RECORD SAMPLING

Record sarriplirig shall be continuous whenever the ventilation system is operating. San1ples shall be collected monthly, for periods in which the ventilation system has operated. Samples shall be composited and analyzed quarterly, ifa sample was collected during that quarter. Licensee sh_all docu_ment minimum detectable concentrations for the stack emissions measurements (WAC 246-247-075 (3, 8, 9))

8) CLOSURE OF ACCESS DOOR_S

All acce·ss doors shall remain closed until the restart of the ventilat_ion system (WAC 246-247-040(5)).

9) ALPHA/BETA MDAs an_d MDCs REQUIRED FOR ANALYTICAL LABO RA TORIES

The following alpha/beta MDA and MDC limits shall be used by the analytical laboratory when analyzing the samples collected.

The NoD1inal S~mple Volume fora single sample filter of20,000 ft3 (5.7E+08 mL)

Gross Alpha (c) MDA (a) -1-+5.0E-0+6 µCi MDC (b) ;_y)8.8E-le5 µCi/mL

Gross Beta (c) MDA (a) 1.-1-0E-0eS µCi MDC (b) l.98E-IM µCi/mL

Silver (ag) zeolite (d) MDA (a) l.9E-05 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quarterly composite sample of262,000 ft3 (7.4E+09 mL)

Sr-90 MDA (a) I .4E-05 µCi MDC (b) I .9E-15 µCi/mL

Gamma Energy Analysis (e) MDA (a) I .4E-05 µCi (as Cs-137) MDC (b) l.9E-l 5 µCi/mL (as Cs-137)

Isotopic Pu

(i.e. Pu-238, Pu-239/240)

Pu-241

Am-241

MDA (aj I .SE-06 µCi

MDA (a) 7.4E-05 µCi

MDA (a) J .4E-06 µCi

Page 8 of9

MDC (b) 2.0E-16 µCi/mL

MDC (b) 1.0E-14 µCi/mL

MDC (b) l.9E-16 µCi/mL


MDA = miriimum detectable activity; MDC= minimum detec.table concentration.

(a) Actual MDAs derived from sample analyses shall be as low as reasonably achievable and shall not exceed the values specified in Table I provided the sample meets cir exceeds its respectJve.n<Jm.inal volwne. The target M.D.As in Table I are de.Jived from mu.Itiplying the MDCs in Table I by the respective nominal sample volumes shown in the table.

(b) Actual MDCs derived from sample analysis shaB be as low as reasonably attainabk and shall not exceed the values.specified in the Table I provided the sample meets or exceeds its respect.ive nominal vol.ume. The target M·bcs in Table I are 10% of the concentration values in Table 2 of 40 CFR 61, Appendix E.

( c) GAB e~ission dat.a ¥e ojten used in dose ca.J.cuJations to su.bsfrtute for the pre.sumed presence of the usually most prevalent alpha- and beta-emitting radionuclides having the highest dose factors, which, depending <in facility soi:irce term, for alpha-emitters has mostly usually been Pu-239/240, but occasionally Am-241, and for beta-emitters, Sr-90, but occasionally Cs-137.

(d) Silver zeolite analysis shall be designed to primarily identify 1,129,

(e) Afl positive gamma-energy analysis (GEA) r.c,sults sh.all be reported, with the except.i.o_n of short lived progeny ofRn,222 and Rn-220. At a minimum, GEA shall be designed to identify peaks ofCo-60, Ril-106, Sb-125, Cs-134, Cs-I 37,.Eil-l 52, Eil-154, Eu-155, and Pa, 231.

Page 9 of9

ATTACHMENT 2

NOTIFICATION OF OFF-PERJ\11T CHANGE PERMIT NUMB]l:Jl: 00-05-006, RENEW AL 2

Consisting of 2 pages, including this cover page

NOTIFICATION OF OFF-PERMIT CHANGE Perm_it Number: 00-05-006, Renewal 2

This notification is provided to the Washington State Department of Ecology, \Va:shington State Department of Health, a_n_d the U.S. Environmental Protection Agency as a notice ofan off-permit change desc_ri_bed a:s follows.

'f'.he_(ollowirig changes are allowed pursuant to WAC 173-401-724(1 ), WAC 173-401-724(2), and WAC 173-401-724(6): I. charige is not specifically addressed or proh_i):>ited by the AOP terms and conditions; 2. Cliange does not weaken the enforceability of tlie existing AOP conditions; 3. Ch:a:nge is not a Title I modification or subjec_t to the acid rain requirements under Title IV o_fthe FCAA; 4. CJ-iange ineets all applicable requirements arid do_es not violate an existing permit term or condition; 5. Change has complied with applicable preconstnictio·n review requirements established pursuant to

RCW 70.94._152.

Descriotion of.the chan11e:

A discrepancy between the analytical laboratory minimull1 detectable activity (MDA) and the 2706-T l_icense MDA for gross alpha and gross beta (GAB) was discovered during an internal compliance audit. To align the license with the analytical laboratory MDA, a revision to cond_i_tion 9 of the 2706-T license is proposed. This change will not affect the emissions reported but will accurately reflect the laboratory instrument sensitivity for the GAB an_alyses which is less than the current license requirements.

Date of cban11e: _<To_ be nrovided in the·a11:encv· annroval order.). . . . -~

Upon approval of changes by the Washington State Department of Health

Describe the emissions resultin11 from the chaiiee: ...

This change is administrative and there is no change in emissions . ..

Describe the new applicable requirements that will apply as a result oft!ie·change: fTo be nrovided in the a11:encv annroval order.)_

-- -

There is no new reql)ir~ment as this is an administrative revision of an e_J:<i_sting requirement .

.

April 2013, Rev. 0

3

Completeness Review Checklist (Reference: WAC 246-247.110, Appendix A)

Application Description•(inchlde lM#)::~4'1::.:'f2...2_./Jlli::d.~~'4.!L~ZS,2uc.../___(_~;_ii_,OJ;~Jl'.:.Ct'.,J~..C~'!'.'.Z:.~:.(i~,.l..J...GL;~tQ

Reviewer(s): /:S /lq ijq; I~---

# I.

2.

3.

Item Comment Complete?

Name and address of the facility, Provide all required infonnation. and location (latitude and longitude) of the emission,unit. Ref: l 7-ESQ-0008

Page: I

Name, title, address,,and phone P.roviae all required infonnation. number of the responsible manager. Ref: I 7°ESQ-0008

Page: I

Identify the type of proposed Provide all;required infonnation. action for which this application is, submitted: • "Emission·Unit" means,any-single localion that emits or has the PTE airborne radioactive Ref: l 7-ESQ-0008

(a) Construction of new emission material. This may be a;point source,:nonpoin1 source,.or source of fugiiive emissions. Page: 1

unit; • ''Construction'' means fabrication, erection, or.installation of.a new building, structure,

(b) Modification of existing plant, process, or operation within a facility that has the PTE airbome radionuclides, (WAC 246-247-030(8)]

emission unit: identify whether • "Modificafio,t" means anY.ph)'sical change in,.or change in the ~ethod of operation of, an this is a signilicanl modification; emission-unit that couldiincrease the amount of radioactive,materials em~tted or may,restilt (c) Modification:ofexisting in the emission of any radionuclide not previously emitted! 1'[WAC 246,247-030(16)] unregis1ered unit. • ''Significant'' means the PTE airbome·radioactivity at·a rate that couldiincrease·the TEDE

to the MEI by at least 1.0 mrem/yr as a:resuh of a proposed modification. [WAC 246,247-030(25)]

1 "This definition includes the cieanup of land contaminated with rddioactive material, the decommissioning of buildings, structures, or plants where.radioactiVe contamination exists, and changes that'will cause an increase in the emission unii's operating design capacity. This definition excludes routine !nain~cnarice, rolitine rqJair, replacement-in-kind,, any incrc-Jscs,in the production rate or hours of operation,providcd the emission unit docs not exceed the release quantities specifiect'in the license application or the operating, design capacity upprovt--d hyithe dcpartmcnl, adciilion.ofahatemcnt technology as long as ii is not 1lcss environmentally beneficial than existing, approve,lconirols, and changes that result in an increase in the quantity of cmission_s of an existing radionuclide that-will be offset by an _eq~ml or greater decrease in the quantity Of emissions of another radionuclide that is deemed at least as hai..nr<lous with regard to its TEDE'to the MEI."

Page I of8

# Item Comment Complete? 4, If this projecl'is subject to the The issuance, revocation, or suspension of individlllll licenses authorizing the

requirements of the State possession, use, and•transfer of radioaclive,source,material under RCW 70.98.080 is Environmental' Policy Act (SEPA) exempt from-SEPA requirements. [WAC 197-11-845] ·Ref: t?-ESQ,0008·

contained in WAC I 97-1 I, provide- NIA ALARCT

the name of the lead agency, lead' REVISION REQUEST

agency contact person, and,their Page: phone number.

S; Describe,the chemical and The application should provide a process flow chart and define all unit operations physical•processes upstream of the performed on·the radionuclide source material, to include process maximum emission.unit. temperature, peak pressure, rates, flow rates, and directions wiihin.ihe process, physical, Ref: 17-ESQ0 0008

and chemical form and thermodynamic state of the radionuclide materialiat all steps in NIA ALARCT

the process. Unit operations include: fluids transportation, filtration, solids fluidization, REVISION

evaporation, condensation, gas absorption, distillation; extraction, adsorption, drying, REQUEST gas liquefaction, refrigeration, solids transportation, crushing,and pulverization, milling, screening,and sieving, mixing, distillation, and,chemical or nuclear reaction. ·Page:

Process·flow chart Unit operations described· P~ocess variables given Physical slate changes identified Chemical form changes identified State changes identified Process equipment identified:

• Maker

• Model . • Maximum capacity or functional rating

• Description

6, Describe the existing and proposed Provide all·required infonnalion. (as applicable) abatement technology. Describe,the basis for • "Abatement teclmology" means any mechanism, process or ntethod that has the potential to Ref: 17-ESQ-0008

the use of the proposed,system. redLice public exposure-to radioactive air emissions. Abatement control features include NIAALARCT Include expected efficiency of aLitomatic mechanisms and administrative,.controls used in,the:operation·and_control·of REVISION

each control,device, and the annual abatement lechnology from entry ofradionuclides into the Veritilated vapor space to release REQUEST

average volumetric flow rate in to the environment. [WAC 246-247-030(1)]

meters'isec for the emission unit. Abatemcnt:technology identified: Page:

•Maker •Model

Page 2 of8

# Item Comment Complete?

•Maximtim capacity or funclional rating •Controls

Basis description Efficiency of each control·device Annual 1 average Volllmetric flow rate-for emission•unit

7. Provide conceptual drawings Provide all,rcquircd infonnation. showing all applicable control technology components fromthe • "Abatement tecluiology" means·any,mechanism, process·or method•that has the potential to Ref: I 7'ESQ-0008

point of entry of radionuclides'into · redllce public exposure to radioactive air.entissions. Abatement control features;include

the·vapor space,to•release to the automatic mechanisms and·administrative.controls used in the operation and control of N/AALARCT

environment. abatement techilology from entry ofradiormclides into the Ve~tilated vapor space·to release REVISION

' lo the environment. [WAC 246-247-030( l·ff REQUEST

Control technology identified: Page:

•Maker •Model •Maximum capacity or functional rating •Controls '•Description

8. Identify each radionuclide that Provide al11required infonnation. could contribute greater than ten I

· percent of the PTETEDE to the Provide the,basis for this determination, and describe-the controls that are in place to Ref: 11:ESQ-0008·

MEI, or greater than 0, I mrem/yr ensure thaMhis description remains accurate through·the operating.life of the emission N/AALARCT

PTE TEDE to the MEI. unit. REVISION

• list of radionuclides that couid1contribute greater than 10% REQUEST

• list of radionuclides that could contribute greater than 0, I mrem/yr . Page:

9. Describe.the eflluenl monitoring Provide all required information. system for the proposed control system. Describe each piece of Provide design drawings of the.sampling/monitoring.system. For the Ref: ,J7cESQ,0008·

monitoring equipment and its sampling/monitoring system, include maker, model number, maximum capacity, and Page: 8·ofNOC 920

monitoring capability, including descriptive comment. Provide maker and model of sample filters to be used, and which is page 7 of

detection limits, for each collection efficiencies of those filters. Provide.the overall efficiency of the sample replacement NOC J0JJ. This is the

radionuclide that-could contribute nozzle and1sample·transmission1line, Describe sample analysis·techniques and the key revised section greatedhan ten percent of the P'.f.E equipment used in analysis. Describe the.controls that:are in place to ensure.that these TEDE to the MEI, or greater than descriptions,remain accurate through the operating life of the emission unit. 0.1 mrem/yr PTE TEDE to the

l'age 3 of8


MEI, or greater than twenty-five Descriplion of moni1oring·system

percent of the TEDE to the MEI, Design· drawings

after controls. Describe'the Sampling, monitoring and,analyzing equipment and system components:

method for monitoring or • Maker

calculating those radionuclide • Model number

emissions. Describe the method • Capacity

with detail sufficient to • Description

dcmonstratc compliance with the Monitoring ·Equipment:

applicable requirements, • Detection limits for each item on the list provided for 8

• Detection limits for each radionuclide that could contribute.greater than 25% of the TEDE to the MEI (abated)

Detailed•description'ofmethod:for monitoring and calculating the emissions

to. Indicate the,annual possession quantity for each.radionuclide.

Ref: I 7-ESQ-0008

N/AALARCT I REVISION

REQUEST

- Page:

11. Indicate the:physical form of each Provide,all required information. radionuclide in inventory::solid, I 7-ESQ-0008

particulate solids, liquid, or gas. Physical. fonn for each radionuclide Ref: N/AALARCT REVISION REQUEST

Page:

12. Indicate the release form of each Provide,all required information. radionuclide in inventory: particulate solids, vapor, or gas. Sec note below for flllidizcd or-aerosolized portici.Jlates or liquids, and \ndicate whether these arc Ref: I 7-ESQ-0008

Give the chemical fonn and' ICRP present.

30 solubility class, if known. NIA ALARCT

• Release fonn for eaCh mdionuclide;in inventory REVISION

• Chemical fonn for each radionuclide in inventory REQUEST

• ICRP 30 solubility.class for each.radionuclide in·inventory

• Are fluidized or aerosolized oarticles oresent? Page:

Page 4 of8

# Item

13. Release rates.

(a),New emission unil: Give predicted release rates without any emissions control equipment (the •PTE) and with the proposed control equipment using the efficiencies described·in subsection (6) of WAC 246-247-110.

(b) Modified emission,unit: Give predicted:release rates without any emissions.control equipment (the PTE)·and withithe existing and proposed control equipment using the efficiencies described in subsection (6) of WAC 246-247-110. Provide theilatestyear's emissions data or emissions estimates.

ln,all cases, indicate whether the emissio~ unit is operating in a batch·or continuotis•mode.

14. Jdentifv the MEI bv distance and

Comment

Provide all required information,

"Porenlial-to-emil" means 1he rate of release ofradionuclides from an emission unit based on,the actual or potential discharge of the effiuent stream that would result if all,abatement control equipment did not exist, but operations·are-otherwise normal.

Determine PTE by one of the following methods:

(a) Multiply the annual possession quantity of each radionuclide by the release fraction for that radionuclide, depending on its physical state. Use the following,release fractions:

(i) I for gases; (ii) 10·3 for liquids or-particulate solids; and (iii) 10-<> for solids.

Determine the physical·stale for each radionuclide by considering-its.chemical form and the highest temperature to=which iris subjected. Use-a release fraction of one if the radionuclide is subjected to temperatures at or above its,boiling point; use·a re,ease.fraction of 10-3 if the radionuclide'is subjected to temperatures at.or aboveiits melting poirit, bul below its.boiling point. lfthe·chemical form,.is not known, use·a release frac~io~·ofOne for-any-radiom.iclide·thal is heated:to a temperature of one hu!}di"ed degrees Celsius or more, boils at a temperature of.one· hundred degrees Celsitis or less, or is iritentionallY dispersed into the.environment. 01her release fractions may be·used only with the department's approval; or

(b)·Perfomra back-calculation i.ising ~east.ired.emission rates and in-siw measiJremerits of.the control equipment-efficiencies, as approVed by the-department; or

(c) Measure the quantities of radioniJclides captured in.each:_coritrol device, coupled W~1h,in silu measurements of the control·equipment.efficiencies, as approvediby the department; or

(d).Sample•the effiuent upstream from all control devices, as approved,by ihe department; or

(e) Use an alternative method approved by the department.

Predic1ed-release rates, abated Predicted release rales, unabated latest year's emissions data, for existing emission unils batch or.continuous process reiease fraction justified

Provide all reouired information.

Page 5 of8

Complete?

Ref: 17-ESQ,0008

N/AALARCT REVISION REQUEST

Page:


direction from the emission:unit(s). 'Fhe M El is detennined by "Maximally exposed individual" (MEI) means any member of the public (real or hypothetical) Ref: I 7-ESQ-0008

considering distance, windrose who abides or.resides in:an-unrestrictCd area, and may receive the highesl TEDE from the

data, presence of vegetable emission-unit(s) under consideration, taking into account all exposure.pathways affected by the NIA ALARCT

gardens, and meat or milk radioactive air emissions. [WAC 246-247-030(15)]· REVISION

producing•animals-at unrestricted REQUEST

MEI distance and direction. areas surrounding the emission Page: unit.

15: Calculate the TEDE to the MEI Provide all required information. using an approved procedure (sec J,7-ESQ-0008

WAC 246-247-085). For each "Total effecti,1e dose equivalent" (TEDE) means the sum of.the dose equivalent due to external

radionuclide identified in exposures and the CEDE due to internal exposures. [WAC 246-247-030(26)] Ref:

subsection (8) of WAC 246-247- NIA ALARCT

110, determine the TEDEto the By radionuclideTEDE 10-MEl,,abated REVISION

MEI for existing and proposed By radionuclide TEDE 10 MEI, unabated REQUEST

emission controls, and·without any input data input data supponed? Page:

emission controls (the PTE) using justificaiion for CAP88·usage• the release rates from subsection (not used) (I 3) of,this section. Provide all input data used in the calculations.

16. Provide cost factors for "BARCT"" means-best available radionuclide control technology; ALARACTmeans as low as construction, operation, and reasonably achievable radionuclide control technology. See Chapter 246-247-030(6)-and

maintenance-of the proposed Chapter 246-247-030(4), respectively: An application is incomplete ir it does not contain a Ref: 17-ESQ-0008

control technology components BARCT or ALARACT demonstration.

and•system, ifa BARCT or NIA ALARCT

. ALARACT demonstration is not BARCT is required for all:new construction and significanrmodifications commenced after REVISION

submitted with the NOC. August ,10, 1988. [WAC 246-247-040(3)) REQUEST

ALARACT is required for existing units and non;significant modifications. [WAC 246,247- Page: 040(4).

BARCT or.ALARACT demo altached Cost Factors

17. Provide an estimate-of the lifetime l!rovide the required infonnation. for the facility process with the emission rates provided in this Process lifetime - answered but not ·complete. Ref: I 7-ESQ-0008

Page 6 of·8


application. N/AALARCT REVISION REQUEST

Page:

18. Indicate which of the following A BARCT demonstration is·used to choose control technologies for the mitigation of emissions· control technolo!,'Y standards have of radioactive material from new emission units or significant modifications-to emission units.

Ref: I 7-ESQ-0008 been considered and will be The bases for the BARCT demonstration requirements are the BARCT standard given in WAC complied with in.the design and 246-247-040, and the definition of BARCT given in WAC 246-247-030. This.procedure

N/AALARCT operation of new or modified incorporates certain implementing criteria that enable the department to evaluate a facility's

REVISION emission unit described in this compliance with the BARCT standard. It is the applicant's responsibility to demonstrate the

REQUEST application: effectiveness of their BARCT detennination,to the department. The facility should contact the

department at-the conceptual design phase for guidance on the-BARCT demonstration Page:

ASME/ANSI AG-I, Code on requirements. The department may adjust this demonstration procedure on a case-by-case basis,

Nuclear Air and Gas Treatment as·needed, to ensure compliance with the substantiVe standard.

(where there are-conflicts in The BARCT demonstration includes the abatement technology and indication devices that standards with the other listed demonstrate the effectiveness of. the abatement technology from entry of radionuclides into the references, this standard shall take ventilated vapor space to release to the.environment. The applicarit shnll evaluate all'available precedence) control,technologies that can reduce the ~evel ofradioni.iclide emissions. ASME/ANSI N509, Nuclear Power Plant Air-Cleaning,Units The BARCT demonstration and the:emission unit design and construction,mllst meet, as

and Components applicable, the technology standards shown at right !f the unit's PTE exceeds 0.1 mrem/yr TEDE

ASME/ANSI N510, Testing of to theMEI. If the PTE is below this value, the.standards must be-met only to the extent justified

Nuclear Air Treatment:Syslems by a cost/benefit evaluation.

ANSI/ASME NQA-1, Quality An ALARACT demonstration is used:for inspection or audit purposes, and lo demonstrate . Assurance Program Requirements compliance with the substantive ALARACT technology standard as required by this chapter. An

for Nuclear Facilities ALARACT demonstration is-used,to evaluate the adequacy of control technology on existing

40 CFR 60, Appendix A, emission units and to choose control.technologies for proposed non-significant modifications of

Methods l, I A,2, 2A, 2C, 2D, 4, emission units. The bases for the ALARACT demonstration requirements are the ALARACT

5, and 17 standards given in WAC 246-247-040 and the definition of ALARACT given in WAC 246-247-

ANSI/IIPS·Nl3.1-1999, Sampling 030. It is the applicant's responsibility to demonstrate the effectiveness of their ALARACT determination lo the department. The department may adjust this demonstration procedure on.a

and Monitoring Releases of case-by-case basis, as needed, to ensure compliance with the siJbstantive-standard. Airborne Radioacli ve Substances

· from the Stacks and Ducts of The ALARACT demonstration includes the abatement technology and indication devices, from Nuclear Facilities entry of radionuclides into the ventilated vapor space to release 10 the environment. The facility

shall evaluate the existing control system in relation to applicable technology standards, and

ANSI/HI'S NI 3.1-1969, Guide,to other control technologies that have been successfully operated for similar applications.

Sampling Airborne Radioactive The ALARACT demonstration and the emission unit design and construction must meet, as

Page 7 of8


Materials in Nuclear Facilities:if , applicable, the technology standards at,right if the unit's PTE exceeds 0.1 mrem/yr l'EDE to the the unit's potential-to-emit exceeds MEI. If the Pl'E is below this-value, the standards must-be met only to the,cxtentjustilied by a

'

' 0.1 mrem/yr TEDE to the MEI and coSt/benefit evaluation.

the unit is nol'required to meet Adequacy of the-information suppliedwillibe judged by RAES. ANSI/HPS Nl3.l-1999 under ; [WAC 246-247' 120, WAC246-247-130, invoked by WAC 246-247-040(3) and WAC 246-247-federal regulations. '040(4)]

' ·For each Slf!ndard,not so indicated,

I ; BARCT demonstration given; or ALARACT demonstration given will comply with: I

give reason"to suppon adequacy of!the • ASME/ANSI AG-I de~ign and operation of the emission • ASME/ANSI N509 uni~ as,.proposed: • ASME/ANSI NSIO

' • ANSI/ASME NQA-1

• ANSI/HPS Nl3.1-1999

• 40 CFR60, Appendix A - I or IA - 2, or 2A, or 2C, or 2D -4 - 5

' -17 , Cost/benefit justifying deviations for minors· ; design record.jusiifications for absent components; for majors (parlially present)

Page 8 of8

4

DUPLICATE STATE OF WASHINGTON

DEPARTMENT OF HEALTH OFFIG OF RADIATION PROTECTION

30? Br,1dlcy Blvd., Suite 201 • Rich/iJnd, Washington 99352

TDD Relay Service: 1-800-1/33-6388

November 28, 20 I 6

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

Re: Notice of Construction (NOC) Appli_cation Completeness Review

AIR l6alll2 NOC 1033

Reference: I. Letter 17-ESQ-0008 (IM 9,263), "Transmittal ofRadioacdve Air E_I11issions Lice_ns~/As LowAs Reason<!l>_ly Achiev<1ble Control Technology Revision Request to Modify the2706-T Radioactive Air Emissions Unit License and Notification of Off-Permit Change, Permit Number: 00-05-006, Renewal 2"

Mr. Shoop:

Th_i_s letter 4ocuments th_e complet_eness review ofth_e R~f~r~n!=e I app_l_ication for 2706~T. No further information is required as the application has been deemed complete per Washington Administrative Code (WAC) 246s247-l io Appendix A - Application Information Requirements.

As referenced in WAC 246-247-060(! b), we had 30 days to perform this completeness review from the date the application was received November 4, 2016.

As referenced 1ri WAC 246-24 7-060(1c), within 60 days of the determination of completeness, we shall issue <1 license_. We will WClrk with your staff to have this license issued by January 28, 2017.

If you have any questions regarding this approval, please contact Thomas Frazier at [email protected] or by telephone at (509) 946-0074.

Sincerely,

~~Jttl John Martell, Manager Radioactive Air Emissions Section

cc: (see next page) Pu_hlic H.e.1llh - Ahyays \Vmking inr ,1 S,,ler ,ind I-IP,1!Ihicr \V;1sl.1ington

Mr. Doug Shoop November 28, 2016 Page 2 of2

cc: Ruth Allen, WRPS Matthew Barnett, PNNL Lilyru:u:i Bat1der, Ecology Shawna Berven, WDOH Lucinda Borneman, WRPS Lee Bostic, BNI FrankCarleo, CHPRC Cliff Clark, USDOE-RL Jack Donnelly, WRPS Deimis· Faulk, EPA Eric Faust, USDOE-RL Thomas Frazier, WDOH Gary Fritz, MSA Philip Gent, Ecology Daniel Heuston,. Ecology Reed Kaldor, MSA Paul Karschnia, CHPRC Jim McAuley, EPA John Schmidt, WODH Jeff Voogd, WRPS Environmental Portal RAES Tracking: 16-204; IM 9,263; NOC 1033; EU 315

AIR 16-1112

5

License / ALARACT Revision Request NOTE: Any increase to abated or unabated potential to emit (PTE) is considered·a modification and requires an

Appendix .4 Application per Washington Administrative Code (WAC) 246-247,

Submittal Date: July6~015

~ Lkense Revision WDOH Condition Number: 9

D A!,ARACT Revision NewALARA

~~~~~-

D Report of Closure

PROJECT IDENTIFI

The original worg_ing. ociated with the abatement technology for both licenses included the use of pre and HEPA titers. The proposed wording deletes the wording associated with the pre and HEPA filters. The attached licenses with redlihe/strikeout changes detail the original and proposed wording.

The original wording for Emis_sion Unit (EU) 315 Cond,ition 9 is:

ALPHA/BETA MDAs·and MDCs REQUIRED FOR ANALYTICAL LABORATORIES

The following alpha/beta MDA and MDC limits shall be used by the analytical laboratory when analyzing the samples collect_ed.

Rev. 3 (1/20/15) Pagelof3

To r~qu_est upda_te_s to _this form, please c_ontact Shawna Berven at (509) 946-0192 or ai"[email protected]_

The Nominal Sample Volume for a single sample filter of 20,000 ft3 (5.7E+08 mL) Gross Alpha (c) MDA (a) l.lE-07 µCi MDC (b) 2.0E-16 µCi/mL Gross Beta (c) MDA (a) l.lE-06 µCi MDC (b) l.9E-15 µCi/mL S_ilver (ag) zeolite (d) MDA (a) l.9E-05 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quarterly composite sample of262,000 ft3 (7.4E+o9 mL) Sr-90 MDA (a) l.4E-05 µCi MDC(b) 1.9E-15 µCi/mL Gamma Energy An_alys_is (e) M,DA (a) IAE-05 µCi (as Cs-137) MD (b) l.9E-15 µCi/mL (as Cs-137) Isotopic Pu (i.e. Pu-238, Pu-239/240) Pu-241 Am-241

MDA (a) l.5E-06 µCi MDA (a) 7.4E-05 µCi MDA (a) l .4E-06 µCi

MDA = minimum de_tectable activity; MDC= mi_nimum

(a) Actual MDAs derived from sample analyses shaW s w as re ably achievable

exc_eed. the values s.pecified in. Table I provided the sam~eet . r eeds its resp: . ive nominal volume, The target MDAs in Table 1 are derived from mu · ;'K; ng the MDCs in Table I by the respective nominal sample volumes sho= in the table.

(b) Actual MDCs derived from sample ana1}~:ls-sball be as low as r~o bly attainable and shall not exceed the values specified.in the Table I - v:~e sample me~ o ~eeds its re~pective nominal volume .. The target MDCs in Tab!\ are ¾"hJ:.the concen!l)ltion values in Table 2 of 40

CFR 61, Appendix E. ·!).ell~ ----.......__ -(c) GAB emission dat_a are o ed in do_se cal lg· s to S~5\ityt{for the presumed presence oft_he

usually most prevalen ~~ eta-emitting uioriuclideskaving the highest dose factors, which,

dependin. · go. n facilitifsource t:;, r alpha-emi ha.s mostl.y us.ually been Pu-239/240, bu.t occasionally Am;Q4{,. a for be - mitters, Sr-90, t casicirially Cs-137.

(d) Silver-zeolite.analysis's~e d i ~o primaril · entify 1-129. (e) All .positive amma-ener a · Q!oA)'Tesului aU be reported,.with the ex_ception ofs_hort-lived

progen)'. -22_ Rn-- . ta · EA shall be designed to identify peaks of Co-60, Ru-I b-125, 3 , Cs-13~152, Eu-154, Eu-155, and Pa-231.

The prop ~~ording for 398 ~ondition 9 is:

ALPHA/BETA fvl.~~and M REQUIRED FOR ANALYTICAL LABORATORIES

The followini)i Ii eta MDA and MDC limit_s s_hall be used by the analytical laboratory when analyzing the samples c ected. · ·

The Nominal Sample Vol_ume for a si_ngl~ sample fi_l_ter of20,000 ft3 (5.iE+o8 mL) Gross Alpha (c) MDA (a) 5.0E-06 µCi MDC (b) 8.SE-15 µCi/mL Gross Beta (c) MDA (a) l.0E-05 µCi MDC (b) l.SE-14 µCi/mL Silver (ag) :i:eolite (d) MDA (a) l .9E-05 µCi (as Ril-106) MDC (b) 3.4E-l 4 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quarterly composite sample of 262,000 ft3 (7.4E+09 mL) Sr-90 MDA (a) l .4E-0_5 µCi MDC (b) l .9E-l 5 µC1/mL

Rev. 3 (1/20/15) Page2 or3

To request updates to this form, please con:,act Shawna BervetJ. at (509) 946-0192 or [email protected]·v

Gamma Energy Analysis (e) Cs-137) Isotopic Pu (i.e. Pu-238, Pu-239/240) Pu-241 Am-241

MDA(a) l.4E-05 µCi(asCs-137)

M_DA (a) l .5E-06 µCi MDA (a) 7.4E-05 µCi MDA (a) l .4E-06 µCi

MDC (b) l.9E-15 µCi/mL (as

MDC (b) 2.0E-16 µCi/mL MDG (b) L0E-14 µCi/mL MDC (b) 1.9E-16 µCi/mL

MDA = minimum detectable activity; MDC = minimum detectable concentration.

(a) Actual ·MD As derived from sample analyses shall be,as low as reasonabll/'\chievable a:nd shall i:i_ot exceed the values specified in Table I provided the sample meets or exl)l,ed~ respective nominal vol_um~_. The target MDAs in Tab_le I are derived from multiplying th£KIIDCs m Table I by the respective nominal sample volumes shown in the table.

(b) Actual MDCs derived from sample analysis shall be as low as exceed the values specified in the Table I provided the sa:rn nominal volume.The target MDCs in Table I are 10% oyi..1-'"'""'~ CFR 61, App~ndix E_.

·e sits respective lu in Table 2 of 40

(c) GAB emission data are often used in dcise calculati to substit~e for the presum -~sace of the usually most p_re.valent alpha. - and beta-em, __ "tting ra'd1 u "des.ha~i;:,_the. highest dos £ fors, which, depending oil facility source term., for alpha-emitters ha m tl ~M.y been Pu-23':l -40, but occasionally Am-241, and for beta-emitters, Sr-90, but oc io~lly Cs-137.

(d) Silver-zeolite analysis shall be designe primarily identify -l · . · (e) All positive gammasenergy analysis (G ) i,ults shall be repo , ith the exception of short-lived

progeny ofRn-222 and Rn-220. At a mim · ~ shall be des~ciNJfidentify peaks ofCo-60, Ru-106, Sb-125, Cs-134, Cs-137, Eit-152, -1 , u- and Pa-2y

Rev. 3 (1/20/15) Page-3 of 3

To req·uest updates to this form, please contact Shawna Beiven at (509) 946-0/92 or aii-ric/1/andfiidoh.wa.gov

Attachment 1 EU315 RedHned Licen.se Ve.rsio.n


200W P-296T007-001 296-T-7 This is a M~iNOR. ACTi"VELV venti'iated emission unit.

T PLANT COMPLEX


SLJ!c.k.Height: 28.00 ft 8.53 m. Stack Diameter 2jo ft.

Average Stack Effiuent Temperarure: 78 degrees Fahrenheit. 26 degrees Celsius.

Average Stack Exhaust Velocity:·8 I.00 ft/second. 24.69 m/second.

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

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

0.70m.

Zone or Area Abatement Technology Prefilter

Required # of Units I

Additional Descrip.tion

HEPA Fan To operate per Conditions and

Limitations of the license.

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


Moni.toring and Testing R~quirew-ents

Radionuclides Requiring Measurement

Sampling Frequency

40 CFR 61.93(c)(4)(e) 40 CFR 61, Appendix B, TOTAL ALPHA TOTAL See special conditions. & WAC 246-247-075(3) Method 114(3)" BETA

Sampling Requirements Record Sample Additional Requirements

Additional monitoring or sampling requirements established by this License will be listed in the Conditions and Limitations section,.if applicable.

Operatio.'!aJ St.at.us Ope.ra.t.i.o'!:~1 S.ta.ius A,tivities at the 2706-T Fac.i.l.i!Y irivo.lve waste mal)age'.ll,nt Operat.ions in support of d.econtami.riation and de.coriitTiissiOning ope:ratioris at th.e H,mford She_.

Thi.s Emission Unit has 1 active Notice(s) of Const.ructJo.n,

Project Title

Operation of2706-T Building (Replaced NOC ID 829)

;

Approval#

AIR 14-1001

Date Approved NOC_ID

10/10/2014 920

Con~it.ions (st.ate onJy enforce<!ble: WAC 246-247-040(5), 060(5) if not specified)

I) The total abated emission limit for this Notice of Construction is limited to 7.50E-03 rnrem/yeano the Maximally Exposed Individual (WAC 246-247-040(5)).

2) Thi.s approva.1 applies only to tl19se activit_ies d.~cribed below. No addit.ional ~ct.ivities or variations on the approved activities that constitute a "modification" to the emission unit, as defi°'ed in (WAf, 246-247-030(16)), may be condu.cted. The approved activities are limited to:

Al) PACKAGING AND.REPACKAGINGWASTE

Page 1 of9

Attachment 1 EU315 Redlined License Version

Packaging and repackaging activities are performed for waste generated at 2706-T as well as for onsite and offsite generators. The repackaging of waste supports waste acceptance criteria for other TSD facilities." For example, prohibited items from waste p_ackages are removed and e_ith~r staged for later handling or repackaging using remote or manual methods.

Packaging and repackaging activities are: Ala) Sorting. Alb) Segregation. Ale) Removing prohibited items. A_l cl) Compositing/aggrega~ing solids or liquids. A I e) Adding absorbent. Alf) Size reduction [e.g., cutting (jaws, saws, torches)], ben_ding, fol_ding, crushing (e.g., drum crusher), shredding, compacting, or similar methods that do not have a higher extent of disruption]. Alg) Voic!.filling. Alh) Pressure relie£'release (e.g., aerosol cans, gas cylinders, d.rwns, or either similar containers). A2) VERIFICATION ACTIVITIES

Verification support activities are provided for waste and other materials that are generated on or off the Hanford Site.

Verifica_tion activitie_s are.:.

A2a) Physical ob.s~rvation. A2b) Nondestructive examination (NDE). A.2c) Nond_estructive assay (NOA). A2d) Chemical field screening. A2e) Radiological surveys: A2f) Ra_diological sampies. A2g) Headspace gas sampling. Aih) Chemical sampling.

A3) SAMPLING ACTIVITIES

Sampling of waste generated by operations or by other onsite or offsite generators is performed. The purp:ose ofsamp_ling is to confirm process knowledge, c_l:iar_act_e_rize was_te, support verification, and determineland disposal requirements as applicable.

Sampling activities are:

A3a) Field screening [e.g., pH paper, oxidizer, volatile o"rganic analyses (VOAs), polychlorinated biphenyls (PCBs ), or similar screening parameters]. A3b) Obt_ainil).g a sample for analysi_s [ e.g., gra_b, composite, composite liquid waste sampler (COLIW ASA),_ or other similar sampling techniques]. A3c) Shipping/transferring the samples to an approved laboratory for analysis. A3d) Disposition of sample returns (e,g., placement back into the parent container or anotli:er approved container/tank). A3.e) Headspace gas analysis [typically in s"iipport of the Waste I~olaticm Pilot Plant (WIPP) Project]. · ·· ·

Page 2 of9

Attachment 1 EU315 RedHned License Version

A4) DECONTAMINATION/REFURBISHMENT ACTIVITIES Materials, equipment, and waste can be decontaminated (e.g., free release, reduce the radiological tevels, or other similar criteda) using a vari_ety of me_thods. Equipm.:nt can also be repaired and refurbished within the.2706-T facility. Within 2706-T, decontamination of2706-Tstructural components may be performed.

Decontamination and refurbishment activities at 2706-T are: A4a) Vacuum blasting. A4b) Brushing. A4c) Abrasive tools. A4d) Scraping. A4e) Washing (e.g., chemicals/detergents). A4f) Immersion. · A4g) Electro-polishing. A4h) Cutting (e.g., removal by sawing, torch cutting more highly radioactive components or other similar methods). A4i) Rust/paint removal. A4j) S_and Masting. A4k) Vacuuming.

A5) MAINTENANCE ACTIVITIES A variety ofpreveiltative and/or repair maintenance activities are performed at 2706-T. Some maintenance activities involve the temporary shut down of the 296-T-7 exhaust stack.

Maintenance activities are·:

A5a) Painting. A5b) Crane maintenance. A5c) Electronic systems functional checks and repairs [CAMs, personnel contamination monitors (PCMs)]. A5d) Calibrations. A5e) Mechanical overhaul and rebuild. A5 f) Bearing replacement. A5g) Pump and motor alignment. Maintenance may be p·erforme,d on: A5h) Rollup doors. A5i) Heat pumps. A5j) Exhaust fans_. A5k) Transformers. A5l) Scale systems. A5iil) Wire rope A5n) Stack systems. A5o) Forklift_s.

A6) WASTE TREATMENT ACTIVITIES

2706-T is a RCRA treatment and Swra·ge facility permitted by the Washington St.ate Depanment of Ecology (Ecology).


A6a) Macro~ncapsul_atioll_.

PageJ of9

Attachment I EUJIS Reiliined License Version

A6b) Absorption. A6c) Neutraliz_ation. A6d) Irrimobilifation. A6e) Encapsulation. A_6t) Stabilization (solidifii:at_ion, cementation, grouting). A6g) Coriipacticiii. A6h) Amalgamation. A6i) Segregation. A6j) Shredding. A6k) Venting and driUing. A6l) Size Reduction.

A7) RECYCLING ACTIVITIES

Materials are recycled whenever possible. Recycled materials are:. ferrous and non-ferrous metal, light bulbs, aerosol cans, oils, and batteries. - - ..

AS) STORAGEACTIVITIES

2706-T stores materials (chemicals, or equipment, or sirri.ilar mate'rials) to support operations. Radioactive wastes may be stored uncontainerized or in: A8a) Containers (boxes, drums, tanker tmcks/railcars, or large diame_ter con_t_ainers). A8b)Tanks. A8c) Sumps and pipes_.


The movement ofmate_rial_s, equip01e_n_t and waste is necessary to support operations and maintenance. Movement activities (using a forklift, crane, truck, dolly, personnel) are: A9a) Receiving waste (liquid, solid, semi-solid ) for storage and/or treatment. A9b) Movement of waste (liquid, solid, semi-solid) and equipment. A9c) Movement of liquids, sludges, or othe_r waste from ~_o_nta_i11e_rs and/or t_anks via transfer lines. A9d) Waste container transfers. A9e) Pl.acing and storing c_hemical products in flammable cabinets or other approved storage locations. A9f) Movement of contaminated material.

Housekeeping activities involve maintaining 2706-T in a clean and orderly condition.


A 1 0a) Sweeping (brooms). Al Ob) Mopping (squeegees or 01ops}. Al 0c) Vacuuming. A toe!) Dust_i_ng. Al0e) Wiping (sponges, towels). A 1 Of) Picking up debris. Al0g) Removal of trash.

Page 4 of9

Attachment 1 EU315 Redlined License Version

Al I) SURVEILLANCE ACTIVITIES

Surveillance activities involve walking down and inspecting various areas, systems, and components. Surveillances typically consist of daily, weekly, and monthly inspections of waste containers, tanks, buildings, or similar locations. Surveillances are subject to change (adding, deleting and/or modifying) as operations, maintenance, engine:ering, and radiological control d_ictates. Surveillances, inspections, and maintenance activities that do not have the potential to create · airborne contam_ination can occur withi_n the 2706-T Buildi_ng when the 296-T-7 exhaust stack emission system is shutdown.

The fol]owing surveiUances are performed at 2706-T:

A 11 a) Container storage areas treatment and storage tanks and ancillary equipment.. A 1 lb) Genera_! condition of building structures. Al 1 c) Cold weather surveillances (typically, between October I and March 31 ). A 11 d) Inspection of equipment. All e) Inspection of HEPA filtered vaciiums. Al 1 t) Radiological surveys.

2706-T: The 270.6-T facility includes the 2706-T building and the.2706-TA Bu{lding. The 2706-T Buildingand the 2706-TA Building make up a single structure and are described briefly here.The 2706-T facffity handles low-level wast_e, ntixed low level waste, and transuranic (TRU) waste. The 2706-T Building was built in 1959 as a low-level radiological decontamination building. The original building was 66 feet long and 50 ft wide. The 2706-T A Building was added in 1994/1995 over the concrete pad on the west side of the 2706-T. on·e roHup-door and one man-door provid_e access between 2706-T and 2706-TA Building. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-T Building operations area. Waste handling and decontamination operational areas of the 2706-T Building are open and unobstructed. The 2706-T building is a pre-engineered metal building. The foundation is concrete slab on grade throughout. The 2706-T Building includes two pits, one for decontamination and trea_tm_em of motor vehicles and other large equipment, and one for rail car decontamination and treatment. These pits can a_lso be used to suppon collection of liquids from waste handling activities.


includ~ waste sampling, pa_ckagi_ng an_d repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement activities. One egress door leads directly to the exterior of2706-T Building. Other doors lead directly t_o the non-ventilated lean-to on the nonh side, and an air lock provides access to the.2706-T A Building operations area .. The railwa·y and auto pits have metal grating and some wooden covers to prevent falls into the pits. An epoxy floor sealant had been applied to all operational area floors. To supp:on these operations, greenhouse_s are used as necessary in 2706-T. Greenhouses are temporary or semi-permanent radioactive material confinement structures, and can be used for contamination control. If used, greenhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation s"y:stein.

The atmosphere dean-up train (ACT-i) system, spri_llkler system riser room, and electrical room are located in the south lean-to (non-ventilated).

2706-TA: The 2706-TA B_uilding is an addition to the 2706-T Buj_lding instal_led in the 1990s as an add-on over the concrete storage pad located west of the building. The 2706-T A Building is

Page5of9

Attachment 1 EU3.15 RedHned License Version

approximately 54 feet long, 45 ft wide, and 23 feet high. There are t,fo rbllup doors lO:cated at the west end of the building. The 2706-TA Building has steel primary and secondary structural elements and corrugated sheet metal exterior siding and roofi_ng p_an~l_s. Three heat pµmps provide heating, ventilation, and air conditioning for the 2706- TA Building operations area. The floor is concrete slab on grade. An epoxy floor sealant had been applied to all operational area floors. Waste handling arid decontamination op_erahonal areas of the 2706-TA Building are open and unobstructed.


include waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, deconta:mination/refurbishn)e_nt, 111_aintena11ce, recyclj_ng, storage, housekeeping, surveillance, and movement activities. To support waste activities, greenhouses are u"sed if necessary. Greenhouses·are temporary or semipennanent radioactive material confinement structures, and can be used for contamination control. When used, greenhous_es shall exh_aµ_st to the areas ventilated by the 296-T-7 ventilation system.

Attached to the south side of 270_6-TA Building is a lean-to rriade up of two rooms. Th~ larger room houses the new ACT-2 HEP A filter system, which serves the operational areas. The ACT-l and ACT-2 syst_ems exhaust through the 296-T-7 stac_k. Th~ seco_nd room houses electronic controllers and electrical switchgear supporting operations.

Emission_s from these activi_ties are exh_aust_ed through 296-T-7, except for emissions resulting ·from vented TRU containers stored within the facility, which may be released to the 200 Area diffuse and fugitive emission unit when the ventilation system is not in operation.

· 3) The PTE for this project as determined under WAC 246-247-030(2l)(a-e) [as specified in the application]is 7.S0E-02 inrern/year. Approved are the associa_ted potentia_lrelease rates (Curies/year) of:

DE-0 l .90E-05 C_ontaiiled WAC 246-247-030(2l)(a)

Any radion_uclide on the chart ofth_e nucl_ides could be encountered. A small contribution from the gaseous radiOn_u~li_des may ~C en·coUritered. The radioriuclides within the facility ar~ conr~olle<l by the li~cnsec ·in terms of dose-equivalent (DE) C\lries. A conservative PTE tracking method for the demonstration of compliance.to the licensed PTE limits is provided in the conditions of the license: "Contained" means "~ithin typical TRU waste contain_ers for -.yhich a release fi:actirin_ of 2_E-09 has bt;!~ry. de_t_CJ:l!l_ip..e_d to b_e ap"propririt_c."

DE-0 2.90E-03 Liquid/Particulate Solid WAC 246-247-030(2l)(a)

Any radionuclide on the chan of the nuclides could be encountered. A small con_tribu_tiol) f:r:om the gas.eous radion_u_cli_des may be enCouriteied. The radionuclides within the facility are knoWTl to and controlled by the licensee in terms of do~~ equi~a-icnt (DE) -C~ries. A. conservati;e PT"E cracking method for the demonstration of compliance to the.licensed PTE.limits is provided in the conditions of the license. This amount of DE curies is permitted within the facility uncon_taine_d i1_1 TRU wast_e con:tainers as liquiq./pary:_i~ul_a.t_e fo{which a r~l_cilsc fra~tio·n of I E-03 is appropriate.

H -3 l.S0E+0l Ga·s WAC 246-247-030(2 I )(a)

Rn-219 2.00E-01 Gas WAC 246-247-030(21 )(a)

Rn" 220 2.80E+0l Gas WAC 246-247-030(2l)(a)

Rn - 222 l.47E+00 Gas WAC 246-217-030(2l)(a)

The radio_active isotopes idemified for this emission unit are (no quantities specified):

H- 3 Rn - 220 Rn- 222

Page 6 of9

Attachment I EU315 RedHned License Ve_rsion

The potential release rates described in this C_ondition were iised to determine _control technologies and monitoring requirements for this·approval. DOE must notify the Department ofa "modification" to the emission unit, as defined in WAC 246-247-030(16}. DOE must notify the Department of any changes to aNESHAP major emission unit when a specific isotope is newly identified as contributing greater than 10% of the potential TEDE to tile MEI, or grea_ter than 25% oft.he TEDE to the MEI after controls. (WAC 246-247-110(9)) DOEmust notify the Department of any changes to potential release rates as required by state cir federal regulations including changes that wo.uld c_onstitute a s_ignificant modification to the Air Operating Permit under WAC 173-401-725(4). Notice will be provided according to the particular regulation ooder which notification is required. If the 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 oy copi_c:,s of doclll)1e_ms.

4) USE OFALARA PRINCIPLE

All activities involving potentially airborne radioactive materials in 2706°T shall be conducted in accordance with the ALARA principle. (WAC 246-247-040(5)).

5) A PTE TRACKING IN AIR SPACEVENTILATED BY 296~T-7

The PTE in the space ventilated by 296-T-7 sha.lJ be tracked for compliance to the license limit as described in this condition.

Waste Contained in Typic_al TRU Waste Conta_ine_rs: PT!;:< 9490 DE Ci/year• 2E-09. Compliance: maintain annual total of DE Ci • 2E-09 below limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 241-Am].

Venting of Waste Uncontained.in Typical TRU waste Containers: PTE < 9490 DE Ci/year • I E-03 * 5.7E-05. Compliance: maintain annual total of DE Ci• IE-03 • 5.?E-05 ve_nted below limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 241°Am].

Torch cutting: PTE< 9E-04 mrem/year. Compliance: Maintai_n the product of inches cut and contamiriatio_n level to:< 8.8 E+09'in-dpm/l00 sq.cm beta/gamma and< 8.8E+6 dpm/100 sq.cm alpha. (Note·: The release at the cut is assumed gaseous dueto high cutting t_emperature, but it is also assumed that any_gases thus·formed will recondense into a particulate form by the time they reach the filters, and be subject to the standard removal efficiency of the HEPA filter.) [Dose contribution of this activity to license limit estimated assuming all alpha is 24 l-Am, all beta/garrima is 137-Cs.] ·

G_ases in Waste Contained in Typical TRU Waste Conta_iners: PTE < 7E-04 mrem/year. Compliance - maintain: tritium PTE below 15 Ci/yr; 219-Rn PTE below 0.2 Ci/yr; 220-Rn PTE below 28 Ci/yr; 222-Rn PTE below l .47 Ci/year. These limits apply to process-enhanced radionuclides only, per (WAC 246-247-020(4)). [Dose contribution of this activity to license limit estimated using isotope-specific dose conversions factors,] ·

Other Processes: PTE < 4.9 E-0_:? .. mre_m/year. Compliance: maintain total facility DE Ci/year (exclusive ofTRU included above)* I E-03 below 2.9 • IE-03, or maintain the sum Ci(alpha) • l E-03 • 17 + Ci(bet_a/gamrna) • l E- 03 • 0.J l below 4.9 E-02 mrem/year. [Dose contribution of this activity's PTE to license limit estimated assuriiirig DE Curies are 241-

. Am].

Page 7 of9

Attachment 1 EU315 Red.lined License Version

Residual Contamination: PTE < 7.1 E-03 mrem/year. Accounts for residual contaniiriation present in facility if posting is Contamination Area or below. Greater contamination levels result from other p·rocess:es, and are accmmted for in the PT.E(s) assoc.i_ate_d wi_t_h t_he.m. No specific comp I iance demonstration is necessary beyond the compliance with posting requirements. [Dose contribution of this activity to license limit estimated assuming all alpha is 241-Am, all beta/gamma is 137-Cs.]

The facility shall document and ·implement a program of inspection and maintenance to ensure the coiltiriuous integrity of comamination fixative use.d wi.t_hj_n t_he faciHty.

That the totalPTE does not exceed licensed limits shall be routinely verified, and documentation of that verification shail be maintained. (WAC 246-247-040(5)) (WAC 246-247-060(5))


The ventHat.ion systern shall be in operat_ion when activities involving radioactive or contaminated materials are perfonned within the ventilated space .. The ventilation system shall be in operation if any part of the 2706-T Fadiity is p·osted as a high con.t(!migation area, or higher. Storage/movement of ventilated (NucFil or vent clip) TRU containers is permitted when the ventilation system is not operating (WAC 246-247-040(5)).


Record sampling shall be continuous whenever the ventilation system is operating. Sart1ples shaH be collected monthly, for periods in which the ventilation system has operated. Samples shall be composited and analyzed quarterly, ifa sample was collected during that quarter. LiC:ensee shall doc.ument minirt1.um dete_ctable co.ncentrations for the stack emissions measurements (WAC 246-247-075 (3, 8, 9))

8) CLOSURE OF ACCE_SS DOORS

All access doors shall remain closed uritil the restart of the ventilation syste_m (WAC J46-247-040(5)).

9) ALPHA/BET A MDAs and MDCs REQUiRED FOR ANALYTICAL LABO RA TORIES

The following alpha/beta MDA and MDC limits shall be used by the analyticaUaboratory when aiialyzing the samples collected.

Th~ Nominal Sample Volume for a single sample filter of 20,000 ft3 (5. 7E+08 mL)

Gross Alpha (c) MDA (a)-M-5.0E-0+6 µCi MDC (b) ~8.8E-le5 µCi/mL

Gross Beta (c) MDA (a) I .+oE-065 µCi MDC (b) l .98E-l~ µCi/mL .

Silver (ag) zeolite (d) MDA (a) l.9E005 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quarterly composite.sample of262,000 ft3 (7.4E+09 mL)

Sr-90 MDA (a) l .4E-05 µCi MDC (b) l.9E-15 µCi/mL

Gamma Energy Analysis (e) MDA {a) l .4E-05 µCi {as Cs-137) MDC(b) l ._9E-l 5 µCi/mL {as Cs-137) .

Isotopic Pu

(i.e. Pu-238, Pu-239/240)

Pu-241

Aril-241

MDA (a) l .5E-06 µCi



Page 8 of9

MDC (b) 2.0E-16 µCi/~


M·Dc (b) l.9E-l 6 µCi/rt!L

Attachment I EU315 Redlined License Version


(a) Actual MDAs derived from sample analyses shal_l be as low as reasonably achievable and shall not exceed the values specified in Table 1 provided the sample meets or exceeds its respective nominal volume. The target MD As in Table 1 are derived from n:mlt_iplying the MDCs in Table 1 by the respective nominal sample volumes shown in the table:

(b) Actual MDCs derived from sample analysis shall be as low as reasonably attainable and shall not exceed the values specified in the Table 1 provided the sample meets or exceeds its respective nominal volume. The target MDCs in Tab.le I are 10% of the concentra_tion · values in Table 2 of 40 CFR 61, Appendix E.

(c) GAB emission data are often used in dose calc_ulations to substitµte for th_e presumed presence of the usually most prevalent alpha- and beta-emitting radionuclides having the highest dose factors, which, depending on facility source term, for alpha-emitters has mostly usuaJly been Pu-239/240, but occasionally Am-241, and for beta-emitters, Sr-90, but occasionally Cs-137.

(d) Silver zeolite analysis shall be designed to primarily identify 1-129.

(e) All positive gamma-energy arialysis_(GEA) resu_l_ts sha_l_l be reported, with the exception of short lived progeny of Rn-222 and Rn-220. At a minimwn, GEA shall be designed to identify peaks of Co-60, Ru-106, Sb-125, Cs-134, Cs-137, Eu-_152, Eu-154, Eu-155, and Pa-23 l.

Page 9 of9

Att.a.i;hn:_ie~t I EU315 Redlined License Version


200W P-296T007-00I 296-T-7 This is,; M-INOR. ACTIVELY ventilated emission unit.

T PLANT COMPLEX


Stack Height: 28.00 ft 8.53 m. Stack Diameter 2.30 ft.

Average Stack Effiuent Temperature: 78 degrees Fahrenheit. 26 degrees Celsius.

Average Stack Exhaust Velocity: 81.00 ft/second. 24.69 m/second.



0.70m.

ZOcie or· Area Abatement Tec_h:nology Prefilter

Required# of Unit.s I

Additional Descrfption

HEPA I Fan I To operate per Conditions and

Liriiifati_Oris of t,he l_ic.ense.

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



Radioiiuclides Requiriiig I\leasurement

S_anip_ling Frequency

40 CFR 6l.93(c)(4)(e) 40 CFR 61, Appendix B, TOTAL ALPHA TOTAL See special conditions. & W.AC 246-247-075(3) Method 114(3) BETA

Sanip_li_llg Requi_re_ments R_ecord Sample Additional Requirement!;

Ad_ditiql)~.1 r'f(onitfirin·g or samplin·g reqlliremen_ts established by this License will be listed in the Condition's and Limitations section, if applicable. ·

Operational Status Operational Status Activities at the 2706-T Facility involve waste management operations in support of decontamination and decommissioning operations at the Hanford Site.

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

Project Title

Operation of2706-T Building (Replaced NOC ID 829)

Approval#

AIR 14-1001

Date Approved NOC_ID

10/10/2014 920

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

I) The total abated emission limit for this Notice of Construction is limited to 7.50E-03 rnrem/year to the Maximally Exposed Individual (Yv AC 246-24 7-040(5)).

2) This approval applies only to those activities described below. No additional activities or vari_ations on the approved acti.vit_i_es that constitute a "modification" to the emission unit, as defined in (WAC 246-24 7-030( 16)), may be conducted. The approved activities are limited to:

Al1PACKAG.ING AND R.E.PACK. AGING WASTE . . . -

Pagel of9

Attachment I EU315 Redlined License Version - ... - . - . -

Packaging arid repackaging ac_tivities are performed for wa_ste gen(!rat_ed at 2706-T as well as for onsite and offsite generators. The repackaging of waste supports waste acceptance ciiteria for other TSD facilities. For example, prohibited items from waste packages are removed,and either staged for later ha.ridling or repackaging using remote or ma_nual r_nethods.

Packaging and repackaging activities are: Ala) Sorting. A I b) Segregation. Ale) Removing prohibited items. Aid) Compositing/aggregating solids or liquids. Ale) Add_ing absorben_t,. Alf) Size reduction [e.g., cutting Uaws, saws, torches)], bending, folding, crushing (e.g., drum crusher), shredding, compacting, or similar methods that do not have a higher ex;_e_n_t of disruption]. Alg) Void filling. Al h) Pressure rel_ieUrel_e_ase (e.g., aerosol cans, gas cylinders, drums, or other similar containers). A2) VERIFICATION ACTIViTiES

Veri_fic_ation Sllppo_rt activities are provided for was_te and other materials that are generated . on or off the Hanford Site.


A2a) Physical observation. A2_b) Nonde_structive exa_r_nination (NDE). A2c) Nondestructive assay (NDA). A2d) Chemical field screening. A2e) Radiological surveys. A2f) Radiological samples. A2g) Headspace gas sampling. A2h) Chemical.sampling .

. A3) SAMPLING ACTIVITiES

Sampling of wast_e generated by operations or by other onsite or offsite generators is performed. The purpose of sampling is to confirm process knowledge, characterize waste, support verification, and determine la_nd disposal requirements as applicable.


.I A3a) Field screening [e.g., pH paper, oxidizer, volatile organic analyses (VOAs), polychlorinated biphenyls (PCBs), or similar screening parameters]. A3b) Obtaining a sample for analysis [e.g., grab, composite, corrip_osite liquid waste sampler (COLIW ASA), or other similar sampling techniquesf A3c) Shipping/transferring the samples to an approved laboratory for a_nalys_is. A3d) Disposition of sample returns ( e.g., placement back into the parent container or another approved container/tank). A3e) Headspace gas analysis [typically in support of the Waste.Isolation Pilot Plarit (WIPP) Project].

Page 2 of9

Attachmen_t 1 EU315 Rectlined Lice_nse Versi_on

A4) DECONTAMINATION/REFURBISHMENT ACTIVITIES Materials, equipment, and waste can be decontaminated (e.g., free release, reduce the radiological ievels, or other similar critetja) usi,ng a vari_ety of m·ethods_. E51uipm~nt can. al_so be repaired and refurbished within the 2706-T facility. Within 2706-T, decontamination of2706-T structural components may be performed.

Decontamination and refurbishment activities at 2706-T are: A4a) Vacuum blasting. A4b) Brffshing. A4c) Abrasive tools. A4d) Scraping. A4e) Washing (e.g., chemicals/detergents). A4t) Immersion. A4g) Electro-polishing. A4h) Cutting (e.g., removal by sawing, torch cuiting more highly radioactive components or other similar methods). A4i) Rust/paint removal. A4j) Sand blasting. A4k) Vacuuming.

A5) MAiNTENANCE ACTIVITIES A variety ofpreveritative and/or repair maintenance activities are performed at 2706-T. Scime maintenance activities involve the temporary shut down ofthe 296-T-7 exhaust stack.


A5a) Pa_in_ting. A5b) Crane maintenance. A5c) Electronic systems functional checks and repairs [CAMs, personnel contamination monitors (PCMs)]. A5d) Calibrations. A5e) Me_chanical overhaul and rebuild_. A5 t) Bearirig replacement. A5g) Pump and motor alignment. Mairitenarice may be performed ciri: A5h) Rollup doors. A5i) Heat pumps. A5j) Exhaust fans. A5k) Transformers. A51) Sc_aJe syst_ems. A5m) Wire rope A5n) Stack systems. A5o) Forklifts.

A6) WASTE TREATMENT ACTIVITIES

2706-T is a RCRA treatment and Storage facility permitted liy the Washington StateDepartment of Ecology (Ecology).


A6_a) Macro_encapsula_tion.

Page 3 of9

At_tachment 1 EU315 R_e_<l_li_ned L_icegse Version

A6b) Absorption. A6c) Neutralization. A6d)'Irnrnobilization. A6e) Encapsulation. A6l) Stabilization (solidification, cementation, grouting). A6g) Compaction. A6h) Amalgamation .. A6i) Segregation. A6J) Shredding. A6k) Venting and drilling. A61), Size Reduction.

A 7) RECYCLING ACTNITIES

Materials·are recycled whenever possible. Recycled materials are: ferrous and non-ferrous metal, light bulbs, aerosol cans, oils, and batteries.

AS) STORAGE ACTIVITIES

2706-T stores materials (chemicals, or equipment, or similar materials) to support operations. Radioactive wastes may be stored uncontainerized or in: A_8a) Containers (box:es, dmms, tanker tmcks/raikars, or large diameter containers). A8b) Tanks. A8c) Sumps and pipes.


The movement ofll].aterial_s, e_quipmen_t and waste.is necessary to support operations and maintenance. Movement activities (using a forklift, crane, truck, dolly, personnel) anc:: A9a) Receiving waste (liquicl, solid, semi-solicl ) for storage and/or treatment. A9b) Movement of waste (liquid, solid, semi-solid) and equipment. A9c) Moveme_nt of iiqu_ids, sludges, or other waste from containers and/or tanks via transfer lines. A9d) Waste container transfers. A9e) Placing and storing chemj_cal produc_ts in fla_I1].Il!.abl_e cabinets or other approved storage locations. A9 l) Movement of contaminated material.

AlO) HOUSEKEEPING ACTIViTIES

Housekeeping activities involve maintaining 2706~T in a clean and orderly condition.

Hou_sekeeping act_ivities are:

AlOa).Sweeping (brooms). Al Ob) Mopping (squeegees or mops). A I Oc) Vacuuming. Al Od) Dusting. AlOe) Wiping (sponges, towels). A[Ol) Picking up debris_. Al Og) Removal of trash.

Page 4 of9

Attachment 1 EU31S RedHned L_icense Ve_rsio_n

Al 1) SURVEILLANCE ACTIVITfES

Surveillance activities involve walking down and inspecting various areas, systems, and components_. Surveillances typically consist of daily, weekly, and monthly inspections of waste containers, tanks, buildings, or similar locations. Surveillances are subject to change (adding, deleting and/or· modifying) as operations, maintenance, engineering, and radiological control dictates. Surveillances, inspections, and maintenance activities that do not have the potential to create airborne contamination can occur wi_t_hi_n the 2706-T Buj_lding when the 296-T-7 c,~haus_t stack emission system is shutdown.

The foBowi_ng survej_llances are performed at 2706-T:

Al I a) Container storage areas treatment and storage tanks and ancillary equipment. A_ 11 b) General condition of buifoing structures. Al I c) Cold weather surveillances (typically, between October 1 and March 31). Al ld) fnspection of equipment. Al le) fnspection of HEPA filtered vacuums. A 11 f) Radiological surveys.

2706-T: The 2706-T facility includes the 2706-T building and the 2706-TA Building. The 2706-T Building and the2706-TA Building make up a single structure and are described briefly here. The 2706-T facility han_dles low-level waste, mixed low level waste, and transuranic (TRU) waste. The 2706-T Building was built in 1959 as a low-level radiological decontamination building. The original building was 66 feet long and 50 ft wide. The 2706-TA Building was added in 1994/1995 over the conc"rete pad on the west side of the 2706-T. One rollup-door and one man-door provide access between 2706-T and 2706-TA Building. Three heat pumps provide heating, ventilation, and air con_ditioning for th_e 2706-T Building operations area. Waste handling and decontamination operational ar~as of the 2706-T Building are open and unobstructed. The 2706-T building is a pre-engineered me_tal building. The foundation is concret_e sl_ab on grade throughout. The 2706-T Building includes two pits, one for decontamination and treatment of motor vehicles and other large equipment, and one for rail car decontamination and treatment. These pits can _also be u_sed to support collection of liquids from waste handling activities.

CURRENT OPERATIONS fN 2706-T BUlLDfNG

i_fldtide waste sampling, packaging and repackaging. head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement act_ivit_ies. One egre_ss d_oor l_c,ads directly to the exterior of2706-T Building. Othe"r doors lead directly to the non-ventilated lean-to on the north side, and an air lock provides access to the 2706-TA Building operations area. The railwayand auto pits have metal grating and some woode1_1 cove_rs to prevc,nt falls i_nto t_he pi_ts_. An epo:xy floor sealant had been applied to all operational area floors. To support these operations, greenhouses are used as necessary in 2706-T. Greenhouses are temporary or semi-permanent radioactive material confinement stru_ctures, and can be used for c6ntamination control. If used, greenhouses shall exhaust to the areas ventilated by the 296-T, 7 ventilation system.

The atmosphere clean-up train (ACT-I) system, sprinkler system riser room, and electrical room are located in the south lean-to (non-ventilated).

270_6-T A: The2706-TA Building is an addition to the 2706-T Building installed in the 1990s as · an add-on over the concrete storage pad located west oft]:ie building. The 2706-TA Building is

Page S of9

Attachment 1 EU315 Redl_ined Lic_en_se Version

approximately 54 feet long, 45 ft wide, and 23 feet high. There are two roll up dciors located at the west end of the building. The 2706-T A Building has steel primary and secondary structural e_lements an~ corrug~ted sheet metal exterior siding and roofing p~nels. Three heat pumps )Jrovide heating, ventilation, and air conditioning for the 2706- TA Building operations area. The floor is concrete slab on grade. An epoxy floor sealant had been applied to all operational area floors. Was_te hand_ling and decont_amin_ation operational areas of the 2706-TA Building are open a_n_d unobstructed.

CURRENT OPERATION IN P06-TA BUILDING

include waste sampling, packaging and repackaging, head-gas sampling, managing waste contai_ne_rs, decontamin_ation/refurbishrnent, ma_intenance, recycling, storage, housekeeping, surveillance, and movement activities. To support waste activities, greenhouses are used if necessary. Greenhouses are temporary or semipermanent radioactive materi_al confinement structures; and c·an be used for contamination control. When used, greenhouses shall exhaust to the areas ventilated by the 296,T-7 ventilation system.

Attached to the south side of2706-TA Building is a lean-to made up of two rooins. The larger room houses the new ACT-2 HEP A filter system, which serves the operational areas. The ACT-! and ACT-2 systems exhaust through the 296-T-7 stack. The second room houses electronic controllers and electrical switchgear supporting operations.

Emissi_ons from t_hese ac_ti vi ties are exhausted through 296-T-7, except for emissions resulting from vented TRU containers stored within the facility, which may be released to the 200 Area diffuse and fugitive emission unit when the ven_t_i_l_ation syst(!m is not in operat_ion.

3) The_PTE for.this project as determined under WAC 246-24 7-030(21 )(a-e) [as specified in the applicatioh]"is 7.50E-02 mrern/yea:r. Approved are the associated potential.release rates (Curies/year) of:

DE-0 l.90E-05 Contained WAC 246-247-030(2l)(a)

Any radionuclide on the chart of the nuclides could be encountered. A small contribution from the gaseous r3d_iori_u_clides n:iay b_e encountered. The radionuclides within the focil_ity are c_ontrol_led by the licensee in terms or do'se~equivalent (DE) cu·ries, A co·nservative PTE tracking method for the demonstration of compliance to th_e licensed PTE fimits is pra"vfded in the conditions of the iiccns~. 11 C'ontai~~d" mean~ "~ithin typical n~."U waste containers for which a release.fraction of2E-09 has been determined to be appropriate."

DE-0 2.90E-03 Liquid/Paniculate Solid WAC 246-247-030(2 l)(a)

Any rudionuclidc on the.chart ofrhe nuciides could be encountered. A small contribution from the gaseous radionuclides may be encountered. The radionuclides within the facility are known to and controlled by the ticcns~ in tejms o~ d_ose eqll._ival~n_c _(DE) Curies. A cOi:,.serva_tivc PTE 'frac~ing m_ettiod for the d~onsn:ation of compliance to the licensed PTE limits is provided in the conditions of the license. This amount of DE cllries is permitted within the facility uncontalned in TRU waste containers as liquid/paniculace for which a release fra~tio_n of l E-03 is apprOptjacc_.

H - 3 l.50E+0I Gas WAC 246-247-030(21 )(a)

Rn C 219 2.00E-01 Gas WAC 246-247-030(2 l)(a)

Rn" 220 2.80E+0l Gas WAC 246-247-030(2l)(a)

Rn - 222 l.47E+00 Gas WAC 246-247-030(2l)(a)

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

H- 3 Rn - 219 Rn- 220 Rn - 222

Page 6 of9

Attachment I EU315 Redlined L_ic_ense Version

The potential release rates described in this Condition were u·sed 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 whe_n a specific isotope.is newly identified as contributing greater than 10% of the potential TEDE to the M_EI, or gre_at_e_r than 25% of the TEDE to the ME°I 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 regulatioris including changes that would constitute a significant modification to the Air Operating Permit under WAC 173-401-725(4). Notice will be proviaed according to the particular regulation under which notification is required. If the applicable regulation(s) does not ad_dress manner and type ofnot_ification, DOE wi)l provide the Department with advance written notice by letter or electronic mail but not solely by copies of documents ..

4) USE OF ALARA PRINCIPLE

All activities involving potentially airborne radioactive materials in 2706-T shall be c·onducted in accordance with the ALARA principle. (WAC 246-247-040(5)).

5) A PTE TRACKING IN AIR SPACE VENTILATED BY 296-T-7

The PTE in the space ventilated by 29_6-T-7 shal 1 be tracked for compliance to the license limit as described in t_his condi_tion.

Waste Contained in Typical TRU Waste Containers: PTE < 9490 DE Ci/year• 2E-09. Compliance: maintain annual tota_l of DE Ci • 2E-09 below limit (Dose comribiltion of this activity to license limit estimated assuming each DE Ci is 241-Am].

Venting of Waste Unccintained in Typical TRU waste C_ontainers: PTE < 9490 DE Ci/year• lE-03 *5.7E-05. Compliance: maintain annual total of DE Ci• lE-03 • 5.7E-05 vented below limit. (Dose con_tributioi, of this activity t_o license hmi_t estimated assuming each DE Ci is 241-Am].

Torch cutting: PTE< 9E-04 rnrem/year. Compliance: Maintain the product of inches cut and contamination level t_o: < 8.8 E+09 in-dpm/100 sq.cm beta/gamma and< 8.8E+6 dpm/100 sq.cm alpha. (Note: The release at the cut is assumed gaseous due to high cutting temperature, but it is also assumed that any gases thus formed will recondense irito a particulate form by the time they reach the filters, and be subject to the stan_(j.ard re_rnova_l efficiency of the HEPA filter.) [Dose contribution of this activity to licerise limit estimated assuming all alpha is 241-Am, all beta/gamma is 137-Cs.]

Gases in Waste Contained in TypicalTRU Waste Containers: PTE < 7E-04 rnrem/year. Compliance - maintain: tritium PTE below 15 Ci/yr; 219-Rn PTE below 0.2 Ci/yr; 220-Rn PTE below 28 Ci/yr; 222-Rn PTE below 1A7 Ci/year. These limits apply to process-enhanced radionilclides only, per (WAC 246-247-020(4)) .. [Dose contribution of this activity to license limit estimated using isotopespecific dose conversions factors.]

Other Processes: PTE < 4.9 E-02 rnrem/year. Compliance: maintain total facility DE Ci/year (exclusive ofTRU in_cluded above)• 1 E-03 be_low 2.9 • 1 E-03, or maintain the sum Ci(alpha) • 1 E-03 • 17 + Ci(beta/gamma) • 1 E: 03 • 0.31 below 4.9 E-02 mrem/year. [Dose contribution of this activity's PTE to license limit estimated assuming DE Curie_s are 241-Am].

Page 7 of9

Attachment I EU315 Redlined License Version

Residual Contamination: PTE < 7.1 E-03 mrem/year. Accounts for residual ·contamination present in facility if posting is Contamination Area or below. Greater contamination levels result from other proc:esses, and are accounted for in the PTE(s) associated with them. No specific compliance demonstration is necessary beyond the compliance with posting requirements. [Dose contribution ohhis activity to license limit estimated assuming an alpha is 241-Am, all beta/gamma is 137-Cs.]

The facility shall document and implement a program of inspection and maintenance to ensure the continuous integrity of contamination fixative used within the facility. '

That the total PTE does not exceed licensed limits shall be routinely verified, and documentation of that verification shall be maintained. (WAC 246-247-040(5)) (WAC 246-247-060(5))


The ventilation system shall be in operation when activities involving radioactive or contaminated materials are performed within the ventilated space. The ventilation system shall be in operation if any part of the 2706-T Facility is posted as a high contamination area, or higher. Storage/movement of ventilated (NucFil or vent chp) TRU comainers is pennit_t_ed when the ventilation system is not operating (WAC 246-247-040(5)).


Record sampling shall be continuous whenever the ventilation system is operating. Samples shall be collected monthly, for periods in which the ventilation system has operated. Samples shall be composited and analyzed quarterly, if a sample was collected during that quarter. Licensee shall document minimum detectable concentrations for the stack emissions measurements (WAC 246-247-075 (3, 8, 9))

8) CLOSURE OF ACCESS DOORS

All access doors shall remain closed until the restart of the ventilation system (WAC 246-247-040(5)).

9) ALPHNBETA MDAs and MDCs REQUIRED FOR ANALYTICAL LABORATORIES

The following alpha/beta MD A and MDC limits shall be used by the analytical laboratory when analyzing the samples collected.

The Nominal Sample Volume for a single sample filter of20,000 ft3 (5.7E+08 mL)

Gross Alpha (c) MDA (a)-hJ.5.0E-0+6 µCi MDC (b) ~8.8E-le5 µCi/mL

Gross Beta (c) MDA (a) l.-l-0E-065 µCi MDC (b) 1.9SE-l~ µCi/mL

Silver (ag) zeolite (d) MDA (a) l.9E-05 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quarterly composite sample of262,000 ft3.(7.4E+o9 mL)

Sr-90 MDA (a) l .4E-05 µCi MDC (b) 1.9E-I 5 µCi/mL

Gamma Energy Analysis (e) MDA (a) I .4E-05 µCi (as Cs,]37) MDC (b) l.9E-15 µCi/mL (as Cs-137)

Isotopic Pu

(i.e. Pu-238, Pu-239/240)

Pu-241

Am-241



MDA (a) I .4E-06 µCi

Page 8 of9

MDC (b) 2_.0E-16 µCi/mL


MDC (b) I. 9E- I 6 µCi/mL

Attachment I EU315 Re_dlined License Version

MDA; minimum detectable activity; MDC; minimum detectable concentration.

(a) Actual MDAs derived from srupple analyses shall ~e as low as reasonably achievabl_e and shall not exceed the values specified in Table 1 provided the sample meets or exceeds its respective nominal volume. The target MD As in Table I are derived from multiplying the MDCs in Table I by the respective nominal sample volumes shown in the table.

(b) A_ctu_al MbCs derived from sample analysis shail be as low as reasonably attainable and shall not exceed the values specified in the Table I provided the sample meets or exceeds its respective nominal volume. The target MDCs in Table I are I 0% of the concentration values in Table 2 of40 CFR 61, Appendix E.

(c) GAB emission data are often u·sed in dose calculations to substitute for the presumed presence of the usually most prevalent alpha- and beta-emitting radionuclides having the highest dose factors, which. depending on facility source term, for alpha-emitters has mostly usually been Pu-239/240, but occasionaHy Am-241, and for beta-emitte_rs, Sr-90, but occasionally Cs-13 7.

(d) 1S ilver zeolite analysis shall be designed to primarily identify 1-129.

(e) All pos_itive gamma-energy analysis (GEA) results shail be reported, with the exception of short lived progeny ofRn-222and Rn-220. At a mini.mum, GEA shall be designed to identify peaks ofCo-60, Ru-106, Sb-125, Cs-134, Cs-137, Eu-152, Eu-154, Eu-155, and Pa-23 I.

Page 9 of9

Frazier, Thomas (DOH)

From: Sent: To: Cc: Subject: Attachn;ents:

Tom,

Karschnia, Paul T <[email protected]> tue_sday, August 02, 2016 8:53 AM Frazier, Thomas (DOH) Schmidt, John W (DOH); F·au_st, Eric f; E_ngelrn_ann, Richa_rd H; Karschni_a, Pa~_I T Draft license revision for EU315 RE: 2706-T S_tack Sampl_ing; 2706T License 071216-ALARACT Rev Form (1-20-lS)Revl .doc; Technical Exchange f-iotes 062316.docx

At last week's exchange meeting, John S. indkated you will be the reviewer on the 2706T M.DC/M.DA change_s due to the

differences between the original WSCF values and the GEL contract. I have attached a draft of the license revision for your review and comment prior to the formal submittal.

Let nie know if you have any questions or if we need to meet. I go out on short term disability starting 13 September, so

it would be nice to get my end done for the formal submittal prior to that date. Th·anks.

Tad

Paul (Tad) K_arschnia CHMM, ASQ-CQT, CESCO Environmental Pro_tection Technical Service·s Phone (509)-376-2088/ Cell (541) 571-1627

Paul T [email protected]

1

Frazier, Thomas ([)OH)

From: Sent: To: Cc: Subject:

Thank you

Schmidt, John <[email protected]> Tuesday, June 28, 2016 12:20 PM Faust, Eric T; Martell, P John (DOH) Berven, Shawna D (DOH); Karschnia, Pa·u1 T; Laws, Gail L (DOH) RE: 2706-T Stack Sampling

From: Faust, Eric T [mailtci:[email protected]] Sent: Tuesday, June 28, 2016 11:40 AM ·

To: Martell, P John (DOH) <[email protected]>; Schmidt, John W (DOH) <[email protected]> Cc: B_erven, Shawna D (DOH) <[email protected]>; Karschnia, Paul T <Paul_ [email protected]>

Subject: 2706-T Stack Sampling

J_ohn M. and John S.,

As part of a process improvement for reguh1tory reqtii_rement impll'!_me_nt_at_ion, a di_screpancy was identi_tied between the 2706-T (EU315) Condition 9, gross alpha and gross beta (GAB) minimum detectable concentrations (MDC) and the MSA contract lab (GEL) contractual GAB MDCs. The EU3 J 5 Condition 9 limits were obtained from the WSCF scope of work instead of the GEL contractual iiriiits (which were implemente_d during the same time period a:s the most recent EU3 l 5 license revision). The difference in the prescribed instrument sensitivity is an order of magnitude between 10- 15 (GEL Li_init) and 10·16 (EU3 l 5 limit). The proposed resolution is to revise the EU3 l 5 Condition 9 to reflect the GEL contractual GAB MDC limits.

Th_anks, Eric Faust 509-376-9607

1

Frazier, Thomas (DOH}

From: Frazier, Thomas (DOH) Sent: To:

Tuesday, August 02, 2016 2:09 PM 'Karschnia, Paul T'

Subject_: R_E: Draft lice_nse revision for EU315

Tad, I have time in my schedule and will certainly be able to work with you to finalize this license revision before you

leave for your short term disability; if nothing 1inforeseen occurs.

Tom

From·: Karschnia, Paul T [mailto:Paul_T_/a·rsch·[email protected]]

Sent: Tuesday, August 02, 2016 8:53 AM To: Frazier, Thomas (DOH) <[email protected]>

Cc: Schmidt, John W (DOH) <[email protected]>; Faust, Eric T <[email protected]>; Engelmann, Richard H <[email protected]>; Karschnia, Paul T <[email protected]> Subject: Draft license revision for EU315

Tom,

At last week's exchange meeting, John S. indic·ated yo"u will be the reviewer on the 2706T MDC/MDA changes due to the

differences between the origina_l WSC°F value_s and the GEL cont_ract_. I have attached a d_raft of the ficense revision for your review and comment prior to the formal submittal.

Let me know if you have any questions or if we need to meet_. I go out 9n short term d:isability sta_rting 1:3 September, s_o it would be.nice to get my end done for the formal submittal prior to that date. Thanks.

Tad

Pau_l {Tad) Karschnia

CHMM, ASQ--CQT, CESCO

Environmental Protection Technical Services Phone (509)--376--2088/ Cell (541) 571--1627 Paul T [email protected]

1


From: Sent: To:: Cc: Subject:

Thank you

Schmidt, John <[email protected],gov> Tuesday, June 28, 2016 12:20 PM Faus.t. Eric T; Ma·rtell, P John (DOH) Berven, Shawna D (DOH); Karschnia, Paul T; Laws, Gail L (DOH) RE: 2706-T Stack Sampling

From: Faust, Eric T [mailto:[email protected]] Sent: Tuesday, June 28;.201611:40 AM To: Martell, P John (DOH) <[email protected]>; Schmidt, John W (DOH) <[email protected]> . ' .. . . - . -- . . . ' ~ . - .. . . .. ··- ·- . . ..

Cc: Berven, Shawna D (DOH) <[email protected]>; Karschnia, Paul T <[email protected]> · Subject: 2706-T Stack.Sampling

John M. _and John S.,

As part of a process iril.provemeiit for regulatofy recjuirernentimplementation, a discrepancy was identified between the 2706-T (EU315) Condition 9, gross alpha and gross b_eta (GAB) minimum detectable concentr,!tions (MDC) and the MSA con_tract l_,!b (GEL) contractual GAB MDCs. The EU3 l 5 Condi_tion 9 limits were obtained from the WSCF scope of work instead of the GEL contractual limits (which were implemented during the same time period as the most recent EU3 l 5 license revision). The difference in the prescribed in:strumentsensitivllyis a:n order of magnitude between I 0-15 (GEL Limit) and 10·16 (EU3 l 5 limit). The proposed resolution is to revise the EU3 l 5 C.Ondition 9 to reflect the GEL contractual GAB MDC limits.

Thanks,· Eric Faust 509-3 76-9607

1


From: Sen~: To: Cc: Subject: Attachments:

ram,

Karschnia, Paul T < Paul0 T [email protected]>

Tuesd.iy, Augus_t 02, 2016 8:53 AM Frazier, Thomas (DOH) Schmidt, John W · (DOH); Faust, Eric t; Enge_lmann, Richard_ H; Karschnia, Pa_ul T Draft license revision for EU315 RE: 2706-T Stack sa:m·pling; 270_6T Ucense 071216-ALARACT Rev Form (1-20-lS)Revl .doc; Technical Exchange Notes 062316.docx

At last week's exchange meeting, John S. indicated you will be the reviewer on the 2706T MDC/MDA changes due to the differences between the original WSCF values and the GEL contract. 1 have attached a draft of the license revisio"n for you_r revie"' a_nd com_me_nt prior to the form.al submitta_l.

Let me know if you have ariy questions or ifwe rieed to meet. 1 go out on shoitterm disability starting 13 September, so it wou_l_d be nice to get my end· done fo_r the formal su_bm_ittal prior to that da_te. Thanks.

Tad

Paul (Tad) Karschnia CHMM, ASQ-CQT, CESCO Em,iron_ment_al _Protection Technic_al S_e_rvic_es Phone (509)-376-2088/ Cell (541) 571-1627 Paul T [email protected]

c'1ZtK:·

1

Attendees:

WDOH Technical Exchange Notes

From Discussion 0800-0900, 23June.2016

2420 Stevens Center Rm 176, Richland WA

WDOH -John Schmidt, Tom Frazier

DOE/RL- Eric Faust

CH PRC-Stephanie Jo_hansen, Dave Watson, Deborah Singl_eton, Fen Simmons Tad Karschnia

1) WESF ventilation construction progress - Dave Watson

a. Startup testing schedule

• The construction progress was briefed for the K3N skid and tank TK-100

• It was agreed th~t an email notificat_ion to WDOH would fulfill the WAC

notification requirements. The email will bracket all the testing dates with

WDOH being notified via phone/email of each specific test date as soon as the

exact date was finalized in the daily "War Room" meeting.

2) CSB pending mairitena·nce.on north and south (?) exterior docirs - Dave Watson

• The outage duration is expected to be 2-3 weeks in either August or September.

• The ciuter shield door repairs may require that the inner door be open during the day to

facilitate work on the outer door track.

• It was agreed that an email would be provided to WDOH prior to the start of work

(similar to the T Plant Power PMs) outlining the ALARACT controls to be used during the

outage.

3) FF-01 license revision on FFTF SSF -Tad Karschnia

.a. Calculation finalized~ decreased prospective PTE at.new MEI l9cat_ion

b. Path forward?

• It )Illas agreed that the decrease in PTE does not meet the definition of a

modi_fica_tion so the license revision process would be used to correct the license

PTE limits.

q) B Pia Rt sarnpliRg aREI Fwst isswes·· Stewart MeP.4aAaREI Rescheduled 0930 6/29/16_

5) Sta_b_i_li_zation and C_h_a_racterization License-+S9 Tad Karschnia

• WDOH is willing to look at proposed changes involving the log keeping

requirement.

• This work scope will be added to the project schedule table below.

6) WSCF vs GEL MDCs for Gross Alpha and Gross Beta~ Tad Karschnia

• Differences between the 2706-T (EU315) license MDC limits and the GEL Lab

MDC contractual limits were discovered as part of a CHPRC requirements

identification process imp'rovement initiative.

• WDOH stated that a notification would need to be made concerning the

discrepancy between the license and the contractual MDCs/MDAs.

• The resolution will be the submittal if a revision to the license to align the

license condition with the contractual limits.

7) Open Di_scussion

WDOH has an opening for an HP3 position.

Project Status Estimated completion date

Working on NB.1-1999 5.2.2.2 CSB license revision for flowrate evaluation. Remove or revise 9/30/16

flo_wrate co·ndition

FFTF SSF lice rise. revision· Dose calc_ulations completed for

6/30/16 new receptor location

/


To: Karschnia, Paul T Cc: Subject:

Schmidt, John W (DOH); Faust, Eric T; Engelmann, Richard H RE: Draft license revision for EU315

Tad

From: Karschnia, Paul T [mailto:[email protected]] Sent: Tuesday, August 02, 2016 8:53 AM To: Frazier, Thomas (DOH) <[email protected]> Cc: Schmidt, John W (DOH) <Joh·[email protected]>; Faust, Eric T <[email protected]>; Engelmann, Richard H <[email protected]>; Karschnia, Paul T <[email protected]> Subject: Draft license revision for EU315

Tom,

At last week's exchange m·eeting, John S. indicated you will be the reviewer on the 2706T MDC/MDA chang·es due to the differences between the origina'i WSCF value_s and t_he GEL contract I have attached a draft of the li_ce.nse revision for your review and comment prior to the formal submittal.

Let me know if you have any que.stions or if we need to meet. I go out on short term disability starting 13 September, so it would be nice to get my end done for the formal submittal prior to that date. Thanks.

Tad

Paul (Tad) Karschnia CHMM, ASQ-CQT, C_ESCO Environmental Protection Technical Services Phone.(509)-376-2088/ Cell (541) 571-1627 Paul T [email protected]

1


From: Sent:

'To: Cc: Subject:

Thank you

Schmidt, John <[email protected]>

Tuesday, June 28, 2016 12:20 PM Faust, Eric T; Martell, P John (DOH)

Berven, Shawn·a D (DOH); Karschnia, Pa·u1 T; Laws, Gail L (DOH)

RE: 2706-T Stack Sampling

From: Faust, Eric T [mailti:l:[email protected]]

Se_nt: Tuesday, June 2_8, 2016 11:40 AM

To: Martell, P John (DOH) <[email protected]>; Schmidt, John W (DOH) <[email protected]>

Cc: Serven, Shawna D (DOH) <[email protected]>; Karschnia, Paul T <[email protected]>

Subject: 2706-T Statk SampHng

John M. and John S.,

As part of a process improvement for regulatory requirement implementation, a discrepancy was identified between tl1e 2706-T (EU3 l 5) Condition 9, gross alpha and gross beta (GAB) minimum detectable concentrations (MDC) and the MSA contract lab (GEL) contrnctual GAB MDCs. The EU3 l 5 Condition 9 limits were obtained from the WSCF scope of work instead of the GEL contractual limits (which were implemented during the same time period as the most recertt.EU3 l 5 license revision) .. The difference in the prescribed instrument sensitivity is an order of magnitude between 10· 15 (GEL Limit) and 10·16 (EU315 limit). Th_e proposed resolution is to revise the EU3 l 5 Condition 9 to reflect the GEL contractual GAB MDC limits.

Thanks, Eric Faust 509-376-9607

1

. ©


From: Sent: To: Cc:

Faust, Eric T <[email protected]> Wednesday, December 07, 2016 4:03 PM Frazier, Thomas (DOH)

Schmidt, John W (DOH); Karschnia, Paul T; Carleo, Frank J; M_artell, P John (DOH) Subject: R~: Rough Drafts of Licenses for NOC 1033 (Operation of the 2706, T Buildi_ng), NOC

1075 (\Naste RE!ce_iving and Processing Facility WRAP)), and NOC 1076 (Head Space Gas Sampling at WRAP Facility)

Tom,

Thank you for the opportunity to comment. We only had comments on the following:

JFor EU I 183 -NOC 1076- HSGS I) Condition 2 -insert activity boiler plate language foun~ i;tart of cpnd,WOl)!i f ~ 5 into condition 2

for uniformity between licenses .,,.. Ci~ ~ ~ ~ /\ 11 (J 2) Condition.2 - 2nd para, line 5 - typo in spelling of word "ne\v··~ ~ ~ 3) Condition 2 - Recommend addi_rig information on head sgace gas analysis to permitted activity

description. Currently only sam lin° i_s addressed in condition 2.

4) Condition 4_ & 5 - Reco_ ·n:m __ .. remo~i__'.; ~:i:t: ~~late language :g the s. tartJf/ach condition for uniformity between licenses. __.. V'f.-/~~ ~ •

EU 193 and 3 IS-no comments '(/

Thanks and please contact me if you have any quest.ions, Eric 509-3 76-9607

From: Frazier, Thomas(DOH)[mailto:fhomas.£razier'@DOH.WA.GOV] Sent: Friday, Dece_mber 02, 2016 11:44 AM

To: Faust, Eric T <[email protected]>

Cc:_ Carleo, Frank J <Frank J [email protected]>; Schmidt, John <[email protected]>; Martell, John <[email protected]> • -

Subject: Rough Drafts of Licensl!s for NOC 1033 (Operation of t_h_e 2706'T Building), NOC 1075 (\Naste Receiving and Processing Facility WRAP)), and NOC 1076 (He.ad Space Gas Sampling at WRAP Facility) Importance: High ·

Eric-;

Here are the rough drafts for t_he licenses for NOC 1033 (Ope_ration of the.2706-T Building), NOC 1075 (wa·ste Receiving

and Processing Facility WRAP}), and NOC 1076 (Head.Space Gas Sampling at WRAP Facility} for your review. Once we

have your comments back on these licenses·and have incorporated them as appropriate;we will send them out a_s 28

Day Drafts. We also simplified the.numbering system used in the>license for NOC 1033 (Operation cif the 2706-T Building) to make it easier to follow.

Thanks,

"Emission Unit ID: 315

200W P-296T007-001 296-T-7 This is a MINOR, ACTIVELY ve"ntilatcd en1issioii unit.

T- PLANT COMPLEX


Stack Height: 28.00 ft. 8.53 m. Stack Diameter ·2.JO ft.

Average Stack Effiuent Temperature: 78 degrees Fahrenheit. 26 degrees Celsius.

Average Stack ExhaustVelocity: 81.00 ft/second. 24.69 m/second.



Zone or Area Abatement_ Techn_ology

Prefilter

HEPA

Fan

Required# of Unit_s

o.iom.

Monitori_ng Requirements _ . . ..

Addi_tion_al Description

To operate per Conditions and Limitations of the License.

state enforceable: WAC 246-247-040(5), 060(5), and federal_ly enfo_rceable: 40 C_FR 61 subpart H.

Fe~~rnl and State -~~gulat_<i_ry _

Monitoring and Testing R~uirements

Radionuclides Requiring Measurement

Sampling Frequency

40 CFR 61.93(c)(4)(e) & WAC 246-247-075(3)

40 CFR 61, Appendix B, Method 114(3)

TOTALALPHA TOTAL BETA

See special conditions.

Sampling Requirements Record Sample Additional Requirements

AdditiOnal m"onito·ring or s·arT'lpllnQ requirei}ne_nts established by this Lic~nse will be listed in the Conditions and Limitations section, if applicable.

Operational Status Activities·at the 2706-.T Facility involve waste management operations in suppo'rt of decontamina_tion 011d decomissioning operations at the Hanford Site_.

Th_is E_n,_i_s_s.ion Unit has 1 active Notice(s) of Construction.

Project Title Approval# i;>a_te Approved NOC_I_D Operation of2706-T Building (Replaces NOC 920) Nol Approved

Conditions (state only enforceable: WAC 246-247-040(5), 060(5) if not specified) 1) The total abated emission limit for this Notice of Construct_ion_ is limi_ted to 7.50E-03 mrem/year to the

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

1033

2) This approval applies cinly to those activities described below. No additional activities or variations on the approved activities that constitute a "modification" to the emi_ssion unit, as defined i_n (WAC 246-247-030(16)), may be conducted. The approved activities are limited to:o ·

A) PACKAGING AND REPACKAGING WASTE

Packaging and repackaging activities are performed for waste generated at 2706-T as well as for onsite and offsite generators. The repackaging of waste supports waste a_cceptance criteria for other Treatment Storage and Disposal (TSD) facilities .. For example, prohibited items from waste packages are removed and either staged for later han_dling or repa_c_kaging using remote or manual methods.

Pac_kaging and repackaging activities are:

a) Sorting. b) Segregation.

Page 1 ofBforEU_ID315'

c) Removing prohibited items. d) Compositing/aggregating solii:ls or liquids. e) Adding absorbent. l) Size reduction [e.g., cutting (jaws, saws, torches)], bending, folding, crushing (e.g., drum crusher), shredding, compacting, or similar methods that do not have a higher extent of disruption). g) Void filling. h) Pressure relie£'release (e.g., aerosol cans, gas cylinders, drums, or other similar containers).

B) VERIFICATION ACTIVITIES



a) Physical observation. b) Nondestructive examination (NDE). c) Nondestructive assay (NDA). d) Chemical field screening. e) Radiological surveys. l) Radiological samples. g) Headspace gas sampling. h) Chemical sampling.

C) SAMPLING ACTIVITIES

Sampling of waste generated by operations or by other onsite or offsite generators is· performed. The purpose of sampling is to confirm process knowledge, characterize wa_s_te, support verification, and determine land dispos_al requirements as applicable.

Sa_mpling activities are:

a) Field screening [e.g., pH paper, oxidizer, volatile organic analyses (VOAs), polychlorinated.biphenyls (PCBs), or similar screening parameters]. b) Obtaining a sample for analysis [ e.g., grab, composite, composite liquid waste sampler (COLIW ASA), or other similar sampling tecliniques]. c) Shipping/transferring the samples to an approved laboratory for analysis. d) Disposition of sample returns (e.g., pl_acernent back int_o the parent container or another approved container/tank). e) Headspace gas analysis [typically i_n support of the Waste Isolation Pilot Plant (WIPP) Project].

D) DECONTAMINATION/REFURBISHMENT ACTIVITIES

Materials, equipment, and wast_e can be decontaminated (e.g., free release, reduce the radiological levels, or other similar criteria) using a variety of methods. Equipment can also be repaired and refurbishe_d within the 2706-T facility. Within 2706-T, decontamina_tion of2706-T structural components may be performed.

Decontamination and refurbishment activities at 2706-T are:

a) Vacuum blasting. b) Brushing. c) Abrasive tools. d) Scraping. e) Washing (e.g., chemicals/detergents). l) Immersion. g) Electro-polishing. h) Cutting (e.g., removal by sawing, torch cutting more highly radioactive components or other similar

Page 2 of B for EU_ID 315

methods). i) Rust/paint removal. j) Saiid blasting. k) Vacuuming.

E) MA!_NTENANCE ACTNITIES

A variety of preventa_tive ancl/or repai_r mai_n_tenance ac_t_ivities are performed at 2706-T. Son1_e n1_ai_ntena_n_ce activities involve the temporary shut down of the 296-T-7 exhaust stack.


a) Painting. b) Crane maintenance. c) Electronic systems functional checks and repairs [CAMs, personnel contamination monitors (PCMs)]. d) Calibrations. e) Mechanical overhaul and rebuild. f) Bearing replacement. g) Puinp ani:l motor alignment.

Maintenance may be performed on: a) Rollup doors_. b) Heat pumps .. c) Exha_i,st fans. d) Transformers. e) Scale syste_ms. f) Wire rope. g) Stack systems. h) Forklifts.

F) WASTE TREATMENT ACTIVITIES

2706-T is a Resource Conservation and Recovery Act(RCRA) treatment and Storage facility permitted by the Washington Sta_te Dep~_n1e_nt of Ecology (Ecology).


a) Macroencapsulat_ion. b) Absorption. c) Neutralization. d) lmriJobiliiation. e) Encapsulation. f) Stabilization (solii:lification, cerrieritation, grouting). g) Compaction. h) Amalgainaticin. i) Segregation. j) Shredding. k) Venting and driBing. l) Size Reduction.

G) RECYCLING ACTIVITIES

Materials are recycled whenever possible. Recycled materials are: ferrous and non-ferrous metal, light bulbs, a_c:;rosol c.ans, o{ls, and batteries.

H) STORAGE ACTNITIES

Page 3 of 8 for EU_ID 315

2706-T stores materials (chemicals, or e:quipment, or sil)lil_ar material_s) t_o support operations. Radioactive wastes may be stored uncontainerized or in: a) Containers (boxes, drums, tanker truc_ks/raikars, or large diameter containers). b) Tanks. c) Sumps and pipes.

I) EQUIPMENT, MATERIALS, AND WASTE MOVEM_ENT ACTNIT!ES

The movement of materials, equipment and waste is necessary to support operations and maintenance. Movement activities (using a forklift, crane, truck, dolly, personnel) are: a) Receiving waste (liquid, solid, semi-sol_id ) for storage and/or treatment. b) Movement of waste (liquid, solid, semi-solid) and equipment. c) Movement of liquids, s_ludges, or ot_he_r waste from cont_ainers and/or tanks via transfer lines. d) Waste container transfers. e) Placing and s_toring chemic.al products i_n flammable cabinets or other approved storage locations. f) Movement ()[ contaminated material.

J) HOUSEKEEPING ACTNITIES



a) Sweeping (brooms). b) Mopping (squeegees or mops). c) Vacuuming. d) Dusting. e) Wiping (sponges, towels). f) Picking up deliris. g) Removal of trash.

K) SURVEILLANCE ACTNITIES

Surveillance activities involve walking down and inspecting various areas, systems, and components. Surveillances typic_ally consist of daily, weekly, and monthly inspections of waste containers, tanks, buildings, or similar locations. Surveillances are subject to change (adding, deleting ancilor modifying) as operations, ma_intenance, enginee_ring, and radiological control dictates. Surveillances, inspections, and maintenance activities that do not have the potential to create airborne contamination can occu_r within the 2706-T Building when the 296-T-7 exhaust stack emission system is shutdown.


a) Container storage areas·treatment and storage tanks and ancillary equipment. b) General condition of building structures. c) Cold weather surveil_lances (typically, between October I and March 31 ). d) Inspection of equipment. e) Inspection of HEPA filtered vacuums.

-- - .

F) Radiological surveys.

2706-T: The 2706-T facility includes the 2706-T building and the 2706-TA Building. The 2706-T Building and the 2706-TA Building make up a single struct_ure a_nd are described briefly here. The 2706-T facility handles low-level waste, mixed low level waste, and transuranic (TRU) waste.

The 2706-T Building was built in 1959 as a low-level radiological decontamination building. The original building was 66 feet long and 50 ft wide. The 2706-TA Building was a_dded i_n 1994/1995 over the concrete pad on the west side of the 2706-T. One rollup-door and one man-door provide access between 2706-T and


2706-TA Building. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-T Building operations area. Waste handling and decontamination operational areas of the 2706-T Building are open and unobstructed. The 2706-T bu_{Iciing is a pre-engineered me_tal building. The foundation is concrete slab on grade throughout. The 2706-T Building includes two pits, one for decontamination and treatment of motor vehicles and other large equipment, and one for rail car decontamination and trea_tmen_t. These pi_t_s can also be used to support collection of liquids from waste handling activities.


I_nclude waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement activities. One egress door leads directly to the exterior of 2706-T Building. Other doors lead directly to the non-ventilated lean-to on the north side, and an air lock provides access to the 2706-TA Building operations area. The railway and auto pits have metal grating and soine wooden covers to prevent falls into the pits. An epoxy floor sealant had been applied to all operational area floors. To support these operations, greenh_ouses are used as necessary in 2706-T. Greenhouses·are temporary or semi-permanent radioactive material confinement structures, and can be used for contamination control. !fused, greenhouses sha_ll exhaust to t_he areas ventilated by the 296-T-7 ventilation system.

Th_e atmosphere dean-up train (ACT-I) systern,.sprinkler system riser room, and electrical room are located in the south lean-to (non-ventilated).

2706-TA: The 2706-TA Building is an addition to the 2706-T Building inst_alled i_n th_e 1990s as an add-on over the concrete storage pad located west of the building. The2706-TA Building is approximately 54 feet long, 45 ft wide, and 23 feet high. There are two rollup doors located at the west end of the building. The 2706-TA Building has steel primary and secondary structural elements and corrugated sheet metal exterior siding and roofing panels. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-TA Building operations area. The floor is concrete slab on grade. An epoxy floor sealant had been applied to all operational area floors. Waste handling and decontamination opera_tional areas of the 2706-T A Building are open and unobstructed.


Include waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, house.keeping, s_urveiHance, and movement activities. To support waste activities, greenhouses are used if necessary. Greenhouses are temporary or semipermanent radioactive material confinement structures, and can be used for co_mamination ccmtrol. When used, greenhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation system.

Attached to the south side of 2706-TA Building is a lean-to made up of two rooms. The larger room houses the new ACT-2 HEPA filter system, which serves the operational areas. The ACT-I and ACT-2 systems exhaust through the 296-T-7 stack. Th·e second room houses electronic controllers and electrical switchgear supporting operations.

Emissions from these activities are exhausted through 296-T-7, except for emissions resulting from vented TRU containers stored within the fadlity, which may be released to the 200 Area diffuse and fugitive emission unit when the ventilation system is _not in operation.

3) The PTE for this project as determined under WAC 246-247-030(21 )(a-e) [as specified in the application] is 7.S0E-02 mrern/year. Approved are the associated potential release rates (Curies/year) of:

DE-0 1.90E-05 Contained WAC 246-247-030(21)(3) Any ra·dionuclide on the chart of the nuclides could be encountered. A small contribution from the gaseous radionuclides may be encoun"tered. The radior1uclides within the facility are controlled by the licensee in terms of dose-equivalent (DE) Curies. A conservative PTE tracking method for the demonstration of com·pliance to the licensed PTE limits is prrivided in the conditions of the license. "Contained" means "within typical TR!J wasJe coritainel"S ~or wf:lich a releas_e fraction of 2E-09 ha·s been determined to be appr'opriate."


DE-0 2.90E-03 Liquid/Particulate Solid WAC 246-247-030(21 )(a) Any radionuclide on the chart of the nuclides could be encountered. A small contribution from the gaseous radionuclides may be encountered. The radionuclides within the facility are kno\M'l to and controlled by the licensee in terms of doseequivalent (0.E) CLJ~es. A COnservative PTE tracking method for the demonstration of compliance to the licensed PTE limits is provided in the condiUons of the license. This amount ·of DE curies is perrilitt0d within the fadlity Uncontained in TRU v,,,aste containers as liquid/particulate for which a release traCtion of 1 E-03 is appropriate.

H-3 1.50E+01 Gas WAC 246-247-030(21)(a)

Rn - 219 2.00E-01 Gas WAC 246-247-030(21)(a)

Rn - 220 2.80E+01 Gas WAC 246-247-030(21)(a)

Rn - 222 1.47E+00 Gas WAC 246-247-030{21)(a)

The radioactive isotopes identified for this emission unit are (no quantities specified): H-3 Rn-219 Rn-220 Rn-222

The potential rele_ase rates described in this Condition were used to determine control technologies and monitoring requirements for this approval. DOE must notifiy the Department of a "modification" to the emission uni_!, as defined i_n WAC 246-247-030(16). DOE must notify the Department of any changes to a NESHAP major emission writ when a specific isotope is newly identified as contributing greater than 10% of the p_otential TEDE to the MEI, or greater than 25% of the TEDE to the MEI after controls. (WAC246,247-l l 0(9)) DOE must notify the Department of any changes to potential rekase rates as required by state or federal regulations including c_hanges that would constitute a significant modification to the Air Operating Pennit under WAC l 73-401-725(4). Notice will be provided according to the particuiar regulation under which notification is required. If the 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) USE OF AS LOW AS REASONALBE ATAINABLE PRINCIPLE

All activities involving potentially airborne radioactive materials in 2706-T shall be conducted in accordance with the ALARA principle.

5) PTE TRACKING IN AIR SPACE VENTILATED BY 296-T-7

The PTE in the SIJace ventilated by 296-T-7 shall be tracked for compliance to the license limit as described in this condition.

Waste Contained in Typical TRU Waste Containe.rs: PTE < 9490 DE Ci/year• 2E-09. Compliance: maintain annual total of DE Ci * 2E-09 below limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 241-Aril].

Venting of Waste Uncontained in Typical TRU waste Containers: PTE < 9490 DE Ci/year• I E-03 • 5. 7E-05. Compliance: maintain annual total of DE Ci • I E-03 • 5. 7E-05 vented below limit. [Dose contribution of this activity to license limi.t estimated assuming each DE Ci is 241-Aril].

Torch cutting: PTE< 9E-04 nirem/year. Compliance: Maintain the product of inches cut and contamination level to:< 8.8 E+09 in-dpm/100 sq.cm beta/gamma and< 8.8E+6 dpm/100 sq.cm alpha. (Note: The release at the cut is assumed gaseous due to high cutting t~mperature, but it is also assumed that any gases thus formed will recondens_e into a particulate form by the time they reach the filters, and be subject to the standard removal efficiency of the HEPA filter.) [Dose contribution of this activity to license l_imit estimated assuming all alpha is 241-Aril, all bet_a/garnma is 137-Cs.]

Gases in Waste Contained in Typical TRU Waste Containers: PTE < 7E-04 mrem/year. Compliance - maintain: tritium PTE below 15 Ci/yr; 219-Rn PTE below 0.2 Ci/yr; 220-Rn PTE below 28 Ci/yr; 222-Rn PTE below l.47 Ci/year. These limits apply to process-enhanced radionuclides only, per (WAC 246-247-020(4)). [Dose contribution of this activity to license limit estimated using isotope-specific dose conversions factors.]


0

Other Processes: PTE < 4.9 E-02 mrern/year. Compliance: mainta_in total facility DE Ci/year (exdusive of1RU included above)• lE-03 below 2.9 • IE-03, or maintain the sum Ci(alpha) • IE-03 • 17 + Ci(beta/garnma) • !E-03 • 0.31 below 4.9 E-02 mrem/year. [Dose contribution of this activity's PTE to Hcense limit estimated assuming DE Curies are 241-Am].

Residual Contamination: PTE < 7.1 E-03 airem/year. Accounts for residual contamination present in facility if posting is Contamination Area or below. Greater contamination levels result from other proces_ses, and are ~ccoUI1ted for in the PTE(s) a·ssociated with them. No specific compliance demonstration is necessary beyond the compliancewith posting requirements. [Dose contribution of this aciivity to license limit estimated assuming all alpha is 241-Am, ail beta/gamnia is 137-Cs.]

The facility shail document and implement a program of inspection and maintenance to ensure the continuous integrity of contamination fixative used within the fac_ility.

That the total PTE does not exceed licensed limits shall be routinely verified, and documentation of that verification shall be maintained.


The ventilation system shall be in operation when ac_tivities involving radioactive or con_t_aminated materials are perfonned within the ventilated space. The ventilation.system shall be in operation if any part of the 2706-T Facility is posted as a high contamination area, or higher. Storage/move11_1ent of ventilated (NucFil or vent ciip) TRU containers is permitted when the ventilation system is not operating.

7) CONDITIONS REQUIRJNG CONTINUOUS RECORD SAMPLING

Record sampling shall be continuous whenever the ventilation system is·operating. Samples shall be collected monthly, for periods in wh_ich the ventilation system has operated. Samples shall be composited and analyzed quanerly, if a sample was collected during that quarter. Licensee shall document minimum detectable concentrations for t_he.sta~k emissions measurements. (WAC 246-247-075 (3, 8, 9))


All roll up doors providing access to the interior of the 2706-T and/or 2706-TA buildings from the ambient atmosphere shall remain closed whenever the vent.ila_t_ion system is in operation as required by condition 6.

9) ALPHNBETA MD As and MDCs REQUIRED FOR ANALYTICAL LABO RA TORIES


The Nominal Sample Volume for a single sample filter of 20,000 ftA3 (5.7E+08 rnL) Gross Alpha (c MDA (a) 5.0E-06 µCi MDC (b) 8.8E-15 µCi/mL Gross Beta (c MDA (a) 1.0E-05 µCi MDC (b) 1.8E-14 µCi/mL Silver (ag) zeolite (d) MDA (a) l .9E-05 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quanerly composite sample of262,000 ftA3 (7.4E+09 mL) Sr-90 M_DA (a) 1.4E-05 µCi MDC (b) 1.9E-15 µCi/mL Gamma Energy Analysis (e MDA (a) 1.4E-05 µCi (as Cs0 137) MDC (b) 1.9E-15 µCi/mL (as Cs-137) Isotopic Pu (i.e. Pu-238, Pu-239/240) Pu-241

MDA (a) l .5E-06 µCi MDA (a) 7.4E-05 µCi MDA (a) 1.4E-06 µCi


MDC (b) 2.0E-16 µCi/mL MDC (b) l.0E-14 µCi/mL MDC (b) 1.9E-l 6 µCi/mL

(a) Actual MDAs derived from sample analyses shall be as low as reasonably achievable and shall not exceed the values specified in Table I provided the sample meets or exceeds its respective nominal volume. The target MDAs in Table I are derived from multiplying the MDCs in Table I by the respective nominal sample volumes

Page 7 of 8 for EU_I_D 315

shown in the table.

(b) Actual MDCs derived from sample analysis shall be as low as reasonably attainable and shaft no_t exceed the values specified in the Ta_ble I provided the sample Illeets or exceeds its respective nominal volume. The target MDCs in Table I are I 0% of the concentration values in Table 2 of 40 CFR 61, Appendix E.

(c GAB emission data are often used in dose calculations to substitute for the presumed presence of the usµally most prevalent alpha- and befa-emitting raciion_i,_clides having the highest dose factors, which, depending on fac_ility source term, for alpha-emitters has mostly usually been Pu-239/240, but occasionally Am-241, an_cl for beta-emitters, Sr-90, but occasionaily Cs-137.

(d) Silver zeolite analysis shall be designed to primarily identify 1-129.

(e All positive.gamma-energy analysis (GEA) results shall be reported, wi_t_h the exception of short lived progeny of Rn-222 and Ri_i-220. At a minimum, GEA shall be designed to identify peaks ofCo-60, Ru-I 06, Sb-125, Cs-134, Cs-137, Eu-152, Eu-154, Eu-155, and Pa-231.

Page a of a for EU_ID 315


Stack Height: 28.00 ft. 8:53 m. Stack Diameter 2.30 ft.

Average Stack Effluent Temperature: 78 degrees Fahrenheit. 26 degrees Celsius.




Zone or Area Abatement Technology

Pretilter

HEPA

Fan

. Required # of Units

Mo_nitoring R.equi.ren:ients . . .

0.70 m.

. Addi(!onal_ J?e_scrjp!iC11_1 ,.C:-

7Ef" To operate per Conditions and ·Limitations of the \icense. ·

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


40 CFR 6l.93(c)(4)(e) & WAC 246-247-075(3)


40 CFR 61, Appendix B, Method 114(3)

Sampling Requirements Record Sample

Ad_di~~r:,al RequlrO~e:~~

~adion!,l~lides R.eq11iring 1\leasurement

TOTALALPHA TOTAL BETA

s. lin amP .... g Frequency

Additional monitoring or sampling requirements established by this License will be listed in the Conditions and limitations section, if applicable.

Operational S_~a~_us Activitie,s at th_e 2"?06-T Fac_iJi~y i_nyo!Ve waste manageme·nt operations i_n support of decontamin3tio_n and d~comissioning operations _at th~ H3:I1for~ _Sit~.

This E111iss.ion Un.it has 1 acti.ve N.otice(s) of Construction.

Project Title Approval# Date Approved NOC_ID Operation of 2706-T Bu· din,epl es NOC 920) Not Approved 1033

Conditions (state on.iv""' WAC 246-247-040(5), 060(5) if not specifi~d) I) The total abated emission limit for thi_s Notice ofConstruction.i.s limited to 7.50E-03 mrern/year to the

Maximally Exposed ln.d.ividua.1 (IV 4 C 246 i41-Q4D(5)t.

2) This approval applies only to those activities described below. No additional activities or variations on the approved activities that con.st.it.LI.I~ a "modifica.t.ion" to the emission unit, as defined in (WAC 246-247-030(16)), may be condilcteil. The approved activities are limited to:

A) PACKAGING AND REPACKAGING WASTE ~~ Packaging and repackaging activities are performed for waste generated at 2706-T asae . onsite and offsite generntors. The repa.ckaging of was.te s.upports waste acceptance criteria for ot TSO cilities. For example, prohibited items from waste packages are removed and either staged for lat mg or repackaging using remote or manual methods.

Packaging and repackaging activities are:


Page 1 ol 8 lor EU_ID 315

c) Removing prohi_bited items. d) Compositing/aggregating solids or liquids.

dding absorbent. e reduction [~.g., cu~ing (jaws, saws, torches)], bending'. folding, crushi~g (e.g., drum crusher), mg, compacting, or s1m1lar me_t_hods that do not l]ave a higher extent of d1srupuon]. ·

g) Void filling. h) Press_ure re_iief/release (e.g.-, aerosol cans, gas cylinders, drums, or other similar containers).


Verification support activities are provided for waste and oth:er materials that are genernted on or off the Hanford Site.


a) Physical observation. b) Nondestructive examination (NOE). c) Nondestructive assay (NOA). d) Chemical field screening. e) Radiological.surveys. f) Radiological samples. g) Headspace gas sampling". h) Chemical sampling.

C) SAMPLING ACTivITIES

S_ampling of waste generated by operations or by other onsite or offsite generators is performed. The purpose of sampling is to confirm proc:es_s kriowledge, characterize waste, support verification, and determine land disposal requirements as applicable.


a) Field screening [ e.g., pH paper, oxidizer, volatile organic analyses (VOAs), polychlorinated biphenjrls (PCBs), or similar screening pararneters]. b) Obtaining a sample.for analysis [e.g., grab, composite, cciritposite liquid was_te samp_ler (COUWASA), or ot_her s_imilar sampling techniques]. c) Shipping/transferring the samples to an approved laboratory for analysis. d) Disposition of sample retunis (e.g., placement back in_to tl]e p_aren_t container or another approved container/tank). · e) Headspace gas analysis [typically in support of the Waste Isolation Pilot Plant (WIPP) Project].

D) DECONT AMINA Tl ON/REFURBISHMENT ACTIVITIES

Qaterials, e. quipmen_t, a_nd waste can be de. contamin_ated (e.g., fr. ee release, reduce the ra_diological le. vels, or er similar criteria) using a variety of methods. Equipine·nt can als_o be re.paired and refurbished within the

06-T facil_ity. Within 2706-T, decontamination of2706-T structural components may be performed.

Decontamination and refurbishment activities at 2706-T are:

"'1' a) Vacuum blasting. b) Brushing. c) Abrasive.tools. d) Sc_raping. e) Washing (e.g., chemicals/detergents). f) Immersion. g) Elect_ro-poiis_hing.


•

i

h) Cutti_ng (e.g., re_mova_l by sawi_ng, torch cutting 111ore highly radioactive compon_ents or other similar rriethods). i) Rust/paint removal. j) Sand blasting_ k) v a·cuuriiiilg.

E) MA_INTENA_NCE ACTIVITIES

A variety of preventative and/or repair maintenance activities are performed at 2706-T. s·ome 111._a_i_nte_n_an_ce ac_tivi_t_ie_s i_nvolve the tempora-ry shut down of the 296-T-7 exhaust stack.


a) Painting. b) Crane maintenance.

I c) Ele.ct_rnnic syst.,111.s function-al checks a:nd repairs [CAMs, personnel contamination monitors (PCMs)]_ d) Calibrations. e) Mechanical overhaul and rebuild.

\I I) Bearing rep_l~c~ment. '\ ~) Pump and motor alignment.

Maintenance may be performed on: h) Roil up do:C,rs. i) Heat pumps .. j) Exhaust fans. k) Tra'nsformers. i) Scale systems. m) Wire rope. n) Stack systems_

o) Forklifts. . , ~-~ F) WASTE TRE~T ACTIVITIES ..

2706-Tis~ treatment and Storage fac_ility pell1l_itted by the Washington StateDepartrrient of Ecology (Ecology)~


a) Macroencapsulation. b) Absorption_ c) Neutra_(ization. d) Iriimobilization. e) Encapsulation_ I) Stabilization (solidification, cementati_on, grouting). g) Compaction. h) Amalgamation. i) Segregation. j) Shredding. k) Venting and drilling. I) Size Reduction.


Materials are recycled whenever possible. Recycled materials are: ferrous and non-ferrous metal, light bulbs, aerosol cans,- oils, and batteries.-

H) STORAGE ACTIVITIES


2706-T stores materials (chemicals, or e:quipment, or similar m.aterials) to support operations. Radioactive wastes may be stored uocontainerized or in: a) Containers (boxes, drums, tanker trucks/railcars, or large diameter containers). b) Tanks, c) Sumps and pipes.

I) EQUIPMENT, MATERIALS, AND WASTE MOVEMENT ACTIVITIES

The movement of materials, equipment and waste is necessary to support operations and maintenance. Movement activities (using a forklifr, crnne, truck, dolly, personnel) are: a) Receiving waste (liquid, solid, semi-solid) for storage and/or treat.men!. b) Movement of waste (liquid, solid, semi-solid) and equipment. c) Movement of liquids, sludges, or other waste from containers and/or tanks via transfer lines. d) Waste container transfers. e) Placing and storing chemical products in flammable cabinets or other approved storage locations. f) Movement of contaminated ma.t.e.rial. ·

J) HOUSEKEEPING ACTIVITIES



a) Sweeping (brooms). b) Mopping (sqileegees or mops). c) Vacuuming. d) Dusting. e) Wiping (sponges, towels). f) Picking up debris. g) Removal of trash.

K) SURVEILLANCE ACTIVITIES

Surveillance activities i.nvolve w.alking down and inspecting various areas, systems, and components .. Surveillances typically consist of daily, weekly, and monthly inspections of waste comainers, tanks, buildings, or similar locations. Surveillances are.subject to change (adding, deleting arid/or modifying) as opera_tions, 11).ai.n.t.ena:nce, engineering, and radiological control dictates. Surveillances, inspections, and maintenance activities that do not have the poten.t_i_al to c.reate ~irborne contamination can occur within the 2706-T Building when the.296-T'7 exhauststack emission system is shutdown.

The following survei'flam:es are p<crformed a.t 2706-T:

a) Container storage areas treatment and storage tanks and ancillary equipment. b) General c:onciition ofbui].ding strncmres. c) Cold weather surveillances (typically, between October I and Ma'rch 3 I). cl) Inspection of equipment. e) Inspection of HEPA filtered vacuums. F) Radiological surveys.

2706°T: The 2706-T facility includes the 2706-T btiilding and the 2706-TA Building. The 2706-T Building and the 2706-T A Building make up a single structure and are described briefly here. The 2706-T facffi.1Y handles lciw-level waste, m.ix.e.d low ·level waste, and transuranic (TRU) waste.

The 2706-T Building was built in 1959 as a low-level radiological decontamination building. The original building was 66 feet long and 50 ft wide_. The 2706-TA Building was added in 1994/1995 over the concrete pad on the west side of the 2706-T. One rollup-door and cine man-do.or provide acces_s be.tween 2706-T and

Page 4 of B for EIJ_ID 315

'

•

2706-TA Building. Three heat pumps provide heating, ventilation, and air co·nditioning for the 2706-T Building operations area. Waste handling and decontamination operational areas of the.2706-T Building are open and unobstructed. The 2706-T building is a pre-engineered metal building. The foundation is concrete slab on grade throughout. The 2706-T Bu_i_ld_ing includes two pi_ts, one for deco~_t_am_ina_t_i_on·and treatment of motor vehicles and other large equipment, and one for rail car decontamination and treatment. These pits can also be used to support collection of liquids from waste handling activities.

URRENT OPERATIONS IN 2706-T BUILDING

Jude waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, co"ntamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement

activities. One egress door leads directly to the exterior of2706-T Building. Other doors lead directly to the non-ventilated lean-to on the north side, and an air lock provides access to the 2706-TA Building operations area. The railway and auto pits have metal grating and some wooden covers to prevent falls into the pits. An epoxy floor sealant had been applied to all operational area floors. To support these operations, greenhouses are used as necessary in 2706-T. Greenhouses are temporary or semi-permanent rad}oact_ive mat_erial confinement structures, and can be used for contamination control. If used, greenhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation system.

The atmosphere clean-up train (ACT-I) system, sprinkler system riser rooi:n, and electrical room are located in the south lean-to (non-ventilated).

2706-TA: The 2706-TA Building is an addition to the 2706-T Building installed in the 1990s as an add-on over the concrete storage pad located west of the building. The 2706°TA Building is·approxii:nately 54 feet long, 45 ft wide, and 23 feet high. There are two rollup doors loc_ated at the west end of th_e buildi_ng. The 2706-T A Building has steel primary and secondary structural elements and corrugated sheet metal exterior siding and roofing panels. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-TA Building operations area. The floor is concrete slab on grade. An epoxy floor sealant h"ad been applied t_o all operational area floors. Waste handling and decontamination operational areas of the 2706-TA Building are open and unobstructed.

CURRENT OPERATION IN 2706-T A BUILDING

~Jude waste sampling, packaging and repac_kaging, head-gas sampling, managing waste c·ontainers, ~ontamination/refurbishment, maintenance,.recycling, storage, housekeeping, surveillance, and movement

activities. To support waste activities, greenhouses are used if necessary. Greenhouses are temporary or semipermanent rad_ioa_ctive material confinement strffctures, and can be u_sed for contaniination control. When used, greenhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation system.

Anached to the south side of2706-TA Building is a lean-to made up of two roo_ms. The larger roorri hous_es the new ACT-2 HEPA tilter system, which serves the operational areas. The ACT-I and ACT-2.systems exhaust through the 296-T-7 stack. The second room houses electronic controllers and electrical switchgear supporting operations.

Emissions from these activities are exhausted through 296-T-7, except for emissions resulting from vented TRU containers stored within the facility, which may be released to the 200 Area diffuse and fugitive emission unit whe.n the v~nt_i_lation system is not in operatio"i:i,_.

3) The PTE for this project as determined under WAC 246-247-030(21 )(a-e) [as specified in the application] is 7.50E-02 mrern/year. Approved are the associated potential release rates (Curies/year) of:

DE-0 1.90E-05 Contained WAC 246-247-030(21 )(a) Any radionuclide on the d1art. of the nudides could be encountered. A small contribution from the gaseous radionuclides may be encountered. The radionuclides within the facility are controlled by the licensee in terms of dose-equivalent (DE) Curies. A cons·ervative PTE·tracking method fo"r thEI de·monStration of Ccimplian·ce _to the lic:ensed PTE limits is provided in the conditions of the license. "Contained" niea_ns "within typical TRU waste coritainers for which a release fractiOn of 2E-09 has been d9termined to be appropriate." · ·· ·


4)

DE-0 2.90E-03 Liquid/Particulate Solid WAC 246-247-030(21 )(a) Any radionuclide on the chart of the nuclides could be encountered. A small contribution from the gaseous radionuclides may be encountered. The radionuclides within the facility are known to and controlled by the licensee in terms of do_seeqlliValent (DE) Curies. A co·nservative PTE tracking method for the demonstration of compliance to the licensed PT!= limits is piovided in the co"ndition·s of the license. This amollnt or DE curies is permitted within lhe facility uncontained in TRU waste containers aa liquid/pcirticulate for Which a release fraction of 1 E-03 is appropriate.

H-3 1.50E+01 Gas WAC 246-247-030(21 )(a)

Rn - 219 2.00E'01 Gas WAC 246-247-030(21 )(a)

Rn -220 2.80E+01 Gas WAC 246-247-030(21 )(a)

Rn -222 1.47E+00 Gas WAC 246-247-030(21 )(a)

The radioactive isotopes identified for this emission unit are (no quantities specified): H-3 Rn-219 Rn-220 Rn-222

The potential release rates described in this Condition were used to determine control techn_ologies a·n_d 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 must notify the Department of any changes to a NESHAP major emission unit when a specific isotope is newly identified as contributing greater than I 0% of the potential TEDE to the MEI, or greater than 25% of the TEDE to the MEI after controls. (WAC 246-247-110(9)) DOE must notify the Depanment 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 I 73-401-725(4). Notice will be provided according to the particular regulation under which notification is required. If the applicable regiilation(s) does not address manner and type ofnotification, DOE will provide the Department with advance otice by letter or electronic mail but not solely by copies of dociiments.

All activities involving potentially airborne radioactive materials in 2706-T shall be conducted in accordance with the ALARA principle. (\V.'.C 216 247-040(5Jr


The PTE in the space ventilated by 296-T'7 shall be tracked for compliance to the license liniit as described i_n this condh_ion.

Waste Contained in Typical TRU Waste Containers: PTE < 9490 DE Ci/year• 2E-09. Conipli_ance: main_t_ain annual total of DE Ci • 2E-09 below limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 241-AI_n].

Venting of Waste Uncontained in Typical TRU waste Containers: PTE < 9490 DE Ci/year• IE-03 * 5.7E-05. Compfiance: maintain annual total of DE Ci • 1 E-03 • 5. 7E-05 vented below limit. [Dose contribution of this activity to license limit estimated assuming each DE C1 is 241-Am].

Torch c_ut_t_ing: PTE< 9E-04 mrem/year. Compliance: Maintain the product of inches cut and contamination level to:< 8.8 E+09 in-dpm/100 sq.cm beta/ganima and< 8.8E+6 dpm/100 sq.cm alpha. (Note: The release at the cut is assumed gaseous due to high cutting temperature, but it is also assumed that any gases thus fonned will reccindense into a pa_nicula_te form by the time they reach the filters, and be subject to the standard removal efficiency of the HEPA filter.) [Dose contribution of this activity to license limit estimated assu_ming all alpha i_s 241-Am, all beta/gamma is 137-Cs.]

Gases in Waste Contained in Typical TRU Waste Containers: PTE < 7E-04 mrem/year. Compliance - maintain: tritium PTE below 15 Ci/yr; 219-Rn PTE below 0.2 Ci/yr; 220-Rn PTE below 28 Ci/yr; 222-Rn PTE below 1.47 Ci/year. These limits apply to process-enhanced radionuclides only, per (WAC 246-247-020(4)). [Dose contribution of this activity to license limit.estimated.using isotope-specific dose conversions factors.]


•

•

6)

7)

8)

9)

Other Processes: PTE < 4.9 E-02 mrem/year. Compliance: maintain total facility DE Ci/year (exclusive ofTRU included above) • I E-03 below2.9 • I E-03, or maintain the sum Ci(alpha) • I E-03 • 17 + Ci(beta/gamma) • IE-03 • 0.31 below 4.'9 E-02 mrein/year. [Dose contribu_tion of this a'ctivity's PTE to license limit ,;stima_ted ass_umi_ng DE Curies are 241-Am].

Residual Comamination_: PTE < 7. IE-03 mrem/year. Accoun_ts for residu_al con_tamination presen_t in facility i_f posting is Coritaniin·ation Area cir below. Greater contamination levels result from other processes, and are accounted for in the PTE(s) associated with them. No specific compliance demonstration is necessary beyond the compliance with posting requirements.' [Dose con_tribution of this act_ivity to li_cense (imit estima_ted assuming afl alpha is 241-Am, all beta/gamma is 13 7-Cs.]

The fac_,!ity sha_B document and implement a program of inspec_tion arid mainterian·ce to ensure the contiriiious integrity of contamination fixative used within the facility.

Th_at the t_otal PTE d9es not exceed lic:ensed limits shall be routinely verified, arid do_cumentation of that verification shall be maintained. (WAC 216 247 (WJ(5)l (l\,.,C 216 217 060(5)t"

CONDITIONS REQUIRING OPERATION OFVENTILATION SYSTEM

Th_e ventilation system shall be in operation when activities involving radioactive or contaminated materials are performed within the ventilated space. The ventilation system shall be in operation if any part of the 2706-T F_acility is posted as a high contamination area, or higher. Storage/movement of ventilated (NucFil or vent dip) TRU containers is pemiined when the ventilation system is not operati~'AC 246 247-040(5), (WA.C 216 -247-~ . CONDITIONS REQUIRING CONTINUOUS RECORD SAMPLING

Record sampling shall be continuous whenever the ventilation system is operating. Samples shall be collected monthly, for periods in which the ventilation system has operated. Samples shall be composited and analyzed quarterly, if a sample was collected during t_hat qu~rter. Licen_see s_ha!i dcicum_e:m mi_n_imiim detectable concentrations for the stack emissions measureme~WAC 246-247-075 (3, 8, 9)) .

CLOSURE OF ACCESS DOORS CJ

All roll up doors providing access t_o the i_n_te_rior of the 2706-T a_n~or 2706-TA bu,Idings from the ambient atmosphere shall remain closed whenever the ventilation system is in operation as required by condition 6.

rfl!'4C 24{;-24'i' 010(S)) (WAC 216 247 Q60(S))

ALPHA/BETA MD As and MDCs REQUIRED FOR ANALYTICAL LABORATORIES


The N_ominal Sample Volume for a single saniple filter of20,000 ft"3 (5.7E+08 mL) Gross Alpha (c MDA (a) 5.0E;06 µCi MDC (b) 8.SE-15 µCi/mL Gross Beta (c MDA (a) I.0E-05 µCi MDC (b) 1.8E-14 µCi/mL Silver (ag) zeolite (d) MDA (a) l.9E-05 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quarterly composite sample of26_2,000 ft"3 (7.4E+09 mL) Sr-90 MDA (a) 1.4E-05 µCi MDC (b) l.9E-15 µCi/mL Gamma Energy Analysis (e MDA (a) l.4E-05 µCi (as Cs-137) MDC (b) l.9E-15 µCi/mL (as Cs-137) Isotopic Pu (i.e. Pu-238, Pu-239/240) Pu-241 Am-241

MDA (a) l .SE-06 µCi MDA (a) 7.4E-05 µCi MDA (a) l .4E-06 µCi

MDA = minim_um det_ectable activity; MDC= minimum detectable ccin_centration.

MDC (b) 2.0E-16 µCi/mL MDC (b) L0E-14 µCi/mL MDC (b) l.9E-l 6 µCi/mL

(aj\ctual MD As derived from sample analyses shall be as low as reasonably achievable and shall not exceed the


values specified in Tab.le I provi.d_ed the s_ampl!'.mee.t_s or exceeds its respective nominal volume. The target MDAs in Table I are derived from multiplying the MDCs in Table I by the respective nominal sample volul)l.es shown in the table. ··

(b)\ctual MDCs derived from sample analysis shall be as low as reasonably attainable and shall not exceed the values specified in the Table I provided the sample meets or exceeds its respective nominal volume. The target MDCs in Table I are ]0% of .th!' cori~ent~ation val_u~s in Table 2 of 40 CFR 61, Appendix E.

(c GAB emission data are often used in dose calculations to substitute for the presumed presence of the usually most prevalent alpha- arid b_eta-einitting ra_dionrniides having the highest dose factors, which, depending on facility source term, for alpha-emitters has mostly usually been Pu-239/240, but occasicirially Ain-241, and for be_ta-emitters, Sr-90, but occasionally Cs-137.

(dpilver zeolite analysis shall be designed to primarily identify 1-129.

I

(e All positive gamma-energy analysis (GEA) re·sults shail be reported,-with the exception of short lived progeny ofRn-222 and Rn-220. At a·minimurn, GEA shall be designed to identify peaks ofCo-60, Ru-106, Sb-125, Cs-134, Cs-137, Eu-152, Eu-154, Eu-155, and Pa-231. (WAC J4~ J47 Q4Q(5l) (W•C J46 J47 Q~9(5))

Page 8 of.8 for.EU_ID 315

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i Richland Operations Office ' ~- · ~ · ! P.O. Box 550, MSIN: A5s14 .i,;>,y.:::,~ \ Richland, WA 99352 ··-------- - -----,-· ••. ilceType

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STAH OF WASHINGTON

DEPARTMENT OF HEALTH OFFICE OF IMDIATION PROTECTION

3(J'J Br,1dlcy Blvd., Suite 201 • Richl,md, Washington 99152

TDD Relay Service, 1·800·833-6388

December 14, 20 I 6

CERTIFIED MAIL 7015 0640·0007 5050 7951

Mr. Doug Shoop, Manager United States Department ofEriergy Richland Operations Office P.O. Box 550, MSIN: A5-14 Richland, Washington 99352

Re: 28-Day Draft Approval ofNotice ofConstruct_i_on (NOC) IQ33

AIR 16-1209 NOC 1033

Reference: Letter l 7-ESQ-0008 (IM 9,263), from DoU:g Shoop (USDOE) to.Donald Dossett (EPA), ~ol)li M_arteH (WDOH), and Alex~dra Smith (Ecology), "Transmittal of Radioactive Air Emissions License/As Low As · · R~as_onably Achievable Control Technology Revision Request to Modify the 2706T Radioactive Air Emissions Uriit License ... ,,, dated November 2, io I 6. - . - . - .

Mr .. Shoop:

~t to Chapter 246-247 of the Washington Administrative Code (WAC), your reference revision request will be approved according to the enclosed License for:

Operation of2706-T Bu_i_lding (Replaces NOC 920) · (EU 315; NOC 1033)

The Washington State Department of Health (DOH) considers tJ.i.e cond_itions, co1.1trol_s, monitoring requirements, and limitations of the License iiitegral to approval of your application.

This approval shall take effect, and a final approval letter issued, twenty-eight (28) days after you receive this letter, unless you apply for an adjudicative proceeding, as described below.

If you accept the conditions and limitations of this approval and do not wish to apply for an adjudicative proceeding, but msh to proceed under this approval before the 28 days have

Public Health - Alw;1ys Working !or a S.1fer ,1nd He.1lthier \-\'.1shington

Mr. Doug Shoop December 14, 2016 Page 2 of3

AIR 16-1_209

elapsed, please notify us in writing and the DOH will issue a final approval letter. Your notice should be mailed or faxed to:

DOH - Ofjice of Radiation Protection Radioactive Air Emissions Section 309 Bradley Blvd., Suite 20 I Richland, Washington 98352 FAX: (509) 946-0876 .

If there are concerns wi_th the conditions and limitations of the approval, please notify the DOi-f. If att_empts to resolve the concerns fail, the DOH will deny your application and you may contest the conditions and limitations of this approval, withi1128 days of receipt, by filing the enclosed Request for Adjudicative Proceeding or a document providing substantially the same infonnal:ion with the DOH, Adjudicative Service Uriit (ASU}, in a manner that s_hows proof of service on the ASU. The,ASU's address is:

DOH - Adjudicative Service Unit 310 Israel Road SE P.O. Box 47879 Olympia, Washington 98504-7879

You must include a copy of this approval withyour application. FILING. SHALL NOT BE DEEMED COMPLETE UNTIL THE ADJUDICATIVE SERVICE UNIT ACTUALLY RECEIVES YOURAPPLICATION.

If you have any questions rega.rdirig this approval, please contact Thomas Frazier at thomas.fraziert'@doh.wa.gov or, by phone, at (509) 9.46-0774.

Sincerely,

~r&a-John Martell, Manager Radioactive Air Emissions Section

Enclosures: (1) Conditions and Limitations for EU 315 (NOC 1033) (2) Request for Adjudicative Proceedings

cc: (see next page)

Mr. Doug Shoop December 14, 2016 Page 3 of3

cc: Ru_th Allen, WRPS Matthew Barnett, PNNL Lilyann Bauder, Ecology Shiiwna Berven, WDOH Lucinda Borneman, WRPS Lee Bostic, BNI Frank Carleo, CHPRC Cliff Clark, USDOE0 RL Jack Donnelly, WRPS Dennis Faulk, EPA Eric Faust, USDOE-RL Thomas Frazier, WDOH Gaxy Fritz, M_SA Philip Gent, Ecology Daniel Heuston, Ecology Reed Kaldor, MSA Paul Karschnia, CHPRC Jim McAuley, EPA John Schmidt, WDOH Jeff Voogd, WRPS Environmental Portal RAES Tracking: Line 16-204; Resp. to IM 9,263; EU 315; NOC I 033

AIR 16-1209 - . ·-

!:;mission Unit ID: 3 I 5

200W P-296T007-001 296-T-7 This is n MINOR. ACllVELY VCfltilatcd emission unit.

T- PLANT C-OMPLE)(

E_mlsslon Unit Information

Stack Height: 28.00 ft. 8.53 m. Stack Diameter 2.30 ft.

Average Stack E(Quen_t Temperature: 78 degrees FahrenheiL 26 degrees Celsius.


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

Prefilter

HEPA

Fan

ll!lonltorl_ng Requirements

Required # of Units

0.70m.

Additional Description

To operate per Conditions and Limitations of the license.

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

Federal and Stnte Regulatory

40 CFR 61.93(c)(4XeJ & WAC 246-247-075(3)

Monitoring and Tes ting Requireme_1:,Js

40 CFR 6 f, Appendix B, Method 114(3)

Sampling Requirements Record Sample Additional' Reql.lirernonts

R,adJonucli<:fes ~eqll!J::in·g Measure"me·nt

TOTALAf.PHA TOTAL BETA

Sampling Frequency

Sec special conditions.

Additlonal n:-onito~ng or sampling requirements e:stablished by this Lice"nse will be Usted In the Condilions and Limitations section. if applicable.

Operational Stohu Activities at the 2706·T Facility invol"'.e Waste ma"1:iagerrie_nt op.eratiOns ii} sUppOrt of dCContaminatiOn and decomissiO_ning op.era_tions cit the Hanf6rd Si.te.

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

Project Tltle Approval# Date Approved NOC_ID Operation of 2706 ... T Building (Replac·es NOC 920) No_t App_roved

Con_ditlons (s~ate on_ly enforceable: WAC246-247-040(5}, 060(5) If not specified) I) The total abated emission limit for this Notice of Construction is limited to 7.SOE-03 mrem/year t_o the

Maximaily Exposed Individual (WAC 246-24 7-040(5)).

1033

2) This approval applies only to those activities described below_. No add";_t_i_ona_l 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. The approved activities are limited to:


Packaging and repackaging activities arc performed for waste generated at 2706-T as well as for <insite and offs_ite generators. The repackaging of waste supports waste acceptance criteria for other Treatment Storage and Disposal (TSD) _facilities. For exampl_e, prnhibi_t_ed item_s from waste packages are removed and either staged for later handling or repackaging using remote or manual methods.

Packaging and repackaging activities arc:



c) Removing prohibited items. d) Compositing/aggregating solids or liquids. e) A~ding absorbent. I) Size reduction [e.g., cuning (jaws, saws, torches)], bending, foldin·g, cnishi_ng (e.g., drum crusher), shredding. compacting. or similar methods that do not haven higher extent of disruption]. g) Void filling. h) Pressure relief/release ( e.g., aerosol cans, gas cylinders, drums, or other similar containers).

B) VERIFICATION ACTNITIES



a) Physical observation. b) Nondestructive examination (NOE). c) Nondestructive assay (NOA). d) Chemical field screening. e) RacHological surveys. I) Radiological samples. g) Headspace gas sampling. h) Chemical sampling.

C) SAMPLING ACTNITIES

Sampling of waste generated by operations or by other. onsite or off site generators is performed. The purpose of sampling is to confirm process knowledge, characterize waste, support verification, and determine land disposal requirements as applicable.

Sampling activiti_es are:

a) Field screening [e.g., pH paper, oxidizer, volatile organic analyses (VOAs), polychlorinated hiphenyls (PCBs), or similar screening parameters]. b) Obtaining a sample for analysis [e.g., grab, composite, composite liquid waste sampler (COLIWASA), or othe_r similar sampling techniques]. c) Shipping/transferring the samples to an approved laboratory for analysis. d) Disposition of sample returns ( e.g., placement back into the parent container or another approved container/tank). e) Headspace gas analysis [typically in support of the Waste lsolotion Pilot Plant (WIPP) Project].

D) DECONTAMINATION/REFURBISHMENT ACTlVITiES

Materials, equip_men_t, and ·waste can be decontaminated (e.g.,Jree release, reduce the radiological levels, orother similar criteria) using a variety of methods .. Equipment can also be repaired and refurbished within the 2706'T faciliiy. Within 2706-T, decontamination of 2706-T structural components may be performed.

Decontamination a.nd refurbishment activi_ti_es at 2706-T are:

a) Vacuum blasting. b) Brushing. c) Abrasive tools. d) Scraping. e) Washing (e.g., chemicals/detergents). I) Immersion. g) Electro-polishing. It) Gulling (i.:_.g., n:)nuva·l by sawi_11g, lu~i.:_l_1 1.:u_l_l)_,_Lg murt: highly radiu_a.clivt: c_unjpuncri_ls u_r ulht:r si_~nilar

Page 2 of 8 forEU_ID 315

methods). i) Rust/paint removal. j) Sand blasting. k) Vacuuming.

E) MAfNTENANCE ACTIVITIES

A variety of preventative and/or repair maintenance activities are performed at 2706-T. Some maintenance activities involve the temporary shut down of the 296-T-7 exhaust stack.

M3in_t_e:i,.an·ce activit_i.es are:

a) Painting. b) Crane maintenance. c) Electroni_c systems fu_nctional chec_~ and repairs [CAMs, personnel contamination monitors (PCMs)]. d) Calibrations. e) Mechanical overhaul and rebuild. I) Bearing replacement. g) Pump and motor alignment.

Maintenance may be performed on:: a) Roll up doors. b) Heat pumps. c) Exhaust fans. d) Transformers. e) Scale systems. I) Wire rope. g) Stack systems. h) Forklifts.

F) WASTE TREATMENT ACTNITIES

2706-T is a Resource Conservation and Recovery Act (RCRA) treabn_cnt and Storage facil_ity permitted by the Washington State Department of Ecology (Ecology).

Treabnent activities are:

a) Macroencapsulation. b) Absorption. c) Neutralization. d) Immobilization. e) Encapsulation. I) Stabilization (solidification, cementation, grouting). g) Compaction. h) Amalgamation. i) Segregation. j) Shredding. k) Venting and drilling. l) Size Reduction.


Materials are recyc_led whenever possibl_e_. Recycled m_a_t_e_rials are: ferrous and non-ferrous metal, light bulbs, aerosol cans, oils, and batteries.

H) STORAGE ACTNITIES

Peg~ 3 of 8 f~r E~_ID 31?

2706-T stores materials (chemicals, or equipment, or.similar materials) to.support operations. Radioactive wastes may be stored uncontainerized or in: a) Containers (boxes, drums, tanker trucks/railcars, or large diameter containers). b) Tanks. c) Sumps and p_ipes.

I) EQUIPMENT, MATERIALS, AND WASTE MOVEMENTACTIVITIES

The movement of materials, equipment and waste is necessary to support operations·and maintenance. _Movemen_t activities _(using a forklift, crane, truck, dolly, personnel) are: a) Receivi,ng wast~ (li_qu_i_d, sol_id, semi-sol_id) for s_t_orage and/or tfeatmerit. b) Movement of waste (liquid, solid, semi-solid) and equipment. c)Movement of liquids, sludges, or other waste from containers and/or tanks via.transfer lines. d) Waste container transfers. e) Placing and storing chemical products in flammable ca)>inets or other approved storage locations. fl Movemen_t of contaminated materia_l.




a) Sweeping (brooms). b) Mopping (squeegees or mops). c) Vacuum_ing. d) Dusting. e) Wiping (sponges, towels). fl Picking up debris. g) Removal of trash.

K) s·u'ilVEILLANCE ACTYVITIES ·- . - --

Surveillance activities involve walking down and inspecting various areas, systems, and components. Surveillances typically _consist of daily, weekly, and monthly inspections of waste containers, tanks, buildings, or similar locations. Surveillances are subject to change (adding, deleting and/or modifying) as operations, maintenance, engineering, and radiological contro·l dictates. Surve{ilances, lnspectioris, and mai_ntenance activities tha_t do n:Ot have the potential to create airborne.contamination ~an-~~il~ within the 2706-T B~ilding when the 296-T-7 exh_a\1St s~ac_~ e1pission sys-tern is shutdown.


a) Container storage areas treatment and storage tanks and ancillary equipment. b) General condition o(build°ing strucru·res. c) Cold wea_ther surveillances (typically, between October I and March 3 l). d) Inspection of equipment. e) Inspection ofHEPAfiltered vacuums. F) Radiological surveys.

2706-T: The 2706-T facility'inclildes the 2706-T building and the 2706-TA Building. The 2706-T Building and the.2706-TA Building make up a single structure and are described briefly here. The 2706-T facility handles low-level waste, mi~ed low level waste, and transuranic (TRU) waste.

The 2706-T Building was.built in l 959 as a low-level radiological decontamination building. The original building was 66 feet long and 5_0 ft wide. The 2706-TA Building was added in 1994/1995 over the concrete paJ un tho west sido of U1e 2706-T. One roll up-Joor ru1d one mru1-door provide access between 2706-T and


2706-TA Building. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-T Building operations area. Waste handling and decontamination operational areas of the 2706-T Building are open and unobstructed. The 2706-T building is a pre-engineered metal building. The foundation is concre_te slab on grade throughout. The 2706-T Building includes two pits, one for decontamination and treatment cif motor vehicles and other large equipment, and one for rail car decontamination and treatment. These pits can also be used to support collection of liquids from waste handling activities.

CURRENT OPERATIONS IN 2706-TBUILDING

Include waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, d_econtam_inatio"n/refu_rbishment, ~aintenance, recycling, storage, housekeeping,.surveillance, and movement activities. One egress door leads directly to the exterior of2706-T Building. Other doors lead directly to the non-ventilated lean-to on the north side, and an air lock provides access to the 2706-T A Building operations area. The railway and auto pits have metal grating and some wooden covers to prevent falls into the pits. An epoxy floor sealant had been applied to all operational area floors. To support these operations, greenhouses are used as necessary in 2706-T. Greenhouses are temporary or semi-pennaoent radioactive.material confinement structures, and can be used for contamination control, If used, greenhouses shall exhaustto the areas ventilated by the 296-T-7 ventilation system.

The atmosphere clean-up train {ACT-I) system, sprinkler system riser room, and electrical room are located in the s_outh lean-to (non-ventilated).

2706-TA: The 2706-TA Building is an addition to the 2706-T Building installed in the 1990s as an add-on over the concrete stornge pad located westofthe building. The 2706-TA Building is approximately 54 feet long, 45 ft wide, and 23 feet high. There are two roll up doors located at the west end of the building. The 2706-T A Building has steel primary and secondary structural elements and corrugated sheet metal exterior siding and roofing panels. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-TA Building operations area. The floor is concrete slab on grade. An epoxy floor sealant had been applied to all operational area floors. Waste handling and decontamination operntional areas of the 2706-TA Building are open and unobstructed.


Include waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycl_ing, storage, ~oU.Sekeeping, survei-ilance, and movement activities. To support waste activities, greenhouses are used if necessary. Greenhouses are temporary or semipermanent radioactive material confinement structures, and can be used for contamination control. When used, greenhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation system.

Attached to the south side of2706-TA Building is a lean-to made up of two rooms. The larger room houses the new ACT-2 HEPA filter system, which serves the operational areas. The ACT-! and ACT-2 systems exhaust through the 296-T-7 stack. The second room houses electronic controllers and electrical switchgear supporting operations.

Emissions frcim these activities are exhausted through 296-T-7, except for emissions resulting from vented TRU containers stored ivithin the facility, which may be released to the 200 Area diffuse and fugitive emission unit when the ventilation system is not in operation.

3) The PTE for this project as determined under WAC 246-247-030(21)(a-e) [as specified in the appiication) is 7 .50E-02 mrem/year: Approved are the associated potential release rates (Curies/year) of:

DE-0 1.90E-05 Contained WAC 246'247-030(21 )(a) Any radionuclide on the chart of the nuclides could be encountered. A small contribution froll'l the gaseous radionudides may be encountered. The radionuclides within the facility are controlled by the llcense'e in terms of dose-equivalent (DE} Curies. A conservative PTE tracking method tor the demonstration of compliance to the licensed PTE limits is provided in the conditions of the llcense. "Containecr means "withln typi_cal TRU waste containers for which a release fraction of 2E-09 has been detennined to be appropriate."


DE-0 2.9_0E--03 Liquid/Particulate S_olid WAC 246-247-030(21 )(a) Any radionuclide on the chart of lhe nuclides could be encountered. A small contribution from the gaseous radionucBdes may be encountered. The radlonucHdes within the facility are known to and controlled by the licensee In terms of doseequlvalent (DE) Curles. A conservative PTE tracking melhOd for the demonstraUon of compliance to the licensed PTE limits Is provided In the conclltlons of the license. This amount of DE curies Is permitted within the facility uncontained in TRU waste containers as liquid/particulate for which a release h'action or 1 E.oJ Is appropriate.

H-3 1.50E+01 Gas WAC 246-247-030(21 Xa)

Rn - 219 2.00E-01 Gas WAC 246-247-030(21 Xa)

Rn -220 2.BOE+01 Gas WAC 246-247-030(21 Xa)

Rn -222 1.47E+OO Gas WAC 246-247-030(21)(a)

The rndioact_ive isotopes identified for this emission unit are (no quantities specified): H - 3 Rn - 219 Rn - 2·20 Rn -222

The potential release rates described in this C_ondition were used to determine control technologies a:na monitoring requirements for this approval. DOE must notifiy 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 10% of the potential TEDE to the MEI, or greater than 25% of the TEDE to the MEI after controls. (WAC 246-247-110(9)) DOE m_ust notify t_he Department of nny changes to potential release rates as required by state or federal regulations incliiding changes that would constitute a significant modification to the Air Operating Permit linder 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 ofnotification, DOE will provide the Department with advance written notice by letter or electronic mail but not solely by copies of documents.

4) USE OF AS LOW AS REASONALBE ATAINABLE PRINCIPLE

All activities involving potentially airborne.radioactive materials in 2706-T shall be conducted in accordance with the ALARA principle.



Waste Contained in Typical TRU Waste Containers: PTE < 9490 DE Ci/year• 2E-09. Compliance: maintain annual total of DE Ci• 2E-09 below limit[Dose contribution of this activity to license limit estimated assuming each DE Ci is 241-Am].

Venting of Waste Uncontained in Typical TRU waste Contai_ners: PTE < 94_90 DE Ci/year• l_E-03 • 5.7E-05. Cmnpliance: main_tain annual total of DE Ci • I E--03 • 5. 7E-05 vented below limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 241-Am].

Torch cutting:.PTE< 9E--04 mrem/year. Compliance: Maintain the product of inches cut and contamination level to: < 8.8 E+09 in-dpm/100 sq.cm beta/gamma and< 8.8E+6 dpm/100 sq.cm alpha. (Note: The release at the cut is assumed gaseous due to high cutting temperature, but it is also assumed that any gases thus formed will rec_ondense into a particulate form by the time they reac_h the filters, and be subject to the standard removal efficiency of the HEPA filter.) [Dose contribution of this activity to license limit estimated assuming all alpha is 24 laAm, all beta/gamma is 137-Cs.]

Gases in Waste Contained in Typical TRU Waste C_ontainers: PTE < 7E--04_ mrem/year. Compliance - main_tain: tritium PTE below 15 Ci/yr; 219-Rn PTE below 0.2 Ci/yr; 220-Rn PTE below 28 Ci/yr; 222-Rn PTE below 1.47 Ci/year. These limits apply to process-<:nhanced radionuclides only, per (WAC 246-247-020(4)). [Dose contribution of this activity to license limit estimated using isotope-specific dose conversions factors.]

Pago 6 of 8 for.EU_IO 315

Other Processes: PTE < 4.9 E-02 mrem/year. Compliance: maintain total facility DE Ci/year (exclusive ofTRU included above) • I E-03 below 2.9 • I E-03, or maintain the sum Ci(alpha) • I E-03 • 17 + Ci(beta/gamma) • IE-03 • 0.3 I below 4. 9 E-02 mrem/year. [Dose contribution of this activity's PTE to license limit estimated assuming DE Curies are.241-Am].

Residual Contamination: PTE < 7.1 E-03 rrirem/year. Accounts for residual contamination present in facility if posting is Contamination Area or below. Greater contamination levels result from other processes, and are accounted for in the PTE(s) associated with them. No specific compliance demonstration is necessary beyond the compliance with posting requirements. [Dose contribution of this activity to license limit estimated assuming all alpha is 241-Am, all beta/gamma is 137-Cs.] -

The facility shall document and implement a program of inspection and maintenance t_o ensure the continuous integrity of contamination fixative used within the facility.

That the total PTE does not exceed licensed limits shall be routinely verified, and documentation of that verification shall be maintained.


The ventilation system shall be in operation when activities involving radioact_ive or contaminated materials are performed within the ventilated space. The ventilation system shall be in operation if any part of the 2706-T Facility is posted as a high contamination area, or higher. Storage/movement of ventilated (NucFil or vent clip) TRU contai_ners is pennined when the ventilation system is not operating.


Record sampling shall be continuous whenever the ventil_ation system is operating. Samples shall be collected monthly, for periods in which the ventilation system has operated. Samples shall be composited and analyzed quarterly, if a sample was collected during that quarter. Licensee shall document minimum detectable concentrations for the stack emissions measurements. (WAC 246-247-075 (3, 8, 9))


All roll up d_oors providing access to the interior of the 2706-T and/or 2706-T A buildings from the ambient atmosphere shall remain closed whenever the venti"lation system is in operation as required by condition 6.

9) ALPHA/BET A MDAs and MDCs REQUIRED FOR ANAL YT!CAL LABORATORIES

The following alpha/beta MDA and MDC limits shall be used by the analytical laboratory when analyzing the s.nnplcs collected.

The Nominal Sample Volume for a single.sample.filter of20,000 ftAJ (5.7E+08 mL) Gross Alpha (c MDA (a) 5.0E-06 µCi MDC (b) 8.8E-15 µCi/mL Gross Bern (c MDA (a) 1.0E-05 µCi MDC (b) l.8E-14 µCi/mL Silver (ag) zeolite (d) MDA (a) l.9E-05 µCi (as Ru-106) MDC (b) 3.4E-14 µCi/mL (as Ru-106)

The Nominal Sample Volume for a quarterly composite sample of 262,000 ftAJ (7.4E+09 mL) Sr-90 MDA (a) 1.4E-05 µCi MDC (b} l.9E-l5 µCi/mL Gamma Energy Analysis (e MDA (a) l.4E-05 µCi (as Cs-137) MDC (b) L9E-15 µCi/mL (as Cs-137) Isotopic Pu (i.e. Pu-238, Pu-239/240) Pu-241 Am-24!

MDA (a) LSE-06 µCi MDA (a) 7.4E-05 µCi MDA (a} l.4E-06 µCi

MDA = minimum detectable activity; MDC= minimum detectable concentration.

MDC (b) 2.0E-16 µCi/ml MDC (b) I.0E-14 µCi/mL MDC (b) l.9E-16 µCi/mL

(a)\ctual MD As derived from sample analyses shall be as low as reasonably achievable and shall not exceed the values specified in Table l provide_d the sample meets or exceeds its respective nominal volume. The target MDA$ in Table I are derived from multiplying the MDCs in Table I hy the respective nominal sample volumes


shown in the table.

(b)\ctual MDCs derived froni sample analysis shall be as low as reasonably attainable and shall not exceed the values specified in the Table I provided the sample meets or exceeds its respective nominal volume. The target MDCs in Table I are 10% of the concentration values in Table 2 of40 CFR 61, Appendix E.

( c GAB emission data are often used in dose calculations to substitute for the presumed presence of the usually mo_st prevalent alpha- and beta-emitting rad.i!)nuclid.es having tJ:i.e highes.t dose fa.ct.ors, which, depending on facility s<iiirce terni, for alpha-emitters has m·ostly usu·ally beeri Pu-239/240, but occasionallyAm-241, ana fo.r beta-emitters, Sr-90, but occasionally Cs-137.

( d),ilver zeolite analysis shall be designed to primarily identify I-129.

(e AIJ pos.i_tive gantl)la-e_nergy analysis (GEA) results shaH .be reported, with the exception of short lived progeny ofRn-222 and Rn-220. At a inininium. GEA shall be designed to identify peaks ofCo-60, Ru-106, Sb-125, Cs-134, Cs-137, Eu-152, Eu-154, Eu-155, and Pa-231.


In Re The Approval of:

STATE OF WASHINGTON DEPARTMENT OF HEALTH

ENVIRONMENT AL HEALTH. PROGRAMS OFFICE OF RADIATION PROTECTION

Docket No: 28-DA Y DRAFT FOR NOTICE OF CONSTRUCTION (NOC) 1033

REQUEST FOR ADJUDICATIVE PRO_CEEDING

Approval No: AIR 16-1209

!HE STATE OF WASHINGTON TO: Mr. Doug Sho'op, Manager United States Department of Energy Richland Operations Office P.O. Box 550, MSIN: AS-14 Richland, Washington 99352

lfyou wish 10 request an adjudicative p_roc_ee~_i_ng, you or your attorney must COMPLETE AND FILE THIS FORM OR A DOCUMENT PROVIDING SUBSTANTIALLY THE SAME INFORMATION WITH THE DEPARTMENT OF HEAL TH ADJUDJCA TIVE SER VICE UNIT WITHIN TWENTY-EIGHT (28) DAYS OF YOUR RECEIPT of this Request for Adjudicative Proceeding form and a copy of the Office of Radiation Protection's·approval, AIR 16-1209.

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

Department of Health Adjudicative Service Unit 310 Israel Road S.E. P.O. Box 47879 Olyriipia, WA 98504-7879

With .your application, you m_ust i_nclude a copy of the Office of Radiation Protection's approval.

FILING SHALL NOT BE DEEMED COMPLETE UNTIL THE ADJUDICATIVE SERVICE UNIT ACTUALLY RECEIVES YOUR APPLICATION.

YOU HA VE THE RIGHT TO a formal hearing in this matter conducted pursuant to R_evi_seq Code of Washington (RCW) 43.70.115, Chapter 34.05 RCW, and Chapter 246-10 of the Washington Adm_inistrative Code (WAC). Alternatively, you may waive the formal hearing and submit a written statement and supporting documents setting ~ut your position, yo_ur defenses, and a;,"y -~itigating cfrcumstances that you wish to bring to the Department's attention. You h_ave the right to be represented by an attorney at your own expense.

I.

[ ] I WILL BE represented by an attorney. His/her name, address, and phone number are:

Name:

Address:

Phone:

Request for Adjudicative Proceeding Page I of4

[ ) I WI.LL NOT B.E r,eprese.nted by an attorney.

If afte_r silbmilling this request, jlou obtain attorney representation or change attorneys, you !!!.JlJ1. notify the Adjudicative Service UniL

n. i DO NOT w.aive. my right to a fo.rrnal he.a!ing.

] I DO waive my right to a formal hearing. I unde~d that if I waive my right to a formal hearing. the Depamnent may decide this matter solely with reference to information in the Depamnent's possession and to such written statements and supporting documents as I may have submitted. ·

If you choose to waive your right to a formal hearing, please complete the following:

( I AM NOT submitting documents to the Departnierit in support ofniy position.

I AM submitting a swam statement and/or other documents to theDepartment in support of my position. Instructions - Please indicate your responses below:

If you are submitting documents to the Depamnent, please list and briefly identify all such documents.in. the space provided below and.on any additional sheet that may be necessary.

Requ~I for Adjudicative Proceeding Page 2 of 4

Ill.

ADMISSION/DENIAL OF.CONDITIONS OR LIMITATIONS

The Office of Radiation Protection's approval AIR 16-1209, dated December 14, 2016, contains conditions and limitations set out as numbered paragraphs. In the space below you must indicate, in good faith, whether you admit, or do not contest, or deny the conditions or limitations. Conditions or limitations denied or not contested may later be admined. Conditions or limitations admitted or not contested shall be conclusively deemed true for funher proceedings.

Instructions: I admit, deny, cir do not contest the conditioiis cir limitations as fo_I_lows (fill in the appropriate paragraph num_ber):

Paragraph __

P11ragraph __

Paragraph ____ _

Paragraph __

Paragraph __

Paragraph __

Paragraph __

Paragrap_h __

Paragraph __

Deny

[ l Do Not Contest

Please anach any additional sheets that may be necessary to respond to all allegations.

If you have chosen not to waive your rights to a formal hearing, please state all grounds for contesting this mane_i in the space provided below and on any additional sheets that may be itece·ssary.

Rec/uest for Adjudicative Proceeding Page 3 of4

IV.

·You have the right to an interpreter; appointed at no cost, if you are a hearing impaired person or limited English speaking person. If any wimess for you is a hearing impaired person or a limited English speaking person, an interpreter will be appointed at your expense.

l [DO]/ [DO NOT] (circle one) request an interpreter be appointed. !fan interpreter is requested, please indicate the person or persons for whom an interpreter is required and their primary language, and/or whether they are hearing impaired. ·

IF you FAIL TO FILE YOUR A_PPLICATION IN A TIMELY MANNER, OR If'. YOU FILE YOUR APPLICA T!ON TIMELY BUT FAIL TO APPEAR AT ANY SCHEDULED SETTLEMENT CONFERENCE, PREHEARING CONFERENCE, OR HEARING WiTHOUT LEAVE To Do so, rnE DEPARTMENT MAY DEciDi:: tH1s MA mR \v1Tttou'r YouR YOUR PARTICIPATION AND WITHOUT FU.RTHER NOTICE TO YOU.

DATED this. ____ day of _________ _, ___ _

Party

Pany's Representative (if any)

WSBA #: _________ _

Request for Adjudicative Proceeding Page4 of4

8

STATE OF WASHINGTON

DEPARTMENT OF HEALTH OFFICE OF RADIATION PROTECTION

109 Bradley Blvd., $u_itc 201 • Rich~a"'nd,1W.1s1Jingtnn 99352

TDD Relay Service: 1-800-833-6388

January 24, 2017

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

Re: Final Approval of Notice of Construction (NOC) I 033

Mr. Shoop:

AIR 17-115 NOC 1033

Pursuant to Chapter 246-247 of the Washington Administrative Code (WAC), youfrevision -request i_s approved, as negotiated, ac:cording to the enclosaj emission unit (EU) specific license for: · ·

Operation of 2706-T Building (Replaces NOC 920) (EU 315; NOC 1033)

The conditions, controls, 111onit_oring requ_i_r_ements, and li111itations of this license must be observed in order for you to be in compliance with WAC 246°24 7. Failure to meet any provision of this license may result in the revocation of approval, the issuance ofNotfoes of Violation, or other enforcement.actions under WAC 246-247-100.

If you h_ave any ques~ons regarding this approval, please contact Tom Frazier at Thomas.Frazierui)doh.wa.gov or, by phone, at (509) 946-0774.

T9)_14Jit John Martell, Maiuiger Radioactive Air Emissions Section

Enclosure: NOC 1033 for EU 315

cc: (see.next page)

Public Health - ,\lwc1ys \Vorking r'or ;1 S,1for ;rnd l·lc,dlhier \Vashingion

0

Mr.Doug Shoop January 24, 2017 Page 2 of2

cc: Ruth Allen, WRPS Matthew Barn_ett; PNNL Lily~ Bauder, Ecology Shawna Beiven, WDOH Lucinda Bornelilan, WRPS Lee Bostic, BNI Frank Carleo, CHPRC Cliff Clark, USDOE-RL Jack Donnelly, WRPS Dennis Faulk, EPA Eric Faust, USDOE-RL Thoi:nas Frazier, WDOH Gary Fritz, MSA Philip Gent, Ecology Reed Kaldor, MSA Paul Karschnia, CHPRC Jim McAuley, EPA John Schmidt, WDOH JeffVoogd, WRPS Envirol)Il).e!ltal Portal RAES Tracking: Line 16-204; EU 315; NOC 1033

AIR 17-115

Emission Unit iD: 3 is

200W P-296T007-001 296-T-7 This is a MlNOR, ACTIVE-LY Vffllila1ed emission unit.

T· PLAN} C0:MPLEX


Stac_k He_igh_t: 28_.oo ft. 8.53m. Stack Diameter 2.30 ft.

Average Stack Effluent Temperature: 78 degrees l'ahrenh_eit. 26 degrees Celsius.

Average Siack ExhaustVelocity: sl.oo ft/second. 24.69 m/second. AbatementTechnology ALARACT WAC 246-247-040(4) state only enforceable: WAC 246-247-010(4), 040(5), 060(5)

Zone or Areai Abatement Technology

Pr_efil_t_er

HEPA

Fllll

Required # or Units

0.70m.

_ Add_i_tioo_al Description

To operate per Condi_tions and Limitations of the license.

Monitoring Req·uirements state enfora,able: WAC 246-247-040(5), 060(5), and federally enforceable: 40 CFR 61 subpart H


<10 C_FR 6L93(c)(4)(e) & WAC 246-247-075(3)

Monitoring and Testing Requ_i_remt:nts

40 CTR 61, Appendix B, Method.I 14(3)

Sampling Requirements Record Samp_le Addltlonal Roqulremen18

Radlonudides Requiring Measurement

TOTAL ALPHA TOTAL BETA

Sampl_lng Frequency

See special conditions.

Ad_dition-~1. m_onl~iiri9 o·r sa"nipllrlg ·requirements estabUshecl by lhts License wlll be listed tn the Conditions and Limitations section, Ir appficab_le.

· Operational Status ·Activiti_es ~t the 2706-T Facility involve waste management operations in support of decontamination and decomissioning opcraiiom 81 the Hanford Site.

This Emission Unit has 1 active Notice(sl of Construction.

Project Titlfl

Operation of2706-T Building (Replaces NOC 920)

Approval#

A_IR 17-115 Date Approved NOC_io

1/24/2017 103_3

Condition!! (state only enforceable: WAC 246-247--040(5), 060(5) If not specified) t) The total abated emission liinit for this Notice or"Construction is limited to 7.S0E-03 mrem/year to the

Maximally Exposed Individual (WAC 246-24 i-040(5)). ·

2) This approval applies only to those activities described below. No additio_nal ,activi)ies 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. The approved activities are limited to:


Pac_kaging and_ repackagi:ng activities are perfonned for waste generated at 2706-T as well as for onsite and offsite generators. The repackaging of was_te supports waste acceptance criteria for other Treatment Storage and Disposal (TSD) facilities. For example, prohibited items from waste packages are removed and either staged for later handling or repackaging using remote or manual methods.

Pac_kagi_ng and repackaging activities are:


Paget ol 8 lor EU_ID 315

I

c) Removing prohibited items. d) Composit_ing/aggregating solids or liquids. e) Ad.ding absorbent. f) Size reductio:n [e.g., cutti_ng_{jaws, saws, torches)], bending, folding, crushing {e.g., drum crusher), shredding, compacting, o:r simi_lar methods that do not have a higher extent of disruption]. g) Void filling. h) Pressure relief/release (e.g., aerosol cans, gas cylinders, drums, or other si111ilar con_tainers).




a) Physical observation. b) Nondestructive examination (NDE). c) Nondestructive assay (NDA). d) Chemical fi_e_l_d scree_ning. e) Radiological surveys. f) Radiological samples. g) Headspace gas sampling. h) Chemical sampling.

C) SAMPLING ACTIVITIES

Sampling of waste gene_rated by operations or by other onsite or offsite generators is performed. The purpose of sampl_ing is to con_fi_rm process knowledge, characterize waste, support verification, and determine land disposal requirements as applicable.


· a) Field screening [e.g., pH paper, oxidizer, volatile organic analyses (VOAs), po_lychlo_rin_ated biphenyls (PCBs), or similar screening parameters]. b) Obtaining a sample for analysis [e.g., grab, composite, composite liquid waste sampler (COLIWASA), o_r other similar sampling techniques]. c) Shipping/transferring iiie samples to an approved laboratory for analysis. d) Dispos_i_t_i_on of sample returns (e.g., placement back into the parent container or another.approved container/tank). e) Headspace gas analysis [typ_i_cally in s_upport of the Waste Isolation Pilot Plant (WIPP) Project].

D) DECONTAMINATION/REFURBISHMENT ACTIVITIE_S

Materials, equipment, and waste can be decontaminated (e.g., free re_Ieas,:, redt,1ce the radi?logical levels, or other similar criteria) using a variety of methods. Equipment can also be repaired arid refurbished withi_n the 2706-T fac_i_l_ity. Within 2706-T, decontamination of2706-T structural components may be perf<inned.

Decontamination and reftirbishrri-ent activiti_es at 2706-T are:

a) Vacuum blasting. ·b) Brushing. c) Abrasive tools. d) Scraping. e) Washing (e.g., chemicals/detergents). f) Immersion. g) Electro-polishing. h) Cutting (e.g., removal by sawing, torch cutting more highly radioactive c0_1nponents or other similar

Page 2 of B for EU_ID 315

metho<!5). i) Rust/pain.I re_moval. j) Sand blasting. k) Vacuuming.

E) MAINTENANCE ACTIVITIES

A variety of preventative and/or repair maintenance activitie_s are perfonned at 2706-T. Some maintenance act_ivities involve the temporary shut down of the 296c T-7 exhaust. sta<:k_.

Mairiteria.nce activities are:

a) Painting. b) Crane maintenance. c) Electronic systems functional checks arid repai.rs (CA_Ms, personnel contamination monitors(PCMs)J. d) Calibrations. e) ]v!echanical overhaul and rebuild. f) Bearing re!)lacement. g) Piinip arid rnotor alignment.

Maintenance may be perfornied. o_n: a) Roll up doors. b) Heat pumps. c) Exhaust fans. d) Transfonners. e) Sca_l_e systems. f) Wire rope. g) Stack systems. h) Forklifts.

F) WASTE TREATMENT ACTIVITIES

2706-T is a Resource Conservation and Recovery Act (RCRA) treatm~nt and Storage facility pennitied by the W~h_i_ngton State Department of Ecology (Ecology).

Trea:tmeftt a~tiYities ll!~=

a) Macroencapsulation. b) Absorption. c) Neutralization. d) Immobilization. e) Encapsulation. f) Stabilization (solidification, cemerimti<iri, grouting). g) Compaction. h) Am_~lgarnation. i) Segregation. j) Shredding. k) Venting and drilling. I) .Size Reduction.


Materials are recycled wh~never possible. Recycled materials are: ferrous and non-ferrous metal, light bulbs, aerosol cans, oils, _ai:i~ batt~ri~.

H) STORAGE ACTIVITIES


2706-T stores materials (chemicals, or equ_ipment, or similar materials) to support operations. Radioactive wastes may be stored uncontainerized or ii:i,_: a) Containers (boxes, drums, tanker trucks/railcars, or large d_iarrieter containers). b) Tanks. c) Sumps and pipes.

I) EQUIPMENT, MATERIALS, AND WASTE MOVEMENT ACTIVITIES

The movement of materials, equipment and waste is necessary to support operations and maintenance. Movement activities (using a forklift, crane, truck, dolly, pe_rsonnel) are: a) Receiving waste (liquid, solid, semi-solid ) for storage and/o_r treatment. b) Movement of waste (liquid, solid, semi-solid) and equipment. c) Movement ofliquids, sludges, or other waste from containers and/or tanks via transfer iines. d) Waste container transfers. e) Placing and storing c_hemicaJ products in flammable cabinets or other approved storage locations. f) Movement of contaminated material.


H_ousekeeping activities involve maintaining 2706-T in a clean and orderly condition.


a) Sweeping (brooms). b) Mopping {squeegees or mops). c) Vacuuming. d) Dusting. e) Wiping (sponges, towels). f) Picking up debris. g) Rem_ov~I of trash.

K) SURVEILLANCEACTIVITIES

Surveillance activities in\•olve walking down and inspecting various areas, systems, and components. Surveillances typically consist of daily, weekly, and monthly inspections of waste containers, tanks, buildings, or similar locations. Surveillances are subject to change (adding, deleting and/or modifying) as operations, maintenance, engineering, and radiological control dictates. Surveillances, inspections, and maintenance activities that do not have the potential to create airborne cont11111ination can occur within the 2706-T Building when the 2°96-T-7 exhaust stack emission system is shutdown_.

The folJowing surveillances arc performed at 2706'T:

a) Container storage areas treatment and storage tanks and ancillary equipment. b) General condition oftiuilding structures. c) Cold weather surveillances (typically, bet_ween Oc_tober I and March 31 ). d) Inspection of equipment. e) Inspection of HEPA filtered vacuums. F) Radiological surveys.

2706-T: The 2706-T facility inc_l_udes the 2706-T building and the 2706-TA Building. The 2706-T Building and the 2706-TA Building make up a single structure and are described briefly here. The 2706-T facility handles low-level waste, mixed l~w level waste, a·nd transuranic (TRU) waste.

The 2_706-T Building was built in 1959 as a low-level radiological deconta!Tl_iriation building. The original ouilding was 66 f~t long and 50 ft wide. The 2706-TA Building was added in 1994/1995 over the concrete pad on the west si_de of the 2706-T. One rollup-door and one man-door provide access between 2706-T and

Page 4 ol 8 lor EU~IO 3·15

2706-T A Building. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-T Building operations area. Waste handling and decontamination operational areas of the 2706'T Building are open and unobstructed. The 2706-T building is a pre-engineered metal building. The foundation is concrete slab on grade throunhout. The 2706-T Building includes two pits, one for decontamination and treatment of motor vehicles and other large equipment, and one for rail car decontamination and treatment. These pits can also be used to support collection of liquids from waste handling activities.


Include waste sampling, packaging and repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement activities. One egress door leads directly to the exterior of2706-T Building. Other doors lead directly to the non-ventilated lean-to on the north side, and an air lock provides access to the 2706-TA Building operations area. The railway and auto pits have metal grating and some wooden covers to prevent falls into the pits. An epoxy floor sealan_t had been appl\e<l to ~ii ope_rational area floors. To support these operations, greenhouses are used as necessary in 270_6-T. Greenhouses are temporary or se_mi-perman·ent radioact_ive mall,rial confinement structures, and can be used for contamination control. If used, greenhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation system.

The atmosphere clean-up train {ACT-I) system, sprinkler system riser room, and electrical room are located in the south lean-to {non-ventilated).

2706-TA: The 2706-TA Building is an addition to the 2706-T Bu_i14i_ng installed in the i"990s as an add-on over the concrete storage pad located west of the buildin·g. The 2706-TA Building is approximately 54 feet iong, 45 ft wide, and 23 feet high. There are two rollup docirs located at the west end of the building. The 2706-TA Building has steel primary and secondary structural elements and corrugated sheet metal exterior siding and roofing panels. Three heat pumps provide heating, ventilation, and air conditioning for the 2706-TA Building operations area. The floor is concrete slab on grade. An epoxy floor sealant had been applied to all operational area fl_oors. Waste handling and decontamination operational areas of the 2706-TA Building are open and unobstruct_ed.


·include waste sampling;packaging and repackaging, head-gas sampling, managing waste containers, decontamination/refurbishment, maintenance, recycling, storage, housekeeping, surveillance, and movement activities. To support waste activities, greenhouses are used if necessary. Greenhouses are temporary or semipermanent radioactive material confinement structures, and can be used for contamination control. When used, gree_nhouses shall exhaust to the areas ventilated by the 296-T-7 ventilation system.

Anached to the south si_de of2706-TA Buil4ing is a le_an-to made up of two rooms. The larger room houses the new ACT-2 HEPA filter system, which serves the ope_rational areas. The ACT-I an_d _ACT-2 syste_ms exhaust through the 296-T07 stack. The second room houses electronic controllers and electrical switchgear supporting operations.

Emissions from these activities are exhausted through 296-T-7, except for emissions resulting from vented TRU containers stored within the facility, which may be released to the 200 Area diffuse and fugitive emission unit when the ventilation system is not in operation.

3) The PTE for this project as determined under WAC 246-247-030(2l)(a-e) [as specified in the application] is 7.50E-02 mrem/year. Approved are the associated potential release rates {Curies/year) of:

DE-0 t.90E-05 Contained 'l':/AC 246-247-030(21 )(a) Any radionuclide on the ci'lart of the nuclides could be encountered. A Small contribution from the gaseous radlonudlcles may be encoun'tered. The radlonu"ctldeS within thEI faclllty era contioUed bY thB HienSee in _termS of dosiMquival8nt (OE) Curies. A conservali~ PTE traddrig fTlelhod far the dem0nStralio"n Of COl11p!iancit to the llc_ensed PTE JJmlt, is provided In the conditions of the llce11se. ~cciritalried" ITleins "within typical TRU waste COntainBra for which e release fraction of 2E-09 ties b·een detBrmlned to b8 appf'Op-rlate.· · · ·


DE - 0 2.90E-03 Liquid/Particulate Solid WAC 246-247-030(21)(8) Any radionuclide on the Chart of the nuclldes could be encountered, A 61Tlall contribution from lhe gaseous radlonuctlcles may be encountered. The radlonuclldes within the faclllty ere known tlJ and controlled by the llce-nsee In terms of doseequivalent (OE) Curies. A ccnservative PTE tracking method for the· dem-onstration Of compllance to lhe Hcensod PTE limits Is provided In the conditions of the license. This amount of OE curies 1s·pemt/tte<t"wlU1in the facJ/lry unconralned In TRU waste ccntainera es lfquld/particulate forwh\eh a rete·ase fracllol'I of 1E-03 is appropriate.

H-3 1.50E+01 Gas WAC 246-247-030(21)(8)

Rn· 219 2.00E-01 Gas WAC 246-247-030(21)(8)

Rn-220 2.80E+01 Gas WAC 24S-247-030(21)(a)

Rn- 222 1.47E+OO Gas WAC 246-247-030(21)(8)

The radioactive.isotopes identified for this emission uni_t are (no quantities specified): H - 3 Rn· 219 Rn· 220 Rn -222

The potential 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 must notify the Department of any changes to a NE.SHAP 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 25% of the TEDE to the MEI after controls. (WAC 246-247-110(9)) DOE m_us_t notify the Department of any changes to potential release rates as required by state or federal regulations includi_ng changes that would constitute a significant modification to the Ai_r Operating Permit under WAC 173-401-725( 4 ). Notice will be provided according to the particular regulation under wh_ich notification is required. If the applicable regulation(s) does not address manner and type of notification, 00.E wi{! provide the Department with advance written notice by letter or electronic mail but not solely by copies of doc_uments.

4) USE OF AS LOW AS REA_SONALBE ATAINABLE PRINCIPLE

· · · All activities involving potentially airborne racii_oactive materials in 2706-T shall be conducted in accordance with the ALARA principle.

5) PTE TRACKING IN AIR SPACE VENTILATED BY296-T-7


Waste Contained in Typical TRU Waste Containers: PTE < 9490 DE Ci/year• 2E-09. Compliance: maintain annual total ofDE·Ci • 2E-09 below limit. [Dose contribution of this activity to license limit estimated assuming each DE Ci is 241-Am].

Venting of Waste Uncontained in Typical TRU waste Containers: PTE < 9490 DE Ci/year• 1 E-0.3 • 5.7E-05. Compliance: maintain annual total of DE Ci• IE-03 • 5.7E-05 vented below limit. [Dose contribution of this activity to license limit estimate_d assuming each DE Ci is 241-Am].

Torch cutting: PTE< 9E-04 mrem/year. Compliance: Maintain the product of inches cut and contamination level to:< 8.8 E+09 in-<lpm/100 sq.cm beta/gamma and< 8.8E+6 dpm/100 sq.cm alpha. (Note: The release at the cut is assumed gaseous due to high cutting temperature, but it is also assumed that any gases thus formed will recondense into a particulate form by the time they reach the tilters, an_d be s_ubject to the standard removal efficiency of the HEPA filter.) [Dose contribution of this activity to license limit est_imated assuming all alpha is 241-Am, all beta/gamma is 137-Cs.)

Gases in Waste Contained in Typical TRU Waste Container's: PTE < 7E-04 mrem/year. Compliance - maintain: tritium PTE below 15 Ci/yr; 219-Rn PTE below 0.2 Ci/yr; 220-Rn PTE below 28 Ci/yr; 222-Rn PTE below 1.4 7 Ci/year. These liniits apply to process-enhanced radionuclides only, per (WAC 246-247-020(4)) .. [Dose contribution of this activity to license limit estimated using isotope-specific dose conversions factors.]

Paga 6 of B for EU_ID 315

Other Processes: PTE < 4.9 E-02 mrem/year. Compliance: maintain total facility DE Ci/year (~xdus_ive ofTRU iticltided above)• I E-03 below 2.9 • I E-03, or maintain the sum Ci(alpha) • I E-03 • 17 + Ci(beta/gamma) • IE-03 • 0.31 below 4.9 E~2 mrem/year. [Dose contribution of this activity's PTE to license limit estimated assuming DE Curies are 241-Am].

Residual Contamination: PTE < 7. I E-03 mrem/year. Ac_counts for residual contamination present in facility if posting is Contamination Area or below. Greater co·ntamination levels result from other processes, and are accounted for in the PTE(s) associated with them. No specific compliance demonstrat_i_on is n~cessary beyond the compliance with posting requirements. [Dose contribution of this activity to license limit estimated assumi_ng all alpha i_s 241-Am, a_ll beta/gamma is 137-Cs.]

The facility shall document ai:id impleQ1ent a program of inspection and maintenance to ensure the continuous integrity of contamination fixative used with_in the facility.

That the total PTE does not exceed licensed limits shall be routi_nely verified, and documentation of that verification shall be maintained.

6) CONDITIONS REQUlRING OPERATION OF VENTILATION SYSTEM

The ventilation system shall be in operation when activities involving radioactive or contaminated materials are performed within the ventilated space. The ventilation system shall be in operation if any pan of the 2706-T Facility is posted as a high contamination area, or higher. Storage/movement of ventilated (NucFil or vent clip) TRU containers is permitted when the ven_tilation system is not operating.

7) CONDITIONS REQUIRfNG CONTfNUOUS RECORD SAMPLfNG

Record sampling shall be continuous whenever the vent_ii_ati_on system is operating. Samples shall he collected monthly, for periods in which the ventilation system has operated. S_arnples shall be composited and analyzed quarterly, if a sample was collected during that quarter. Licensee shall docu111ent mi~im_um detectable concenrrations for the stack emissions measurements. (WAC 246-247-075 (3, 8, 9))


All roH up doors providing access ta the interior of the 2706-T and/or 2706-TA buildings from the ambien_t atmosphere s_hall remain closed whenever the ventilation system is in operation as required by condi_tion 6.

9) ALPHNBETA MDAs and MDCs REQUIRED FOR ANALYTICAL LABO RA TORIES

The following alpha/beta MDA and MDC limits shall be used by the analytical laboratory when analyzing the samples collected. ·

The Nominal Sample Volume for a si_ggle sample fi_lter of20,000 ft"3 (5.7E+o8 rnL) Grass Alpha (c M_DA (a) S.0E-06 µCi MDC (b) 8.8E-15 µCi/mL Grass Beta(c MDA (a) I.OE-OS µC·i MDC (b) 1.SE-14 µCi/mL Silver (ag) zeolite (d) MDA (a) I .9E-OS µCi (as Ru-106) MDC (b) 3.4E-14 µCi/rnL (as Ru-106)

The Nominal Sample Volume for a quarterly composite sample of262,000 ft"3 (7.4E+09 mJ,) Sr-90 MDA (a) 1.4E-0S µCi MDC (b) 1.9E-15 µCi/mL Gamma Energy Analysis (e MDA (a) l.4E-05 µCi (as Cs-137) MDC (b) 1.9E-15 µCi/mL (as Cs-137) Isotopic Pu (i.e. Pu-238, Pu-239/240) Pu-241 Am-241

MDA (a) I.SE-06 µCi MDA (a) 7.4E-OS µCi MDA (a) 1.4E-06 µCi

MDA = lllinimum detectable activity; MDC = minimum detectable concentration.

MDC (b) 2.0E-16 µCi/mL MDC (b) I.0E-14 µCi/mL MDC (b) l.9E-16 µCi/mL

(a)\ctual MDAs derived from sample analyses shall be as low as reasonably achievable and shall not exceed the values specified in Table I pra·vided the sample meets or exceeds its respective nominal volume. The target MDAs in Table I are derived from multiplying the MDCs in Table I by the respective nominal sample volumes

Page 7 ol B lor EU_I_D 315

shown in the table.

(b)\ctual MDCs derived froin sample analysis shall be as low as reasonably anaJ_n~b_le and shall not exceed the values specified in the Table I provided the sample meets or exceeds its respective nominal volume. The target MDCs in Table j are 10% of the concentration value_s in Table 2 of 40 CFR 61, Appendix Ee ·

(c GAB emission data are often used in dose calculations to s_ubstitute for the presumed presence o_fthe usually most prevalent alpha- and beta-emitting radionuclides having th:e highest dose factors, which, dependi_ng on facility sow-cc term, for alpha-e111iners has mostly usually been Pu-239/240, b_ut occasionally Am-241, and fo_r be_ta-emitters, Sr-90, but occasioriaUy Cs-13.7.

(d),ilver zeoiite analysis shall be designed to primar{Jy id_entify 1-129.

(e All positive gainma-en,rgy analysis (GEA) results shall be reported, with the exception of short_ Uved progeny of Rn-222 and Rn-220. A_t ain_inimum, ·GEA shall be designed to ·ide_l)tify peaks of Co-60, Ru-106, Sb-I 2,, Cs-134, Cs-137, EuCJ52, Eu-154, Eu_-lSS, and Pa-231.


Documents

Licensing File - Washington · period. Also, have HSC do an informal review of the license for consistency before sending t_o the licensee. £} HSC Info~cense Review iJfJ .~V•J•