OlfT' 1 Licensing File...file (be sure table of c'ontents prdvidesfdr final letter/license), final trans_mi_ttal lette_r, and final license to ef HP3 for final review. et..HP3 approves

Table of Contents

I) Lic~s_ing Checklist 2) Authorization LB #4 751

Ha_nford Richland WA RAEL-FF-OJ

Tank.Farm Guzzlei:,_.....-(EU 1449; NOC_JM2)

1 LL,

/OlfT' Licensing File

3) Other Applicable Documentation (Emails, reports, calculaticiiis, etc.) 4) Informal Draft EU License 5) Licensee Comments on Informal Draft 6) Re.solution of Cornm~nt_s 7) Origional Guzzler application 09sESQ-542 8) 28 Day Draft

a~ Liee·asee Acse·p~Bi=u~e 9) Final License

Item#

?'t I l1'1A:IP9R,) ~ rr:r~14 Ir [)'GT Gl CZ Z I £ %L.

·Tilnl. fl1,{w, fJuzz/e;LICENSING CHECKLIST

(Rev. 2)

[ otJ e Tl> oJ.16 I

Plea_s~_ initial box~~· as.app~opri9te, rather.than placinr:,_ a check mark.in the.box

RAES date received ~N""--'/~A~_and I)i!(assigned 1.6:t:F 4?5 I ,J f;M) : -

GIA 4Ji(J AJoc ~~o

8"38" "'7 74-

Evi ,44-q ,'\/c>C, I 01p4'~

Entered into RAES Tracking/ROTT I IO'ciO_(,::i ·. Completeness Review due -~rJ.c.-if=A~-

To HP3 (responsible for facility) for assignmen_t_: __ J~--vJ~-~---SCHM~~-=· ~I.D~~~----

To assigned HP2: _ ~- _ M~CQ.eM1CJ?

Add draft Table of Contents and separator pages to.file.

Conduct completeness review using ''Completeness Review Checklist" and draft "Completeness Notification'' letter"within 20 days of RAES date received. Discuss any concerns/issues with HP:l during this 20 day period.

Pl_ace "Completeness Review Checklist" in license file and prepare draft "Completeness Determination'' letter. Letter m11st go 0111 within 30 days of RAES date received.

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

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

Forward iicense file and draft "Completeness Determination'' letter to HP3 for review. (If 28-{j_ay draft· hds already been reviewed by licensee and HP3 and is ready to go 011/ at the 30 day mark, yo11 may combine completeness and 28-day draft.)

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

HSC - work with HP3 to resolve any comments then forward draft "Completene_ss Det_enninat_ion" l_ett~rto AA3 for finalization (HSC will update RAES Tracking/ROTT upon transmittal and will note the.28:, , Day Draft Due Date, be_low, upon returning file to you). You now h_ave 60 days t_o issue the official 28-' : Day DraftApproval letter.

28-Day Draft Due Date: _p--: (See next step, immediately.)

Is it necessary to send the 20-Day City Ncitification? If yes, prepare ASAP and forward to HP3 for review (follow same process as above for letter issuance [HP3 -> HSC -> AA3]). HSC will update RAES Tracking/ROTT iipon transmittal and will ncitify you of20-Day Comment Dile Date, below, upon returning the file to you).

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

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

20-Day Comment Due Date: ~ ------------(see page 2)

Page 1 o_f 2 A_// nsso_cia_t_ecf dot:11").elJ.l tempfa_tes ca'} ~e found OIJ t_he S: Driye at: S: 1£.Pf!\D_'a(a\8!' _ AIR\fuJ.§S\L(citJ,S_ing Qocs

.'//.

. -'_,~ ·w 0

Within 40 days .f}"' ofcompletenes·s detemtined, complete th_orough review of application and draft license. Any EU specific conditions must have justification/basis documented in the 'expla_nation' section of the da_tab_ase. Discuss any c·oncerns/issues with HP3 during this 40 day period. Also, have HSC do an informal review of the license for consistency before sending to the licensee .

HSC lnformal License Review CV-- ,Jt,US lj?_s,/rM

Send informal draft license to lic_ensee for review, allowi_ng them a weekto 10 days to get comments back to you. Be sure to include a ·'due date'. ,

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

~ HP3 approves a~d f?rwards lic~nse file and draft letter to HS~ for revie/ttsc reviews and forwards pt(__.. to AA3 for fin_a_l1za_t_mn (H_SC win hold file until licensee receives 28-day draft). ·

J::rl Upon licensee receipt of 28-day draft,'~~lll update RAES Tracking/ROTT, verify database o/ concurrence, and return lic~nse file to HP2 with due date for lice_nsee response or final issuance of.

license.

Final Due Date: I { 9} Ir"] i

Once licensee has accepted, or the 28 days has e'xpired (no more than 2-3 d_ays before), obt~in an ;f tf approvaLnuml:Jer (AIR#) from AA3 and prepare final license and ''Final Approval" letter. Send licens·e

file (be sure table of c'ontents prdvidesfdr final letter/license), final trans_mi_ttal lette_r, and final license to HP3 for final review.

ef et..HP3 approves and forwards to HSC for review. HSC forwards to AA3 for fi_nalization.

finalizes: .

Add final letter(s)

Upda_t_e RAES Tracki_ng/RDTT

oj:C:> Verify database concurrence

~ Update Licensee List

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

Page 2 ·or 2 All assrJciated document templates can be found on the S: Drive at: S:\£PH\Data\RP _AIR\RAES_\Licensing Do_cs

I

Item# )

-r:

From: Se_nt_: To:

'''"'"·"·"''""'

Schmidt, John W (DOH) Thursday, June 30,.2016 3:44 PM Berven, Shawna D (DOH)

Cc: Subject:

Frazier, Thomas (DOH); Laws. Gail L (DOH) FW: NOC Conso_lidation

Shawna.

We will use this as the, initiatin~ document for starting the check list. riumbei, To,;; has his air~;dy ct-rafted and ·is fill out his checklist.

Thanks

From: Schmidt, John W (DOH) Sent: Thursday. June 30, 2016 7:_51 AM

Please get Gail and Tom the IM - .. ' .

To: 'Jones,.Rosemarie' <[email protected]>; Faust, Eric T <[email protected]>; Kaldor, Reed A <Reed A [email protected]>; Bowser, Dennis W <Dennis W [email protected]>; Karschnia. Pa1,1l T <Paul T [email protected]>; Lehm_an, Karro! D <Karro! D [email protected]>; Utley, Randell J (DOH) <[email protected]> Cc: '[email protected]' <rdhagg,[email protected]>; Barnett, Matthew <[email protected]>; Berven. Shawna D (DOH) <Shawna.Berven@DOH. WA.GOV>; Frazier, Thomas (DOH) · · <[email protected]>; L_aws, Gaj_l L (DOH) <Gail.LawsliilDOH. WA.GOV> Subject: RE: NOC Consolidation

All,

Thank you for the very productive meeting. My understanding is you were going to look at the list of Noc··s and EU's to determine which you would like to close or combine and we will meet again the end · of July.

We are going to handle this as an administrative change to these licenses. Where or when needed, we wi,fl process sign_i.fi~r(m cha_nges using our revision fon:n or~ full modi~cation iJtriggered.

There are a few ofNOCs we would like to start breaking apart now just to start the process (NOCs 851 TRU Decon Trailers, 834 Trench 31 and 34, and 628,627, 626, 625 WTPJ Tom Frazier will be working the TRU and Trench. Gail Laws will be doing the WTP (Bob H, We can discuss this in our meeting next \ve_ek)

Eric, please schedule us a room for the last week of July (27 or 28) to continue our discussion.

j,,·s

----Original Appointment--.--From: Jones, Rosemarie [mailto:[email protected]] Sent: Wednesday, June 22,.2016 8:20 AM · To_: Jones, Rosemarie; Faust. Eric T; Kaldor, Reed A; Bowser, Dennis W;·Karschnia, Paul T; Lehman, Karro! D; 'Utley. Randell'; Schmidt, J_ohn W (DOH) Cc: '[email protected]'; Barnett, Matthew

Subject: NOC Consolidation When: Wednesday, June 29, 2016 10:30 AM:11:30 AM (UTC-08:00) Pacific Time (US & Canad_a)_. Where: CNF-RL-825Jadwin/540S/700

The purpose of this meeting is to d·iscuss the request received from WDOH on Monday, 6/13, to consolidate Not_ices ofConstruction. lfyou have-any questions, please contact Eric Faust on 509a376-9607.

Item#

r

'

McCormick, Ernest R (DOH)

From: McCormick, Ernest R (DOH) Sent: To:

Wednesday, September 28, 2016 1:15 PM Martell, P John (DOH)

Cc: Utley, Randell J (DOH) Subject: Tank farm guzzler license and draft 28 da"y letter Attach_rne_nts_: EU 1449, NOC 1064 9-27-2016.pdf; Guzzler_28-Day Draft._doc

John

I h_ave attached th_e li_cen_se for the Gu_zzler that will be used on the ta_n_k farm in place of th_e EU 476, NOC 860 Site-wide Guzzler.

Th.ere are no changes between th_e EU 476 (Hanford Sitewide Guzzler-001) NOC 774 (Operati_on of the Guzzle_r "' in Tank Farm Facilities) and the new EU 1449 (Tank Farm Guzzler®) NOC 1064 (Guzzler® Operation in Tank Farm Facilities)

Some key items to note·a"re:

NOC 1064 will be more costly to operate, it will need a pre-operational NDA and another NDA at the end of each quarter for the first year, it will then need to be relicensed to modify the release fraction according to the data acquired in the NDA. Each NDA is expected to cost $20,000 for a total of s·100,ooo added to the operating cost for the fi_rst year. At the end of the first year of operation the NOC will need to be relicensed to accommodate the release fraction evaluation.

NOC 1064 has a stop work level of 10,000 cpm/probe size beta/gamma. The conversion from cpm to dpm will need to be stated to understand if this allows work at 50,000 dpm, such as the NOC 860 or at 100,000

This license will need to use the same unique equipmentidentifica~ion number as the EU 476 as itis the same equipment used in a different geographical area.

I recommend that we not issue this tank farm guzzler license for the site-wide guzzler, but use the site-wide guzzler license for the operation of the site-wide guzzler.

Ernest McCormick, Health Physicist II Washington State Department of Health Division of Environmental Health Office. of Radiation Protection Radioactive Air Emissions Section 309 Bradley Blvd., Suite 201 Richland, WA 99352 Hanford Mailstop: Bl-42 Email: ernest.mccormick@doh. wa .gov Phone: (509) 946-0624 Fax: (509) .946-0876 tell: (509) 727-0886 .

All comments or statements are provided as Tecliiiical Assistance as allowed under the authority of Chapter 43.05 RCW Technical Assistance Programs 010(3).

1

McCormick, Ernest R (DOH)

From·: McCormick, Ernest R (DOH) Sent: To·:

Tuesday, September 27, 2016 10:01 AM Berven, Shav,ina D (DOH)

Cc: Utley, Randell J (DOH) Subject: Guzzler EU RAES tracking nu·mber

Sha\,1/na

I have generated a new EU arid new NOC for a new Guzzler license,

Guzzler® Operation in Tank Farm Facilities (Replaced NOC ID 774) EU 1449, NOC 1064,

I need ·to have a RAES tracking number.

I am doing things backward, I will start a file and then search for a reference to authorize the work of generating this new EU and closing

NOC 838, Roof Replacement Activities Involving Radioactive Contamination at Facilities on the Central Plateau EU 447, Type l, Type 2, Type 3 PTRAEU EU 455, HEPA Vac EU 4 76, Guzzler EU 486,200 Area Diffuse/Fugitive

The guzzler EU 476 will need to be sent to RL and ORP to reflect the removal of NOC 774 and NOC838 from the.Guzzler and e·stablish EU 476 with a single NOC of 860.

It is my hope that the new EU and NOC that I have generated will go away and the EU 476 NOC 860 will be the only guzzle·r license, but the ta~k farms are insisting on keeping the current license conditions, even though they w_ill never

use the license as written.

Ernest McCormick, Health Physicist II Washington State Department of Health Division of Environmental Health Office of Radiation Protection Radioactive Air Emissions Section 309 Bradley Blvd., Suite 201 Richland, WA 99352 Hanford Mailstop: 81-42 Email: [email protected] Phone: (509) 946-0624 Fax: (509) 946-0876 Cell: (509) 727-0886

All comments or statements are provided as Technical Assistance as allowed under the authority of Chapter 43.05 RCW Technical Assistance Programs 010(3).

1

Item#

Emission Unit ID: 1449

200 Tank Farm Guzzler This is a MINOR. ,\CTIVELY ventilall.-d '--m.ission unit.

Tank Fanns

E_mission Uni_t ln_forma~ion

Stack Height: 12.00 ft. -3.66 m. Stack Diameter 0.75 ft.

Average Stack Effiuent Temperature: 54 degrees Fahrenheit. 12 degrees Celsius.

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

Abatement Technology BARCT WAC 246-247-040(3). 040(4)

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

Zone or Area .~ .. ~ - Abatef!l"eDt T!Chli~logy

Collection Tank and Plate Separator

C)'clone Separator·

Micro-strainer Device

HEPA Filter

Baghouse

Monitoring Requirements

R_equired # of Units

2

3

2

0.23 m.

Three in-place tested HEPA filters in j,arnl~

Bag.house system with a total of68 bags(i.e., 34 bags per baghouse).

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

Federal and State Regulatory

40 CFR 6l .93(b)(4)(i) & WAC246-247-075(3)

Monitoring and Testing Requirements

40 CFR 61. Appendix B Method l l 4(3)

Radionuclides Requiring t\.leasurement

Each radionuclide that could contribute greater than l 0 percent of the PTETEDE to the MEI. greater than 0. l mrem/yr PTE TEDE to the MEI. and greater than 25 percent of the TEDE to the MEI after co~IW'

Sampling Frequency

When the HEPA filters are replaced and annually screening the HEPA fi It ration systen:i.

Samplin·g Require·ments

Addi_tlonal R_equir·en:,entS

Radiation surveys and to include but not limited to~~i\'g of the HEPA filters and screening the HEPA filtration system using gamma spectroscopy. ~

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

Ope"ratio·nal Status The Guzzler p6rtable emission unit is a com·pletely self.contained vacuum used to support operations, such a.~ but not limited to, wasie characterization. v.aste retrieval, decommissioning, deactiv~~-~· ~nance, and' construclion ary~ operation support activities. The emission unit o~erates intennitteny .

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

Project Title ./

Guzzler O~eration in Tank Farm Facilities (Replaced NOC"f'i.774)

Approval# Date Approved NOC_lD Not Approved 1064

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

1) The total abated emission limit for this Notice ofConstniction is limited to 2.00E-02 mrem/year to the Maximally Exposed Individual (WAC 246-247-040(5)). The total limit on the Potential-To-Emit for this Notice of Construction is limited 10 5.00E-02 mrem/year to the Maximally Exposed Individual (WAC 246-247-030(2 l )).

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

Page 1 of 3 fo·r EU_ID 1449

._

be conducted.

The utilization of the Guzzler for excavation of soil and gravel within the 200 Area Tank Fann Complex. Activities shall include potholing for uti[ity loc_ations, and general soil/debris/gravel removal and excavation.

Backfilling activities shall be completed manually using shovels, backhoes, loaders, and packers.

3) The Annual Possession Quantity is limited to the following radionuclides (Curies/year):

Alpha - 0 2.40E+OO I Beta - 0 3.00E+O I I Based on Am241 Based on Sr90+D ~

4) REPORTING-NOA on Filter Change and Annual Gamma Spectroscopy Aerosol testing and NDA of Guzzler HEPA l).l.ters shall be conducted annually per NOC I 072 or subsequent r· Vision_. (\\'Ac.210 ~=7-040tS,~

BATEMENT CONTROL-Stop Work Trigger ..-c--HP shall field survey every vertical and linear foot of excavation. The "Stop Work Trigger" is l 0,000 cpm per probe size ( l 5cmA2-GM, P-11 Probe) beta-gamma and 20 cpm per probe size (50 cmA2-Portable Alpha Monitor (PAM)) alpha from direct contamination readings I cm above soil surface. (\I/AC 24ti-24)..(}"11u(J), 66f)f'".ryr~

6) CONTAMINATION CONTROL-Smear of Guzzler Exhaust _ , _..HPT shall survey (smear) the Guzzler exhaust (discharge) at the end of each shift of Guzzler use. -tWAG 24-6~ 04 O€al, 969( S)J

~ RELEASE FRACTION EVALUATION-Initial and Quarterly NDA Required

~re-operational ~100 Oes11uctiue ,•mely~A+-ofthe HEPA filters will be required prior to use of the Guzzler pursuant to this license. Alternatively, a pre-operational NDA will not be required if the HEPA filters have not been used since the last NDA or the HEPA filters are new. An NDA of the HEPA filters will be required with every 90 calendar days of use within the 200 Area Tank Fann Complex. This 90 day period is defined as 90 calendar days past the first day the Guzzler is used within the 22~).'ea Tank Fann Complex. The Guzzler tracking log will track the accumulated PTE for this emission unit (EUl,{1449) annually, where ever it is used on the Hanford Site. The Guzzler tracking log will be required to track the accumulated PTE based upon soil contamination readings and adjusted (only for operntion under this ·approval} by the release fraction of l .OE-03.

Once the Guzzler is in use under this license an NDA is required prior to exit from use in the 200 Area Tank Fann Complex to use elsewhere on the Hanford Site.

If the accumulated PTE, within the 200 Area Tank Fann Complex, based upon the tracking log reaches 0.025 mrem/yr, an addition_al NDA of the HEPA filters will be required and the 90 day NDA cycle will begin again. If the accumulated PTE, within the 200 Area Tank Fann Complex, based upon the tracking log reach.es 0.0375 mrem/yr, another NDA of the HEPA filters will be required and the 90 day cycle will begin again. If the accumulated PTE, within the 200 Area Tank Fann Complex under this license, based upon the tracking log reaches

; mrem/yr, use of the Guzzler must stop for therema_inder of the calendar year.

o assess if the release fraction of l .OE-03 is conservative. A minimum o As is required for the evaluation. '(\!'AC 246-~~ 64Qt5), 860(:§)) (4)

8) WDOH APPROVAL-Release Fraction Verification Needed The request for a.ppro_¥for release fraction to be changed from l to I .OE-03 is·approved and will be verified as conservative using o/f_ condition 7. f','IAC 216 217 Q1Q(5). ()('.jQ(¥

9) REPORTING-Limits on Emission by Use 200 Area Tank Farm Complex:

For Guzzler Excavation: l .60E-04 mrem/yr Beta based on Sr-90+D, 2.50E-02 mrem/yr Alpha bas_ed on Am-241, 2.50E-02 1mem/yr total unabated dose and I .OOE-05 mrem/yr abated dose.

For Backfilling: l .60E-04 mrem/yr Beta based on Sr-90+D, 2.50E-02 mrem/yr Alpha based~~!'?'· 2.50E-02 mrem/yr total unabated dose and 2.00E-2 mrem/yr abated dose. {WAG 2~ 674?-040(-5r,660r

Page 2 of 3 for EU_ID 1449

10) REPORTING-Total Combined Dose to the Offsite MEI This em.ission unit is limited to an annual abated dose to the offsite MEI of 5.0 E-2 mrem/yr when com~dr the abated offsite dose to the MEI for Emission Unit 476 "Guzzler™'' .• (:J,\lAC No-2~40E3), 060f!,v //{__,,,/

-~ ...

. ,

....

····-


· .. Item#


Hanford Sitewide Guzzler-001 Guzzler This is a MiNOR.. ACTIVELY ventilatro emission unit.

G_UZZLER

Emission Unit Information

Stac_k Height: 1_2.00 ft. J_66m. Stack Diameter 0. 75 ft. - ·- --


nt/second. Average Stack ExhaustVelociry: ft/secondc

Abc1tement Tech_nology BARCT WAC 246-247-040(3). 040(4)

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

Zone or Area Abatement Technology


Cyclone Separa_to_r


HEPA

Baghouse


Required# of Units

2

3

2

0.23 m.

AIRXX~xxx

Additional D_escriptiori

Three in-place tested HEPA filters in parallel.

Baghouse system with a total of 68 bags (i.e., 34 bags per baghouse).

state enforceable: WAC 246°247-040(5), 060(5), and federally enforceable: 4_0 CFR 61 subpart H


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


40 CFR 61; Appendix B, Method l 14(3)

Radionuclides Requiring Measurement

Each radionuclide that could contribute greater than I 0% of the potential-to-emit TEDE to _the MEI, greater than 0.1 rn:n:nt/yr potential-to-emit TEDE to the MEI, arid greater than 25% of the TEDE to th_e MEI. after controls.

Sampling Frequency _ _

When the HEPA filters are replaced and annually screening the HEP A filtration system.

Sampling Requirements Radiation surveys and to include but not limited to NDA testing of the HEPA filters and screening the HEPA filtration system using gamma spectroscopy.

AdditiOnal RE!quirements

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

Ope_rlltio_n_al S(atus Tl_te G_uzz_lei" ® portable emission Unit ·is a co·mpletely self-c_o·11tairie_d \'.a~u;ur:i:i Used to Support oper_at_i_Ons, s\J~h ·as but n_ot li11_1ited to, waste cJ:iara_cte"~zatiOn. wa·st_e ~etrieva_l. decOr;rim_issioning, deactiVa_tion. ·ma:in\e:n3:11:ce, Ulld construction an_d op_e"ratiOri Sup-pOrt a~ti0ties. The em_ission U)j.i_t oPexa_tes·int~_r:i:ijitle_n_tly.

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

Page 1 of X_for EU_ID 476 XX/XX/201§

Project Title

Use oftbe GU2Zler™ (Filter Vacuum Truck} Vacuum Excavation System for Radiologica~'A I, it<al,jJ Activities on the-Hanford Site .. (Replaced NOC~ 1774. 8381

Page 2 ot'X}or ~U_ID 476

Approval# AIR 1§-XXX

C>ate Approved NOC~ID XX/XX/201§ XXX

XXIXX/201§

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

1) The total abated emission limit [or radiolocically Iinuted FVT activiud for this Notice of Construction is limited to 5.00E-02 mrem/year to the Maximally Efosed Individual (Yo/ AC 246-247-040(5)). The PTE I '· . . for rad1olocica1Iv limited FV activ1tiej as determined under WAC 246-24 7-030(21 )( a-e) [as specified in the application] is 5.00E-02 mrem/year.

The total abated emission limit for Central Plateau FVT roof replacement activitie,l for this Notice of Construction is limited to 9.S0E-03 mrem/year to the Maximal[ Ex osed Individual (WAC 246-247-040(5)). The PTE for entral Plateau FVT roofre lacement activities · as determined under WAC 246-24 7-030(2l)(a-e) [as specified in the application] is 4.S0E-02 mrem/year.

The total abated emission limit for Tanlc Fann FVT activities in high contamination ared for this Notice of Construction is limited to 2.00E"02 mrem/year to the Maximally Exposed Individual

WAC 246-247-040(5)) .. The total limit on the Potential-To-Emit for Tank Fann FVT activities in bighj ontamination are for this Notice of Construction is limited to 5.00E-02 mrem/year to the Maximally

Exposed Individual (WAC 246-24 7-030(2 I)).

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

HANFORD SITE RADIOLOGICALLY LIMITED ACTIVITIES

The utilization of the Guzzler™ Vacuum Excavation System (Guzzler™) for potholing to support utility locations, soil removal/general excavations, and radiologically limited activities involving roof or pit cleaning (note, radiologically limited activities means work locations where soil radiological contamination levels are not expected to exceed 50,000 dpm/probe size beta-gamma and/or l 40 dpm/probe size alpha). For purposes of this license, "soil" will be defined as sand, dirt, gravel, gravel and tar mixtures and rock, or any combination of these items. Note, beta-gamma probe size is -16. 7 cniA2 and alpha probe size is -50 cmA2. Note, the terms, '"Guzzler™," and "Filtered Vacuum Truck (FVT)," may be used interchangeably.

In most cases, for excavations, the excavated soil will be·used for backfilling of the excavated areas. The backfilling activities will be completed manually, using shovels, or using backhoes, load!'rs, or packers. For cleaning activities and some excavations, the soil will either be containerized for disposal or transported to an appropriate disposal facility (e.g., LLBGs, ERDF, etc.) within the FVT collection tank for noncontainerized disposal. In some cases, soil may be unloaded from the FVT and packaged at the disposal facility for containerized disposal.

Only radiologically contaminated or potentially contaminated soil will be removed or excavated using the regulated FVT system. All soil removed from the system will be handled as potentially contaminated, unless otherwise surveyed or analyzed.

The regulated FVT will not be used for the decontamination of valve pits within the tank farms. The regulated FVT is also excluded from areas containing radiological contamination above 50,000 dpm/probe size beta-gamma and/or 140 dpm/probe size alpha. ·

Soil can be slowly dumped from the collection tanlc by controlling the raising and lowering speed of the tank.

Soil from contaminated areas enters the unit through a hose. An air lance attachment may be used to aid in the loosening of soil.

The various cleaning and excavation activities will be compl_eted using the FVT along with shovels, picks and/or the air lance attachment to loosen the soil, and backfilling activities will be completed using backhoes, loaders, compactors with plates, and p_icks and shovels, as appropriate. In some cases, however, an area may be physically inacc·essible for the regulated FVT. In those instances, the cleaning or excavation, as well as any backfilling activities will be completed using backhoes, loaders, compactors with plates, and/or picks and

Page 3 of X_for EU_ID 476

shovels, as appropriate

Areas of the vacuum truck where condensate may accumulate such as the HEPA filter housing, silencer, and micro-strainer will be drained on an as needed basis to remove condensate buildup. The drained water will be containerized and properly dispositioned. If radiological contamination is present, the liquid may be solidified with absorbent materials, and the resulting matrix may be packaged and disposed of at a radioactive landfill (e.g., LLBG, ERDF, etc.). Alternatively, the liquids may be transferred to an approved container or tanke_r truck (see Emission Unit ID 888) for transport to the Effiuent Treatment Facility (Emission Unit ID 301) or either facility licensed to receive radioactively contaminated liquids.

CENTRAL PLATEAU ROOF REPLACEMENT ACTIVITIES

Management of radioactive contamination during roof replacement activities.

All work shall be performed in accordance with written contractor radiological control requirements (associated with posting and downposting requirements for doing work in outdoor contamination areas and fixed contamination areas) and the as low as reasonably achievable (ALARA) program requirements. These requirements are to be carried out through activity work packages/procedures and associated radiological work permits.

Types of facilities allowed to use this NOC are active and operational, currently in surve_{llance and maintenance (S&M) mode, or in transition to S&M mode.

Activities are non-routine activities that have a potential to create a new temporary emission source and/or a modification of a source(s) of diffuse an_d fugitive e_missions at facilities on the Central Plateau.

Screening Surveys

Roofreplacement activities include radiological surveys to determine if radioactive contamination is present and the extent of such contamination. Spot c_ontamination (e.g., bird droppings) managed before commencement of roofreplacement work is handled per existing methods and is considered a routine housekeeping activity (similar to spot contamination found at ground levels).

Managing Radioactive Contamination

Contaminated roofing materials may be removed by manual or powered methods,_ including saws or other Cllttihg devic.es, shovels, Wheelbarrows, conveyors, chutes, or other similar equipment (conveyors or chutes may be used only for packaged radioactive waste or for non-contaminated roofing material). Radioactive waste shall be managed in accordance with existing onsite requirements and waste acceptance criteria. Radioactive waste either shall be containerized in drums, skiffs, boxes, or other containers, or handled as bulk waste (e:g., dump truck) and transferred to the appropriate disposal facility. Management of radioactive contamination is aUowed to include removal and subsequent size reduction of contaminated equipment from a roof as well as isolation and blanking of utilities, vents, and ductwork.

Accumulated rainwater that has contacted co·ntamination areas s_hafl be aflowed to evaporate in place or is characterized, collected, and managed in accordance with stoimwater discharge requirements or transferred to an appropriate d·isposal facility.

A graded approach is allowed to be used to match controls wi_th expected contamination levels per radiological control manuals and methods. Radiological contamination that is encountered will either be managed as a fixed contamination area (i_.e., less than 20 dpm/l 00 cm2 smearable alpha and less than l ,000 dpm/100 cm2 smearable beta) or will be managed as a contamination area (radiological contamination levels are between 20 and 2,000 dpm/100 cm2 alpha or between 1,000 and l 00,000 dpm/100 cm2 beta) using appropriate controls to roiniroiz~ worker exposure. These controls include water for dust suppression, fixatives, covers, windscreens, or greenhouses (with PTRAEU exhausters) that will be applied, if needed, as determined by the Health Physics organization, and consist of ALARA tec_hniques.

Process descriptions and abatement controls, as d_escribed in the latest approved revisions of the Guzzler NOC Page 4 of XJor EU_lD 476

(99-SfD,02 I), the PTRAEU NOC (DOE/RL-96-75), or the HEPA Vacuwn NOC (DOE/RL-97-50).shall be use<l; however, the a~_tivi_ty-specific operational c_ontrol_s and trnck_ing require_ments shal_l follow these approval conditions. The Guzzler, PTRAEU, and HEPA vacuwn units shall have a removal efficiency of99.95% for radioactive airborne particles.

TANK FARM FACILITIES ACTNITJES [N HIGH CONTAMINATION AREAS

The utilization of the Guzzler for excavation of sciil and ave! within · gh contamination areas iI the 200 Area Tank Farm Com lex up to 10,000 cpm per probe size (15cmA2-GM, P-1 I Probe) beta-gamma and,_~

0 cpm per probe size 50 cmA2-Portable Al ha Monitor AM al ha from direct contamination readino-s I cm bove soil surface Activities shall include potholing for utility locations, and general soil/debris/gravel

rell_loval and ~xcavatio_l).

Backfilling activities shall be completed manually t1sing shovels, ba_cKI:ioes, loa<lers, an_d pac_kers.


3) The PTE for this proj~ct ttor rad10l091cally luruted F VI activmej as determined under WAC 246-247-030(21 )(a-e) (as specified in the application]is 5.00E-02 mrem/year. Approved are the associated potential release rates (Curies/year) of:

Alpha - 0 1.79E-03 Gas WAC 246-247-030(21 )(a)

200 Area *gaseous physical state assumed for purposes of conservatism relative to assigned release fraction. Am-241 used as conservative alpha emitter.

Alpha - 0 1.30E-04 Gas WAC 246-247-030(21 )(a) 300 Area •gaseous physical state assun:ied for purposes of conservatism relative to assig·ned relea~e rra·~uoi:1. U-2_34 Used as conservative alpha emitter.

Alpha - 0 7.26E-04 Gas WAC 246-247-030(21 )(a) 400 Area ·gaseous physical state assumed for purposes of conservatism relative to assigned release fraction. Pu-239 used as conservative alpha emitter.

Alpha - 0 1.79E-03 Gas WAC 246'247-030(21 )(a) 100 Area *gaseous phySical state assumed for purposes of conservatism relative to assigned release fra_ction. Am-241 used as conservative alpha emitter.

B/G-0 4.48E-02 Gas WAC 246-247-030(21 )(a) 200 Area ·gaseous physical state assumed for purposes of conservatism relative to assigned release fraction. Sr-90 used aS conservative beta emitter.

B/G-0 4.48E-02 Gas WAC 246-247-030(21 )(a) 300 Area •gaseous physical state assumed for purposes of conservatism relative to assigned release fraction. Sr-90 used as conservative beta emitter.

B/G-0 1.46E-02 Gas WAC 246-247-030(21 )(a) 400 Area "'gaseous physical state assumed fo_r purpos_es of cOnservatisrii relative tO assig'ned release fraction. Sr-90 used as conservative beta emitter. · · · -

B/G-0 4.48E-02 Gas WAC 246-247-030(21 )(a) 100 Area *gaseous physical state assumed for purposes of conservatism relative to assigned release fraction. Sr-90 used as coiiservative B/G em(tter.

The radioactive isotopes identified tor radiololrically limited FVT activitieij for this emission unit are (no quantities specified):

Am-241 Co-60 Cs-134 Cs-137 Eu-152

Eu-154

Pu - 241

Th - 23_2

Eu - 155

Ru-106

U -234

Pu - 238

Sb -125

U -235

Pu - 239

Sn -113

U - 238

Pu -240

Sr-90

The potential release rates described in this Condition were used to deterniine 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 Depariment 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 Depar1ment of any changes to potential release rates as required by state or federal regulations including changes that would constitute a significant modification to the Air Operating Permit under WAC 173-40 I -725( 4). Notice will be provided according to the particular regulation under which notification is required. If the applicable regul_ation(s) does not address manner and type of notification, DOE will provide the Depariment with advance written notice by letter or electronic mail but not solely by copies of documents.

The. PTE for Central Plateau FVT roof replacement activities . , ,j as determined under WAC 246-24 7-030(2 l )(a-e) [as specified in the application] is 4.80E-02 mrem/year. Approved are the associated potential release rates (Curies/year) of:

Alpha - 0 1.00E-03 Liquid/Particulate Solid WAC 246-247-030(21 )(a) License PTE limit bounds 1.0E-03 Ci/yr.241Am and release fraction of 1.0. Any radionuclide on the chart of the nuclides could be encountered during roof replacement activities. The radionuclides specifically listed in the NOC application were chOsen to conservatively represent all radionuclide emissions that may occur in particulate fomi. A small contribution from the gaseous radi.onuclides may be encoun_tered. Although any radion~cli_de could be present. for conservatism all alpha is

Page 6 of XJor EU_ID 476

assumed to be 241Am and all beta/gamm-a is assumed to be 137Cs for dose calculation estimates. Other radionuclides i:i,ay be enco_untered and are appioved so long as they ire coi:,serv_atively ~ep_res_en_ted by the total alpha and total beta/gamma constituents.

B/G-0 5.00_E-02 Liqui_d/Particulate Solid WAC 246-247-030(21 )(a)

License PTE limit bounds 5.0E-02 Ci/yr 1_37Cs an_d release fraction of 1.0. Any radionuclide on the chart of the nuclides could be encountered during roof replacement activities. The radionuclides specifically listed in the NOC application were chosen to conservatively represent all radionuclide emissions that may occur.in particulate form. A small contribution from the gaseous radionudides may b"e encountered. Although any radionuclide could b·e present. for conservatism all alpha is assumed to be-241Am and all beta/gamrfra is assumed to he 137Cs for dose catculalion estimates. Other radi9nuclideS may be el)countered and a~e approved so I0ng as they are conserv_atively represented by the total alpha and total beta/gamma constituents.

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 th~ 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 must notify the Department of any changes to potential release rates as required by state or federal regulations including changes that would constitute a significant modi_fication to the Air Operating Permit under WAC 173-40 l-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 of notification, DOE will provide the Department wi_th advance written notice by letter or electronic mail but not solely by copies of documents.

The Annual Possession Quantity for Tank Farm FVT activities 11; high contamination areaij is limited to the following radionuc lid es ( Curies/year):

Alpha - 0 2.40E+00 I · Beta - 0 3.00E+0 l Based on Am241 Based on Sr90+D

4) All soil excavation activities operating u·nder this NOC must cease operations when sustained wind conditions reach or exceed 20 miles per hour.

[l'IO"[E 1_0 Ill;:VIE_WER~: ~E:}V REQUI~MEJ\!T FOR_ <;:H_!'RC ,A.NI) ',V]sP~]

5) The facility must maintain a log in an approved format for this activity or emission unit..(W AC 246-247-080(7)

[NQTETO REVIF;WERS: SLIGHTREWO!ill!NG OF REQUIREMENT FOR CHPRC AND WRPS] 6) The following are the allowable radionuclides fur radiologically liinited FVF acti'litie~: Co-60, Sr-90, Cs-137,

Cscl34, Th-232, U-234, U-235, U-238, Eu-152, Eu-154, Eu-155, Ru-106, Sn-l 13, Sb-125, Am-241, Pu-238, Pu-239, Pu-240, and Pu-241. If any either radionuclides are suspected or verified through soil analysis the department must be notified.

[QUESTION FOR REVIE~ERS: CAN JHIS REQUIREMENT AL$Q,A.PPt y to CHPRC _AND Wfil>s WITH OU:( C::Al!_SING PROBLEMS}]

Page 7 of X_for EU_ID 476 X)(/)()(/201 §

7) For dose modeling !fur Cenlral Plateau FVT roof replacement acti,~tie~. the radionuclides of concern shall use cesium-137 (representing beta/gamma emitters) and americium-241 (representing alpha emitters).

8) For Tank Fam1 .FVT acti~~lies in high cont.11nin.~tion areas. aerosol testing and NDA of Guzzler HEP A filters shall be conducted annually per NOC ID 658 or subsequent revision. WAC246-247-040(5), 060(5).

9) For Tank Fam, FVT activities in high contamination area:!. HPT shall field surve)!I every vertical and linear foot of excavation. The "Stop Work Trigger" is 10,000 cpm per probe size (15cm"2-GM, P-11 Probe) beta-gan,rna and 20 cpm per probe size (50 cm"2-Portable Alpha Monitor (PAM)) alpha from direct contamination readings l cm above soil surface.

WAC 246-247°040(5), 060(5).

10) For Tank Fam1 FVT acti~ties in high contamination areaJ. HPT shall survey (smear) the Guzzler exhaust (discharge) at the end of each shift of Guzzler use.

WAC 246-247-040(5), 060(5).

11) RELEASE FRACTION EVALUATION For Tank Farm FVT acti~ties in high contamination arearl.

12)

13)

A pre-operational Non-Destructive Analysis (NDA) of the HEPA filters will be required prior to use of the Guzzler pursuant to this licerise. Alternatively, a pre-operational NDA will not be required if the H~PA filters have not seen any use since the last NDA or the HEPA filters are new. An NDA of the HEPA filters will be required with every 90 calendar·days of use within the 200 Area Tank Farm Complex. This 90 day period is defined·as 90 calendar days past the first day the Guzzler is used within the 200 Area Tank Farm Complex. The Guzzler tracking log will trac.k t),e accumulated PTE for this emission unit (EUID 476) annually, where ever it is used on theHanford Site. The Guzzler tracking log will be required to track the accumulated PTE based upon soil contamination readings and adjusted (only for operation under this approval) by the release fraction of l .0E-03.

Once the Guzzler is in use under this license an NDA is required prior to exit from use in the 200 Area Tank Farm Complex to use elsewhere on the Hanford Site.

If the accumulated PTE, within the 200 Area Tank Farm Complex, based upon the tracking log reaches 0.025 mrem/yr, an additional NOA of the HEPA filters will be required and the 90 day NDA cycle will begin again. lfthe accumulated PTE, within.the 200 Area Tank Farm Complex, based upon the tracking log reaches 0.0375 mrem/yr, another NDA of the HEPA filters will be required and the 90 day cycle will begin again. If the accumulated PTE, within the 200 Area Tank Farm Complex under this license, based upon the tracking log reaches 0.05 mrem/yr, use of the Guzzler must stop for the remainder of the calendar year.

After a year of operations under these approval conditions, an evaluation of the res.ults shall be made available to WDOH to assess if the release fraction of l .0E-03 is conservative. A minimum of 4 ND As is required for the evaluation.

WAC 246-247-040(5), 060(5).

F\pr Tank Fam, FVT activities in high contamination areas, 1!he request for approval for release fraction to be changed from l to I .0E-03 is approved and will be verified as conservative using the condition b1 I oeleasej &action evaluatiod.

The following are the annual emission limits for radiologically limited FVT acti~tie4 for the NOC: lO0AREA: For FVT Cleaning/Excavation: 2.88E-3 mrem Sr-90, 3.4E-2 mrem Am-241 For Backfilling: 2.88E-6 mrem Sr-90, 3.45E-5 mrem Am-241

200AREA: For FVT Cleaning/Excavation: l .96E-3 mrem Sr-90, 2.34E-2 mrem Am-241

For Backfilling: l .96E-6 mrem Sr-90, 2.34E-5 mrem Am-241

300AREA: For FVT Cleaning/Excavation: 3.9E-2 mrem Sr-90 8.3E-3 mrem U-2.34 For Backfilling: 3.9E-5 tnrem Sr-90, 8.3E-6 mrem U-234

Page 8 of XJor EU_ID 476

400AREA: For FVT Cleaning/Excavation: 8.5E-4 mrem Sr-90, 8.34E-3 mrem Pu-239 For Backfilling: 8.5E-7 mrem Sr-90, 8.34E-6 mrem Pu-239.

lrhe following are the annual emission limits for Central Plateau M roof replacement activities! Total sum of the potential releaserates of the Guzzler and HEPA Vacuums shall noi exceed 1.0 E-3 Ci/Year Alpha and 5.0 E-2 Ci/Year Beta/Gamma.

[fhe following are the annual emission limits for Tank Farm FVT acti,ities in high contamination areas for the NOC!

200 Area Tank Farm Comp le)'.(:

For Guzz_ler El'.(c_ava_ti_on: L60E-04 '1frern/yr Beta b~sed on Sr-90+O, 2.50E-02 mrem/yr A]pha based on Am-241,2.50E-02 mrem/yr total unabated dose and l .00E-05 mrem/yr abated dose.

For Backfilling: l .60E-04 mrem/yr Beta based on Sr-90+O, 2.50E:02 mrem/yr Alpha based on Am-241, 2.S0E-02 mrem/yr total unabated dose and 2.00E-2 mrem/yr abated dose.

WAC 246-247-040(5), 060(5).

14) U.S. DOE shall monitor this project or emission unit as follows: In addition to the surveys described in this NOC! periodic confJ.ITll!ltory measurements are required. This may include but_ is not li_mited to NOA testing of the HEPA filters when the HEPA filters are replaced and annually screening the HEPA filtration system usirig gamma spectroscopy. (WAC 246-247-075(8)0 ·


Item#·

Item#

09-ESQ-542

Mr. John Martell, Manager Radioactive Air Emissions Section Washington State Department of Health 309 Bradley Blvd., Suite 20 I Ric11l_and, Washington 99352 (Hanford Mailstop: B 1-.42)

Dear Mr. M_artel_l:

NOV 2 4 2009

Ccr4-C75 RECEIVED

NOV 3 0 2009 Wa Dept of Health - Office of AadiaHon ProtocHorf

THE U.S. DEPARTMENT OF ENERGY, OFFICE OF RIVER PROTECTION (ORP) REQUEST FOR APPROVAL OF MODIF[CA TION TO THE NOTICE OF CONSTRUCTION FOR THE GUZZLEREXCAVATION AND BACKFILLING ACTIVITIES IN SUPPORT OF THE 200 AREA A FARM COMPLEX

ORP requests Washington State Department of Health review and approve the "Notification of Off-Permit Change Hanford Site Air Operat_i_ng Perm_it Nu_mber 00-05-006 Renewal I," (Attachment l) and "Notice of Construction for Guzzler Operation in the 200 Area Tank Farm Compl~x" (Attachment 2). This modification is being submitted in compiiance with Washington Administrative Code 173,246-247, ''Washington Adrninistrative Code 246-247, Radiat_ion Protection - Air Emissions,'' as amended, and Air Operating Permit 00-05-006 Renewal I.

ORP is proposing a revision to the subject Notice of Construction Application and Off Permit change to Ai_r Operating Permit Emissio·n Uriit identification number 476, Notice of Construction ID number 647. ORP is requesting the release fract_ioll for Guzzler exc_avation activities be change·d from I to I E-03 based upon the attached supporting documentation. The proposed change wiU provide for more flexibility in use of the Guzzler for excavation of contaminated areas within the Tank Farms than currently exists under the existing permit conditions and is well support_ed by industry and Environmental Protection Agency data.

If you have any questions, please contact me, or your staff may contact Dennis W. Bowser, Environmental Compliance Division, (509) 373-2_566.

ESQ:DWB

Attachments: (2)

cc: See page 2

Noc w47

Sincerely,

Shi,l,: tflz:, Office f River Protectio·n

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Mr. Kevin W. Smith, Manager . · 1'1' _ ~"' -United s. tates Departm_ent of Energy. ~·. Ofc i2 2016 ~ Office of River Protection "" P.O. Box 450, MSIN: H6-60 , ;,-____.. - vsc~ Richland, WA 99352 :::::::· ==========::::::=::::::::::===:

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PS .Form 3811, July 2015 PSN 7530·02·000-9053 Domestic Rotum Receipt

STATE OF WASHINGTON

DEPARTMENT OF HEALTH OfFICE Of 11,\0IATION Pl{OTECTION

.10? llr.idlcy lJlvd., Suite 201 • Richl,md, w~1sllingto11 99352

TDD Rel.1y Service: 1-ll00-ll33-638H December 7, 2016

CERTIFIED MAIL 7015 0640 0007 5050 7883 7015 0640 00075050 7890

Mr. Kevi_ll W. Smith, M_an,ager United States Department of Energy Office of River Protection P.O. Box 450, MSIN: H6-60 Richland, Washington 99352

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

AIR 16-1201 RAELFF-01

NOCs 1064 & 1072

Re: 28-Day Draft Approval of Notices of Construction (NOCs) I 064 and I 072

Reference: Emf!il (1,,8# 4 751 ), fi-911?- John Schmidt (WDOH) to Multiple US DOE Staff, "NOC Consolidation", dated June 30, 2016.

Messrs. Smith Wl.d Shoop:

As per the reference.email, we have worked with your staff to make changes to move the NOCs and/or Emission Units (EUs) associated with this license from a one-to-many, to a one-to-one relationship. We appreciate your cooperation and wil'iingness to support our future database 11eeds and to make license actions more efficient and cost effective moving forward.

Pursuant to Chapter 246-247 of the Washington Administrative Code (WAC), your modifi_cation to EU 4 76 (H_anford Sitewide Guzzler-00 I) to generate NOC I 072 "Hanford Sitewide Guzzler-00 I" will be approved for use as the license anywhere on the Hanford Site, according to the enclosed Lic·ense for: ·

Hanford Sitewide Guzzler-001 (Replaced NOC 860) (EU 476, NOC 1072)

This NOC also includes the applicable portions (pertaining to Guzzler use) of the previous NOC 838.

ru'blic He.11th - Alw;1y!:, \Vorking for c1 s~1!er ,rnd Hc,1lthie1· \,\la5hingto11

Messrs. Smfrh and Shoop AIR 16-1201 December7,2016 · Page2of3

This NOC ( 1072) will be used in conjunction with NOC 1064 (for EU 1449), having a combined dose to the maximally exposed individual (MEI) of0.05 mrem/year, per the enclosed.License for:

Guzzler Operation in Tank Farm Facilities (Replaced NOC 774) (EU 1449, NOC 1064)

The Washington State Department of Health (DOH) considers the condllions, controls, monitoring requirements, and limitations of this license integral to approval of your application.

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

If you accept the conditions and liniitatioris of this approval and do not wish to apply for an adjudicative proceeding, but wish to proceed under this approval before the 28 days have elapsed, please notify us in writing and the DOH will issue the final approval letter. Your notice should be mailed or faxed to:

DOH - Office of Radiation Protection Radioactive Air Emissions Section 309 Bradley Blvd., Suite 201 Richland, Washington 99352 FAX: (509) 946-0876 EMAIL: [email protected].

If there are concerns with the conditions and limitations of the approval, please notify the DOH. If attempts to resolve the concerns fail, the DOH will cieny yoilr application and you may contest the conditions and limitations of this approval, wi_thin 28 days of receipt, by filing the enclosed Request for Adjudicative Proceeding or a document providing substantially the same information with the DOH, Adjudicative Service Unit (ASU), in a manner that shows proof of service on the ASU. The ASU's addres_s 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 with your application. F.ILING ·sHALL NOT BE DEEMED COMPLETE UNTIL THE ADJUDICATIVE SERVICE UNIT ACTUALLY RECEIVES YOUR APPL!CA TION.

Messrs. Smith and Shoop December 7, 2016 Page 3 of3

AIR16-1201

lfyou have any questions regarding this draft approval, please contact McCormick emest.mcconnick@dol1.\va.gov at (509) 946-0624 or John Schmidt [email protected] at (509) 946-0534 ·

Jo~,~ Radioactive.Air Emissions Sectfon

Enclosures: (1) NOC 1072 (EU 476)- Hanford Sitewide Guizler-001 (2) NOC I 064 (EU 1449) - Guzzler Opera1ion in Ta.nlc Fann Fa"ilities (2) Requ_est forAdjudicative Proceeding

cc: Ruth Allen, WR.PS M_atthew Barnett, PNNL Lilyann Bauder, Ecology Shawna Serven, WDOH Lucinda Borneman, WRPS Lee Bostic, BN.I Dennis Bowser, USDOE-ORP Frank Carleo, CHPRC Cliff Clark, USDOE-RL Jac_k Donnelly, WRPS Dennis Faulk; EPA Eric Faust, USDOE-RL Gary Fritz, MSA Philip Gent, Ecology Robert Haggard, BNI Dan}el Heuston, Ecology Jessica Joyner, WRPS Reed Ka_l_dor, MSA Paul Karschnia, CHPRC Ernest !vlcCon:nick, WDOH Jim McAuley, EPA Bryari Trim.berger, USDOE-ORP Randy Utley, WDOH Jeff Voogd, WRPS Envircirunental Portal RAES Tracking: L_ine 16-205 and 16-206; EU 476 and 1449; NOC 1064 and 1072

Emlsd_on Unit ID: 476

Hanford Sitewide Guz:zler-001 Guzzler This is a MINOR. ACTIVELY ventilated emission unit.

GUZZLER


Stack Height: I 2.00 ft. 3.66m. Stack Diameter 0.75 ft.

Average Stack Effiuent Temperature: 54 degrees Fahrenheit. i'2 degrees Celsius.

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

Abatement Technology BARCT WAC 246-247-040(3). 040(4)

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

Zone or Area Abatement Technology


Cyclone Separator


HEPA

Baghouse

Required# of Units

2

3

2

0.23 m.

Ad.~tio11a! D~~ription


Baghouse system ~th a total of 6_8 hags (i;_e., 34 bags per baghouse).

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


40 CFR 61.93{b){4){i) & WAC 246-247-075(3)

Monitoring and Testing ~~':l_ire-:ne_nJs

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

RadionucUdes Requiring i\'_lensllrefill:Dt

Each radionuclide that could contribute greater than I 0 percent of the PTE TEDE to the MEI, greater than 0.1 mrem/yr PTE TEDE to the MEI, and greater than 25 percent of the TEDE to the MEI after controls

SampUng Frequency

When the HEP A filters are replaced and annually screening the HEP A filtration

.system ..

Sampling Requirements Radiation surveys and to include but not limited to NOA testing of the HEPA filters and screening the HEPA filtration >)'Stem using gamma spectroscopy.

Additional Requlroments

Ad.ditional monitoring or s6nipling reQuirem·ents e·stablished by this License will bo listed in the Conditions and Limitations section, if appncabla.

Operational S_tatus The Guzzler p0nable emission unit is a completely self-contained Vacuum used to suppon operations, such as but not limited to, waste characterization, waste ·retrieval, decommissioning, deactivation, maintenance, and construction and operation support activities. The emission unit operates intermittently.


Project Title Approval# Date Approved NOC_ID

Use of the Guzzler (Filter Vacuum Truck) Vacuum Excavation System for Radiologically Limited Activities on the Hanford Site {Replaced NOC 860)

Not Approved

Conditions (state only enfcirceable: WAC 246-247-040(5), 060(5) if not specified) I) The total abated emission liniit for this Notice of Construction is limited to 5.00E-02 mrem/year to the

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

2) PROCESS DESCRIPTION

1072

This approval applies only to th_ose activi_t_ies des_c_ribed bel9w. No ad<{ition_al activities or variations on the


approved activities tha1 constitule a "modification" 10 the emission unit, as defined in WAC 246-247-030(16), may be conducted.

The utilization of the Guzzler for potholing 10 support utility locations, soil removal/general excavations, and radiologically limited activities involving roof cleaning (note, radiologically limited activities means work locations where soil radiological contamination levels are not expected to exceed 50,000 dpm/probe size beta-. gamma and/or 140 dpm/probe siz.e alpha). For purposes of 1his license, "soil" will be defined as sand, dirt, gravel, gravel and 1ar mixtures, rock, or any c.ombina1icin of1hese items. Note, be_t.a-gamma probe size is -16.7 cmA2 and alpha probe size is -50 cmA2. Nole, the 1errils, "Guzzler," and "Fillere.d Vacu·um Truck (FVT),'' may be used interchangeably.

In most cases, for excavations, the excavated soil will be used for backfilling of the excavated areas. The ba_c_kfilling activities will be completed manually, using shovels, or using backhoes, loaders, or packers. For cleaning activities, and some excavations, the soil win either be con.toinerized for disposal or transported to an appropriate disposal facility (e.g., Low Level Burial Grounds, Environmental Res.t.orntion Disposal Facility) within the FVT collection tank for no containerized disposal. In some cases, soil may be unloaded from the FVT and packaged at the disposal facility for containerized disposal.

Only radiologically contaminated or potentially contaminated soil will be removed or excavated using the regula.ted FVT system. AH soil .removed from the system will be handled as potentially contaminated, unless otherwise surveyed or analyzed.

The regulated FVT will not be used for the deconllltllination of valve pits within the tank farms. The regulated FVT is also excluded from areas containing radiological conllltllination above 50,000 dpm/probe size betagamma and/or 140 dpm/probe size alpha.

Soil can be slowly dumped from th_e collec.tion rnnk by controlli.ng the raising and lowering speed of the tank.

Soil from contaminated areas enters the unit through a hose. An air lance auachment may be us.ed to aid in the loosening of soil.

The various cleaning and excavation activities will be completed using the FVT along with.shovels, picks and/or the nir lance attachment to loos"1! the soil, and backfilling activities will be completed using backhoes, loaders, compactors wi1h plates, and picks and shovels, as appropriate. In some cases, however, an area may be physically inaccessible for the regulated FVT. In those instances, the cleaning cir eJ_<cavation, as we(! as any backfilling activities, will be completed using backhoes, loaders, compactors with plates, and/or picks and shovels, as appropriate.

Areas of th.e FVT where condensate may accumulate, such as the HEPA filter housing, silencer, and microstrainer, wil_l be drained on an as needed basis to remove condens.ate buildup. The drained water will be containerized and properly dispositioned. If radiological contamination is present, the liquid may be solidified with absorbent materials, and the resulting matrix may be packaged and disposed of a_t a radioactive landfill (e.g., LLBG, ERDF, e1c.) .. Al1ernatively, the liquids may be transferred to an approved container or tanker tru:ck (see Emission Unit 888) for transport to the Effiuent Treatment Facility (Emission Unit 301) or other facility licensed to receive radioactively contaminated liquids.

Roof Replacement Screening Surveys

Roof replacement activities include radiological surveys 10 determine if radioactive c_ontamination is present and the extent of such contamination. Spol contamination (e.g., bird droppings) managed before commencement of roof replacement work is handled per existing methods and is considered a routine housekeeping activity (similar to spot contamination found at ground levels).

Managing Radioactive Contamination for Roof Replacement

Contaminated roofing materials may be removed by manual or powered methods, including saws or other cu.t_t.ing devi.ce_s, shovels, wh~elbarrows. conveyors, chutes, or other similar equipment ( conveyors or chutes


may be used only for packaged radioactive waste or for non-contaminated roofing material). Radioactive waste shall be man·aged in accordance with ~xisting onsite requirements and waste acceptance criteria. Radioactive waste eithe_r shall be containerized in drums, skiffs, boxes, or other containers, or handled as bulk waste (e,g., dump truck) and transferred to the appropriate disposal facility. Management of radioactive contamination is allowed to include removal and subsequent size reduction of contaniinat_ed equipment from a roof as well as isolation and blanking of utilities, vents, and ductwork.

Accumulated rainwater that has contacted contamination areas shall be allowed to evaporate in place or is characterized, coilected, and managed in accordance with stormwater discharge requirements or transferred to an appropriate disposal facility.

A graded approach is allowed to be used to match controls with expected contamination levels per radiological control manuals and methods. Radiological contamination that is encountered wiU either be nianaged as a fixed contamination area (i.e., less than 20 dpm/100 cm2 smearable alpha and less than 1,000 dpm/100 em2 smearable beta) or will be managed as a contamination area (radiological contamination levels are between 20 and 2,000 dprn/100 cm2 alpha or between 1,000 and 100,000 dpm/100 cm2 beta) using appropriate controls to minimize worker exposure. These co_i:,trols i_nclude wat_er for dust suppression, fixatives, covers, windscreens, or greenhouses (with PTRAEU exhausters) that will be appl_i_ed, i_f needed, as determined by the Health Physics organization, and consist of ALARA techniques.

3) The PTE for this project as determined under WAC 246-247-030(2 l)(a-e) [as specified in the application] is 5.00E-02 mrem/year. Approved are the associated potential release rates (Curies/year) of:

Alpha -0 1.79E-03 Gas WAC 246-247--030(21Xa) 200 Area ·gaseous physical state assumed for purposes of conservatism relatlvo to assigned release fraction. Arn-241 used as conservative alpha emitter.

Alpha -0 1.30E-04 Gas WAC 246-247-030(21)(a) 300 Area •gaseo1.1s physical state assumed for purposes of conservatism relative to assigned release fraction. U-234 used as conservative alpha emitter. ·

Alpha - 0 7.26E-04 Gas WAC 246-247--030(21 )(a) 400 Area •gaseous physical state assumed l'o(purpciSe·s of conservatism relative to assigned release fraction. Pu-239 used as conservatlve alpha emitter.

Alpha -0 1.79E-03 Gas WAC 246-247--030(21)(a) 100 Area •gaseous physical state assumed for purposes of conservatism relative to assigned release fraction. Am_-241 used as conservative alpha emitter.

BIG -0 4.48E-02 Gas WAC 246-247--030(21)(a) 200 Area •gaseotJs physical state assumed for purposes of conserv.titlsm relative to assigned retease fraction. Sr-90 Us8d as conservative beta emitter. ·

B/G-0 4.48E-02 Gas WAC 246-247--030(21Xa) 300 Are'a ·gaseo1.1s physical state assumed for purposes of conser.iatlsm relative to assigned release fraction. Sr-90 used es conservative beta emitter.

BIG ,0 1.46E-02 Gas WAC 246-247-030(21 )(a) 400 Area •g;;iseotJs physical state assumed for purposes of conservatism relative to assigned release fractlon. Sr-90 used as conservative beta emitter.

B/G-0 4.48E-02 Gas WAC 246-247--030(21 )(a) 100 Area •gaseous physical state assumed for purpo_ses of conservatism relative to assigned release fradlon. Sr-90 used as conservative 8/G emitter.

The radioactive isotopes identified for this emission unit are (no quantities specified): Am-241 Co-60 Cs-134 Cs-137 Eu-152

Eu -154

Pu - 241

Th -232


Eu -155

Ru - 106

U-234

Pu - 238

Sb - 125

U -23_5

Pu - 239

Sn - 113

U -2_38

Pu -240

Sr - 90

The potential release rates described in this Con_dition were used to de_tennine control te<:hnologies and monitoring requirements for thi_s approval. DOE must not_ifiy the Depart_ment of a "_modification" to the emission unit, as defined in WAC 246-247-030(16). DOE must notify the Oepanment 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 theTEDE to the MEI after controls. (WAC 246-247-110(9)) DOE must notify the Department of any changes to potential release rates as required by state or federal regulations including changes that would constitute a significant modification to the Air Operating Permit under WAC 173-401-725(4). Notice will be provided according to the particular regulation under which notification is requi_red. Ifthe applicable regulation(s) does not addr_ess rnanner and type of notification, DOE'wiTI provide the Depanment with advanc¢ written n·otice by letter or electronic mail but not solely by ccipies of documents.

4) ABATEMENT TECHNOLOGY-EXCAVATION AND BACKFILLING-Wind Speed Limit All soil excavation activities operating under this NOC must cease operations when sustained wind conditions reach or exceed 20 miles per hour.-

5) REPORTING-WDOH Approved Log The facility must maintain a log in an approved fonnat for this activi_ty or emission unit. (WAC 246-247-080(7))

6) WOOH NOTIFICATION-Allowable Radionuclides The fol_lowing are th~ allowable radi~nudi_des: Co-60, S_r-90, Cs-137, Cs-134, Th-2_32, U-234, U-235, U-238, Eu-152, Eu-154, Eu-155, Ru-106, Sn-113, Sb-125, Am-241, Pu-238, Pu-239, Pu-240, and Pu-241. lfany other rndioriiiclides are suspected cir verified through soil analysis, the Depanment milst be notified.

7) RE_PORTING-Ann_ual Emission Lirni_ts The following are the aniiual emission limits for the NOC:

I00AREA: For FVT Cleaning/Excavation: 2.88E-3 mrem Sr-90, 3.4E-2 mrem Am-241 For Backfilling: .2.88E-6 mrem Sr-90, 3.45E-5 mrern Arn-241

200AREA: For FVT Cleaning/Excavation: l.96E-3 mrem Sr-90, 2.34E-2 mrem Am-241 For Backfilling: I .96E-6 mrem Sr-90, 2.34E-5 mrem Am-241

300AREA: For FVT Cleaning/Ex·cavatio"n: 3.9E-2 mrein Sr-90 8.3E-3 mrem U-234 For Backfilling: 3.9E-5 mrem Sr-90, 8.3E-6 mrem U-234

400AREA: For FVT Cleaning/Excavation: 8.5E-4 mrem Sr-90, 8.34E-3 mrem Pu-239 for Backfilling: 8_.5E-7 mrem Sr-90, 8.34E-6 mreni Pu-239. (WAC 246-247-040(5), WAC 246-247-060(5))

8) REPORTING-NOA on Fil_ter Change and_ Annual Gamma Spectros_copy DOE shall monito'r this prOject or emis.Sion un}t 3:5 follows:: In a.dP.i~i_on to the su_rveys desi:ri_bed i_n th.is NOC. periodic confinnatory· measiirements are required. This may include but is not limited to NOA testing of the HEPA filters when the HEPA filters are replaced and annually screening the HEPA filtration system using gamma spectroscopy. (WAC 246-247-075(8))

9) REPORTING-To_tal Comb_ined Dose to the Offsite MEI This emission unit is limited to an annual abated dose to the offsite.MEI of5.0 E-2 mrem/yr when combined with the abated offsite dose to the MEI for Emission Unit 1449 "Tank Fann Guzzler".



200

Tank Farm Guzzler Thi; is a MINOil, AC.TrvELY ventifatcd emission unit.

Tank Farms


Stack Height: 12.00 ft. 3.66m. Stack Diameter 0.75 ft.


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

Abatement Technology BARCT WAC 246-247-040(3), 040(4)


ZOne or. Area Abatement Technology


Cyclone Separator

Micro•strainer Device

HEPA Filter

Baghouse

Monitoring Requirements _ _ _

Re_<1uired # of Units

2

3

2

0.23 m.

Additional Description


Baghouse system with a total of 68 bags(i.e., 34 bags per baghouse).

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


40 CFR6l.93(b)(4)(i) & WAC 246-247-075(3)


40 CFR 61, App_endix.B Method l 14(3)

Radionuclides Requiring ~len~~~~men_t

Each radionuclide that could contribute greater than IO percent of the PTE TEDE 10

the MEI, greater than 0.1 mrem/yr PTE TEDE to the MEI, and greater than 25 percent of the TEDE to the MEI after controls.

SDn:ap_lJng Frequency

When the HEP A filters arc rcplac_ed an_d annually screening the HEP A filtration system.

Sampling Requirements Radia:tiOn surveys and to include bur nor limited to non destructive analysis testing of the HEPA .(i_lters and screening the HEPA filtration system using gamma spectroscopy.

Additional Roquiremonts

Additional monitoring or. sampling reQuirements established by this License will be listed in th8 Conditions and Limitations section, if applicable.

Operational Status The Guzzler portable emission unit is a completely self-contained vaCu_um used to support operations, such as but not limited to, \Yaste characterization, waste retrieval, decommissioning, deactivation, mairitenance, and conS:truction and operation support activities. The emission unit operates intcrminently.


Project Title Approval# Date Approved NOC_ID Guzzler Operation in Tank Farm Facilities (Rep_l_aced NOC 774) Not Approved 1064

Conditions (state only enforceable: WAC 246-247-040(5), 060(5) if not specified) I) The total abated emission limit for th_i_s Notice of Construction is limited to 2.00E-02 mrem/year to the

Maximally Exposed Individual (WAC 246-247-040(5)). The total limit on the Potential-To-Emit for this Notice of Construction is limited to 5.00E--02 mrem/year to the tvlax_imally Exposed Individual (WAC 246,247-030(21)).

2) This approval applies only to those activities described below. No add_i_tional activities or variations on the approved activities that constitute a "modification" to the emission unit. as d_efin_ed in WAC 246-247-030( 16),


may be conduc_ted.

The utilization of the Guzzler for excavation of soil and gravel within the 200 Area Tank Farm Complex. Activities shall include potholing for utility locations, and general soil/debris/gravel removal and excavation.

Backfilling activities shall be completed manually using shovels, backhoes, loaders, and packers.

3) The Annual Possession Quantity is limited to the following radionuclides (Curies/year):

Alpha - 0 2.40E+00 I Bet.a -0 3.00E+0I I Based on Am241 Based on Sr90+0

4) REPORTING-NOA on Filter Change and Annual Gamma Spectroscopy Aerosol testing and NOA of Guzzler HEPA filters shall be conducted annually per NOC 1072 or subsequent revision.

5) ABATEMENT CONTROL-Stop Work Trigger Health Physics Technician shall field survey every vertical and linear foot of excavation. The "Stop Work Trigger" is 10,000 cp_m per probe siz, (15cmA2-GM, P-11 Probe) beta-gamma and 20 cpm per probe size (50 cmA2-Portable Alpha Monitor (PAM)) alpha from direct contamination readings I cm above soi_! surfac_e.

6) CONT A.MINA TION CONTROL-Smear of Guzzler Exhaust HPT shall survey (smear) the Guzzler exhaust (discharge) at the end of each shift of Guzzler use.

7) RELEASE FRACTION EVALUATION-Initial and QuarterlyNOA Required A pre-ope_rational NOA of the HEPA filters will be required prior to use of the Guzzler pursuant to this license. Alternatively, a pre-operational NOA will not be required if the HEPA filters have no_t been used since the last NOA or the HEPA filters are new. An NOA of the HEPA filters will be required with every 90 calendar days of use within the 200 Area Tank Farm Complex. This 90 day period is defined as 90 calendar days past the first day the Guzzler is used within the 200 Area Tank Farm Complex. The Guzzler tracking log will track the accumulated PTE for this emission unit (EU 1449) annually, where ever it is used on the Hanford Site. The Guzzler tracking log will be required to track the accumulat_ed PTE based upC>n soi_! ccmtami_nation readings and adjusted ( only for operation under this approval) by the release fraction of I .0E-03.

Once the Guzzler is in use under this license an NOA is required prior to exit from use in the 200 Area Tank Farm Complex·to use elsewhere on the Hanford Site.

lfthe accumulated PTE, within t~.e 200 Area Tank Farm Complex, based upon the tra~king log reaches 0.025 mrern/yr, an additional NOA of the HEPA filters will be required and the 90 d:iy NOA cycle will begin again. If the accumulated PTE, within the 200 Area Tank Farm Complex, based upon the tracking log reaches 0.0375 mrern/yr, another NOA of the HEPA filters will be required and the 90 day cycle will begin again. If the accumulated PTE, within the 200 Area Tank Farm Complex under this license, based upon the tracking log reac_hes 0.05 mrem/yr, use of the Guzzi.er m_us_t stop for the.rema_inder of the c_alendar year.

After a year ofo·peraticiiis under these approval co_ndi_tions, an evaluation of the results shall be made available to the Deparunent to assess if the release fraction of I.0E-03 is conservative. A mi_nimum of four (4) NOAs is required for the evaluation.

8) WOOH APPROVAL-Release Fraction Verification Needed The request for approval for release fraction to be changed from I to I .0E-03 is approved and will be verifie_d as conservative using condition 7.

9) REPORTING-Limits on Emission by Use 200 Area Tank Farm Complex:

For Guzzler Excavation: I .60E-04 mrern/yr Beta based on Sr-90+O, 2.S0E-02 mrern/yr Alpha based on Am-241, 2.50E-02 mrem/yr total unabated dose and I .00E-05 mre_m/yr abat_ed dose_.

For Backfilling: I .60E-04 mrem/yr Beta based on Sr-90+O, 2.50E-02 mrem/yr Alpha based on Arn-241, 2.50E-02 mrem/yr total unabated dose and 2.00E-2 mrem/yr abated dose.

10) REPORT!NG'Total Combined.Dose to the Offsite MEI


This emission unil is liniiled to an annual abated dose ·10 the offsite MEI of 5.0 E'2 mrem/yr when coin.bined with lhe abated offsile dose to the MEI for Emission Unil 476 "Guzzler'""·

Page 3 of 3 for EU_lb 1449

Docket No:

STATE OF WASHINGTON DEPARTMENT OF HEALTH

ENVIRONMENTAL HEALTH PROGRAMS OFFiCE OF RADIATION PROTECTION

REQUEST FOR ADJUDICATIVE PROCEEDING

AJiprc)Val NO: AIR 16-1201

In Re The Appmval of/select the ap_prnpriate EU specific license):

O EU 476, NOC 1072- Hanford Sitewide Giizzler-001 (Replaced NOC 8_60)

0 EU 1449, NOC 1064 -G_uzzler Operation in Tank Fa_rm Faciiities (Replaced NOC 774)

THESTATE OF WASHINGTON TO: - - - -- - -- Mr. Kevin W. Smith, Manager

United States Department of Energy Office cif River Prci,tectlon P.O. Box 4!iO, MSIN: H6-60 Richland, Washington 9935

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

If you wish to request an adjudicative proceeding, .you or yotir anorriey miist COM_PLETE AN[) FILE THIS FO_13.M OR A DOCUMENT PROVIDING SUBSTANTIALLY THE SAME INFORMA T!ON WITH THE DEPARTMENT OF H.EALTH ADJUDICA TIVESERViCE UNIT WITHiN'1\VENTY-EIGHT (28) DAYS OF YOUR °RECEIPT of this Request for Adjudicative Proceeding fonn and a copy of the Office of Radiation Protection's approval, AIR !6-1201.

You must file your application in a manner 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 Olympia, WA 98504-7°879

With your application,-you must include a copy of the Office of Radiation Protection's approval.

HqNG SHA_LL NOT B_E DEEivl_ED COMPLETE UNTiL THE ADJUDICATIVE SERVICE UNIT ACTUALLY RECEIVES YOUR APPLICATION.

YOU HAVE THE RIGHT TO a fonnal hearing in this maner conducted pursuant io Revised Code of Washington (RCW) 43.70.115, Chapter 34.05 RCW, and Chapter 246-.10 of the Washington Administrative Code (WAC). Alternatively, you may waive the formal hearing and submit a written statement and supporting docum·ents setting out your position, your defenses,.and any mitigating circumstances that you wish to bring to the De_partment's attention.

You have the right to be represented by an ancirriey at your own expense.'

Request for Adjudicative Proceeding Pagelof4

I.

[ J I WILL BE represented by an attorney. His/her name, address, and phone number are:

Name:

Address:

Phone:

[ ] I WILL NOT BE represented by an attorney.

If after submitling this request, you obtain atlorney representation or change atlorneys, you mu.,t n_otify th_e Adjudicative Service Unit.

II.

I DO NOT waive my right to a formal hearing.

[ J I DO waive my right to a formal hearing. I.understand that ifl waive my fight to a formal hearing, the Department may decide this matter solely with reference to inforriiaticin in the Department's pos_session and to such written statements and supporting documents as I may have submitted.

If_you choose to waive yimr righ_t to a fonn_a_l hearing, p_lease complete the following:

I AM NOT submitting documents to the Department in support ofmy position.

1 AM subm_itti_ng a sworn statement and/or other documents to the Department in support of my position. I~~tructions - Please indicateyour responses below:

If you are submitting documents to the Departmen_t, please l_i_st and briefly identify all such documents in the space provided below and cin any a_d_diti_o_n~l sheet_ that may be necessary.

Request for.Adjudicative Proceeding Page 2 of4

Ill.

ADMISSION/DENIAL OF CONDITIONS OR LIMITATIONS

The Office of Radiation Protection's approval AIR 16-1201, dated December 7, 2016, contains conditions and limitations set out as numbere_d paragraphs. In the space belo_w you m_ust i_ndicatc, in g(!od faith, whe_tlicr you a_dmit, or do ·not contest, or deny the conditions or limi_tations. Conditions or limitations denied or not contested may later be admin_e:d. Co_nd.itions or li,:nil!ltions admitted oi- noi°contested· shail be concl_usively-deemed true for further proce_edings.

Instructions: I admit, deny, or do not contest the conditions or limitations as follows (fill in the appropriate_paragraph number):

Do Not Contest Paragraph __

Paragraph __

Paragraph __

Paragraph __

Paragraph __ -

Paragraph __

Paragraph ___ _

Paragraph __

Paragraph __

Please attach any add_itiona_l sheets tha_t m_ay be nece_ssary to resp(!n_d to a_ll allegations.

.l

[

If you have ch·oseri not to waive yo:ur righ_t_s t_o a formal h:ea,i_ng, p_l_ease s)ate al_! gro_uri_dsfor co_nte_sting th_i_s matter in the space provided below and on any additional she_e_ts that may be necessary.

Request for Adjudicative Proceeding Page 3 of4

IV:

You have the righ_t to an interpreter, appointed at no cost, if you are a hearing impaired person or limited English speaki_ng person. If any witness for you is a hearing impaired person or a limited English speaking person, an interpreter will be appointed at your expense.

I [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 APPLICA T!ON IN A TIMELY MANNER, OR iF YOU FILE YOUR APPLICA TlON TIMELY BUT FAIL TO APPEAR AT ANY sci-i"E.DULED SETTLEMENT CONFERENC-E, PREHEARING d)NFERENCE, OR HEARING WITHOUT LEAVE TO DO SO, THE DEPARTl'vi"ENT MAY DECIDE THIS MA TIER WITHOUT YOUR YOUR PARTICIPATION AND WITHOUT FURTHER NOTICE TO YOU.

DATED this ____ day of _________ _, ___ ~

Party

Party's Representative (if any)

WSBA #: --~--'----'--~

Request for Adjudicative Proceeding Page 4 of4

Item#

STATE OF WASHINGTON

DEPARTMENT OF HEALTH OFFICE Of RADIATION PROHCrlON

309 Br,d/ey Blvd., Suite 201 • Richland, Washing/on 99352

TDD Refoy Service: 1-1100-833-6388

January 17, 2017

!Vlr: Doug Shoop, Manager United States Department of Energy Richland Operations Office · P.O.-Box 550, MSIN: AS-14 Richland, Washington 99352

Mr. Kevin W. Smith, Manager Uriited States Department of Energy Office of River Protection P.O, Box 450, MSIN: H6-60 Richland, Washington 99352

Re: Final Approval ofNotice ofConstructioil (NOC) 1064

Mes_srs. ShcJOp and Srnith:

AIR 17-112 NOC1064

.. Putsuanno Chapter 246°247 of the Wasl:ii_ngto_n Administrative Code (WAC), your· update was approved January 9,2017, according to the enclosed license for.

Guzzler Operation in TankFal'II_I Facilities (Replaced NOC 774) (EU 1449; NOC 1064)

this NOC (I 064) wiH be used in conjunction with NOC 1072 (for EU 476) having a combined dose to the maximally exposed individual of 0.05 mrem/year per the license for:

Use of the Guizler (Filter Vacuum Truck) Vacuum Excavation System for Radiologically Limited Activities on the Hanford Site (Replaced NOC 860)

(EU 476, N()C 1072)

Note: Tlii.s NOC (1072) also includes tl,e applicab~e portiof!S (pertaining to Gual_er Use) of the previous NOC 838.

The conditions, controls, monitoring requirements, and limitations of this license must be observed in order for you to be in compliance wipi WAC 246-247. Failure to meet any provision of this li_cens_e may result in the revocation of approval, the issuance ofNotices of Violation, or other enforcement actions under WAC 246-247-100.

Public Health - Alw,1y5 Working fur a 5,til~r ;ind l·lc.1lth[er \Vashington

Messrs. Shoop and Smith January 17, 2017 Page 2 of2

AIR 17-112

If you have any questions regarding this draft approval, please contact, pl_ease contact Ernest McCorriiick [email protected] at (509) 946-0624 or Randy Utley [email protected] at (509) 946-0534.

Sincerely,

John Martell, Manager Radioactive Air Emis.sions Section

Enclosure: Conditions and Limitations for EU 1449 (NOC 1064)

cc: R11tli Al_len, WRPS Matthew Bari:tett, PNNL Lilyann Bauder, Ecology Shawna Berven, WDOH Lucinda Borneman, WRPS Lee Bostic, BNI Dennis Bowser, USDOE-ORP Frank Carleo, CHPRC Cliff Clark, USDOE-RL Jack Donnelly, WRPS Dennis Faulk,.EPA Eric Faust, USDOE-RL Gary Fritz, MSA Philip Gent, Ecology Robert Haggard, BNI Daniel Heu.ston, Ecology Jessica Joyner, WRPS Reed Kaldor, MSA Paul Karschnia, CHPRC Jim McA11ley, EPA Ernest McCormick, WDOH Bryan Trimberger, US.POE-ORP Ran_dy Utley, WDOH Jeff Voogd, WRPS Environmental Portal RAES Tracking: Line 16-206; EU 1449; NOC 1064

Emission Unil ID: 1449

200 Tank Farm Guzzler lhiS is o MINo:R. ACT.IVELX vcnlihncd emis.sion Uni1.

T11nk Farms

Emissio_n Unit Information

S1aek Height: 12.00 fi. 3.66m. S_tack Diameter 0.75 ft_

Average S_tack Effluent Temperature: 54 degrees Fe.hrcnheit 12 degrees Celsius.

Average.S1aek ExhaustVelocity: ft/se_corid. m/second.

Abatement Techn_ology BARCT WAC 246-247--040(3),040(4)


Zone or Area Ab!'lement Technology

Collection Tank and Plate S_eparato_r

Cyclone Separator

t-.'.f_i~ro-strai~~r Device

HEPA Filter

Baghouse


Required # of Units

2

J

2

0.23m.

A_ddltlona.l !}e_sc_riptlon

Three in-place tested HEP A filters in panlleL

Baghouse system with a total of 68 bag,(i.e., 34 bag, per baghousc).

state e_nforceable: WAC 246-247-040(5), 060(5), and federally enforceable_: 40 CFR 61 subpart H Federal and State

-- -Regulatory

- 40 CF_R 6L93(b)(4)(i) -- . ·& WAC 246-247,

075(3 )-•. ;~· -·,;- -··.1

Monitoring and Tts~irig RJiJ11fremeilts

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

R;ldion_uclldes Requiring Measurement

Each radionuclide that co_uld co_ntri_bute greater than I 0 percent of the PTE TEDE to the MEI, greater than 0.1 rrirem/yr PTE TEDE to the MEf and greaterthan 25 percent of the TEDE to the MEI after controls_.

Sampling Frequency

When tlie HEPA filters are replaced and annually screening the HEPA filtration system.

Sampling Requirements Radiation surveys and to include but nol limiled to non destructive analysis testing of the HEPA filters and screening the HEPA filtration system using gamma spectroscopy. -·

Addltlonal Requlrt1mo~

Additional monitoring or sampling requirements E!S_f?blished ~y D:iis ~icen_se wtll be llsted In the Conditions and Limitations_ ~n, If app~tll~.

Operational Status The Guzzler ponable emission unit is a co_mpletely self-contained vacuum used to suppon operations, such as bllt riot limited t~1 waste characterization, waste retrieval, decommissionirig, denctiyati_on, rriai_nt~imince, and construction and operation sueport activities. The emis.SiO:n uni_t ope~tes intenninently.

Thl_s Emission Unit has 1 acUve NoUce(s) of Construction.

Project Title Guzzler Operation in Tank Farm Facilitie_s (Replaced NOC 774)

Approval# AIR 17-112

Date Approved NOC _ID i/9/2017 1064

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

1) The total abated emission limit for this Notice of Construction is limited to 2.00E-02 mrem/year to the Maximally Expo~ed l_I)dividual (WAC 246-247-040(5)). The total limit on the Poteniial-To-E111it fort_!:iis Notice of Construction is limit_ed t_o 5.00E-02 mrem/year 10 the Maximally Exposed Individual {WAC 246-247-030{2!)).

2) This approval applies only to those activities described below. No additional activities or variations on the approved activities that constitute a "modification" to the e111_is_s{on unit, as defined in WAC 246-247-030(16), may

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be conducted.

The utilization of the Guzzler for excavation of soil and gravel within the 200 Area Tank Farm Complex. Activities shall include potholing for utility locations, and general soil/debris/gravel removal and excavation.

Backfilling activities shall be completed manually using shovels, bac_khoes, loaders, and packers.

3) The Annual Possession Quantity is limited to the following rodlonudides (Curies/year):

Alpha- a 2.40E+00 I Beta - o 3.00E+0l I Based on Am241 Based on Sr90+O

4) REPORTING-NOA on Filter Change and Annual Gamma Spectroscopy Aerosol testi_ng and NDA of Guzzler HEPA tilters shall be conducted annually per NOC I 072 or subsequent revision.

5) ABATEMENT CONTROL-Stop Work Trigger Health Physics Technician shall field survey every vertical and linear foot of excavation. The "Stop Work Trigger" is I 0,000 cpm per probe size ( I 5cmA2-GM, P-11 Probe) beta-gamma and 20 cpm per probe size (50 cmA2-Portable Alpha Monitor (PAM)) alpha from direct contamination readings 1 cm above soil surface.

6) CONTAMINATION CONTROL-Smear of Guzzler Exhaust HPT shall survey (smear) the Guzzler exhaust (discharge) at the end of each shift of Guzzler use.

7) RELEASE FRACTION EVALUA TrON-[nitial and Quarterly NDA Required A pre-operational NDA of the HEPA tilters will be required prior to use of the Guzzler pursuant to this license. Alternatively, a pre-operational NDA will not be required if the HEPA filters have not been used since the last NDA or the HEPA filters are new. An NDA of the HEPA filters will be required with every 90 calendar days of use w·ithin the 200 Area Tank Farm Complex. This 90 day period is defined as 90 calendar days past the first day the Guzzler is u_sed within the 200 Arca Tank Farm Complex. The Guzzler tracking log will track the accumulated PTE for this emission unit (EU 1449) annually, where ever it is used o_n th_e Hanford Site. The Guzzler tracking log will be required to track the accumulated PTE based upon soil contamination re_adings and adjusted (only for operation under this approval) by the release fraction of I.0E-03.

Once the Guzzler is in use unde_r this license an NDA is required prior to exit from use in the 200 Area Tank Farm Complex to use elsewhere on th_e Hanford Site.

If the ·accumulated PTE, within the 200 Area Tank Farm Complex, based upon the tracking log re·aches 0.025 mrem/yr, an additional NDA of the HEPA filters will be required and the 90 day NDA cycle will begin again. If the accumulated PTE, within the.200 Area Tank Farm Complex, based upon the tracking log reaches 0.0375 mrem/yr, another NDA of the HEPA filters will be required and the 90 day cycle will begin again. If the accumulated PTE, within the 200 Area Tank Farm Complex under this license, based upon the tracking log reaches 0.05 mremlyr, use of the Guzzler must stop for the remainder of the calendar year.

After a year of operations under these approval conditions, an evaluation of the results shall be made available to the Department to assess if the release fraction of\ .0E-03 is conservative. A minimum of four (4) NDAs is required for the evaluation.

8) WDOH APPROVAL-Release Fraction Verification Needed The request for approval for release fraction to be changed from I to I .0E-03 is approved and will be verified as conservative using condition 7.

9) REPORTING-Limits on Emission by Use 200 Arca Tank Farm Complex:

for Guzzler Excavation: I .60E-04 mrem/yr Beta ba_sed on Sr-90+D, 2.SOE-02 mrem/yr Alpha based on Am-241, 2.50E-02 mremiyr total unabated dose and I .OOE-05 mremlyr abated dose.

For Backfilling: I .60E-04 mrem/yr Beta based on Sr-90+D, 2.50E-02 mremlyr Alpha based on Am-241, 2.S0E-02 mrem/yr total unabated dose and 2.00E-2 mremlyr abated dose.

I 0) REPORTING-Total Combined Dose to the OfTsite MEI This emission unit is limited to an annual abated dose to the offsite MEI of 5.0 E-2 mrem/yr when combined with

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the abated offsite dose to the ME_! for Emission Unit 476 "Guzzler™".


Documents

OlfT' 1 Licensing File...file (be sure table of c'ontents prdvidesfdr final letter/license), final trans_mi_ttal lette_r, and final license to ef HP3 for final review. et..HP3 approves