00139950^_ 9101780 , I Department of Energy e R It Richland Operations Office P.O. Box 550 Richland, Washington 99352 91-EAB-093 MAY 6 1991 MAY, 2 Mr. Charles E. Findley, Director Hazardous Waste Division U.S. Environmental Protection Agency 1200 Sixth Avenue Seattle, Washington 98101 01991 m Mr. Timothy L. Nord, Project Manager State of Washington Department of Ecology Mail Stop PV-11 Olympia, Washington 98504-8711 Dear Messrs. Findley and Nord: f` PUREX STORAGE TUNNELS PART B PERMIT APPLICATION (TSO: 5-2-1) ° This letter transmits a Notice of Deficiency (NOD) response table and associated proposed revised text addressing the thirty-eight NOD comments received from the State of Washington Department of Ecology (Ecology) pertaining to the PUREX Storage Tunnels Part B Permit Application. This transmittal fulfills Ecology's request that a NOD response table be submitted on or before May 6, 1991. ^.r _ -- If you have any questions regarding the enclosed NOD response table or associated proposed revised text, please contact Mr. C. E. Clark of the U.S. Department of Energy, Richland Operations Office on (509) 376-9333, or Ms. C. J. Geier of the Westinghouse Hanford Company on (509) 376-2237. Sincerely, ^,^k^g16i7^g7920 E. A. Bracken, Director ^ Q Environmental Restoration Division Richland Operations Office ERD:CEC `tE0£6Z Enclosures: 1. NOD Response Table 2. Proposed Text Revisions cc w/o encl.: P,. ,j„_r,.Qay, EPA R. E. Lerch, Manager Environmental Division Westinghouse Hanford Company ^ I No. 1. ! r k A ^ .^ `^ ^ THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 1 of 21 Comment/Response Concurrence Forward, page iii, line 14. The permit application states that storage of mixed waste is regulated under the Resource Conservation and Recovery Act of 1976. The handling and storage of mixed waste at the Hanford Reservation is also regulated by and will be permitted under the Dangerous Waste Regulations, Chapter 173-303 WAC. Ecology Requirement: Edit the text accordingly. DOE-RL/WHC Response: The text will be edited to include reference to the Dangerous Waste Regulations, Chapter 173-303 WAC. Proposed Revised Text: Forward, page iii. line 14 (revised). "Handling and storage of the mixed (dangerous and radioactive) or the nonradioactive portion of the waste associated with the equipment is regulated under the Resource Conservation and Recovery Act of 1976 and the Dangerous Waste Regulations, Chapter 173-303 Washington Admininstrative Code". 2. Forward. aage iii. line 37. Subpart X of 40 CFR 264 is referenced for a miscellaneous unit. The appropriate citation for the Dangerous Waste Regulations will be WAC 173-303-680, Miscellaneous Units. Ecology Requirement: Revise the text to refer to the Washington Administrative Code here and other instances as appropriate. DOE-RL/WHC Response: The text will be edited to include the cited reference to the Washington Administrative Code as appropriate. Proposed Revised Text: Forward, page iii, line 37 (revised). "In this Part A revision, the PUREX Storage Tunnels have been redesignated a miscellaneous unit (Washington Administrative Code 173-303-680)." Note: 3. Similar changes will be made throughout the permit application. Acronyms and Abbreviations, page vii. The section on Acronyms and Abbreviations is too brief. should be expanded to also include Definitions of terms subject to ambiguity (e.g., site vs. unit). It Ecology Reouirement: Expand this section accordingly. Refer to the 616 Nonradioactive Dangerous Waste Storage Facility Part B Permit Application for guidance. THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) Comment/Response No. DOE-RL/WHC Response: The Acronyms and Abbreviations section will be expanded to be similar to the A Definition Section, currently being developed for the Hanford Facility Permit. The PUREX Tunnels Part B definitions section, Section 1.4, will be developed in accordance with the content of the Hanford Facility Permit. Page 1-1, line 35. The permit application states that there are 17 railcars stored in Tunnel Number 2 as of January 1, 1990. On page iii of the Forward, the permit application is stated to contain information available as of August 31, 1990. It does not seem reasonable that the number of railcars in this tunnel would not be known on a more current basis. Ecology Requirement: State how many railcars are currently stored in the tunnels. Information regarding materials stored in these tunnels must be as current as possible. Revise the text as appropriate, here and elsewhere in the permit application. DOE-RL/WHC Response: The permit application will be revised to specify the number of railcars • stored in each of the tunnels as of January 1, 1991. Ecology will be notified of future increases or decreases in the number of railcars stored in the tunnels via the TSD facility annual dangerous waste report issued per WAC 173-303-390 (2). Proposed Revised Text: Forward, Page iii, line 35 (revised). "The PUREX Storage Tunnels Dangerous Waste Permit Application (Revision 0) consists of both a Part A and Part B permit application and is based on information as of January 1991." Note: Similar changes will be made throughout the permit application. Page 1-4, line 45. The permit application mentions clean closure. Ecology is current developing policy on closure standards for TSD units with mixed waste contamination. Guidance will be provided as soon as it is available. DOE-RL/WHC Response: The policy regarding closure standards for TSD units with mixed waste will be incorporated into the permit application as appropriate when it becomes available. This policy will be discussed in association with the development of the Hanford Facility Permit. Page 1-5, line 43. The permit application discusses permit modifications. The new version of the Dangerous Waste Regulations uses a different classification system for permit modifications and is considerably more extensive. Attachment 1 May 6, 1991 Page 2 of 21 Concurrence Attachment 1 May 6, 1991 Page 3 of 21 THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) Concurrence Comment/Resoonse No. Ecology Reauirement. Revise this section of the permit application so that it will be in accordance with the version of chapter 173-303 WAC which will be in effect at the time of permit issuance. DOE-RL/WHC Response: The permit application will be revised as requested. Proposed Revised Text: l.I1dULeI" 1 . U . 3eLL1U11 1 . 3 - rerllllL V I U UII I GdLIMu 1reV1dl:eS UIU SeCLIun 1.4 11CMu1119 SUUSeLL1UnS 1.4.1 and 1.4.2.1 "All modifications to the permit will be carried out in compliance with the requirements of WAC 173-303-830." 7. Page 2-3, line 16. Typographical Error: DOE-RL/WHC Response: "...and transite annex..." Permit application text will be corrected. Proposed Revised Text: Chapter 2.0. page 2-3. line 16 (revised). offices ,... " 8. "....storage galleries; and (3) an annex that includes Page 4-8, line 35. The permit application states that if a hazardous material were released from its container, "... no significant impact to the environment would occur." This statement is unsubstantiated. Ecology Requirement: Provide documentation supporting this statement in the form of a Safety Analysis Report or other equivalent document with the next NOD Response Table or delete this statement from the permit application. DOE-RL/WHC Response: Statement will be deleted from the permit application. 1 ^ i .e ! . A g 4 ^ ^ Attachment 1 May 6, 1991 Page 4 of 21 THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) Concurrence Comment/Resoonse No. Proposed Revised Text: Chaoter 4.0. Section 4.2.3 (revised). 4.2.3 Protection of Extremely Hazardous Waste in Containers [0-1c] The amount of elemental lead, elemental mercury, and silver salts stored in the PUREX Storage Tunnels is sufficient to characterize this material as extremely hazardous waste. Because the PUREX Storage Tunnels are totally enclosed, protective covering from the elements and from run-on is provided for the storage of extremely hazardous waste. Periodic inspection of the equipment stored in the PUREX Storage Tunnels is not feasible because of radiation levels in excess of 5 roentgen per hour. Safe management of this waste is based on the following considerations. 9. . The operation of the PUREX Storage Tunnels is passive. . The extremely hazardous waste is compatible with its storage container and the storage environment. Page 4-9. line 31. should be M-22-01. Typographical Error: DOE-RL/WHC Response: 10. Page 6-3. line 7. 11. Page 6-3, line 36. the correct milestone Permit application text will be corrected accordingly. Typographical Error: DOE-RL/WHC Response: Milestone M-21-01 does not exist; "These are..." should be "There are..." Permit application text will be corrected. The permit application mentions dangerous waste signs. Ecology Requirement: Describe these signs in detail. DOE-RL/WHC Response: A detailed description of the signs will be added to the permit application. ; 11., ' ; ' 7, THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 5 of 21 No. Comment/Response Concurrence Proposed Revised Text: Chaoter 6.0, Section 6.1.1.3 (revised) 6.1.1.3 Warning Signs [F-la(3)]. Warning signs are posted around the perimeter of the PUREX Facility. The signs are printed in English, legible from a distance of 25 feet, and visible from all angles of approach. Three types of signs are posted around the PUREX Facility and contain the following legends: • No Trespassing. . Warning. • Notice. By Order Of The United States Department Of Energy This Area Patrolled By Police Dogs All Persons-Vehicles Subject To Search For Prohibited Articles. Additionally, points of access to the PUREX Storage Tunnels are posted with the following warning signs: "DANGER Unauthorized Personnel Keep Out!" in accordance with the requirements of WAC 173-303-310(2)(a). The word DANGER is in large, white, block letters on a bright red background. The remaining lettering is black letters on a white background. 12. Page 6-3. line 37. Typographical Error: DOE-RL/WHC Response: "...are in tact, visible..." Permit application text will be corrected. Proposed Revised Text: Chapter 6.0. page 6-3, line 37 (revised). "The point of access is inspected to ensure signs warning of dangerous waste are intact, visible, and legible. 13. Page 6-3, line 42. The permit application states "...verification is conducted by observing an indicator light and a pressure differential gage located in the PUREX Plant operating records." This does not make sense; the instruments would not be located in the operating records. Ecology Reguirement: necessary. Clarify what was meant by the above quoted statement. DOE-RL/WHC Response: Permit application text will be revised. Revise the text as 3 ! ! ^ ` ' ` .a THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) No. Comment/Response Proposed Revised Text: 14. Chapter 6.0. page 6-3, line 42 (revised). "This verification is conducted by observing an indicator light and a pressure differential gage located in the PUREX Plant Power Control Room." Page 6-6, line 1. The permit application states that water will not be used for fire control at the PUREX Storage Tunnels. Ecology Reauirement: DOE-RL/WHC Response: application. Describe what fire controls measures would be used in the event of a fire. A description of fire control procedures will be included in the permit Proposed Revised Text: Chapter 6.0. Section 6.3.1.4 (revised). 6.3.1.4 Water for Fire Control [F-3a(4)]. The fire hazard associated with the operation of the PUREX Storage Tunnels is considered to be very low due to the minimal amount of combustibles stored within the tunnels and the lack of an ignition source (Rambosek, 1972). In the event of a fire in the storage area of the tunnels the contingency plan will be activated. Due to the leachable characteristic of the dangerous waste stored within the tunnels, water will not be used for fire control. Reduction of the air supply to the storage area by isolation of the tunnel exhaust system should permit the fire to self extinguish. Should the fire continue to propagate, heavy equipment and cranes will be called to the scene to cover areas of the tunnels that may collapse. 15. Page 6-6, line 43. Control of run-off is described, however, this description actually discusses run-on. Both run-on and run-off must be discussed. Ecology Reouirement: Revise the text accordingly. DOE-RL/WHC Response: on and run-off. Permit application text will be revised to provide discussions of both run- Attachment 1 May 6, 1991 Page 6 of 21 Concurrence THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) No. Comment/Response Prouosed Revised Text: The design of the PUREX Storage Tunnels included consideration and provisions for the control of run-on. Construction of both tunnels included the application of a moisture barrier before placement of the soil overburden. On Tunnel Number 1, 90-pound mineral surface roofing (tarpaper) was applied to the external surfaces of the structural timbers (top and sides). The roofing material was nailed in place with an overlap of approximately 4 inches at all joints and seams. All interior and exterior steel surfaces of Tunnel Number 2 were coated with a 35-mil bituminous, solvent coal tar base, coating compound. The coating was applied using a two-coat system, with each coat not less than 18 mils, ensuring a total dry film thickness of not less than 35 mils. The soil overburden covering the PUREX Storage Tunnels also is contoured to provide a side slope of 2 (horizontal) to 1(vertical). This construction serves to divert any seasonal or unanticipated run-on away from the storage area of the PUREX Storage Tunnels. Periodic inspections of the tunnel side slopes are conducted to ensure the contours remain in a condition that will preclude ponding and continue to divert run-on away from the tunnel storage areas. Further discussion of the design of the PUREX Storage Tunnels is provided in Chapter 2.0, Section 2.1.4. Run-off at the PUREX Storage Tunnels is controlled by the design features of the tunnels exterior which serve to divert run-on away from the interior of the tunnels. Additionally, all waste within the tunnels is stored well above the floor level on railcars. The control of run-on combined with the storage of all waste above the floor elevation provides adequate assurance that run-off will not occur at the PUREX Storage Tunnels. 16. Page 6-7, line 42. Tunnel 2. Ecology Requirement: Backup or redundant systems are not provided for the ventilation system in Provide information on the hazards due to failure of the ventilation system. DOE-RL/WHC Response: The discussion of the ventilation system for Tunnel 2 will be expanded to address hazards associated with failure of the system. Attachment 1 May 6, 1991 Page 7 of 21 Concurrence THE PUREX STORAGE TUNNELS PART 8 PERMIT-APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) No. Comment/Resoonse Proposed Revised Text: Chapter 6.0, page 6-7, section 6.4.4.2 (revised). Electrical power is required to operate the water-fillable doors and the ventilation fan in Tunnel Number 2. Backup or redundant systems are not provided, as failure of the equipment would not have the potential to result in a release of dangerous waste to the environment. 17. There are no hazards associated with the shutdown of the tunnel ventilation system due to loss of electrical power or as a result of a mechanical failure. Back-up or redundant systems are not provided as the system is operated only to maintain air balance and provide secondary control of radioactive airborne particulate. In the event the Tunnel number 2 ventilation system shuts down a reversal of airflow occurs, redirecting the airflow to the PUREX Canyon ventilation system. The PUREX canyon ventilation system is filtered and is equipped with a steam-driven emergency exhaust fan for back-up in the event of an electrical power failure. Page 6-8, line 9. A full faced respirator is mentioned. It is not clear if this is a supplied air or purifying air respirator. Ecology Requirement: Clarify what type of respirator is used. DOE-RL/WHC Response: Types of respirators used will be specified in the permit application. Proposed Revised Text: Chapter 6.0. page 6-8, section 6.4.5 (revised). .. a cloth cap and hood, and a full face air respirator equipped with a high-efficiency particulate air filter. Such equipment is also considered to be sufficient protection from the dangerous waste stored within the PUREX Storage Tunnels. 18. Page 7-1. line 14. USDOE/RL states that parts of the contingency plan serve to fulfill requirements other than Ecology's. Ecology agrees that sections of the documents not subject to regulation by Ecology should be excluded from the permit(s). Any part(s) of submitted documents not applicable to the permit application will not be adopted as part of the permit and therefore will not be subject to the modification requirements of WAC 173-303-830. Ecology Reouirement: Documents submitted for the permit which contain extraneous information should be accompanied by a cover letter indicating which chapter(s) or section(s) are applicable to the permit application, or, conversely, should be excluded. Attachment 1 May 6, 1991 Page 8 of 21 Concurrence 9! 1 . ! ^ 1^? ? THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 9 of 21 Comment/Resoonse No. DOE-RL/WHC Response: This comment will be resolved in accordance with the development of the Hanford Site Facility Permit. The PUREX Tunnels Part B will be revised in accordance with the content of the Hanford Facility Permit. 19 Page 11-1. line 38. The plan states that closure of the PUREX Tunnels will be performed in conjunction with the 200-PO-1 and 200-PO-2 operable units. Closure must be performed in compliance with WAC 173-303-610(4). Ecology ReQuirement: Revise the closure plan accordingly. DOE-RL/WHC Response: The closure plan will be revised to include the cited reference. Proposed Revised Text: Chapter 11.0. Section 11.0 ( revised). 11,0 CLOSURE AND POSTCLOSURE REQUIREMENTS [I] This chapter presents the closure plan for the PUREX Storage Tunnels. Closure will comply with WAC 173-303-610 regulations for the closure of dangerous waste facilities. The PUREX Storage Tunnels are used only for the storage of equipment and materials removed from the PUREX Plant. Detailed records are maintained of all materials (both dangerous waste and non-dangerous waste) which are stored within the tunnels. As a controlled storage unit with limited dangerous waste storage (lead, mercury, and silver salts), the PUREX Storage Tunnels are not anticipated to become extensively contaminated by dangerous waste (the use of the word contaminated refers to contamination by dangerous waste regulated by Ecology). All equipment and material stored at the waste management unit is stored in a retrievable manner on railcars; therefore, the closure approach will be clean closure. Consistent with the criteria that must be met to clean close a facility, no post-closure activities will be necessary. This chapter describes the performance standard that will be met and closure activities that will be conducted to achieve clean closure in accordance with WAC 173-303-610 requirements. 20 Page 11-1. line 46. The closure plan states that closure will take place after removal of the stored equipment and that the removal will be performed in conjunction with, "the final disposition of equipment from the PUREX Plant. A common equipment disposal method will be established as part of the PUREX Facility closure." Removal of the equipment is part of the closure of the PUREX Tunnels. Concurrence THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 10 of 21 No. Comment/Response Ecology Reouirement: Revise the text to accurately reflect the closure process. Note also that the PUREX Facility Part B Permit Application scheduled to be submitted in September 1992 must allow for removal of mixed waste from the tunnels to the canyon area and contain the proposed treatment discussed in this permit application's closure plan. DOE-RL/WHC Response: Chapter 4.0 will be revised to allow for the transfer of railcars into and out of the Tunnels as part of normal operations. Chapter 11.0 will be revised to indicate that closure will take place after all equipment is removed from the tunnels. The text will be clarified to indicate that removal of the equipment from the railcars and subsequent treatment will be addressed in the PUREX Plant Part B once details and engineering are available. Proposed Text Changes: Chapter 11.0'. Section 11.1 (revised), 11.1 CLOSURE PLAN [I-1] Because of the high radiation levels associated with the equipment stored within the PUREX Storage Tunnels, an engineering study (Appendix 11A) was conducted to evaluate different strategies for closure of the waste management unit. This engineering study considered two categories of disposal alternatives: (1) clean closure of the storage tunnels following retrieval of all stared equipment and materials, and (2) in situ disposal. The results of the engineering study indicated that the preferred course of action is clean closure, using the alternative involving the retrieval, processing in the PUREX Plant, and disposal at appropriate disposal unit. A no action alternative was not considered viable within the regulatory framework governing the disposal of the equipment. If clean up to background threshold levels is not achievable, then health-based standards derived from the Model Toxics Control Act (MTCA), WAC 173-340, will be evaluated for use as action levels. Concurrence THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) No. Comment/Resoonse The closure of the PUREX Storage Tunnels will occur following removal of all stored equipment that contains dangerous waste and following the determination that the waste management unit is no longer needed. A written notification will be submitted to Ecology at least 45 days prior to the initiation of closure activities. As presently envisioned, removal of the equipment stored within the PUREX Storage Tunnels will be performed in conjunction with the processing and disposal of the equipment presently in place at the PUREX Plant. An area within the PUREX Plant will be modified as required to locate, remove, and separate the dangerous waste from process equipment. This will reduce the volume of material which must be treated or stored as dangerous waste ^and allow for the disposal of the majority of the waste volume as non-regulated low-level radioactive waste. The liquid disposal systems and remote handling capabilities in place at the PUREX Plant will be used in preparing the process equipment for disposal. Closure of the PUREX Storage Tunnels will involve two phases. The first phase will ensure that the structure and associated components are not contaminated with dangerous waste. Decontamination will take place if contamination with dangerous waste is detected above background or regulatory thresholds and will continue until contamination is equal to or below background or regulatory thresholds. The second phase will entail sampling of the storage area and surrounding areas to verify that no contaminants above background or regulatory threshold levels are present outside the unit at closure. If contamination is still above background threshold levels, then health-based levels (acceptable to Ecology) will be used. Activities that are planned to achieve clean closure are presented in the following sections. 21. Page 11-2. line 42. The plan discusses clean closure requirements that are not equivalent to those of WAC 173-303-610(2). Ecology Reouirement: The closure requirements stipulated in WAC 173-303-610(2) must be met in order to clean close. See comment number 5. DOE-RL/WHC Response: The closure plan will be revised to reflect the closure requirement stipulated in WAC 173-303-610(2). Attachment 1 May 6, 1991 Page 11 of 21 Concurrence THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) No. Comment/Resoonse Proposed Revised Text: Chapter 11.0. Section 11.1.1. (revised). 11.1.1 Closure Performance Standard [I-1a] This section describes the performance and/or removal or decontamination standards to be applied to the PUREX Storage Tunnels. 11.1.1.1 Performance Standard [I-la(2)]. This plan has been developed to close the PUREX Storage Tunnels in a manner that meets the following closure performance standards of WAC 173-303610(2)(a). • Minimize the need for future maintenance. • Control, minimize, or eliminate to the extent necessary to protect human health and the environment, the postclosure escape of dangerous waste, dangerous constituents, leachate, contaminated run-off, or dangerous waste decomposition products to the ground, surface water, groundwater, or atmosphere. • Return the land to the appearance and use of surrounding land areas to the degree possible given the nature of the dangerous waste activities. The performance standards can be achieved through identification and evaluation of contamination based on soil baseline levels; health-based environmental standards; type, extent, and significance of contamination; and remedial action standards that provide for achievable cost and benefit protection of the environment and human health. Attachment 1 May 6, 1991 Page 12 of 21 Concurrence No. THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 13 of 21 Comment/Resaonse Concurrence In general, these standards will be achieved by removing, to background levels or regulatory thresholds, dangerous waste from the unit and decontaminating or removing all equipment, structures, soils, or other materials containing or contaminated with dangerous waste or waste residue. If background threshold levels are not obtainable then health-based, MTCA derived, standards will be used. 11.1.1.2 Removal or Decontamination Standard [I la(1)]. Prior to the initiation of closure, equipment containing dangerous waste will be retrieved for separation, processing, and treatment before disposal in an appropriate unit. Should decontamination be necessary, as determined by authoritative sampling, all materials contaminated with dangerous waste will be removed and disposed of [WAC 173-303-610(2)(b)]. Samples will be obtained from the gravel and soil materials from the floors of the tunnels to ensure that the environment has not been contaminated by the equipment storage operations. Should contaminants be detected above appropriate threshold, background or health-based values, the gravel and soil will be excavated to a depth where dangerous waste constituents are equal to or below the appropriate threshold values. Soil concentration levels will be established by soil sample analytical methods specified in SW-846 (EPA 1986) or an equivalent method. Background threshold concentrations and significance levels will be based on information including mean concentrations and variance for each constituent of concern. Specific approaches and the criteria and assumptions implicit in establishing concentration levels that constitute significant deviation from background or other control levels will be consistent with the outcome of background discussions currently underway with Ecology and the EPA. Background sampling will be done at the time of closure. 22. Page 11-4. line 7. Tunnels." The plan states, "No partial closure is anticipated for the PUREX Storage Ecology Reouirement. Discuss the statement with regard to the conclusion of.RHO-CD-1076 (September 1980, G. R. Silvan), which states an page 33, "if the contents of the tunnel must be removed, it should be deactivated as soon as possible to ensure the tunnel is still structurally sound during the removal operation." THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 14 of 21 Comment/Resoonse No. DOE-RL/WHC Response: Although no partial closure of the PUREX Storage Tunnels is anticipated, the structural integrity of Tunnel Number 1 has been questioned (Silvan 1980). To resolve this issue, an assessment of structural integrity is being conducted. Should the assessment of Tunnel Number 1 determine that closure of the tunnel is warranted, a partial closure of the waste management unit will be initiated. Closure of Tunnel Number 1, i.e. partial closure of the waste management unit, would not affect the operation of Tunnel Number 2. Closure of Tunnel Number 1 would be performed in accordance with the established closure plan. 23. Page 11-4, line 37. Minor modifications to the permit in accordance with WAC 173-303-830(4) to the permit are discussed. WAC 173-303-830 is being revised significantly in the next version of the Dangerous Waste Regulations. Ecology Requirement: Revise the text to be in accordance with the next version of the Dangerous Waste Regulations which will be in place at the time of permit issuance. DOE-RL/WHC Response: modifications. The text will be revised to address the most current requirements for permit Proposed Revised Text: Chapter 11.0. Section 11.1.3, (revised). 11.1.3 Maximum Waste Inventory [I-1c] The eight railcar capacity for Tunnel Number I was reached in January 1965. The combined volume of equipment stored on the eight railcars in Tunnel Number 1 is approximately 780 cubic yards. As of January 1, 1991, the combined volume of equipment stored on the 17 railcars in Tunnel Number 2 is approximately 1,780 cubic yards. Tunnel Number 2 has a maximum storage space of 40 railcars. Based on projections for future equipment storage, it is anticipated that another 16 railcars of equipment will be stored in Tunnel Number 2 before PUREX Plant closure. Concurrence 3 1 ! ^ ^' .+ ? THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) Attachment I May 6, 1991 Page 15 of 21 Comment/Response No. Concurrence Because of the limitations in projecting the types of equipment to be stored in the future and the amount to be placed on the railcars, the total volume of equipment in storage at any one time is uncertain. The maximum volume of waste to be stored within Tunnel Number 2 is estimated to be approximately 3,500 cubic yards. This estimate assumes the average volume of equipment presently stored on the railcars will be representative of the average volume of equipment on the 16 railcars anticipated to be placed in the tunnels in the future. Assuming the 16 railcars anticipated to be placed into storage contain the same fraction of mixed waste as the railcars presently stored in the PUREX Storage Tunnels, an additi,onal 4,220 pounds of lead, 1,100 pounds of silver, and 200 pounds of mercury will be placed into the tunnels. This will bring the maximum total inventory of mixed waste in storage in the PUREX Storage Tunnels to an estimated 14,000 pounds. 24. Page 11-5. line 37. The removal of the stored inventory is discussed. No mention is made of how it will be determined that no additional mixed waste exists in or on these failed equipment parts and railcars. Ecology Requirement: Discuss how it will be established that the inventory not known to contain mixed waste does not contain mixed waste. DOE-RL/WHC Response: Identification and separation of the mixed waste from the equipment will be addressed in the PUREX Plant Part B Permit Application when details become available. 25. Page 11-6, line 26. The plan states that a radiation survey will be initiated well in advance of PUREX Storage Tunnels Closure. Ecology Requirement: State when this investigation is scheduled to begin. as time frames for technology development. Include details such DOE-RL/WHC Response: The details associated with removal of railcars from the tunnels have been removed from Chapter 11.0 and added to Chapter 4.0. The reference to an overall radiation survey has been deleted. 26. Page 11-11, line 33. plans. The professional engineer certification is not consistent with other closure Ecology Reouirement: Revise the certification statements so that it is consistent with other closure plans. Refer to the 183-H Solar Evaporation Basins Closure Plan for guidance. DOE-RL/WHC Response: The closure plan certification statement will be revised to be consistent with the outcome of discussions associated with development of the Hanford Facility Permit. THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 16 of 21 No. Comment/Response 27. Page 11-12, line 33. The closure plan states that because this is a federal facility, the closure cost estimate is not required. Concurrence Ecology Reauirement: The application must state that closure cost estimates will be provided by October 1, 1991, and will be updated annually thereafter. These estimates are being required under the facility reporting requirements of WAC 173-303-390. At this time, Ecology is not requiring that these estimates be provided as part of the financial requirements under WAC 173303-620. However, these estimates must be provided in the same level of detail that is required for the purpose of the financial requirements. DOE-RL/WHC Response: The permit application will be revised to indicate that closure cost information will be provided as part of the annual reporting requirements of WAC 173-303-390. The schedule for initial submittal of projections of anticipated costs will be established as part of discussions associated with the development of the Hanford Facility Permit. Proposed Text Changes: Chapter 11.0. Section 11.4 (revised) .11.4 CLOSURE COST ESTIMATE [1-4] Closure cost estimates are not required for federal facilities as stated in WAC 173-303-620. However, projections of anticipated closure costs will be provided and updated in an annual report submitted to Ecology. 28. Paae 12-1. The Dangerous Waste Regulations are in the process of being revised. Ecology Requirement: Ensure that the reporting and record-keeping requirements of the new revision will be met. DOE-RL/WHC Response: reporting. The text will be revised to address the most current requirements for spill The rhquirements will be incorporated once they become available. 29. Page 12-4. line 32. Ecology is in the process of developing consistent spill reporting requirements. These requirements will be formally provided to USDOE/RL as soon as possible. any case, reports should be made to Ecology's Kennewick office, (509) 546-2977. Ecology Reouirement. Revise the contingency plan accordingly. In ^ . THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) No. Attachment 1 May 6, 1991 Page 17 of 21 Comment/Resaonse Concurrence DOE-RL/WHC Response: The permit application will be revised to reflect the latest spill reporting requirements agreed upon in discussions associated with development of the Hanford Facility Permit. The requirements will be incorporated once they become available. 30. • Appendix 7A. page 1. The emergency plan mentions DOE-RL Procedures Manuals. Ecology Requirement: Describe these manuals further. DOE-RL/WHC Response: DOE-RL procedures manuals will be described in the text. Proposed Revised Text: Appendix 7A. page 1. (revised). "...and Procedures Manuals, the WHC Emergency Plan (WHC-CM-4-1) and this document. The DOE-RL Procedures Manuals contains procedures for use by DOE-RL and contractor personnel for response to declared emergencies on the Hanford Site and affecting DOE-RL property and facilities. The DOE-RL Procedures Manual includes the following: o o o o o o o o o o o a Notification procedure for activation of DOE-RL personnel and resources Operation of the DOE-RL Emergency Center Operation of the Hanford Unified Dose Assessment Center Procedure for closure of the Columbia River Recovery, re-entry, and post accident operations procedure Bomb threat procedure Civil disturbances response procedure Terrorist threat response procedure Fire response procedure Extraordinary conditions response procedure (Weather Emergencies) Public Affairs and Joint Information Center procedure Emergency phone numbers listing. Copies of the existing ..." 31. Appendix 7A, page 3. Figure 1.b of the 200 East Area is illegible. No. THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 18 of 21 Comment/Resaonse Ecology Requirement: Provide a legible copy. DOE-RL/WHC Response: All figures in Appendix 7A will be reviewed. provided where needed in the next revision of the emergency plan. 32. Appendix 7A. page 14. Checklist. Ecology Requirement: Table. Concurrence Legible copies will be Document number WHC-IP-0603 is referenced on the Building Emergency Review Describe this document and provide a copy under with the next NOD Response DOE-RL/WHC Response: The Building Emergency Plan Review Checklist, form 54-6000-369, is a form used at the Hanford Site to record training completion at both hazardous and non-hazardous units. The two documents referenced on the checklist as WHC-IP-0263-( ), applicable to hazardous units, and WHC-IP-0603-( ), applicable to non-hazardous units, describe the type of emergency plan which is applicable and reviewed. Because the PUREX Facility is categorized as a hazardous unit, WHCIP-0603 is not applicable. Because WHC-IP-0603 is not applicable, further discussion is not considered appropriate. 33. Appendix 7A, page 16. The HMRT is referred to by acronym only. Ecology Requirement: Acronyms should be avoided in this type of document and the minimum should be spelled out in the first usage. DOE-RL/WHC Response: The text will be revised to define the acronym. revision of the Emergency Plan will include an acronyms list. Additionally, the next Proposed Revised Text: Appendix 7A. Section 3.02 (revised) In cases involving soil contamination, sampling must be performed to determine the lateral and vertical extent of contamination. The BED is responsible for coordinating onsite characterization activities which will be performed by Hanford Site organizations, and the Hazardous Material Response Team (HMRT) who are trained...... 34. Aonendix 7A, page 31. Ecology Requirement: DOE-RL Order 5484.1 is referenced. Provide a copy of this order. Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 19 of 21 Comment/Resoonse No. DOE-RL/WHC Response: (Attachment A). 35. THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION A copy of DOE-RL Order 5484.1 is attached to the NOD Response Table Appendix 7A, page 103. The emergency equipment list is incomplete and does not give the locations of the emergency equipment. (The referenced map is illegible). Ecology Response: Provide a comprehensive inventory with specific amounts and locations of equipment as required by WAC 173-303-350. DOE-RL/WHC Response: An emergency equipment list identifying specific amounts and locations of equipment will be incorporated into the emergency plan in the next revision. The requested inventory of emergency equipment is attached to the NOD response table (Attachment B). 36. General Comment. The MSDS states an Ecology reportable quantity. Ecology is currently developing a spill reporting policy. This will be provided to USDOE as soon as it is available. DOE-RL/WHC Response: The MSDS will be removed from the emergency plan. Reference will be made to the location of the MSDS files in the next revision of the emergency plan. 37. Appendix 11A, page 11. It is assumed that the closure activities for the PUREX Storage Tunnels will occur in conjunction with the closure activities for the PUREX Plant. This may be appropriate for Tunnel 2, but Tunnel 1 was found to be of adequate but questionable integrity in 1980. Ecology Requirement: Evaluate the assumption that both tunnels will be closed in conjunction with the PUREX Plant, Demonstrate that postponing closure of Tunnel 1 will not result is a more difficult closure due to failure of the timbers. Refer to the second paragraph of page 11A-16. DOE-RL Response: An assessment of structural integrity of Tunnel Number 1 has been initiated. Should the results of the assessment indicate unacceptable risk associated with continued operation of Tunnel Number 1, the tunnel will be closed. 38. Appendix 11A. Page 42. The weighting factors included in the evaluation of closure options do not accurately reflect the ordering cited in the text. For example, the text states, "Personnel protection was considered to be the most important item overall (ALARA evaluation and industrial health and safety) followed by compliance with the present regulatory framework." However, the weighting factors assigned were the same for ALARA evaluation and regulatory acceptability (4.0) and smallest overall for industrial health and safety (1.5). Furthermore, on page 11.A-56 it states, "determination of a preferred alternative will be based on regulatory acceptability..." Concurrence ) 9 No. 1 4 ^ , ' I n I : THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION Attachment 1 May 6, 1991 NOD RESPONSE TABLE (with Proposed Revised Text) Page 20 of 21 Comment/Resoonse Ecology Requirement: Correct those inconsistencies and the evaluation of closure alternatives to accurately reflect the stated criteria ordering. DOE-RL/WHC Response: Inconsistencies in the engineering evaluation will be corrected. Proposed Revised Text: Aapendix 11A. Section 5.1. (revised) 5.1 CRITERIA Eight disposal concepts for the equipment were considered for this study. An evaluation matrix was used to compare the alternatives and arrive at a preferred alternative for disposal of the equipment. The matrix consisted of seven criteria for comparison of the alternatives. The criteria are ALARA evaluation, regulatory acceptability, cost, potential for negative environmental impact (short-term), availability of technology, packaging/transportation feasibility, and industrial health and safety. Each criterion was assigned a weighting factor to indicate relative importance. Personnel protection was considered to be the most important item with an overall weighting factor of 5.5 [ALARA evaluation (4.0) plus industrial health and safety (1.5)]. Compliance within the present regulatory framework (regulatory acceptability) was considered the next most important. Potential for environmental releases, which can be remediated during the alternative, costs (capital and annual), technology availability, and packaging/transportation feasibility follow in order of importance. The following criteria and associated weighting factors demonstrate the importance of each criterion: Concurrence THE PUREX STORAGE TUNNELS PART B PERMIT APPLICATION NOD RESPONSE TABLE (with Proposed Revised Text) No. Attachment 1 May 6, 1991 Page 21 of 21 Concurrence Criterion Weighting Factor ALARA evaluation Regulatory acceptability Short-term environmental impact Costs Technology availability Packaging/transportation feasibility Industrial health and safety 6.0 4.0 4.0 3.5 3.0 2.0 2.0 1.5 CONCLUSIONS AND RECOMMENDATIONS In the proposed alternatives evaluation found in section 5.0, each alternative was ranked according to selected criteria. Table 9 summarizes the weighted scores for each alternative. Three alternative scores are ranked closely. The three highest ranked alternatives are in situ grout injection, retrieval/disposal in the PUREX Plant, and retrieval/process in the PUREX Plant. A comparison of these alternatives, according to the above mentioned criteria, is found below. The PUREX Storage Tunnels Part B Permit Application NOD Response Table (with Proposed Revised Text) ATTACHMENT A LI r U.S. DEPARTMENT OF ENERGY RICHLAND OPERATIONS OFFICE ORDER RL 5484.1 Copv 9-26-83 SU6JECT: ENVIRONMENTAL PROTECTION, SAFETY, AND HEALTH PROTECTION INFORMATION REPORTING REQUIREMENTS PURPOSE . To supplement DOE 5484.1, ENVIRONMENTAL PROTECTION, SAFETY AND HEALTH PROTECTION INFORMATION REPORTING REQUIREMENTS, of 2-24-81, and to assign additional requirements and responsibilities for implementation at the Richland Operations Office (RL). Additional reporting requirements are to be found in DOE 5484.2, UNUSUAL OCCURRENCE REPORTING SYSTEM, of 813-81; RL 5484.2, UNUSUAL OCCURRENCE REPORTING SYSTEM FOR RL, of 8-23-83; and DOE directives in the 5500 series concerning emergency planning, preparedness and response. 2. g^ CANCELLATION . a. MSI 78-6, Rev. 1, CONTROL OF POST-ACCIDENT EVENTS AT HANFORD, of 1215-78. b. RL 0502, NOTIFICATION, of 6-29-78. INVESTIGATION AND REPORTING OF OCCURRENCES, 3. SCOPE . The provisions of this Order contractors, and their subcontractors. 4. REFERENCES . are applicable to RL, RL .,.t ;r 5. a. Executive Order (E.O.) 12088, of 10-13-78, which ensures Federal compliance with applicable pollution control standards. b. DOE 5484.2, UNUSUAL OCCURRENCE REPORTING SYSTEM, of 8-13-81, which provides criteria for reporting unusual occurrences. CONTRACTOR NOTIFICATION REQUIREMENTS . A summary of RL contractor notification, investigation and reporting requirements applicable to this Order is included as Attachment 1. Alex G. Fremling Manager DISTRIBUTION: INITIATED BY: RL Office and Division Directors and Branch Chiefs All Contractors Safety and quality Assurance Division RL 5484.1 9-26?83 Attachment 1 Page 3 (through 6) SUMMARY OF RL NOTIFICATION..INVESTIGATION AND REPORTING REQUIREMENTS CHART (SEE HARD COPY) RL 5484.1 i (and ii) TABLE OF CONTENTS Page CHAPTER I- NOTIFICATION OF OCCURRENCES, RESPONSIBILITIES AND AUTHORITIES . 1. 2. 3. Safety and Quality Assurance Division . . . . . . . . . . . . . . . . .I-I Public Affairs Office . . . . . . . . . . . . . . . . . . . . . . . . .I-1 RL Contractors . . . . . . . . . . . . . . . . . . . . . . . . . . . .I-1 CHAPTER II - INVESTIGATION REQUIREMENTS. i IP 1. 2. 3. 4. 5. 6. 7. Manager of RL . . . . . . Chairman of the RL Board of Investigation Safety and Quality Assurance Division . . RL Program Division or Office . . . . . . RL Budget Division . . . . . . . . . . . . RL Financial Division . . . . . . . . . . Contractor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .II-I .II-1 .II-1 .II-2 .II-2 .II-2 . I I -2 CHAPTER III (Reserved ). CHAPTER IV - ENVIRONMENTAL PROTECTION, SAFETY AND HEALTH PROTECTION REPORTS CONTRACTOR REQUIREMENTS . ,., rN 1. 2. 3. Immediate Notification Requirements . Reports . . . . . . . . . . RL Coding Instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .IV-1 .IV-1 .IV-1 RL 5484 9-26-83 I-1 (and 1-2) CHAPTER I NOTIFICATION OF OCCURRENCES: RESPONSIBILITIES AND AUTHORITIES 1. SAFETY AND OUALITY ASSURANCE DIVISION (SQA) shall: a. Maintain duty officer system for 24-hour coverage. The SQA duty officer, upon notification of an occurrence by the Patrol Operation Center (POC) or contractor, will notify RL program divisions or offices in accordance with established procedures, and RL upper management as appropriate. b. Provide the RL Manager (MGR) with prompt and accurate information as to the severity of an accident and the type of investigation required. c. At the.direction of the MGR, send an RL representative to the scene to ensure that, consistent with the prevention of additional accidents, "freeze" the scene of the accident. prevent the disturbance of physical to the subsequent investigation. w- d. need for rescue, first aid, and all necessary steps are taken to The purpose of this action is to evidence which may be important At the direction of the MGR, notify the Office of Operational Safety, Headquarters (EP-HQ), on FTS 233-5555. The confirming teletype to EP-HQ will be prepared by SQA for the MGR's signature. ^ Copies will be provided to HQ offices as specified in DOE 5484.IA, Chapter II. e. Notify local, required. state, and Federal Agencies of the occurrence, when Notification shall be made on a case-by-case basis and shall be at the direction of the MGR. PUBLIC AFFAIRS OFFICE (PAO) shall prepare and release public statements on occurrences, subject to the approval of the MGR. In some cases this responsibility may be delegated to the event contractor. Such decisions will be made on a case-by-case basis, and are subject•to the approval of the MGR. RL CONTRACTORS shall, as a minimum, make oral notification to the appropriate RL program division or office, to PAO, and to SQA or the SQA duty officer as soon as it is apparent that an incident may meet the criteria of a Type A or B occurrence. Requirements for notification of these and other occurrences are specified in Attachment 1(See page 3 of this Order). RL 5484.1 9-26-83 CHAPTER II INVESTIGATION REOUIREMENTS 1. MANAGER OF RL . Following RL staff review of the Board of Investigation (Board) report, the Manager (MGR) shall: a. Provide a copy of the report, the Board recommendations and any additional recommendations to the responsible RL program division or office for action and followup through the appropriate Assistant Manager (AM). b. Provide copies of the report and all recommendations to the Safety and Quality Assurance Division (SQA), through the Assistant Manager for Safety, Safeguards and Quality Assurance (AMS), for transmittal to DOE Headquarters (HQ). fP tr 2. CHAIRMAN OF THE RL BOARD OF INVESTIGATION shall: a. Convene the Board, proceed with the investigation, and prepare the report to be transmitted to the MGR. The investigation will be conducted and the report will be prepared in accordance with ERDA 76-20, Accident/Incident Investigation Manual. _ b. Provide SQA with all backup material and its report for retention. relative to the investigation -.R 3. SAFETY AND OUALITY ASSURANCE DIVISION (SQA) shall: a. " Recommend to the MGR the classification of an occurrence and the type of investigation to be conducted. b. Recommend to the MGR the membership of the Board and its.Chairman for an occurrence to be investigated as a Type A or B. c. Prepare letters to the Chairman of the Board and to the event contractor for the MGR's signature, establishing the membership of the Board and special instructions. d. Prepare for the MGR's signature a memorandum transmitting the investigation reports and the Board's recommendations to HQ offices as specified in DOE 5484.1, Chapter II. e. Maintain the official file of correspondence initiated by RL relative to the report and corrective actions on the recommendations. 11-2 4. RL 5484.1 9-26-83 f. Distribute copies of the report to other RL contractors, the public reading room, and offsite as appropriate. g. Prepare a letter to EP-HQ for the AMS signature, officially closing the investigation file when all corrective actions have been completed. RL PROGRAM DIVISION OR OFFICE shall: a. Transmit the final report and appropriate/applicable recommendations to the event contractor for corrective action. b. Followup with the contractor to assure that corrective actions are adequate and complete. c. Provide SQA with a quarterly status report on the recommendations and officially notify SQA when all corrective actions have been completed. 5. RL BUDGET DIVISION shall identify as applicable and as available funds to support occurrence investigation and reporting requirements. 6. RL FTNANCE DIVISION shall provide the Chairman of a DOE Accidenz Investigation Board with a cost code for charging necessary investigation and reporting expenses. 7. CONTRACTOR shall: a. Investigate occurrences in accordance with DOE 5484.1 when directed by the MGR to conduct a Type A or B investigation. The investigation and report shall be in accordance with ERDA 76-20. b. Maintain a file of material report. ^ relative to the investigation and its RL 5484.1 9-26-83 IV-1 CHAPTER IV ENVIRONMENTAL PROTECTION, SAFETY, AND HEALTH PROTECTION REPORTS RL CONTRACTOR REOUIREMENTS 1. IMMEDIATE NOTIFICATION REOUIREMENTS . In addition to the notification and reporting requirements contained in Attachment 1(see page 3) of this Order, RL contractors are required to verbally notify responsible SQA environmental protection officials within 24 hours of becoming aware of any of the following occurrences: a. Any violation of applicable Federal, state, or local pollution control standards and requirements established pursuant to (but not limited to) the environmental protection statutes referred to in Section 1-102 of Executive Order 12088. b. Any noncompliance with the terms and/or conditions of an existing National Pollutant Discharge Elimination System (NPDES) permit, Prevention of Significant Deterioration (PSD) permit or any other environmental protection-based permit, or formal agreement with an applicable regulatory body. c. Any gaseous or liquid radiological effluent releases which exceed DOE requirements and/or contractor specific radiological release concentration guides. a" r _., 2. REPORTS . Following the 24-hour verbal notification of occurrences specified in paragraph I of this Chapter, an Unusual Occurrence Report will be submitted according to procedures in DOE 5484.2. 3. RL CODING INSTRUCTION . For those occurrences specified in Attachment 1 of this Order which require the completion of DOE F 5821.1 (Attachment 15 of DOE 5484.1), the following is to be used for completing SECTION 0 of the form. !^. a. Column 4 - Contractor alphabetical designations: Rockwell Hanford Co. - A Battelle - Pacific Northwest Laboratory - B Hanford Environmental Health Foundation - H J. A. Jones Construction Services Co. - J IV-2 RL 5484.1 9-26.-83 UNC Nuclear Industries, Inc. - D Westinghouse Hanford Co. - W b. Column 5 - Alphabetical designations for the main Areas: 100-B Area - B 200-E Area - E 100-D Area - D 200-W Area - W 100-F Area - F 300 Area - L 100-H Area - H 400 Area - T 100-K Area - K 600 Area - C 100-N Area - N 700 Area - A 1100 Area - S C? tf, ^-, c. Column 6 - Alphabetical designations for facilities within the main areas shall be designated by the operating contractor. d. Columns 7-9 - Three (3) spaces are allowed for map numbers. The map numbers shall be designated by each contractor and be within the assigned number series listed for release `*± points. e. ,, Maps should be 8 1/2 x 11" if possible. Columns 10-12- Each contractor is assigned release points as follows: a number series for UNC Nuclear Industries, Inc. 001 to 025 Battelle - Pacific Northwest Laboratory 026 to 075 Westinghouse Hanford Co. 076 to 150 Rockwell Hanford Co. 151 to 600 Other contractors will be assigned individual release point numbers as required by the Chief, Radiological and Environmental Safety Branch, SQA. The PUREX Storage Tunnels Part B Permit Application NOD Response Table (with Proposed Revised Text) ATTACHMENT B rn 10 ..^ FIRE EXTINGUISHERS Operations Inspection Frequency: Station Number Monthly L ocation Type PUREX Main Lobby by Door 60 Dispatcher's Office Central Hallway by Room 11 Central Control Room Behind Central Control Room (door) Halon Halon 10# ABC Halon Halon 5A Behind Central Control Room (backwall) Halon 6 7 8 9 10 11 12 13 Women's Change Room SWP Lobby by RPT Office Men's Locker Room West Switch Gear Room Maintenance Lunch Room Maintenance Shop Hallway Maintenance Shop Welding Crib 10# ABC 20# ABC 10# ABC Halon Halon 20# ABC 5# ABC 5# ABC aE" 14 Tool Crib Room 100 20# ABC r.. 15 16 17 18 19 20 21 22 Dock Gas Welding Cart Electricians Maintenance Shop Maintenance Building Upstairs 2714-A Building Paint Shack Service Blower Room Power Control Process Blower Room Power Control Room 104, ABC 10' ABC 10# ABC 10# ABC 20# ABC 10# ABC 10# ABC Halon 22A 23 Process Blower Room Dock (BBQ) Compressor Room Entry 5# ABC 104 ABC 23A Compressor Room Door North 109 ABC 24 25 25A 25B 26 27 28 29 30 31 32 33 33A 34 35 36 37 38 39 40 41 42 Compressor Portable (outside) Badgehouse Upper East Wall Badgehouse Upper AMS Badgehouse Lower AMS AMU Basement AMU 1ST Floor AMU 2ND Floor AMU 3RD Floor AMU Penthouse Upstairs Room 102B (hallway) Upstairs Room 105 (hallway) Computer Room 113 Computer Room 113A Lunch Room P & 0 Gallery Rack 62 P & 0 Gallery Rack 50 P & 0 Gallery Rack 44 P& 0 Gallery Portable Welder P & 0 Gallery Portable Gas Cart Exit Compressor Room (Col 26) P & 0 Gallery Rack 25 P & 0 Gallery Head End Door 10# BC Halon 10# ABC 10R ABC 10# ABC 10" ABC 104" ABC 10# ABC 20# ABC 10# ABC 10# ABC 10# ABC Halon 10# ABC 10# ABC 20# ABC 100 ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC I 2 3 4 5 c'! F.. FIRE EXTINGUISHERS Station Number - Location Type 43 44 P& 0 Gallery Drown Tank C-3A Lab Dock 10# ABC 10# ABC 45 46 Lab Lunchroom Hallway Lab Women's Locker Room 20# ABC 10# ABC 47 48 49 50 51 52 Lab Men's SWP Change Room Lab Hallway Room 60 Lab Counting Room 55 Sample Receiving #2 Lab Hallway Room 53 Lab Hallway Room 51 10# ABC 10# ABC Halon 10# ABC 10# ABC 10# ABC 53 Lab Supply Room 10# ABC 54 55 56 Lab Vent'Room East Entrance Lab Vent Room West Entrance Head End Battery Room Entrance 10# ABC 5# ABC 10# ABC Halon 57 Head End Control Room 58 Behind Head End Panel 10# ABC 59 East Switch Gear Room Halon 60 61 62 63 64 65 66 67 East Change Room East SWP Change Room East End A-Equipment Room White Room Canyon Lobby Sample Gallery Col. 2 Sample Gallery Col. 9 Sample Gallery Col. 18 10# ABC 10# ABC 100 DC 10# ABC Halon 10# ABC 10# ABC IN ABC 68 Sample Gallery Col. 24 10# ABC 69 Sample Gallery Col. 29 10# ABC 70 Sample Gallery Col. 34 10# ABC -a 71 72 U-Cell Entrance Sample Gallery Col. 39 IN ABC .10# ABC ^ 73 74 Sample Gallery Manipulator Shop PIV Room East End 10# ABC Halon PIV Room West End Storage Gallery by Elevator Storage Gallery Col. 24 Storage Gallery Col. 28 Upper Level Storage Gallery Col. 29 Storage Gallery Col. 33 Upper Level Storage Gallery Col. 34 Storage Gallery Col. 36 Upper Level Storage Gallery Col. 39 Storage Gallery East End Q-Cell Exit to Stairs Q-Cell Corridor Airlock Q-Cell Hood Maintenance Room Q-Cell AMU Hot Shop Lobby Hot Shop Hot Shop Hot Shop Halon 20# ABC 10# ABC 10# ABC 10# ABC 100 ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 20# A 20# BC f 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 90A 90B FIRE EXTINGUISHERS Station Number C'q 4•^ Location Type N-Cell Loadout Room N-Cell Lower Glovebox Room N-Cell Top of Stairs Upper Control Room Upper Glovebox Room PR Corridor N-Cell Lower Control Room PR Room L-11 Mezzanine Between LII and L10 N-Cell PR Elevator Penthouse R-Cell R-Cell ECMP East Crane Cab Foyer East Crane Cab 10# ABC 10# ABC Halon Halon 20# ABC 10# ABC Halon 10# ABC 10# ABC Halon 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# BC East Crane On Top Slave Crane 15# BC 10# ABC Slave Crane On Top WCMP West Crane Cab West Crane Cab Foyer West Crane Relay (Back Room) West Crane On Top Of Bridge 10# 10# 10# 10# 10# 10# West Elevator Motor Room 211-A Dock 8 211-A East Wall 10# ABC 10# ABC 10# ABC 113 114 115 116 117 118 119 119A 120 120A 121 121A 122 122A 203-A Pump House 203-A Control Room 206-A Door #1 RR Cut Storage Shed RR Cut Inside Tunnel Door RR Cut Inside Car Puller Motor Room M0-666 MO-666 H0-64-15323 (S&PM Trailer) HO-64-15323 (S&PM Trailer) MO-707 Inside (Maint. Engineering Tr) MO-707 Outside (Maint. Engineering Tr) MO-023 Kitchen (Misc Trailer) M0-023 Northwest Door (Misc Trailer) 10# 10# 100 10# 10# 10# 20# 10# 10# 10# 10# 10# 10# 10# 122B MO-023 Southeast Door (Misc Trailer) 209 ABC 123 124 124A 125 126 127 128 128A MO-035 MO-409 MO-409 2711-A 2712-A 213-A 291-AD 291-AD 10# 10# 10# 10# 10# 10# 10# 10# 91 92 93 94 95 96 97 98 99 100 101 102 102A 103 104 104A 105 106 106A 107 108 108A 108B 109 -..^ r^. 110 111 112 (Material Control Trailer) Northeast (Lab Trailer) Northwest (Lab Trailer) Outside Inside ABC ABC ABC ABC BC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC ABC BC ABC ABC FIRE EXTINGUISHERS Station Number Location Type 129 130 131 132 133 212-A 295-A ASD 294-A 292-AB Bottle Rack At Stack Building 292-AB North Door Inside Stack Bldg. 133A 20# BC 10# ABC 10# BC Halon 10# ABC 292-AB South Door Inside Stack Bldg. 134 135 Halon 293-A Airlock 293-A Upper Control Room 136 291-A Steam Turbine South Wall 10# ABC 10# ABC 137 291-AE 4th Filter Bldg. Front Entry 137A t^ <*+ f ra, 138 138A 139 140 141 142 10# BC 10# ABC 291-AE 4th Filter Building Back Exit 10# ABC 295-AB PDD 295-AB PDD Change Shack PR Dock Emergency Generator Inside Fence Emergency Generator Outside Fence 203-A Change Shack 10# 10# 10# 10# 10# 10# ABC ABC ABC ABC ABC ABC 143 206-A/RR Cut Change Shack 144 145 146 10# ABC PUREX Backside Change Shack RR/Cut Change Shack Outside Compound M0-405 SE Door 147 10# ABC 10# ABC 10# ABC MO-405 Kitchen 148 149 10# ABC MO-405 NE Door MO-405 NW Door 150 151 10# ABC 10# ABC MO-405 SW Door MO-405 Front Entry Airlock 152 153 154 155 156 157 158 159 160 161 162 163 164 10# ABC 10# ABC MO-347 NE Door MO-347 Kitchen MO-347 NW Door M0-355 NE Door M0-355 Kitchen M0-355 NW Door Training Trailer Training Trailer MO-273 East Bay East Wall MO-273 Front Door Entrance M0-273 West Bay West Wall MO-273 North Hallway M0-273 Kitchen 10# ABC 10# ABC 10# ABC Halon 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC 10# ABC FIRE HYDRANTS Operations Inspection Frequency: Hydrant Number 1A Monthly L ocation Across from 211-A (eastside) 2A East of Lab Dock #7 and Lab Trailer R3A 4A 5A Southeast Corner Backside of PUREX by Door 275 Eastend, Backside of PUREX Eastside of Building 213 R6A Westend, Backside of PUREX Westside of Building 213 7A Westend Backside of PUREX, across from 2712-A 8A R9A 10A Northwest end of MO-023, by steamline Westend Frontside of PUREX, next to water storage tank Front of 202-A, next to PUREX Badgehouse walkway «^FIRE DEPARTMENT CONNECTORS ^ Operations Inspection Frequency: Connector Number .-t I 2 3 4 5 6 Monthly Location FDC FDC FDC FDC FDC FDC at Badgehouse Riser 3 south of PR Dock" Riser 1 next to SWP Dock Foam System next to Door 75 next to Door 83 Laboratory Sprinkler System next to Door 174 SAFETY SHOWERS Operations Inspection/Test Frequency: Station Number ,.. Monthly Location 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 AMU AMU AMU AMU AMU AMU P&0 P&O P&O P&O P&0 P&O P&O P&O P&O 16 P&O Gallery Rack 7 17 18 P&0 Gallery Rack 3 Lab Hallway 19 Lab Hallway Basement (north) Basement (south) 1st Floor 2nd Floor 3rd Floor Dock (Bay B) Gallery Rack 62 Gallery Rack 55 Gallery Rack 48 Gallery Rack 42 Gallery Rack 35 Gallery Rack 32 Gallery Rack 26 Gallery Rack 21 Gallery Rack 15 20 Lab Supply Room 21 22 Lab Dock (outside door 102) White Room Column 9 23 White Room Column 5 24 25 Sample Gallery Column 3 Sample Gallery Column 7 26 Sample Gallery Column 11 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Sample Gallery Column 15 Sample Gallery Column 17 Sample Gallery Column 21 Sample Gallery Column 25 Sample Gallery Column 28 Sample Gallery Column 30 Sample Gallery Column 34 Sample Gallery Column 38 Sample Gallery Column 40 U-Cell Q-Cell Hood Maintenance Room Q-Cell AMU Hot Shop R-Cell 211-A Dock 211-A Sulfuric Tank 211-A Sulfuric Tank 211-A Dock 8 211-A Dock 8 211-A Dock 8 211-A Dock 8 211-A Tank 34 Neutralizer SAFETY SHOWERS Station Number .,^• "•6 ..^ Location Tank 1] Tank 12 Tank 20 Tank 21 Tank 40 Tank 41 Tank 42 Inside (northwest) Inside (southeast) Nitric Unload Station NAOH Station (truck pad area) NAOH Station (trench area) Outside East Wall Pump House Control Room Dock 10 (east) 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 211-A 211-A 211-A 211-A 211-A 211-A 211-A 211-A 211-A 211-A 215-A 215-A 203-A 203-A 203-A 203-A 65 203-A Dock 10 (west) 66 67 68 69 70 71 72 203-A by Tank P-4 206-A (inside Fractionator Bldg) 293-A Outside (west wall) 293-A Lower Control Room 293-AA (H202 Area) New PDD (not in service yet) 295-AC CSL EYE WASH STATIONS (PERMANENT) Operations Inspection/Test Frequency: Station Number t*^ Location I 2 3 4 5 6 AMU AMU AMU AMU AMU AMU Basement (north) Basement (south) 1st Floor 2nd Floor 3rd Floor Dock (Bay B) 7 Lab Hallway 8 Lab Hallway 9 Lab Hallway 10 11 12 13 14 15 16 17 18 19 Monthly Lab Supply Room Battery Charging and Storage Room Sample Gallery Column 3 Sample Gallery Column 30 Q-Cell AMU 211-A Inside (southeast) 215-A NAOH Station (truck pad area) 215-A NAOH Station (trench area) 293-AA (H202 area) New PDD (not in service yet) EYE WASH STATIONS (PORTABLE-GREEN UNITS) Operations Inspection Frequency: Monthly Pipefitter PM (2A24026) Frequency - empty and refill: yearly) Station Number 1 2 3 ^ Bi-Annual (twice Location Paint Shop Lab Vent Room (southwest end) PIV Room (cage) EYE WASH STATIONS (PORTABLE-SILVER UNITS) Operations Inspection Frequency: Weekly Pipefitter PM (2A24025) Frequency - empty and refill: Station Number I 2 3 4 5 Location Central Control Instrument Room Head End Instrument Room N-Cell N-Cell PR Room Monthly SELF-CONTAINED BREATHING APPARATUS Operations Bottle Pressure/Equipment Inspection Frequency: Operations Functional Test/Equipment Inspection Frequency: Station Number f^ \P` w.e Location 1 Main Hallway 2 Main Hallway 3 4 5 6 7 Main Main Main Main Main 8 Main Hallway Hallway Hallway Hallway Hallway Hallway 9 10 11 East Switchgear Room East Switchgear Room Lab Lunchroom Hallway 12 13 14 Lab Lunchroom Hallway N-Ce ll Upstairs Hallway N-Ce ll Upstairs Hallway Weekly Monthly EVACUATION BUSES Operations Start/Run Frequency: Weekly Operations Functional Test/Equipment Inspection Frequency: 200E Garage Class B Inspections: Yearly ^ ,.r ' •, aw. Monthly Bus Number Location HO-IB-01810 HO-1B-01817 HO-1B-01827 PUREX Front Parking Lot (west side of MO-273) PUREX Front Parking Lot (west side of MO-273) PUREX Front Parking Lot (west side of MO-273) AMU/211-A SPILL CONTROL STATIONS Operations Inspection Frequency ( plant operating): Weekly Operations Inspection Frequency ( plant down): Monthly Station Location Snill Control Station Contents AMU Basement AMU Ist Floor AMU 2nd Floor ■ Tyvek Acid Suit ■ Acid Type Goggles ■ Acid Type Gloves AMU 3rd Floor ■ Hazorb Pads 211-A ■ Polyzorb Pads ■ Disposable Bags AMU/21 1-A SPILL CONTROL CENTERS Operations Inspection Frequency (plant operating): Weekly Operations Inspection Frequency ( plant down): Monthly c' Station Location Sp ill Control Station Contents AMU AMU AMU AMU ■ Acid Spill Kit ■ Caustic Spill Kit ■ Solvent Spill Kit Basement 1st Floor 2nd Floor 3rd Floor 211-A ^. ^ 2-WAY RADIOS .... ^r^ Operations Test Frequency: Monthly Station Location Iylg Head End Control Room Desk Portable 1 1 Central Control Room Desk 1 Dispatch Office Desk Portable I 9 Q uantit y TEST EVACUATION/TAKE COVER SIRENS Operations Test Frequency: Monthly Tyoe of Siren Evacuation (steady) Take Cover (wavering) PAX CRASH ALARM Operations Test Frequency: Weekly Tyoe of Alarm Pax Crash Alarm (steady phone ring) C" P^• ra. SELF-ILLUMINATED "EXIT" LIGHTS Operations Inspection Frequency: Door Number F~^ N. IV% Monthly Location of Light 16 Compressor Room Door to P&O Gallery - Column 26 19 P&0 Gallery to Lab - Column 35 *167 240 238 Lab Mens SWP Room to Change Room Lab Vent Room Eastend Door Lab Vent Room Westend Door 27 Lab Vent Room from Crane Gallery *166 Lab Corridor East Airlock 102 Lab Airlock Door to Dock 6 173 174 Lab Door to Dock 5 Eastside - Outside Door Lab Storage Room to Dock 5 - Outside Door *168 125 Lab Womens SWP to Change Room Lab Airlock to Dock 7 - Outside Door 131 20 24 East Switchgear to Dock 7 East Switchgear to P&O Column 35 P&O Gallery to East Stairwell B-115 Storage Gallery Eastend *25 *271 263 331 B-175 B-4 *B-5 Mezzanine to East PRV East Change Room to South Stairs SWP Lobby to ECMP Stairs ECMP Door - Canyon Side Bottom of ECMP Stairwell - Outside Door Sample Gallery to SWP Lobby Stairwell Column 10 Sample Gallery to AMU Airlock Column 18 B-8 *B-47 Sample Gallery to Lab Stairs Column 31 Sample Gallery to East Stairwell B-49 Sample Gallery to West Stairwell 12 P&0 Gallery Column 10 39 501 Maintenance Lunchroom Hallway Westend Maintenance Shop - Outside Door 29 Tool Crib - Outside Door 505 525 509 43 no # 44 *143 142 no if 148 207 no if 69 B-14 B-113 236 no if 14 271-AB East Entrance - Outside Door 271-AB Upstairs East Hallway Door - Outside Door 271-AB Upstairs North Door - Outside Door West Switchgear Room Door - Outside Door Hallway to Door 44 SWP Lobby - Outside Door Supply Room Hallway Door Womens SWP Room to Supply Room Womens Change Room East Wall Main Lobby Door to Door B-60 2nd Floor by Conference Room - Outside Door 2nd Floor Hall to Door B-207 AMU First Level - Outside Door Basement AMU to Stairwell Storage Gallery by Elevator 2nd Level AMU by Elevator 3rd Level AMU by Stairs P&O Gallery Column 19 SELF-ILLUMINATED "EXIT" LIGHTS Door Number h^. 15 75 76 83 84 B-49 B-101 B-135 *B-149 *B-146 *B-104 B-120 B-119 B-138 B-133 201 *161 Location of Light P&O Gallery Column 22 Service Blower - Outside Door PROCESS BLOWER WEST DOOR - Outside Door PROCESS BLOWER EAST DOOR - Outside Door COMPRESSOR ROOM OUTSIDE DOOR - Outside Door Sample Gallery to West Stairwell Hot Shop Lobby to West Stairwell N-Cell Airlock--South Doors N-Cell Entrance--Inside N-Cell Entrance--Inside PR Corridor West Door By West R-Cell Door West Wall Eastside between N-Q-Cell Glovebox N-Cell Lower Control Room N-Cell Mezzanine WCMP to West Stairwell Canyon Lobby Inside ^ LEGEND: a.e *(xxx): door may not be numbered B-(xxx): door is below main floor level no #: no door # on door or floor plan EMERGENCY ACID SUIT LOCKERS Operations Seal Inspection Frequency: Monthly Operations Replenish/Reseal Frequency: Quarterly Locker Location Number of Lockers AMU Basement AMU 1ST Floor AMU 2ND Floor AMU 3RD Floor P&O - Column 24 P&O - Column 40 211-A LO f^ 203-A 206-A 293-A Q-Cell Sample Gallery Column 4 Sample Gallery Column 15 Sample Gallery Column 33 Emergency Acid Suit Locker Contents: ■ Complete Acid Suit with Hood £ ■ Full Face Shield ■ ■ ■ British Leggins/Rubber Boots Acid Type Goggles Acid Type Gauntlet Gloves emergency emergency emergency emergency emergency emergency emergency emergency emergency emergency emergency emergency emergency emergency EMERGENCY CABINETS Operations Inspection/Replenish Frequency: Quarterly Cabinet Locations 1. Lab Trailer MO-409 (outside/southside) 2. 3. 2714-A Chemical Warehouse (outside on dock) Across from the PR Dock (by steamline) Cabinet Contents f "4 Battery operated light Cyalume lightsticks, white (2 yr shelf life) Fire blanket in tote pack Radiation rope Yellow rope Acid suit Face shield Goggles (acid type) Acid resistant rubber boots Acid resistant rubber gloves Leather gloves Hazorb spill control pillows Polyzorb spill control pillows Sorbent material (kitty litter) Plastic disposable bags PCB gloves Masking tape Green tape Retractable knives Blank "Caution" sign Blank "Danger" sign Grease type pencil .-;. First aid kit (mostly bandages/check seal) List of phone numbers of persons to contact Quantity each package each roll roll each each pair pair pair pair each each gallon bundle pair roll roll each each each each each list Information List: A. Radiological Safety Kit has SWP and respirators located in MO-035. B. Bomb Search Kit has rope, tape, flashlights and copy of Emergency Plan, located in MO-035. C. Emergency SCBA's ■ Lab Hallway ■ East Switchgear Room ■ Main Lobby Area (mens change room hallway) ■ 211-A Building ■ 2711-A Building BOMB SEARCH KIT Administrative Inspection/Replenish Frequency: Quarterly Kit Location MO-035 Kit Contents Flashlights (with batteries) Bump hats h. C-* -- a Yi1 Gloves Maps Marking pens Mirrors (and extension handles) Crescent wrenches (for mirror adjustments) Spools of string Green tape Masking tape Ouantitv 6 6 6, pairs 6 sets 6 6 2 6 6 rolls 6 rolls EMERGENCY LANTERNS Covered on the following Electrical PM's: 2A22001 2A22058 2A22074 r^ h . ^^ -Monthly Annual Annual A CORRESPONDENCE DISTRIBUTION COVERSHEET Page 1 of 2 Author Addressee J. R. Bellomy, 6-1745 CE Findley, EPA Correspondence No. Incoming: 9101780 TL Nord, Ecology Subject: Ref #9152838 RESPONSE TO THE FEBRUARY 5, 1991, NOTICE OF DEFICIENCY FOR THE PUREX STORAGE TUNNELS DANGEROUS WASTE PERMIT APPLICATION (TSD: 5-2-1) INTERNAL DISTRIBUTION Approvat Date Name Location Correspondence Control A3-01 u/att PUREX / U03 Plant ^ ^. R. V. Bowersock 56-19 K. A. Hadley N1-35 D. G. Harlow 56-17 G. J. LeBaron S6-19 J. C. Midgett S6-15 R. C. Roal S6-08 M. L. Sullivan S6-19 ^! ENVIRONMENTAL DIVISION J. R. Bellomy H4-57 L. C. Brown H4-51 C. J. Geier H4-57 R. J. Landon B2-19 R. E. Lerch (Assignee) B2-35 S. M. Price H4-57 F. A. Ruck III H4-57 ..^ ^ Y. 54-6000-117 ( 9/88) (EF) WEF008 Distribution Coversheet 01991 I CORRESPONDENCE DISTRIBUTION COVERSHEET Page 2 of 2 Author Addressee J. R. Bellomy, 1945 CE Findley, EPA Correspondence No. Incoming:9101780 TL Nord, Ecology Subject: Ref # 9152838 RESPONSE TO THE FEBRUARY 5, 1991, NOTICE OF DEFICIENCY FOR THE PUREX STORAGE TUNNELS DANGEROUS WASTE PERMIT APPLICATION (TSD: 5-2-1) INTERNAL DISTRIBUTION ApprovaL Date Name Location u/att SAFETY. QUALITY ASSURANCE. AND SECURITY J. R. Bell R3-09 G. D. Carpenter B2-16 P D. G. Farwick H4-16 F` D. E. Good S0-97 J. W. Hagan 83-55 P. A. Praetorius S1-56 GENERAL COUNSEL C. K. DiSibio B3-03 B. D. Williamson B3-15 c''+ - -^ CONTROLLER E. P. Vodney B3-50 ENVIRONMENTAL AND WASTE MANAGEM E NT PROGRAM INTEGRATION cc: L. L. Powers 132-35 J. L. Waite B2-35 R. J. Bliss (Level I) V,EDMC/AR_ B3-04 .^J.H_4-22 JRB LB H4-57 JCM LB S6-15 Attachments same as letter #9152838 141AY ft 1 o,99, ^^PONc9fNCE.C^