STATE OF WASHINGTON DEPARTMENT OF ECOLOGY 3100 Port of Benton - Richland, WA 99354 - (509) 372~7950 711 for Washington Relay Service 0 Persons with a speech disability can call 877?833?6341 May 10, 2017 Mr. Doug S. Shoop, Manager Mr. Ty Blackford, President and CEO Riehland Operations Of?ce CH2M HILL Plateau Remediation Company United States Department of Energy PO Box 1600, MSIN: H7-30 PO Box 550, MSIN: A7-50 Richland, Washington 99352 Richland, Washington 99352 Re: Administrative Order Order Docket 14156 Site Location United States Department of Energy Hanford Site PUREX Tunnel 1 EPA/State ID WA7890008967 Dear Mr. Shoop and Mr. Blackford: The Department of Ecology (Ecology) has issued the enclosed Administrative Order requiring United States Department of Energy Richland Operations Of?ce and CH2M HILL Plateau I Remediation Company to comply with: 0 Chapter 70.105 Revised Code of Washington (RCW), Hazardous Waste Management Act. 0 Chapter 173?3 03 Washington Administrative Code (WAC), Dangerous Waste Regulations. - Hanford Facility Resource Conservation and Recovery [Act Permit, Dangerous Waste Portion Revision 8C WA 7890008967. If you have questions regarding this order please contact Ron Skinnarland, Waste Management Section Manager, at (509) 372-7 924 or ron. skinnarland@ecy. wa gov. Sincerely, MM Alexandra K. Smith Program Manager Nuclear Waste Program Enclosureszi Administrative Order By certi?ed mail cc: See Page 2 Doug S. Shoop and Ty Blackford May 10, 2017 Page 2 cc electronic W/enc: Dave Bartus, EPA Sheryl Bilbrey, EPA Jack Boller, EPA Lucy Edmondson, EPA Dennis Faulk, EPA Erny Laija, EPA Mark Macintyre, EPA Kim Ogle, EPA Kevin Schanilec, EPA Cheryl Williams, EPA Duane Carter, USDOE Cliff Clark, USDOE Al Farabee, USDOE Tony McKams, USDOE Julie Reddick, USDOE Allison Wright, USDOE Moses Jaraysi, David Richards, Jon Perry, MSA Ken Niles, ODOE Shawna Berven, DOH John Martell, DOH Caroline Cress, AGO Andy Fitz, AGO Randy Bradbury, Ecology Kathy Conaway, Ecology Suzanne Dahl, Ecology Jared Mathey, Ecology John Price, Ecology Darin Rice, Ecology Ron Skinnarland, Ecology Alexandra Smith, Ecology Cheryl Whalen, Ecology Correspondence Control Environmental Portal Hanford Facility Operating Record Correspondence Control cc W/enc: Rod Skeen, CTUIR Gabriel Bohnee, NPT Russell Jim, YN Susan Leckband, HAB Administrative Record NWP Central File Administrative Order Docket #14156 May 10, 2017 Page 1 of 8 STATE OF WASHINGTON DEPARTMENT OF ECOLOGY IN THE MATTER OF AN ADMINISTRATIVE ORDER ADMINISTRATIVE ORDER DOCKET 14156 AGAINST . UNITED STATES DEPARTMENT OF ENERGY AND CH2M HILL PLATEAU REMEDIATION COMPANY To: To: Mr. Doug S. Shoop, Manager - Mr. Ty Blackford, President and CEO Richland Operations Of?ce CH2M HILL Plateau Remediation Company United States Department of Energy PO Box 1600, MSIN: PO Box 550, MSIN: A7-50 Richland, Washington 99352 Richland, Washington 99352 Order Docket 14156 Site Location United States Department of Energy Hanford Site PUREX Tunnel 1 EPA/State ID 1 WA7890008967 The Department of Ecology (Ecology) has issued this Administrative Order (Order) requiring Department of Energy Riohland Operations Of?ce (USDOE-RL) and CH2M HILL Plateau Remediation Company to comply with: 0 Chapter 70.105 Revised Code of Washington (RCW), Hazardous Waste Management Act. Chapter 173-303 Washington Administrative Code (WAC), Dangerous Waste Regulations. 0 Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C WA 7890008967. Chapter 70.105 RCW and the Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C - Condition authorizes the Department of Ecology (Ecology) to issue Orders requiring compliance whenever it determines that a person has violated any provision of Chapter 70.105 RCW, or that one or more of the circumstances described in Condition exist. Ecology has determined that one or more Violations have occurred, and that at least one of the circumstances described 1n Condition II. Y. 2. exists, based on the facts provided below. Administrative Order Docket #14156 May 10, 2017 Page 2 of 8 For these reasons, and in accordance with RCW 70105095 and the Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C - Condition it is ordered USDOE-RL and take the corrective actions listed after each violation or circumstance. These corrective actions are required at the location known as Plutonium Uranium Extraction (PUREX) Tunnel 1 and 2 at the United States Department of Energy Hanford Site. Background: The PUREX Storage Tunnels, which are ?miscellaneous units? under Washington?s Dangerous Waste Regulations, are used for storage of mixed waste subject to the requirements of WAC 173-3 03?680. The two tunnels store waste from the PUREX Plant and other onsite sources. Since being placed into service, mixed waste has been stored in the tunnels on railcars, although not all material stored in the tunnels contains mixed waste. The construction of PUREX Tunnel Number-1 was completed in 1956. The tunnel is approximately 19 feet wide by 22 feet high by 358 feet long and provides storage space for eight railcars. Between June 1960 and January 1965 all eight railcar positions were ?lled and the tunnel subsequently was sealed. The combined volume of the equipment stored on the eight railcars presently in Tunnel Number 1 is approximately 780 cubic yards. The waste stored in the tunnels could include barium (D005), cadmium (D006), chromium (D007), lead 03008), mercury (D009), selenium (D010), silver (D011), and light mineral oil (WT02, state?only, toxic, dangerous waste) contained in oil absorption material. The silver is predominately in the form of salts and 18 considered ignitable (D001) because of the presence of silver nitrate Cadmium also could be considered state only, toxic, dangerous waste (WT02). According to ?An Evaluation of the Structural Integrity of PUREX Storage Tunnel 1, submitted by Westinghouse Hanford? Company in May 1991, ?In September 1990, a dangerous waste .permit application for the PUREX Storage Tunnels (DOE, 1990) was submitted to Washington State Department of Ecology by the United States Department of Energy Richland Operations Office.? The evaluation further states, ?On February 5, 1991, the State of Washington, Department of Ecology, issued a Notice of Deficiency (NOD) for the PUREX Tunnels Dangerous Waste Permit Application (Nerd, 1991). In the NOD, the Department of Ecology questioned the advisability of leaving dangerous waste stored in the Tunnel 1 in light of statement made by Silvan (1980) about the structural integrity of Tunnel To address the NOD, Westinghouse Hanford Company, the operating contractor responsible for the PUREX Storage Tunnel, requested Los Alamos Technical Associates to make an independent evaluation of the structural integrity of PUREX Storage Tunnel 1. The conclusions of the independent study were in part as follows: 0 Because of the interaction and dependency on other disposal actions taking place throughout the Hanford Site, none of the options studied can be accomplished in the near term. Disposal options included retrieving the waste for treatment and disposal and constructing a new facility for retrieving gamma processing and treatment of the waste for disposal. Administrative Order Docket #14156 May 10, 2017 Page 3 of 8 0 The study determined that the rate of loss of strength due to gamma radiation is diminishing with time so that even by the year 2001, the timber will still have 60% of its original strength. Therefore it was recommended that the dangerous waste in the tunnel remain as is and that if a decision for final disposition is not made by the year 2001, that the structural integrity again be evaluated in light of any then available information including any further tests on wood preservation that may have been completed at that time. As part of the Central Plateau Milestone Negotiations in summer of 2016 between the ?Fri-Party Agencies, a new milestone was created in response to public comment and State interest for Department of Energy to prepare a plan to address structural integrity of both PUREX Storage Tunnels and 2. Milestone: Lead Regulatory Agency: Ecology Milestone: Submit to Ecology as a secondary document a data quality objectives report to assess the structural integrity of the PUREX storage tunnels 1 and 2. Due Date: 09/30/2017 As of May 10, 2017 Ecology has provided comments to United States Department Energy on the draft Data Quality Objectives summaries for resolution. Based on the violations and circumstances described in this Order, Ecology is exercising its rights reserved under HFFACO Article XLVI, Paragraph 136, to require the Corrective Actions described below. 'Violations and Circumstances: Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C Condition II.L.1 Design and Construction of the Facility. ?The Permittees will design, construct, maintain, and operate the Facility to minimize the possibility of a ?re, explosion, or any unplanned sudden or non-sudden release of hazardous substances to air, soil, ground water, or surface water, which could threaten human health, or the environment.? Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C Condition LIE-.6 Duty to Mitigate. ?In the event of noncompliance with the Permit, the Permittees will take all reasonable steps to minimize releases to the environment, and will carry out such measures as are reasonable to minimize or correct adverse impacts on human health and the environment.? Administrative Order Docket #14156 May 10, 2017 Page 4 of 8 . Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C- Condition 1. E. 7, Proper Operation and Maintenance ?The Permittees will at all times properly operate and maintain all facilities and systems of treatment and control, which are installed or used by the Permittees, to achieve compliance with the Conditions of this Permit. Proper 'operation and maintenance includes effective performance, adequate funding, adequate operator staf?ng and training, and adequate laboratory and process controls, including appropriate quality assurance/quality control procedures. This provision requires the operation'of backup or auxiliary facilities, or similar systems only when necessary to achieve compliance with the Conditions of the Permit.? Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion RevisiOn 8C- Condition II. Y. 2. ?Notwithstanding any other condition 1n this Permit, Ecology may directly exercise any administrative or judicial remedy under the following circumstances?: ?Any discharge or release of dangerous waste, or dangerous constituents, which are not addressed by the HFFACO, as amended.? ?Discovery of new information regarding dangerous constituents or dangerous waste management, including but not limited to, information about releases of dangerous waste or dangerous constituents which are not addressed under the HFFACO, as amended.? determination that action beyond the terms of the HFFACO, as amended, is necessary to abate an imminent and substantial endangerment to the public health, or welfare, or to the environmen Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C Process Section 4.2.3, Extremely Hazardous Waste in Containers ?The present amount of mixed waste stored in the PUREX Storage Tunnels is suf?cient to characterize this material as extremely hazardous waste. Because the PUREX Storage Tunnels are enclosed totally, 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 and cannot be justi?ed under ALARA guidelines. Safe management of this waste is based on the following considerations. 0 The operation of the PUREX Storage Tunnels is passive, once a storage position is ?lled, the storage position remains undisturbed until closure.? Observations of Violations and Circumstances: USDOE and have not properly operated and maintained the PUREX Storage Tunnel 1 to achieve compliance with the Conditions of the Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision 8C. USDOE and have failed to keep the operation of the PUREX Storage Tunnel 1 undisturbed until closure of the dangerous waste management unit and failed to keep it totally enclosed with a protective covering from the elements and from run? on. Administrative Order Docket #14156 May 10, 2017 Page 5 of 8 USDOE and have failed to maintain and operate the PUREX Storage Tunnel 1 to minimize the possibility of an unplanned sudden or non-sudden release of hazardous substances to air, soil, ground water, or surface water, which could threaten human health, or the environment. On the morning of Tuesday May 9, 2017, during routine work activities in the vicinity of the PUREX Tunnels (200E), a partial subsidence was observed on the south side of PUREX Tunnel 1 at 8:06 am. At 8:09 am, an incident was declared and the Incident Command Post was populated with Mark Tews identi?ed as the Building Emergency Director. The Facility Emergency Response Organization was assembled at 8:09 am. A precautionary take cover was announced at 8:11 am. Inquiries were made and all staff were accounted for and there were no injuries. The area (N and gates) were secured at 8:19 am. An initial informational noti?cation was made to Ecology (Schleif) at 8:57 and. Although no release had been currently identi?ed, the RCRA Contingency Plan was implemented at 10:45 am. A bridge from the Incident Command Post to the Emergency Operations Center was requested and an Alert Classi?cation was declared at 8:26 am. Ventilation was shut off in building M0294 for the take The. Plutonium Finishing Plant shift of?ce was noti?ed for use of Talon robot to obtain photos and dose rate readings. Data indicated that there was not a release. The initial derived air concentration values represented the amount of radon related particles present in the sampled air. When they were counted later, the results fell below the instrument detection levels which is indicative that no release of radioactivity from Tunnel 1 occurred. A continuous monitoring plan is planned to be established for the surrounding area using the appropriate monitoring equipment. Visual observations, via photos, determined that there was a breach in the tunnel caused by failure of the internal structure. This breach left a 15?20 foot opening in the tunnel. Engineering evaluated the options below for stabilizing the event: 0 Covering the breach with'a tarp 0 Building a structure over the breach 0 Planned engineered ?lling of the hole with an undetermined amount of sand It was decided that the initial approach would be to ?ll the hole with sand and provide continuous monitoring. As of May 10, 2017, crews began ?lling the collapsed section of the tunnel. The hole is being ?lled with soil using heavy equipment. Approximately 50 truckloads of soil is expected to provide an additional level of protection against any potential contamination release. Radiological monitoring continues to be performed with no indication of release reported thus far. It is unknown how long it will take to complete thelwork, but it is expected to continue for several shifts. Administrative Order Docket #14156 May 10, 2017 Page 6 of 8 CorreCtive Action 1: Starting immediately, determine the cause of breach 1n PUREX Storage Tunnel 1 and assess if there is an immediate risk of further failures 1n PUREX Storage Tunnels 1 and 2. By July 1, 2017, submit to the Department of Ecology, Nuclear Waste Program a structural integrity evaluation for both PUREX Storage Tunnels 1 and 2. Corrective Action 2: Starting immediately, develop corrective actions to ensure the safe storage of the waste in the PUREX Storage Tunnels 1 and 2 in light of the above described failure in PUREX Storage Tunnel 1, until a decision on permanent disposition of the PUREX Storage Tunnels and 2 is determined as part of closure under the Dangerous Waste Regulations. By August 1, 2017, submit a draft report detailing the corrective actions to ensure the safe storage of the waste in the PUREX Storage Tunnels 1 and 2 to the Department of Ecology, Nuclear Waste Program for comment and approval. . Corrective Action 3: By October 1, 2017, submit a draft permit modi?cation to the Hanford Facility Resource Conservation and Recovery Act Permit, Dangerous Waste Portion Revision SC to modify the permit to do the following: - 0 Update Preparedness and Prevention Addendum to ensure the control and mitigation of run?on onto PUREX Storage Tunnel 1 and 2. 0 Update Process Information Addendum to include information required under Corrective Action 2 to demonstrate the ongoing ability of PUREX Storage Tunnel 1 to continue to safely store mixed waste until closure. This includes submitting as a part of the modification, the structural integrity evaluation supporting safe operation of PUREX Storage Tunnel 1. 0 Update the Closure Addendum. to include any interim actions needed for safe storage of waste in PUREX Storage Tunnel 1. - Updatethe Closure Addendum to address ?nal closure under the Dangerous Waste Regulations coordinated with the future CERCLA remedial decisions. Under RCW 34. 05.110, small businesses are eligible for a waiver of a first?time paperwork violation and an opportunity to correct other violations. Ecology has determined the requirements of RCW 34.05.110 do not apply to the violation(s) described in this Order because you are not a small business as defined in RCW 34.05.110 (9). Failure to comply with this Order may result in the issuance of civil penalties or other actions, administrative and/or judicial, to enforce the terms of this Order. Administrative Order Docket #14156 May 10, 2017 Page 7 of 8 You have a right to appeal this Order to the Pollution Control Hearing Board (PCHB) within 30 days of the date of receipt of this Order. The appeal process is governed by Chapter 43.21B RCW and Chapter 371?08 WAC. ?Date ofreceipt? is de?ned in RCW 4321130010). To appeal you must do both of the following within 30 days of the date of receipt of this Order: 0 File your appeal and a copy of this Order with the PCHB (see addresses below). Filing means actual receipt by the PCHB during regular business hours. 0 Serve a copy of your appeal and this Order on Ecology in paper form - by mail or in person. (See addresses below.) E-mail is not accepted. You must also comply with other applicable requirements in Chapter 43.2113 RCW and Chapter 371-08 WAC. Department of Ecology Department of Ecology Attn: Appeals Processing Desk Attn: Appeals Processing Desk 300 Desmond Drive SE PO Box 47608 Lacey, WA 98503 Olympia, WA 98504?7608 Pollution Control Hearings Board Pollution Control Hearings Board 1111 Israel Road SW . . PO Box 40903 STE 301 Olympia, WA 98504?0903 Tumwater, WA 98501 Please direct all questions about this Order to: Ron Skinnarland Department of Ecology Nuclear Waste Program 3100 Port of Benton Blvd. Richland, WA 993 54 (509) 372?7924 rski461@ecv.wa.gov Administrative Order Docket #14156 May 10, 2017 Page 8 of 8 0 Pollution Control Hearings Board Website 0 Chapter 43.21B RCW Environmental and Land Use Hearings Of?ce Pollution Control Hearings Board 0 Chapter 371-08 WAC Practice and Procedure 0 Chapter 34.05 RCW - Administrative Procedure Act 0 Chapter 70.105 RCW Hazardous waste Management 0 Chapter 173-303. WAC Dangerous Waste Regulations AlexandralK. Smith Date Program Manager Nuclear Waste Program