a 1 1 ?auction DEPARTMENT OF AW ECOLOGY State of Washington January 9, 2018 Mr. Doug S. Shoop, Manager Richland Operations Of?ce United States Department of Energy PO Box 550, MSIN: H5-20 Richland, Washington 99352 Re: Creation of Danger Pursuant to Article Hanford Federal Facility Agreement and Consent Order . Reference: ?Plutonium Finishing Plant (PFP) Timeline of Contamination Spreads, Surveying of Areas and Workers, and Safety Controls?, Issued by CH2M HILL Plateau Remediation Company and Department of Energy Richland Operations Of?ce, December 20, 2017 Dear Mr. Shoop: This letter noti?es the United States Department of Energy - Richland Operations Of?ce (USDOE-RL) that the Washington State Department of Ecology (Ecology) and the United States Environmental Protection Agency (EPA) have determined that the recent contamination events at the Plutonium Finishing Plant (PF P) on the Hanford site are creating a danger to the health or welfare of the people on the Hanford Site and to the environment. Ecology and EPA are aware that USDOE-RL has stopped work at the PFP site at this time. However, given our determination, we hereby invoke Hanford Federal Facility and Consent Order (HF ACO) Article (?Creation of Danger?) and order all work at PFP to stop until Ecology and EPA determine that USDOE- RL has taken actions suf?cient to allow the remaining work at PF to continue and informs USDOE- RL that work may res.ume As provided by Article any dispute on this stop work shall be immediately referred to the Interagency Management Integration Team level of the appropriate HF ACO dispute resolution process. Summarynof Ev?ents: Ecology and EPA were noti?ed on December 14,2017, of a decision to stop work as a result of elevated radiation levels detected by air samplers worn by workers conducting PF demolition activities (reference). These workers were not in areas where respiratory protection is required. Mr. Doug S. Shoop January 9, 2018 Page 2 of 4 Elevated readings on these personnel .air monitors were detected on December 8, 9, and 12. The stop work directive based on these elevated radiation levels was lifted on Thursday, December 14, after additional surveys of trailers and vehicles resulted in no additional detections and the control area was extended. On Friday, December 15, demolition of the Plutonium Reclamation Facility (PRF) resumed. On swing shift, worker surveys following demolition of PRF found contamination at a stationary, passive monitoring point located northwest and outside established control areas. Subsequent monitoring found contamination on the hood of one vehicle, on a jersey barrier, on the stairs of an of?ce trailer, on a dumpster near an of?ce trailer, and near mobile of?ce trailers. No work occurred on Saturday, December 16. When work resumed on Sunday, December 17, CH2M HILL Plateau Remediation Company issued a stop work directive after noti?cation of the contamination discovered on December 15. Additional surveys were taken, and no additional contamination was found outSide the contamination area. The PRF demo1ition debris was covered with soil for stabilization and a ?xative was applied. On Monday, December 18, a second layer of soil and ?xative was placed on the PRF debris. Surveys on Monday found contamination on the hoods of cars and around and between mobile trailers at PFP. Ecology and EPA were noti?ed on December 18 that contaminated personal vehicles had been driven home over the weekend. By Tuesday, December 19, a total of seven contaminated personal vehicles that had been driven home were identi?ed. Contamination surveys were conducted at the seven homes. No contamination was found. As of January 3, 2018, Ecology and EPA understand that contamination is still being detected at passive monitoring points at PFP within control areas, indicating that the contamination has not yet been controlled. Determination: . Ecology and EPA agree that the events described above have created a'danger to the health or welfare of the people on the Hanford Site and to the environment within the meaning of Article of the HFFACO. Because of these circumstances, Ecology and EPA want to ensure the circumstances that created the danger are corrected before work at PF resumes. To that end, the two agencies request the following information from USDOE-RL no later than January 26, 2018: l. A description of the corrective actionsithat were developed as part of the causal analysis - for these events and those that were implemented. 2. A brie?ng summarizing these corrective actions. Mr. Doug S. Shoop January 9, 2018 Page 3 of 4 3. Records of both the Continuous Air Monitoring stations (CAMS) and surveys taken from November 1, 2017, to January 5, 2018. This should include alarm set points and calibration dates for CAMS. 4. Log books and/or Radiological Work Packages detailing contamination controls water, ?xative, and cover material) from November 1, 2017, to January 5, 2018. 5. Location and usage logs of water foggers for contamination control from NOVember 1, 2017, to January 5, 2018. 6. Lapel monitor readings from November 1, 2017, to January 5, 2018. 7. Bioassay Results to include: a. Dose, location, sample date, and result date. b. Dates that employees. were offered bioassays. c. Any d0se modeling done to account for delays from uptake to bioassay. 1 Once Ecology and EPA have a chance to review the requested documents, we will make an additional determination on whether these actions are suf?cient to allow the remaining work at PFP to continue. Ecology and priority is for the remaining work at PFP to be completed in a manner that protects both workers and the environment. If you have questions regarding this determination please contact Emy Laij a, Remedial Project Manager for EPA, at (202) 564-2724 or laij a.emerald@epa. gov or Stephanie Schleif, Facility, Transition Project Manager for Ecology, at (509) 372-7929 or stephanie.schleif@ecy.wa. gov. Sincerely, Alexandra K. Smith Laura Buelow Program Manager Acting Manager Nuclear Waste Program Hanford Project . Washington State Department of Ecology United States Environmental Protection Agency Hand delivered cc: See Page 4 Mr. Doug S. Shoop January 9,2018 Page 4 of 4 cc electronic: cc: Dave Bartus, EPA Sheryl Bilbrey, EPA Jack Boller, EPA Craig Cameron, EPA Lucy Edmondson, EPA Dave Einan, EPA Emy Laij a, EPA Mark Macintyre, EPA Kim Ogle, EPA Kevin Schanilec, EPA Cheryl Williams, EPA Cliff Clark, USDOE Glenn Konzek, USDOE Tom Teynor, USDOE Allison Wright, USDOE Tom Bratvold, Bill Cox, . MoSes Jaraysi, Jon Perry, MSA Rose erri, YN Jean Vanni, YN Ken Niles, ODOE Caroline Cress, AGO Andy Fitz, AGO Koa Kaulukukui-Barbee, AGO Shawna Berven, DOH John Martell, DOH Mathey, DOH Randy Bradbury, Ecology Edward Holbrook, Ecology Jared Mathey, Ecology John Price, Ecology Darin Rice, Ecology Stephanie Schleif, Ecology Ron Skinnarland, Ecology Brigitte Weese, Ecology Cheryl Whalen, Ecology Correspondence Control Environmental Portal Hanford Facility Operating Record MSA Correspondence Control USDOE-RL Correspondence Control Matt Johnson, CTUIR Jack Bell, NPT Rose Longoria, YN Susan Leckband, HAB Administrative Record NWP Central File