j? I I i United States Environmental Protection DEPARTMENT OF Agency ECOLOGY State of Washington June 26, 2018 . By certi?ed mail Mr. Doug S. Shoop, Manager Richland Operations Of?ce United States Department of Energy PO Box 550, MSIN: Richland, Washington 99352 Re: Items Needed to Lift the Washington State Department of Ecology (Ecology) and the United States Environmental Protection Agency (EPA) Creation of Danger Stop Work Pursuant to Article of the Hanford Federal Facility Agreement and Consent Order (HFFACO) References: See page 3 Dear Mr. Shoop: On January 9, 2018, Ecology and EPA issued a letter to the United States Department of Energy Richland Operations Of?ce (USDOE-RL) invoking HFFACO Article (?Creation of Danger?). The letter ordered all work to stop at Plutonium Finishing Plant (PFP) until Ecology and EPA notify of the regulatory agencies? determination that corrective actions taken and proposed are suf?cient to allow the remaining work at PFP to continue and that work may resume. As part of the invocation of Article of the HFFACO, Ecology and EPA requested information from USDOE-RL regarding the circumstances that created the danger at PFP. However, after evaluation of the information received, Ecology and EPA determined that additional information was needed in order to evaluate whether the Creation of Danger event at PFP has been adequately addressed, a prerequisite to lifting the stop work order. This information request was provided to USDOE-RL in an email sent on May 21, 2018 (Enclosure). As stated in the enclosure, prior to the restart of PFP demolition, Ecology and EPA need to receive items one through ?ve. Once those items are received and our reviews are complete, Ecology and EPA will lift the stop work order under Article for the Low?Risk Demolition as de?ned under Reference 2. Ecology and EPA would like to continue working collaboratively with USDOE-RL in project manager meetings to address any questions or concerns that our agencies may have regarding the enclosed requests. We note that the revised air model (Paci?c Northwest National Laboratory documents and PNNL-27456) relies on a number of assumptions about the controls that will be in place and how the remaining demolition work will be performed. Mr. Doug S. Shoop June 26, 2018 Page 2 of 3 We also note that for the higher risk work, the air model predicts that detectable levels of contamination will escape the controlled boundary. Given this, Ecology and EPA have two additional conditions: 1. The Removal Action Work Plan (RAWP) shall be amended to state that the assumptions in PNNL documents PNNL-27464 and PNNL-27456 will be adhered to, and any deviations must be approved in advance by Ecology; and 2. Any radioactive airborne or surface contamination found outside controlled areas at or above model predictions, posted levels, or EPA environmental levels will be immediately reported to Ecology and EPA. so they can evaluate whether to invoke a stop work and an assessment of the effectiveness of corrective actions documented in a Root Cause Evaluation Report. If Ecology and EPA invoke a stop work, USDOE-RL shall identify what additional measures (beyond those documented in the Root Cause Evaluation Report) can be implemented to prevent any further contamination outside the controlled boundary. The RAWP shall also be amended to include the provisions of this paragraph. Prior to the lifting the stop work order for the High Risk Demolition, Ecology and EPA require a brie?ng from USDOE-RL that includes: 1. An evaluation of the effectiveness of the corrective actions that have been implemented in the Resumption of Work Plan. 2. A high risk work package. 3. The lessons learned from the completion of the Low-Risk Demolition. After this brie?ng is completed, Ecology and EPA will evaluate whether to lift the Article Stop work for the High Risk Demolition. Our priority continues to be for the remaining work at PF to be completed in a safe manner for both the workers and the environment. If you have questions regarding this order, please contact Jim McAuley, Radiation Program Manager for EPA, at mcauleyiim?epagov or (206) 553-1987, or Stephanie Schleif, Facility Transition Project Manager for Ecology, at or (509) 372-7929. Sincerely, Alexandra K. Smith A 6-an Program Manager Manager Nuclear Waste Program Hanford Project Washington State Department of Ecology United States Environmental Protection Agency Enclosure By certified mail cc: See page 3 Mr. Doug S. Shoop June 26, 2018 Page 3 of3 References: 1. Ecology and EPA letter, dated January 9, 2018, ?Creation of Danger Pursuant to Article Hanford Facility Agreement and Consent Order Draft A, received May 15, 2018, ?Plutonium Finishing Plant Work Resumption Plan? cc electronic W/o enc: Dave Bartus, EPA Sheryl Bilbrey, EPA Jack Boller, EPA Craig Cameron, EPA Lucy Edmondson, EPA David Einan, EPA Emy Laij a, EPA Mark Macintyre, EPA Jim McAuley, EPA Kim Ogle, EPA Kevin Schanilec, EPA Cheryl Williams, EPA Cliff Clark, USDOE Eric Faust, USDOE Glenn Konzek, USDOE Tom Teynor, USDOE Allison Wright, USDOE Tom Bratvold, Bill Cox, Moses araysi, Jon Perry, MSA ERWM Staff, YN Ken Niles, ODOE cc w/enc: Administrative Record NWP Central File cc W/o enc: Matt Johnson, CTUIR Jack Bell, NPT Rose Longoria, YN Susan Leckband, HAB Caroline Cress, AGO Andy Fitz, AGO Koa Kaulukukui-Barbee, AGO Shawna Berven, DOH Mike Elsen, DOH John Martell, DOH Mathey, DOH Annie McLain, DOH Randy Bradbury, Ecology Jared Mathey, Ecology John Price, Ecology Darin Rice, Ecology Stephanie Schleif, Ecology Ron Skinnarland, Ecology Alexandra Smith, Ecology Brigitte Weese, Ecology Cheryl Whalen, Ecology Correspondence Control Environmental Portal Hanford Facility Operating Record MSA Correspondence Control USDOE-RL Correspondence Control