Cn OCT2119 s~#@ 4 2. To: (Receiving Organization) 3. From: …/67531/metadc718256/m2/1/high_re… · Project W-314 will restore zmd/or upgrade existing Double-Shell Tank (DST) System

Cn

OCT2119w ~ HIJG,NEERING DATAT17ANSIVIITTALPago 1 0+

s~#@ 4 l, EDT 624003

2. To: (Receiving Organization) 3. From: (originating organization) 4. Related EDT No. :

Distribution Tank Waste Retrieval N/A I6. Desi an Authori WI Desi9n A9ent/C.9. 7. Purchase Order No. :

=~’’’’’-”-- N/A. Iullel>ull ,., . .

,..., ,wtarks: 9. Equip. /Component No. :

formation and distribution N/A,.-.10. System/B(dg. /Faci lity:

N/A

11. Receiver Remarks: 11A. Design Baset i ne Document? [] ,,s [x] No 12. Major Assm. Dug. No. :

N/A13. Permit/Permit Application No. :

N/A14. Required Response Date:

I I 1

15. DATA TRANSM1TTED I (F) I (G) I (H)

(Al (c) (D) Approval Re=.n Ori.$

Item(E) Title or Description of Data “..,”. ‘or .a,or

[B) Do..nw”titwawing No. s; ;.:No.

Transmitted

rnitt.s ski..

1 HNF-3054 o Project W-314 E 1 1Environmental Permits.- . . . . .. . .. . . . I-)1 . .

-u._Receiw

er

1

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Aw...l D.$imz.r IF) Reason for Transrmttal [G) Oispo,ition (H) & (N

E, S, Q, D m NIA 1. Approval 4. Review 1. Approved 4. Reviewed nolcwnment

[see WHC-CM-3.5, 2. Release 5. Past-Review 2. Approved Wcormnent

Sec. 12.7)

5. Reviewed wlmxmnent

3. Information 6. Gkt [Receipt A.know. Rewired) 3. Disapproved wlcmnment 6. Rece#pt ack”owledLIed

DISTRIBUTIONor required signatures)

(G) (H) ,J, Name. . . . (K) Stgnat”’e (L) Date (M) MSIN

17. SIGNATURE/[(s.. Ammwd Desig”ato’ f

—---- .=— —ia.u19A!J!bzso @l -s/

21. DOE APPROVAL ( i f requi red)Ctr(. No.

$ r] Atm,cwedK, S. Toll s n

*##~ R’ti

7R. L. . .

?’&)

ion. e o T at Authorized Represe”tati.e Dated

,,O,igi”ato’ for Receiving Orwnizatio. Cognizant Manager

BD-7400 -172-2 (05/96) GEF097

,,;h& t./,& I ii firoved ./comnents

rl Di wmxoved wlconrnents

BD-74W1 72.1

Project W-3 14 Phase IApprovals Plan

Environmental

I. G. Pam. K. S. Tollefson. R. D. Potter. and R. L.

HNF-3054, Rev.

Permits and

TreatLockheed” Mart in Hanford Corporation, Ri chl and, WA 99352U.S. Department of Energy Contract DE-AC06-96RL13200

EDT/ECN : 624003 Uc : 721Org Code: 73600 Charge Code: 106454B&R Code: EW3130010 Total Pages: 5 q

Key Words: W-314, Environmental Permits, Tank Farm Upgrades.

Abstract: This document describes the range of environmental actions,including required permits and other agency approvals, for Project W-314activities in the Hanford Site’s Tank Waste Remediation System. Thisdocument outlines alternative approaches to satisfying applicableenvironmental standards, and describes selected strategies for acquiringpermits and other approvals needed for waste feed delivery to proceed.This document also includes estimated costs and schedule to obtain therequired permits and approvals based on the selected strategy. It alsoprovides estimated costs for environmental support during designconstruct on based on the prel imi nary project schedule provided.

and

TRAOEMARK DISCLAIMER. Reference herein to any specific crnnnercial pr.cduct, process, or service bytrade name, trademark, mu!nufacturer, or othermi se, does not necesssri 1y constitute or inpty itsendorsement, recwmendat i on, or favoring by the Uni tsd States Government or any agency thereof orits contractors or subcontractors.

Printsd in the United States of America. To obtain copies of this docunent, contact: DocunentControL Services, P.O. Box 950, Mai (stop H6-08, Rich Land UA 99352, Phone (509) 372-2420;Fax (509) 376-4989.

.,...m

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OATE WW!FORD 4

8TA’4

RELEASE ‘m

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Ref6ase’~ rova t Oate Rekease Stanp

Approved for Public Release

A-6400-073 (01/97) GEF321

HNF-3054, Rev. O

PROJECT W-314 PHASE 1 ENVIRONMENTALPERMITS AND APPROVALS PLAN

October 1998

Prepared for

Lockheed Martin Hanford CorporationRichland, Washington

981015.1132

HNF-3054, Rev. O

CONTENTS

GLOSSARY

1.01.11,1.11.1.21.1.31.1.41.1.51.1,61.2

2.02.12.22.32,3.12,3,22.4

3.03.13.23.33.3.13.3.23.4

4.04.14.24.34.3.14.3,24.4

5.05.15.25.3

5.3.15.3.25.4

NATIONAL AND STATE ENVIRONMENTAL POLICY ACTS ....................................2-1SUMMARY OF KEY MQUI~MENTS ...........................................................................2.lAPPLICABILITY TO PROJECT W-314 ACTIONS ..........................................................2.l

sATIsFYmG Applicable MQuIwMENTs ..............................................................2.2Recommended NEPA Approach ...........................................................................................2.2Recommended SEPA Approach ............................................................................................2.3PRELIMINARY SCHEDULE AND COST ESTIMATES ..................................................2.4

AIR QUALITY PROTECTION . .. .... .. . .. .......3-1SUMMARY OF KEY REQUIREMENTS AND PERMITTING PROCESSES ...............3-1APPLICABILITY TO PROJECT W-314 ACTIVITIES . 3-1SATISFYING APPLICABLE AIR QUALITY PROTECTION REQUIREMENTS .........3-1Available Altcmatives .........................3-1Recomendcd Approach .......................................................................................................3.2PRELIMINARY SCHEDULE AND COST ESTIMATE ....................................................3.2

RADIATION PROTECTION STANDA~SMONITO~G ..........................................4.lSUMMARY OF KEY REQUIREMENTS AND APPROVAL PROCESS ........................4-1APPLICABILITY TO PROJECT W-314 ACTIONS ..........................................................4.2

SATISFYING APPLICABLE RADIATION PROTECTION REQUIREMENTS ............4-2Available Alternatives ...........................................................................................................4.2Rccomended Approach .......................................................................................................4.3PRELIMINARY COST AND SCHEDULE ESTIMATES ..................................................4.3

DANGEROUS WASTE MANAGEMENT .........................................................................5.lSUMMARY OF KEY REQUIREMENTS AND PE~ITTNG ........................................5.lAPPLICABILITY TO PROJECT W.314 ACTIONS ..........................................................5.l

SATISFYING APPLICABLE DANGEROUS WASTE MANAGEMENTREQUIREMENTS ................................................................................................................5.lAvailable Altcmatives ..........................5-2Recommended Approach ..................... ..................5-2PRELIMINARY COST AND SCHEDULE ESTIMATES ..................................... . .. .. ...5-3

981014.1322 111

6.06.16.1,16.1.26,1,36,1,46,1,56,26,36.4

7.0

HNF-3054. Rev. O

CONTENTS (cent)

MISCELLANEOUS ASSESSMENTS, PERMITS, AND APPROVALS ..........................6-1SUMMARY OF KEY REQUIREMENTS AND PROCESSES ..........................................6.lCultwal/Ecological Resowce Review ...................................................................................6.lSite Location ..........................................................................................................................6.lExcavation Pemit ..................................................................................................................6.2American Indian Tribal Governmen tAgreements ................................................................6.2Endangered Species Act Compliance ....................................................................................6.2APPLICABILITY TO W-314 ACTIONS ............................................................................6.2SATISFYING APPLICABLE REQUIREMENTS .. .... .. ....6-2PRELIMINARY COST AND SCHEDULE ESTIMATES ..................................................6.3

APPENDICES

A ENVIRONMENTAL REQUIREMENTS CHECKLIST FOR PROJECT W-3 14 .................. APP A-i

B PROJECT W-314 PERMITTING APPROVAL SCHEDULE .................................................APP B-i

981014.1322 iv

HNF-3054. Rev. O

GLOSSARY

ALARAASIL

BARCT

CAACDRCERBCFRCx

D&DDCRTDNRDOEDOE-RL

DST

EAECOEcologyEDEEISEMPEPA

FDHFEMPFY

HLWHNF

ILAW

LAW

MAP

NAAQSNEPANESHAPSNOC

NOINRCNSR

as low as reasonably achievableacceptable soarce impact level

best available radionuclide control technology

Clean Air Act of 1977conceptual design reportcultural/ecological resource review

Code of Federal Regulationscategorical exclusion

decorrrmissioning and decontaminationdouble-contained receiver tankWashington State Depwtmcnt of Natural ResourcesU.S. Department of EnergyU.S. Department of Energy, Rmhland Operations Officedouble-shell tank

environmental assessment

environmental compliance officerWashington State Department of Ecologyeffective dose equivalentenvironmental impact statementenviromrrental monitoring planU.S. Environmental Protection Agency

Fluor Daniel Hanford, Inc.fstcility effluent monitoring planfiscal year

high-level wasteHanford Nuclear Facility (document identifier)

immobilized low-activity waste

low-activity waste

mitig,atlon action plan

National Ambient Air Quality StandardsNationcrl Environmental Policy Act of 1969National Emissions Standards for Hazardous Air Polhrtantsnotice of construction

notice of intentNuclear RegrrIato~ Conmrissionnew source review

981014.1322

PHMCPNNLPSD

QA

RCRAROD

SASAPSEPASPCSST

TAPsT-BACTT-SDTWRS

WACWDOHWFDWMHWMNW

981014.1322

HNF-3054. Rev. O

GLOSSARY (cent)

Project Hanford Management Contract

Pacific Northwest National Laboratoryprevention of significant deterioration

quality assurance

Resource Conservation and Recoveiy Act of 1976record of decision

(EIS) supplement analysis

sampling and analysis planState Environmental Policy Act of 1971special protective coatingsingle-shell tank

toxic air pollutantsbest available control technology for toxicstreatment, storage, and/or disposalTank Waste Remediation System

Washington Adrrrinistrative CodeWashington State Department of Healthwaste feed deliveVWaste Management Fcdeml Services of Hanford, Inc

Waste Management Federal Services Northwest

vi

HNF-3054, Rev. O

PROJECT W-314 PHASE 1ENVIRONMENTAL PERMITS AND APPROVALS PLAN

1.0 INTRODUCTION

This document describes the environmental actions, including required permits and other agency approvals,that affwt Tank Farm Restoration and Safe Operations (TFRSO), Project W-3 14, within the Hanford SiteTank Waste Remediation System (TWRS) Project. This document expands on the information presented inthe Waste Feed Delivery Environmental Permits and Approvals Plan (HNF-240 1). It also incorporates andreplaces the Permitting Plan for the Tank Farm Restoration and Safe Operations Project, Project W-3 14(WHC-SD-W314-EV-001). This document, hereafter referred to as the Project W-314 environmental plan,identifies applicable environmental standards, and describes selected strategies for acquiring permits andother approvals needed for Project W-3 14 desigdconstnrction. This plan also will be used in support ofoperational startup for upgrades to tank farm systems. Appendices provide a summary of permits/approvals,cost estimates, and schedule information for implementing the selected strategies.

1.1 PROJECT W-314 SCOPE OF WORK

The mission of the TWRS Project is to provide safe storage and management of legacy and new waste,retrieve and dispose of the waste, decornmis ion and decontaminate TWRS facilities and structures, and closeTWRS sites. The TWRS mission analysis report (HNF-SD-WM-MAR-O08) provides detailed informationconcerning the full scope of the TWRS Project, including the phased implementation approach andprivatization initiative for tank waste retrieval and disposal. Witbin the TWRS Project, Project W-314 wasestablished to provide major upgrades in the areas of waste transfer instrumentation and control, tankventilation, and electrical distribution for existing tank farm facilities. Project W-3 14 work will enable tankwaste to be stored, treated, and immobilized in an environmentally sound, safe, and cost-effective manner.

Project W-3 14 will restore zmd/or upgrade existing Double-Shell Tank (DST) System facilities to ensure that

the tank farm infrastructure will be able to support TWRS waste feed delivery requirements and continuedsafe management of tank waste. The capital improvements provided by Project W-314 will increase themargin of safety and reliability for DST System operations, and will aid in aligning affected tank farms to be

in compliance with applicable environmental regulations. Additional benefits will be realized subsequent toproject completion in the form of reduced equipment downtime, reduced health and safety risks to personnel,reduced operating and maintenance costs, and will minimize personnel exposure to radioactive and/orhazardous material. The full SCOPCof Project W-314 is detailed in the conceptual design report(WHC-SD-W314-CDR-001) and upgrade scope summary report (HNF-SD-W314-RPT-003).

Project W-3 14 work is divided into two phases. Phase 1 includes those scope elements necessary to support

the TWRS privatization initiative. Design requirements for Phase 1 address development, restoration, and

up~ades for the following key systems, structures, and components (SSCS) within the DST System

.

.●

981014.1322

Piping and transfer systems

Instrumentation and control systems

Facility structures.

l-l

HNF-3054, Rev. O

The tank farms included in Phase 1 scope are AN, AP, AZ, AY and AW. Phase 1 scope also incorporates anew 200 Errst Area waste transfer system, m well as upgrades and replacements to the existing master pumpshutdown (MPS) system.

This Project W-3 14 environmental plan addresses only the Phase 1 scope. Phase 2 scope supports futurewaste storage, retrieval, feed staging operations, and selected regulatory compliance upgrades. Anenvironmental plan will be prepared (or revised) at a future date to address Phase 2 work. The followingsections provide additional detail on Phase 1. This scope was used to evaluate the environmental permits,

approvals, and other compliance actions that will be required to proceed with Phase 1,

1.1.1 200 East Waste Transfer System Upgrades

Project W-3 14 will provide for comections from the 24 l-AN Tank Farm to the 241-AP, 241-AZ, and24 I-AY Tank Farms. The anticipated work scope is described in the Project W-314 Upgrade ScopeSummary Report (HNF-SD-W-314-RPTO03). Generally, the scope of work includes the following.

.

.

.

.

●

●

New Pipelines. Two new transfer lines will bc routed from the existing cross-site transfer lines(constructed under Project W-OSS). A slurry transfer line wdl be routed to tank 24 l-AN- 104 while asupcrrmtc transfer line will be routed to tank 241-AN-101. One new transfer Iinc will be routed fromtank 241-AN-104 to trrnk 241-AP- 104. One new transfer Iinc will be routed from tank 24 I-AN-1OI tothe new AZ valve pit Iocrrted just cast of tank 241-AZ-101. Two new transfer lines will be routed tlomthe new AZ valve pit to the AP Tank Farm: one of the lines will be routed to 24 l-AP valve pic the otherline will be routed to the high-level waste (HLW) interface point for the Private Contractor. All the newtransfer lines will be routed abovegrade, on an earthen bernr, around the existing east tarrk farms, andoutside the fences of the tank farms.

Cross-Site Transfer Line Tie-In. The new transfer lines will tie-in directly to the cross-site transferlines at a point west of the 244-A lift station. The new lines will extend the continuous leak detectionsystem installed in the cross-site transfer lines to the two end points in the AN Tank Farm. The cross-sitetransfer lines that currently ternrimrte at the 244-A lift station will be taken out of semice.

241-AN-04A Pump Pit. Work in this pit will provide a new pit leak detection system, replace nozzles,core drN existing cover blocks for the new pit leak detection system and drain valve operator, and repairthe special protective coating (SPC) on pit surfaces and the cover blocks as required.

241-AN-OIA Pump Pit. Work in this pit will provide a new jumper manifold with valve position

system, provide new pit rmd encasement leak detection systems, replace nozzles, core rfdl existing coverblocks for the new pit leak detection systcm rmd drain valve operator, and repair SPC on pit surfaces andthe cover blocks as required.

New AZ Valve Pit. Work will include constructing a new pit and cover blocks, providing a newjmnpermrmifold to connect all the new transfer lines entering and exiting the pit, installing a stainless steel linerand pit drain for the pit, rmd providing new pit and encasement leak detection systems and spare nozzles.

241-AP Valve Pit. Work in this pit will provide rrnew valved jumper correcting into the existingjumper manifold, a new pit leak detection system, replace nozzles, comect existing position switches tothe new MPS system, and provide new position sensors for the new valves.

981014.1322 1-2

HNF-3054, Rev. O

. MPS System Interface. All new leak detection systems and all new valve position systems installed byProject W-3 14 will be fcd into the MPS/lwman machine interfaces (HMI) system.

1.1.2 MPS System

The existing MPS system will be replaced with a programmable logic controller (PCI)/HMI-based system.

Work will include providing tbe following major systems and components:

. Six PLCnetworknodes

. 10 HMIs(hwdware andsoftware)

. Terminal boxes cormectedto field located devices

. Oneinput/output boxtoconnect SYfarminputstoa PLC

. Anethemetnetwork toimpIement PLC-to-PLC mdHMI-to-HMI networks

. Underground signal cabling between tank farm terminal boxes

. 30 transfer pump interlock relays to implement transfer PUMP shutdowm.

Tbe MPS system will provide transfer flexibility, increased reliability, and expandability to accommodatefuture system needs.

1.1.3 AN Valve Pit Upgrades

The scope of work for the AN valve pits includes jumper/valve manifolds with position sensors, new pit andencasement leak detection systems, new cover blocks, electrical upgrades to snpport the instrumentation, andrepairs to SPC on pit surfaces as needed. Specific work includes the following.

.

.

.

.

Decontaminating and Snlid Waste Removal. Project W-314 will decontaminate valve pits as requiredto allow entry in support of construction activities, Solid waste (e.g., jumpers) will be removed rmdpackaged for disposal.

Piping Systems. Project W-3 14 will provide newjumper/valve manifolds and new flush line nozzles in241-AN-A and -B valve pits.

Instrumentation and Control Systems. Project W-3 14 will provide new pit leak detection systems for241-AN-A and -B valve pits, and replace the encasement leak detection system for 3-irrch SN-268-M25with new systems. Project W-3 14 will provide valve position systems for all the valves installed as part

of the jmnper/valve manifolds in241 -AN-A and –B valve pits (excludes drain valves). Project W-314will provide electrical power for new leak detection systems, and connect flush line pipe stubouts to theexisting cathodic protection system. Leak detection and valve position signals will be connected directlyto the new MPS system.

Structures. Project W-3 14 will provide new cover blocks for 24 l-AN-A and –B valve pits. The newcover blocks will be provided with penetration for the manifold valve operators, pit leak detectionsystem, gas sampling ports, and inspection ports. Project W-3 14 will repair existing protective coatingin 241-AN-A and –B valve pits, as required, and will apply new SPC to the tops and bottoms of the newcover blocks to facilitate future cleanup of the pits and cover blocks.

981014.1322 1-3

HNF-3054, Rev. O

1.1.4 AZ Tank Farm Upgrades

The scope of work for the AZ Tank Farm upgrades includes new transfer lines, new pit and encasement leak

detection systems, cover block modifications, and electrical upgrades to support instrumentation, Specificwork includes the following.

. Decontamination and Solid Waste Removal. Project W-314 will decontaminate valve pits as requiredto allow entry in support of construction activities. Solid waste (e.g., jumpers) will be removed andpackaged for disposal

. Piping Systems. Project W-314 will provide a new waste transfer line (SN-63 1), with encasement,

between 241-AZ-O 1A and -02A pump pits, and a new waste transfer line (SN-632), with encasement,between 241-AZ-OIA pump pit and the new AZ valve pit located east of the AZ Tank Farm.Project W-3 14 will provide flexible jmnpers (temporary) and new transfer line nozzles in 241-AZ-OIA

and -02A pump pits.

. Instrumentation and Control Systems. Project W-314 will provide new pit leak detection systems for241 -AZ-O 1A and -02A pump pits, and provide a new encasement leak detection system for the new

transfer line (SN-631 ) between 24 l-AZ-O 1A and -02A pump pits and between 24 l-AZ-O 1A pump pitand the new SN-632 valve pit. Leak detection signals will be comected directly to the new MPS system.Project W-3 14 also will provide electrical power for the new leak detection systems and provide cathodicprotection to the new transfer line between 24 l-AZ-O 1A and -02A pump pits, and also between

241-AZ-O 1A pump pit and the new SN-632 valve pit.

. Structures. Project W-314 will modifi the existing cover blocks for 241-AZ-OIA and -02A PUMP pitswith penetrations for the encasement drain valve operators and the pit leak detection systems, as required,and also will repair the existing SPC, as necessary, to facilitate future pit cleanup.

1.1.5 AY Tank Farm Upgrades

The scope of work for the AY Tank Farm upgrades includes ncw transfer lines, new central pump pit nozzles,new pit and encasement leak detection systems, cover block modifications, and electrical upgrades to supporttbe instrrrmentation upgrades. Specific work includes the following.

. Piping Systems. Project W-314 will provide a new waste transfer line (SN-635), with encasement,between 241-AY-OIA and -02A pump pits, and a new waste transfer line (SN-633), with encasement,between 241-AY-02A pump pit and the new AZ valve pit located east of the AZ Tank Farm.Project W-3 14 will provide new jumper/valve manifolds and transfer line nozzles in 241-AY-OIA and-02A pump pits,

. Instrumentation and Control Systems, Project W-314 will provide new pit leak detection systems for241 -AY-O 1A and -02A pump pits, rmd a new encasement leak detection system for the new transfer line(SN-635) between 24 I-AY-O 1A and -02A pump pits and new transfer line SN-633 between241 -AY-02A pump pit to the new AZ valve pit. The leak detection system will be connected directly tothe new MPS system. Project W-314 will provide electrical power for the new leak detection systems,and cathodic protection to the new transfer line (SN-635).

. Structures. Project W-314 will modify the existing cover blocks for 241-AY-O 1A and -02A pump pitswith penetrations for the valve operators and the pit leak detection systems, as required, and repairexisting SPC, as necessary, to facilitate future pit cleanup.

981014.1322 1-4

HNF-3054. RCV.O

1.1.6 AW Valve Pit Upgrades

The scope of work for the AW valve pits includes jmnper/valve manifolds with position sensors, new pit andencasement leak detection systems, new cover blocks, electrical upgrades to support the instrumentation, andrepairs to SPC on pit surfaces as needed. Specific work includes the following.

Q Decontamination and Solid Waste Removal, Project W-314 will decontaminate valve pits as requiredto allow entry in support of construction activities. Solid waste (e.g., jranpers) will be removed andpackaged for disposal.

. Piping Systems. Project W-314 will provide new jumperlvalve manifolds and new flush line nozzles in241-AW-A and –B valve pits.

. Instrumentation and Control Systems. Project W-314 will provide new pit leak detection systems for241-AW-A and –B valve pits, rmd replace the encasement leak detection system for 3-inch SN-268-M25with new systems. Project W-3 14 will provide valve position systems for all the valves installed as part

of the jumper/valve manifolds in241 -A W-A and -B valve pits (excludes drain vrdves). Project W-314will provide electrical power for new leak detection systems and comect flush line pipe stubouts to theexisting cathodic protection system. Leak detection and valve position signals will be comected directlyto the new MPS system.

● Structures. Project W-314 will provide new cover blocks for241 -AW-A and –B valve pits. The newcover blocks will be provided with penetration for the manifold valve operators, pit leak detection

system, gas sampling ports, and inspection ports. Project W-3 14 will repair existing protective coatingin 241 -AW-A and –B valve pits as required, and will apply new SPC to the tops and bottoms of the newcover blocks to facilitate future cleanup of the pits and cover blocks.

1.2 structure ANDcoNTENT oFPRoJEcTw-314 ENvmoNMENTALPLAN

Program-level environmental strategies for delivering waste feed in support of the privatization initiative aredescribed in HNF-2401. These waste feeddelive~ s&ategies weredeveloped toimprove tieintegationofenvironmental actions within the overall TWRS Project and among projects (such as Project W-314) thatsrrpport waste feed delivery. Theinfomation, methodologies, andstrategies developed andevaluatedinHNF-2401 establish a supporting basis for the more detailed, project-specific analysis provided in thisProject W-314 environmentalplan. Thus, this Project W-314envirom]ental plan focuses onlyonenviromental actions necessa~to support Project W-314, andspecificaIly Phase 1 scope. Key objectivesinclude:

. Detemining theenviromental requirements thatreasonably can beexpwtedto apply to Project W-3l4,

Phase I

. Identi&ing thepemlits, approvals, andother mandato~enviromental compliance actions fiatmustbesatisfied for Project W-314, Phase 1 to proceed

. Recomending approaches andspecific actions foracquiring needed pemitsand approvals and

achieving environmental compliance

. Estimating theschedules andcosts forimpIementing therecomended enviromental actions forProject W-3 14, Phase 1.

981014.1322 1-5

HNF-3054. Rev. O

The first of these objectives, determining enviromrrentrd requirements, was satisfied partially by the broadregulatory screening provided in HNF-2401. A more detailed analysis of applicable standards is performedin the modified environmental requirements checklist, provided as Appendix A. The checklist srnrrmarizes

the results of this detailed analysis of the potentially relevant environmental starrdards for Project W-314,Phase 1. Those standards that were determined to be applicable are evahsated for permit, approval arrd othercompliance actions in the main body of this Project W-314 enviromrrental plan. Consequently, the rest of thkplan is organized as follows.

2.0 National and State Environmental Policy Acts. This section addresses federal arrd state obligations toconsider the full range ofenvirorrmental and socio-economic impacts of projects and activities.

3.0 Air Quality Protection. This section addresses actions that could emit chemically and/or radiologicallyhazardous constituents to the air.

4.0 Environmental Exposures. This section addresses the need to ensure public and persomel protectionfor potential radiation and hazardous material exposure routes.

5.0 Dangerous Waste Management. This section addresses actions associated with generating, treating,storing, rural/or disposing of dangerous and mixed waste streams.

6.0 Miscellaneous Assessments, Permits, and Approvals. This section addresses other, more generalrequirements, such as prcserwng cultural resources rmd protecting endangered species habitats.

7.0 References. This section provides cited references.

Each of these sections (except for the References) briefly summarizes the key environmental requirements,the relevancy to Project W-3 14, Phase 1 work, and associated permit and approval processes. In most cases,the path fonvard is based on needs rrnd schedules, but alternative compliance approaches are discussed ifthese exist and if relative advantages and disadvantages need to be assessed. Specific actions (e.g., applyingfor permits, submitting approval requests, establishing monitoring programs) for implementing the relevantrequirements and recommended compliance approaches are described. Each of these actions depends on thecompletion of seprrrate, usually sequential tasks (e.g., assembly of application data, submittal to the agency,response to comments). Appendix B provides a schedule Iiaking the strategy for acquiring the environmentalpermits and rrpprovals with the Project W-3 14, Phase 1 pluming basis.

981014.1322 1-6

HNF-3054. Rev. O

2.0 NATIONAL AND STATE ENVIRONMENTAL POLICY ACTS

The National Environmental Policy Act (NEPA) of 1969 was enacted to ensure that environmental mattersare considered before federal actions are initiated that might affect the qnality of the human envirormrent.The Stare Environmental Policy Act (SEPA) of 1971 (Chapter 43.21C Revised Cnde of Washington) is theWashington State equivalent of NEPA, and requires evaluation of environmental impacts associated with aproject or an agency action before approval of the project nr action is granted.

2.1 SUMMARY OF KEY REQUIREMENTS

The DOE regulation (Title 10 of the Code of Federal Regulations [CFR] Pti 1021) promulgated mrderNEPA was developed to conform to 40 CFR Parts 1500-1508 regulations and to categorize theenvironmental impacts associated with various DOE proposals or actions. The NEPA stnrrdards require thatenvironmental considerations be identified and evaluated early in the plaming process for all proposedfederal actions, Only DOE and/or DOE-RL can approve the correct level of NEPA review on tie HanfordSite.

The types of NEPA documentation that maybe required for reviewing federal actions include:

. Environmental impact statement (EIS).

● Supplement analysis (SA).

. Envirorrmcntal assessment (EA).

. Categorical exclusion (CX).

. Sitewide categorical exclusion (SWCX)

More detail on NEPA documentation and the NEPA approval processes can be found in HNF-PRO-452 andHNF-SP-0903.

The SEPA Rules, Chapter 197-11 of the Washington Administrative Code (WAC) are promulgated andmanaged by the Washington State Department of Ecology (Ecology). SEPA requires evaluation by a state orlocal agency of environmental impacts associated with an action under its jurisdiction before approval by theagency. On the Hanford Site, the SEPA process begins when approval(s) or modification(s) (e.g., license,and permit) must be obtained for a proposed action to proceed. When a proposed action has been addressedunder NEPA, Ecology maybe asked to adopt or concur with the NEPA documentation. More detail on SEPAdocumentation rmd the SEPA approval processes can be found in HNF-PRO-452.

2.2 APPLICABILITY TO PROJECT W-314 ACTIONS

As described in Section 1.0, prnposed actions for Project W-3 14, Phase 1 include upgrading rmd constructing

waste feed transfer Iincs, tank ventilating, and related supporting activities such as instmmentatinn, electricaland infrastructwe upgrades. These actions are subject to consideration under NEPA and, because of requiredpermits and approvals, SEPA. As discussedinHNF-2401, a substantial body nf NEPA documentation existswith respect to waste feed delivery activities and projects. Current NEPA documentation, directly andindirectly addressing Project W-3 14, includes:

. The TWRS EIS (DOE/EIS-0189F).

. The TWRS Record of Decision (ROD) (62 FR 8693).

I

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●

✎

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The Safe Interim Storage EIS (DOE/EIS-0212) and ROD (60 FR 61687).

The TFRSO/Project W-314 SA (DOE/EIS-0189-SA l).

The TWRS SA (DOE/EIS-0189-SA2).

This NEPA documentation anticipated aud addressed the impacts associated with W-314 supporting projects

and associated Phase 1 activities, and was prepared with substantial involvement by Ecology. The TWRSEIS was issued jointly by DOE and Ecology, aud Ecology has concurred with the Phased Implementationalternative selected by DOE in the TWRS ROD. Ecology comments were included in the TFRSO/TrojectW-3 14 and TWRS SAS. To date, Ecology has deferred to the published NEPA documentation in lieu ofindependent SEPA reviews,

2.3 SATISFYING APPLICABLE REQUIREMENTS

HNF-2401discussed several alternative approaches for satisfying applicable NEPA and SEPA requirements.These ranged from relying on existing NEPALSEPA documentation, to supplementing existing materials, topreparing completely new documentation. The key discriminator for selecting an approach is the degree ofcoverage, or ‘environmental bounding’, addressed by the available NEPA/SEPA documentation, In general, if

the types and extent of environmental impacts associated with a proposed action are described adequately inexisting documentation, NEPA and SEPA have been satisfied and no further documentation is required. Ifthe environmental impacts are not bourrded adequately, additional review rrrrdassessment are needed,

To support this Project W-314 environnrcntal plan, the scope of Project W-314 work was evaluated relative

to existing NEPA docmrrentation and related SEPA determinations. The following sections describe therecommended approach to satisfying the applicable NEPA and SEPA requirements.

2.3.1 Recommended NEPA Approach

Under NEPA, additional NEPA documentation is not required as a project moves from conceptual desigrr todetailed desigrr and construction, unless there is a reasonable basis for concern that chrmges to the projectwould result in environmental or human health impacts that substantively exceed those considered in existingNEPA documentation. NEPA anticipates that EISS will be prepared based on conceptual designs and thatchanges will occur in the selected alternative as it moves toward implementation. In fact, NEPA should becompleted early in the design process to allow decisious to be made before makmg irretrievable comsnitmcnts

of resources or usimg the NEPA process to support decisions that already have been made. Minor changes mdesign, schedule, or equipment should not trigger a NEPA requirement for any level of NEPA analysis uulessthere is some basis to assume a substantive change in environmental and human health impacts, A change

alone does not require NEPA analysis.

The find TWRSEIS(DOE/EIS-0189F) evaluated environmental impacts associated with upgrading tankfarm infrastnrctwe, including waste transfer, instrumentation, ventilation, and electrical systems. In addition,the TFRSO/Project W-314 SA (DOE/EIS-O 189-SA1) expanded on the TWRS EIS to address environmentalimpacts associated with the following.

●

✎

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Ventilation System Upgrades - primarily for DST farms 241-AN, -AP, and –AW. This also wouldinclude replacing the ammhrs ventilation system for 241 -SY and replacing the exhaust ventilation

systems support for 244-A and 244-S.

Tarrk Famr Instrumentation and Control Systems Upgrades – existing tarrk monitoring systems wouid bereplaced and/or upgraded for measuring waste level, temperature, and vapor pressure. Primary

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ventilation instrumentation for all DSTS would be upgraded. Existing leak detection systems would be

up~adcd or replaced. The master pump shutdown system would be upgraded.

. Electrical System Upgrades - existing power for the primary ventilation systems would be modified and

upgraded to provide backup power capabilities for primary ventilation systems in Tank Farms 24 l.Ap,-AN, -AW, -AX, -AZ, and -SX, Electrical service upgrades also would include 244-A double-containedreceiving tank (DCRT) and 244-S DCRT.

. Waste Transfer System Upgrades - a new buried waste transfer line approximately 40 meters (130 feet)long from 24 l-AZ-O1Apmrrppitto241 - AZ-02A pump pit withir the 24 l-AZ Tank Farm fence line.

. Demolition – demolition of existing systems and equipment would take place under the proposed action,

Existing seal pots and all underground electrical systems, process piping, and ventilation piping thatwould be replaced by Project W-314 would be placed in a safe configuration and abandoned in place

unless otherwise noted.

Based on the Project W-314 SA 1 analysis, the potential impacts for Project W-314 would be small andbounddby theimpacts assessed fortlle TWRSEIS preferred alternative. Therefore, a determination wasmade that no additional NEPA analysis was required.

The revised scope of an alternative trrrrrsfer line proposed following development of the Project W-314 SA 1cwently isunder DOE NEPArevie\v regarding adetemination foradditional docmentation. The currentplanning basis assumes either a letter-to-file, or more conservatively, a SA will need to be prepared.

A path forward also is under review by DOE regarding the need for the preparation of a mitigation actionplan (MAP) for Project W-314. Aprelimina~ review of thewastetransfer system route indicateda WP

worrldnot be required. Anymitigatioll actions, inapplicable, would beidentified inthe Cultwal andEcological Resource Reviews discussed in Section 6.3.

2.3.2 Recommended SEPAApproach

Asdocmented in Appendix A, Project W-314is considered torequire appropriate SEPAdocmentation. As

discussed, there is existing NEPA documentation addressing the Project W-314 scope the TWRS EIS(DOE/EIS-O189F) and TWRSROD (62 FR8693); al,dtheproject-related SA(DOE/EIS-Ol89-SAl). TheNEPA documentation anticipated and addressed the impacts associated with Project W-314 supportingprojects andassociated Phase l activities. The TWRSEIS wasissuedjointly by DOEand Ecology. Ecologyhas concurred with the Phased Implementation alternative selected by DOE in the TWRS ROD.

The following alternatives exist for compliance with SEPA

. Submit aletter to Ecology for SEPAadoption antiorprovide abriefing toappropriate regulatoragencies (Ecology is the lead agency) stating that DOE-ILL believes existing cnvirorrrrrentaldocumentation provided to or prepared by Washington State agencies, and issuance ofperrnits by thoseagencies, covers this action.

. Submit aSEPAenviromcntaI checklist inconjwction withanapplication forpemit(s) needed (e.g., air,RCRA, building) and let Ecology determine if an EIS is required.

The recommended approach is to submit a letter for SEPA adoption and provide a briefing to inform Ecologythat fie TWRSEIS (DOE/EIS-O 189F) RODcovers Project W-314, Phasel activities.

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2.4 PRELIMINARY SCHEDULE AND COST ESTIMATES

If a letter-to-tile is determined to be acceptable for NEPA compliance, this approach can be implemented in

approximately lmOnthfOr acOstOfapprOximately $2K. Should aSAberequired, theduration ofthis effortwould be about 5 months, with an associated cost of approximately $ 15K.

Assuming Ecology concurs with the opinion that SEPA would be satisfied by the NEPA documentation, the

effofito gain Ecology 'sconcwence will be relatively nominal. Theduration oftbiseffort would be about1 month for a cost of approximately $1 K.

More detailed infornration (including time and level of effort assumptions) for the schedule and cost estimatesis presented in Appendix B.

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3.0 AIR QUALITY PROTECTION

The Clean Air-Act (CAA) was enacted in 1970 under 42 USC 7401 et seq. and amended in 1990. InWashington State, EPA, Ecology, Washington State Department of Health (WDOH), and local air authoritiesimplement the provisions of the CAA.

3.1 SUMMARY OF KEY REQUIREMENTS AND PERMITTING PROCESSES

The air permitting process is based on standards adnrinistered by regulatory agencies and contained in thefollowing regulations:

. National Emissions Standards for Hazardous Air Pollutants (NESHAPS) (40 CFR 61 Subpart H)

. Prevention of Significant Deterioration (PSD) standards (40 CFR 52.21 and WAC 173-400)

. Operating Permit Regulation (WAC 173-401)

. Ambient Air Quality Standards for Radionuclides (WAC 173-480)

. Radiation Protection - Air Emissions (WAC 246-247)

. Controls for New Sources of Toxic Air Pollutants (TAPs) (WAC 173-460).

These regulations establish standrrrds and rules applicable to the control and/or prevention of the emission ofair contaminants. Three main requirements to be met are use of best available control teehrrolo~,quantification of air pollutant emissions; and demonstration of human health and environrrrental protection.

Detailed information on the emissions abatement system, the gaseous effluent monitoring system, the processproducing the emissions, and the nature of all emissions to the atmosphere are required for submissions madepursuant to the CAA. A detailed description of requirements is provided in HNF-2401.

3.2 APPLICABILITY TO PROJECT W-314 ACTIVITIES

The proposed activities include upgrading and constructing waste feed lines and supporting activities. TheProject W-3 14 activities will require several air-related permits and approvals before commencement ofactivities. These pemrits and approvals will be issued by several regulato~ agencies, including the EPA,Ecology, and WDOH.

3.3 SATISFYING APPLICABLE AIR QUALITY PROTECTION REQUIREMENTS

The following sections describe the alternatives available for obtaining appropriate air quality documentation

and the reconurrended approach for the Project W-314 environmental planning basis.

3.3.1 Available Alternatives

Various avenues could be evahratcd in an effort to support the air permitting for Project W-314 activities.The length of the pemlitting process depends on the quantity of emissions and the availability of necessayinformation. The alternatives open for consideration are as follows.

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1. Use existing air permitting documentation within identified scope, emissions limits, and time constraints.

2. Obtain WAC 246-247,40 CFR 61 Subpart H, and WAC 173-460 approvals when informationnecessary to complete the applications is available,

3. Obtain WAC 246-247,40 CFR61 Subpart H, and WAC 173-460 approvals separately as informationbecomes available to complete the applications.

4. Obtain WAC246-247 and WAC173-460 approvals inaphasd approach. Permit applications are

prepared forandrepresent acomprehensive project thataffec& anindividual emission point. Obtainingseparate approvals, by segmenting a project into separate notices of construction (NOCS), is not allowedmrderthe Clean Air,4cr. Toreceive therequircd approvals forpreconstiction orprelimin~ activitiesearly in the project’s schedule, a phased approach could be implemented,

The NESHAPS regulations do not allow phased permitting; therefore, an application for the entire projectmust resubmitted andapproved before anyconstmction. Itisstill possible tophase theother applicationsbecause the NESHAPS application does not require the same level of detail of information for approval.

3.3.2 Recommended Approach

Air permitting applications have been prepared and approved for Project W-3 14 low-activity waste (LAW)and HLWtransfer systems, ANOCcovering Project W-314activities wasprepmed in October ofl997md

approved bythe responsible agencies. Rccentscope changes have been identified fortie200 Eastwastetransfer system. These changes will likely inlpactexisting NOCapprovals.

For radioactive air emissions, it is assumed that a short form NOC will need to be prepared to addresschanges to the waste transfer systcm, but cannot begin until more definitive information is available regnrdingdesign and operating conditions.

The planning basis for nonradioactive air emissions assumes that TAPs will not exceed small quantityemission limits anda Ietterdocmellting theplaming basis review will be prepared. Aprelimimuy reviewofprevention of significant deterioration (PSD) and new source review (NSR) applicability indicates that aletter-to-file docmentillg revie\v resuIts also\vill berequired. Once NOCsare approved, theapprovalconditions areinco~orated into theairoperating pemit(AOP), If futrrre modifications ofan NOCrrrerequired, the AOP will require revision as well.

3.4 PRELIMINARY SCHEDULE AND COST ESTIMATE

It will take approximately 6 months (assuming that all required information and data are available forsubmittal) topreparc asbofiform NOCpcrmit application andreccive regulator approval. Ifmore than one

application is required, the application(s) can (and should) be prepared and submitted in parallel to shortenthetimeto receive all applicable approvals. Expcdicnt preparation ofanapplication depends ontime1yreceipt of the descriptive information and the emissions estimate.

HNF-3054, Rev. O

The generic schedule for preparation of a short form NOC is as follows:

. Prepare emissions estimate/calculations

. Prepare permit application

– draft applicationinternal reviewresolvelirrcorporate comments

. FDH review- Review— resolve/incorporate comments

. DOE-RL review— review— resolvelirrcorporate comnrcnts

Regulator 30-day completeness notification

Regulator review and approval

-1 month minimum

-1 month-2 weeks

-2 weeks

-2 weeks-2 weeks

-2 weeks-2 weeks ( internal)

-1 month (regulator)

-1 month

A preliminary cost estimate of $19,000 has been developed for the activities associated with securing one

WDOH air permit and approval. If best available radionuclide control technology (BARCT) arrd bestavailable control technology for toxics (T-BACT) assessments need to be prepared, each assessment mightcost an additional $15,000 (approximate). The approximate cost to submit the WDOH short form NOC

application to EpA and Obtain approval is approximately $3,000. The cost to incorporate approvalconditions to the draft air operating permit is estimated at $1,000. Estimated time to prepare and documentanalysis in a memo to file for TAPs is 1 month, a NSR is 1 week, and PSD is 2 weeks. Total cost for these

activities is approximately $4,000.

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4.0 RADIATION PROTECTION STANDARDS/MONITORING

DOE Orders 5400.1, “General Environmental Protection Progmm”, aud 5400.5, “Radiation Protection of thePublic and the Environment”, establish standards aud requirements that must be followed to protect members

of the public and the environment against rmdue risk from radiation. Additional requirements for radioactiveand mixed waste management are fouud in DOE Orders 5820.2A.

4.1 SUMMARY OF KEY REQUIREMENTS AND APPROVAL PROCESS

DOE Order 5400.1 requires a written environmental monitoring plan (EMP) for each site, facility, or processthat uses, generates, releases, or manages significant pollutants or hazardous materials. The EMP mustinclude the rationale and design criteria for the monitoring protyam, as well as describe the extent andfrequency of the monitoring. The EMP also must contain quality assurance (QA) requirements, programimplementation procedures, directions for preparation and implementation of reports, and directions foridentification and discussion of effluent monitoring and environmental surveillance. An EMP is prepared forall DOE activities on the Hanford Site and is updated every 3 years to include new or modified facilities andprojects (DOE/RL-9 1-50).

The effluent momtoring portion of the plan must verify compliance with applicable regulations and DOE

Orders. For major facilities on the Hanford Site, this is documented in the form of specific facility effluentmonitoring plans (FEMP). Preparation of a FEMP assesses effluent monitoring systems and evaluateswhether these systems are adequate to ensure the public health and safety as specified in applicable federal,state, and local requirements. The FEMP ensures long-range integrity of the effluent monitoring systems byrequiring an update whenever a new process or operation introduces new hazardous materials or sigrrificant

radioactive materials. This document is reviewed amually rmd must be updated, at a minimum, every3 years.

DOE Orders 5400.1 and 5400.5 require that baseline data be obtained before the start of a project(pi-e-operational monitoring) and that periodic (near facility monitoring) be performed to determine if theenvirorrment is being affected. The basic monitoring required includes the following:

. Radionuclide concentrations in the ambient air

● Background radiation levels at the project site and in surrounding areas

. Radionuclides present in flora, fauna, soil, wildlife, and water.

Subpart H, “National Emission Standards for Emissions of Radionuclides Other Than Radon fromDepartment of Energy Facilities” (40CFR61), establishes exposure limits and monitoring requirements.The exposure limits for members of the public from radionuclide emissions is an effective dose equivalent(EDE) not to exceed 10 mrem per year. Compliance with this standard is measured by calculating the highestEDE where a person resides or abides using an EPA-approved method.

Radioactive waste (e.g., mixed, high-level, transuranic, etc.) generated by DOE operations is to be safely

stored, treated, and disposed according to the requirements set forth in DOE Order 5820.2A. Radiation doselimits received by members of the public as a result of the management and storage of spent nuclear fuel,high-level, or transuranic waste at any DOE disposal facility are not to exceed the limits described in40 CFR 191, Subpart A(b),

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A FEMP determination is perfomred to assess the need to prepare a FEMP. The radioactive and chemicalsource terms must be reviewed, and if one of the two thresholds can be exceeded, a FEMP must be prepared.If not, a one-page form is sufficient to document the determination. The sitewide EMP (DOE/RL-91-50) willbe updated automatically; no facility specific effort is required.

Most of the F1uor Daniel Hanford, Inc. (FDH) team environmental monitoring activities are perfomred byWaste Management Federal Services of Hanford (WMH) and Waste Management Northwest (WMNW).Policy and integration activities are the responsibility of FDH. The Harrford Site Integrated Plan forEnvironmental Monitoring (HNF-MR-0535) was developed and agreed to by all Hanford Site contractors[Pacific Northwest National Laboratory (PNNL), Bechtel Hanford, Inc. (BHI), arrd the FDH team]. Themonitoring of effluents and the environment is documented formally each year, and all TWRS activities need

to be included as appropriate.

A pre-operational environmental study is to be conducted before startup of a site, facility, or process that hasthe potential for significant adverse environmental impact (DOE Order 5400. 1). A pre-operationalenvironmental study will be required for the 200 East Area waste transfer system. This study should beginnot less than 1 year (preferably 2 years) before startup, so seasonal changes can be evaluated. This studyprecedes the conceptual design report and can include data acquired in the site selection process, excavationpermit process, and NEPA/SEPA process. For more information refer to the environmental complianceprocedures, HNF-PRO-453, HNF-PRO-456, and HNF-PRO-457. It is assumed that each individualsupporting project will request a pre-opcratiorral survey of the proposed usage location, as soon as the siteevaluation review is complete.

The following effluent or environmental reports require data from Hanford Site facilities and projects, Themonitoring, reporting, and routine communication among contractors is described in the Integration Plan forEnvironmenralMonitoring (HNF-MR-0535). Although the reports typically are published aurrually, themonitoring and collection of meaningful data, without duplication of effort, requires regular interaction withthe other mrsite contractors. The reports are(1) the environmental releases report, which reports data forradioactive and nonradioactive substances released into the enviromrrent during each calendar-year; (2) theradionuclide air emissions report, due to the EPA by June 30 each year, (3) the nonradioactive emissionsreport to ecology; and (4) the Hanford Site environmental report issued annually,

4.3 SATISFYING APPLICABLE RADIATION PROTECTION REQUIREMENTS

The following sections describe the alternatives available for satisfying appropriate radiation protection

requirements and the recommended approach for the Project W-3 14 environmental plamring basis.


The three alternatives available for this project are (1) gather the required information specifically for thisproject or (2) use information gathered by TWRS and routine monitormg, and (3) use existing data and

supplement data with sampling data.

Alternative I is judged to be the most expensive in that it would be difficult to separate the acquired projectdata from the TWRS data in the case of overlapping projects, potentially resulting in duplicating efforts.

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Alternative 2 would use existing data for the baseline would limit efforts to ongoing monitoring, Theongoing monitoring could be accomplished by use of onsite programs and the specific monitoring establishedfor ‘TWRS.

Alternative 3 would use existing data and supplement the data with additional sample collection, analyticaltesting, and data evaluation as needed.


The recommended approach is to use Alternative 3. For pre-operational monitoring, some baseline dataexists. However, it is assumed that additional pre-opemtional monitoring data will need to be acquired forportions of the 200 East Area alternative transfer line in previously undisturbed areas.

The planning basis assumes a sampling analysis plan (SAP) will be required to determine the types of mediato be sampled, location and number of samples to be collected, and constituents to be analyzed. A finalreport will be issued after completion of monitoring activity.

4.4 PRELIMINARY COST AND SCHEDULE ESTIMATES

Costs will be incurred by ‘the need to evaluate new project scope for threshold monitoring limits. The currentplaming basis includes an estimate for pre-operational monitoring activities over a minimum of 1 year for an

approximate cOst of $68,000. This estimate includes assumptions for sample collection, analytical testing,data evaluation, and report preparation to establish an environmental baseline. Refer to Appendix B.

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5.0 DANGEROUS WASTE MANAGEMENT

A comprehensive national program was crracted ander the Resource Conservation and Recovery Act(RCRA) of 1976 to mandate that hazardons (dangerous) waste would be treated, stored, arrd disposed of soastominimize thepresent and futwetkeat tohmanhealth andtieenviroment. In Washington State,WAC 173-303, Dangerous Waste Regulations are the implementing regulations.

5.1 SUMMARY OF KEY REQUIREMENTS AND PERMITTING

WAC 173-303 regulations apply to all facilities within Washington State that treat, store, and/or dispose ofdangerous waste. These regulations are equivalent to, or more stringent then, the federal hazardous wasteregulations, Under the dangerous waste program, all treatment, storage, and/or disposal (T SD) units must

obtain a permit. Units that were in existence on November 19, 1980, were gnrrted an interim status permitwith the submittal of a Part A, Form 3, identifying the intent to treat, store, and/or dispose of dangerouswaste. A final status permit M granted after final administrative disposition of the Part B docrmrentation.

The process for obtaining a RCRA permit consists of three collective submittals. Each submittal consists ofvarious levels of detailed information concerning the TSD unit. The three submittals are the notice of intent(NOI); the Part A, Form 3, pwrnit application (Part A); and the Part B permit application (Part B). A

detailed description of RCRA pemlit submittals is provided in the Waste Feed Delivery EnvironmentalPermits and Approvals Plan (HNF-240 1).


The proposed action includes upgrading and constructing waste feed transfer lines, ventilation systems, andrelated supporting activities, Many of these proposed actions will require permits and other approvals fromstate agencies (e.g., Ecology). As docrrmented in Appendix A, Project W-314 is subject to theWAC 173-303 TSD requirements and must be covered adequately under the appropriate RCRA interimstatus arrdlor final status pemlits.

As previously noted, the Hanford Site has been issued a sitewide final status permit that is amended

periodically to include unit-specific requirements for each of the major TSD units on the Hanford Site, Manyof the anticipated Project W-314 Phase 1 activities involve new/replacement transfer lines to the Tank Farms,primarily the DST System. The DST System c.arrently is covered under interim status, and a unit-specific

final status permit application is being prepared for submittal to Ecology. It will be necessary to ensure thatthe DST System interim status and eventual final status permit are consistent with and adequately cover theplanned Project W-3 14 activities.

5.3 SATISFYING APPLICABLE DANGEROUS WASTE MANAGEMENTREQUIREMENTS

The following sections describe the alternatives available for obtaining appropriate RCRA documentationand permits and the recommended approach for the Project W-3 14 environmental plaming basis,

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HNF-3054, Rev. O


The scope of work identified for Project W-314 so far does not impact the current permitting domrrrrents andcan be performed mrder interim status for the DST System. As the desigrr for new transfer lines and upgradesevolve, it should be reviewed by the knowledgeable personnel to ensure that compliant systems are beingproposed, which can be permitted in the future. It might be appropriate to seek opinions or direction fromEcology on issues of regulatory interpretation, or where early agency involvement might expedite the finalpermit approval. Relevant design media and system descriptions must be provided to TWRS Environmentalstaff for incorporation into the DST System Part B permit application docmrrentation. If design anddescriptions camrot be provided in time for final submittal of the Part B, a permit modification will need to beprocessed and approved by Ecology before implementing any design changes in the field. Two basicalternatives have been identified for consideration:

. Integrate the Project W-314 activities with the DST System TSD permitting efforts, arrd stay consistentwith the current schedule and plans for maintaining interim status aad obtaining a final status permit forthe DST System,

. Seek to integrate the Project W-314 activities with an independent TSD permitting process for WFD thatwould be more closely aligned with the schedule and plans for WFD activities.

It should be noted that it would be very difficult to distinguish WFD activities from the DST System.Although both alternatives theoretically are feasible, the second alternative is much less practical. However,

should significant problems arise (e.g., denial of the DST System final status pemrit) that would prevent orsubstantially delay WFD, Alternative 2 could become a more viable option.


The current recommended approach m to review the Project W-314 activities for changes in scope (e.g.,changes in processes or waste types and increases to desigrr capacity) and ensure that sufficient coverage Midentified in the DST System Part A during interim status. This approach also ensures that changes to thePart A are reflected in the DST System. As needed to maintain interim status, the DST System Part A should

be updated to include new components, structures, or operating systems associated with Project W-3 14.During preparation, the Part B final status pemrit application for the DST System should include theavailable and required design-level information for the plrumed W-314 transfer lines and upgraded stmcturesand components. Inclusion of conceptual and pm-conceptual infomration should be avoided, However, itmight be advantageous to address the overall Project W-314 scope in tbe final status permit application to

establish a basis for aud to simplify future permit modifications.

The following assumptions apply to this recommendation

. Changes to the scope identified within this plan will require re-evaluation for new impacts, and asneeded, changes to the Part A.

. Desigu would bc completed before the DST System Part B, Rev. 1, final status permit application issubmitted in to Ecology in June 2000.

. The DST System Part B would be revised to reflect changes in piping and transfer systems

. The SST Closure Work Plan would be revised to include W-314 new and replaced transfer lines

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. Hanford Facility Dangerous Waste Pernrit Application, General Information Portion (DOE/RL-91-28)would be revised to provide current information.

Based on the listed assmrrptions, no further action is required by the project at this time. Per schedule, alldefinitive desigrrs will be completed by the cut-off date of December 1999 (last input to Part B application.)A working draft of the DST Part B application is planned for snbmittal to Ecology in January 2000. The due

date for the DST Part B application submittal to Ecology is June 2000. A revised Part A is planned forsubmittal with Part B application and not as a separate activity.

No finther action currently is required by Project W-314 at this time. However, the planning basis assumesproject support will be needed for submittal of completed Project W-314 definitive design drawings toaccompany the DST Part B application submittal and revisions.


The current planning basis assumes the Project W-3 14 Phase 1 upgrades and transfer line constructionactivities have been addressed in the current DST interim status pernrit and will be identified in the DST finalstatus permit application; therefore, no fhther cost and schedule estimates have been identified in this plan.

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6.0 MISCELLANEOUS ASSESSMENTS, PERMITS, AND APPROVALS

In addkion to the major regulatory programs, several miscellaneous assessments, permits, and approvals areaddressed in the following sections.

6.1 SUMMARY OF KEY REQUIREMENTS AND PROCESSES

The following reviews and approvals are required before constnrction or excavation activities begin

6.1.1 Cultrrral[Ecological Resource Review

A cultural review is performed for any project involving demolition, modification, or deactivation of apotentially historic facility or structure (36 CFR 800). The CERR must be made before initiating anyexternal surface-disturbing activity onsite, or if any modifications are plamed for any facility with the poten-tial for inclusion on the National Register of Historic Places. The request form to perform this assessment islocated on the HLAN, under Site Forms, [A-6001-930, “Request for Cukrrral/Historic Resources Review”],The regulatory agency is DOE-RL.

A site survey should be performed to identify the following

. Any plant or animal species protected under the Endangered Species ActCandidates for such protection

. Species listed as threatened, endangered, candidate, sensitive, or monitored by Washington State

. Species protected under theMig?alory Brd Treq Act.

Also assessed is whether the planned activities have the potential to disturb any priorily habitats and/orspecies identified in the survey. Any mitigation actions would be required during the review. The request

form to perfoml this review (along with the CERR) is macro GEF271. This review also fulfills the NEPAecologicalhiological review requirement.

NOTE This section also applies to taking, possession, transportation, sale, purchasehrter, export, andimport of special status plants and animals (both living and dead). This section also includesremoval/remediation action, corrective action, decontaminatiotidecommissioning (D&D) activities, andproject construction activity.

6.1.2 Site Location

Any new facility must receive a landlord site location review, coordinated by Dyncorp/Site and Land UsePlaming organization. This review is a best management practice and offers an opportunity during the earlyplanning stages to identify unusual or uncertain complirmce, safety or operations issues. This review coverssimilar aspects as the alternatives review under NEPA (EIS or EA).

A siting evaluation should be made of the proposed routing for ali underground or above-ground piping, pits,

pads, and support structures within Project W-3 14 A review for intrusion into radiation control areas,underground contamination areas, and buried tanks also should be made to avoid any unanticipatedexposures. Data from the site location review should be maintained for reference by the excavation permitauthority.

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HNF-3054, Rev. O

6.1.3 Excavation Permit

An excavation pemrit is required before initiating any potential surface-disturbing onsite activities(36 CFR 800). The request form to obtain this pemrit is located on the HLAN, mrder Site Fomrs,[A.7400.373, “Hanford Excavation Permit”]. The TSD mrit enviromrrental compliance ofticcr (ECO) could

review and approve excavation permits before excavation begins to ensure that all CERR issues are met.

Detailed infomration needed for the excavation pemrits rmder Project W-3 14 will be the responsibility of

each individual supporting project. Data from the site location review should be examined during the

approval of the excavation pemrits.

6.1.4 American Indian Tribal Government Agreements

American Indian Tribal Governments have a special and unique Icgal relationship with the US FederalGovernment and its ag,cncics (DOE 1230.2) These relationships are defined in numerous treaties, statues,historical precedents, and the US Constitution. In addition, Washington State has agreements respectingcur-rent and future use of the lands surrounding the Hanford Site. All actions on the Hanford Site that mightimpact these agreements must be approved by the DOE-RL office for native American interests. TheCultural Resource Review will be the mechanism for identifying any such potential impacts.

It is assumed that all actions included under Project W-314 will occur inside or within 150 meters of the200 EastL200 West tank famr boundaries. The TWRS areas have an existing cultural review (initiallyAugust 16, 1994; updated aumrally). The new transfer line construction activity will require a culturalresource review before start of construction. A resource review generally takes 2 weeks.

6.1.5 Endangered Species Act Compliance

A site assessment should be made to determine whether any planned activities have the potential to disturbany habitat used by wildlife before construction or habitat modification (50 CFR 402.6). The regrslato~agency is the State or Federal Fish and Wildlife Service For onsite construction, a biological survey willneed to be perfomred.

6.2 APPLICABILITY TO W-314 ACTIONS

The proposed action includes upgrading and constructing waste feed transfer lines, ventilation upgrades, andrelated supporting activities. Many of these proposed activities will require pemrits aud other approvals fromECOS or line managers for onsite construction operations. As docrrmerrted in Appendix A, Project W-3 14 isconsidered to require the appropriate rnisccllaneous permits and assessments before initiating excavation orconstruction activities.

6.3 SATISFYING APPLICABLE REQUIREMENTS

The cultural resource review and endangered species compliance reviews have been addressed in ‘blanket’reviews for TWRS. Project W-314 should fall within the area identifiedbyPNL(1994) aud PNNL (1 997).

The regulatory strategy is that the ‘blanket’ reviews will encompass the activities within the 200 East TaakFamr bomrdary and a request for a review of Project W-314 relative to the existing survey reports, asamended, will be required before securing rm excavation pemlit. In the case of the proposed alternative waste

981014.1322 6-2

HNF-3054, Rev. O

feed transfer line, a biological and cultural resource review will be required to ensure that the activity is withinthe bounds of the ‘blanket’ TWRS reviews. Any mitigation requirements will be documented in the CERR.The plaming basis assumes that neither mitigation nor a MAP will be required.


It is expected that most of the assessments, permits, and approvals previously discussed are being completed

under tbe scope of existing programs and activities for TWRS rind/or the Hanford Site. The scope, costs, arrdschedules for these ongoing programs already have been established, arrd are not likely to be significantlyaffected by activities specific to Project W-3 14, Additional efforts for cultural arrd ecological resourcewalkdowns of the transfer pipeline corridor are expected to take approximately 1 month and cost $3,000,

981014.1322 6-3

981014.1322

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This page intentionally left blank.

6-4

HNF-3054, Rev. O

7.0 REFERENCES

DOE/EIS-O 189F, Final Environmental Impact .%[ementfor rhe Tank Waste Remcdiation ,’$swtn,U.S. Department of Energy, Richhmd Operations Office, Washington.

DOEIEIS-O 189-SA 1, Supplement Analysis for the Proposed Upgrades to the Tank Farm Ventilation,Instrumentation, and Electrical Systems under Project W-314 in Support of Tank FarmRestoration and Safe Operations, U.S. Department of Energy, Richland Operations Office,Washington.

DOE/EIS-0189-SA2, Supplement Analysis for the Tank Waste Remedlation System, U.S. Department of

Energy, RichIand Operations Office, Washington.

DOE/EIS-02 12, Safe Interim Storage of Hanford Tank Wastes Environmental Impact Statement,U.S. Department of Energy, Richland Operations Office, Richland, Washington.

DOE Order 451. IA, National Errvirorrrnerrtrrl Policy,@ Compliance Program

DOE Order 1230.2American Indian Tribal Government Policy.

DOE Order 5400.1, General Environmental Protection Program.

DOE Order 5400.5, Radiation Protection of the Public and the Environment.

DOE Order 5820.2A, Radioactive Waste Management.

DOE Order 6430. 1A, General Design Criteria.

DOEIRL-91 -28, Hanford Facility Dangerous Waste Permit Application, General Information Portion,U.S. Department of Energy, Richland Operations Office, Richland, Washington.

DOEIRL-91-50, ErrvironmentalA40rritorargPlan lJniled Stales Department of Energy Rich[andOperations Office, Rev. 2, 1997, U.S. Department of Energy, Richland Operations Office, Richhurd,Washington.

HNF-2401, Waste Feed Delivery Environmental Permits and Approvals Plan, Lockheed Martin Hanford,Richland, Washington, 1998.

HNF.MR-0535, Integration Plan for Environmental Monitoring, Rev. O, 1997, Fhror Daniel Hanford, Inc.,Rich[and, Washington.

HNF-PRO-452, NEPA, SEPA, Cultural and Natural Resources, Fhror Daniel Hanford, Inc., Richlarrd,Washington.

HNF-PRO-453, Enwronmetrtal Notij7catiotr atrdReporting, Fluor Daniel Hanford, Inc., Richland,Washington.

HNF-PRO-456, Water Quality, Fluor Daniel Hanford, Inc., Richland, Washington.

981014.1322 7-1

HNF-3054. Rev. O

HNF-PRO-457, Environmental Reguimtwnls Evahiadon, Fhsor Daniel Hanford, Inc., Riclrland,Washington.

HNF-SD-W314-RPT-003, Tank Farm Restoration and Safe Operation, Project W-314, Rev. 3,1998,Nmrmtec Hanford Company, Richkmd, Washington.

HNF-SD-WM-MAR-O08, Tank Waste Remediation System Mission Analysis Report, Rev. 3,1998,Lockheed Martin Hanford Company, Richland, Washington.

HNF-SP-0903, National Environmental Policy Act Source Guide for the Hanford Site, Fhsor DanielHanford, Inc., Richkmd, Washington.

PNL, 1994, letter from ME. Crist, Pacific Northwest Laboratories, to W.B. Baucroft, Westinghouse Harrford

Company, “Cultural Resources Exemption of the Tank Farm Areas”, August 16, 1994.

PNNL, 1997, letter from C.A. Brandt, Pacific Northwest National Lahorato~, to Randy K. P’Pool, LockheedMartin Hanford Corp., “Blanket Biological Review for the Tank Farm Facilities, 200 E and200 W Areas, #97-200-047”, April 15, 1997.

WHC-SD-W3 14-CDR-001, Conceptual Design Reporl for Tank Farm Restoration and Safe Operations,Project W-314, Rev. 1, 1996, Numatec Hanford Corporation, Richland, Washington

WHC-SD-W314-EV-00 1, Permitting Plan for the Tank Farm Restoration and Safe Operations Project,Rev. O, 1996, Westinghouse Hanford Company, RichIand, Washington.

60FR61687, Record of Deczsion for Safe Interim Storage of Hanford Tank Wastes, Hanford Site,

Richland, Washington.

62 FR 8693, Record of Decision for Tank Waste Remediation System, Hanford Site, Richland, Washington.

981014.1322 7-2

HNF-3054, Rev. O

981014.1322

APPENDIX A6

ENVIRONMENTAL REQUIREMENTS CHECKLIST FOR PROJECT W-314

APP A-i

9810141322

HNF-3054, Rev. O


APP A-ii

HNF-3054, Rev. O

Summary of Potential Project W-314Environmental Permits, Approvals, or Requirements

Affected Permit, approval, Regulating Responsible Applicabilityenvironment or requirement nr standard agency (Yes or no and assumed action]

VEPA NEPA Documentation 40 CFR 1500-1508 DOE Yes10 CFR 1021 TWRS EIS & SupplementDOE Order 451.1A Analysis (<10 pages). May

submit to Ecology foracceptance,

;EPA SEPA Documentation WAC 197-11 Ecology YesAdoption Notice or letter sent toEcology with SupplementAnalysis in Lieu of SEPA

Checklist.dl Media Cultural Resource 10 CFR 1021 DOE Yes

Review 36 CFR 63 State Historic CRR required for the 200 East36 CFR 800 Preservation alternate transfer route.43 CFR 7 Office

Ecological Compliance 10 CFRIO21 DOE YesReview DOE Order 5484,1 USFWS ECR will be required for

50 CFR 17 Ecology 200 East alternate transfer route50 CFR 402.6 not covered by the tank farmWAC 232-12 ECR, Reportkwillb previewed

for restrictions or impacts priorto obtaining excavation permit

American Indian DOE 1230.2 DOE NoPolicies Review 42 USC 1966 BIA

Excavation Permit 36 CFR 800 DOE YesIncludes review of NOC

conditions, & review ofECRICRR

Preoperatiomd DOE Order 5400.1 DOE YesMonitoring of Facility, Preoperational Monitoring

Site, rmd Operations , required for 200 East alternatetrrmsfer outside tank farm

boundaries (not previously

Gcncml ~ublic &evaluated).

DOE Order 5400.1 DOE YesEnvironmental DOE Order 5400.5 Covered by compliance withProtection; radiological/Radiation Protection ALARA requirements in workStandards }ackages during construction.

,1[Air Air Operating Permit WAC 173-401 Ecology Yes,missions WDOH AOP will require revision for

EPA radionuclide emissions only. No

changes to TAPs provisions ofAOP,

9810141322 APP A-1

HNF-3054, Rev, O


Affected Permit, approval, Regulation Responsible Applicabilityenvironment or requirement or standard agency (Yes or no and assumed action)

Non- New Source RevieW WAC 173-400-110 Ecology Yes

Radioactive Sorrme Registration WAC 173-400-101 Memo to file documenting

Air Emissions evaluation. Conclude “no newsource.”

Substantial Alteration WAC 173-400-114 Ecology Noof Emission ControlTecfmology

Prevention of WAC 173-400-141 Ecology YesSignificant Criteria Pollutant evaluationDcteriomtion (e.g., particulate) performed

with TAPs applicabilityevaluation. Include evaluation inmemo to file for TAPs.

Toxic Air Pollutants WAC 173-460-030 Ecology Yes(TAP) /NOC; WAC 173-460-040 Perform TAPs applicabilityNew Source Review evaluation. Prepare memo to tile

docrrmenting “no new sourcerequired’.

Radioactive Source Review/NOC; WAC 246-247-060 WDOH Yes

Air Emissions Radiation Protection WAC 246-247 Assumes two (2) short fomr-Air Emissions NOCSNESHAP 40 CFR 61 Subpart H EPA Yes

Assmrres a short form NOC toEPA for approval, in parallel

with NOC short form submittalto WDOH.

Domestic Waste Septic Systems WAC 246-272 WDOH NoWater Disposal <14,500 gpd capacity

Septic Systems WAC 173-216 Ecology No>14,500 gpd capacity WAC 173-240

WAC 173-221, -221A

Storm Water Storm Water 40 CFR 122 EPA No

Disposal Discharge Under WAC 173-226 EcologyGeneral PcrnritStorm Water WAC 173-218 Ecology NoDischarge Under UICPermit

Drinking Water Engineering Approval; WAC 246-290.—

supply

WDOH NoSystem ID. NumberOperator Certdication WAC 246-292 WDOH No

Radioactive Reproccssiag, DOE Order 5820.2A DOE Yes

Waste Management, or DOE Order 6430. 1A EPA

Management Disposal of Spent 10 CFR 962 NRCNuclear Fuel 40 CFR 191

981014.1322 ‘ APP A-2

HNF-3054, Rev. O


Affected Permit, approval, Regulation Responsible Applicabilityenvironment or requirement or standard agency (Yes or no and assumed action)

lolid Waste Solid Waste WAC 173-304 Ecology NoManagement DOE 5400.1 DOE

BCHD

)angerous Dangerous Waste WAC 173-303 Ecology Yes

Vaste Management 40 CFR 260 through EPA Per schedule, all definitive

268 design will be complete by cut-

off date of December 1999 (lastinput to Part B application.)Due date for Pmt B submittal toEcology is Jrme 2000. RevisedPart A to be submitted with PartB application and not as aseparate activity. Supportsubmittal of design drawingswith Part B submittal rmdrevisious as needed.

Notice of Intent (NOI) WAC 173-303-281 Ecology No

JSTS Underground Storage WAC 173-360 Ecology NoTank Permit 40 CFR 280 EPA

pecial Polychlorinated 40CFR761 EPA No

ubstances biphenyls WAC 173-303 EcologyUsed oils WAC 173-303 Ecology No

40 CFR 279 EPAAsbestos BCCAA Reg. 1, BCCAA No

Article 8 EPA40 CFR 61

Chlorofluoro- 40 CFR 82 EPA No

carbonsOzone DepletingSubstancesPollution Prevention WAC 173-307 Ecology YesPlans for Hazardous This is covered by TWRS

Substances and internal procedures,

WastesNotification/ 40 CFR 302 EPA YesReporting of 40 CFR 372 Ecology This is covered by sitewide arrd

Hazardous Materials WAC 173-340 TWRS internal procedures.

Spills/Releases

981014.1322 APP A-3

HNF-3054, Rev. O


Abbreviations

ALARABCCAABCHDBfACRRCFRDOEEcologyECREPAgpdNEPANESHAPNOCNRC

SEPAUICUscUSFWSUSTWACWDOH

as low as reasonably achievableBenton County Clean Air AuthorityBcnton County Health DepartmentBureau of Indian AffairsCultural Resources ReviewCode of Federal RegulationsUnited States Department of EnergyWashington State Department of EcologyEcological Compliance Review EPAU.S. Envirorrrrmntrd Protection Agencygallons per dayNational Environmental Policy ActNational Emission Standards for Hazardous Air PollutantsNotice of ConstructionU.S. Nuclear Regulatory CormnissionState Environmental Policy Actunderground injection controlUnited States CodeU.S. Fish and Wildlife Service

underground storage tankWashington Administrative CodeWashington State Department of Health

981014.1322 APP A-4

981014,1322

HNF-3054, Rev. O

APPENDIX B

PROJECT W-314 PERMITTING APPROVAL SCHEDULE

APP B-i

981014.1322

HNF-3054, Rev. O


APP B-ii

Estimated Cost and Schedules to Obtain Permits and Provide Support for Desigrr nud Construction,

Area/location T~e of envirourrrentalLabor type

Effort Estimated Task dnrationlassumptions /scheduleof task perrnitkegulatory task (hours) cost ($) complete

o BTAfN PERMITS AND APPROVA LS

General Phase 1 Environmental Plauuing Exempt 200 14,000 6 WeeksSummary and Permit Plan Non-Exempt 30 1,050 Complete by October 30, 1998Revision (FY 1998)

Phase I Envirorrrnental Permit Exempt 50 3,500 6 WeeksPlan Update (FY1999) Non-Exempt 5 175 Complete by July31, 1999

Phase I Environmental Permit Exempt 50 3,500 6WeeksPlan Non-Exempt 5 175 Complete by July31, 2000 g

~ Update (FY 2000) ~

wg

w“*

LPhase I Environmental Permit

xExempt 50 3,500 6 Weeks :

Plan Update (FY2001) Non-Exempt 5 175 Complete byJnly31, 2001 0

National Envirorunental Policy Exempt 200 14,000 5 MonthsAct Non-Exempt 20 700 Complete prior to finishing Definitive(Supplement Analysis) Design for the 200 East Alternative Route

State Environmental Policy Act Exempt 10 700 1 MonthAdoption Notice or letter to Non-Exempt 1 35 Submit with Supplement Analysis whentransmit Supplement Analysis trarrsmitted to Ecology

Estimated Cost and Schedules to Obtain Permits and Provide Support for Desigrr and Construction

Area/location T}pe of environmentalLabor type

Effort Estimated Task duratiotiassumptions /schedule

of task pemrithegrdatorv task (hours) cost ($) complete

o BTAIN PERMI TS AND APPROVA LS

General Notice of Construction (NOC) Exempt 570 39,900 6 Months (Each NOC)

Radioacth,e Air Emissions: Non-Exempt 57 1,995 Assmnes one new short-form NOC for

Prepare and submit one nc!v waste transfer route (Exempt –

short-form NOC. Assume no 35,000 hourshronexempt -37 hours) and

BARCTITBACT assessment one additional short-forrn NOC (Exempt –

required. 220 honrshronexempt -20 hours) during

Phase I construction. Begin preparing NOC

application for the Alternate Line Route byOctober 1, 1999 and snbmit to WDOH byJmre 15, 1999 to support a April 1, 1999construction start date.

NOC: National Emission Exempt 80 5,600 1 Month (Each NOC)

Standards for Hazardous Air Non-Exempt 8 280 Assumes one NOC for Alt. Line Route and

pollutants (NESHAP): Prepare one other during construction. Submit NOC

and submit two (2) revised or to EPA by August 15, 1999 to support a

new NOC to EPA October 1, 1999 construction start date.Due Dates for second application TBD.

Air Operating Permit (AOP): Exempt 20 1>400 1 Month (Each NOC)

Incorporate NOC approval Non-Exempt 2 70 Submit changes as soon as each NOC has

conditions from NOC submittal been approved.

above

Estimated Cost and Schedules to Obtain Permits and Provide Support for Design and Construction

Area/location Type of environmentalLabor type

Effort Estimated Task duration/assmnptions /scheduleof task permithegulatorv task (hours) cost ($) complete

NOC - Toxic Air Pollutants Exempt 40 2,800 1 Month(TAP): Memo-to-file thata Non-Exempt 4 140 Completeby December 30,1998. AssumesTAP NOC will not be required that the evaluation concludes that no TAP

exceeds the Small Quantity Emission Limit..

o BTAIN PERMI TS AND APPROVA LS

General New Source Review (NSR), Exempt 20 1,400 1 MonthSource Registration: Memo-to- Non-Exempt 0 0 Complete by December 30, 1998file that New SourceRegistration will not be required.

Prevention of Significant Exempt 20 1400 1 MonthDeterioration (PSD): Memo-to- Non-Exempt 1 35 Complete by December 30, 1998file that PSD will not be required

200 East Altemati\,e Cultural Resources Review Exempt 20 1,400 1 MonthRoute (cm) Non-Exempt 1 35 Complete by December 30, 1998

Updatedhrew CRR for new route

Ecological Compliance Review Exempt 20 1,400 1 Month(ECR): Updatedhrew ECRto Non-Exempt 1 35 Complete by December 30, 1998cover new route.

Preoperational Monitoring: Exempt 321 22,470 1 YearConduct preoperational Non-Exempt 30 1,050 Evaluate existing data and supplementmonitoring, including sampling Analytical existing data with additional samples asof soil, air, and vegetation costs 45,000 required. Assume 10 soil samples, and 4

vegetation samples at $3,000 per sample.Assume 6 TLD’s at 500.00 per TLD



Effort Estimated Task durationlassurnptions /schedule

of task permitkegulatom task (hours) cost ($) complete

‘OTAL HOURS AND Exempt 1671 115,920

;OST TO OBTAfN Non-Exempt 170 5,950

‘ERMITS & Analytical

iPPROVALS costs 45,000

DES IGN AND CON STRUCTION SUP PORT

I.N Farm and Valve Pit Design Review, Support: Exempt 45 3,150 1 Week per design package@ 10 hours per

Jpgrades Revie\v 30%, 60% and final Non-Exempt o 0design packages, and ECN’S

package (30 hours, assuming 3 reviews) and15 hours for review of ECN’S to design

during construction package during construction.

Excavation Permit: Exempt 10 700 1 Month

Environmental support for CRR, Non-Exempt 1 35 Permits to be issued to support each

ECR and other issues. construction package.

Air Emissions: Technical issue Exempt 192 13>440 12 Monthsresolution during constmction Non-Exempt 19 665 Planning basis is 4 exempt hours per week.

(E.g., clarification of permit Includes clarification of current NOC

conditions), regulato~ interface, conditions andtechnical issue resohrtion

compliance inspections, and during construction, Construction

audit support during completion, including trmrover is September

construction.. 30, 1999.

Dangerous Waste Technical Exempt 48 3360 12 Months

issue resolutiordregul story Non-Exempt o 0 Planning basis is 1 exempt hour per week,

interfacdcompliance inspection Construction completion, including turnoverduring construction is September 30, 1999.

Estimated Cost and Schedules to Obtain Permits and Provide Support for Desigrr and Constriction


Effort Estimated Task duratiordassumptions /schedule

of task permitiregrrlatorw task (hours) cost ($) complete

Standard Startup Review (SSR) Exempt 100 7,000 6 Months

as defined in HNF-PRO-055 Non-Exempt 10 350 Assume 90% MH in last 2 mths; prep. of 3affidavits (15 Irrs each ,incl. revs); attend 8

SSR meetings (7 @ 2 trrs, l@,l hr.); dot.review /reproduction (10 hrs), and project

walkdowrrs (3 Ohours)


AZ Farm and Valve Pit Design Review Support: Exempt 45 3>150 1 Week per design package (Q, 10 hours per

Upgrades Review 300/., 60% and final Non-Exempt o 0 package (3 Ohours) and 15 hours for review

desigm packages, and ECN’S of ECNS to design package daringduring construction constriction.

Excavation Permit Exempt 10 700 1 Month

Erwironmental support for CRR, Non-Exempt 1 35 Permits to be issued to support each

ECR and other issues. , construction package.

Air Emissions: Technical issue Exempt 120 8,400 15Monthsresolution during construction Non-Exempt 12 420 Planning basis is 2 exempt hears per week.( E.g., clarification of permit Assmnes some efficiency with multiple

conditions), regalato~ interface, work packages mrderway simultaneously.

compliance inspections, and Support includes clarification of cnrrentaudit support during NOC conditions and techrical issue

construction.. resolution daring constrrrction.Constriction start date is Jmre 2000.Constriction completion date is

October 31,2001. Scheduled tarnover dateis January 3,2002.

Estimated Cost and Schedules to Obtain Pernrits and Provide Support for Design and Construction.


Effort Estimated Task duration/assumptions /scheduleof task permithegulatorw task (hours) cost ($) complete

Dangerous Waste: Technical Exempt 30 2,100 15Monthsissue resohrtionkegulato~ Non-Exempt o 0 Planning basis is 0.5 exempt hour per week.interface/compliance inspection Assumptions and construction statiendduring construction date is the same as above.

Standard Startup Review (SSR) Exempt 100 7,000 6 Monthsin accordance with HNF-PRO- Non-Exempt 10 350 Assume 90% MH in last 2 mths; prep. of 3055 affidavits (15 hrs each ,incl. revs); attend 8

SSR meetings (7@2trrs, l@lhr.); doc.review /reproduction (10 hrs), and projectwalkdowrrs (30 hours)


Aaster Pump Shutdown Design Review Support: Exempt 45 3,150 1 Week per design package@ 10 hours perMPS) Upgrades Review 30%, 60% and final Non-Exempt o 0 package (30 hours) and 15 hours for review

design packages, and ECN’S of ECN’S to design package duringduring construction construction.

Excavation Permit Exempt 10 700 1 MonthEnvironmental support for CRR, Non-Exempt 1 35 Permits to be issued to support eachECR and other issues. construction package.

Air Emissions: Technical Issue Exempt 54 3780 27 Months

resolution drrring construction Non-Exempt o 0 Planning basis is 0,5 exempt hour per week.

(E.g., clarification of permit Some etkiency assumed with multiple work

conditions), regulatory interface, packages in process simultaneously. Support

eumpliance inspections, andincludes clarification of current NOC conditions

audit support duringand technical issue resolution duringconstnrction. Construction skut date is

eunstruction. October 1, 1999 with completion September 18,2002, and turrrovm September 3,2002.

Area/location

of task

Estimated Cost and Schedules to Obtain Permits and Provide Support for Design and Construction.

Type of environmentalpermitiregulaton, task

Dangerous Waste Technicalissue resolution/regulatoVinterface/compliance inspection

during constnrction

Operational Readiness Revie\vwith full RL participation inaccordance with HNF-PRO-055

Labor type

Exempt

Non-Exempt

ExemptNon-Exempt

Effort

(hours)

54

0

18820

Estimatedcost ($)

3>780

0

13,160700

DESIGN AND CONSTRUCTION SUPPORT

=

Review 30%, 60% and final

Excavation PermitEnvironmental support for CRR,ECR and other issues.

ExemptNon-Exempt

ExemptNon-Exempt

450

101

3,1500

70035

Task durationlassumptions /schedulecomplete

27 MonthsPlanning basis is 0.5 exempt hours per week

with same assumptions and constructionstarVend dates as above.

12 MonthsAssume 90% MH in last 6 mths; prep, of 6affidavits (15 Irrs each, incl. revs); attend 24mtgs.(2 b.rs each); doc review (20 hrs); andissue/cOmment resolution (3Olrrs).

1 Week per design package@ 10 hours per

package (30 hours) and 15 hours for reviewof ECNS to design package duringconstruction.

1 MonthPemrits to be issued to suppost eachconstruction package.

Estimated Cost and Schedules to Obtain Permits and Provide Support for Desigrr and Construction.

Area/location T~-pe of environmentalLabor type

Effort Estimated Task duratiorr/assrrmptions /schedule

of task perrnitkegrdatorw task (hours) cost ($) complete

Air Emissions: Technical issue Exempt 104 7,280 13 Months

resolution during construction Non-Exempt 10 350 Plaming basis is 2 exempt hours per week.

(E.g., clarification of NOC Assume some efficiency with multiple

approval conditions), regulatory upgrade packages in processinterface, compliance simultaneously. Support includesinspections, and audit support clarification of current NOC conditions and

during construction. technical issue resolution duringconstruction. Theconstruction start date,according to the Multi-Year Work Plan, isOctoberl, 1999. The constructioncompletion date is August 2,2001 withturnover occurring on September 28,2001.

Dangerous Waste: Technical Exempt 26 1>820 13 Monthsissue resolutionhegulato~ Non-Exempt o 0 Planning basis is 0.5 exempt hours perinterface/cOmpl iance inspection week. Assumption arrdconstruction startduring construction andenddate arethe same as above.

Readiness Assessment (RA) in Exempt 150 10,500 12 Months

accordance ivith HNF-PRO-055 Non-Exempt 15 525 Assume 90% MH in last 6 mths; prep. of 6

affidavits (15 hrs each ,incl. revs); attend 16mtgs.(2 Irrs each); doc review (1Obin); and

issue resolution (18 hrs)

Estimated Cost and Schedules to Obtain Perrrrits and Provide Support for Design and Constrrrction.


Effort Estimated Task drrrationlassmrrptions /schednleof task perrrrit/regul atory task (hours) cost ($) complete

DES IGN AND CON STRUCTION SUPPORT

AWFarrrr and Valve Pit Design Revie\v Support: Exempt 45 3>150 1 Week per desigrr package @ 10 hours perUpgrades Review 30%, 60% and final Non-Exempt o 0 package (30hours) and 15hoars forreview

desigrr packages, and ECN’Sduring construction

of ECN’S to design package duringconstriction.

Excavation Permit, Exempt 10 700 I MonthEnvironmental support for CRR, Non-Exempt 1 35 Perrrrits to be issued to support eachECR and other issues. construction package,

Air Emissions: Technical issue Exempt 104 7>280 13Monthsresolution during construction Non-Exempt 10 350 Plaming basis is 2 exempt hours per week.(E.g., clarification of perrrrit Assume some efficiency with multiple workconditions), regulato~ interface, packages in process simultaneously.compliance inspections, and Support includes clarification of cnrrentaudit support during NOC conditions arrd techrical issueconstriction. resolution daring construction, The

construction start date is October 1,2001.The construction completion date is October30,2002. Turnover isscheduled for

December 31,2002.

Dangerous Waste: Technical Exempt 26 1>820 13 Monthsissue resolutiotiregul story Non-Exempt o 0 Paining basis is 0,5 exempt hears per week.interface/compliarrce inspection Assmrrption and constnrction start/end datesduring construction same as above



Effort Estimated Task duratiotiassumptions /scheduleof task perrrritkegalatorv task (hours) cost ($) complete

Standard Startup Readiuess Exempt 100 7,000 6 Months(SSR) Non-Exempt 10 350 Assmrre 90% MH in last 2 mths; prep, of 3in accordance with HNF-PRO- affidavits (15 hrs each ,irrcl. revs); attend 8055 SSR meetings (7 @ 2 hrs, l(i?jll hr.) ; dot.

review /reproduction (10 hrs), and projectwalkdowrrs (30 hours)


.Y Farm and Valve Plt Design Review Support Exempt 45 3,150 1 Week per desigrr package @ 10 hours perJpgrades Revie\v 30%, 60°A and final Non-Exempt o 0 package (30hours) and 15hours forreview

design packages, and ECN’S of ECN’sto design package duringduring construction construction.

Excavation Permit Exempt 10 700 1 MonthEnvironmental support for CRR, Non-Exempt 1 35 Permits to be issued to support eachECR and other issues. construction package.

Air Emissions: Technical issue Exempt 184 12,880 23 Monthsresolution during construction Non-Exempt 18 630 Planning basis is two exempt lrdwk(E.g., clarification of permit Assmue some efficiency w/ multiple pkgs inconditions), regulatory interface, process simrdtaneously. Support includescompliance inspections, and clarification of current NOC conditions andaudit support during technical issue resolution duringconstruction. construction. Theconstruction start date is

October 2,2000. Theconstnrctioncompletion dateus May 2,2002. Turnoveris scheduled for Jmre 28,2002.

Dangerous Waste: Techoical Exempt 46 3,220 23 Months

issue resolutionkegrdatory Non-Exempt o 0 PkuuringbasisisO .5exempthoursper week.

interface/compliance inspection Assurrrption and construction startJend date same

Estimated Cost and Schedules to Obtain Permits and Provide Support for Desigr and Construction.

Arealocation Type of environmentalLabor type

of task permith’egulatory task

during construction

Standard Startup Review (SSR) Exempt

per HNF-PRO-055 Non-Exempt

TOTAL HOURS AND Exempt

COST Non-Exempt

Effort Estimated Task duratiorr/assumptions /schedule

(hours) cost ($) completeas above.

100 7,000 6 Months

10 350 Assume 90% MH in last 2 mths; prep. of 3

affidavits (15 brs each ,incl. revs); attend 8SSR meetings (7@2hrs, l@lhr.); doc.review /repro.( 10 hrs); and project

walkdowns (3 Ohours)

2,056 143,920150 5,250

HNF-3054. Rev. O


APP B-12

DISTRIBUTION SHEETTo From Page 1 of 1

Distribution Waste Feed Delivery Program Date 08/26/98ProjectTitle/WorkOrder EDT No. 624002

Project W-314, Environmental Permits and Approvals P1an ECN No.

Text Text Only Attach./ EDT/ECNName MSIN With All Appendix Only

Attach. Only

T. W. Bohan S5-04H. L. 8oston R2-53D. E. 8owers 55-13D. J. Carral1 R1-51D. B. Cole R3-25G. D. Cummins H6-26T. A. Dillhoff R1-51B. G. Erlandson R1-51J. D. Galbraith R3-73J. S. Garfield R3-73J. L. Gilbert R3-47D. M. Hammond R1-44J. L. Homan R1-44R. W. Jacobson SO-09K. W. Leliefeld SO-09D. L. McGrew R3-25R. P. Marshall R3-74E. E. Mayer R2-50P. C. Millar R1-51C. H. Mulkey R1-51I. G. Papp R3-73R. D. Potter R3-J3R. W. Powell H5-03R. W. Root R2-53W. T. Thompson R3-73K. S. Tollefson R1-51R. L. Treat R3-73R. D. Wojtasek R2-53Central Fi1es 81-07TWRS TFRC

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x

;xxxxxx

x

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x

x

x

A-6000-135 (01/93) UEF067

Documents

Cn OCT2119 s~#@ 4 2. To: (Receiving Organization) 3. From: …/67531/metadc718256/m2/1/high_re… · Project W-314 will restore zmd/or upgrade existing Double-Shell Tank (DST) System