DOE OSTI2015
The U.S. Department of Energy (DOE) is responsible for the environmental cleanup of the Hanford Site central plateau. As part of this responsibility, DOE contractors conduct deactivation, decommissioning, decontamination, and demolition (D4) of retired/inactive facilities, including very large chemical processing facilities. To date, DOE contractors have demolished hundreds of facilities, reducing baseline site maintenance costs and reducing the environmental threats and hazards that the degrading buildings present. Many of these Hanford facilities include asbestos-containing materials (as well as other hazardous components), which must be managed in compliance with applicable regulations and standards. In most cases, the facilities are demolished as Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) removal or remedial actions. In an effort to streamline cleanup operations and to utilize site cleanup funding more efficiently, while still being protective of personnel and the environment, agreements were reached between the US Environmental Protection Agency (EPA) Hanford Project Office, the Washington Department of Ecology (Ecology), the Benton Clean Air Agency (BCAA) and the US Department of Energy Richland Operations Office (DOE-RL) on approaches to be utilized for demolition. One of these approaches would involve leaving cement asbestos board siding (e.g. transite), an EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP) Category II non-friable asbestos-containing material, in place during demolition using heavy equipment, employing a set of controls that would maintain protection of personnel and the environment. This agreement was documented in a number of formal communications, including Notices of Intent issued as required by the asbestos NESHAP regulation, letters between the various agencies, CERCLA work plans, and the approved contractor baselines. A large number of buildings were demolished with transite siding in place, using the agreed upon controls and approaches. Personnel breathing zone and work area perimeter monitoring verified that the controls employed were protective in that there were no exceedances of permissible exposure limits during or after the demolition operations. EPA later reconsidered their previous concurrence with demolishing transite materials in place and issued a joint letter with Ecology revoking concurrence on any of the aforementioned CERCLA decision documents and associated work plans. DOE and their contractors took action to comply with the approach to demolition preferred by EPA for future demolitions, and initiated a series of actions to modify asbestos management practices in their operations accordingly. This paper will discuss both the actions taken to address EPA concerns with sites where transite materials were left in place for demolition and actions taken to ensure that the central plateau D4 program complies with the 40 CFR 61 Subpart M, National Emission Standard for Asbestos, (Asbestos NESHAP) methods for asbestos management. (authors)
12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗