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Honeywell Performance Materials and Technologies Honeywell P.O. Box 430 2768 North US 45 Road Metropolis, IL 62960 July 2, 2013 UPS/Next Day Air Attention: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 References: Docket No. 40-3392; License SUB-526 SUBJECT: SUPPLEMENTAL INFORMATION FOR POND CLOSURE LICENSE AMENDMENT REQUEST On December 2, 2010, Honeywell submitted a license amendment request related to the proposed decommissioning and partial site release of the pond areas at MTW (ADAMS Accession No. ML 103400520), as supplemented in subsequent correspondence. Honeywell participated in a telephone call with the NRC regarding the application on June 28, 2013. Based on those discussions, Honeywell is providing supplemental information relating to the application. First, Honeywell is providing the NRC with information regarding correspondence with other agencies relating to the proposed pond closure. Briefly, MTW is seeking to amend its Resource Conservation and Recovery Act (RCRA) permit No. B-65R to permit in-place closure concurrent with the decommissioning action under NRC regulations. As part of the closure process, MTW has submitted to the Illinois Environmental Protection Agency (IEPA) an application to modify MTW's RCRA Permit to allow MTW to close the ponds under RCRA regulations governing closure in place. The in-place closure also requires a modification of an associated waiver issued by the U.S. Environmental Protection Agency (USEPA) in 1987. Honeywell has requested a waiver modification from USEPA and is working with USEPA on the technical support for this waiver modification. A copy of the following correspondence is attached to this letter: * Letter from S. Chisek, Andrews Engineering, to S. Nightingale, Illinois Environmental Protection Agency, November 29, 2010 (Attachment 1 - Permit Modification Request) * Letter from L. Smith, Honeywell, to S. Nightingale, Illinois Environmental Protection Agency, dated September 7, 2012 (Attachment 2 - Permit Renewal Application) * Letter from S. Bodine, Barnes & Thornburg, to M Guerriero, USEPA Region 5, dated April 16, 2012 (Attachment 3 - Waiver Modification Request)
Transcript

Honeywell

Performance Materials and TechnologiesHoneywellP.O. Box 4302768 North US 45 RoadMetropolis, IL 62960

July 2, 2013

UPS/Next Day Air

Attention: Document Control DeskDirector, Office of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory Commission11555 Rockville PikeRockville, MD 20852

References: Docket No. 40-3392; License SUB-526

SUBJECT: SUPPLEMENTAL INFORMATION FOR POND CLOSURE LICENSEAMENDMENT REQUEST

On December 2, 2010, Honeywell submitted a license amendment request related to theproposed decommissioning and partial site release of the pond areas at MTW (ADAMSAccession No. ML 103400520), as supplemented in subsequent correspondence.Honeywell participated in a telephone call with the NRC regarding the application onJune 28, 2013. Based on those discussions, Honeywell is providing supplementalinformation relating to the application.

First, Honeywell is providing the NRC with information regarding correspondence withother agencies relating to the proposed pond closure. Briefly, MTW is seeking to amendits Resource Conservation and Recovery Act (RCRA) permit No. B-65R to permit in-placeclosure concurrent with the decommissioning action under NRC regulations. As part ofthe closure process, MTW has submitted to the Illinois Environmental Protection Agency(IEPA) an application to modify MTW's RCRA Permit to allow MTW to close the pondsunder RCRA regulations governing closure in place. The in-place closure also requires amodification of an associated waiver issued by the U.S. Environmental Protection Agency(USEPA) in 1987. Honeywell has requested a waiver modification from USEPA and isworking with USEPA on the technical support for this waiver modification. A copy of thefollowing correspondence is attached to this letter:

* Letter from S. Chisek, Andrews Engineering, to S. Nightingale, IllinoisEnvironmental Protection Agency, November 29, 2010 (Attachment 1 - PermitModification Request)

* Letter from L. Smith, Honeywell, to S. Nightingale, Illinois Environmental ProtectionAgency, dated September 7, 2012 (Attachment 2 - Permit Renewal Application)

* Letter from S. Bodine, Barnes & Thornburg, to M Guerriero, USEPA Region 5,dated April 16, 2012 (Attachment 3 - Waiver Modification Request)

Second, Honeywell is providing an assessment of the impacts associated with analternative that was not specifically discussed in our application. The environmentalimpacts of this alternative are addressed below:

Alternative: Ex-situ stabilization followed by on-site placement in a newly-constructed landfill

Under this alternative, radiologically-contaminated materials would be removedfrom the facility, stabilized through the addition of Portland cement or similarpozzolanic material, and placed in a newly-constructed landfill with an engineeredRCRA cover and liner system at the site. This alternative is not the preferredalternative. This alternative would have no net environmental benefits relative tothe other alternatives. The environmental impacts of excavation would be similarto those associated with the offsite disposal alternative. The environmentalimpacts associated with a new onsite landfill would be similar to the proposedaction, but with the additional impacts associated with construction of the newlandfill and increased dose to workers associated with removal of the materialsfrom the ponds and transfer to a newly-constructed cell. There would be no landuse benefit associated with this alternative since the land lost to the newly-constructed cell would offset the land gained from unrestricted release of the pondareas. In addition, both the preferred alternative and the on-site landfill would beprotective of human health and the environment because both would comply withapplicable state and federal requirements for on-site waste facilities. Thisalternative is not environmentally preferable to the proposed action.

Please contact Mark Wolf at (618) 309-5013 should you have any questions or requireadditional information.

Sincerely,

Sry mith

Plant anager

Attachments: as stated

cc:

Tilda Liu, Sr NMSS Project ManagerMail Stop EBB 3WFN-13A44U.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

2

Attachment 1

A& ANDREWSENGINEERING, INC.

November 29, 2010

Mr. Steve Nightingale, P.E., ManagerPermit Section, Bureau of LandIllinois Environmental Protection Agency1021 N. Grand Ave. EastSpringfield, Illinois 62794-9276

Re: 1278540002 - Massac CountyHoneywell International Inc.ILD006278170RCRA Part B Permit No. B-65RClass 3 Permit Modification Request

N Surface Impoundment Closure PlanPUBLIC RECORD CLAIMED EXEMPT IN PART

Dear Mr. Nightingale:

On behalf of Honeywell International Inc. (Honeywell), enclosed are an original and three copies of aClass 3 permit modification request to Honeywell's RCRA Part B permit (Permit No. B-65R).

In accordance with 35 III. Adm. Code 1828.401, we are making the claim that portions of theenclosed document are exempt from public disclosure. Specifically, we claim the referenced figuresand detailed closure cost estimate are exempt from public disclosure.

Due to security concerns, the Illinois EPA has previously granted the referenced figures exemptstatus; the enclosed figures are simply updated versions. As you know, the Honeywell facilitymanages and processes radioactive materials in accordance with policies of the Nuclear RegulatoryCommission. Stringent security measures are in place to prevent disclosure of information that couldpose a security risk; the enclosed figure contains such information.

The detailed closure cost estimate is considered confidential business information in accordance with35 III. Adm. Code 1828.202(a)(1)(F). This information is of a type that is customarily held inconfidence by Honeywell.

In accordance with 35 III. Adm. Code 1828.401(c)(2)(D), we have included one "clean" copy of theClass 3 modification request that does not contain the portions of the modification request we areclaiming as exempt from public disclosure.

If you have any questions or require further information, please contact me at (217) 787-2334. Thankyou.

Sincerely,

Sean C. Chisek, P.E.Project EngineerSCC:scc:sjbEnclosure(s)cc: Mark Wolf- Honeywell International Inc., Metropolis Works

Ken Sendelsky - Honeywell International Inc.Gene Thomas - Honeywell International Inc.Mara Hollinbeck - CH2M Hill, Inc.Gerry Williams, P.E. - Enercon Services, Inc.

\ aeai1•bsl1991•91 -135MM%2010V-wdsClosure%,pplcabonC0verLett 11-29-2010.doc,. AppOcatiris

3300 Ginger Creek Drive, Springfield, Illinois 62711 + 217.787.2334 tax 217.787.9495 www.andrews-eng.com

Attachment 2

Honeywell

Performance Materials and TechnologiesHoneywellP.O. Box 4302768 North US 45 RoadMetropolis, IL 62960

September 7, 2012

Mr. Stephen Nightingale, P.E.

Manager, Permit SectionBureau of Land

Illinois Environmental Protection Agency

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, Illinois 62794-9276

Subject: 1278540002 - Massac County

Honeywell International Inc.

ILD006278170

Permit No. B-65R Renewal Application

Dear Mr. Nightingale:

Enclosed are an original and three copies of a renewal application for the Honeywell

International Inc., Metropolis Works (Honeywell) RCRA Part B Permit No. B-65R. Copies

have also been sent to the public repositories and U.S. EPA Region 5. Please note thefollowing clarifications:

1. Throughout the RCRA Part B permit renewal application the following definitions

apply.

a. Honeywell - Refers to all property owned by Honeywell International Inc. at thislocation. The term Honeywell is also synonymous with Honeywell International Inc.

Metropolis Works. A legal description of Honeywell is contained in Section B,

Attachment B-3. For purposes of this permit renewal application, withinHoneywell are corrective action areas and RCRA-permitted units.

b. The Controlled Area or the Fenced Area - Refers to the area surrounded by

security fencing where production operations occur. This area is licensed by theNuclear Regulatory Commission (NRC). The Controlled Area (a.k.a. the Fenced

Area) is shown in Section B, Figures B-2.0 and B-2.2. The RCRA-permitted units,including two container storage areas and four surface impoundments, arelocated within this area.

2. In the form 39(i) certification:

a. For question No. I, which asks whether Honeywell or its owners or offers "everowned or operated waste sites, waste transportation operations or CCDD filloperations (anywhere) at anytime," the Honeywell corporate history extends backmore than 125 years and includes more than a thousand locations. Accordingly,Honeywell is responding to this question with information about currentlypermitted U.S. waste sites, waste transportation operations or CCDD filloperations at Honeywell International Inc. sites as listed by the U.S. EnvironmentalProtection Agency. This information does not include sites where Honeywell'ssole involvement relates to cleanup activities.

b. For question No. [[(a), Honeywell understands this question to refer to "federal,state, or local laws, regulations or ordinances" governing waste or CCDD.

BackgroundHoneywell is located at 2768 North US 45 Road, Metropolis, Massac County, Illinois.Honeywell began operations in 1958 and converts uranium ore concentrates intouranium hexafluoride (UF6), produces gaseous fluorine for captive use, and producescalcium fluoride, a byproduct. Honeywell previously produced other fluorine containingproducts, including: sulfur hexafluoride, iodine pentafluoride, and antimony pentafluoride.

Routine operations result in the generation of hazardous wastes. Honeywell managescertain of these wastes pursuant to a RCRA permit. Honeywell's initial Part B permit wasissued by U.S. EPA on March 31, 1987. On February 3, 2003, the Illinois EPA approved thecurrent Honeywell Part B permit. The 2003 permit approved storage of certain wastes incontainers in an area referred to as the Lab Storage Area; four surface impoundmentsreferred to as Ponds B, C, D, and E; and corrective action activities for Solid WasteManagement Units (SWMUs). In 2001 Pond A was closed by removal. On January 10,2003, the Illinois EPA certified RCRA closure of Pond A.

Honeywell has received approval of a number of permit modifications including amodification approved July 15, 2008, adding a new storage area referred to as thePotassium Hydroxide/Sodium Hydroxide Muds container storage area. On September 8,2010, the Illinois EPA approved a modification to the Part B permit that allowed storageof Ammonium Diuranate (ADU) muds in this area, and changed its name to theKOH/NaOH/ADU muds container storage area.

On November 29, 2010 Honeywell submitted a Class 3 permit modification request (LogNo. B-65R-M-18) to change the closure plan of Ponds B through E. This permitmodification request proposes to close Ponds B through E in-place and currently is underreview.

2

Groundwater MonitoringAt the time of this submittal, groundwater is monitored under five distinct monitoringprograms. These groundwater monitoring programs are listed and summarized below;detailed descriptions of the groundwater monitoring programs are contained in SectionsE and K of the attached permit renewal application.

" RCRA Ponds - The RCRA Ponds monitoring program (previously referred to as theRCRA Part B Groundwater Monitoring Program) monitors the regulated units referredto as Ponds B through E.

" Chlorinated Solvent/Arsenic Area Groundwater Investigation - The ChlorinatedSolvent/Arsenic Area Groundwater Investigation (previously referred to as the RCRAGroundwater Investigation) was performed to investigate potential groundwaterimpacts related to historic operations in the Controlled Area.

" Kickback Area - The Kickback Area monitoring program monitors the SWMU locatedoutside the Controlled Area referred to as the Kickback Area.

" Creosote Area - The Creosote Area monitoring program monitors the SWMUs locateoutside the Controlled Area referred to as the Creosote Area.

" Landfill - The Landfill is a SWMU located outside the Controlled Area consisting of apermit exempt landfill in accordance with Section 21(d) of the Illinois EnvironmentalProtection Act.

Proposed ModificationsThis permit renewal application has been formatted in accordance with the Illinois EPA"RCRA Part B Permit Application Decision Guide," Revised July 2006. The only exceptionto this is D-4, Surface Impoundments. Section D-4 has been formatted in accordance withthe Illinois EPA "RCRA Part B Permit Application Decision Guide," December 1990,because the July 2006 version does not contain a section for surface impoundments.

This permit renewal application modifies the names of the container storage areas asfollows:

* Lab Storage Area - This container storage area is now named RCRA Small (a.k.a.Building 66).

" KOH/NaOH/ADU Muds Container Storage Area - This container storage area is nownamed RCRA Large (a.k.a. Building 26).

This permit renewal application proposes certain changes listed below, to the Part Bpermit.

3

" RCRA Large - It is proposed to reconfigure and reduce the capacity of RCRA Large. Adescription of the reconfiguration is contained in Section D1.

" Wastes Stored in RCRA Small and RCRA Large - It is proposed to store the samewastes in RCRA Small and RCRA Large. A description of these wastes is contained inSection C.

• Background RCRA Pond Monitoring Wells - It is proposed to modify the locations ofthe background wells. Information regarding the proposed revision is contained inSection E.

" Corrective Action - It is proposed to add an Area of Concern (AOC) consisting of theplant underground sewer systems. Information regarding this AOC is contained inSection K.

Example Procedures and LogsWithin this permit renewal application are example procedures and logs. These exampleprocedures and logs may be altered in the future to accommodate operational changes.However, Honeywell will maintain procedures and logs to demonstrate compliance withthe applicable RCRA requirements. Modification to these example procedures and logswill not constitute a modification to the Part B permit.

If you have any questions please contact Mark Wolf at (618) 524-6201. Thank you.

Very truly yours,

Plant Manager

Enclosure(s)

4

Attachment 3

BARNES &THORNBURG LLP Suite 500

1717 Pennsylvania Avenue N.W.Washington, D.C. 20006-4623 U.S.A.(202) 289-1313

Susan Parker Bodine Fax (202) 289-1330

(202) 371-6364 [email protected]

April 16, 2012

Margaret GuerrieroDirectorLand and Chemicals DivisionUS EPA Region 577 W. Jackson Blvd.Chicago, IL 60604

Re: Honeywell Metropolis, Illinois

Dear Margaret:

Thank you very much for making both yourself and your staff available to meet representativesof Honeywell on March 21, 2012. As we discussed in that meeting, Honeywell is seeking amodification of the November 6, 1987, variance from the minimum technology requirements ofsection 3004(o)(1) of the Resource Conservation and Recovery Act (RCRA) for four existing,permitted surface impoundments at the Honeywell facility in Metropolis, Illinois.

Following our meeting, your staff provided Honeywell with a copy of the July 8, 1986, GuidanceDocument on Interim Status Surface Impoundments Retrofitting Variances (OSWER Directive9894.00-1b) (EPA/530-SW-86-017). That guidance applies to the variances under Section30050) of RCRA. We understand that the EPA would use the criteria in the guidance to evaluatean application for a variance modification. In other words, the EPA would agree to modify thevariance as long as the application continued to meet the variance criteria.

As you know, the existing Metropolis variance is based on Section 3005(j)(4), which authorizesa variance from minimum technology requirements based on a demonstration that a surfaceimpoundment is located, designed, and operated so as to ensure that there will be no migration ofany hazardous constituent into groundwater or surface water at any future time. The originalMetropolis waiver was based on modeling showing no migration of hazardous constituents for atleast 44 years.

As noted in OSWER Directive 9894.00-1b, a demonstration of no migration also can be basedon the nature of the material in the pond. The guidance uses an example similar to thecircumstances of the Metropolis impoundments. In the example, the impoundments oncecontained a corrosive waste that had been neutralized and was not otherwise hazardous. TheMetropolis impoundments likewise once contained corrosive wastes, and the remaining sludgesare no longer corrosive (because they are not aqueous) or otherwise hazardous.

Atlanta Chicago Delaware Indiana Los Angeles Michigan Minneapolis Ohio Washington, D.C.

Margaret GuerrieroApril 16, 212Page 2

In addition to the "no migration" variance criteria under Section 3005(j)(4), we believe thatHoneywell could modify its variance using the variance criteria under Section 3004(o)(2). Thissection authorizes a variance from minimum technology requirements for impoundments basedon a demonstration that alternative design and operating practices, together with locationcharacteristics, will prevent the migration of any hazardous constituents into the ground water orsurface water at least as effectively as liners and leachate systems that meet minimum technologyrequirements. The availability of this variance to existing impoundments is noted in OSWERDirective 9894.00-1b, at 1-11. The applicability of 3004(o)(2) variances to existingimpoundments also is noted in an October 15, 1988, memorandum from Marcia Williams,Director, Office of Solid Waste, to Waste Management Division Directors (this memorandum isidentified as a supplement to OSWER Directive 9894.00-1b).

Before we prepare a formal application to modify the existing variance, we would like toschedule a meeting with your staff to discuss the technical aspects of the demonstrations to bemade under these two variances. In preparation for that meeting, we have reviewed the guidancesent by your staff, the October 15, 1988, memorandum discussed above, the September 15, 1986,Implementation Strategy for Surface Impoundment Retrofitting Exemptions (OSWER Directive9484.00-3), the July 1992 draft guidance on No Migration Variances to the Hazardous WasteLand Disposal Prohibitions (EPA/530R92023), and the preambles to the HSWA codificationrules. Please let us know if there are any other documents you believe are relevant.

In addition, at the appropriate time, we would like to meet with the green remediationcoordinator for the Land and Chemicals Division, to discuss opportunities to incorporate greenremediation elements into a plan to close the Metropolis impoundments in place.

Thank you again for your assistance. We greatly appreciate your willingness to work with us onthis matter.

Sincerely,

cc: Michael HarrisIgnacio ArrazolaLeverett NelsonMaria GonzalezJim Blough

BARNES&THORNBURG LLP


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