09 3 DOE/EH/OEV-33- P Copy U.S. Department of Energy Environment, Safety and Health Office of Environmental Audi t Environmental Survey Preliminary Repor t DOE Activities at Santa Susana Field Laboratories Ventura County, Californi a February 1989 HDMSP00042393 DOE/EH/OEV-33-P U .S . Department of Energy Washington, DC Environment , Safety and Health Office of Environmental Audi t 0 Environmental Survey Preliminary Repor t DOE Activities at Santa Susana Field Laboratories Ventura County, California February 1989 HDMSP00042394 PREFACE TO THE DEPARTMENT OF ENERGY SANTA SUSANA FIELD LABORATORIES ENVIRONMENTAL SURVEY PRELIMINARY REPOR T This repo rt contains the prelimina ry findings based on the first phase of an Environmental Survey at the U . S . Depa rt ment of Energy ( DOE) activities at the Santa Susana Field Laboratories Site (SSFL), located at Ventura County , California . The Su rv ey is being conducted by DOE's Office of Environment , Safety and Health . The Su rv ey is a po rt ion of the larger , comprehensive DOE Environmental Survey encompain call major operating facilities of DOE . The DOE Environmental Survey is one of a series -of i, itiatiies announced on September 18, 1985 , by Secreta ry of Energy, John S . Herrington ,, t9strengthen `the environmental, safety, and health programs and activities within DOE . The,purpose of the: Environmental Su rv ey is to identify , via a "n o-fault " baseline Su rv ey of all3he Dep;7Ttm.trt 's major operating facilities, environmental problems and areas of environmenta1 "risk . The identified problem areas will be prioritized on a Depa rt ment-wide basis in order. of importance in`t989 . The prelimina ry findings are subject to modification Lased ~op coouii'entsfrom the San Francisco Operations Office concerning their technical accuracy . 4hg modified :findink s will be incorporated into the Environmental Su rvey Summa ry Report. Februa ry , 1989 Washington, D .C . HDMSP00042395 TABLE OF CONTENTS r. SECTION PAGE EXECUTIVE SUMMAR Y ES-1 1 .0 INTRODUCTIO N 1- 1 2 .0 GENERAL SITE INFORMATION 2 .1 Site Settin g 2 .2 Overview of Major Site Operations 2 .3 State and Federal Concerns t:. 3 .0 r TV. MEDIA-SPECIFIC SURVEY FINDINGS AND OBSERVATIONS 3 S: 3 .1 .1 Background Environmental Information 3.1 3- 1 3 .1 .2 General Description of Pollution Sources an( Controls 3 .1 .3 3-9 Environmental Monitoring Program , 3 .1 .4 Findings and Obse rvations 3 .1 3 .1 .4 .1 3 .1 .4 .2 1, 3 .1 .4 .3 3 .1 .4 .4 3 .2 3 .2 .1 3 .2 .2 3 .2 .3 3 .2 .4 3 .2 .4 .1 Air 3-1 8 3-2 1 Category I Category 11 Category I I1 Category IV Soils Background Environtmintal4uformation Getteral 'Oescription of• ptlluf on Sources and Controls .641ronmental Monitoring Program • aind,Ftgsa rid`.'Qbsijfations - egoryj 3-2 1 3-2 1 3-2 1 3-2 1 3-2 2 3-2 2 3-2 3 3-2 5 3-32 3-3 2 3 .2 .4 .2 C@tegbry 11 3-3 2 3.2.4.3 `'Category III 3-32 3.2 .4.4 33 3 .3.2 3 .33 ,3.3.4 ' 3 .3 .4 .1 3 .3 .4 .2 3 .3 .4 .3 3 .3 .4 .4 3 .4 3 .4 .1 3 .4 .1 .1 3 .4 .1 .2 3 .4 .2 3 .4 .3 3.4.4 ' Catego ry IV Surface Water Background Environmental information General Description of Pollution Sources and Controls Environmental Monitoring Program . Findings and Obse rvations Category 1 Category II Category III Category IV Hydrogeology Background Environmental information Geology Groundwater Regime and Use General Description of Pollution Sources and Controls Environmental Monitoring Program Findings and Observations 3 .4 .4 .1 3 .4 .4 .2 3 .4 .4 .3 Catego ry I Category Catego ry III 3 .4 .4 .4 Catego ry IV 3-34 3-3 5 3-3 5 3-4 2 3-49 3-56 3-56 3-58 3-5 8 3-5 8 3-5 9 3-5 9 3-5 9 3-6 0 3-6 2 3-6 6 3-69 II - 3-6 9 3-6 9 3-6 9 3-7 1 t: HDMSP00042396 TABLE OF CONTENTS (CONTINUED ) SECTIO N 4 .0 4 .1 4 .1 .1 4 .1 .1 .1 4 .1 .1 .2 4.1 .2 4 .1 .2 .1 4 .1 .2 .2 4 .1 .2 .3 4 .1 .2 .4 4.2 4 .2 .1 4 .2 .2 4 .2 .2 .1 4 .2 .2 .2 4 .2 .2 .3 4 .2 .2 .4 4 .2 .3 4 .2 .4 4 .2 .5 4 .2 .6 4 .2 .6.1 4 .2 .6.2 4 .2 .6.3 4 .2 .6.4 4. 3 4 .3 . 1 4;3:2 4:3 . 3 4,3:4 . 4 .3.4:1 4.3 .4 .2 4 .3 .4 :3 4 .3 .4 .4 4.4 4 .4 .1 4 .4 .2 4 .4 .2 .1 4.4 .2 .2 4 .4 .2 .3 4 .4 .2 .4 4. 5 4 .5 .1 PAG E NON-MEDIA-SPECIFIC FINDINGS AND OBSERVATIONS 4-1 Waste Management 4- 1 General Description of Pollution Sources and Controls 4-2 Hazardous Waste 4-2 Radioactive Wastes 4- 8 Findings and Observations •4-12 Category -I ,4=12 Category II '4<1 2 Category II I 4Category IV 4-'k<3: Toxic and Chemical Materials 4-15 Toxic Substance Management 4-15 Toxic Chemical Use and Storage"` 4-1 6 Bulk Liquid Chemicals and Fuels Storage Areas 4-16 Low-Volume Storage Areas 417 Solvent and Chemical Storage abine ' 4-17 Improper Storage of Battetes 4-1 7 Polychlorinated Bipherayls : 4-17 Asbestos 4-1 8 Pesticides - 4-19 Findings-and Observations ' :< 4-1 9 Category 1 ' 4-1 9 ~tategikry II 4-2 1 Categot y:i11 4-2 1 Category jV " 4-2 1 ;Radlalrion . .. ',:'• 4-2 6 Background Environmental information 4-26 General Description of Pollution Sources and Controls 4-2 8 Environmental Monitoring Program 4-33 Findings and Observations 4-3 4 Category I 4-34 Category II 4-34 Category III 4-34 Category IV 4-3 4 Quality Assurance/Quality Control 4-36 General Description of Data-Handling Procedures 4-36 Findings and Observations 4-3 9 Category I 4-39 Category II 4-39 Category III 4-39 Category IV 4-3 9 Inactive Waste Sites and Releases 4-40 General Description of Pollution Sources and Controls 4-4 0 ni HDMSP00042397 TABLE OF CONTENTS ( CONTINUED ) SECTIO N PAG E B/886 Former Sodium Burn Pit Area B/059 Former SNAP Facility B/021, 022 RMDF Leachfield Old Conservation Yard B/056 Landfil l ESADA Chemical Storage Yard B/100 Trenc h Southeast Drum Storage Yard New Conservation Yar d Area of B/133 Sodium Burn Facilit y 4 .5 .1 .1 4 .5 .1 .2 4 .5 .1 .3 4 .5 .1 .4 4 .5 .1 .5 4 .5 .1 .6 4 .5 .1 .7 4 .5 .1 .8 4 .5 .1 .9 4 .5 .1 .10 4 .5 .2 4 .5 .2 .1 4 .5 .2 .2 4 .5 .2 .3 4 .5 .2 . 4 Findings and Observations Category I Category II Category III Category IV REFERENCES 4-42 4-46 4-46 4-46 4-46 4-47 4.47 7 4-47 4-44 % 4-48 4-48 4-48 4-48 4-6 2 R- 1 BB- 1 BIBLIOGRAPHY APPENDICE S A SURVEY ,PA TICIPANTS A-1 , :,SITE- SR£11£'SURVEIi; ACTIVITIES C B- 1 ,ENVIRONMENTAL SURVEY PLAN FOR THE U . S . DEPARTMENT OF ENERGY C- 1 AC-T1.V1 .11ES'AT SANTA SUSANA FIELD LABORATORIES 04EMICAL SYMBOLS , ABBREVIATIONS, AND ACRONYM S D- 1 iv HDMSP00042398 TABLE S NUMBER PAG E 3-1 COMPARISON OF FEDERAL AND CALIFORNIA AIR QUALITY STANDARDS 3-2 3-2 WIND DIRECTIONSATSSFL 3-5 3-3 WIND DIRECTION FREQUENCIES BURBANK AIRPORT 3-6 3-4 AMBIENT AIR RADIOACTIVITY CONCENTRATION DATA 3-8 1968 THROUGH 198 7 3-5 PERMITTED AIR SOURCES 3-:1 0 3-6 ATMOSPHERIC RADIOACTIVE EMISSIONS 3 :-12 3-7 RMDF ATMOSPHERIC EMISSIONS 3-20 3-8 SOIL RADIOACTIVITY DATA, 1987-195 7 3-9 VEGETATION RADIOACTIVITY DATA . 1985-1957 _ 3-30 3-10 SOIL SAMPLE ANALYSES - SODIUM BURN PIT 3-33 3-11 SUMMARY OF WATER USAGE 3-41 3-12 CALIFORNIA REGIONAL WATER QUALITY CONTROL IQARD'CRITE.RJA 3-5 0 FOR DISCHARGING NONRADIOACTIVE CONST,ITtJENTS ;FROM,ROCKE7DYNE DIVISION, NPDES NO . CAOO-0001309, ORDER 8425 ; E.FFECTIVE-. SEPTEMBER 17, 1984 3-13 SEWAGE TREATMENT PLANT EFFLUENT ;LIM TATICNS 3-51 NPDES NO . CAOO- 0001 309 ;ORDE.R .84-85S .EFF.ECTIV -SEPTEMBER 17, 198 4 3-14 CHARACTERIZATION OF RU-NOFT WATERS : • 3-53 3-15 ASBESTOS IN RUNOFF WATERS • 3-54 3-16 RADIOACTIVITY-iN SELECTEDSEDII iVTSAMPLES 3-57 4-3 4-1 WASTE STREAMS :':. 4-2 BOWL ARtA PROCESS EQUIPMENT WASTE - DOE/MORGANTOWN 4-6 : 4-20 4-3 PESTTCIOES U5ED AT SSF . •. . 4-4 .-CHEMIAAL~-S'TORED1h1 BUILDING 007 4-22 4-5 CH MICA4 S STORED IN BUILDING 008 4-2 3 .D FICIENCIES-WITH OUTDOOR CHEMICAL STORAGE CABINETS 4-25 4-6 4-7 •'ID'S;,AVERAGE ANNUAL EFFECTIVE DOSE EQUIVALENT TO 4-2 7 'HUMANS FROM NATURAL BACKGROUND RADIATIO N 44- `CURRENT DECONTAMINATION AND DECOMMISSIONING (D&D) 4-2 9 STATUS OF FORMER NUCLEAR OPERATION S 4-9' . ACTUAL AND POTENTIAL HAZARDOUS SUBSTANCE RELEASE LOCATIONS 4-43 4-10 RADIOACTIVE WASTE GENERATED - 1962 4-45 SODIUM BURN PIT TEST TRENCHES, SAMPLING AND ANALYSES 4-53 4-11 SOIL ANALYSIS FOR VOCs - BURN PIT TEST TRENCH BPL-2 (3 .5-4 .0 FT) 4-5 5 4-12 V HDMSP00042399 FIGURE S PAG E NUMBER 2-1 2-2 3-1 3-2 3-3 3-4 3-5 3-6 3-7 3-8 3-9 3-10 3-11 3-12 4-1 4-2 4-3 LOCATION OF SANTA SUSANA FIELD LABORATORIES AREA IV LOCATION OF RADIONUCLIDE PARTICULATE AMBIENT AI R SAMPLING STATIONS RMDF AIR HANDLING SYSTEM 2- 2 2- 3 3- 7 3-1 4 HOT LABORATORY AIR PARTICULATE CONTROL ON-SITE SOIL SAMPLING LOCATIONS OFF-SITE SOIL SAMPLING LOCATIONS PRINCIPAL FEATURES OF THE SANTA CLARA AND LOS ANGELE S RIVER BASINS SURFACE DRAINAGE SYSTEM RECLAIM WATER SYSTEM FRESH WATER DISTRIBUTION SYSTEM 16 3 6 3= ?. 3-31 SANITARY SEWER SYSTEM -AREAS II, III &IV GROUNDWATER CONTOURS, INFERRED FLOW D .IfRECTIONS ;AN'b MAJOR STRUCTURAL DISCONTINUITIES ." .. GROUNDWATER MONITORING` 0CATIONS NEARARtA IV SECURITY AND RADIATION :ARE, .,ACCESS :t ROV1:51ONS LOCATIONS OF ACTUAL AND ;ROTENTIAi. HAZARDOUS SUBSTANC E RELEASE LOCATJONS T-886 SODIUM BURN PIT AREA LAYOOT AND TEST TRENCH LOCATIONS 3-4 6 3-6 3 3-3 7 3-3 8 3-40 3-6 7 4-3 2 4-44 4-50 vi HDMSP00042400 EXECUTIVE SUMMAR Y Introductio n This report presents the preliminary findings from the first phase of the Environmental Survey of the United States Department of Energy (DOE) activities at the Santa Susana Field Laboratories Sit e (DOE/SSFL), conducted May 16 through 26, 1988 . The Survey is being conducted by an interdisciplinary team of environmental s,pecial'rst3, led end managed by the Office of Environment, Safety and Health's Office o ~ Enviroi°urieRtal Audit:" Individual participants for the Survey team are being supplied by a private contractor .,-The objective of the Survey is to identify environmental problems and areas of environrrient& risk associated with DOE activities at SSFL . The Survey covers all environmental :mp.dra .ar d all areas of environmental regulation . It is being performed in accordance with . the DOE "E"nvirons ental Survey Manual . This phase of the Survey involves the review of ezisting jrte environmental data, observations of the operations performed at SSFL, and interviev,s wititi,sit personnel . Site Descriptio n The Santa SussE '_fField°Laboratories'Site (SSFL) is located in southeastern Ventura County near the crest of the $ ;m, Hills at thk,western border of the San Fernando Valley . This location is about 47klrometer3 29 rttmas) northwest of downtown Los Angeles . The site occupies 1,080 hectares (2,668 . cres) situated in rugged terrain typical of mountain areas of recent geological age . SSFL is situated on a plateau approximately 1,000 feet above the floor of the west San Fernando Valley . Th e nearest communities are in the Simi Valley, which is about 2 .7 kilometers (1 .7 miles) northwest of the site . Administrative and scientific activities also take place at the DeSoto, Plumber, and Canoga Avenue locations . The DOE programs are conducted primarily in Area IV of the SSFL Site . Area IV (290 acres) includes a 90-acre DOE optioned area that houses the Energy Technology Engineering Center (ETEC) . Rockwell International Corporation and its predecessor organizations have been the operating contractors for DOE programs and facilities since the early 1950s . These facilities have included ETEC as well as a number of other research and development facilities . In Areas I to III of the SSFL Site, Rockwell conducts operations for NASA and the Air Force . Area II is owned by the National Aeronautical and Space Administration (NASA) and operated by Rockwell . ES-1 HDMSP00042401 Representatives of SSFL, DOE San Francisco Operations Office, and the Survey team met with five representatives of state and local agencies on April 6, 1988, at SSFL to discuss their concerns . The questions from the attendees were general in nature , and no major issues , environmental or otherwise , were raised . Summary of Findings The major preliminary findings of the Environmental Survey of DOE activities at SSFL are as follows .: t'. I • There are approximately 10 areas at SSFL Area IV where hazardous and/or' dioacti-ye substances resulting from DOE activities have or may have beerr: disposed.:of,4pilled, or released . These constitute actual and potential sources ofsoil ;` and/or . grour`d'wate r contamination . The full nature and extent of contamination is not known . a . There are at least three areas of groundwater cortaminatibfi : Area IV that appear to be related to past DOE activities . The eontamimants are_chl' inated organics in the parts-perbillion range . Some of the concerttratfdx(s-exce+ed the'California Action Levels . • Due to an insufficient- number of::'groundwater monitoring wells, the groundwater monitorirrgpiogram is `trot capable of : accurately determining direction of groundwater flow t:haract4ri- rng t1,e nature and extent of groundwater contamination at known and psena{ sourci-a:reas; and detecting off-site groundwater contamination . OveratB'Conclu4ian s The Survey found no environmental problems at SSFL that represent an immediate threat to human life . The preliminary findings identified by the Survey do indicate that a few areas are actual or potential sources of soil and/or groundwater contamination and that inadequacies in the groundwater monitoring system make it difficult to characterize the nature and extent of contamination . The environmental problems described in this report vary in terms of their magnitude and risk . A complete understanding of the significance of some of the environmental problems identified requires a level of study and characterization that is beyond the scope of the Survey . Actions currently under way or planned at the site will contribute toward meeting this requirement . ES-2 HDMSP00042402 1 .0 INTRODUCTIO N The purpose of this report is to present the preliminary findings made during the Environmental Survey conducted May 16 through 26, 1988, of U .S . Department of Energy activities at the Santa Susana Field Laboratories Site (DOE/SSFL) in Ventura County, California . Actvities under contract to DOE are conducted at SSFL by Rockwell International - Rocketdyne Division . This report reflects conditions during the Survey and does not include remedial actions initiated since that time . Although "SSFL" is used throughout the report, the Survey included only DOE activities at SSFL . 'As a Preliminary Report, the contents are subject to revision . Revisions to the preliminary findings; . based on San Francisco Operations Office technical review, will be incorporated into the _Ervir .onmental Survey Summary Report . The DOE/SSFL Survey is part of the larger, comprehensive DO • . Enviro :n' nerital survey effort announced by Secretary John S . Herrington on Septeml. a 18, 19$5 . The purpose of the Environmental Survey is to identify, via a no fault"':baselrne S irveycf ;;alI the Department's major operating facilities, existing environmental problems and areas of•etivironmental risk . The identified problem areas will be prioritized in 198 .cm a Departm t-wise basis in order of importance . The prioritization will enable DOE tQ more effectively address environmental problems and allocate the resources necessary to core ct'these problems= Because the Survey is "no fault" and is not a n audit," it is not deigned to identify-specific, isolated incidents of noncompliance or to analyze environmen*af°r>inagejerit prKtic2s . Such incidents and/or management practices are, however, used in thy:-5urv y as a`irreeans of identifying existing and potential environmental problems an d risks .'-- T h Environmental Survey is being conducted by an interdisciplinary team of environmental specialists headed and managed by the Office of Environment, Safety, and Health's Office of Environmental Audit. A complete list of Survey participants and their affiliations is included in Appendix A. The Survey team focused on all environmental media, using Federal, state, and local environmental statutes and regulations, accepted industry practices, and professional judgment to make the preliminary findings included in this report . The team carried out its activities in accordance with the guidance and protocols in the DOE Environmental Survey Manual . Substantial use of existing information and of interviews with knowledgeable field office and site-contractor personnel accounted for a large part of the on-site effort . A summary of the site-specific Survey activities is presented in Appendix B, and the Survey Plan is presented in Appendix C. HDMSP00042403 The preliminary Survey findings are presented in Chapters 3 and 4 in the form of existing and potential environmental problems . Chapter3 includes those findings that pertain to a specific environmental medium (e .g ., air or soil) whereas Chapter 4 includes those that are non-media specific (e .g ., waste management, radiation, and quality assurance) . Because the findings vary greatly in terms of magnitude, risk, and characterization and consequently require different levels of management attention and response, they are further divided into four categories within each of the sections in Chapters 3 and 4 . The criteria for placing a finding into one or more of the four categories are as follows : Category I includes only those findings which, based upon the information avail 6le-tc ;the Team' Leader, involve immediate threat to human life . Findings of this type shatfbeJmmedi,tely conveyed to the responsible Environmental Safety and Health personnel at the steie or in control of the facility or location in question for action . Category I finding~..are, :those environmental problems where the potential risk is highest, the confidence it the`• indiri( ; based on the information available, is the strongest, and the appropriate : respot o f a l ternat i ves . .to tte, finr-( I Ox) . `'f(fhe'"only non-attainment area in the state with respect to NOx is th e Los Arig.eles area .) With' .respect to ozone, the southern half of Ventura County (in which SSFL is located) still has a non-attainment designation . It appears that this status will continue for the foreseeable future and that the VCAPCD will continue to address all aspects of smog-ozone formation, including hydrocarbon and NOx emissions . The southern half of Ventura County is still listed as having a non-attainment status for total suspended particulates . However, with respect to the new inhalable particulate standard, the entire county is included in Category 3, the category most likely to be in compliance . Air quality standards for California (and Federal standards for comparison) are shown in Table 3-1 . Ventura County has no problems with attainment of the visibility, lead, hydrogen sulfide, or vinyl chloride standards . 3-1 HDMSP00042415 TABLE 3- 1 COMPARISON OF FEDERAL AND CALIFORNIA AIR QUALITY STANDARDS SSFL - VENTURA COUNTY, CALIFORNIA Federal Standard s Averaging Time Primary - Californi a Standard Seconda ry Objectiv e OZON E 1-Hour 0 . 12 ppm Same 0 . 10 pprn To prevent eye irritation ; 240 Vg/M3 200 118/m3 breathing diffkUThe- CARBON MONOXID E 8-Hour 9 .3 ppm 10 mg/m3 Same 9 .0 ppm 10 mg/ m3 1-Hour 35 ppm 40 mg / m3 Same 20 ppm 0 .05 ppm 100 11g/M3 Same T o pre ent arbox-~hemoglobi n •je-uels greate rihan 2 'percent . :-2.3 mglm 3 NITROGEN DIOXID E Annual 1-Hour - To prevent health risk an d improve visibility . - 0 .25 pp m 470 jg/m 3 Annual 24.-Hour 0 .03`pom "$ =1.tg/m3 - 0 .14 ppm - - 0 .05 ppm 131 Ug/m 3 365 pg/ m3 3-Hour - 1-Hour - To prevent increase i n respirato ry disease, plan t damage, and odor . - 0 .5 ppm 1,310 jtg/m 3 0 .25 pp m 65511g/m 3 SULFATE S 24-Hour 25 11g/m3 To improve visibility and prevent health effects. 3-2 HDMSP00042416 TABLE 3- 1 COMPARISON OF FEDERAL AND CALIFORNIA AIR QUALITY STANDARDS SSFL - VENTURA COUNTY, CALIFORNI A PAGE TW O Federal Standards Averaging Time Primary California Standard Secondary O b jec t i v e PARTICULAT E Annual Geometric Mean 24-Hou r Averag e 75 pg/m3 260 pg/m3 60 pg/m3 150 µg/m3 30 pg/m3 PM10* 50 ug/m3 PM10* To improve visibility, and " prevent health effects VI S IBILITY REDUCING PARTICLE S (State Standard : One observation . Insufficient amount tdredvice the pre'thiling visibility to less I than 10 miles when the relative humiaity'is FFsst h an ;70 pgrcent . LEA D 30-Day - Calendar Quarte r 1 .5 ug/m3 Same 5;.1;.5:u[rn3 To prevent health problems . .a. HYDROGEN SULFID9_R' 0 .03 pp m 1-Hour To prevent health problems . 42 ug/m 3 ., VINYL CHLOR) DE (ZH1OROETHENE ) :24-Hour - .010 ppm 2 06 jtg/m 3 To prevent health problems. Source : EPA, 1987 and California, 1987 . *PMIO = Particulate matter ten microns or less in size . ppm = parts per million . 3-3 HDMSP00042417 Meteorology Because the upper winds ( above 4 , 000 feet ) above the site have been presumed to be similar to the upper winds at the Burbank Airpo rt ( BAP), 22 miles east of the site , SSFL has for many years used BAP wind rose information in calculations of estimated dose . In addition this data would be utilized in predicting downwind effects of any unscheduled release . This practice has been assumed to be adequate even though it has been acknowledged that : " Upper wind flow plays little or no role in the transpo rt of any effluent from the site . This is due to the fact that , although some incidf its might be accompanied by thermal effects , none can be postulated which would providtx .e'nqug h heat to cause cloud rises more than 1 , 500 feet above ground " (Ashley, 1962) . During 1960-1961 information was gathered from a meteorological tower located in Area "1 1 " Only wind speed and direction data are available . Wind direction frequencies frorb-th .is . 1960-1961 data are shown in Table 3-2 (Ashley, 1962 ) . In addition data from this$ima 'are shown for the summer and winter seasons . For comparison ,' data from tire. Burbank •;'' Airport -.are shown in Table 3- 3 (Moore, 1988a) . Although data for the two locations are somew1 at similar, there are considerable differences, especially when the seasona differences are considered . For example , data for the NNW through NE quadrant ( that is thesufn of the fre' q'uar iesfrom the NE , NNE, N , and NNW segments ) indicates that the wind is frcm,.t iiat di?fiction 41 .7 percent of the time at BAP but varies from 33 .8 percent ( winter) to 12 .0 per'r pt (s cnmerj at .S FL', averaging 22 .8 percent annually. It- mustbe ackr i tiwledged that the above data at SSFL are sparse and out of date . A study made in the-.1960- 61 period did show that a " very good correlation existed " between the above ( Area II) data and wind data from Atomics International ( i .e ., Area IV) wind instruments , " although a detailed and lengthy statistical analysis was not performed " (Ashley , 1962) . The absence of an on-site meteorological tower is discussed in Finding 3 . 1 .4 .4.1 . Radiological Air Qualit y Air quality for pa rt iculate radioactivity is determined at eight sampling stations on or near the SSFL . The sampling station locations are shown in Figure3-1 . Methodology is discussed in Section3 .1 .3 . Pa rt iculates are examined for alpha and beta radioactivity . Annual averages for 1968 through 1987 are shown in Table 3- 4 . The data in the table reflects a change in the averaging procedure a ft er 1981 . Before 1982, DOE instructions were to replace an y 3-4 HDMSP00042418 TABLE 3- 2 WIND DIRECTIONS AT SSF L SSFL - VENTURA COUNTY, CALIFORNI A Frequency (Percent ) Wi n d F rom A nnua l Summer Only Winter Onl y 10 .1 5 .2 15 . 2 6 .8 4 .0 9. 7 23 .1 30 .0 16 . 8 WNW 5 .7 5 .7 ;: ;'S.. 8 W 2 .2 1 .7 . 2 F WSW 06 0 . -3 SW 0 .6 .5 SSW 0 .3 N NNW NW ~ ." . Q?.3-. . 0. 7 0.4 1 .9 S SSE 10 . 9 1 .5 1 .4 1.6 6 .5 7. 2 M 10.2 11 .7 8.8 E 9 .9 14 .5 5. 3 . ENE 1 .2 1 .5 0. 8 NE 2 .9 1 .9 3. 8 NNE 3 .0 0 .9 5. 1 Source : Ashley, 1962 . 3-5 HDMSP00042419 TABLE 3- 3 WIND DIRECTION FREQUENCIES BURBANK AIRPOR T SSFL - VENTURA COUNTY, CALIFORNI A Wind From Frequency (%) Annua l N NNW NW WNW 18 . 8 11 .8 8.5 13 . 1 W 5 .3 WSW SW SSW 2.4 1 .7 2.1 S SS E 4.3 SE 5:2 ES E E : . 3' 0 EN E NE .NNE 3. 4 7. 7 3-6 HDMSP00042420 LEGEN D 800 • AMBIENT AIR SAMPLING LOCATIO N 1600 SCALE IN FEET Source: Adaptod from Moore, 1988b FIGURE 3- 1 LOCATION OF RADIONUCLIDE PARTICULATE AMBIENT AIR SAMPLING.`. ' SSFL-VENTURA COUNTY. CALIFORNIA TABLE 3- 4 AMBIENT AIR RADIOACTIVITY CONCENTRATION DATA 1968 THROUGH 198 7 SSFL - VENTURA COUNTY, CALIFORNI A SSFL Site Averag e (10-12 uCi/ml ) Year . Number of Samples Alpha Beta 1987 2,460 0 .0019 0 .02 7 1986 2,415 0 .0028 0 .06 1 1985 2,450 0 .0020 0.040 ' . ' 1984 2,461 0 .0014 -Q.`Q 24 _ 1983 2,328 0.001D '0 .02 3 1982 2,347 0 0013 0 .02 2 1981 2,518 1980 2,342 1979 ' '0 0068. . 0 .1 2 D .fl064 0 .03 5 2,519 0 .0065 0 .02 0 1978 .2 ,402 0 .0072 0 .08 8 .1,977 2;438' 0 .0066 0 .1 7 1476 2,520 0 .0065 0 .1 1 T 2,450 0 .0060 0 .07 3 :J974 2,477 0 .0057 0 .1 6 1973 2,311 0 .0072 0 .03 8 1972 2,430 0 .0086 0 .1 4 1971 2,476 0 .0086 0 .3 3 1970(a) 2,434 ---- 0 .3 6 1969 2,364 --- 0 .2 6 1968 2,157 --- 0 .3 2 Source : Moore, 1988b . (a) Ambient air alpha radioactivity values were included in the beta values and not reported separately prior to 1971 . 3-8 HDMSP00042422 values that were below MDL with values equal to the MDL . This resulted in averages that were biased on the high side . As expected, both alpha and beta radioactivity have generally decreased during this period . Although phase-out of older facilities and decreased levels of operation of existing facilities are partly responsible, current controls have played an important role in this decrease . Controls are discussed in Section 3 .1 .2 . 3 .1 .2 General Description of Pollution Sources and Control s There are relatively few permits issued by the VCAPCD to SSFL_ This is largely because" :VCAPCD ordinarily issues a permit to cover a group of sources with a common location or furictron Current permits are shown in Table 3-5 . Several of these have expiration dates in then ext fewyea s Severa4 have expired and must be renewed if future operation is contemplated . Natral-gas capacities-6f the combustion sources are shown along with permissible emissions: in pounds pet . hoer . All the combustion sources have limitations on the quantities of natut l gas`' used .' When No . 2 diesel oil firing is allowed (only during natural gas curtailmer)t), its :fi'ring,tate'arid' naximum hours of use are stipulated . The sources have additional emission :limtsexpresfed irrzons per year . This has the effect of limiting the number of hours of operation .per, :year Many of the additional strpulateit .restrictions •are intended to minimize the impact of combustion sources on smog fc3r~Fr ation nearby or . iri downwind areas . For example, operation of the Babcock & k`JVj•sodiupi heater requires contact with the air quality reporting section of the VCAPC -lo ddtermiretf.a•'smog alert has been forecast for the start up day . If a smog alert is forecast _the-It+gstirig rn,1st be postponed . Another restriction limits simultaneous use of combustion sources :' The Kamer boiler cannot be operated when the B&W sodium heater and the Coen heate r are operating near capacity . A further restriction requires continuous NOx monitoring of the stack gas from the Coen heater . Monitoring is described in Section 3 .1 .3 . Another restriction limits the B&W heater to a maximum concentration of 80 .7 ppm of NOx in the waste gas. At the maximum firing rate this is equivalent to about 11 .5 pounds per hour, which is well below an allocated share of the 58 .31 pounds per hour allowed for the boilers covered by Permit No . 1124 . This additional restriction is based on measurements made during tests conducted during December 1983, which showed this concentration to be normally attainable . Limited testing conducted in 1987 indicates that this limitation may not be easily achieved during future operation . 3-9 HDMSP00042423 TABLE 3- 5 PERMITTED AIR SOURCE S SSFL - YENTURA COUNTY , CALIFORNIA Permit Number Permitted Emissions (Pounds per Hour) Natural Gas Expiration Date Source Ca p aci t y (BTU/hour x 10-6) ROC NOx TSP SOX CO 5 .4 8 .39 4 .0 ---1 .86 ---- 0 .07 0 .07 0 .07 0 .07 0 .07 0 .07 0 .07 3 .51 3 .51 3 .51 3 .51 3 .51 3 .51 3 .51 431 4 .31 4 .31 4 .31 4 .31 4 .31 4.31 10 .06 10.06 10.06 10 .06 10 .06 10 .06 10 .06 3 .2 0 3 .2 0 3 .2 0 3 .2 0 3 .2 0 3 .20 3 .20 0 .01 0 .14 0 .01 0 .51 0.0 4 0•.66 0 :66 58 .31 58 .31 9 .40 9 .40 157 .28 157 .28 16.9 3 16.9 3 0 . 66 58 .31 9 .40 157 . 28 16.93 58 .31 9 .40 157 . 28 16 .9 3 j•w 1124 12/31/88 • Molten salt test reactor , . ' • Product gas combustor (baghbilse) • Cleaver Brooks boiler • Portable preheat boiler • Low NOx/SOx combustor (baghouse) . .', ; ., • Air heater • Coal storage, transfer, and crushing facilit y 00863 • Coal liquefaction reactor evaluatio n system 00346- 8 • R&D coal liquefaction process 0290 06/30/90 • Eclipse Mark IV 100 steam boiler (1) 0271 12/ 31/88 • B &Wheater (1) • Coen heater (1) • Keelen steam boiler • Five space heaters 0226 09/30/87 • Sodium burn facility 0230 06/30/87 • Vapor Corporation heater (No . 2 fuel oil fired ) 0229 06/30/87 • Coal liquification reactor evaluation systems TOTAL SITE 200 .. 240' ;" 25 .2 8 .71 `•.'' ' . ' 0 .b6' 1 .0 4 .3 498 .86 0,03- P. 67 0 .06 2 .20 0 .1 5 0 .01'. . , 2 .30 0 .01 12 .40 0 .0 1 14 .79 182 .45 20 .3 3 0 .79.' : . Source : Assembled from SSFL files by Survey team . (1) May be fuel-oil fired during natural gas curtailment . (2) Total site permitted emissions are less than the sum of source emissions because of restrictions on simultaneoususif sources . Radionuclide Source s Radionuclide emissions at SSFL from 1985 to 1987 are summarized in Table 3-6 . At present, the principal source of radionuclide air emissions at SSFL is the Radioactive Material Disposal Facility (RMDF) . The RMDF accounted for 7 . 2, 9 .0, and 76 . 7 percent of the radioactive air emissions from SSFL in 1985, 1986, and 1987, respectively . The increase in the fraction of emissions in 1987 was the result i # a decrease in the total emissions following shutdown of other facilities ( Building'*055 . a.nd Building 020) . Since no activity is anticipated in Building 020 in 1988 , the majority'radaonuclici e SSFL emissions will be from the RMDF . The RMDF consists of four buildings in which handling and storage a+it'i .vities.octur` • Building 021 in which decontamination and! packaging;is.coi di tted . • Building 022 in which high -level radioactive - materials are stored pending shipmen t off-site . • Building 0-7S in which lowerJe'et'radioactive materials are stored pending shipment . eh'radioactive sources utilized in research activities are stored when no t Other, buildings at the RMDF are office and storage buildings and Building 665, which housed decontamination units that have been shut down and are scheduled for demolition (Chapman, 1986) . The only air emissions at RMDF are from activities at Buildings 021 and 022 . ( Buildings 075 and 621 contribute to direct radiation , which is discussed in Section 4 . 3 .) These emissions consist principally of particulate matter removed from the surfaces of objects during decontamination . The surface particles result from handling and storage activities in Building 022 and decontamination processing and packaging activities in Building 021 . Pa rt iculate matter contains uranium and plutonium plus 137Cs, 90Sr, 85Kr, and 147Pm as mixed fission products and C060 and Eu152 as activiation products . Control of air emission consists of filtration by high efficiency particulate air (HEPA) filters . 3-1 1 HDMSP00042425 TABLE 3-6 ATMOSPHERIC RADIOACTIVE EMISSIONS SSFL - VEN.TlIR4'COUNTY, CALIFORNI A Total Radioactivity Released (Ci ) Emissions Volume (M3) Buildin g ,Alp h a 1985 1986 1987 Beta 198 5 , ; :,--, 1986 1987 1985 1986 1987 020 2 . 5 x 108 5 . 0 x 108 5 .4 x 108 4. 5 x 10-7 • .' } 3 'x 10-7 1 .8 x 10-7 9 .0 x 10- 5 2 .2 x 10-3 3 .7 x 10- 6 021-022 2 .3 x 108 3 .3 x 108 2 . 4 x 108 3 . 9 x 10 - 8 g`6 x 10-8 2r 5 x 10 7 9 .0 x 10 6 1 .3 x 10 - 5 1 .22 x 10- 5 055 2 . 2x108 1 .1x108 5 . 3x10-8 4 .1x108', '' - 1 .5x106 4 .0x106 - SSFLTotal 7 .0 x 108 9 .4 x 108 10 .0 x 10-5 3 .9 x 10 5 1 .59 x 10- 5 7 .8 x 108 5. 42 x 10 -7 2 .17 x`10 7 10-7 Source : Assembled from Rocketdyne Annual Monitoring Reports (1985-1987j :by'~OE Survey team . A schematic diagram for the HEPA filter system used to control air emissions from the RMDF is shown in Figure 3-2 . Air flow from the storage vaults in Building 022 is provided by two 11-brake horsepower ( BHP) blowers with a capacity of 10,400 cubic feet per minute ( cfm) each . An emergency 19-BHP blower with a capacity of 17,680 cfm is also available . In the event of a blower failure, an emergency diesel generator ( EDG) provides power for the emergency blower . The emergency blower is powered by the EDG , regardless of the electrical supply conditions . If the facility loses off-site power , the EDG sta rt s automatically and is capable of bringing the emergency blower to full speed within 10 seconds . If either of the vault blowers malfunctions,-th e EDG must be sta rt ed manually . A separate exhaust system is provided for Building 021 . This consists of 'a ' 19- BHP,b4owei'= With a capacity of 17,680 cfm . Air flow within the building (as with the flow in Builthng• .022)' is arranged from areas of lower contamination to areas of high contamination .` An emergency blower is not provided at Building 021 since , during an emergent y , control 'of .eml Si :ons by rapid shutdown o f operations is practical . A separate blower is provided for exhaust ai,rAabou~ 5,000 cfm) from the evaporator and adjacent areas . This exhaust air passes through a water separator followed by a prefilter and then a heater to prevent condensatiot;% rior to filtrat or}-by HEPAs . The air rer1(.iVed _from th4-424tt 'area of Building 022 is processed through 2 banks of filters , as shown in .Figure; 3-2h'bank consists of a set of 10 prefilters and 10 HEPA filters . The banks are separated into'five chamb rs , each containing 2 prefilters and 2 HEPAs . Each chamber can be isolated from the exhaust flow for servicing . Moreover , each chamber can be independently monitored for pressur e drop br be tested for efficiency using dioctyl sebacate (DOS) . Annual testing was changed from dioctyl phthalate to DOS in 1982 on advice from DOESan Francisco Operations Office ( Jackson , 1981) . Standard operating procedures at RMDF require DOS testing after each change of filters or after 1 year in service . SOPs also require replacement of filters when the pressure drop across filters exceeds 3 inches of water with an absolute maximum of 6 inches . Air flow from Building 021 (other than the air from the evaporator mentioned above ) is processed through banks of 14 prefilters and 14 HEPAs . The banks are separated into banks of 2 prefilters and 2 HEPAs , which can be isolated for servicing , monitoring , or testing . SOPs are identical to those cited above for Building 022 . 3-13 HDMSP00042427 BUILDING T021 . DECONTAMINATION ROOM EMERG . DIESE L GENERATOR BLOWER #3 022 EMERG . EVAPORATO R BLOWER #1 BLOWER #4 FILTER BANK #3 FILTER BANK #1 BLOWER I EVAPORATO R FILTER S FROM VAULTS BUILDING 022 Source : Adopted from Chapman, 1986 FIGURE 3- 2 RMDF AIR HANDLING SYSTEM SSFL-VENTURA COUNTY, CALIFORNI A After the flow from the evaporator hood is conditioned, to remove moisture as mentioned above, it is filtered through a bank of 4 prefilters and 4 HEPA filters . The combined flow from the four banks of filters is transferred by the several blowers, as shown in Figure 3-2, to the exhaust stack . This stack is 3 feet in diameter and 130 feet tall . Under conditions where all blowers (not including the emergency blower) are operating at full capacity, the stack would carry about 43,000 scfm . Under normal conditions, however, the vault area is evacuated-at a rate of 15,000scfm and the air flow from the decontamination area is about 8 , 500scfm'ii~ ; .N }en combined with the normal flow of about 2,500 cfm from the evaporator, a total flow .af261900 d ;is transferred to the stack . This flow yields an escape velocity of about 60 feet-per setoftt'at the to p the stack, which provides for excellent dispersion . Hot Laboratory Prior to 1988 , emissions from the Hot Labora tory (Bttytding.020) w ere a significant fraction of the total SSFL radioactive air emissions . Emissions; . .1988' -~i re ' anticipated as near zero because o f extensive reconstruction work in,progress . The Hot Laboratory used principally.to .examine irradiated reactor fuel, to prepare irradiated fuel for reprocess g., and ta'perform'other operations requiring handling of highly radioactive specimens :: .'•Work is per{i~rzned in cells isolated from operating areas through extensive use of remote contra i and*{ eriscopes . Air flow follows the traditional concept of flowing from areas of rovver contamiri°ation to higher contamination . In addition, leakage around cell doors is essentially elim iinated . Since the cells are the areas of highest contamination, these are evacuated by a n independent system (NRC, 1977) . A schematic diagram of air flows, valves, and filters is shown in Figure 3-3 . The flexibility of ventilation is excellent. Any number of cells can be exhausted at either a high or low rate . Independently, the remainder of the building can be exhausted at any of several rates, depending on which areas are in use . At low rates, make-up air can be added prior to the cell blowers, and additional air can be added at the base of the stack to improve escape velocity . As shown in Table 3-6, emissions from the Hot Laboratory can be a major portion of the total SSFL emissions, which ranged from near zero in 1988 to as high as 90 percent in 1985 . Other major sources of radionuclide particulate emissions at SSFL have been limited to the Nuclear Materials Development Facility (NMDF), Building 055 . THE NMDF was constructed for research an d 3-15 HDMSP00042429 CELL 1 CELL 2 CELL 3 CELL 4 ::PRE FI LTERS (LOC4TED IN y y y HOT CHANG,[; R9OM.,: . HOT SHOP .HOT LA8 OPERATING GALLERY MANIP. ROOM(H 3.1 ) LOW VOLUME VALVES HEPA FILTER S "kHIGH VOLUME ~' .•' VALVES . •. :. HIGH VOLUME CELL VENTILATION (12.540 cfm) DILUTION BLOWER S MAKE-UP AIR VALVE (16,575 cfm ) Source : NRC, 1977 FIGURE 3- 3 HOT LABORATORY AIR PARTICULATE CONTROL` SSFL-VENTURA COUNTY, CALIFORNIA development and production work with alpha emitting and/or highly radioactive fuels . Air emissions were primarily radioactive particulates and were controlled by HEPA filtration . This facility, which had become a minor contributor to SSFL emissions (e .g ., Table 3-6 shows 10 percent of SSFL 1986 emissions were from the NMDF), was permanently shut down in July 1986 . Nonradionuclide Emission s Major sources of nonradionuclide emissions are the permitted sources shown in Table 3-5 "' As discussed previously, these sources are limited not only in emission rates per hour > ;shov r in Table 3-5) but also in tons per year, in amount of fuel burned, and in simultaneous`opvratioh . of several sources. These restrictions and the intermittent operation of most facilitiesresul.ta:n very low emissions of permitted parameters annually . All permitted facilities are conventional units , with the .. exceptiorr of the coal gasification unit, the sodium heaters , the low NOx/SOx combustor , and thp~sodimu rn burn,facili3y ~ ationwhidi gasified coal to form a low BT U (90-100 BTU per cubic foot ) g . any, is expected in the future . The low NOx23funifvitas tested td study coal combustion under conditions designed to give low concentrati:ans ofboth sjtfur'oxides and nitrogen oxides . Essentially the low sulfur oxides were obtained by`-'45P o'f 44pestone injection and the low nitrogen oxides were obtained by quenching partl'y .•combust gas prior to completing combustion . Studies were completed in early 1988 . Limited operation in the future is possible . The sodium burn facility (Building 133) is designed for reaction of waste materials containing metallic sodium . Wastes containing impurities such as sodium-potassium alloys and hydrides of alkali metals can also be handled . Conditions of heating are sufficient to react all the materials . Reaction takes place in a pan heated with natural gas fuel . Reaction products are prevented from release by a venturi scrubber . Removal of particulates is sufficiently efficient that compliance with the emission limitation of 1 .0 pounds per hour is routine . The aqueous discharge from the venturi scrubber and the reaction pan is essentially a high-quality, dilute, sodium hydroxide solution which can be used to replace normally purchased sodium hydroxide . 3-17 HDMSP00042431 Although the burn facility has not been used since April 1987, it is available for use in the future . Utilization of chlorinated solvents and freons is small . During a 1987 survey (Remley, 1987), annual use of methyl chloroform was estimated to be about 630 pounds per year . This survey also estimated annual use of freons (mostly freon-12 and freon-22 in air conditioning) to be about 1,450 pounds per year . 3 .1 .3 Environmental Monitoring Progra m Ambient Air Monitorin g SSFL operates a network of eight ambient air samplers (see Figure 3-1)-i Which coftjet particulate samples continuously . Seven samplers (A-3 to A-9) are located near major- ~ou .rces or"downwind . These collect a sample every 24 hours on a 37 mm diameter filterrat•a .flow rale.of 25 cubic meters per day . A somewhat unique arrangement of hardware allows air ;flow'1o:l a switched to a fresh filter each midnight. Seven samples are collected each m eek, one ..samj 4e representative of each of the preceding 7days . An eighth sample (A-1) is .co(ieetedadjacent to the sampler near Building 100 (A-3) . This sample is collected over a 7-day'period :Thus, in total, about 2,500 samples are collected each year . Samples are cot>nted4or alpha and-beta radiation following a 120-hour delay to allow fo r decay of radon and tfjoron daughters, . : Many of the ,daif; 'sampjg"s.-re near or below the method detection limits (MDL) . For example, in 1987 ; 99 perte itof the alpha measurements and 64 percent of the beta measurements were below MDL. .Although-the 7-day sampler provides information which serves many purposes, it provides an excellent quality control check on the daily sampler . In recent years there has been excellent agreement between the daily and 7-day samples . For example, in 1987, the daily samples showed an average (see Table 3-4) of 0 .0019 x 10-12 uCi/ml for alpha radioactivity and 0 .027 x 10-12 uCi/mI for beta . During 1987, the average of 7-day samples showed 0 .0015x 10-12 uCi/mI for alpha and 0 .0289 x 10-12 uCi/ml for beta . Typically, 68 percent of the alpha measurements and 0 percent of the beta measurements are below MDL for the 7-day samples . Stack Samplin g All stacks known to contain any significant quantity of radionuclides are continuously monitored at SSFL . During 1987, this included only Building 020 and the stack serving Buildings 021 and 022 . Prior to July 1986, Building 055 was also monitored . During 1988 (including the on-site portion of th e 3-18 HDMSP00042432 Environmental Survey), Building 020 was essentially inactive . This presented the opportunity to perform maintenance on the sampling and analytical equipment employed at Building 020 . Sampling at Buildings 021-022 consists of continuously collecting a sample of gas withdrawn from the stack . A flow rate of 62 liters per minute provides sampling that is approximately isokinetic . A filter with 5 micron porosity is changed weekly . A detector mounted nearby would alarm at any rapid build-up of radioactive material on the filter . Additional precautions to prevent large discharges from the stack come as a result of frequent monitoring of the pressure drop across ..the HEPA filters and monitoring (primarily for employee health purposes) conducted within :the ;Iw o buildings . , Emissions from the RMDF complex have been low for many years . Recent: results are ommarfzed in Table 3-7 . Better precision results, because fewer measurements are. close t6 detection limits than with ambient air measurements . In 1987, 31 percent of the .alpha ,measurements and none of th e beta measurements were below MDLs . The annual monitoring report usually contains`•a=$tafernerit such as : The effectiveness of the air cleaning systems is evident from the fact that .the :atynospheric effluents are less radioactive than is the ambient air" (Moore, 1%8b)_`' . In 1987, this was correct for the emissions from Building 020 and for the DeSoto buiI4-jax6s- Table 3-I%- hows, however, that emissions from Buildings 021-022 were higher than .: th `'4equl`u lent ac8bient air . Nevertheless, controls are effective and the total radioactivit -,releese is low- ! ki_ `1987, the total released was less than 1 percent (0 .17 percent alpha, 0 '17-p ccent~b4ta) of to appropriate DOE guideline . Modeling by AIRDOS-EPA is used to estimate doses to the general population . Doses are not substantially different from zero . For example, the average individual dose to a person living within an 80-km radius was 9 .6 x 10-7 mrem in 1987 . The total dose from all sources, including natural background, is about 180 mrem . Total dose from SSFL, including direct radiation, will be discussed more fully in Section 4 .3 . 3-19 HDMSP00042433 TABLE 3- 7 RMDF ATMOSPHERIC EMISSIONS SSFL - VENTURA COUNTY , CALIFORNI A Total Radioactivity Released (Ci) Y ear Annual Average Average Ambient Ai r Concentratio n Beta ( .Ci/ml) * Alpha Beta Concentration Beta (uCi/ml) 1987 2 .5x10-7 1 .2x10-5 51x10-15 29x10-1 5 1986 4 .6 x 10-8 1 .3 x 10-5 40 x 10-15 73,x..11.0-1' 5 1985 3 . 9 x 10-8 9 .0 x 10-6 39 x 10-15 3t 'x 1A~' 5 1984 7 .4 x 10-8 3 .7 x 10-6 1 .1 x 10-1 5 1983 4 .7 x 10-8 1 .1 x 10-6 3 .4 x 10-4 k . 1982 2 .4 x 10-8 0 .61 x 10-6 1981 < .87 x 10-8 4 x 10-6 32 ~ t O t 5 -42 x 10-1 5 •: .`1,2 x'10-1 < 120 x 10 1 5 Source : Adapted from Rocketdyne Annual Mp6}t6'r)rig' Rep 6:rt_5 (1 81 -1987) by DOE Survey Team . * 7-day samples at SSFL Building 100 from 1985 fo° 1988 ; at Desoto Site from 1981 to 1984 . 3-20 HDMSP00042434 3 .1 .4 Findings and Observations 3 .1 .4 .1 Category I None . 3 .1 .4 .2 Category II None . 3 .1 .4 .3 Category I I I None . 3 .1 .4 .4 1. Category I V Lack of Meteorological Tower . Lack oaf ,a metrological tower could result in inaccurate dos e assessment in the e v t of an unscheduled -release . Without a meteorological tower providin g current wind • eed and ditezti©rr•. d ta, it is not possible to accurately predict the area of impact_YS_ta unsg-Fteduled.release . In addition, annual calculations of the air pathway dose to the 'population us~rt ,theAIRDOS-EPA computer model may be in error, since old and inappr`i priate i°1 ormation from the Burbank Airport (BAP) is used . It has been assumed that the BAP information is adequate because upper winds above the sit e are similar to upper winds at BAP, 22 miles east of the site . However, data taken from a meteorological tower that was operated in Area II during 1960-1961 shows some differences . For example, data for the NNW through NE quadrant (that is, the sum of the frequencies from the NNW, N, NNE, and NE segments) indicates that the wind is from that direction 41 .7 percent of the time at BAP but varies from 33 .8 percent of the time (winter) to 12 .0 percent (summer) at SSFL . 3-21 HDMSP00042435 3 .2 Soil s 3 .2.1 Background Environmental Informatio n Naturally occurring soils at SSFL have formed through weathering and erosion of the geologic formations present at the facility . The soil consists of recently deposited (in geologic time) unconsolidated sand, silt, and clay referred to as Quaternary Alluvium . The Burro Flats area contains the most continuous soil zone at the site ; as much as 6 .6 meters (20 ft .) in depth . Other areas of:fhe site exhibit shallow soils, often discontinuous laterally, where outcrops of the Cretaceous C'batsw rth Formation sandstone form cliffs or rock knobs protruding from the surface (Refer to ;Setion 3 .4 .1`:for information on the site geology) . Within the weathered rock zone, ;call sear ..:oGc tpy joints, fractures, and faults in the rock mass where the sandstone has been decomposed iri place by'water i n fil tra ti ng from th e sur face a l ong th ese fea t ures . Background levels of radioactivity in soil and vegetation at SSFCWq-re it itially measured in 1954 prior to any on-site activity with radioactive materials ;; B.otli`.on -site and off-site regional soil and C•- vegetation monitoring for radioactivity has be 5lperformedsince that time . Generally, on-site values of gross alpha and gross,beta have been s rrttlar to off-site values . Both on-site and off-site values also show a gradvaf j.ncr2ase in gross alphl a and gross beta since initial sampling, reported by SSFL to be due mostly o global nt1cf'ea ,weapons test fallout . The most recent soil radioactivity data (see Section.,.3 .2 ). shoyv -•average values of 27 .1 pCi/g for gross alpha, and 25 pCi/g for gross beta from 48 oiiysitg-sarnples: : :'I` e' average values from 48 off-site samples for the same period were 75 :7 pCiLg for:grosi'aipha and 24 pCi/g for gross beta (Moore, 1988) . Vegetation analyses, when last reportedly sand in 1985, shows a similar relationship with on-site average values of 3 .8 pCi/g for gross .alpha, and 135 pCi/g for gross beta from 48 samples . The average values from 48 off-site samples for the same period were 4 .7 pCi/g for gross alpha and 133 pCi/g for gross beta (Moore, 1986b) . Additional information and data from the environmental monitoring program are presented in Section 3 .2 .3 . There are no Federal or state regulations that limit the concentration of uranium in soils . However, there is guidance available from both the U .S . Nuclear Regulatory Commission (NRC) and the U .S . Department of Energy (DOE) . The NRC, in a memorandum pertaining to a Branch Technical Position on the disposal or on-site storage of residual thorium or uranium, established derived concentration limits for various disposal options (NRC, 1981) . One of these options applies to wastes with sufficiently low concentrations of uranium or thorium that they would present no health risk and may be disposed of in any manner . The acceptable concentrations for this disposal option were derived by the NRC using radiation dose guidelines recommended by the Environmental Protectio n 3-22 HDMSP00042436 Agency for protection against transuranium elements present in the environment (EPA, 1977) . The derived concentration limits are natural uranium, 10 pCi/g ; depleted uranium, 35 pCi/g ; and enriched uranium, 30 pCi/g . The concentration limit for natural uranium is based on the assumption that all the daughter products are present in secular equilibrium . The DOE has established guidelines for residual radioactivity at Formerly Utilized Sites Remedial Action Program (FUSRAP) and remote Surplus Facilities Management Program (SFMP) sites (DOE, 1985 and Gilbert et at ., 1985) . The guidelines specify concentrations for thorium-232 &• .230, and radium-228 & 226 only . For other radionuclides or mixtures, the soil concentration q ide}Rues must be derived, on a site-specific basis, using a basic dose limit of 100 mrem/yr to anliitdi-vldual, from all pathways . There are no Federal regulatory standards for nonradiological contaminant concentrations in soil as there are for drinking water supplies or air except for PCBs in,Sojt (40'CFR 761 :-125) .A determination of "safe " or "acceptable " levels in soil depends ort pntari inanmi jratron pathways ( e .g ., wind or water erosion or leaching to the groundwaterf .'and*,pafential'.'}humala exposure routes ( e .g ., ingestion of soil by children or farm animals , ingestion of c mitiated' ~ roundwater , or inhalation of fugitive dust containing contaminants ),., Therefore ,-Federdh y acceptable levels for most contaminants must be determined on a site -specific-aahd chemical -specific basis . California ham :?tgisla `•t1 resl~ qld *4rimit concentrations for several substances, mostly known or suspected a7cin Sgens, that, 4f'*exceeded in a material (i .e ., soil, etc .), render it to be a hazardous waste:. There 16re to -such limits--Soluble Threshold Limit Concentration (STLC) and Total Threshold Ejmit concentr kt+on (TTLC)--as defined in Title 22 of the California Administrative Codes . In addition, the;State Water Resources Control Board is organized on a regional basis to allow specific regional or Ioca'needs to be addressed that would not apply to other areas of the state . The regional boards have authority to regulate, and as such, the Los Angeles Regional Water Quality Control Board has entered into a memorandum of understanding (Resolution 85-26) with the Resource Management Agency of the County of Ventura that requires cleanup of contaminated soils . Therefore, state and county standards for contamination of soils are in effect at SSFL, and are limited to STLCs, TTLCs, and background levels. 3 .2 .2 General Description of Pollution Sources and Control s Soils can become contaminated by air emissions, runoff, disposal activities, spills, and resuspension of contaminated materials from other areas . Because on-site soil sampling at SSFL typically has been limited in terms of areas sampled and constituents analyzed, the Survey team in some cases utilize d 3-23 HDMSP00042437 process information and field observation to identify a number of potential soil contamination sources and to verify areas of known soil contamination . Actual and potential sources of soil contamination consisting of diffuse and/or large areas where soils have been contaminated from research operations and airborne emissions are not apparent at SSFL . Discrete areas of soil contamination , resulting from isolated small spills or inadve rtent releases have occurred and are addressed in Section 4 .5 .2 .3 . Soil contamination associated with storage areas and with inactive waste disposal sites is addressed as pa rt of Sections 4 .1 .2 and 4 . 5 .2 .3 ., respectively , and in the findings dealing with the particular disposal sites . Areas of known soil contamination are described briefly as follows : Old Sodium Burn Pit (8-886 ) - The area referred to as the Old Sodium Bi :trh.Pif ;or the " Burn Pit" occupies approximately 4,650 square meters ( 50,000 sq :.; t) oo the north side of Building 886 (see Figure 4-3) . The facility consisted of a treatment area wi ' fh ;,a.concrete sump , an upper pond , a lower pond , and the nearby sur.-o undi ` 'area. that Was used for °'laydown " or burial . It was used extensively during the'•. 196~19TOs 1t±meperiod for disposal of combustible materials such as sodium ,. .N aK, and kerosene::(QIson et al ., 1987 ) . Investigative trenching use d as a pa rt of a Phase. hi ;CERCLA investigatiot>• performed by a consultant to the site, revealed soil contamination' .isisting of;I'organic` solvents , diesel fuel , and oil and grease , PCBs, PCTs, terphenyf 'and~trp}'renyls .(Olson et al ., 1987 ) . Concentrations in the soil for organic solvents ranged from 3100 ' iugf/kg for Freon - TF to 22 mg/kg for trans - l,2-dichloropropane . Other 1,1-dichloroethane ; ~organ.i '.~satvgnts encountered were carbon tetrachloride ; $ ;1-dichl oethylene ; ethyl benzene ; tetrachloroethylene ; toluene ; 1,1,1- trichloroethane ; and trichloroethylene . Concentrations in the soil for PCBs and PCTs were repo rted to be as - high as 12 and 1 .4 mg/kg respectively, and terphenyls and biphenyls ranged from nondetectable to 880 and 102 mg/kg respectively ( Olson et al ., 1987) . Sodium Reactor Experiment (SRE) Watershed - Surface water runoff from the SRE Watershed area which was sampled and analyzed once , was found to contain asbestos at a concentration of approximately 226 million chrysotile structures per liter ( EMSI, 1987) . The SRE Watershed area contained buildings constructed with transite siding ( an asbestos-containing product) and asbestos roofing ; asbestos insulation was used on the sodium piping . In addition , the SRE cooling tower , which contained asbestos- based " Munters Fill ," was destroyed by fire in approximately 1972 . Although many of the asbestos - bearing materials have been removed from the area , the more recent sampling of surface -water runoff indicates that a source of 3-24 HDMSP00042438 asbestos exists in the area . SSFL has not investigated the area to determine the source of the asbestos . 3 .2 .3 Environmental Monitoring Progra m Environmental monitoring of soil and vegetation for radioactivity was initiated in 1954 at SSFL and has continued to the present. The current program is directed and performed by the Radiation and Nuclear Safety Group of the Health, Safety, and Environment Department . The intent of- :the program is to adequately survey environmental radioactivity to ensure that nuclear operations do not contribute significantly to environmental radioactivity ( Moore , 1988) . The locati6crsseiectectf.or on-site sampling were selected in the mid-1950s (prior to SRE construction) .. based.!bn...the planned' locations for reactor experiments . The locations for monitoring have not sagnficantly c ange6t,sinc e the original selections were made, although site operations ha ve'changed' reaative ~'to potentia l radioactive sources for contamination (see Finding 3 .2 .4 .4 .1) . The current program of soil monitoring consists, of~oAectiri . .48 •iemples from on-site and off-site locations up to 16 kilometers (10 mile3) .- .frorn-`-the facility-•on a quarterly basis (Moore, 1984 ; Moore, 1986) . Figures 3-4 and' . 3-5 show on-sit e' .. and off-site sampling locations . Samples are collected from an undistVrbect area within 1:5 meters (50 feet) of the location listed in the Radiological Envirorr r;mntal . :Monitoxing;Pro'gram document (Moore, 1986) . No sample location markers are .use4`:i.o tFii'fjel"d to define the area to be sampled . The sample is collected by scooping up approxfmptelFT00 grams of soil from the top 2 .5 cm (1 inch) of soil using a plastic scoop . The sampre is prepSred` by.drying, sieving on a 0 .6 mm Coors crucible, and spreading with alcohol on a copper .planchet,'-Analyses are performed by counting for 100 minutes for gross alpha and gross bet a at an, on-site laboratory . The balance of the raw sample and the furnaced sample are then composited and gamma scanned . Data analyses are reviewed by four site personnel . The samples are collected and analyzed by the same person, and the samples do not leave the sampler's possession . No formal chain-of-custody is used . Semiannually, samples are collected by SSFL and analyzed off-site for plutonium by an independent laboratory according to NRC guidelines . Vegetation monitoring for radioactivity, which was conducted with monthly soil monitoring, was discontinued after 1985 when SSFL also decided to reduce soil monitoring from monthly to quarterly intervals . Compilations of soil and vegetation monitoring data are presented in Tables 3-8 and 3-9, respectively . As previously discussed in Section 3 .2 .1, the average of on-site radioactivity analytical values for soil and vegetation are similar to the average of off-site values . 3-25 HDMSP00042439 'fr LEGEN D Securi ty Control Center Soil Sampling Locatio n On Access --~ Road Silvernale Resesvpir 0 60 0 ,-.Scale, Feet I Source: Moore, 1988b FIGURE 3- 4 ON-SITE SOIL SAMPLING LOCATIONS SSFL-VENTURA COUNTY, CALIFORNIA R I HA,'.- Canoga Par k Thousand Oak s Woodland Hills Source : Moore, 1988b FIGURE 3-5 OFF-SITE SOIL SAMPLING LOCATIONS SSFL-VENTURA COUNTY, CALIFORNIA TABLE 3- 8 SOIL RADIOACTIVITY DATA 1987-1957 SSFL - VENTURA COUNTY, CALIFORNI A On-Site Average or Rang e (pCi/g) Off-Site Average or Rang e (pCi/g ) Year Number of Samples Alpha Beta Number o f Samples Alpha 1987a 48 27 .1 25 48 25 .7 1986a 48 26 .7 26 48 25 . 1 1985a 144 25 .2 24 48 26 . 3 1984a 144 25 .8 24 48 ;` .•. 1983 144 0 .61 24 t_ ~.. 48. . 0 .59 23 1982 144 0 .69 48 0 .68 23 1981 144 0 .69 48' 0 .64 23 1980 144 0 .66-. 24 48 0 .58 23 1979 144 `. . 0 .64 •=25 48 0 .50 23 1978 144 0 .63 : 24 48 0 .51 24 1977 ; 144 •0 .56 24 48 0 .53 23 0 .56 25 48 0 .56 24 ° 2:5 Beta . ; ' 24 23 1975 : 144 0 .60 25 48 0 .58 24 1974 144 0 .60 25 48 0 .54 24 1973 144 0 .57 25 48 0.51 24 1972 144 0 .56 25 48 0 .57 24 1971 144 0 .55 25 8 0 .53 23 1970 144 0 .47 27 48 0 .48 25 1969 144 0 .42 27 48 0 .42 25 1968 144 0 .47 26 48 0 .48 26 1967 144 0 .41-0 .42 28 48 0 .38-0 .39 24 1966 144 0 .40-0 .41 29 48 0 .43-0 .44 25 1965 144 0 .46 36 142 0 .46-0 .47 29 1964 152 0 .44-0 .46 32 299 0 .40-0 .44 26 3-28 H D M S P00042442 TABLE 3-8 SOIL RADIOACTIVITY DATA 1987-1957 SSFL - VENTURA COUNTY, CALIFORNIA PAGE TW O On-Site Average or Rang e (pCi/g) Off-Site Average or Rang e (pCi/g ) Y ear Number o f Samples Alpha Beta Number o f Samples 1963 156 0 .41-0 .43 45 455 0 .38-0 .42,, . 42 1962 147 0 .42-0 .44 48 453 0 .35-0 .4;1'-. 47 1961 120 0 .30-0 .37 34 458 1960 115 0 .34-0 .41 23 36 --' • . 1959 107 0 .43 15 1958 80 0 .27 ' 1957 64 0 .32 Alpha Beta 2:3 0 .27-0..37 19 ' : . .32 14 109 0 .26 10 3 .14 0 .35 10 Source : Adapted from Moore, 1987, and'.Mloor2undated . a The change in alpha activi y ;after 1983 is-the result of an improved calibration method that provides a true` neasure ofi:.aJpFia.~'activity in thick samples rather than the relative values used previous(1t',Values for•.1987 using the prior method would be 0 .87 for the on-site averag .a 0 .83`fq'r the.o' ,f-side average . 3-29 HDMSP00042443 TABLE 3- 9 VEGETATION RADIOACTIVITY DATA, 1985-1957 SSFL - VENTURA COUNTY, CALIFORNI A On-Site Average or Rang e (pCi/g-ash) Off-Site Average or Rang e (pCi/g-ash ) Y ear Number o f Samples Alpha Beta Number o f Samples Alpha Bet a 1985a 144 3 .8 135 48 4 .7 13 3 1984a 144 4.0 136 48 5 .9 13 6 1983 144 0 .18 149 1982 144 0 .16 140 48 t; . 48: ~• . 1981 144 0 .20 137,-.. 1980 144 0 .25 1Q 1979 144 0 .24 1978 144 0 .24' . '•, 1977 144 ` . . . 0 .22 ' 0 .19`` . 1976 :1`44 '`'0 24 .a:17,' . . 143 ' 13 0 0..21 12 9 48 0 .19 142 4$ 0 .23 13 4 48 0 .24 143 '462 48 0 .21 142 170 48 0 .22 14 7 155 48 0 .21 14 1 166 ' ;.= 1914 144`.• 0 .20 152 48 0 .27 14 1 1973": 144 0 .24 155 48 0 .24 14 2 1972 'L1 144 0 .23 145 48 0 .36 12 5 1971 144 0 .24 165 48 0 .31 13 2 1970 144 0 .33 159 48 0 .30 14 2 1969 144 0 .40 165 48 0 .36 144 1968 144 0 .51 158 48 0 .51 20 5 1967 144 0 .62 286 48. 0 .39 41 3 1966 144 0 .37 169 48 0 .37 12 3 1965 144 0 .55-0 .56 162 142 0 .61 13 8 1964 152 0 .49-0 .50 211 293 0 .50-0-51 18 1 3-30 H D M S P00042444 TABLE 3-9 VEGETATION RADIOACTIVITY DATA, 1987-1957 SSFL - VENTURA COUNTY , CALIFORNI A PAGE TWO On-Site Average or Range (pCi/g-ash) Off-Site Average or Rang e (pCi/g-ash ) Year Number of Samples Alpha Beta Number of Samples 1963 156 0 .43-0.44 465 456 1962 147 0 .44-0 .45 500 453 1961 120 0 .32-0 .35 224 459 1960 115 0 .31-0 .35 137 362:' 1959 96 0 .29 212e .•-, 1958 65 0 .57 fi83 1957 58 1 .1, : . X293 . 0- . :. ':. 304 Alpha 0 .42-0 .44.fr-0 .29 ° :. Beta • :> ' . .,'-,'40 6 2d6 0,21 0:25 13 6 0.18 16 8 =' 0 .39 35 6 0 .89 20 0 Source : Adapted from Moore, 1987, and Moore, undated . a The change in alpkr :zctivityaft er 1903 i~TChe result of an improved calibration method that provides a true,eneasure of~ilpha,- ctivity in thick samples rather than the relative values used previousfiC-%_Val+es for 185 using the prior method would be 0 .19 for the on-site aver#g?ai 0 . 23 :for the .o >-£hansfer`*€ank at the no rtheast bounda ry of the site in Area I . The main storage reservoir is kxated ' in= Area II and consists of one 3 . 8-million-liter (1 . 0 million gallon) tank plus three 384,000=liter (1F1€,000 gallon) tanks maintained at 666 meters ( 2,185 feet) above sea level . A gravityfed=_distribution system se rv es all of SSFL from this source. There is also a 1 .89 million-liter (0 . 5 million gallon ) storage tank in Area IV at an elevation of 652 meters (2,140 feet), which se rves as a rese rv e supply for peak demands and for fire protection for the DOE facilities . Refer to Figure 3-9 for details . The major on -site well currently in use is Well No . 5 in the central pa rt of Area I . This well has supplied up to 38 million liters ( 10 million gallons ) of water per month and has been gradually increasing its total annual pumping rate since overhaul in early 1985 . Well No. 13, along the no rthern site boundary in Area II, had provided up to 17 . 7 million liters (4 .68 million gallons) per month until it was shut off in Janua ry 1987 . SSFL has gradually increased the volume of on-site well water used in the fresh water system, while gradually reducing water purchased from District 17 . Table 3 - 11 summarizes water usage rates for the three principal sources for the years 1984 through 1987 . Note that over the 4- year period, purchased water has declined from 45 . 8 percent of the total water use to 31 . 2 percent. 3-39 HDMSP00042453 Source : Stafford, 1984a FIGURE 3- 9 FRESH WATER DISTRIBUTION SYSTEM SSFL-VENTURA COUNTY . CALIFORNIA TABLE 3-1 1 SUMMARY OF WATER USAGE SSFL - VENTURA COUNTY , CALIFORNIA % Purchased fro m District 1 7 District 1 7 Purchased Water Well No . 5 Well No . 13 Total Water Use 1984 148,336,8451 (39,190,712 gal ) 122,453 , 8341 (32,352 , 400 gal ) 52 ,779,5541 ( 13,944, 400 gal ) 323,570 , 233 I (85,487,512 gal ) 1985 95 , 226,7391 (25,158 ,980 gal ) 21,736 , 1201 ( 5,742 , 700 gal ) 95 ,377,0801 ( 25,198 , 700 gal ) 212 , 339,9391 .< " ' . 44 . (56,100, 380 gat); 1986 85 , 170,3881 (22,502 , 084 gal ) 134, 863,7141 (35,631, 100 gal ) 23 ,346,6371 ( 6,168,200 gal ) 243 .3 $Q 39 1 164,301 384:igal ) 1987* 65, 556,8061 (17,320 , 160 gal ) 144,464 ,8961 ( 38,167 , 740 gal ) (01) , . ., (0 gal)' .. . : = 210,02.f,702'1 5 ;487,900 gal ) Year 45 . 8 •:_' ' 31 . 2 Source : SSFL Watermaster ' s Files * Usage for 1987 based on data f9r f`rfsf-9. bi hs ofjheyear , extrapolated upward using average usages for 3 prior years: : We}f :l o 13 :jivps k . i'bwn to have been shut down for al I of 1987 . - 3-41 HDMSP00042455 Site topography, natural drainage , and a maximum expected extreme precipitation rate of no more than 46cm ( 18in .) per month during the rainy season all tend to minimize any threat due to flooding at SSFL ( Cleveland , 1985) . No SSFL facilities are located in the flood plain , and all active areas of the site are well drained to control storm water run-off . Elevations of the active areas va ry from 550 to 640 meters ( 1,800 to 2 , 100 feet) . During major storm events which produce heavy runoff, bypass culve rt s on-site are opened to divert stormwater flows around the R - 1 Pond and the Silvernale Pond . Flows thus dive rt ed are then impounded at the Perimeter Pond and the R-2A Rond respectively. Area IV, where the DOE operations are based , has had no problems with tloodin U .industrial waters and most of the stormwater runoff are drained through open charnels _ and' ulvert+s=to the large retention ponds R - 2A and R- 2B in Area II . A small po rtion f5tormw,ater drains toward the no rth and west toward Meier and Runkle Canyons throu .ghetq Jed tli'annels : The slopes are steep enough that flooding is not a problem , even during'the 4severec storms :. However, diversion dikes designed to convey stormwater run-on away fiom areas wfe hazardous wastes have been buried were breached during prelimina ry clean - up effot _aiid 1 avenot been replaced . As a consequence, storm -water running downslope , through this area basses through the burn pits and burial site on its way off-site . For fu rther dk- ssian of this proli4m , refer to Section 3 .3 .3 . Afthoogh sit ► }ersosii 1 at SSFL conduct extensive monitoring of on - site well waters and file regular reportwith th`4=California State Depa rtment of Health Services ' Sanita ry Engineering Branch, none of the well water or water purchased from District 17 is used for drinking water . The total use for these' waters is industrial ( Bulan, 1987a ) . Since 1976 , drinking water has been purchased as bottled water from several different sources , licensed to provide this se rv ice to the public . Multiple suppliers are used so that adequate quantities can be made available during periods of water sho individual suppliers may be forced to reduce deliveries . rt age when At current levels of activity , the entire SSFL Site is consuming an average of 1,154 units of bo tt led water per month . Based on 19-liter ( 5-gallon) units, an average population of 900 people per day , and an average of 22 working days per month, this rate of consumption provides 1 .1 liters ( 2 .3 pints) per day per person . 3.3 .2 General Description of Pollution Sources and Control s One of the largest sources of industrial wastewaters under DOE control is the Sodium Components Test Installation ( SCTI), located at Building 356 . This facility is used for performance evaluation o f 3-42 HDMSP00042456 large heat exchangers, steam generators, and their in-line components (e .g ., valves, seals, expansion joints) . Extensive cooling arrangements are involved, with up to 10 forced draft cooling towers online to provide heat removal from the water-cooled condenser system and boiler feed pump seal coolers, lube oil coolers, and air compressors . In addition to this circulating cooling-water system, a treated-water system is installed to provide makeup water to the steam and feedwater system, and to filter and demineralize the full condensate flow from air-cooled and water-cooled condenser systems . This treated-water system must have tight control of feedwater purity, pH, and dissolve d oxygen content . The demineralizer regeneration is accomplished using strong sulfuric acid and soditfr hydroirtde solutions to condition the six mixed-bed ion-exchange resin columns . Regenerati:ornecessaiy' every 5days of operation for the typical resin column and produces .about 45,OX1liters (12,000 gallons) of spent regenerants for disposal from the system Separate batches cif spent acid s and caustic solution rinses are released slowly at the same time, yielding near .-I-y neutral wastewaters . These wastewaters then flow by gravity to Pond 'R-2B ;;.wyhero:%this sr ll flow mixes with other wastewaters from Areas II and III . The SCTI hg u.tii zes a--nine-ty be reverse osmosis (RO) unit to lower the total dissolved solids content of :the fee{1vsrater :•.The`brines from this RO are also release d to Pond R-2B for reclaim . During the Survey, irogres5,on anew cogeneration plant being erected adjacent to the SCTI was observed . Thi"ss'Unit,'~ desi"gnateff as the ETEC Power Pak, will produce electricity from steam generated4nrcompohierlt testing at the SCTI . Up to 360,000 kg-cal/minute (25,000 KW), enough to +gh#~inore iian`5,Q80 homes, will be generated and sold to the local utility . The only wastewater originating at'`the Power Pak will be steam condensates and blowdown from the recirculating cooling water systems . Both of these wastewaters will be released to the channel that conveys SCT I flows to Pond R-2B in Area II . SSFL has used several different methods for cleaning and decontaminating system components after experiments shut down, or during active periods of component repair and reuse . Formerly, steamcleaning lances were used to remove sodium at two primary locations : an area immediately east of Building 143 (the former graphite-moderated sodium reactor experiment facility) and in the westernmost part of the site at Building 886 (the sodium disposal facility) (Adler et al ., 1986) . This practice is no longer used at SSFL . More recently, cleaning and decontamination operations were accomplished at Building 463, the Component Handling and Cleaning Facility (CHCF) . Here, all cleaning was accomplished by using ethanol in place of water and thus eliminating this source of contaminated wastewaters . However, prior to this change, soils in the B-886 burn pit area ha d 3-43 HDMSP00042457 become contaminated with heavy metals, organics, and low-level radioactivity, principally . cesium-137 . Refer to Finding 3 .3 .4 .2 .1 for additional information regarding this problem Intrusion of groundwater into Building 059 produced wastewaters contaminated with radioactivity from induced activity in the basement sand . Some of this water remains in the basement of the building, mixed with sand . A standpipe which drains three sides of the building via French drains shows measurable levels of chlorinated organics in the parts per billion (ppb) range . A positive hydraulic head is maintained outside the basement to prevent any outward migration :of radioactivity or other contaminants . No radionuclides have been detected in the stand pipe .' - . , alcu l'ated Dail y Source : Ghirelli, 1984 . * The daily maxtirr%i ;i n turbidity limit shatl not be exceeded more than 5% of the tim e during any2hour period 3-51 HDMSP00042465 is achieving nearby total compliance with all requirements . Moreover , this compliance is being achieved by a wide margin , since most concentration - limited constituents are being released at less than 25 percent of their 30 -day average and maximum concentrations . For load-based requirements compliance is perfect , and the typical release rate for the eight load-based limits (including flow rate) is only 1 to 2 percent of the limit. The only controlled wastewater characterisitc that occasionally approaches its maximum limits is temperature , which sometimes reaches 24 °C (72°F) . Since water is only released between November and May in most years , this requirement is not likel y to be exceeded either . In compliance with the California Safe Drinking Water and Toxic Enforcement Act of19~86., otherwi se known as Proposition 65, SSFL conducted a study of site runoff waters . A list of'• oterltial toxi substances regulated under Proposition 65 was used to identify possible pr_ot lien. area3'whera .rtunof f waters may come in contact with listed substances . A knowledge of past engineering and test operations was also used to identify possible problem areas . A n - was charged with the necessary sampling and analytical tasks to cpmplelr ,the;study: Nine SSFL locations were identified as candidates for sampling , and %pater ti rr, cher*jcal • :5tibstances were designated fo r analysis . Fou rteen of these were organic su k Of the nine SSFL locations rdent find , two were .in Area I, one in Area III, and three each in Areas II and IV . Locations are .escri ..ed more. fuFl:y .i Table 3-14, which also provides analytical data for those chemicals ide.f"tf' d as prgsent ir .~iterrunoff . All samples were collected during the first few hours of measurable ;train ,st~the begin nngof runoff on March 21 , 1987 . This was done to avoid the dilution effects of cortrnue ;r infall on the samples ( EMSI, 1987 ) . A separate compilation of analytical data for°aslbe'stos is pi"©vided in Table 3-15 . The Idtations most affected by DOE activities are identified as RD-4 , RD-6, and RD - 9, since they are all in Area IV . To a lesser extent , locations RD - 3 and RD 7 may also show impacts , since most natural runoff from Area IV arrives there and mixes with a larger volume of runoff waters from sites in Area II and III . A review of results shown in Table 3-14 indicates that recommended primary drinking water standards for arsenic were exceeded at all locations draining Area IV except for RD - 7, the R-2B Pond inlet . For chromium , the standard was exceeded only at RD-9 , while the lead standard was exceeded for points RD-7 and RD-9 . No Area IV source was detected for thorium . Comparison with drinking water standards is done for information only, since there is no indication that runoff waters from any of these areas ever reaches a point where they may be used as a drinking water supply source . For all metals except thorium , highest concentrations occurred at RD - 9, the east drainage to Meier Canyon from the sodium disposal facility runoff . With respect to organics , impacts were less significant . Given a California Depa rt ment of Health Services action level of 0 . 040 mg/I fo r 3-52 H D M S P00042466 TABLE 3-1 4 CHARACTERIZATION OF RUNOFF WATERS SSFL - VENTURA COUNTY , CALIFORNI A All concentrations are in mg/ L RD-1 RD-2 RD-3 RD-4 RD-5 RD-6 RD-7 RD-8 RD- 9 ,G..19 0:3x4 Inorganic s Arsenic <0 .1 0 .16 0 .10 0 .17 0 .12 0 .14 Chromium <0 .03 0 .11 <0 .03 <0 .03 <0 .03 <0 .03 <0A-, .1-'<0 Lead <0 .05 <0 .05 <0 .05 <0 .05 <0 .05 <0 .05' '`0 .09 Thorium <0 .1 <0 .1 <0 .1 <0 .1 ND ND 0 .18 .< .0 .1 <0 .1 3 0 .14::' '<'O+.65 . .':.,,0 .2 1 <0':1, <111 <0 . 1 ND ND ND Organic s Chloroform Methylene Chloride ND 0 .15 ND ND 0 .45 0 :15.1.. ND `. `'• . 5• IND ND 0 .40 ND Source : Adapted from EMS[' 1987 . ND - None detected . Key to Sampling Locatior: RD-1 Well 13 CaiyQn in Area II .' . RD-2 Perini' 'ter Por d tn' 4rea i RD-3 R=2A Pond i n Area 11 . . RO-4 . A'r a. .jnd Building 163 in Area IV, draining to Meier Canyon, . RD3•, R-i.indin :*cea I . RD-b Buildttc 886 in Area IV East drainage in Meier Canyon Location 2 . RD-7' R-2B P6nd Inlet in Area II . RD,8 Silvernale Pond in Area Ill . RD-,9• Building 886 in Area IV East, draining to Meier Canyon Location 3 . 3-53 HDMSP00042467 TABLE 3-1 5 ASBESTOS IN RUNOFF WATERS SSFL - VENTURA COUNTY, CALIFORNI A Fiber Types and Units RD-1 RD-2 RD-3 RD-4 RD-5 RD-6 156 0 0 225 0 136 0 0 165 Bundle 0 0 0 Matrix 20 0 0 Million Structures/I RD-7 RD-8 0 110 18 .5 0 0 86 17 :3"' 23 0 0 12 :. 37 0 0 12` : RD- 9 0 Million Chrysotiles/l : Fiber ,1',2 0 Million Chrysotiles >5 um/I : Fiber 2 .9 0 0 6 .6' '0 ., Bundle 0 0 0 1.6. "s:(3•• Matrix 0 0 1,430 0 %%_ 0 0:' . 1,139'• Q.. :' Mass Concentration ug/I . ;. .,o 0 0 0 -Q, :'• 0 0 0 0,°-' 0 0 0 0 4,54.6: 0 0 1,623 186 0 -0 1,765 0 0 686 121 0 '..3. Chrysotiles, jig/I : Fiber Bundle 0 •0 0 2,224 0 0 698 65 0 Matri)t 21 0 0 557 0 0 239 0 0 32 .4 0 0 257 0 0 0 0 0 -Bundle 0 0 0 1,500 0 0 0 0 0 Matrix 0 0 0 47 0 0 0 0 0 . Chrysooi l es'> u m :ag(I >,Fiber Source : Adapted from EMSI, 1987 . Key to Sampling Locations : RD-1 Well 13 Canyon in Area II . RD-2 Perimeter Pond in Area I . RD-3 R-2A Pond in Area II . RD-4 Area behind Building 163 in Area IV, draining to Meier Canyon . RD-5 R-1 Pond in Area I . RD-6 Building 886 in Area IV East draining in Meier Canyon Location 2 . RD-7 R-2B Pond Inlet in Area II . RD-8 Silvernale Pond in Area III . RD-9 Building 886 in Area IV East drainage to Meier Canyon Location 3 . 3-54 HDMSP00042468 methylene chloride ( Rogers , 1986), runoffs RD-3 and RD- 4 indicate that there may be some carryout of this organic from Area IV . Similar concentrations at locations RD-1 and RD-8 are not likely to be related to DOE operations , because of their distance from any DOE installations. There may be a problem with other contaminants in the north-bound runoff . Since this runoff is not routinely monitored as pa rt of any ongoing SSFL/Area IV surface water monitoring program, undetected release of contaminants may be occuring . Inadequate characterization of surface-water runoffs prevents SSFL from identifying potential problems ( refer to Finding 3 . 3 .4 .4 .1) . For example, asbestos data in Table 3 - 15 show highest measurements in two locations that drain northward frbm SSFL . Sample RD -4 from the area behind Building 163 contained the singl'e •- hghest rnass concentration of asbestos at 4,546 mg/I . Structure counts were read at 225 mill ior; .$trtictures per liter, of which 165 million were chrysotile fibers ( EMSI, 1987 ) . California had proposed a "s i Kificant risk level" for ingesting asbestos from drinking water of 140 million fibers `. per -day ,' so the RD-4 runoff fiber content was at 118 percent of the proposed , level . iaw.ever, it is extremely unlikely that any of the asbestos in the runoff toward Meier Canyon could ever affecttwater supplies in the Sim i Valley . Even though SSFL uses bottled-, water as its ., sole 'potable water source, the freshwater distribution system is routinely ar~a1y ed for radioacti'j #y and bacteriological parameters . Samples for radioactivity meant' nentsare 'collected' monthly from two widely separated sources on-site . In 1986 , the .a+Zacage gtoss~alpha•yneasurement was 6 . 55 ± 9 .09 pCi / I and the corresponding average gross beta : meps&ement was ' 3 .58 ± 0 . 95 pCi/I for the 24 samples . Individual supply wells are also analyzed twicea ye °ai-For the three most used wells, the following average values were repo rt ed for t986 and 1987`:. Activity in pCi/I Well Year Gross Alpha Gross Bet a WS-5 1986 11 .34 ± 1 .84 4 . 53 ± 0 .3 8 WS-5 1987 4 . 06 ± 3 .50 3 . 96 ± 0 .6 3 WS-12 1986 7 .79 ± 0 .25 4 .93 ± 0 .0 7 WS-12 1987 12 .97 ± 5 .19 3 .70 ± 1 .2 1 WS-13 1986 9 .72 ± 0 4 .34 ± 0 WS-13 1987 3 . 99 ± 2 .08 4 .01 ± 0 .3 2 3-55 HDMSP00042469 All average measurements were below the recommended levels for drinking water, although an occasional individual gross alpha reading exceeds the 15 pCi/I recommended level for drinking water . The bacteriological analyses are uniformly reported at coliform counts of <2 .2 MPN total coliform per 100 ml of sample, a count common to all 99 samples taken in 1987 . Samples were collected twice monthly from two storage tanks (central storage and the westernmost tank) and from Well WS-13, whereas Wells WS-5 and WS-12 were sampled monthly . Other locations in scattered buildings were sampled once a year . From all available data, the freshwater system's quality with respect to radioactivity and bacteriological considerations is uniformly acceptable . Data on non-radioactive chemical parameters is not routinely collected, since the system does not ser4e a s a drinking water supply . Sediment sampling programs for radioactivity are conducted monthly ..'for_ selected locutions, including several which could be affected by DOE activities . These .,fpcationsti.utude mud from th e bottom of the R-2A Pond and from sediments deposited in ~he .d:rainage".ditch leading to Bell Canyon . Data for 1985 and 1986 are presented in-'T.abl~3,_16:,,::Wat€ersamples covering the same periods are also presented for comparison . kn 1,98~beta activity= 'i sediments and water for both locations was slightly higher by 3 to 7 percent . 'A'Icha.activities presented a different pattern . Both locations showed a 20-30 percent decline frorra .198557to 1986 in sediment activity, but a 35-50 percent gain in water activity . AlfJieasdrements indicated relatively low levels of gross radioactivity well below the drinking water criteria fior'_raci :±pactivity, with no serious deposition of activity in on-site o r off-site sedim.en.t :. Very fi tfe cl fit"ri rta(madioactive parameters exists for on- or off-site locations, possibly because all data on radii;activity indicate minimal likelihood of problems with off-site migration of contaminants from SSFL and/or DOE operations . Monitoring requirements imposed by the site's NPD5 permit and Proposition 65 appear to be the full extent of surface water measurements at the site . Other sampling appears to be related to special events, such as spills, leaks or the need to characterize new test solutions . 3 .3 .4 Findings and Observations 3 .3 .4 .1 Category I None . 3-56 HDMSP00042470 TABLE 3-1 6 RADIOACTIVITY IN SELECTED SEDIMENT SAMPLES SSFL - VENTURA COUNTY, CALIFORNI A Gross Radioactivity Measuremen t Locat i on Act i v i ty Un i t 1985 198 6 Pond R-2A : Sediment Water Alpha pCi/g 31 .4 ± 6 . 0 Beta pCi/g 24 .0 ± 1 .1 Alpha pCi/I 3 .07 4.18 ± Z 70 Beta pCi/I 3.49 .± 0 .76 . 3 .58•± 1 .1 4 Alpha pCilg ~ .9±6 .5 15 .4±4 . 4 Beta ;:,,C/tj': . ;• 22 .7 ± 1 .1 24 .2 ± 1 . 2 Alpha ' .pCi/l 1 .38 ± 7 .09 2 .02 ± 2 .0 8 pCi/I 2 .49 ± 0 .75 2 .60 ± 0 .5 2 0. 5 Bell Canyon Drainage Ditch : Sediment Water Beta 3-57 HDMSP00042471 3 .3 .4 .2 1 Category I I B-886 Sodium Disposal Facility Runoff . There is a potential for the release of contaminated runoff from the B-886 Sodium Disposal Facility due to inadequate control of stormwater runon and runoff . Soils within the burn pit areas of the facility are contaminated with chlorinated organics, heavy metals, and low levels of radioactivity, principally cesium-137 . Although the limited amount of testing of runoff has not indicated that elevated levels of contaminants are migrating downslope, the existing diversion structure may alfow stormwater from areas upslope from B-886 to enter and leave the area . Samplini4dorein compliance with Proposition 65 at points downslope from the B- 886 area indicated .that tPier was some transport of arsenic, chromium, and lead, albeit at low cgncent ations,(betweIEW 0 .14 and 0 .34 mg/I) . Refer to Findings 3 .2 .4 .3 and 4 .5 .2 .3 for additioriat information r . 4gardin g this problem . 3 .3 .4 .3 Category I I I None . 3 .3 .4 .4 Category I V Surface ; S1Sldter'MgnitorirA Program . The current SSFVArea IV surface water monitorin g progr m does not iiry(jde any periodic sampling ( e .g ., during rainfall events ) of runoff leavin g the site end'-entering Meier or Runkle Canyons to the north of Area IV . This could result i n ttndetect Opel releases of contaminants off-site . For example, the single attempt to collec t runoff during the Proposition 65 sampling and analysis program did indicate that asbestos contamination in surface water runoff from location RD - 4 (the area behind Building 163, the Box Shop) was as high as 225 million structures per liter, of which 165 million were chrysotile fibers . The State of California had listed a " significant risk level " for such fibers as 140 million per day when ingested as potable water . While it is unlikely that the present release could affect water supplies in the Simi Valley downslope of SSFL , the fact that the release was occurring undetected until Proposition 65 required SSFL to consider runoff sampling raises questions about the adequacy of the monitoring program . 3-58 HDMSP00042472 3 .4 Hydrogeolog v 3 .4.1 Background Environmental Information 3 .4 .1 .1 Geolog y SSFL is located in the Simi Hills, the central part of the Transverse Ranges which divides the Simi Valley to the north, from the San Fernando Valley to the south . The Simi Valley is a broad syncinal depression and the Simi Hills form the southern flank of the syncline (Dickens et al ., 1987)' ; T1ieSimi Hills are composed of two principal units (the Chatsworth Formation and Alluviurn'J af two minor geologic units (the Tertiary Martinez Formation and Topanga Formation)- .at th2 sitc,; -these four units are described from oldest to youngest as follows : Chatsworth Formation : The upper Cretaceous age-Cha#s~prorth `brma ion underlies most SSFL . .- sandstone (FaciesA) with O It is composed primarily of well-consolidate, m'assively'-bead.interbeds of siltstone and claystone (Fades. ;!The sandstt3ne facies is primarily arkosic with carbonate cement . At the site, the .bedd`u g genetal .ly dips to the northwest at approximately 20 to 30 degrees. Well . . .developed fractures and joints are visible in the outcrops . The Chatsworth Formati on weathers to form . iffs (Dickens et al ., 1987) . Marti .nsz.farmatrQi'r'. ` The,Pal' ocene Martinez Formation overlies the Chatsworth Formation f and .exposed to"t north and northwest of SSFL, and south of Burro Flats . It is composed o beddM, nat it .-sandstones and shales with a bas a l con g l omera t e . Beddin g d i ps measured .north of-55FL are approximately 30 to 35 degrees to the northwest . The Martinez Formatio n weathers to form slopes (Dickens et al ., 1987) . Topanga Formation : The Tertiary Topanga Formation, younger than the Martinez Formation, is composed of bedded marine sandstone with a basal conglomerate . It is exposed to the southeast of SSFL . Like the Martinez Formation, it also weathers to form slopes (Dickens et al ., 1987, and Dickens and Hawkins, 1986) . Alluvium : The surface drainages and Burro Flats are mantled by a thin discontinuous layer of Quaternary alluvium consisting of a mixture of unconsolidated sand, silt, and clay . Drill hole data indicate that in some areas, the alluvium may be as thick as 6 meters (20 feet) . The alluvium is underlain in some place by a zone of Chatsworth Formation which has been weathered in place (Dickens and Hawkins, 1986, and Dickens et al ., 1987) . 3-59 HDMSP00042473 There are several faults and a shear zone in the SSFL area which offset Paleocene and Upper Cretaceous rock units. One of these faults, the Burro Flats Fault, trends northwest-southeast and passes through the southwestern portion of the facility . The southwestern block of this fault appears to be down-thrown relative to the northeast block . It is not known if there has been strikeslip movement along this fault (Dickens et al ., 1987) . There appears to have been movement along a shear zone which trends northeast-southwest through the facility . The shear zone is characterized by contorted bedding and breccia . The direction of movement is not known (Dickens et al ., 1987) . There are no discussions in the hydrogeologic reports for the site concerning the capability of .-.the faults at SSFL . Other off-site faults in the area are active . The epicenter for the 1971 San•'Fernarzio earthquake, located on the San Gabriel Fault, is approximately 32 km (20 miles}' the "'le (NRC, 1977) . Fracture patterns at the facility have been mapped, and dis w pr2d p yla-., o .omF6ant trends ; north 45 degrees east and north 70 degrees west to east-west (Dickens et ,a .l ., 1987k Jointing is common, with three main orientations present, northwest-sgrltheast ;, northeast :southwest, and east-west . A subsidiary set of joints trending approximately: north- oufh s also present . Measurement of dip angles on the outcrops indicates that the northeess-soithwest'trending joints generally dip to the southeast and the northwest-southeast trending jo(Ats tend to dip to the southwest . The other joint systems tend to be vertical-'3 exhibit high angfedips (Dickens et al ., 1987) . 3 .4 .1 .2 Gro .U:titkwat r:'Red'ime,and'tls e Grocj hdwate Dcc r r, two zones at SSFL . A shallow system occurs in the alluvium and closely uriderl .ying zor gs of weathered sandstone and siltstone, and isolated shallow fracture systems . A deeper system occurs within the fractures of the Chatsworth Formation . In some parts of the facility, the two systems appear to be hydraulically connected (Dickens et al ., 1987) . These two systems are described as follows : Shallow Zone : The Shallow Zone is composed primarily of unconsolidated sand, silt, and clay which has been eroded from the surrounding Chatsworth and Martinez Formations . The weathered portion of the Chatsworth Formation and isolated shallow fracture systems in the unsaturated portion of the Chatsworth Formation are also included in this zone . The Shallow Zone is discontinuous . The shallow zone is normally saturated only during and immediately following the wet season . It may also be saturated along ephemeral drainages and in the southern part of Burro Flats (Dickens et al ., 1987) . 3-60 HDMSP00042474 Water level data from wells indicate that the surface of the saturated portion of the Shallow Zone is generally a subdued expression of the topographic surface . Groundwater occurs under unconfined conditions with the saturated . thickness ranging from less than 0 .3 meters (one foot) to as much as 3 meters (10 feet) . Water primarily moves laterally and also downward into the underlying Chatsworth Formation (Dickens et al ., 1987) . The shallow groundwater system is largely influenced by seasonal fluctuations in rainfall, and as such, gradients, flow rates, and direction are not constant throughout the year . Since information on these physical conditions is also difficult to accurately measure and'"quantify, and the shallow zone is not the dominant groundwater system at SSFL , effort fb . vestigai s. This section discusses the actual and potential sources of groundwater contamination, and the controls used by SSFL to , .irr ibit•~or reduce impacts to the groundwater quality from those sources . Although this sectir r 'focuses oriAhe sources of groundwater contamination, the Findings in Section 3 .4 .446Z"' . on'1 ie°`extent to hich these sources have actually impacted the groundwater . Additional detaif ::and frrrdulgs related to the physical characteristics of the actual and potentia l ,sou•rtes'`of rSuncitiviter contamination discussed below can be found in Sections3 .2, 3 .3, 4 .1 , and 5: Known and potential sources of groundwater contamination are described as follows : Old Sodium Burn Pit (8-886 ) - The area referred to as the Old Sodium Burn Pit or the "Burn Pit" occupies approximately 4,650 square meters (50,000 sq . ft.) on the north side of Building 886 . The facility consisted of treatment area with a concrete sump, an upper pond, a lower pond, and the nearby surrounding area which was used for lay-down or burial . It was used extensively during the 1960-1970 time period for disposal of combustible materials such as sodium, NaK, and kerosene (Olson et al ., 1987) . Investigative trenching as part of a Phase II CERCLA investigation performed by a consultant to the site, revealed soil contamination consisting of organic solvents, diesel fuel, and oil and grease , PCBs, PCTs, Terphenyls, and Biphenyls (Olson et al ., 1987) . 3-62 HDMSP00042476 •os. Flowing Well •OS-2 Flowing Will WS-7 ( 1776.51 .1 . `'i D- li .wS-SP . y 445 .4) ,' '• ; '11715.51 -,(9 HAR-22 1170BA11 / HAR- 611791 31 IHAjt:Z/ 16 12 91 s - ' AREA IV HAR-231/781 .71 . .kJ HAR-, (/66'7.3 ) NAR-19 8607 .61 • RD-11 ( 1742.6) I I • RD-7 11755.21 HAR-2511835.01 1 1 MAR - 24 (1834 .2) ' ..-HAR -16 q(182S.7 ) RD-/ (1740 8 ) 11748.1) J AAA-N 11/W.C1 ~ .910 RD-12' WS-1117 12 \11744 .6 ) f~=7 (1740 .4{• HAR-1 7 ( 1704.4 1 LEGEND • RD-1 Chatsworth Formation Well \ 110 Apparent Direction of Groundwater Flo w Fault, Fracture or Joint \Shear Zon e • WS-5 Well Identifie r (1546 . 4) Water Level Elevation , Feet MS L -1700- Contour of Equal Water Level Elevation , Feet MS L 0 2000 400 0 Scale, Feet 14 P t Source: Adapted from Dickens et al ., 198 7 GROUNDWATER CONTOURS, INFERRED FLOW DIRECfltNS , AND MAJOR STRUCTURAL DISCONTINUITIES SSFL-VENTURA COUNTY, CALIFORNI A FIGURE 3-11 There has not been a groundwater investigation performed for this facility, however, one monitoring well installed in 1985, RS - 18 located approximately 105 meters ( 350 feet) no rt heast of the facility, revealed the presence of volatile organic compounds in December 1987 (the only time the well was observed to contain water ) . compounds detected : 1,1- dichloroethane , Three of the 1,1-dichloroethylene , and trichloroethylene exceed California State Action Levels of 20 , 6, and 5 u g/l respectively . No other groundwater wells or data are available for this facility . It is likely that groundwater contamination exigtsas a result of previous disposal practices at this facility . See Findings 3 .4 .4 .3 . 2 .a and 4 .5 .2 :3 1: .a ;fo r details concerning this facility . Building 059 Area - The subterranean levels of the 059 building formerly housed tlie'SNAP Prototype Reactor , and presently contain Co-60 contaminated"sand and' 4large stainless steel duct that are in contact with groundwater that seeps i n. ti t he b ~ildirig Upon termination of operation in 1969 , pa rts of the reactor systerrtwere-removed . Subsequent decommissioning in 1978 resulted in removal of all contaminated items ex ept fo(an estimated 45,350 kg ( 50 tons) of activated sand , a 150 cm ( 60 1inch ) am'etec ''stainless steel duct, and other activate d material (Stafford, 1987) . . ., During an inspection in 1983,' r qu:n dvvater that had seeped into the building was found to be contain . red w €t eo- 60,1;$taff'ord, 1987) . Since that time , a water management program has cont t4lIed.and mrrrriiired seepage into the building through lowering groundwater levels aroun f eutding by pumping . At the same time, the water level outside the building wa s r•r aintair slightly above the level inside the building in order to cause an inward flow ' .gradient . Although sampling in 1983 did not reveal radioactive contaminants outside th e building , it is probable that the sampling program was not rigorous enough to asce rt ain if contamination existed directly below the building . There are no monitoring wells at the facility . The only source of groundwater data is the standpipe connected to the french drain system that extends around three sides of the building . The Co - 60 within the building represents a potential source of groundwater contamination in an area that is presently incompletely characterized . Although SSFL has not detected Co-60 in the french drain discharge , analysis of the standpipe discharge viater first performed in 1986 revealed volatile organic compound contamination . The California State Action Level for tetrachloroethylene , and trichloroethylene of 4, and 5 ug/l respectively have been exceeded . The source and extent of the volatile organic compound contamination are presently unknown . See Findings 3 .4 .4 .3 . 2 .a and 4 . 5 .2 .3 .1 .b . 3-64 HDMSP00042478 Well RD-7 Area - The groundwater in the area near Well RD-7 is contaminated with volatile organic compounds . The extent of the contamination is unknown and uncharacterized . The California State Action Level for trichloroethylene of 5 ug/l has been exceeded . Although there is an old landfill near Well RD-7, the area has not been investigated well enough to determine if it is the source . There is also an abandoned excavation for Building 056 nearby that could also represent a potential source for the contamination . See Finding 3 .4 .4 .3 .2 .c . Other potential sources also exist nearby in Area IV, and are discussed in Finding 4 ..5 .2 .3 . There are five areas of the site that are potential sources of groundwater contaminztion ."The areas that are potential sources of groundwater contamination are as follows : " Old Landfill - An old landfill approximately 90 meters ( 300 feet) West; of ,the -Building 056 excavation was used for temporary storage of . drum, ned, :wstef; --. and burial of other undocumented materials and spoil from the ;.BBuildhng 056.-oxcavat4on . Although Well RS-16 near this area has typically been dry , a dee:p,weW nearby; WeiL.RD- 7, has revealed groundwater contamination by volatile organic compo' vkds - Ti e . source of the contamination is unknown, and may be the landfill . See Finding 4 : .5:2 .3 . 1 :e for details concerning this area . RMDF Leach Field - An acc±dentah release of radioactively contaminated water containing principaFf S.r-90 a11tl`Y-90to the soil in and beneath a sanitary sewer leach field for the RMDF occurred sdmetime in late 1962 or early 1963 (Bradbury, 1978) . Subsequently, the area was excava. ar4d :cantaminated soil was replaced with clean soil . Contamination was trace d during the excavation, and found to extend downward into joints and fractures in the • Chatsworth Formation . The contaminated joint material was excavated as far as readil y accessible with hand-held pneumatic tools, then sealed with asphalt . Decontamination efforts stopped at that point . There is high probability that contaminants reached the groundwater through infiltration from the leach field . This groundwater in the area of this potential source of contamination has not been investigated . See Finding4 .5 .2 .3 .1 .c for details concerning this potential source of groundwater contamination . Old Conservation Yard - The area referred to as the Old Conservation Yard was used for storage of equipment and wastes. The area was cleared of materials, and regraded in the early 1980s . The storage of wastes in this area represented a potential for spills to have occurred along with subsequent groundwater contamination . No groundwater investigation has been performed in this area . See Finding 4 .5 .2 .3 .1 .d for details concerning this potential source of groundwater contamination . 3-65 HDMSP00042479 B/100 Trench - A trench located east of the B/100 Building was used for disposal of construction debris and possibly hazardous substances that represents a potential source of groundwater contamination . The trench, observed on aerial photographs, was approximately 7 .6 meters (25 feet) wide by 22 .9 meters (75 feet) long . The trench appears in aerial photos from approximately 1961 to 1967 . Several drums adjacent to the trench are visible on some of the photographs . There are no records available to the Survey concerning the operation of this disposal area , and no groundwater investigation has been performed . See Finding 4 .5 .2 .3 .1 .g for details concerning this potential source of groundwater contarn-natan . 3 .4.3 Environmental Monitoring Progra m There is no formal groundwater monitoring program on the optioned Land at SSFL . Th e Environmental Control Unit, contained within the Operation Division of . Rocketdyne, has been DOE. responsible for performing the site- wide monitoring program and inve5tugations relative to closure of approximately 10 ponds at the SSFL site < Although none of -ese ponds are in Area IV, five monitoring wells were installed in Area IV . "None5vf-t . e tnonit -ring wells are on DOE optioned land . However, some of the wells are .near facilities that nay have been impacted by DOE activities . These wells were observed Burin the'SSurvey to evaluate-construction quality . Well construction records were also reviewed .4raddition, there a four springs located off-site to the northwest . These were sampled as pa: ptf the Hydrogeologic Assessment Report (Dickens et al ., 1987) . These springs, located on . .ivate,'property` .were not accessible during the Survey, thus were not observed . Their construction~is: k;r Figure 3-12 shows the locations of the Building 059 Standpipe, wells, and springson and haar Area IV . The wells on the SSFL site observed during the Survey typically had identification signs mounted on posts adjacent to the well, or numbers inscribed in the concrete surface pad . Surface completion was either in a flush mounted valve box, or a steel protective casing for the shallow . wells, and a steel casing for the deep wells . The shallow wells were constructed of PVC casing and records indicated they were sealed with cement grout, and that no bentonite seals were used (Dickens et al ., 1987) . Deeper wells used steel casing , and were installed as an open-hole well, thus not sealed in a specifically restricted zone below the bottom of the surface casing (Dickens et al ., 1987) . The deeper wells also had dedicated centrifugal pumps installed (Dickens et al .,1987) . Problems associated with well construction are discussed in Finding 3 .4 .4 .4 .1 . 3-66 HDMSP00042480 OS-3 OS-5. OS-4 B-059 tld 0 RS-1B 1700' 1800'--- 1900 LEGEND • RD Deep Mdnitorilig. .Welt 2000 O RS/ES Shallow MoRrtb;'q-mq'* Well • OS Off-site Spring • WS Water Supply Wdl l AREA IV ■ B-059 Building B -059 Standpipe FIGURE 3-12 GROUNDWATER MONITORING LOCATIONS NEAR AREA I SSFL-VENTURA COUNTY, CALIFORNIA Sample collection was not scheduled during the field portion of the Survey, and thus was not observed . Procedures provided by the groundwater consultant for SSFL, Groundwater Resources Consultants, Inc . are presented in their 1987 Hydrogeologic Assessment Report in AppendixO (Dickens et al ., 1987) . The procedures were reviewed as part of the Survey . The procedures contain instructions on measuring water levels, purging practices, sample collection, handling, shipping, and chain-of-custody . The procedures also include sections explaining rationale for sampling location , schedules, and analytical testing to be pertormed from each sample round . The monitoring wells installed in Area IV, although some are near suspeeded°`saurces`,-6f contamination, are not sufficient in number or location to provide enough data to f lJ :y;-tharacteriie' site or facility hydrogeologic conditions, the extent of known contamirratibn' . or the-,presence of suspected contamination . There are presently three areas of known'icontami`nati-on, and four areas of suspected contamination as previously discussed in ~ectian3, ; .2 Only " .three of the five wells installed in Area IV are within the proximity of the seven`ereas'of•known:-or suspected groundwater contamination . Of the five wells, only one`i:s: :deep':enough to'provide data on the Chatsworth Formation system (Well RD-7) . The one deep w f! i .s n&t an itself, capable of providing conclusive data on gradient, inferred flow directions, and•floJWrates for the seven areas . These inadequacies in the groundwater monitortng 'program made- it difficult to reliably monitor and accurately characterize groundWatter coptami`natj.ott .(cee Finding 3 .4 .4 .3 . 11) . Groundwater< me ctoring ;VGas'previously performed in the area of the Sodium Reactor Experiment . .Three ' wells iaraing .j depth from 12 .2 meters (40 feet) to 21 .4 meters (70 feet) in depth were installed there" r 1971 or 1972 (Breeze , 1988) . The wells consisted of 7 .5 cm (3 inch) diameter perforated casing (Heine, 1973) . Samples collected from the wells were typically analyzed for alpha and lieta radioactivity, and on at least one occasion for water quality . Typical values reported for radioactivity were approximately 10-7 uCi/ml . Gamma spectroscopy analysis indicated that Cs-137 was the principal emitter present (Heine , 1974) . Monitoring was perfomred from 1973 through 1981 . A search for the wells during the Survey was performed, but none were found . SSFL personnel believed that well No . 1 was destroyed during cleanup of the RMDF Leach Field, but the other wells still existed ( Breeze , 1988) . These wells are not being used in the current groundwater monitoring program, and no record of abandonment was furnished by SSFL (see Finding 3 .4 .4 .4 .2) . 3-68 HDMSP00042482 3 .4 .4 Findings and Observations 3 .4 .4 .1 Category I None . 3 .4 .4 .2 Category II None . 3 .4 .4 .3 1. Category I I I The groundwater monitoring program is inadequate at known or.:, W`s p',Rcte*d"'- sources o f contamination . The groundwater monitoring prograrai '.as . ; number. of inadequacies that e. : make it difficult to reliably monitor or accurelyI aracteriie'gFoundwater contamination . The Survey identified the following def'rcencis s Ks a . Inadequate characterization of site.:hydrogeology (i .e ., the vertical and horizontal flo w rates and directi :tin of-groundwater is not well defined ) at the known or suspected areas of contaminated•groundwater,,--The presence of a groundwater divide in Area IV is apparent, bu.L s t catty ;r tativ~,to`the individual known or suspected sources of contamination has 'rnGG be#b detei'mrned• In addition, only one deep well (Well RD-7) exists that can be use d for4 vestigating the physical characteristics of the Chatswo rth Formation in Area IV . One well, ;s-not capable of providing comprehensive data on horizontal groundwater flo w rates and groundwater gradients at all of the known or suspected areas of contamination . b . Insufficient number of wells to characterize the actual and potential sources of groundwater contamination . The five monitoring wells (one deep, four shallow) installed in Area IV were not located with respect to the seven known or suspected areas of groundwater contamination . Although three of the wells and the standpipe at Building B 059 have indicated groundwater contamination, characterizations at each of the areas is not possible with the one or two wells at the known areas of contamination and none at the suspected sites . The groundwater monitoring locations near each known source of groundwater contamination are : Old Sodium Burn Pit, RS-18 ; Well RD-7 Area, Wells RD-7 and RS-16; and Building B 059, B 059 Standpipe . There are no wells near any of the four potential areas of groundwater contamination . 3-69 HDMSP00042483 c . Off-site groundwater contamination may exist, but be undetected at the off-site sampling locations . The four off-site monitoring locations northwest of Area IV consist of artesian springs or wells of unknown construction . These wells, although convenient, were not designed, constructed, or located to be monitoring wells . Their location, unknown depth, and probable lack of proper construction materials and methods makes them indefensible as adequate sampling points . 2. Groundwater contamination . Based on the available groundwater monitoring data there`are at least three areas of groundwater contamination in Area IV . These areas appr6ar t04! . b e related to past DOE activities . The areas are discussed below . a . Old Sodium Burn Pit The groundwater near the Old Sodium:Burn Pit' ppeatvto be contaminated with volatile organic compounds . Well RS 4 8, (which ; has . been dry at the time of qua rt erly sampling attempts until December. 1 9,87) located approximately 105 meters ( 350 feet ) no rtheast of the fecility: .Kas revealed. shallow groundwater to be contaminated by chloroform , 7 ugl1 1 .,2 =dchloroethane; 24 jig/I ; 1,1- dichloroethylene , 33 jig/I ; trans-1,2-dichloroethj .''ene ; :5 :1i7?Jg t . 1,'1,1-trichloroethane, 20 jig/I ; and trichloroethylene, 660 ug/I (GWRC,`198g} ;-. ., No analyses for radioactivity were performed . The Old Sodiurrr-furn•:Pit is suspected,-*by the Survey team to be the source . Three of the compound's detected 9;,1 .ditfiioroethane, 1,1-dichloroethylene, and trichloroethylene exceej~.Zalit~ot~r i.a Stata,Action Levels of 20, 6, and 5 jig/1 respectively . This 3rea=rrfxtrred to as the Old Sodium Burn Pit or the "Burn Pit" occupies approximately 4,656i►quare meters (50,000 sq . ft .) on the north side of Building 886 . The facility consisted of a treatment area with a concrete sump, an upper pond, a lower pond, and the nearby surrounding area which was used for lay-down or burial . It was used extensively durin g the 1960 - 1970 time period for disposal of combustible materials such as sodium , NaK, and kerosene ( Olson et al ., 1987) . Investigative trenching as pa rt of a Phase II CERCLA investigation performed by a consultant to the site , revealed soil contamination consisting of organic solvents , . diesel fuel , and oil and grease , PCBs , PCTs, Terphenyls, and Biphenyls ( Olson et al ., 1987 ) . See Finding 4.5 .2 .3 .1 .a . b . Well RD-7 Area - The groundwater in the vicinity of Well RD-7 is contaminated with volatile organic compounds . Analyses of groundwater samples collected from Well RD-7 revealed contamination from trans-1,2-dichloroethylene, 3 jig/I ; trichloroethylene, 130 ug/I (maximum ) ; and toluene , 13 jig/1 (maximum ) ( Dickens et at ., 1987 ) . No analyse s 3-70 HDMSP00042484 for radioactivity have been performed . The California State Action Level for trichloroethylene of 5 ug/ I has been exceeded . The source of the groundwater contamination has not been investigated . Although a shallow well nearby, Well RS - 16, has shown 1 ug/I of toluene on only one occasion , there is not conclusive physical or contaminant data to suggest a relationship between these wells or the old landfill located adjacent to them . Other nearby potential sources exist that ar e discussed in Finding 4 . 5 .2 .3 .1 . c . Building 059 Standpipe Area - The groundwater in the vicinity of the' ..8•uilcing 0~3`v .s contaminated with volatile organic compounds . Analyses of: groundwater samples` collected from the standpipe indicates the contamiiiarts are-. pr1rfitipall y tetrachloroethylene, 540 ug/I (maximum) ; trichloroethylene, 1'9. fig/f(maximum) ; and trans- l,2-dichloroethylene, 68 ug/I (maximum) (A taIyticai . Chemistry [SSFL], Various Dates) . Radioactivity has not been detected at';levels ' .consideced above background for the groundwater . The Californr.a State. Actiorr Levi for tetrachloroethylene, and trichloroethylene of 4, and 54g/l respectiie(y, have been exceeded . The detection of tetrachloroethylene,i peculiar to this ro?eetion, as it does not occur at other monitoring wells either in,A i a Ill: . The .; ..i&cce'of` th'e vot,dtil~ `organic contamination is unknown for this area, and has not been i :vestigaaed -' See Finding 4 .5 .2 .3 . b for additional information on potential sources foi s fac(~ty . 3 .4:4:4 1. Category I V Monitoring well construction inadequacies . There are inadequacies in construction of the monitoring wells that may result in questionable data for the following reasons : a . Wells installed in shallow soil zones are not sealed with bentonite seals as per industry accepted practice and Federal guidelines . The lack of a water- tight seal may allow surface runoff to enter the well by flowing down along the casing and into the well screen and filter area . A consequence of this would be possible cross contamination of the groundwater being sampled , pa rt icularly for these shallow wells that reflect seasonal water table changes thus occasionally yield only small volumes of water . 3-71 HDMSP00042485 b . Deep wells that monitor the Chatswo rth Formation use dedicated centrifugal vane type pumps that can cause off-gassing of the volatile organic compounds dissolved in the water . The consequence of using this type of pump is that concentrations analyzed for these analytes may have been reduced during the sampling process . Off- gassing becomes more likely when groundwater is subjected to large temperature and/or pressure changes such as from deep water levels at the site . 2. Lack of well abandonment . Old groundwater monitoring wells which are not going to .";be integrated into the SSFL groundwater monitoring program may provide a direct c6n.duit:;£or accidental or intentional contamination of groundwater . Three wells in the vi issued Detember 13, 1982 (rescinded October S, 1987, but still serving as guidance), and DO>< Ord: i 2O titled Radioactive Waste Management, issued December 6, 1984, are the 4rincipal DOE QFders used in evaluating waste management at DOE sites . The Resource Conservation and Recovery Act (RCRA) of 1976, the 1984 RCRA amendments, and associated regulations issued by the U .S . Environmental Protection Agency (EPA) establish the standards used by the Survey for evaluating hazardous and mixed waste handling facilities . California hazardous waste regulations are similar to those of EPA . However, California is more stringent in areas of waste characterization, waste listing, and regulation of regulated substances tanks . At the time of the Survey, California did not have RCRA primacy . Solid waste regulations of California regulate solid waste facilities of SSFL . "Good Management" techniques, which are practices not specifically required by regulation or DOE orders, are also used by the Survey, when appropriate . 4-1 HDMSP00042487 4 .1 .1 General Description of Pollution Sources and Control s 4 .1 .1 .1 Hazardous Waste Current DOE activities at the SSFL consist of large-scale experiments related to energy technology . Relatively small quantities of hazardous waste are generated . These wastes consist principally of lubricating oils, ethanol, alkali metals (Na, NaK, Li), and small quantities of laboratory chemicals . Waste oils are a California-listed hazardous waste, and alkali metals are hazardous due to thei r reactive prope rt ies . Table 4-1 describes the wastes generated from DOE activities at SSPL A4kali metals are generated from tests involving experimental equipment that would be '.us# .}n sodiu m coo li ng of nuclear reactors . SSFL does not dispose of any hazardous wastes on-site . Storage'-and treatrnen . of reactive alkali metals takes place on-site at two locations . Storage ofehazardgs,wastes other than reactive alkali metals takes place at the Area II National Aeronauttcs ari d.Space -Adam tstration (NASA) hazardou s waste storage facility . B-029 Reactive Metal Storage , . Reactive metals, ind i'ng sodiurift .gt#ssi'um, sodium-potassium, zirconium hydride, and lithium metal, are star `tc B=Q2 At the tithe of the Survey, thirty-five 55-gallon drums of material were in storage . The aria is a ,perrnitted, RCRA, long-term storage area and meets RCRA technical requirements ..f,qr stor e areas . Twenty cold traps containing reactive sodium metal are in storage outside B-029 . These cold traps are inside the fenced area and lie along the path leading to B-029 . The area where the traps are stored is not part of the permitted RCRA storage area that is described in RCRA permit submittals . SSFL intends to cut the traps and remove the sodium . At the time of the Survey, SSFL was encountering difficulty in cutting the traps to gain access to the sodium . Torches were ineffective, since the sodium contained within the traps acted as a heat sink . Because normal saws were not able to cut the traps, SSFL was experimenting with various techniques to cut the traps . Although the traps are in an unpermitted storage area , releases of sodium are unlikely due to the integrity of the traps(see Finding 4 .1 .2 .4 .2) . 4-2 HDMSP00042488 I TABLE 4- 1 WASTE STREAM S SSFL - VENTURA COUNTY, CALIFORNI A Composition Annual Generatio n Rate Laboratory Oil Waste Laboratory Oils 1,000 pounds Off-site Recycl e Ethanol/Dowanol Sodium/Water 16, 000 gallons Off-site Recycl e Sodium Sodium Metal Lubricating Oils Waste Cutting Oil Asbestos Building Materials -- Waste 1,620 gallons 660 gallons T .S .D . Method s On -sit,e-1r atmect. -: 25 cubicyardi •,Off-siteLaiid$iiJ. Source : Lewis, 1987 . 4-3 HDMSP00042489 B-133 Sodium Burn Facilit y Sodium metal is treated at the B-133 Sodium Burn Facility, which is also a permitted RCRA facility . The treatment takes place by oxidizing the sodium in an enclosed burn pan to produce sodium oxide . The sodium oxide fumes are absorbed by a liquid scrubbing system to produce sodium hydroxide . This sodium hydroxide is used by other Rockwell facilities as a treatment chemical . At the time of the Survey, SSFL was developing techniques for treating lithium hydride at the B-133 facility . Drainage from the scrubber contained sodium hydroxide, was conducted to an underground st0C ge tank (UST) in a pit . In early 1987, when the UST was being replaced, it was found that •the soil in the pit was highly akaline . The alkalinity was attributed to leakage containing . sodiu'rri;hyd Qxide (see Finding 4 .1 .2 .3 .1) . The burn facility was shut down at that time . SSFL,'intends tti- remove th e contaminated soil, line the pit with concrete, and install a tank for-;collectinghe.sodiutn hydroxid e effluents from the scrubber- Area II Hazardous Waste Storage Facilit y Nonreactive hazardous wastes, .generated byDOE ;ctivities at SSFL are either stored at the Area II hazardous waste storage facility . _or directly roved from the point of generation to an off-sit e facility (such as ail) . ~ }i s storage fbtUtty is in the NASA area, which is also managed by Rockwell . It was estimated -b. i RockwalT'that*,ap'roximately 10 percent of the wastes stored at Area II are DOE waste, with the remainirg'9Gpercent originating from NASA activities . Operational and permitting activitiesi pert nin tpthe Area II hazardous waste storage area are the responsibility of Rockwell under, its contrkt with NASA . The Area II hazardous waste storage facility is not roofed and is exposed to the elements . The storage area did not have sufficient diked and paved storage area to allow proper segregation of incompatible wastes and sufficient aisle space for unrestricted access to containers . Site personnel reported that equipment used to move containers of hazardous waste was not adequate and that containers had been dropped while being moved . It was also reported that the dike was not impervious, as indicated by leakage of accumulated precipitation from some dikes . The surface area where drums are staged prior to movement to the proper storage compartment is not paved . The lack of a roof has lead to swelling of drums containing volatile organic wastes as a result of heating due to exposure . Site personnel stated that NOVs (Notices of Violation) regarding secondary containment integrity and storage capacity have been received from EPA and the State Department of Health Services . Rockwell has requested funding from NASA to build a new hazardous waste storage area (see Finding 4 .1 .2 .4 .3) . 4-4 HDMSP00042490 Hazardous Waste Decontamination Bowl Area . The Bowl Area was the site of a pilot test for the gasification of coal . This experiment has been terminated . All liquid wastes and readily accessible solid wastes have been removed . However, the process equipment still contains various hazardous wastes, including char oil, tars, and light oils . Closure of the Bowl Area (removal of hazardous wastes and decontamination) has not been initiated, as discussed in the Closure Plan (see Finding 4 .1 .2 .4 .4) . Table 4-2 describes the waste s remaining in the process equipment. This is a DOE - Morgantown program . B-005 Coal Gasificatio n An experimental'coal gasification facility at B-005 is no longer in operation: This process resulted in the generation of "green liquor' wastewater, which contained gigao16, sulfur compounds, and ash . At one time, approximately 80,000 gallons of green Tiquor'weeO :rn sfoca, e . The liquid portion was removed and taken to an off-site hazardous waste faali.ty. tt.iietanj s in which the liquor were stored still contain residual "heels" of 'green lieiutfr" so ds Cfther process residuals may still be in process lines . DOE-Morgantown is negotiating 'a co . ...,Oct to Rockwell for the demolition of the experimental coal-gasific. tivn facility . All process equipment will be decontaminated and waste residues removed as• art of the derolitign'project . El Segundo:.gir F$_uidized=gei_Fombustion (AFBC) Facility Rpikw.ell opere#es a DOE-owned, AFBC test facility at its El Segundo Plant in Los Angeles County . Fluidized-Bed Combustion is used to reduce sulfur dioxide and nitrogen oxide emissions . The facility is used to test heat exchangers . Approximately 1 .5 barrels of ash are produced during each hour or operation . Fly ash is a California state listed hazardous waste . The mixture of spent bed, ash, and baghouse fly ash is considered a hazardous waste . The ash was sent for final disposal at the time of the Survey to a facility at Casmalia, California . Disposal at this facility may not be in compliance with DOE's policy regarding off-site disposal of hazardous wastes . This policy limits off-site disposal of nonradioactive and CERCLA wastes to facilities identified by EPA or by state regulation agencies as suitable for treatment, storage, or disposal of wastes (Walker, 1986) . In 1986, the Casmalia facility was not eligible for disposal of such wastes (Davis, 1986) . 4-5 HDMSP00042491 TABLE 4-2 BOWL AREA PROCESS EQUIPMENT WASTE - DOE/MORGANTOWN SSFL - VENTURA COUNTY , CALIFORNI A Waste Quantity Item Remark s Contents Liquid Soli d (gallons ) 1 . Heavy oil flash tank Solid, heavy oil, tar 2 . Heavy oil separator and accumulato r Solid, heavy oil, tar 3 . Interconnecting piping to 1and 2 Solid, heavy oil, tar 4 . Heavy oil condenser Traces of tar 5 . Reactor pressure shell Char-water wash 6 . Reactor pressure shell quench Char-water wash -- -- 113 drop box Hazardous wzisie- :sCr4p 1/3 drop box Hazardous waste - scrap` 1/3 drop bok'= " Hazardous wash; scra p 1 /2'drop box,, Haz rdous waste - scra p :.'°•~00 1/3°lr pbox Hazardous waste - scra p '260 •}13 drop box Hazardous waste -scra p Char-water wastr . •'"200 1 /3 drop box Hazardous waste - scra p 8 . Cyclone 1 and 2, Char-water vyash 200 1 drop box Hazardous waste - scra p 9 . High-pressure coal N. der• (cylindriealtartl,5 feet x 20 feat#tigh) Rinse tank out, coal dust, pijverized-clean with fir e 'hose 50 0 1,0,:. • "Outlet froth t cyc'Toss Will contain wet black oils 1/2 drop box Hazardous waste - scra p 1 1 . , Light oil condenser Traces of oil and char 1/2 drop box Hazardous waste -scra p 12 . 'Beneath light oil condenser is light oil separator and accumulato r Will contain light oils and cha r 1/2 drop box Hazardous waste - scra p 13 . Light oil flash drum and piping (water jacketed) Will contain light oils and char (small quantity ) 112 drop box Hazardous waste - scra p 14 . From light oil condenser is a line, goes to BTX adsorbe r tank Inspect and flush -- Hazardous liquid wast e pipin g 7_ Reactor pressure shell char receive r .pipe to top-of lig4.61 condense r -- 200 4-6 HDMSP00042492 TABLE 4- 2 BOWL AREA PROCESS EQUIPMENT WASTE - DOE/MORGANTOWN SSFL - VENTURA COUNTY, CALIFORNI A PAGE TWO Waste Quantit y Item Remark s Contents Liquid Soli d (gallons ) 500 15 . BTX adsorber to BTX condenser and collector Inspect and flush 1 6 . Sodium hydroxide scrubber tank (6 feet x 25 feet, full of SS packing), pump, too Traces of caustic soda (flush ) 17 . Low-pressure char receiver Contains some char (flush) -- Hazardous lioo.WZtv ,: : •`<. H 2,000 : ~aiardous liquid wast e 500 tank nextto VTS II stan d `' (12 feet x 16 feet) 18 . Cyclone/char receiver - Contains char-water wash :: ; '. x'00 r Hazardous liquid waste (18 inches x 12 feet ) 19 . Cyclone 2 char receiver Contains a litt(e tar akd.*. .cha r ' ;•-500 1 drop box Hazardous waste - scra p 1/2 drop box Hazardous waste 1/2 drop box Hazardous waste - scra p 20 . Dust collector % Check bags, etc . (flush) 21 . Low-pressure light' &tank.. Light tI4 .0f .d`maybe char 22 . 18 inch it .8,footvertical fenk (high suneY '.Cbal and char dust -flush out 500 Hazardous liquid wast e Contains coal dust - flush 500 Hazardous liquid wast e Low pressure coaI'hoper 100 below first,*dk k Tars, coal -- 1/2 drop box Hazardous waste - scra p 25 . Miscellaneous piping (approximately 200 feet ) Tars, light oils, char - 1 drop box Hazardous waste - scra p 26 . Tank Contains asbestos insulatio n -- 15 ft3 Hazardous wast e 24 :. > VTS I tank, glass tank, and test Fardware Source : Schmidt, 1987 . 4-7 HDMSP00042493 Underground Storage Tanks - Regulated Substance s Section 280 of RCRA regulations required the registration of all underground storage tanks (USTs) containing regulated substances such as gasoline, oil, and chemicals . California law and regulations required leak and/or integrity testing of all USTs . SSFL had 12 USTs at one time . With the advent of new regulatory requirements on the state and Federal level, SSFL has phased out the use of USTs for regulated substances . At the time of the Survey, all USTs containing regulated substances had been taken out of service and all but two had been removed . The final two were scheduled for removal: RCRA Permit Statu s Rockwell International Energy Systems Group was issued a final Hazardous "Waste Facalitie-P'ermit dated February 14, 1984, for SSFL by California . Hazardous waste opirationsdescribed rh the permit included storage in containers and treatment involving bwrni'ngpf sodium metal wastes . The permit requires conformance with conditions described in'[he Operati nal' Pla X submitted to the state by SSFL , which included a closure plan . Treatmep' t .and rage areas.eiescribed in the Closure Plan are Building 029 (Reactive Metal Storage ), and.the Build-Ldg U3 Sutiip ( Sodium Burn Facility) . 4.1 .1 .2 Radioactive Wastes DOE Orders Z `'2%clefi y+ es'rad oacti*ie waste as "solid or fluid materials of no value containing radioactivi'tX, discarded : a-t ms' such as clothing , containers , equipment , rubble, residues or soils . contarninatei 'wiih .r dioactivity, or soils, rubble, . equipment or other items containing induced radioactivity suckrthat the levels exceed safe levels for unconditional release . " Radioactive waste at SSFL consists of both high-activity and low - level wastes . These radioactive wastes are composed of sections of irradiated cladding removed during decladding of reactor fuel elements ; solidified liquid generated during irradiated-fuel-recovery cleaning operations ; building rubble consisting of wood , steel, plaster , plastic, glass , concrete , dirt, etc ., generated during decontamination and decommissioning operations ; and contaminated equipment . High-activity wastes generally contain activation products, primarily Co-60 plus MFP from fuel contact . Process operations generate low-level waste contaminated with uranium, thorium, or plutonium . A small quantity of by-product wastes is generated from research programs . Drumload quantities of TRU wastes are generated during some building cleanup operations. The generation of both high activity and low-level waste depends upon project activity . Highactivity wastes are usually generated only during fuel-decladding operations . Low-level wastes are 4-8 HDMSP00042494 generated from decladding operations and decontamination and decommissioning projects . In FY 1988, approximately 260 cubic feet of high-activity wastes were projected to be generated (Schaubert, 1987) . Quarterly shipment of low-level radioactive waste ranges in quantity from 3,000 to 9,000 cubic feet per quarter . Solid wastes from decladding of spent reactor fuel are sent in sealed drums to the DOE-owned facility for handling and shipment for disposal . The following is a description of those activities generating radioactive wastes and the facilities used to handle radioactive wastes . Sodium Burn Pi t ~ The Sodium Burn Pit was used during the 1960-1970 period for disposal o "corbustable mRaterials, including NaK and kerosene from several programs relating to sodium rea :ctors• .and'component testing of sodium reactors . The area consisted of a concrete' pad next to, .a-.concrete water pool, :an area adjacent to and west of the upper and lower pond areas both downslope from the .po ', .1 ;,and 17. upper pond area used for storage and burial of mater a)s . 'AERCI ;4, Phase II, site characterization has been prepared (see Section 4 .5 .1 for Timbre detaifs)_ tit":has been estimated that 28,640 cubic feet of radioactive waste, 14,400 cubic feet of che'ical'(hazardous waste), and 11,025 cubic feet of mixed hazardous waste will be generated by cleanup ;;c ivities (Stafford, 1987) . • : .• ham. , Bu'rldii~g'A59`(S IAA Gfeund Prototype Test Facility) is no longer in service . However, the vacuum vessel ahd associated structures are highly contaminated with induced activity . The pipe chase room is filled with activated sand . During routine yearly surveillance it was found that 30,000 gallons of groundwater had leaked into the room and became radioactively contaminated . SSFL installed an ion-exchange column to decontaminate the water . Currently groundwater is being pumped from outside the building to maintain a low-head sufficient to minimize inflow but prevent outflow from the pipe chase room . SSFL intends to remove the sand from the room and seal the walls to prevent groundwater infiltration into the room . The sand will be handled as radioactive waste . Sections 3 .2 .1, and 4 .5 .1 have additional discussions on Building 059 . Building 020 - Hot Cel l The Rockwell International Hot Laboratory (RIHL) operations are carried out in Building 020 . These activities consist of the examination of irradiated reactor fuel and the preparation of irradiated fue l 4-9 HDMSP00042495 for eventual reprocessing by removal of the metal cladding and thermal bonding material , cleaning and repackaging of the fuel slugs , and shipment of the fuel for reprocessing . Radioactively contaminated liquid wastes are collected in a 3,000-gallon waste tank in the Holdup Tank building . Most highly contaminated liquid wastes would be absorbed or solidified in the cells at the time of generation . Thus, most of the tank ' s contents would consist of water used during contamination . A weir box collects large pa rt icles prior to their entering the holdup tank . In Cell I, highly acidic and basic solutions are used . Coarse pa rt icles from this cell are separated in a 5-gallon tank prior to release to the holdup tank . All liquid wastes from the holdup tank are serf `to the RMDF ( Radioactive Materials Disposal Facility ) for solidification, storage , and:. .packaging :for shipment for disposal at off-site facdlitia c At the time of the Survey, the Hot Lab was inactive and decorttaminatiorr :w,as . beiftg planned . Decontamination was to take place in such a manner that the f ciEity°:couldbe reactivated e, . . Surface contamination will be removed by techniques such axelec1ropoli<~hing'of internal surfaces of pipes to allow equipment to be decontaminated but still'left :i:r pl.a4,fdr poo-ible future use . Radioactive Materials Disposal Facility (RMDF)'•_ . Handling of both higactivity and, lgyw4,ve1 radioactive wastes and materials, including treatment and storage,4akpla4te1 the RMDF*'The RMDF consists of a complex of buildings, includin g Bu}SJ`ng`` '(k1, Radioactive Waste Processin and P 9 ac aging k , and Equipmen t Decof1temi nation . Building 022, Radioactive Material Storage Vault . . • Building 034, Administration and Engineering Offices . • Building 044, Health Physics Services . • Building 075, Packaged Radioactive Waste Ready for Off-site Shipment . • Building 621, Radioactive Source Storage . • Building 665, Emergency Supplier Storage. 4-10 HDMSP00042496 • Building 068, Open, Covered Building for Temporary Storage of Chemicals and Equipment . • Building 658, Hardened Security Post . • RMDF Drainage Pond . These buildings are all within a fenced and secured area . Waste treatment at the RMDF consisting of solidification of liquid radioactive wastes 'en d evaporation of low- level liquid radioactive waste takes place in B-021 . Evappratior}.` ,f.11 id wastes ' takes place in a hooded rectangular tank ( 4 feet by 6 feet by 1 foot ) using an electric immersion system operating at 180 ° F . Vapors are passed through a HEPA,:fitter and'ekhausted through a 130-foot stack. Liquid wastes evaporated are collected from '$Sf,L and: stored in an 8 , 000-gallon tank at the RMDF and fed from the tank into the evaporator :. The=:evaportior is capable of processing 2,000 gallons per week . However , a typical vve ekly pr gcessi rlg.loac{ might be a few hundred gallons ; actual loads would depend on project acfw ty . irgh- activity wastes from the B - 020 Hot Lab are not treated . Floor drains in B- 021 lead into a 204-gallon, double lined with leak detection UST installe d in 1987 . Sludge frornth :evapdctor is pgriotiically removed and dried in a pail on a hot plate . The pail is then crushed arlaced=in' 5-gallon drum for shipment to an off-site radioactive waste disposal 4, dried sludge shipped in each pail is determined by the radioactivity content facil'i1:y, ';Th,~ . o .4 of'ttie: Sludge .'"-- ;Based on their knowledge of the wastes evaporated, site personnel said that the sludge would not contain metals (hence it is not a RCRA or mixed waste) . In 1987, thirty-eight 5-gallon and 10-gallon pails of dried sludge were generated . However , formal procedures are not in place to determine whether evaporator sludge should be tested for hazardous characteristics if the influent to the evaporator changes (see Finding 4 .1 .2 .4 .1) . High-activity materials such as irradiated fuel elements and high-activity waste resulting from dissections of irradiated fuel and reactor components at the Hot Lab (B-020) are stored in the seven below-grade vaults at B-022 . These below-grade vaults have floor plugs constructed of magnetite concrete and are fitted with steel support racks to hold canisters containing fuel elements or highactivity waste . 4-11 HDMSP00042497 Low-level waste and equipment are stored in B-075 and B-621 . The backwall of B-075 is lead-lined on the side facing the site boundary to reduce off-site direct radiation . At the time of the Survey, 11 drums containing Transuranic (TRU) wastes were in storage . All runoff from the RMDF is directed toward the RMDF pond . This pond is 20 feet by 30 feet by 5 feet deep , is fenced and has a radiation monitor, and pumps with water level controls . The RMDF pond is sealed with coated asphalt to prevent seepage . Sloping of the pavement around B-021, B-022, B-655 , B-075 , and B-621 prevents water from running into these buildings . Collected runoff from.-the RMDF pond is discharged to su rface drainage unless the - radiation monitor alarms ( see Section. 33 . 2 for turther details) . TRU Waste s TRU wastes are not routinely generated at SSFL . Those wastes ti" at ,are' generated usually will result from cleanup activities . This would include the 11;id.-rurris:`of TRd wastes in storage at B-075, from B-055 ( Plutonium Facility) . In the future , 1-1 lrum.s TRU *astas may be generated from cleanup activities at the B -020 Hot Cell . TRU wastes arespackaged for shipment to off-site facilities at the RMDF, with interim storage also-taking place.at the, RMDF . Mixed Wastes Mixed wastes (radibactive 'aru ' hazardous ) are not routinely generated at SSFL . In FY 1988 , 1 liter of radaoactively-gontanlf nate cl mercury and 5 cubic inches of beryllium oxide were in storage awaiting dasposat ( Schaul~e rt, 1987) . 4 .1 .2' . - Findings and Observations 4 .1 .2 .1 Category I None . 4.1 .2 .2 Category II None . 4-12 HDMSP00042498 4 .1 .2 .3 1. Category I I I Sodium Burn Facility Sump . Releases of a caustic solution from the scrubber in the sump at the B-133 Sodium Burn Facility have contaminated the soil . The sodium burn facility is .a permitted hazardous waste facility . The facility contains a tank that served as a reservoir for alkali metal hydroxide solutions from the scrubber of emissions from the burn-pan . During installation of a new tank, soil samples collected from beneath the old tank revealed high pH levels in the soil . Plans have been formulated for the removal of the contaminated soil in accordance vrtit h RCRA requirements . The sump will be rebuilt and a new tank installed with seCorA#r y containment . 4 .1 .2 .4 1 Category I V Waste Characterization Procedures . Formal proceckires..ar,' :nQt"in,place :to determine whether evaporator sludge should be tested for heiardc s charactertssics if the influent to the evaporator changes . Currently, influtnt_ : .to. fie evaporator consists of decontamination solutions from the Hot Cell (when operatrr g) .ard--ofradioactively contaminated groundwater infiltrating into the B-9.59 pipe chase .roon , RMDF personnel have decided not . to test evaporator sludge fir ha'zrdous characteristics based on their judgment that the processes generating thjsadioactive .wastewaters, which are evaporated, do not generate hazardous constixri Howver, if. Characteristics of the radioactive wastewaters differed in the future frofi.tbee>ii3ting streams, or if the existing waste stream characteristic changed due to process changs•,the'=presence of hazardous constituents could be undetected- The slurry would Eiecome t a'zzardous (hence a mixed waste) and thus inappropriately disposed of in a facility not suited for mixed waste disposal . 2. B-029 Cold Trap Storage . Cold traps containing sodium metal, which is hazardous because of the reactivity of sodium metal, are being stored in a non-permitted hazardous waste storage area . The traps are stored outside B-029, which is the RCRA-permitted reactive metals storage area . The sodium metal is contained and is not likely to be released to the environment . However, storage outside the permitted hazardous waste storage area is a technical violation of RCRA regulations . The outdoor storage is expected to take place only until sawing techniques are developed so as to cut the traps and allow the reactive sodium metals to be removed and/or treated . 4-13 HDMSP00042499 3. Area II Hazardous Waste Storage . Inadequacies in the Area II hazardous waste storage facility may result in the improper storage or release of DOE - generated hazardous wastes . The Area II hazardous waste storage facility is owned by NASA and is operated by Rockwell principally for NASA wastes . Approximately 10 percent of the wastes in storage at one time may consist of DOE wastes . The hazardous waste storage facility does not contain sufficient impervious paved area with impervious dikes to allow proper segregation of incompatible wastes or adequate aisle spacing for unimpeded access to containers for inspection and movement . Waste containers are stored on unpaved surfaces . According to site personnel, the dike5in certain areas may not be impervious, as indicated by leakage of accumulated ~i.rall . Equipment used by site personnel for container movement is not adequate .-and;'bi~--occassolI, waste containers have been dropped during movement . Since the . storag: _.4 1ity is not` roofed, these waste containers can be heated up by solar radiation :'Faccility person"net" have reported that drums of solvents have bulged as a result of heating by ttie'sun . Srte- personnel said that regulatory agency personnel have noted these .r)efisiencies during inspections . Rockwell has requested funding from NASAao build a larger' hapardous waste storage area and to utilize the existing site, after amodific ion,' .for ttie initial storage and staging of hazardous waste containers . 4. - ° Facility Closure . Closure _6f '-the Bowl Argo and the Process Demonstration Unit (PDU) facility (removal of h `rdous wastes:_aod:decontamination) has not been initiated according to the closura?p1aft in[+e-operaionS'-plan of the hazardous waste permit . The closure plan in the RCRA'per t give schedule for closure of buildings and test facilities, beginning with submi n of=t xe closure plan to the permitting agency . The facilities in the Bowl Area an d the PDLP.acility have been closed for more than 90 days . All liquid wastes and readil y ' .accessible solid wastes have been removed . However , there is no evidence that a closure plan - has been prepared and final closure initiated . 4-14 HDMSP00042500 4 .2 Toxic and Chemical Material s 4.2.1 Toxic Substance Management The management of toxic substances associated with DOE activities at the Santa Susana Field Laboratory (SSFL) was reviewed to assess compliance with existing Federal and state regulations, DOE Orders, and good industrial practices . The Survey evaluated the use, handling, and disposal of bulk chemicals, industrial solvents, liquid fuels, polychlorinated biphenyls (PCBs), pesticides,4n d asoestos . The Rocketdyne Division has established programs to meet its responsibilities to errtpi'pykes and to protect the environment . The Health, Safety and Environment (HS&5) ;Departr %ent'`fra's the responsibility for a major part of this program . HS&E ensures tha .employe4es .handlirtg hazardous materials are provided the necessary information and, trairyng, .to .allow•. working with these substances in a safe manner . The following are thre',maj r.. fea3ures`0.# ; he hazard communication '' . ; . program : • Evaluating the hazards of materials 'used in the workplace and communicating t o management i~nd .users any new data . on materials in use at the site . • Comdi t. ngz:o'r :erranging for employee training on the use, handling, and storage of i,, ardous matgir.rais'in their work area . Coming and maintaining an inventory list of hazardous materials at SSFL and updating this inventory as required . • Maintaining a file of Material Safety Data Sheets (MSDS) for all hazardous materials . • Providing information on labeling of hazardous materials and furnishing the user with appropriate labels . • Reviewing all purchasing requisitions for hazardous substances, providing management and requisitioner with toxicity information, and recommending whether to obtain the material for use at SSFL . 4-15 HDMSP00042501 The HS&E Department has more than 4,500 MSDS on file with a computer-based index for rapid retrieval of information . This Department also provides assistance on regulations for transportation of the materials and proper storage . Other departments share in the responsibility for proper hazardous material management . For example , the Environmental Control Unit (ECU ) conducts a compliance audit on a monthly basis . The substances subject to survey and audit include chemicals , fuels, gases , products , materials in process, or waste substances. Any discrepancies observed during an audit are repo rted to the pe rt im.nt operating depa rt ment management, and a work order is initiated to correct the problem-' : A letter repo rt of all deficiencies observed is also sent to the specific area management : follow=:u p inspections are conducted at the next audit period . ETEC Procedure No . 4-05 delineates the criteria for the procurement, transportation, storage, and use of hazardous materials (ETEC, 1987) . The procedure 'outfines~ the responsibilities of HS&E, Industrial Security, F&IE (Environmental Control kJnit),Prote . ive° S.er~ices,the Packaging and Transportability Engineer, the appropriate ETEC, manner,'- a d th. .requisitioner/user . Radioactive materials are not included, since they are discusseikina s~parateprocedure . Similar procedures are avaii`rable •: for other SSFL: programs, including other DOE activities . These are described in the Hea4fh-; Safety , and .. nv -ranment Procedure Manual 572-L- 1 (Rockwell International , undated) . 4,2:.2 To) ic' heimi' aJ Use and Storag e Many hazardous substances are in use ; however, most of these materials are used in relatively small quantities (e .g ., reagents in the analytical laboratories) . This discussion will emphasize those substances used in appreciable quantities . 4 .2 .2 .1 Bulk Liquid Chemicals and Fuels Storage Area s Some hazardous materials are stored in large quantities at several locations throughout the DOE program area of SSFL . The substances stored in aboveground storage tanks include fuel oil, diesel fuel, gasoline, lubricating oil, sulfuric acid, and sodium hydroxide solution . During the Survey, these tanks were visually inspected for leaks, adequate secondary containment, appropriate labeling, and other potential deficiencies . A description of six of these tanks and the deficiencies observed are presented in Finding 4 .2 .6 .4 .1 . 4-16 HDMSP00042502 4 .2 .2 .2 Low-Volume Storage Area s Approximately 70 drums containing various types of oils, a microbiocide, lithium hydride, various solvents, and other chemicals are stored in Buildings 007 and 008 . Most of these substances have been stored for many years in metal and fiber drums at sites that are exposed to the elements and lack secondary containment . As a result, many of these drums are deteriorating, and there is evidence of past leaks or spills (see Finding 4 .2 .6 .2 .1) . Several 55-gallon drums containing solvents were on dispensing racks at four locations. These dr-urns did not have drip pans to catch spills or leaks and could be a source of release' of : ;hazardbu substances to the environment (see Finding 4 .2 .6 .4.1) . 4 .2 .2 .3 Solvent and Chemical Storage Cabinets Many solvent and chemical storage cabinets are 10cated -,adjacentQ :buildings . Some of these cabinets were not adequately maintained andtQuldr ult in-the r$1'ease of hazardous substances to the environment . In many cases, the cabinets vrgi i n a'deterrorating condition , and the containers inside the cabinets were badly corroded or ' Jackedfabels . Some of the cabinets did not appear to have been used for several yiears '( see Finding 4 :2:'6 .42) . 4 .2 .2 .4 Impri g2r Stor6e*of B4tterie s Two''pal>ets f_nick#mr-admium batteries were improperly stored . One pallet was stored outsid e 81 .43 ar'id the second pallet was near B-100 . The condition of the plastic casings indicates that these batteries had been exposed to the weather for some time (see Finding 4 .2 .6 .4.3) . 4 .2 .3 Polychlorinated Biphenyl s Written procedures for the disposal , storage , and labeling of polychlorinated biphenyls (PCBs) are included in the Rocketdyne Environmental Control Manual ( Rocketdyne , 1986) . These procedures define the management ' s policy and assign specific responsibilities concerning the use , storage, handling , identification , inspection , transpo rt ation , and disposition of PCBs . These procedures are designed for the Rocketdyne facility to be in compliance with the TSCA regulations (40 CFR 761) . All of the PCB and PCB-contaminated equipment have been retrofitted (fluid removed and flushed) or removed from the DOE facilities at SSFL . The last of the PCB items were retrofitted or removed by an outside contractor before the close of the 1987 calendar year . However, most of the retrofittin g 4-17 HDMSP00042503 of transformers was done during the 1986 calendar year . The retrofitted transformers were sampled and analyzed after 90 days of operation by the contractor . If the fluid concentration was found to contain more than 5 ppm of PCBs (the California standard), the fluid was removed and the transformer was rinsed and then refilled with the non-PCB coolant fluid . This process was continued until the PCB concentration in the fluid remained below 5 ppm . The waste PCB fluids and rinsates were disposed of ( incinerated ) by Rollins Environmental (Deer Park, Texas ), the capacitors were shredded and incinerated by U .S . Ecology Corporation ( Beatty, Nevada ), and those transformers that were removed were triple rinsed and then landfilled :' fhe ;ECU staff conducts an annual audit of the TSD facilities that Rocketdyne utilizes fof 'dil;posal ofi`ats hazardous wastes . The last of the PCB materials removed from DOE facilities were placcd . in storage,iri .B -231, which is a small building that is part of the CTL-2 ( B-206 ) complex; .The.PVB-sl .orage area is 6 by 8feet, has a concrete floor, a 6-inch dike , and adequate protection. from' he'el eme'rits ,,At the time of the Survey, the storage area contained some PCB wastes such s,capa 1c itorj - wipes, and a 55 - gallon drum . However , the origin of this material was not 'knovr1 . . _ The storage area and the' .iuildirtg were properly marked with PCB warning labels . This area is reported to be inspetftgd'on .a .weekly-.basi s Asbestos and asbestos-containing materials (ACMs) have been used at SSFL facilities in the past . The major . asbestos and ACMs include transite (cementitous asbestos) ; vinyl/asbestos floor and ceiling tile ; insulation on piping, equipment, tanks, valves, etc . ; various structural support members such as pipe hangers, tank pedestals, equipment supports, etc . ; pump and valve packing ; and gasket materials . Normally these materials are not friable and are not regulated by the EPA or the Occupational Safety and Health Administration (OSHA) . However, during demolition renovation, or during repair of facilities, they become broken, hammered, sawed, or drilled and are then considered to be friable . All asbestos removal activities are conducted in compliance with OSHA (29 CFR Parts 1910 and 1926), EPA (40 CFR Part 61, SubpartsA and B , 1973), and the National Emission Standards for Hazardous Air Pollutants . The procedures to be used in removing, handling, and packaging the friable asbestos during facility renovations or demolition activities are described in a Rocketdyne Operating Procedure (Schmidt, 1988) . 4-18 HDMSP00042504 Current policy is to contract asbestos remediation jobs to EPA -approved / California - licensed contractors . The facilities containing ACMs at SSFL have been identified ; however, the material is not removed unless it is friable or it is to be renovated or replaced . Replacement insulation, when required , usually consists of calcium silicate . Rockwell does have a person on the staff trained in the procedures to remove asbestos and ce rt ified by the State of California . Management plans to utilize this person ' s se rv ices for asbestos remova l projects that cannot be handled by outside contractors . Some sites where asbestos has been removed include the SCTI facility, 8009 and 8006.. The remove t" asbestos is double bagged and disposed of in a Class 1 landfill (U .S . Pollutio.R, I nc ;,Clive,4Jtali} 4 .2 .5 Pesticide s All herbicides and pesticides are applied at 55I .. .( i ve ir~iing the Q OE-optioned area ) by an outside contractor - The Dewey Pest Control Company • q F n-i fu_ys; California , is ce rt ified by the State of California and has the contract to apply pest {tides ]lath inside buildings and in the required outdoor areas . The pesticides in,irse at'SSFL are listed :j n Table4- 3 . There is only one herbicide on the list, since generally mech rricaI methods ace used to control vegetation at this facility . Pesticides ' ahd krerbicides re' not stored on-site . The contractor brings the types and amounts reguirea for44ch 6f-the weekly applications , and the crew removes any unused chemicals as well as empty2ontainerswhen they leave . 4 .2 .6' Findings and Observations 4.2 .6 .1 Category I None . 4-19 HDMSP00042505 TABLE 4- 3 PESTICIDES USED AT SSFL SSFL - VENTURA COUNTY, CALIFORNI A Pesticide Target Application Target Area Round Up Weed s (Broadleaf) Parking Lot Diazinon R 4E Exterior Pests Where Needed Knox Out 2 FRM Exterior Pests (Bees) Purge CB40 Interior Pests Dursban L.O . Fi c aam W Interior Pest s (Roaches, Ants) Interior Pests (Ants) Annua l Usage Dose Rate FIFRA * Registere d 1 gallon/acre Yes . , As Required 4 oz/3 gallons XIS ; :: ; Where Needed As Required 5 tbs/gaIIon Yes Where Needed As Required Fog`: =.~ _ . e3 Where Needed As Required ` ,2.,oz/gi .Ion Ye s Where Needed .' .. As'•Ir qui et! Yes 2-3*tsps/gallon Source : Adapted from Rocketdyne Division, 1- 9$$ * Federal Insecticides, Fungicide, and R 6 .'c1enticile Act.`' 4-20 HDMSP00042506 4.2 .6 .2 Category I I 1. Deficiencies at Chemical Product Storage Sites . There is the potential for the release of hazardous substances to the soil due to deficiencies in the chemical product storage Buildings 007 and 008. The Survey team observed the following deficiencies . a . Long - term storage - Some chemicals have been in storage for more than 10 years in metal and fiber drums containing a variety of hazardous chemicals in an area that is exposed to the elements . The utility of some of the chemicals as a produi:i is questionable . See Tables 4-4 and 4- 5 for the chemicals in storage , the.gsi a iktity of eac h chemical, and the date purchased . b. Deteriorated drums - Several of the metal and fiber drums have dateriora 'ted and on e drum ( the microbiocide ) has corroded . .Ther•,atso. evidence of past spills a t Building 008 . 4.2 .6 .3 Category II I None . 4 .2 .6 .4 Cate6&y I De4tcieiiic in Bulk Chemical and Fuel Storage Facilities . There is the potential for release of hazardous materials from bulk chemical and fuel storage tanks, as well as chemica l dispensing sites .- Although not regulatory violations, the Survey team identified deficiencies at the following storage and dispensing sites . 4-21 HDMSP00042507 TABLE 4-4 CHEMICALS STORED IN BUILDING 007 SSFL - VENTURA COUNTY, CALIFORNI A Purchas e Date Quantity Chemical LiH Shields Aluminum Clad 11 (3 ,470 pounds) 197 8 LiH 14 each - 55 gallon drum s 1 each - 30 gallon dru m 1 each - 20 gallon dru m 2 each - 5 gallon drums 197 8 197 8 1978 197 8 Sodium Hydride Powder 100 pounds #$,5 Ion Exchange Resins 6 each - 55 gallon drum`-. 1986- Denatured Alcohol 2 each - 55 gallon d'rums' :: 1,9B5 Water Softener Salt 2,000 pounds=.- . Jan . 88 Pulverized Limestone 2, Poly Wax Refractory Cemenia :poue'ds _ Jan . 88 00oiiA~s May 88 2,000 p unds Jan . 88 4-22 HDMSP00042508 TABLE 4-5 CHEMICALS STORED IN BUILDING 008 SSFL - VENTURA COUNTY, CALIFORNI A Chemical Quantity Purchase Date BUILDING 00 8 Hydrazine 7 each - 35 gallon drum s 2 each -15 gallon drums 1986 1986 Amerzine 9 each - 55 gallon drums 1986' ` . ==. ' . Lubricating Oils 19 each - 55 gallon drums Between 19.731;. ' -8 Automatic Transmission Fluid 16 each - 55 gallon drums 1987-Presen t Morpholine 5 each - 55 gallon drums. . Triton X-100 2 each - 55 gallon drums: Resins (Permuted) 35 containers ' (7 cubi c`feet eac4a) . Flake Caustic 2 each- 5s gn'drttms Greater than 10 years ol d Microbiocide 1 each gallon drum Greater than 10 years ol d Sodium Nitrite 5 ea ch - S gallon size Greater than 10 years ol d '_- 1988_ .Greater than 10 years ol d 1985 BUILDINGr'U_0$ SOUTH" MIOPLL'6A Y IVlpbire 4°, ,. . _ • 7 each - 55 gallon drums Mobil DTE~Medium 1 each - 55 gallon dru m Mobil DTE 26 1 each - 55 gallon dru m Mobil DTE 25 3 each - 55 gallon drum s Acetone 2 each - 55 gal lon drum s Triton X-100 2 each - 55 gallon drum s Formula One SAE 10 W 9 each - 5 gallon cans All items listed have been in Building 8 for at least 2-3 years . Source : Moore and Wells, 1988 . 4-23 HDMSP00042509 Area Materia l Capacity (gallons) 356 Sulfuric Aci d 1,500 No secondary containment 356 Sodium Hydroxide, 20% Solutio n 1,500 No secondary containmen t 86,000 T-735 Fuel Oil Soil dike T-731 Fuel Oil 1,500,000 Soil dike T-732 Fuel Oil 1,500,000 Soil dik e B/057 Fuel Oi l 500 No labe l B/358 Sodium Nitrite 55 No drip pia Plant Serv . 55 N6'dsip pan Paint Shop Pai nt Thinner 5-,55 No d'rip,pan ' 8/457 Unknown 2-55 No d't"rpjan & no label * B/008 * ** 2. Proble m Kerosene .•. J9.55 `.: .'' . No3econdary containmen t ``- and evidence of past spill s Various Chemicals and Oils** 55-gallon drums'uvere on disperisingtcks . See Table 4- . Defict#nciestit ltW Che raical Storage Cabinets . The deteriorating condition of many of th e so}venvand chem+ea('storage cabinets could result in the release of hazardous substances to`t~kYp ehv%t nment or a fire . These cabinets are rusted and without labels. Some of th e cabin do not appear to have been used for several years ( e .g ., cabinet at 8-886). See Table 4- 6 for a list of some cabinets , their location , and the deficiencies observed . 3 Improper Storage of Ba tt eries . The improper storage of two pallets of nickel-cadmium batteries can result in the release of acid to the environment . A pallet of nickel -c admium ba tt eries was stored outside of B-143 , and the other pallet was stored east of B-100 . The plastic casings were extremely bri tt le from long-term exposure to the weather and cracked easily- 4-24 HDMSP00042510 TABLE 4- 6 DEFICIENCIES WITH OUTDOOR CHEMICAL STORAGE CABINETS SSFL - VENTURA COUNTY , CALIFORNI A Cabinet Location* Deficiencies Observed B-027 No label on some containers ; container cracked ; containers badly corroded . B-032 No label on some containers ; some containers corroded . B-057 One container leaked . B-062 Labels on containers in poor shape . B-133 No label on one container ; labels peeling ; container corroded::-. B-163 No label on a container . 6-826 (2 cabinets) Appears abandoned ; no labels on some .containers ; labels oeeting ; containers corroded . B-463 (3 cabinets) Containers corroded . B-886 Containers corroded . SCTI Buildin g (3 cabinets) Containers corrodeho la#1 6n sofne containers ; door ajar on one cabinet . Plant Services Building ' . 7 - Flakedfrom two .containers ; no label on one container . Source : S,urt eyfie-a m observations. * Cabinets loo ted outside? of building indicated . Note. ;ThiStrst}s !otintended to be comprehensive . 4-25 HDMSP00042511 4.3 Radiation 4.3 .1 Background Environmental Information The potential sources of radiation at the SSFL Site can be described by assessing individual media (i .e., air, soils, surface waters, and hydrogeology) . Each of these primary pathways is responsible for radionuclide transport and potential contamination of ambient air, soils, drinking water , groundwater, vegetation, and food . Ambient radiation in the vicinity of SSFL is a consequence of both natural and ma'h-mecle sou'rc4s . These sources include cosmic radiation, natural radioactive materials in .,the spil-j, Jiid ,Y .. buildirml materials, fallout from past atmospheric weapons detonations, and releaseso1~radioactive materials from nuclear power plants and other facilities handling radioacl matefials- .worldwide . These releases can result in public dose from the intake of or expo, ureto radioactive materials in air, drinking water, and food . The most significant,-of these exjxosiires,:Is that to the lungs from background levels of radon . The annual average ef ;k-tivedose .eOuivalent for natural background in the United States is approximately 184-milttfomlyeat7_fmremfyear) (United Nations, 1982) . This dose is detailed in Table 4-7 . About one-half-gf "dose equivalent is attributable to the inhalation of radon-222 and its decalproducts . Previously accepted estimates of background doses did not include the radon ce r7bution and . were at levels of about 100 mrem/year . The data st Taiate 4-7 `vwere derived in accordance with the approach recommended by the Triter'rtationa4 rii! tionfor Radiation Protection (ICRP) in ICRP Reports 26 and 30 . This approach altowi .direct cotjparison of the effective dose for various organs by reflecting the distribution of and organ sensitivity to various radionuclides . This is accomplished by applying "weighting factors" to the doses received by individual organs . The weighting factors are expressed as the fraction of the total risk for the entire body attributable to the organ . The sum of the dose equivalent for the individual organs provides an estimate of the total effect of the radiation on the whole body , The EPA reports gamma radiation exposure rates on a quarterly basis for select locations throughout the United States in Environmental Radiation Data (EPA, 1987) . Although a considerable distance from the site, measured exposure rates equivalent to an annual dose of approximately 65 mrem ± 7 mrem were reported for the Berkeley, California, monitoring location during the reporting period of April through June, 1987 . 4-26 HDMSP00042512 TABLE 4- 7 U .S. AVERAGE ANNUAL EFFECTIVE DOSE EQUVALENT TO HUMANS FROM NATURAL BACKGROUND RADIATIO N Organ Annual Effective Dose Equivalen t (mrem ) Gonads 24 Breast 14 Lung ( Total) 10 0 13 Red Bone Marrow Bone Su rfaces 6 Thyroi d 29 . Other 77 TOTAL(1 ) Source : United Nation sc:198 s (1) Total represents the•, maaFtr`prod ct of the appropriat e weighting factor tir'des the .annual dose equivalent for pulmonary trachial/bror Chia}; and mean doses . 4-27 HDMSP00042513 As required by DOE Order 5484 .1, Chapter III, 4d2d1-3, SSFL conducts an annual "assessment and reporting of potential dose to the public ." In 1985 , DOE adopted an interim radiation protection standard for environmental activities to be implemented in calendar year 1985 (Vaughan, 1985) . It is DOE policy to follow the guidance of the National Council on Radiation Protection and Measurements (NCRP) to the extent practicable with respect to radiation protection standards. A comprehensive revision of previous NCRP recommendations on a basic radiation protection is still under development . However, current NCRP guidance is available regarding protection of th e public in its September 18, 1984 , advice to the Environmental Protection Agency published underkhe title "Control of Air Emissions of Radionuclides." In this document, the NCRP endQrses :'.the recommendation of the International Commission on Radiological Protection -fa. limit`ata e continuous exposure to any member of the public from other than medical soyrW_.'and natural' background to 100 mrem per year whole-body dose-equivalent . The previoasy recommended limit of 500 mrem per year is retained for noncontinuous exposures : '. .This -reczmntnenda'tion is now adopted as an interim standard for DOE environmental act,piities : for the sum of all exposure pathways. Radiation exposures are received from e)tti?rna1_s& rces4nd from radionuclides taken into the body by inhalation of air and ingestion of wate r' .ai d foodstuffs . Radionuclides taken into the body will continuously irradiate the; body- until they re removed through either radioactive decay or metabolic processes: .-''Cently,.• internal dose estimates are calculated as "50 year dose commitments' hes `;'rre'obtainec} by integrating the total dose received by an individual's body over an a med remal trig lifetime of 50 years. The doses to the various major organs are consrdefed lot varititjs exposure pathways . The radiation doses received by a specific organ are weighted and s +nmed to determine the total dose . 4 .3 .27 General Description of Pollution Sources and Control s During the 1950s and 1960s, SSFL conducted research and development on many nuclear reactor projects . These projects include the Sodium Reactor Experiment (1957-1964), the Space Nuclear Auxiliary Power (SNAP) reactor, and critical experiments (1957-1973) . Some of these programs or portions thereof were licensed under Nuclear Regulatory Commission (NRC) and predecessor agencies, while others were under the auspices of the Department of Energy (DOE) and its predecessor agencies . As funding for various programs decreased, SSFL began a program of radioactive Decontamination and Decommissioning (D&D) of select operations under the Surplus Facilities Management Program (SFMP) . Criteria for Environmental Analyses of at least seven of these facilities are outlined in Berger, etal_, 1979 . The current D&D status of former nuclear operations at SSFL is shown in Table 4-8 . Source documents for listed D&D activities were numerou s 4-28 HDMSP00042514 TABLE 4- 8 CURRENT DECONTAMINATION AND DECOMMISSIONING (D&D) STATUS Of FORMER NUCLEAR OPERATION S SSFL - VEN'1'`URA COUNTY , CALIFORNIA , .~b AP p xV .a te Builaing No . 003 Facility Hot Cave Nuclear Regulator y Yearsifi'' : ;: '' Operi tion(1) D&D Status 1954-19,73`,. - uild-i : q dismantled - non salvaged equipment sent Commission(NRC) Statu s N .A . to :Bea1,ty, Nevada (UREDA, 1976) . Released fo r unrestricted use (Lanni, 1984) 005 Uranium Carbide pilot fuel fabrication 1966-1967` .• RoornS 1:10 and 113, exhaust ducts and filter .plepu'ms need to be decontaminate d (Chapman, 1987) . N .A . 009 Sodium graphite reactor (SGR) organic moderated reactor (OMR) 1959-1969 1959-1969 Conditionally releiised to unrestricted use (Owens, undtitedj . N .A . 010 Systems for nuclear auxilliary power Facilit~i,ra2ed and shipped to Beatty, Nevada (Stelle, 1979).'` ; N .A . • SNAP8ER • SNAP 2SER 1962-1963 1959-1960 012 SNAP critical 1962-1973 Areas in the corn rgse'buiIc(iig will require monitoring during D&D :(Be ley, 1985) . N .A. 024 SNAP Environmental Test Facility (SETF) S2DR, S 10FS-3, SCA-4 13 , Snaptran-1 1960-1971 Released to conditi,or al unrestricted use (Speights, 1978) . N .A. 028 Shield Test Irradiation Reactor (STIR) 1961-1973 "The facilities were i.4 contarninafed to levels which were as low as practicable ;buV n all cases to level s below the limits describkcta's ~acceptable for futur e N .A . unrestricted use" (UREDA, 197¢) .-,. 055 Nuclear Materials Development Facility (NMDF) 1965-1979 Meets requirements for unrest'icred' .use (Chapman, 1986) and criteria in .Dismantling Plan . Released and Remove d from SNM-21 licens e (Rouse, 1987 ) 059 SNAP 8DR 1962-1969 D&D not complete - Pipe chase rerr+id+atian project N .A . is under way (Meyer, 1988) . ` ~. TABLE 4- 8 CURRENT DECONTAMINATION AND DECOMMIS $IOOI$ING (D&D) STATUS OF FORMER NUCLEAR OPERATION S SSFL - VENTURA COUNTY, CALIFORNIA PAGE TW O Buildin g No . Facility fo !rat~'~. e .. . . . Opel.tion(l) D&D Status Nuclear Regulator y Commission NRC Statu s 073 Kinetics experiment water boiler (KEWB) also includes Buildings 643 ,123 and 79 3 1956-1 .9: 093 AE-6/L-85 Reactor also includes Building 83, 74 and 453 1956-1980 Mee ts criteria for release of facilities for unrestricted '4 (Begley, 1986) and in Dismantling Plan . Released and R-11 8 license terminated (Wenslawski, 1987) 100 Advanced epithermal thorium reactor (AETR) fast critical experimental laboratory (FCEL) 1960-1972 Meets criteria` i .n'clismantling plan (Remley, 1980) . CX-17 License terminated (Reid, 1980 ) 143 Sodium reactor experiment (SRE) includes Buildings 41, 724, 686, 163, 695, 723, 753, 453, 653, 054, 77 3 (drainage control) 1957-1964 D&D 197k 1983''releasett.for unrestricted use (Lanni, 1984 andl3s~pkilitz, 1983) . N .A . 373 SNAP critical assembly (unshielded) 1957 No D&D documetiits av~ail'ab~e .f2) N .A . .All structures and foundations razed except for the '#Ioor a'n'd foundation of Building 73 (Ureda, 1976) . Source- DOE Survey team . (1) Dates provided by Dr . Marlin Remley . (2 ) Survey Report on Building 373 in preparation as part of overall DOE Site Survey . N .A . and spanned many years . Principal radioactive contaminants of concern over the entire period of operation at SSFL have primarily been mixed fission products . In addition to the SFMP D&D activities, SSFL proposed a radiological survey plan and is now conducting these surveys for the purpose of determining "if radioactive contamination exists to such an extent that further surveying or decontamination is warranted . . . ." (Badger and Tuttle, 1985) for facilities outside the SFMP decommissioning program . This program will help to further characteriz e or identify additional radioactive sources . The two major sources of SSFL radioactive material use are the Hot Lab (BuildingO O and-`ke Radioactive Materials Disposal Facility (RMDF) . The first is a facility that is designed for fue4 decladding and other activities requiring hot cell facilities . It is licensed' under Special"' Nuclear Materials License SNM-21 issued by the NRC (Page, 1984) . Spent'DOE-owned : fuel elements have been decladded for further reprocessing at other facilities ; N b%4 ever no suc h activities were being conducted during the on-site survey . A diagram (Figure 3--3:) and'discuispn of airborne radionuclide emission control equipment is provided in Section.,3 . :1 :BProcess-l.iqui i effluents are piped to a hold-up tank, which is analyzed and processed at the .RMD :foruf'rraiate~disposal . The principal source of pot* ntia radiation close : -to the public from SSFL activities is the RMDF . The term "Disposal" in tt RIVIDF_narrie. cs rather misleading, since only decontamination and packaging for ultimate...dh"sp sal'ta'ke'place._at'this facility . The RMDF consists of the following areas (se e Figure4-1) Buildg T021, Radioactive Waste Processing and Packaging , and Equipment Decontamination . Building T022, Radioactive Material Storage Vault . • Building T034, Administrative and Engineering Offices . • Building T044, Health Physics Services . • Building T075, Packaged Radioactive Waste Ready for Transport Off-Site . • Building T621, Radioactive Source Storage . • Building T665, Emergency Supplies Storage . • Building T688, open, covered building for temporary storage of chemicals and equipment . • Building T658, hardened security post at the main gate . • RMDF drainage pond . 4-31 HDMSP00042517 Il N 112P E - 44 T044 T034 I 1658 "Eq uipment Gat e X 1 I IT665 Facilit y enclosed b y 8 ft . fenc e and 3 strands I of barbed wire . Legend ME : ED : EE : PG : P0 : 0 Main Entrance/Exit Equipment Door Emergency Exi t Padlocked Gate Padlocked Doo r Posted Area for Contamination, Airborne Radioactivity and/or High Radiatio n Posted Area for Radioactive Material s .11 / PG The entire facilit y is a controlled radiation area . Source : Adapted from Chapman, 1986 FIGURE 4- 1 SECURITY AND RADIATION AREA ACCESS PROVISIONS SSFL-VENTURA COUNTY, CALIFORNI A 4-32 HDMSP00042518 Airborne effluent controls for the RMDF are shown in Figure 3-2 and discussed in Section 3 .1 .2 . Airborne dose assessments of this facility may be imprecise, as described in Finding 4 .3 .4 .4 .3, because of AIRDOS computer modeling difficulties . Process liquid effluents from the RMDF itself as well as from other on-site radioactive liquid effluents are concentrated in the evaporator located in Building 021 and then packaged for off-site disposal . Building T-075 is the principal direct radiation source of environmental concern . Radioactive waste materials that have been packaged for off-site shipment are stored here, frequently in concentrated form . Despite added shielding, this building continues to be of concern from the staridpoirn .. o f potential public exposure to direct radiation ( see Finding 4 .3 .4 .4 .1) . 4 .3 .3 Environmental Monitoring Progra m Environmental monitoring for the purpose of determining site related increases in environmental radioactivity is conducted for various media, including air, water-and'sq"ii• . Airborne radioactivity is monitored in process stack effluents at the RM >F. and*he H'4'-Lab :-.Ambient air is also monitored for radioactivity, as described in Section 3 .1 .3 :S-y rfaace.;vuater:at SSFL is only monitored following rainfall, as there are no continuously flowing discharges as described in Section 3 .3 .3 . As already discussed in Section 3 .2, soil monitoring hasbeen conducte¢iat SSFL since 1954 . Representative monitoring data have already been psgti~ rated. in theseesectkons and will not be repeated here . Airborne pacticufate emissions from the RMDF are well controlled, as described in Section 3 .1 . Particulate rssio>s :~rom the RMDF are shown in Table 3-7 for the period 1981 to 1987 . Dose to the general' population is extremely low, as evidenced from the calculated total dose to the receptor population living within 80 km . In recent years this dose has ranged from a low of 0 .0029 personrem in-1982 to a high of 0 .017 person-rem in 1985 . The majority of emissions of airborne particulates occurs from the 130-foot stack located between Buildings 021 and 022 (see Figure 4-1) . Environmental soil, water, and ambient air samples are counted for alpha and beta radiation with a low-background, gas-flow, proportional counting system . The system is capable of simultaneously counting both alpha and beta radiation . Because the observed radioactivity in environmental samples primarily results from natural sources and is at low concentrations, constituent radionuclides are not identified for each sample . Dose calculations are performed conservatively, assuming that all alpha activity is plutonium-239 and all beta activity is strontium-90 . Collected samples are also composited for gamma spectrometry of accumulated sample materials . The detection of significant levels of radioactivity would lead to an investigation of the radioactive material involved, the sources, and the possible causes (Moore, 1988) . 4-33 HDMSP00042519 In addition to the significant quantities of transient direct radiation from materials being processed in Buildings 021 and 022, wastes packaged for transport off-site and stored in Building 075 are also a source of direct radiation . Sealed sources (well-shielded ) are stored in Building 621 , and temporary storage of larger moderate concentration material occurs in the fenced areas nearby B-075 and B-621 . Numerous devices are in use to provide continuous monitoring of direct radiation from these sources . SSFL uses Victoreen , manganese - activated , calcium fluoride, glass-bulb , thermolumi nestont dosimeters ( TLD) for measuring direct radiation . As discussed in the previous .iettiop and .,rn Finding 4 .3 .4 .4 . 1, direct radiation measurements at the prope rty boundary,.north' of .tEi.e:;1ZMDF are" greatly influenced by quantities of packaged waste materials stored in Budding T075 . Addi ibnally, the perimeter radiation monitoring program has deficiencies , as diseussed in Hiii.din .g4 .3`A1 .4 .2 . 4 .3 .4 Findings and Observation s 4 .3 .4 .1 Category I None . 4 .3 :4 .'3 Categorv I I I None . 4 .3 .4 .4 Categorv I V No rt h Boundary Penetrating Radiation Doses . Although many improvements have been made to reduce radiation exposure rates , because of changing operations involving radioactive materials handling at the RMDF , these exposure rates may exceed the DOE guideline of 100 mrem/ year for continuous exposure from all pathways at the prope rty boundary north of the RMDF . This guideline is intended to prevent members of the public from unknowingly receiving excessive exposure as a result of DOE operations . However, long- 4-34 HDMSP00042520 term exposure to a member of the public is unlikely due to the rugged terrain along the north boundary and daily security patrols . 2. Penetrating Radiation Monitoring Program . The perimeter penetrating radiation monitoring program is deficient because formally approved and updated procedures are not available . Specific areas of concern include the following : a . Environmental TLD (Victoreen, glass -bulb type) handling procedures do not correspond--to existing written procedures . For example, the calibration source currently used'i's not the one described in the written procedure, and the annealing furnace referenced in the procedure is no longer used . b. Calculations, assumptions, and other supporting data used to dIettrmine boundary dose and dose to the nearest resident are not formally dpctjinented F&--example, source term, inverse square, and air attenuation calcutatiorrs`to dQfermirie,the boundary dose are not presented in the environmental mvnitoriii q" repo r or summarized in a report outlining these assumptions. Written Integra ofit! :of tie site's Landauer (film badge) dosimetry program (for the purpose of measuring perimeter radiation), including QA requirements , has not taken plaO 3. AIRDQS°*`4k ulatii ps :" AIRQOS•iiiodeled population exposure and estimated dose informatio n may l irra cecise beta use of computer code difficulties . Specifically, the AIRDOS-version SSF L psed atthe tiiaf of the Survey would not run multiple source terms for all 80 km sectors an d would ri .t accept multiple dose conversion factors . Because of these deficiencies, sit e personnel must run the code repeatedly for various nuclides and sum the calculated dose s -external to the computer code . The Survey team believes site personnel are currently taking a conservative approach in favor of public safety, and doses are well below guidelines . However, multiple calculations external to the computer code increase the potential for errors in final calculated dose estimates (see Finding 3 .1 .4 .4 .1) . 4-35 HDMSP00042521 4.4 Quality Assurance/Quality Contro l 4 .4 .1 General Description of Data-Handling Procedure s Three analytical chemistry laboratories at SSFL perform analyses of environmental samples from the DOE programs : the Rocketdyne Chemistry Laboratory in Building 300, the Radiation Measurements Laboratory in Building 100, and the Chemistry and Metallurgical Laboratory in Building 065 . In addition, off-site laboratories are used extensively for the overflow environmental samples-`and some special projects such as the Proposition 65 sampling and analysis program conducted TrL 19$ ;by Environmental Monitoring & Services, Inc ., a subsidiary of Combustion Engineering . . *_ ~.• .• .' ; Outside laboratories are required to have adequate QA/QC programs . Water'samplesfor tttemica I analyses are sent only to those laboratories which are approved bythe Statw :of.. .'Califo 'rnia and ar e required to maintain adequate QA/QC programs . Radiological Monitorin g The Radiological Environmental Monitorirlg, :Progc~m is the responsibility of the Radiation and Nuclear Safety Group of ;tie Kealth, Safety -:ad Environment Department . The purpose of the program is to evaluate~the effectiv e,ess;gf the safety procedures and of the engineering safeguards included intofa~i ity de'sjgris, to-ensure that SSFL operations do not increase radiation levels in any significant-amokilt . This-:iTonitoring program is conducted by the Radiological Measurements Laboratory vvi#h asta;ff of two experienced analysts . The baboratory monitors radioactivity levels in on-site and off-site samples of ambient air, surface soil, Surface water, groundwater, and ambient radiation levels . The details concerning the specific sampling location, sampling frequency, and type of analyses performed are presented in Sections 3 .1 .3, 3 .2 .3, 3 .3 .3, 3 .4 .3, and 4.3 .3 . A written quality assurance procedure for the radiological measurements program is available at SSFL (Moore, 1984) . This Rockwell International Department includes a laboratory quality control program that is intended to help ensure the accuracy and precision of the results generated in the laboratory and to continuously monitor the quality of laboratory data . The essential elements for analytical quality control are presented as follows : • Use of high- quality reagent s • Low-level radiation in laboratory air suppl y 4-36 HDMSP00042522 • Controls to minimize laboratory contamination • Use of reagent and sample blank s • Use of control chart s • Use of standard reference materials • Use of blind replicate s • Use of spiked sample s • Participation in laboratory intercomparison programs • Use of calibration standard s In general, the laboratory utilizes these quality control techniques with one except '6' f'ret d samples were not being used at the time of the Survey (see Finding 4 .4 .2 .4.1)_.. Spiked samples provide a measure of the accuracy of the analytical measure,mPnts-'and are an important aspect of a laboratory's quality assurance program AlthQtigh the laboratory participates in the DOE interlaboratory comparison program, a r rbre ft equer rmeasi re of the analytical accuracy is required than once every 6 months . Also ,: ~piiked s4mple . pra de information concerning any specific sample matrix effects on the analytical results . of wever, the laboratory is generating good quality data, as is demonstrated by the results . of dire semiannual DOE Environmental Measurement Laboratory Program and thr4 biennial DOE Radiation Dosimetry Intercomparison Project . Another shQrtc fn ng 'ot the quality control program is the lack of procedures for confirming the analyst ' s ca frulatiions and entry of the results into the computer data base . This deficiency could result iii°;erro s'be2 ii~ag a permanent pa rt of the data base and thereby decrease its reliability (see Fir tdi tg 4 .4 . 2 .4 . ~1 The Rocketdvne Analytical Chemistry Laborator y The Rocketdyne Analytical Chemistry Laboratory is certified by the State of California for the analysis of NPDES and hazardous waste samples . Most of the workload consists of environmental samples (75 percent), and the remaining analyses (25 percent) are in support of the test stands and engineering operations . The laboratory has established an extensive quality assurance/quality control program based on the EPA guidelines (EPA Quality Assurance Management Staff Guidelines, QAMS Document, December 20, 1980, and the Handbook for Analytical Quality Control in Water and Wastewater Laboratories) that is designed to produce results that are scientifically valid, defensible, and of documented precision and accuracy . 4-37 HDMSP00042523 The laboratory uses one-on-one , and on-the -job training for new personnel or new procedures manufacturer ' s manuals are relied on for instrument operating procedures . The . This laboratory is part of an engineering group in the Materials Engineering and Technology Organization , which operates within the Engineering and Test Depa rt ment of Rocketdyne . The main elements of the quality control program include the use of internal standards , exter al standards , working standards , spiked samples , duplicate samples , appropriate blanks, use 'bf :quatity control cha rt s , and pa rticipation in the EPA laborato ry assessment program . The~~qua(ity control samples make up 10-20 percent of the samples analyzed by the laboratw ,ry . These samples are tracked by a computer, which flags any unacceptable results . Such results are ,~evaliiated t o determine their cau se , an d appropriate corrective action is taken . t! ' : The laborato ry' s operation procedures are described . .- in the Rd ketcl r6 ,;:publication ( MPR 82 - 0229), "Water Analysis Laboratory Operation anci' : .Procedures:.,.!Mani al ." This document contains information on ce rt ification , quality 'assurar ce . ou line , • raboratory organization , personnel qualifications , personnel responsibilities , records, sampling procedures , instruments and methods, statistical control , education NPDES permit, an d'jegal aspects . The laborato s w r ## ri ' analytic f procedures for each analyte measured . These procedures are consistent',wkth >-Ef3A protacols, are reviewed frequently , and are revised as required . Written procedures `ere ' at available that describe sampling, sample containers , holding times, and storage : Chain;©f- custody procedures are followed for all NPDES samples , and these samples are kept in a locked refrigerator prior to analysis . The Chemical and Metallurgical Laborator y The Chemical and Metallurgical Laboratory serves a very limited function for environmental analysis . The analysis of materials for asbestos is the only environmental monitoring function of interest to the Survey team . Materials are analyzed for friable asbestos by low - and high power optical microscopy . An inspection of the three laboratories demonstrated that they are equipped with state of-the-a rt instruments and equipment for the monitoring function required of each . The laboratories were clean and well organized . Discussions with individual analysts indicated the appropriate expe rt ise required for the analyses assigned to each of them . The laboratory staff maintains appropriat e 4-38 HDMSP00042524 sample logs, and analytical notebooks, as well as calibration and instrument maintenance records . The maintenance of the analytical balances and the infrared spectrophotometer is managed through service contracts . All standards and limited-life reagents are dated when received . 4 .4 .2 Findings and Observations 4 .4 .2 .1 Category I None . 4 .4 .2 .2 Category II None . 4 .4 .2 .3 Category I I I None . 4 .4 .2 .4 Category I V Deficien4b$Nin t `Procedyres'Tor Radiological Monitoring . Environmental monitoring data may be lessdefen3lbfe as a result of the following quality assurance deficiencies observed a t the Ra easurements 'rolog s M Laboratory at the SSFL Site : Lack of formalized procedures for confirming the analyst ' s calculations and entry of results into the computer data base- b . No use of spiked samples on a routine basis for internal quality control (although the laboratory participates in the external test program of DOE/EML) . 4-39 HDMSP00042525 4 .5 Inactive Waste Sites and Releases 4 .5 .1 General Description of Pollution Sources and Control s The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) established (1) notification requirements, (2) liability standards, and (3) response authority for dealing with releases of hazardous substances to the environment . Also known as "Superfund," CERCLA's scope is expansive . The EPA and state agencies can undertake or order study or cleats up when there is a release or the substantial threat of a release of a hazardous substance. : to:th e environment . Superfund was substantially expanded by the Superfund Amendments nd? Reauthorizatioh Ac t of 1986 (SARA) . In addition to significantly increasing the size of th~e'fund to-fFrtance cleanups, SARA creates a response authority for petroleum underground strage tank 'releases (technically an amendment to RCRA) and mandates community" :.right4to-ki ow a d-%emergency preparedness programs (Title III)_ SARA also obligates Feder`alfac titres to~tomRl:y with the same regulations and policies as other entities . Hence, except for :certa n limited national security waivers, Federal facility cleanup plans for sites on the National Priorities List`must undergo EPA review and concurrence . In addition to CERCLALSARA, .a second .Feileral cleanup authority was created with the passage of the Hazardous a€?d5alid Waste'Amendrrrents (HSWA) of 1984 . Included in the amendments to RCRA was a SectionJdp4(u) known ' . the "Continuing Release " provisions, which required that facilities addrex'ongofi!tg r`eteases from their existing and former Solid Waste Management Units (SWMUs) as acond"+tion of'grenting a final operating or post-closure permit . The implication of this provision is to establish a parallel RCRA-based cleanup program, whereby facilities seeking a permit for a new or ongoing operation must obtain approval for cleanup plans.of their old waste units prior to getting a new permit. The history of DOE-supported activities that are now conducted at SSFL spans three decades and at least three locations since the early 1950s in southern California . The first location was in Downey, California, in Los Angeles County approximately 15 miles directly east of the LosAngeles International Airport, and approximately 15 miles south of Pasadena . At Downey, the Water Boiler Neutron Source was assembled by Atomics International (AI), in a section of the building then occupied by its parent company, North American Aviation . This small physics experiment operated at approximately 1/2 watt, until it was dismantled in 1956 and moved to the Santa Susana Field Laboratory location (SSFL), where it was upgraded to 3 kilowatts (Remley, 1985) . No records were available of the decontamination and decommissioning of the Downey facility . 4-40 HDMSP00042526 The second location for nuclear power research began in Canoga Park , California at the Vanowen Facility in December 1955 . With growth of the activities during the late 1950's, new facilities (the DeSoto complex ) were constructed and activated during 1959 and 1960 . No operational or decontamination and decommissioning records were available regarding the Vanowen Facility . As funding for research and development and manufacturing activities declined in the early 1980's, the activities were consolidated with ongoing projects in the SSFL . The nuclear facilities at :-1he DeSoto complex were decontaminated , decommissioned , and released for unrestricted user They have since been completely refurbished and are now used for other Rocketdyne pro9 a 'rr1$. Extensil e records are available on the decontamination and release of the DeSoto facil3ties . The first energy-related activity at the SSFL site began in April 1 .95 5 with the construction of the "Sodium Reactor Experiment" (SRE) ; which first achieved-..criti-cali.tyinApril 1457 and was shut down in 1964 . This was one of five nuclear power reacfcr des i gns'selected ;, or research by the Atomic Energy Commission (AEC) . The AEC then Sponsor.ed,the`. Constt lction of a full-scale (75 MWe) sodium-graphite reactor in Hallam , Nebraska , w)h • th4 -. ,design and construction supervision by Al . The Hallam Reactor first reached full power i .n July, 1963 and was shut down in September 1964 because of operational .,pxablems . The SRE Wilding (B / 143) is still standing in the no rt heaster n The Energy`Tec)rlogy17gineering Center (ETEC) was established at SSFL as the Liquid Metals Engirieeiing`anter t provide engineering, development, and non-nuclear test support to DOE' s Liquid-Metal F 66tBreeder Reactor ( LMFBR) program . SSFL personnel produced two primary CERCLA documents : a Phase I Installation Assessment repo rt (Adler et al ., 1986) and a Phase II Site Characterization repo rt ( Olson , 1987) . In addition , a brief Preliminary Assessment was completed in 1987 ( Remley , 1987) . The Phase I report ( Adler et al ., 1986) concluded that a landfill area at B/056 (see Finding 4 .5 .2 .3 .1 .d) was "the only site on the ETEC premises that would qualify as a potential CERCLA site under the DOE Order (Ibid .) . The Phase II CERCLA report, however, identified one other site : the B/886 Sodium Burn Pit . The landfill area and the Sodium Burn Pit were identified as sites for cleanup at SSFL (Olson et al ., 1987) . In addition, the Phase II report investigated several other potential CERCLA sites which are discussed in Section 4 .5 .2 . Phase I and II report s were prepared specifically in response to the guidelines given in DOE Order 5480 .14 . 4-41 HDMSP00042527 The Phase I and II reports focused on disposal sites for RCRA wastes in accordance with direction from DOE, rather than considering in detail all potential hazardous substance release locations . The lack of a complete CERCLA investigation is discussed in Finding 4 .5 .2 .4.1 . This section introduces the actual and potential sources of hazardous substance releases to the environment. Section 4 . 5 .2 provides more detail on these sources, which are listed in Table 4-9 and illustrated in Figure 4-2 . Little information was available on the historical waste generation and disposal practices at55r3 : A summa ry prepared in 1962 ( Ferreri, 1962 ) indicated that Atomics International (Al) generated "213,000 gallons of radioactive ( R/A) waste requiring special means of disposal " artCtC y The typesof wastes generated by Al in 1962 are listed in Table 4 - 10 . The 3 , 750 gallons. of combust bre oils appear to have been excluded from the 213,000 gallons tallied irt -the = : Interoffice Letter (Ferreri , 1962) . The wastes were all disposed of off- site by Nutlpr .E(igineerrri Company ( NEC) for a total of $165 , 910 or an average of $ 0 .78 per gallon AppxoximaLely 3 .7-516 gallons of combustible oil generated annually by Al were sent to the radiottiue _mat.er..ials°4isposal facility ( RMDF , described fu rther in Section 4.3) at SSFL for disposal by NE (Despite its name , the RMDF does not dispose of radioactive waste , but rather ..concentrates,* aqueius wastes using evaporation equipment .) No information was available - whether the oil was treated at the RMDF or merely stored for disposal . Another SSFL docurrrept from Nov> ?.rnbet ;1986 (Heine , 1966) indicated that oil was used on roads fo r dust suppressiorj;:' .Th Rtatior i.Saity standard established in 1966, however , set very strict limits on the pees ssibte• level:-:'of• :radioactivity in the oil spread on roads for dust control . The standard essentially p'tiiib7te ;^ihe use of oil with any radioactivity greater than background . No information was available , vever , on the activity prior to this 1966 standard . The waste generation rate at SSFL has decreased significantly since the 1960s through the 1970s when activity at SSFL was at its peak . Table4- 10 shows the volume of waste generated during a period of higher activity at SSFL than present . No specific information is available , however, on nonradioactive hazardous waste such as solvents and PCBs . 4 .5 .1 .1 B1886 Former Sodium Burn Pit Are a The 8/886 Former Sodium Burn Pit was used from the early 1960s through the 1970s for disposal of chemical waste , including solvents, metals ( including Na and NaK), and some radioactive wastes . Flammable chemicals were poured into open pits and burned . Reactive metals were placed into a concrete pit of water or washed and reacted on a steel-plated pad using a steam lance . Unauthorized radioactively contaminated equipment was buried in trenches and placed on th e 4-42 HDMSP00042528 TABLE 4- 9 ACTUAL AND POTENTIAL HAZARDOUS SUBSTANCE RELEASE LOCATIONS SSFL - VENTURA COUNTY , CALIFORNI A Soil l Contamination GW1 . 2 Contaminatio n a . B/886 Former Sodium Burn Pit A A b . B/059 Former SNAP3/Facility -- A Location Name c. 6/021, 022 RMDF4 Leachfiel d d . Old Conservation Yard P e . B/056 Landfill -- f. ESADAS Chemical Storage Area P. '. g . B/100 Trench P h . S . E . Drum Storage Area P „• - i . New Conservation Yar d j . Area of B133 Sodium Burn Facility A -- Source : DOE Survey eam .. 1 "A" 3 : Actual ; "P Potential ; "--" = unlikely or not present ( based o n data avails to in May 1988) . = .~ jG r¢ur d:Wate r Date Nuclear Auxiliary Power. b k,---- Radioactive Materials Disposal Facility . -E~ADA Empire State Atomic Development Authority . 4-43 HDMSP00042529 (a ) ( b) B/059 Former SNAP Facility (c) B/021 , 022 RMDF Laachfield (d) Old Conse rvation Yar d ( e) B/056 Landfil l ESADA Chemical Storage Area ( g) B/100 Trench (h) S .E . Drum Storage Area (i) New Conse rv ation Yar d (]) Area of B133 Sodium Bu rn Facilit y C i SCALE IN FEET Source : Olson, 1987 FIGURE 4- 2 LOCATIONS OF ACTUAL AND POTENTIAL HAZARDOUS SUBSTANCE RELEASE LOCATION S SSFL-VENTURA COUNTY, CALIFORNIA TABLE 4-1 0 RADIOACTIVE WASTE GENERATED - 1962 SSFL - VENTURA COUNTY , CALIFORNI A Waste Description Noncombustible liquid waste Combustible dry waste Quantity(a ) (gallons ) 71,25 0 120,00 0 Noncombustible dry waste 14,000 Combustible organic waste 7,75 0 Total 213,000 . a. ' R/A liquids (oil = 3,750) `.75,000 : Source : Ferreri, 1962 . (a) Quantity generated "''. . anra lly •: ; by ',comics International program n Cenog3 . Park and at SSFL in 196!, 4-45 HDMSP00042531 surface . Exploratory trenches have been dug, and most contaminated equipment has been removed from the ground surface . Groundwater and soil contamination has been detected . 4 .5 .1 .2 B/059 Former SNAP Facilit y The basement of the B/059 SNAP facility is a potential source of groundwater contamination . The basement contains sand and water contaminated with Co-60 . Water in a french drain surrounding B/059, sampled through a standpipe, contains chlorinated organics, including trichloroethylene (TCE ) and tetrachloroethylene (PCE) . 4 .5 .1 .3 B/021, 022 RMDF Leachfiel d The RMDF leachfield was contaminated with radionuclides in the early 1960s when a tank valve was accidentally opened . The tank contained radioactive wastewater being head for treatment and solidification . In 1978, the leachfield was excavated to bedrock and backfilled .~Residual radioactivity was found in the bedrock cracks, presumably froth avast-ewaterpercofation, and the cracks were filled with asphaltic tar . No nonradioactive parame#ers were analyzed during the cleanup . N o groundwater monitoring has been performed . 4.5 .1 .4 Old Conservat rob`Yar d Aerial phot 5grap) 5 oft ;tfe Old' conservation Yard shows that hundreds of drums and equipment were stored thee through`~'the 1960s and 1970s . No analytical or inventory information was availabII4 on t# `e, contents of the drums . Leaks and spills were likely in an area with no containment and .no protectiDn . 4 .5 .1- .5 B/056 Landfil l The B/056 Landfill is a potential source of groundwater contamination because of the disposal of drums of wastes, some of which were hazardous . These drums were found on the top of the landfill and at the bottom of the slope . No inventory is available on the waste placed in the landfill, but approximately 90 drums were removed from the surface of the landfill in the 1980s, and several dozen empty drums were found at the toe of the landfill slope . (The previous history of these drums is unknown .) The landfill was used as a loose fill area from construction and excavation activities, according to SSFL personnel . A single groundwater monitoring well (RD-7), presumably located upgradient of the landfill, is contaminated with up to 130 ppb of trichloroethylene (TCE) and other volatile organics . 4-46 HDMSP00042532 4 .5 .1 .6 ESADA Chemical Storage Yar d Approximately 50-100 drums were stored in the ESADA Area in the 1970s . SSFL personnel indicated that at times drums of alcohols and drums of sodium were stored there . No records other than aerial photographs are available on the material stored there . 4 .5 .1 .7 B/100 Trenc h The trench was used during the 1960s for disposal of construction debris and possibly *hazardou s substances . No information was available on this trench except from photos . 4.5 .1 .8 Southeast Drum Storage Yard Photos from the early 1960s show an area on the southeast's .deQf Area'IV where approximatel y i .. 50 drums were presen t . 4 .5 .1 .9 New Conservation Yard ' The New Conservation Yatd is across the Service Area Road to the south of the Old Conservatio n Yard and has beery: sed for storage ,pr used equipment and drums since the late 1970s . Prior to salvage of stied rrtatdrials, 14aks` and spills of hazardous substances may have caused soi l contami nattpn . ,- r 4 .5 :1 .1'0 Are4df B/133 Sodium Burn Facilit y Equipment was stored at the current B/133 sodium facility for 20 years during the 1960s and 1970s, according to aerial photos and interviews with SSFL personnel . Recent soil analyses shows a pH of 10-11 at B/133 . No other analysis has been performed yet . In addition to these actual and potential hazardous-substance release locations, identified in 4 .5 .1 .1 through 4 .5 .1 .10, one additional area at SSFL appears to have received waste and flammable solvents and waste oils (for fire training exercises) from DOE-sponsored activities . This area is the Area I Burn Pit, located in the Eastern Section of SSFL near the CTL III test stand . This area is not on DOE controlled property . Rockwell performed a surface cleanup of this area in 1983 . No site specific groundwater monitoring has been performed . According to SSFL personnel interviewed, Area IV waste rarely went to Area I, except for occasional fire training prior to the merger of Al and Rocketdyne Protective Services Department (including Fire Department) in 1970 . After 1970 whe n 4-47 HDMSP00042533 there was only one fire department on the Hill, waste from Areas I - III sometimes went to the B/886 Sodium burn pit, and Area IV waste sometimes went to Area I . 4 .5 .2 Findings and Observations 4 .5 .2 .1 Category l None. 4 .5 .2 .2 Category II None . 4 .5 .2 .3 1. Category II I There are approximately 10 areas at .".`SSF L / aIV ` wher$• hazardous and/or radioactive substances-resulting from DOE-related acti:v%t - echave or-ay have been disposed of, spilled, or released . These areas cgnstitute actual aid-. potential sources of soil and/or groundwate r contamination . N9r .of the areas have ben adequately characterized . Each oFt1e1e area '5'discu . sed'below . B/886 Forl`tfef Sodium Burn Pit Area . The B/886 Former Sodium Burn Pit is a potentia l source lof surface water and groundwater contamination and an actual source of soil contamination . It was used from the early 1960s through the 1970s for disposal of chemical waste, including solvents, metals (including Na and NaK), and some radioactive wastes . The Former Burn Pit Area is located in the Northwestern edge of Area IV outside the DOE-optioned land and occupies approximately one acre . Flammable chemicals were poured into open pits and burned . Reactive metals were placed into a concrete pit of water or washed and reacted on a steel-plated pad using a steam lance . Unauthorized radioactively-contaminated equipment was buried in trenches and scattered on the surface . In addition, according to the Phase II report, "occasionally, firearms were used on vessels to 'safely' open containers to the atmosphere" (Olson et al ., 1987, p . 10) . Although this method may have allowed workers to remain at a safe distance from the containers containing reactive substances when they were opened, it did not facilitate capturing the contents. These contents appeared to have included reactive metals (e .g ., Na and NaK), and solvents (e .g ., TCE) . 4-48 HDMSP00042534 The Burn Pit area , which is bounded on the south and east by dirt access roads and on the north and west by large rock outcroppings, covers approximately 1 acre (50,000 ft2) (see Figure 4-3) . There are four major sections of the Burn Pit area : (1) pool area, (2) upper disposal pond, (3) lower disposal pond, and (4) west burial site . The "pool area" was used for the initial staging of wastes and contaminated equipment . The pool is a 42-foot by 12-foot, 15-foot deep concrete pit . Adjacent to the pool is a 2-foot by 15-foot steel pad and a 15-foot by 6-foot blast shield made of 3/4-inch-thick steel . The blast shield vitas installed to provide protection to workers while removing sodium and NaA' f1a m : . y equipment using steam lances . The steel pad protected the concrete fro i :'`danrage fra3rn the violent reactions of the sodium and NaK . Although the Burn Pit was'sur ounded by' chain-link fence with a padlocked gate, the fence was partially _torri .down grad theie wa s easy access through a large hole in the side . Exploratory trenches have been dug, artd must ciitarriitted equipment has been t retr..ieved. from the test trenches was not removed from the ground surface . ~: .quipnsent completely removed from thesite, anei uij?menr found lying on the surface was not completely removed,,cjue to lack ofreso :4 ces . Groundwater and soil contamination has been detecteci. ;;-$ome !waste was `removed in early 1980s (1980-1981), after the ne w sodium bu) facility (B%43.3);+rva s' opened in 1978 . No information was available on the arn,Q ij`.t.or type, of waste-removed, when it was removed, to which location it was tenove to, or ary what basis the removal was initiated or ceased . Soil was sampled fo r ra8iitacti i` only, but not metals or organics . Cesium-137 was the most prevalen t radioi oclide at up to 700 picocuries/g . Approximately 20 cubic yards of contaminated soil were removed from one basin . This soil was not analyzed for hazardous constituents . The only written documentation available regarding the 1980 activities at the B/886 Sodium Burn Pit is an Internal Letter from December 1980, which summarizes the radiation survey , soil sampling , and excavation ( Lang , 1980) . This letter refers to B/886 as the "old hazardous materials burn pit ." According to Lang , " The contamination appeared to be stratified in a layer 8 inches below the surface in a block [sic ] tar type substance . The dirt was excavated down to 2feet after the removal of a piece of pipe - like material that appeared to be the source that was reading > 3,000 uR/hour . Readings in the dark layer ranged to 100 u R/hour but were generally in the 20 -50 uR/ hour range . On December 4, 1980, after 1 inch of rain , the excavation completely filled and the dam between the upper and lower pond washed out allowing the run-off from the upper pond to run through the excavated area across the lower pond , and out into the road to follow 4-49 HDMSP00042535 Source : DOE Survey team FIGURE 4- 3 T-886 SODIUM BURN PIT AREA LAYOUT AND TEST THE 11 LOCATION S SSFL -VENTURA COUNTY, CALIFORNIA its natural run-off pattern ." Residual water from the excavation was analyzed and found to be within "allowable limits" (Lang, 1980) . Background radioactivity was generally 5-1011 R/hour . The Burn Pit area was used most extensively from 1960-1970 for disposal of combustible materials such as sodium, NaK, kerosene, and solvents . The two ponds, upper and lower, located below the pool, were used to react sodium-contaminated equipment . Several large pieces of equipment were left in the ponds and were covered with silt over the years . When some of these large pieces of equipment were retrieved, they were `fou.ri to contain unreacted sodium ; and the remaining equipment is assumed .t0-b4 similarty contaminated . The earthen ponds were constructed by bulldozing a crutf b rix~ around``a low-lying area , and cutting trenches through the berm to facilitterupoff. The Burn Pit West area was located to the west of tj~e-disposal pool . Used components from the SNAP, OMRE, and SRE programs!,* ere 14~und-buried L khe area to the west of the disposal pool during partial cleanup}h :the :e rly 198Q' s .' : • Some preliminary removal and d@cOntairiipation work has been performed . While scrap was being ren owed iii 1.980, nearby•:$bil and the concrete disposal pool were found to b e "radiolog~- ai1i contaminated above acceptable release limits" (Stafford, 1987, p . 2) . At hat="dre , the roncree disposal pool was drained and the walls were decontaminated . poc has si bsequently become pa rt ially filled with water . At the time of the Survey i n IVIy=19$8=ire pit was approximately 1/3 filled with brownish water . No information was avaif le regarding the relative contribution from infiltration into the pit from perched groundwater through cracks in the sides and bottom compared to the contribution from runoff entering the top of the pit had been determined . If cracks in the concrete lining could allow water to seep in, then water could also seep out and cause groundwater contamination . No information was available on the water quality in the pit . After the 1980 findings, SSFL personnel subsequently found radioactively contaminated soil "over a large area of an unpaved section adjacent to the disposal pool" (Stafford, 1987, p . 2) . A more extensive soil survey was being planned at the time of the Survey . The contamination discovered prior to the Survey was found to extend below the soil surface, but was not believed to be deeper than 2 feet . Until a more detailed soil survey could be completed, soil removal was limited to "hot spots ." No radioactive contamination was found in surface runoff samples, but the samples were analyzed only for radioactivity and not for organics and metals . 4-51 HDMSP00042537 For 3 days between March 31-April 2, 1986, SSFL personnel dug 23 test trenches in the Sodium Burn Pit area (4 in the slope below the ponds, 8 in the lower pond, 6 in the upper pond, and 5 in the west area) . This site characterization, consisting of exploratory trenches and soil sampling, revealed the presence of buried radioactive, chemical, . and mixed hazardous wastes . The results of this sampling were presented in the May 1987 Phase II Site Characterization Report (Olson et al ., 1987) . The trenches dug, sampled, or analyzed are listed in Table4-11 and illustrated in Figure4-3 . Samples were collected but not analyzed from three trenches (BP-2, BP-3, BP-4) . No samples were collected from vo trenches (BPU-1 and BPW-1) . Of the remaining 18trenches where the Phased'report suggested implicitly that soil samples had been analyzed, results wer . presented' 16r 5 trenches . No analytical information was available regarding the reriali.ig thirtee trenches. The Phase II report did not state clearly that these samples . had been ah&yzed but suggested it implicitly by noting which selected samptes''were-not,analyzed . The sampling at the Burn Pit was biased W avoid'sampili.ng'tCr Laminated areas , a method which thereby systematically undere timated contar inat on at the Burn Pit . According to the Phase II repo rt, " radiologicafty ' host areas. were avoided to assure that the samples could be handled in. the Chemistr y Labpratory " ( Olson et al ., 1987 , p . 12) . Because radioactive and-,gon-radioactive wastes were probably buried and released together, by avoiding rad'raactive areas; t re .s mpling program probably also avoided non-radioactive areas_ There S: 6oev.i.4en 6i that radioactive and non - radioactive wastes were physically seregated at "'t ; Burn Pit or that they were randomly associated and disassociated . In thbsk ca es&s an '-: information base for the ranking of DOE's env i ronmenta l 'prroblem T 2 .3 Sadapl ih: 'a Analysi s Based . orr- avail-A ble site environmental information and the results of the onsite-S urvey activities , the Survey team will identify Survey-related sampling needs ,. if any. Implementation of the S&A phase of the DOE / SSFL Survey would begin approximately four months after the completion of the on-site Survey activities . If Survey- related sampling is necessary , Idaho National Engineering Laboratory ( INEL ) will provide the field sampling and analytical support . HDMSP00042582 3 .0 AI R 3.1 Issue Identificatio n The air - related Survey activities will involve an assessment of the air emissions at the site , the administrative and emission controls applied to the sources, and the ambient air monitoring systems . The emphasis of the Survey will be on operational and procedural practices associated with the emission sources and the emission control equipment, as well as fugitive emission sources, both within and outside the buildings , and mitigative procedures applied to fugitive emission sources including recently shut down facilities . Close liaison will be maintained with the radiation team member because of the importance of air- rad issues . Close liaison will also be maintained with the QA/TSCA team member because of the interaction of several TSCA regulations aa a air regulations. The general approach to the Survey will include a review of existing aft.-*,. permits, pending applications , and standard operating procedures . Processe s and control equipment will be inspected for compliances with" ;: D4 ':-A1.ARA requirements for radionuclide emissions . The Survey will also review the nonradiological - air contaminants from the different~b uilding3 ..at the site, evaluate any existing controls applied to the ai r ..,emi lions ° and ::assess the need for additional monitoring or emission cgntrals:: t ,'characterize or reduc e the envi ronmental consequences of the emis~.i.on . Th s` Tieuew will include the various shops and storage areas . The ambient air monitoring system wilt be:ev1.uated to assess the adequacy of the existing monitoring program to' .cbarzieteriz environmental impacts of the air emissions from the facility . The:..act yities involved in this part of the spection of '-the • ambient air quality samplers, the Survey will include the . . in meterological tower, . aa ``review . of documentation applicable to the ambient air data acquisition , ,4- an eiia.1 .uatton of the processing procedures used to assure the acr-ur-rcy°of:,the date r Areas of paarti, cIl'ar it t rest will include emissions of the criteria pollutants (ego ... . s.uIfur< : ;eri'Fdes ,. nitrogen oxides, hydrocarbons , carbon monoxide and lead) as..welF. .as regulated hazardous air pollutants ( e.g., radioactive - bearing Although not currently listed as parti•cufiates, tleryllium , and asbestos ). hazardous air pollutants, chlorinated solvents, and freons will be included in this review . The use of all organic solvents will be assessed as a potential or actual sources of emissions to determine if they are adequately characterized, The non-radionuclide emissions assessment will monitored , and controlled . focus on those substances that the EPA intends to list as hazardous or toxic air pollutants ( e .g ., methylene chloride, trichloroethylene, Non-organic air emissions will also be included (e .g., perchloroethylene ). chromium , and sulfuric acid) . ammonia, chlorine , Fugitive emissions from the resuspension of contaminated soils will be evaluated as a potential contributor to the airborne release of radionuclides Consideration will be given to and hazardous materials from the facility . historical and current operations to determine the potentia -1 for soil contamination and windborne releases . HDMSP00042583 Several areas of specific interest have been identified during a review of available documentation : o Control and record keeping for solvent usage , e.g., in vapor degreasers and parts cleaners . o Past and present control and monitoring of radionuclides and organic emissions . o Control of chromium emissions , if any, from cooling towers currently in operation . o Emission potential of fugitive dust sources such as roads . o Design of controls and administrative procedures in the operation of the . : Rad handling facilities . o Potential for asbestos emissions during building decontam'fnatf:oin o r demolition . o Effluent sampling and monitoring operations . Throughout the Survey, emphasis will be placed on assessing , the :avai'lable data to characterize the overall environmental impac t ':pf``plr.an't-ope rations . 3.2 Records Required Files wil l be reviewed as part of ..the `-Survey; _ including documents not yet reviewed or received (e.g., classifies . documents ; individual files , documents not yet identified ) . Specific documents, a'd files to be reviewed as part of the Survey include, but . fll nut be limited to , the following : o PSD ledge r o Air effa%ent tamp 7 fp.g ;and QA procedures o Ambient aft. sampling and QA procedure s o Contractor stack test results o Effluent sampling result s o Laboratory records on TSP analyses ( amoient) o Preliminary drafts of SARA 313 report s o Any other documents pertinent to air emissions from SSFL buildings HDMSP00042584 4 .0 HYDROGEOLOGY AND SOILS 4.1 Issue Identification The hydrogeology/soils portion of the Survey will examine the physical and chemical character of the subsurface materials relative to the environmental impact--actual and potential--that the site activities have on these two media . The result of operations at other nearby facilities has apparently contributed to groundwater contamination at the SSFL facility . The past and present use of radioactive materials at some facilities has contributed to known and potential sources of contamination . Each of the potential source areas where materials have been disposed of," stored, treated for disposal, or spilled will be visited during thee, .tite Survey . Since many of these potential sources are also related .to ._RCRkCERCLA, surface water, and radiation disciplines ; visits wil l be . coor'dinated :.':. with the team members specializing in those fields . Areas to=be :vTsite d include : o o o o Building 059 : SNAP Ground Prototype Test FatjitySodium Burn Pi t RMDF Leach Fiel d Interim Storage Facility o Groundwater Treatment Facilitie s o Holding Ponds and Basins L' mtenti-a1 contaminant source areas, an In addition to examining the actual ad evaluation of the monitoring systems -fbr t:.Qse areas will be performed . This evaluation will involve .' reviewin g- the hydrogeologic and subsurface ..by --formed`the site, the well system (location and characterizations p.6 construction ), and ta . .arnaly'sisz ' Information i'el` tive =.to..-the site geology and surface soils, groundwater regime, _. annmenta T-=tnoni tori ng programs and data will be reviewed at the site-,':, prior t~c3 '- rtd : after the site Survey visit . 4 .2 Records Rewired Documents and files that provide information concerning the presence of contamination , or the monitoring system for the groundwater and soils will be reviewed as part of the Survey . A general list of documents and records to be reviewed includes : o o o o o o o o Geologic and geohydrologic report s Groundwater and soil monitoring plans and procedures Environmental monitoring report s Monitoring well locations and as - built records Disposal area operation and closure plan s Groundwater and soil analytical data Environmental compliance audit report s Unpublished , in-progress, or planned groundwater studies HDMSP00042585 5 .0 SURFACE MATER/DRINKING WATER 5.1 Issue Identification The focus of the surface water/drinking water portion of the DOE/SSFL Survey will be on the potential for release of polluted or contaminated wastewaters to surface waters draining the site or to groundwater aquifers underlying SSFL. Pathways for off-site migration of pollutant may include : .0 Releases (accidental or planned) to the sanitary sewers, retention basins, or to the storm drains . o Spills or leaks into permeable soil areas . o Exfiltration of sanitary wastewaters into soils or groundwater . o Contaminated surface run - offs into storm drains , retention .'basi'ns, Bell Creek Canyon, or , to a lesser extent, the Simi Valley . A review of available information indicates that considerable attention' has ,been paid to control of radiological releases . The Survey .viii a: ;sess the potential for future contamination of wastewaters, as..well' .. as"review present conditions of wastewater control and collectio1 ,system . Liquid waste sources, processes , collection and handling ` _equtpaient ".: will°'be examined and records of operation will be reviewed . The Survey will include identification of;;;: potentia1 discharges to surface waters, or to the on-site sanitary,treatfient facility at the Area III complex, which may not be addressed in operati .ngpermits or other documents . The site will be investigated forge-vidence of .-.:.possible breaks or obstructions in the sewer systems which -cottld * result in releases of wastewater to the environment . The Survey will also address `--. the: possibility of cross-contamination of the SSSFL water piping - ' stem by- •;efther the sanitary or storm drainage systems . Measures taken• io OrRvent back- flow of process wastewater or sanitary sewer flows into;.';he-water ` :d4 tribution system will be reviewed . With respect°;. to °wrastewater monitoring and treatment systems , copies of st°an .dard operating procedures will be reviewed . Operating logbooks and maintenance records will also be checked . Actual procedures put in normal practice by SSFL personnel will be observed to determine how closely SOP's are being 'followed . Interviews with managers and operators of monitoring systems Will be conducted in order to understand modifications or significant deviations , if any, from written SOPs . A walk-through of selected buildings will be made to observe normal routines, including maintenance activities which generate wastewaters . Discharge and monitoring points will be reviewed , and sampling and analytical procedures in use will be observed in action . Emphasis will be placed on the major contributors to wastewater generation , for example : o Cleaning and decontamination operations as practiced at SSFL . o The steam generator and ancillary equipment at the SCTI complex . HDMSP00042586 o The-sewage treatment and disposal plant and ancillary equipment at the Area III . o The service water and potable water treatment distribution systems . o Miscellaneous potential wastewater sources , such as the LLTR water systems, the HTF deaeration tank and test sections , heat exchangers, and cooling towers associated with SCTI , and other cooling operations . Wastewater collection , holding and transfer systems will be evaluated under normal operating conditions , as will the effluent monitoring stations . Site surface drainage characteristics , such as culverts, ditches and basins will also be examined , along with the man - made efforts to control surface run-on , and run-off . 5 .2 Records Require d Files will be reviewed as part of the Survey including documeftts .-r t yet reviewed or received (e .g., classified documents , individual fT]es,'-docVii~erjts not yet identified ). Specific documents and files to,.be reviewed as -part of the Survey include, but will not be limited to , the folowing .: o Documentation of ongoing NPDES permit compl .i anc _: : ' .,. ' o Recent analytical data on wastewater reieasesI.to .the receiving stream(s) . o Notices of violations relating to wa'stewato r rreleases , if any . Operators logbooks and'monitoring.'reports . o Standard operat _tng procedures for wastewater collection , transfer . holding and o Progress- reports <' 9.r ongoing improvements and studies, e .g., upgrade of er.f::genitortnq" system ; improving the quality of flow measurements ; the- .wat data ':on `stormw ter run-off characteristics . o Sampling p? tocols and logbooks . o Monitoring equipment maintenance records . o Detailed drawings of the sanitary and fire protection water supply, storage and distribution systems . o Additional information on the sediment sampling program , data handling and correlation with surface water quality . o Records of drinking water quality . o Internal memos or correspondence relating to surface water /drinking water problems, e . g ., back-flow prevention measures . o Other records as determined on-site . HDMSP00042587 6 .0 SOLID/HAZARDOUS/MIXED/RADIOACTIVE HAST E 6.1 Issue Identificatio n The solid/hazardous/mixed/radioactive waste Survey will be carried out by evaluating all activities generating such wastes, and the facilities used for their accumulation, storage, processing, treatment and disposal, including treatment and/or disposal at off-site facilities and wastes received from offsite facilities . The management of all solid waste streams including mixed wastes , hazardous wastes, radioactive wastes, and non-hazardous non-radioactive wastes will be surveyed . The Survey will consist of several activities : 1) Physical facilities where wastes are generated , accumulated , stored , treated, recycled, processed or disposed will be evaluated ; 2) Management and operations personnel involved in these activities will be interviewed ; and 3 ) Docuinents pertaining to wastes will be reviewed . Based on these acti 4hies , potential for releases that may contaminate the environment will• :.:t-e ewdluate ., SSFL generates a variety .of solid wastes , with all waste& currently generated originating from maintenance , laboratory , experimental 4n& .-:decontamination operations . Waste generating and processing faci 1 iti-es '•that`• .will be evaluated . Personnel from divisions with waste mv 'nage.inent"•re'Sp-ansibilities will be interviewed in order to give a deta :iled°°(tnderstan _Ling of waste management practices. This includes personnel w it4i laie operations responsibilities and those responsible for the overa-7•1 '$dmfflf•stra' tion of SSFL environmental programs including Rocketdyrt.e'-. environmental staff members with responsibilities at SSFL •- ;:DOE faci l tties ... This will include the experimental facilities and the RMf . The SSFL site has:-..')istaricaiiy : been the site for a number of DOE experimental reactors . S 3 :e.ra1 af' `thee eitperiments and the buildings housing them have already been terminated and decontamination and decommissioning carried out . Several bu`is#.jtgs remain which must be .decommissioned and/or decontaminated . This* in:eludbcii 1dings B-009 , 024, 028, 059 , and 665 . Groundwater intruding into .-B;-0590':has been radioactively contaminated . Issues relating to decontamination and decommissioning will be evaluated . Large: scale experimental programs relating to synthetic fuels were conducted at the Bowl Area . Although these experiments have been finished , residues remain within the process equipment which have to be disposed . The Bu rn Pit and possibly other old disposal areas contain wastes which will have to be disposed as part of a cleanup program . Both the Bowl Area and old disposal areas will be evaluated for potential cleanup wastes ( both radioactive and hazardous) . Rocketdyne facilities handling DOE wastes, including the hazardous waste storage area and the sewerage treatment plant will also be evaluated . The solid waste Survey will be coordinated with the CERCLA Survey to identify past and present waste management practices that may result in releases of contaminants to the environment ( e.g ., Burn Pit ) ; the radiation Survey t o HDMSP00042588 identify problems with wastes containing radioactive constituents (e .g., Decommissioning Issues ) ; the surface water /drinking water Survey since water and wastewater treatment produce solid wastes ; the air Survey to identify any solid wastes produced by air pollution control devices ; the TSCA Survey to identify any problems with PCB wastes and underground storage tanks for hazardous substances ; and the hydrogeological and soil Surveys to identify groundwater and soil contamination resulting from the accumulation , storage, treatment and disposal of solid wastes and contaminated facilities (e.g., B059) . 6.2 Records Required Files will be reviewed as part of the Survey, including documents not yet reviewed or received (e .g., classified documents, individual files, documents not yet identified) . Specific documents and files to be reviewed as part~" ;o f the Survey include , but will not be limited to , the following : o Part A and Part B Application related correspondence and a ssbc'atid NODS . o Underground tank storage notification and associated .rrecords, and' tudies . o Audit and/or inspection records ( state , local., and_•fed .era'-l' DOE and SSFL ) o Groundwater monitoring , sampling, an d. anal-yti-cal ,- documehtation . o Release notification and/or occtrrencerecords .' . o Biannual Hazardous Waste Generatfor),'Report, Annual Report of Hazardou s Waste activities . % o Waste inventory .dd'cumentation :.. o Solid Waite Managefent 1h 't Studies and Documents . 0 EnforcemeTjt acttOvt documents . CAr.'respondence with regulatory agencies on solid waste . 0 `-Records dealing with the reuse /recycling of wastes . o Training records . o Decommissioning Plans, Studies, etc . HDMSP00042589 7 .0 TOXIC SUBSTANCES 7.1 Issue Identification The toxic substances Survey will review the use, handling, storage, and disposal of polychlorinated biphenyls (PCBs), asbestos, pesticides, and other hazardous substances used on the SSFL site . The control, tracking, and management of toxic substances will be evaluated through interviews with appropriate personnel, tours of facilities, as well as a review of documents such as purchase and usage records . The primary objective will be to assess the potential for releasing these materials to the environment . The Survey will assess inventory control of any PCB-containing and PCBcontaminated electrical, lubrication, and hydraulic equipment still utilized at the plant . The condition of this equipment, its potential for leakage-, attd the quantity of PCB fluids contained will be considered . Obsolete, stored, oar used PCB equipment will be inspected for proper containment,an :d- adequate .. storage protection (e .g., B-231, Area II) . Handling, removal, - :a:nd .,disposa practices will be reviewed for current and previous inventQ.'ries t d'-*.-esTablish the method of disposal and location of disposal sites . Conformance to' .TSCA reporting regulations for PCB transformers and spill `-, .will .. be~"evaluated . In addition, a review of any PCB spills and cleanups wi .l1'•:,be conducted . A review of the phase out of PCB transformers anq. .ottie .I-_PCt, equipment will b e conducted . The use of asbestos will be determ (freons ) and chloroorganic solvents . Otper'Acord-s -as determined on-site . HDMSP00042591 8 .0 RADIATION 8.1 Issue Identificatio n Radiological issues to be addressed during the Environmental Survey will center around the air, soil, surface water, and groundwater media . Each of the above mentioned media will be evaluated for radiation concerns by collecting background information and data (including ambient data), identifying existing and decommissioned radiation pollution sources and associated controls, and finally by reviewing environmental monitoring programs designed to gather data on identified pollution sources . The Survey will also evaluate rad-waste management practices, direct radiation exposure issues, dose assessment methodologies, and radiochemistry quality assurance programs for environmental monitoring data . Review of rad waste programs including management practices for low-level, transuranic ;- radhazardous (mixed), and adherence to SSFL procedures will be a major-* focuof the radiation portion of the Survey . A more detailed discussion of th' s . subject is provided in Section 6 .0 of the work plan .. ;-The ~•rItifa,>l,0gica't evaluations will be closely coordinated with the other specia U sts'•~r th e Survey team . I Because radiation issues cut across all medial evaTuated during the Survey, the attached daily agenda has been organized . iris:=an -attempt •_to dverlap the other specialists ' activities when they are Qe:yal'uatiiag. radiation issues . Some inefficiencies are to be expected as,!a re lilt `"Of tin's dual coverage approach, however, every effort has been made lmize ;;duplication . To improve the effectiveness of radiation evaluationt,, Mt . ,~:Prancis will rely heavily on the expertise and assistance , of various SSf1, personnel for accomplishing Survey objectives and pointing out where work 04an inefficiencies exist . Discussions with operating and., _supervisory Rerstmnel will also be utilized to provide needed informative} `criticail evaluation . Reports, records, and other data asociated :iwith • :Drrtinuous , intermittent , and any accidental or unscheduled re leases ' should be readily accessible for review. 8 .2 Records ';ui refit Files' "::will `t reviewed as part of the Survey, including documents not yet reviewed or received ( e.g., classified documents , individual files, documents not`-fit identified ) . Specific documents and files to be reviewed as part of the Survey include, but will not be limited to , the following : o NRC license and supporting information documents . o California license and supporting information documents . Radiation- related ambient air quality information . o Background radiation data for soil, surface water , and groundwater . o Inventories of air, soil, surface water, and groundwater radionuclide release points and quantities . o Vegetation radionuclide monitoring data . HDMSP00042592 o Unscheduled or accidental release reports . o Radioanalytical quality assurance programs and procedures . o Dose assessment methodologies , reporting, etc . including assumptions , calculations, o Building plot plans with process and equipment locations . o Description of radiation monitoring equipment practices and procedure s ( e .g ., calibration , maintenance , etc .) . o Reports or recommendations for upgrading radiation monitoring systems . o Reports prioritizing new radiation monitoring installations . o Off-site and on-site radionuclide sampling point criteria . o Rad- waste management practices, policies, procedures .,and cotiaurri,catio n mechanisms . o NESHAPS /DOE Subpart H 61 .90-61 .98 reports . o Information regarding employee radiatio rlexp sure• ;dfata .' .t~r'log ' and locations'oHistrcald-weispoalctv . o State, County and local radi 6t1on ':reg 6lat ons . HDMSP00042593 9 .0 QUALITY ASSURANCE 9 .1 Issue Identification The quality assurance phase of the Environmental Survey will be primarily an evaluation of the sampling and analytical capabilities at the SSFL . The objective will be to review and verify the quality assurance procedures for obtaining process effluent and environmental samples, performing the analyses to measure the concentration of pollutants , and the handling and reporting of the data . All aspects of the quality assurance program relating to environmental management of DOE activities at the Santa Susana Field Laboratories will be reviewed including : operator training ; equipment and instrument calibration / maintenance ; precision and accuracy evaluation ; blank, split, and spiked sample analyses ; sample handling and chain-of-custody procedures ; data reduction and validation ; data reporting and documentation ; as well as the review of calculations and logbooks . The procedures used for sampling and analysis will be monitored to ensure-' ; proper implementation and conformance with accepted pract :i'ces . t e. quality assurance program will be reviewed for the sampling and ana l ytical 'activ 1 ties, and also for any internal quality assurance audits that have , .-been 'conducted . Furthermore , the interlaboratory test programs pa :-rtic.ip.at 'ed. in by the environmental analytical laboratories , as 'a ; mini ittered by the DOE's Environmental Measurements Laboratory and' the 1 nvirrlnm0ntal Protection Agency will be evaluated . The quality assurance ;. p .roce'dur6l . of a y off- site sampling and/or analytical laboratories utilized by~the 'p .ant~will also be reviewed in this Environmental Surve y. 9.2 Records Required Part of the Survey w1,11 censi st of a rev i ew of pertinent files . This will include documents:`,rro't prev `Iously ;` reviewed or received , such as classified documents ( i.f any , . individual files , and documents which have not been identified - a this time . S documents and files to be reviewed in this phase of St},e Surve~r :- i'ncludespecific , but will not be limited to, the following : En'vironmentaT- ' sampling and analysis quality assurance `•- .Analytica l. Chemistry L programs of the laboratories (Chem . and Met pr . Lab , SSF -,laboratory , Control Unit.and radiological measurements laboratory) and Environmental o Quality audits of the analytical laboratories and sampling programassurance . o Analytical and sampling procedures manuals . o DOE and EPA quality assurance results of performance evaluation samples . o Quality assurance reports for the Analytical Chemistry laboratories conducting environmental analyses . o Training policy and records for laboratory personnel . the sample collection and analytical HDMSP00042594 o Maintenance and calibration records for the analytical laboratory and sampling instruments/equipment . o Laboratory notebooks , data reporting forms, chain-of-custody procedures, and sampling logbooks . HDMSP00042595 10.0. INACTIVE WASTE SITES/ RELEASES ( CERCLA) 10 .1 Issue Identification The Survey will attempt to identify environmental problems and potential risks associated with the historical handling, storage and disposal of hazardous substances at SSFL . This aspect of the Survey will be coordinated with the RCRA and hydrogeology team members . The Survey will focus on current an d future risks related to the following : o Past land disposal practices ( on and off- site) ; o Past spills/releases from tanks, pipes , pits , trenches ; o Potential'for future spills / releases ; and o On-going remedial action program . Facilities that have handled or are currently handling hazardous , '--mixed., and low-level radioactive substances at SSFL will be evaluated :: The following areas identified in SSFL documents' :will be~.. evaluated RMDF B /021, 022 No Burn Pit B/886 Landfill B/059 Salvage Yard (Rocketdyne Classificatio n - CHCF B/46 3 SRE B/143 B/003 Hots .Ca Ie STIR LY45 ERTF _ 8,lOr Q - : : :. >GPTF B059 K WBMI%07 3 The". status of_,.activities undertaken pursuant to DOE Order 5480 .14 and SARA Sectign' 120 wi'll be assessed . Records of past off-site disposal from SSFL wilT .be reviewed . Sites that have undergone or are undergoing remediation will be addressed . Records and analytical data in support of the site cleanup will be reviewed . Also, inactive tanks or containers that may have held hazardous substances will be identified and their status assessed . Former storage areas and staging locations will be included in this effort . The team will also want to review the environmental records pertaining to the past management, disposal (on-site and off-site), clean-up, and regulatory compliance . Contacts for this portion of the Survey will include personnel from Facilities & Industrial Engineering, and Environmental Control & Engineering . 10.2 Records Requi red Files will be reviewed as part of the Survey, including documents not yet reviewed or received (e .g ., classified documents, individual files, documents not yet identified) . Specific documents and files to be reviewed as part of the Survey include, but will not be limited to, the following : HDMSP00042596 o Past waste management plans . o SOPs regarding management of hazardous substances , storage areas . disposal area and o Hazardous substances inventories . o Listing of areas used for hazardous substances storage , shipping , and disposal . o Historical files on past operations and processes , methods of handling and disposal . receiving and substances used, an d o Files on past off-site waste handling and disposal . o Records of facility expansion and building rubble disposal . o Descriptions and Notifications of inactive waste si .ttes aw ., -D"enti al ' areas of contamination . . o Description of all waste management facilities ;; inclt&i 4 .'.Ourtal tank s and structures ( existing and removed) . o Historical aerial and surface photographs ".af the. facia`lty . o "Interview files" (18 pers o~s}foahe t' :d-~raft Phase I Installation Assessment report (Adler et.al ;. 19,6 ) o Files pertaining to any radiometric irveys of the site grounds . o Documents Pertfiling to .:at : current , and proposed remedial actions (e.g., RMDF Leach, .F :eld)'.;at SSFL. o Environmental record s•pertaining to past facility responses to hazardous su b st ance:: pills and releases HDMSP00042597 AIR/TSCA - J . CRIS T MONDAY , MAY 16 TUESDAY , MAY 17 . ' . WEDNESDAY , MAY 18 THURSDAY MAY FRIDAY MAY 20 -Introductory Brief- -Tour Rad and ..Ot-her, .,, r'Tour Non-Rad Emis -Review Permitted -Visit Ambient Ai r ings & Site Orients Emission Sources : si,ons Sources : 006, Sources at Buildings Monitor s tion 021, 022, 020, 023, g 008, 011, 029, 355-361 -Review Air Sources : 024, 025, 026, 05a : .° .: '03&,;032 -Air Permits Review -Tour Molten Salt Test 100, 114 , 13 3 057, 059, 062, 06 : . ... . . Facility (w/J . Boros) (w/M . Francis) -Review Fuel Use s -Review Asbestos Projects (w/C . Caruso -Findings Forms Du e For 1st Wee k MONDAY, MAY 23 -Inspect PCB Records Equipment & Storage for Disposal Area (231 in Area II) (w/C . Caruso) TUESDAY, MAY 24 WEDNESDAY , MAY -Review Hydraulic -Informal Debri"efin Test Instrumentation with SSFL Staff 'to~ ` 473, 863, 074, 075 Review Findings -Revisits -Writin g -Detailed Report Out- THURSDAY, MAY 2 6 ''•Ass .ist Team Leader s 1p .preparing fo r Final . ,Close-out .w`Deb'r .ie#ing -Final C1 .6..e-out, . , line & Findings Form Debriefing for, :SS.FL , Due Management . : : : ; : GROUNDWATER /SOILS - D . DETMAN MONDAY, MAY 16 TUESDAY, MAY 17 . .< -Introductory Brief- -Tour RMDF Surface ings & Site Orients Impoundments, & tion Retention Basins -Tour Site Area to (w/J . Boron) -Observe Monitoring' Observe Groundwater Monitoring Well Well Construction Locations with Construction & Locations, & ReRespect to Surface covery Well Location Impoundments & Systems WEDNESDAY , MAY 18 THU RSDAY MAY -Tour Building B/05 9 -Review Groundwater ° • (w/M . Francis) Monitoring Data - T:gir Sodium Burn Pit -Organize Findings ~?.'and': .Interim Storage thus far ',Facility •: :' .` FRIDAY MAY 20 -Meet with Sit e Groundwater Consulta n Staff to Discuss Pro gram Implementation in Past, Present, an d Future (may b e scheduled May 23 i f more convenient ) '• ' -Findings Forms Du e For 1st Wee k MONDAY , MAY 23 TUESDAY, MAY 24 -Tour Soil and -Catch-up Day for Vegetation Sampling Revisits, Tours of Locations (may be Other Areas as scheduled for May 20 needed, or writing if necessary to suit -Review Additional Groundwater ConsulFindings with Tea m tant availability) Leader s -Review Soil an d Vegetation Samplin g Data WEDNESDAY , MAY'25~" THURSDAY, MAY 2 6 -Informal Debriefing =Assist Team Leader s with SSFL Staff t.6 ; #n .preparing fo r Review Findings 'inal Close-ou t -Revisits, as needed, ;~Deb,r' fin g :.4 or writing ritin g -Detailed Report Outline & Findings Form Due -Final ClD,'e-ou't Debriefing for ,SSF L Management ` : `: SURFACE WATER/ DRINKING WATER - JOE BOROS MONDAY , MAY 16 TUESDAY, MAY 17 -Introductory Briefings & Site Orient s tio n -Tour Sewage Col- -Tour RMDF, Surfa~~e•°' Impoundments & Retention Basins •"`'' ~ (w/D . Detman ) - Observe NPDES Moni- ;; toring Stations, lection System (Area IV) & Sewage Treatment Plant Stormwater Run-off (Area III) Systems & Other Parts of Water Reclamation WEDNESDAY, MAY 18 THURSDAY, MAY 19 FRIDAY , .;'-Observe Surface -Tour Molten Salt -Review Sources us i n g Water Sampling Test Facility (w/J . Septic Tanks & Leac h vities,'incIud . Crist) Fields, e . g ., RMD F ~- .pe }' very of Sample s -Review Service Wate r Leach Fiel d `a, ;i4nalytical Labor- ( on -site wells p lus T our L arge Leak Tes t atori ; potable water from Rig - Bldg 05 9 -.T-q:ur'Copl,i ng Towers Ventura Count y :;Ce•~'; 6,1 b ) & Water Waterworks Distric t s " (701 .-A 702) 17) Distribution System -Findings Forms Du e For 1st Wee k MONDAY , MAY '23 TUESDAY . MAY 24 -Tour SCTI, Bldg . 356 -Tour Hydraulic Test (w/R . Basinski ) Facilities 473, 863 -Discuss Drinking & 873 (w/J . Crist) Water Distribution -Catch-up Day for & Control Systems with SSFL Staff -Review and Observe Revisits -Organize Additional WEDNESDAY . MAY „2S'; . THURSDAY, MAY 2 6 -Informal Debriefing' ;;- '`-Assist Team Leader s with SSFL Staff'io' ,in preparing fo r Review Findings •Fjnal,Close-ou t ~.`Debry.e"fing -Review & Revisit as Neede d -Writi .n g Finding s Back-Flow Prevention - Review Spill PreMeasures vention & Counter-Review Data measures Plan w / SSFL Staff - : " -Detailed Report Outline & Findings Form Due -Final Cllate-out l.',t Debriefing for,FL , Management . ; ,r " RCRA - R . BASINSK I MONDAY , MAY 16 -Introductory Briefings & Site Orients tion -Tour Building 020 Hot Lab TUESDAY , MAY IT . ` . .'. . WEDNESDAY, MAY 18 -Visit RMDF 02.Y ;•022 *Tour Inactiv e (w/M . Francis) •• "' Facilities at 009, ;I?,, 024, 059, 064, -Visit 044 RMDF Clean Shop 453, 457, 614, ~ 665?. i -Tour Labs and Sh~ ~ . at 062, 065, 066, .~ 163 THURSDAY MAY -Tour Storage Areas & Buildings : 015, 025, 030, 041, 171, 459, 500, 583, 626 (w/M . Francis) FRIDAY . MAY 20 -Visit Storage Area s & Buildings 008, 029 , 07 5 -Tour Decors Traile r Bldg 11 4 -Visit Sodium Bur n Facility - 13 3 • Y -Findings Forms Du e For 1st Wee k MONDAY , MAY '23 TUESDAY, MAY 24 -Tour X-ray and Rad -Tour Sodium & Liq uid Metal Facili - Labs and Facilities ties : 006, 007, 014, 172, 173, 185, 473, 013, 032, 057, 314, 355, 356, 357, 358, 360, 361, 462, 463 , 320, 600, 610, 656 621 WEDNESDAY , MAY' 2 e. .'.~' -THURSDAY, MAY 26 -Informal Debridfin . Assist Team Leader s with SSFL Staff 'tai'`~ ' .. ch preparing fo r Review Findings , ,•' ; ;~~nalClose-ou t •`' ,'D~r'j efing -Revisit s " • -Detailed Report Outline & Findings Forms Due -Final Clae=oGt Debriefing for .SSF L Management . ; ; :, QA/TSCA - C . CARUS O MONDAY , MAY 16 TUESDAY, MAY 17 , WEDNESDAY , MAY 18 THURSDAY 19 -Introductory Brief- -Evaluate organ,ic,& Review Toxic Sub-Review of Asbestos ings & Site Orients inorganic labs incld s .tance Management, Program incld . use, tion policies, manuals , .. : S-t~tage, use, Distraining, handling, -Review of Analytical chain-of-custody;:' etc . removal, storage, Labs : general redata management, . RReufiew Bulk Chemical disposal, etc . quirements, organicalibration, train-'' : & Fue-1 ;Storage, Visit (Health, Safety and zation, records reing, use of spikes,` Ste 00.5, 022, 064, Environment) quired (ETEC Chem & blanks, duplicates, ".30`(SCTS) :, 462, etc . -Review Ground Water Met . Lab) etc . (SSFL Analyti('#':1,ant Services) Sampling cal Lab) -Water QtjT .t? Moni toripg ;(w/J . Boros) FRIDAY MAY 20 -Radiation Labs (QA / QC) incld . : policies , manuals, sample track ing, data mgmt, cali bration, training , use of spikes, blanks , duplicates, etc . Building 100 (w/M . Francis ) -Findings Forms Du e For 1st Wee k MONDAY, MAY 23 -Review PCB Records & Facilities incld . transformer & PCB materials storage area (B231) (w/J . Crist) TUESDAY, MAY 24 WEDNESDAY , MAY,25'..,` JHURSDAY, MAY 2 6 -Review of Pesticide -Informal Debrief irr~ ;e Assist Team Leader s Program incid : use, with SSFL Staff 'to ,in .preparing fo r handling, storage, Review Findings `Final .,Close-ou t training, disposal, .-'Delr.i .efin g -Writing and/or etc . (Plant Service s revists .-Writing-arid/or revi s -Revi ew sma ll quanti ty chemical storag e areas, bldgs 20 6 (CTL-2), 360, 435 , 023, 065, etc . -Detailed Report Out- -Final C th e-ou t line & Findings Form Debriefing f o Due Management RADIATION - M . FRANCI S MONDAY , MAY 16 -Introductory Briefings & Site Orients tion -Review Facility Radiological Survey Plan and Results to Date TUESDAY , MAY 1 7 -Tour RMDF ("fo'l'low, . . . process flow) B/021' & 022 (w/J . Werner),, -Review Stack Mond:- -• toring, HEPA Program, Decon, Hot & Cold Change Rooms (w/J . Crist) -Discuss Rad Monitoring Systems WEDNESDAY , MAY 18 -Tour Building B/059 (,w/ D . Detman) ;=Tbcr Bldg . 020 !.! y< ;: : ,< . THURSDAY MA Y 19 -Tour Storage Areas, e .g ., B /015, B/025, B/030, B/041 and Others (w/R . Basinski) -Tour Sodium Burn Pit & Interi m Storage Facil i ty -Review Rad Dat a FRI DAY MAY 20 -Visit Radiation La b -Review Current Statu s of Radiological Sur vey Programs and Pla n (observe techniques , if possible ) -Findings Forms Du e For 1st Wee k MONDAY, MAY 23 -Review Perimeter Monitoring Program -Review Direct Source at B/022 & 021 incld Spent Fuel Assemble Evaporator Sludges Source Materials B/621 Packaged Waste B /075 TUESDAY . MAY 24 - Review Dose Assessment Procedures : Pathways, Maxi mally Exposed, Population, Methodologie s -Catch-up Day fo r Revisits, Tours o f Other Areas a s needed -Writing and Or ganizing Findings WEDNESDAY , MAY -Informal Debriefing :;, with SSFL Staff 'toe' Review Findings THURSDAY, MA Y 2 6 -Assist Team Leader s < `ln',Jpreparing fo r 'F1nal .,Close-ou t >'pebr .eTin g -Revisits as Neede d -Detailed Report Outline & Findings Form Due -Final C1,6se-ou t Debriefi'rig for .$.SFL Management CERCLA - J . WERNE R MONDAY, MAY 16 -Introductory Briefings & Site Orients tion -Review Document Archive Index -Request Documents -Review Historical DOE Activities & Tour Selected Sites TUESDAY, MAY 17. .', :••: WEDNESDAY, MAY 18 -Visit RMDF 022, & Sodium Burh' Pit B/886 FRIDAY 14AY 20 i-Visit : Salvage Yard/ -Tour RCRA Surface Rpcketdyne Conserva- Impoundments, CHCF B/463 Yard -E-9/F-3 Disposal .: :'' ;SRk"--B/143 NW LandReview Files Storage Areas °`t• -r•Vy, at B/059 -Tour and Revie w Records for B/00 3 Hot Cave, B/028 STIR , B/OlU ERTF, B/05 9 GPTF, B/073 KEW B -Review Files -Review File s :'r -Revi,ewFiles ° ,, . . r. ° • '+ MONDAY , MAY 23 THURSDAY, MAY 19 TUESDAY, MAY 24 -Revisits as Needed -Revisits as Needed -Review Files -Review Files a WEDNESDAY, MA1~ .28'r -Findings Forms Du e For 1st Wee k THURSDAY, MAY 2 6 -Informal Debriefi,n " ;~ ''-Assist Team Leader s with SSFL Staff 'o~ •. n-'.=~reParin9 fo r 1, Review Findings °, ; : ` .Final, .Close-ou t -Revisits -Writing 0ebr:iefin g ° -Detailed Report Out- line & Findings Form Due -Final Cl. seou t Debriefk•ng for-SSF L . Management s• y?tnd?f; Kilo ACRONYMS APPENDIX D CHEMICAL SYMBOLS , ABBREVIATIONS , AND ACRONYM S ACM Asbestos Containing Material s AEC Atomic Energy Commissio n AIRDOS Estimation of radiation dose caused by airborne radionuclides in area s surrounding nuclear facilities Al Atomics Internationa l ALARA As Low as Reasonably Achievabl e a. m . Ante-Meridiem (before noon ) ARAC Atmospheric Release Advisory Capability Avg . Average BOD Biochemical Oxygen Deman d BOD5 Biochemical Oxygen Demand (,S-daft) •, °C Degrees Celsius (or centigrade) CERCLA Comprehensive Envlronmki to .Response' Compensation, and Liability Ac t CFR Code of Federal Regulations ` CG Concentration Guide , CHCF •' .: ` .< ' omonent Handling and Cleaning Facility Ci Curie( s~ . . ''• cnm s: Centimeter(s) C+' : ; . Cyanid e Carbon Monoxid e COI)- Chemical Oxygen Deman d Cr Chromiu m Cr+6 Hexavalent chromiu m Cs-137 or 137Cs Cesium, isotope 13 7 CTL Component Test Laboratory Cu Coppe r cu . ft . Cubic feet Cu . yd . Cubic yard(s ) DCG Derived Concentration Guid e D&D Decontamination and Decommissionin g D-1 HDMSP00042606 APPENDIX D CHEMICAL SYMBOLS, ABBREVIATIONS, AND ACRONYMS PAGE TWO DOD Department of Defens e DOE Department of Energ y DOT CL Department of Transportation Classificatio n DPM Disintegrations per minut e ECU Environmental Control Uni t ENE East-Northeast e .g . (exampli gratia) for exampl e EPA Environmental Protection Agenc y ESADA Empire State Atomic Development Authority,, . ." .. . ESE East-Southeast a -. . et al . (et alii, aliae, or alia) and othef's* . ETEC Energy Technology Engir eeficEg' en ter-'-w,' .. OF Degrees Fahrenhei t FFTF Fast Flux1 st Facilit y FIFRA ft . FTS .: eral Insecticide, .Fungicide, and Rodenticide Ac t eet, *dot FaEtttity'_Test Syste m Fl7SFAP '_ .'"' '> a :Formerly Utilized Sites Remedial Action Progra m g . .,' =• Gram(s ) .gkcl Gallons per day gpm Gallons per minut e Gal . Gallon(s) hr hou r ha . Hectare(s) HEPA High Efficiency Particulate Ai r HP Horse powe r HS&E Health, Safety and Environmenta l HTF Hydraulic Test Facility ICRP International Commission on Radiological Protectio n i .e . (id est) that is D-2 HDMSP00042607 APPENDIX D CHEMICAL SYMBOLS , ABBREVIATIONS , AND ACRONYMS PAGE THRE E in- inch(es ) Inc . Incorporate d kg Kilogram(s) kg-cal Kilogram-calorie(s) km Kilometer(s ) KP-1 Cooling water treatment chemica l KW Kilowat t Liter(s ) LA Los Angele s Ibs . Pound s LLTR Large Leak Test Ri g LMFBR Liquid Metal Fast Breeder R a .t8 ;;, I pd Liters per da y Ipm Liters pet ;minut e m Met`e`r(s) Max . X+axi .ixru m uCi Mf°crQcuite(s ) mC~''"^ -Med'. - illicurie(s ) Media n fig . Microgram(s ) Mg, Magnesiu m mg Milligram(S) mg/I Milligrams per liter mi . Mile(s ) Min . Minimu m mgd, MGD Million Gallons per Da y ml milliliter(s) mid, MLD Million Liters per Da y mm Millimeter(s ) Jim Micrometers D-3 HDMSP00042608 APPENDIX D CHEMICAL SYMBOLS, ABBREVIATIONS, AND ACRONYMS PAGE FOU R MPN Most Probable Numbe r mrem Millirem(s ) mrem/yr Millirem(s) per year (10-3 roentgen equivalent man/year ) MSDSs Material Safety Data Sheets MW Megawatt N North ; nitrogen Na Sodiu m NA Not Analyzed NASA National Aeronautical Space Administratio n NCRP National Council on Radiation Protection mid Measurements ND None detected NE Northeast NEC Nuclear Engineeringompaity ° NESHAPs National` Emission Standards fir Hazardous Air Pollutant s ng } A00,grams.: NNE rt1 `Iqorthe a NNW North Northwest .: ' Now ""` :4 umber(s) Nbfi Not Otherwise Specifie d "NO2 Nitrogen dixoide ; nitrite NO3 Nitrogen trioxide ; nitrate Np-237 or 237Np Neptunium, Isotope 23 7 NPDES National Pollutant Discharge Elimination Syste m NPL National Priorities List NRC Nuclear Regulatory Commission NTU Nephelometric Turbidity Unit s NW Northwest 03 Ozon e OSHA Occupational Safety and Health Administratio n PCB Polychlorinated biphenyl D-4 HDMSP00042609 APPENDIX D CHEMICAL SYMBOLS , ABBREVIATIONS , AND ACRONYMS PAGE FIV E PCT Polychlorinated terpheny l pCi Picocurie(s) pH Negative logarithm of the hydrogen ion concentratio n PM10 Particulate matter 10 microns or less in diamete r ppb Parts Per Billio n ppm Parts Per Millio n Pu-239 or 239Pu Plutonium, Isotope 23 9 QA Quality Assuranc e QA/QC Quality Assurance/Quality Contro l QC Quality Control RCRA Resource Conservation and Recovery Act RCW Recirculating Cooling Water '.: . RFI RCRA Facility lnvestigpt on ' RMDF Radioactr e.Material Disposal facility ROC Reactive Organic Cot found s S Soto, skfu r 5&A :.sampling and Analysi s .; ;'• Superfund Amendments and Reauthorization Act of 198 6 SCTI Sodium Components Test Installatio n SCTL Sodium Components Test Loo p SDWA Safe Drinking Water Act sec . Second(s) SFMP Surplus Facilities Management Progra m SNAP Space Nuclear Auxiliary Powe r S02 Sulfur Dioxid e 504 Sulfat e SOP Standard Operating Procedure(s ) SPCCC Spill Prevention, Control, Countermeasures, and Contingenc y SPTF Sodium Pump Test Facility D-5 HDMSP00042610 APPENDIX D CHEMICAL SYMBOLS , ABBREVIATIONS , AND ACRONYMS PAGE SIX sq. ft. Square feet sq . mi . Square mile(s) Sr Strontiu m SRE Sodium Reactor Experimen t SSFL DOE activities at the Santa Susana Field Laborator y SSTF Static Sodium Test Facility i s SSW South-Southwes t Std . Standard STLC Soluble Threshold Limit Concentratio n STP Sewage Treatment Plant s. u . Standard units SW Southwest Temp Temperature `. : Th-230 or 230Th Thorium, isotope 230?, TRC Total Residual Chlorine, . TRU Trams jra nGc-- TSCA . dzic Substan es-Control Ac t TSP • c ° '. ° istat'Suspjp nded Pa rticulates TSS Totafiuspended Solid s TTF. ;thermal Transient Facility ,TTLC Total Threshold Limit Concentratio n U, Uraniu m U•=235 or 2350 Uranium, Isotope 23 5 U-238 or 238U Uranium, Isotope 23 8 U .S . United States VCAPCD Ventura County Air Pollution Control Distric t VOC Volatile Organic Compound s W West, tungste n WAA Waste Accumulation Area(s ) WNW West-northwest WSW West-southwest Y3 Cubic yard(s ) Yr Year(s) D-6 HDMSP00042611 APPENDIX D CHEMICAL SYMBOLS , ABBREVIATIONS , AND ACRONYMS PAGE SEVE N a Alph a s Bet a a Sigm a Percent Minute(s) Second(s ) Approximatel y Greater tha n Less tha n Numbe r And (and per se and = amperfird ) Pe r ± I Plus or minus