Free Statement of Facts - District Court of Federal Claims - federal

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Exhibit 26-C

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Section

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TOXIC & CHEMICAL MATERIALS August lOSe Page 3 of 40

° TOXIC AND CHEMICAL MATERIALS SCOPE OF AUDIT

Determinethe current status of PCBs and if practices and procedures conformto PCB regulations (40 CFR 761). 2. 3. 4. 5. Determine current status of asbestosand if practices and procedures the conform to asbestosregulations (40 CFR 61). Determinethe current status of aboveground storege tanks and underground storage tanks andif practices and procedures conformto applicable regulations. Determinethe current status of herbicides/pesticides and if current practices and procedures confon'n to regulations. Determine the status of chemical storage areas with respect to procedures, Material Safety. DataSheets,training andstoragepractices.

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TOXIC & CHEMICAL MATERIALS August1989 Page 4 of 40

TOXIC AND CHEMICAL MATERIALS FINDINGS AUDIT FINDINGS: TCM/AF-1 TCM/AF-2 TCM/AF-3 TCM/AF-4 TCM/AF-5 TCM/AF-6 TCM/AF-7 TCM/AF-8 TCM/AFo9 ImproperStorageof Herbicidesand Pesticides in Building 367 Building 865 PCB Transformer Lack of Proper La~els on PC8WasteTransport Vehicles UndergroundStorage Tanks (USTs) Inadequate Spill andOverflow Control Lack of Storage Dates on PC8WasteDrums Lack of AdequateSecondaryContainmentat PCB Waste StorageFacility Buildings 884 and 778 Inadequately Covered Asbestos the Active Landfill in PCB Spill Cleanup Annual PCB Reports

BEST MANAGEMENT PRACTICES: TCM/BMP-1 TCM/BMP-2 TCM/BMP-3 TCM/BMP-4 TCM/BMP-5 TCM/BMP-6 SecondaryContainmentfor Portable Aboveground Storage Tanks PC8Handling and Spill Remediation Lack of ProperLabeling of ASTs Building 991 at Lack of Secondary Containment Building 5Bt for Chemical Storage Area. Lack of SecondaryContainmentfor Permanent AST at Building 774 ImproperStorageof Chemical Materials in Building 331

Case 1:91-cv-01362-CFL
AtJdlt Dlsctollne 1 N

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Page 5 of 40 August 1989

TCM;~,F-1

Toxic and ChemicalMaterials (TCM) TCM/AF.1 ImproperStorage of Herbicides and Pesticides

Pesticides and Herbicides are not being properly stored in Building 367. Examples of deficiencies that wereol3ser~ed the Audit Team by include:

1)

Haphazard placementof herbicides and pesticides on top of drums, and on the floor in Building 367 hasled to spills andreleasesof stored materials, including the release of dimethylthiuron disulfide (deer and rabbit repellent) onto the concrete floor of the building. This latter release wasnoted on July 11, 1989, during an inspection of the building by the Audit Team. spilled materfal had The beenstored in a glass bottle in a cardboard whichwasplaced on top of a 56box gallon drum. The bottle burst due to high temperaturesin the building, soaked and eventually weakened cardboardbox, which then fell to the floor. By the the time the spill wasdiscovered, the material had begunto corrode the concrete. Thespill wascleanedup by site personnelon July 11, 1989, shortly after they were notified by the Audit Team.Additionally, several containers were being reused to store chemicalsother then the original materials. Thesecontainers wererelabeled but the original labels were unmarked still readable. This and practice could lead to the mixingandstorageof incompatiblematerials. During an inspection by the Audit Team July 11 and 12, 1989, it wasobserved on that a door was proppedopen, windowswere unlocked and open, there was no fire extinguisher available in the building, the heating unit wasinoperable, and there was no means ventilate the building other then by openingthe windows to or doors. Citation and Requirement8

2)

Applicable

40 CFR 165.10, Federal Insecticide, Fungicide, and Rodenticide Act. This citation establishes requirementsfor storage of pesticides that are classed as highly toxic or moderatelytoxic. At least one material in Building 367, Tordon, is included in this definition. 40 CFR 165.10(c) states that pesticides should be stored in a dry, well ventilated, separateroom,building or coveredarea wherefire protection is provided. It is further stated that the entire storage area should be securedby a climb-proof fence, and doors and gates should be kept locked to prevent unauthorized entry. Recommendations

1)

The materials stored in Building 367 should be disposed of in an appropriate manner, and the building decommissioned. Herbicides and pesticides are currently applied at Rocky Flats Plant by a licensed contractor andthere doesnot appear be a needto store themon-site. to

Case 1:91-cv-01362-CFL TCM/AF-1
August 1989

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2)

Until the building can be decommissioned, doors and windows the should be lockedandsecured. Adequate ventilation shouldbe installed so that excess heat build-updoesnot c~use chemical containersstoredin the building to rupture. Thedoorandwindows shouldbe inspecteddaily by site personnel ensure to the security tl~e buildlng. of
If the RockyFlats Plant (RFP)identifies a need to store herbicides or pesticides on-site, a storage facility conforming to the requirements of 40 CFR 165.10 should be constructed;

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Page 7 of 40 August1989

TCMIAF-Z

Toxic and ChemicalMaterials AuditFIndln(~ NUrrLb~ TCM/AF-2 Building 865 PCB Transformer Audit Findlno and Aoollcable Area labeling and flammablematerial requirementsof 40 CFR for PCB 761 transformers (transformers with over 500 ppm PCB) are not being met; ThePC8transformer in Building 865 contains 891,000ppmPC8 (I-TCM-10). The unit situated adjacent to a large pit area in Building 865 and supplies power to an EB furnace. Doors, hallways, and other means accessto the transformer are not labeled of properly. An inspection of the area by the Audit Team, conducted during active maintenance operations, revealed paper trash adjacent to and beneaththe transformer unit. Aoollcable Citation and Reouirements

40 CFR 761.30, Toxic Substances Control Act Combustible materials, including paper, mustnot be stored within five meters of a transformerenclosure. 40 CFR 761.40, Toxic Substances Control Act Thevault door, machinery roomdoor, hallway, or other means access of to a PCB transformer mustbe marked with Ihe large yellow PC8Mark. Recommendations Doors, hallways, and other means accessto the transformer in Building 865 of should be properly labeled with a yellow PCB warning label as required by 40 CFR761.40.

2)

Papertrash adjacent to and beneaththe PCB transformer in Building 865 should be removedand the area within five meters of the unit be kept clear of combustiblematerials as required by 40 CFR 761.30. Signs should be posted in the immediate area of the transformer that require the area be clear of combustiblesand state the regulations. Inspections by Plant Powershould be conductedon a random basis.

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Audtt

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Page 8TCM/AF-3 of 1989 August 40

Toxic and ChemicalMaterials TCM/AFo3 Lack of Proper Labels on PCB WasteTransport Vehicles

A.~dlt Flndlna Number ~LLIdlt Ftndlna TTtle Audit P~ndlna and Aoallcable Reference - -

Vehicles which transport PCB wastesare not properly labeled. Thereare no PCB labels on vehicles for the on-sits transport of PCB wastecontainersat the RockyFlats Plant (RFR)(I-TCM-9). Therequirementsof 40 CFR 761.40(a) state vehicles loaded with containers that contain morethan 45 kg (99.4 pounds)of PCBs the I~quid phaseor with one or morePCB transformers, musthavea yellow PCE~ label. A~ollcabte Citation and Reaulrements

40 CFR 761.40(a) Transport vehicles shall be marked each end and side with the large yellow on PCB Mark, if it is loadedwith PCB containers that contain morethan 45 kg (99.4 Ibs.) of PCSs liquid phase,or with one or morePCB in transformers. Re~ommendatlon~ Vehicles that are being usedto transport PCE~ containers or PC8 transformersshould be labeled with a yellow PCB label as required by 40 CFR 761.40(a).

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Page 9TCM/AF-4 of 40 August1989

Toxic and ChemicalMaterials Audit PTndlno Number ~.~ldit FTndlnd Title Audit Ftndlnq end Aoollc~ble Thereare no formal proceduresin place to minimize the risk of spills and overflows during USTs transfer operations. Thereare no formal procedures place at the Rocky in Flats Plant (RFP)for verification that the volume available in a USTis greater than the volume of product to be transferred, or to require that the transfer operationis constantlymonitored. Discussions with Building 331 personnel (I-TCM-3, I-TCM-4) indicated there were written procedures either governthe transfer of fuels into USTs, require constant to or monitoring the transfer operation. of Aoollceble Citation end Reoulrements TCM/AF-4 UndergroundStorage Tanks(USTs) Inadequate Spill and OverflowControl

40 CFR 280.30: Spill and Overflow Control USTowners and operators must ensure (e.g., via formal measures)that the volume available in the tank is greater than the volume of product to be transferred to the tank before the transfer is made that the transfer operation and is monitored constantlyto preventoverfilling andspilling. Recommendations

1) 2)

Develop formal procedures the trar~sfer and monitoring of petroleumproducts for in USTs. Provide training in the specific proceduresfor transferring and monitoring of petroleumproducts.

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~=,udlt Dlsctollne ~,qdlt

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August1989

Toxic and Chemical Materials TCM/AF-6 Lack of Storage Dates on PCB Waste Drums

Ftndtna Number

Storage of PCB-labeledwaste drums does not meet the requirements of 40 CFR761. Dateson which PCB wasteswereplaced in storage in Building 666, 884, 776, and Unit 1 are not noted on the drums.Log booksmaintainedin the storage areas do not provide the date the PCSwastes were put into storage; they provide the date that the PCS materiaJwastaken"out of service'. Light ballasts suspected containing PCSs of werelocated in a PCB-la.beled drumon the east deck of Building 334. The dock area doesnot have secondarycontainment. Atter review by the Audit Team, drumof discardedlight ballasts wasmoved the storage the to shedadjacent to Building 334. Aoollcable Citation and Requirements

Thestorage of PCB waste drumsdoesnot meetthe requirementsof 40 CFR 761.65(b)(8), Toxic Substances Control PCE~ Articles and PCB Containersshall be dated on the article or container when they are placed in storage. The storage shall be managed that the PCB so Articles or PCB Containers can be located by the date they enter storage. Storagecontainers shall havea record that includes for eachbatch of PCBs the quantity of the batch and the date the batch was addedto the container. The record shall also include the date, quantity, and disposition of anybatch of PCBs removed from the container. 40 CFR 761.60(vi)4, Toxic Substances Control Act AnyPCB article, with PCB concentrationsat 50 ppm greater, shall be or stored in accordance 761.65prior to disposal. with Recommerldatlons

1)

The drums of PC8wastes currently in storage and any drums of PCBwastes placedin storagein the future should be labeled with a permanent marker, noting the date they wereplacedin storage. Written procedures specifying the PCBwaste storage requirements of 40 CFR 761.65 should be developedand implemented.

3)

A checklist should be posted at the entrance to each PCB waste storage area detailing the labeling and marking requirements for each drum and the informationto be includedin the wastearearecord or log book.

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August 1989

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PCl~-Iabeled containers should Toe stored in areas meeting the requirements of 40 CFR76t .65, or designated teml~or~ storage areas. The requirements state that PCI~ items may be stored in an ~ea which does not meet the storage requirements for up to thirty days provided that a. notation is attached to the container indicating the date the item wasremovedfrom service.

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Page 12 of 40 TCM/AF-6
Aug u.st 198S

Toxic and ChemicalMaterials ~,udlt Flndln~ Number TCM/AF-6 Lack of AdequateSecondary Containmentat PCS Waste StorageFacility Buildings 884 and 776 Audit F~ndlr](~ and Aeollcable Reference Secondary containmentstructures for PCB waste drumsin Building 884 and 776 do not meet the requirementsfor PC8storage facilities because the roomin which the drums are located does not have six-inch curbing as required for PCB storage areas, The current two-inch curbing is employed both Building 884 PCB at waste storage area and both PCB wastestorage areas in Building 776 (room127 and room227) is due to site criticality concerns. ~pollcable Citation and Reouirements

40 CFR 761.65(b)1, Toxic Substances Control Act The PC8storage facility shall have an adequatefloor which has continuous curbing with a minimum six-inch high curb. Recommendations

1)

Since the radioactively-contaminated PC8waste drumscurrently in storage in Building 884 and both PCBstorage areas in Building 776 do not meet the requirementfor placementwithin secondarycontainmentwith six-inch curbing, RFP shouldcontact the BPA,explain that criticality safety concerns conflict with the curbing requirement,and request a waiver. Thewaiver should be obtained in writing and a copykept in 8uitding 884.

2) A formal procedureshould be issued to detail the permitted storage requiremen(s for radioactively-contaminated PC8wastes. Theprocedureshould state that the total volume of liquid PCBwastes stored in secondarycontainment with two-inch curbing shall not exceed available volume the containment. the of

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TCM/~,F-7 ~,ugu~t 40 Page 13 of 1989

Toxic and Chemical Materials A~Idlt Flndlna Number TCM/AF-7 Inadequately Covered Asbestosin the ActiveLandfill

Aq~it F~ndlna Title Agc~it Pindtna ~i~d Aoollcable Reference . _

Bagsof asbestos-containingmaterials are not properly coveredwith soil upondisposal. in the activelandfill. An inspection of the landfill revealedthat several bagslabeled "asbestos"(both intact and ripped), a boiler tank with exposedsuspectedasbestos, and suspected'asbestos dabdsfrom the boiler tank wereleft exposed after the normalwork shift wascompleted. The bagslabeled "asbestos" and the suspectedasbestosmaterials were not located in the area designated asbestosdisposal, for OnJune 23, 1989, the Audit Team observedbags labeled asbestos protruding ~romthe landfill cover during workinghours. Several of the bagsweretorn. Althoughthe north portion of the landfill wasdesignatedand signed for asbestos, bagslabeled asbestos werenotedin other areas. Discussions with the equipment operatorat the landfill (I-C-8) indicated his dozer does not allow him to go downslope to cover the waste so he pushes dirt over the edgeof the slope. Theoperator wasobserved leaving the landtill at the end of his shift, leaving the bagsof asbestos exposed. situation wasreportedto The the shift supervisorwhoindicated the bagswouldbe coveredthat night. OnJune24, 1989, the Audit Team revisited the landfill. Covermatedalhad beenplaced over the wastebut approximately7 bagsremaineduncovered.Theshift supervisor was notified and sent someone to cover the remainingbags. out OnJune 26, 1989, the Audit Team revisited the landfill after hours and observedthat there were no exposedbags of asbestos. However, two large pieces of asbestosinsulated equipmenthad been pushedinto the landfill. The units werebadly damaged during the move,and several pieces of the insulation werescattered down 100-foot a path. This situation wasreportedto the shift supervisor.Thelandfill wasrevisited by the audit teamon June27 and July 10, 1989, and there wereno signs of exposed asbestos. Aoollcable Citation and Reoutrements

40 CPR 61.156, Nationa] EmissionStandardsfor Asbestos,Active WasteDisposal Sites Rocky Fiats Plant Services Procedure Manual Sanitary WasteO~sposalProcedure, No:TRK-19 "(c) Rather than meet the no visible emission requirement of paragraph(a) of section, an active waste disposal site would be an acceptable site if at the ~ ooeratina day or at least once ever,, 24-hour oeriod while the site is in continual ~, the asbestos-containing material which was deposited at the site during the operatingdayor previous24-hourperiod is covered with either: (1) At least 15 centimeters(6 inches) of compacted nonasbestos-containing material."
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TheRFP procedure disposal of asbestosstates that the asbastos-contalning for material must be covered at the end of each working day and that the asbestos-containing matedalmus~ disposedof in the designatedlocation. be The site asbestos disposaJ procedure, HS&E 21.03, in Section 3.2, states that all asbestos-containing-material waste must be sealed in containers. Broken or torn containers mustbe placed inside newcontainers before disposal. Section 3.6 states that Plant Serviceswill completelycover the disposedwastedaily. This covershall be a minimum six inches of depth. of R~qommendatlons

1)

Incoming asbestoswaste should be covered as soon as possible, no later than the end of the working day. Asbestosbagsshould be of a different color than other garbage bagsfor easy identification. Asbestos should be disposedof in an area apart from the remaining garbage,preferably in designated pits. Thelift height of the landfill materials. should be decreased bette=' coverage fill for of

3)

A compactor shouldbe installed in order to reducethe volume landfill materials of prior to disposal.

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Toxic and ChemicalMaterials &udlt Findlnd Numbe~ TCM/AF-8 Polychlodnated Biphenyts (PC@s) Spill Cleanup ~,udlt Ftndlncl and Less than one gallon of dielectric fluid released during the failure of a polemountedtransformer (identification number370-022) on June 3, 1989, had PCB concentration of 19 ppm(I-TCM-4). The soil near the asphalt under the failed unit wasnot excavated.In addition, the soil wasnot sampled determine to the presence concentration of PCSs. or A~olleable Citation and Reoulrement

40 CFR 761,125,Toxic Substances Control Act, requirementsfor clean-up of lowconcentration spills whichinvolve less than one pound PCSs weight. by All soils within the spill area.(i.e., visible tracesof soil anda buffer of one lateral foot aroundthe visible traces), mustbe excavated the ground and restoredto its original configurationby back-filling with clean soil (i.e., containing less than one ppm PCSs). Remediationmust be completedwithin 48 hours after the ownerof the equipment, facility, or other sourceof PCBs notified or made aware the of spill. Re¢0mmendatl0n8 Previous PC8spills should be researched to determine if current levels of contamination exceed levels set forth in the regulation. If no action hastaken the place with respect to remediationof previous PC8 spill areas, the areas should be sampledto determine the concentration of PCSsand level of remediation required. The RockyFlats Plant (RFP) should institute a PC8spill cleanup procedurebasedon the applicable requirementsof 40 CFR 761.125.

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Page 16 of 1989 August 40

TCM/AF-9

Toxic and Chemical Materials Audit Ftndlna ~ A~ldlt Flndlno_and A~llcable Number TCM/AF-9 Annu~PCB Repor'(s

Annual PCB reports prepared by RFPdo not meetthe requirementsof 40 CFR 761. Thetotal weight of PCBs kilogramsin PCB in containers in storage and the total weight of PCBs kilograms of PCB in containedin transformers are not included in the annual reports (TCM-8, TCM-10, TCM-11). The PCBtransformer in Building 865 was not included in the annual PCB report until 1988 (TCM-8,TCM10, TCM-11). Aoollcable Citation and Reoulrements

40 CFR 761.180(a), Toxic Substances Control Act Thefollowing information for eachfacility shall be includedin the annualdocument: Total weight in kilograms of any PCBs PCB and items in PCB containers. Total numberof PCB transformers and total weight in kilograms of any PCBs containedin the transformers. Re(tommendatlon~ The concentration of PCBsin PCB containers and in the Building 865 PCB transformer mustbe determinedand the total kilograms of PCBs calculated and included in the annual PC8 reports as required by 40 CFR 761.180(a).

2)

A formal procedureshould be issued which details the requirementsof 40 CFR 761.180(a)and includes example calculations of total weight, information on PCB densities with respectto concentration,endall applicableconversion factors.

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Audit Olselollne. ~ ~IMPFtndlr~a Title ~IMP Rndlnq

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August 1689 Page 17 of 40

TCM/eMFZ.1

Toxic andChemical Materials TCM/BMP-1 Secondary Containmentfor Portable Aboveground Storage Tanks

Port=hie storage ta~ks usedfor temporary storage and supply of solvents, acids, fuels, etc., do not havesecondary containment. the event of a spill or releasefrom portable In tanks, released material wouldnot be contained and, depending the location, could on possibly migrate to nearby surface water. This would not be consistent with requirements the CleanWaterAct. of At the time of the audit, portable tanks without secondary containment werein service at the following locations: 1) Nitric acid tank west of Build!rig 885. 2) Nitric acid tank north of Building 714. 3) Diesel fuel tank north of 776. Appll¢~!l~le BMPR~commendaU0n~;

Portable tanks should be provided with secondary containment to ensure against possiblereleasesof toxic materials to surfacewaters.

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TcM/eMP-2

Toxic and ChemicalReleases TCM/BMP-2 BMPFlndlna Title Polychlorinated Biphenyls (PCBs)Handlingand Spill Remediation

Spill remediation equipmentis not available on vehicles which transport PCB waste drums and containers (I-TCM-8). Site personnel responsible for handling and transporting PCB wastes have not been formally trained in PCB h.andling and spill responseprocedures (I-TCM-8, 11). In the event of a release of PCB waste material dudngtransport, the material could not be adequatelycontained and remediation would be delayeduntil the abpropriatespill response personnel are mobilized. ~oollcable BMP Recommend.atlone

Personnelinvolved in the transport,, of PCB wastesshould be formally trained in PC8 handling and spill response the "first rasponder at awareness" level. Appropriatespill containmentand remediation equipment should be available on transport vehicles.

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Page 19 of 40 TCMIBMP-3
AUgUSt 1989

Toxic and ChemicalMaterials BMP F~ndlno Number TCM/BMP-3 Lackof ProperLabeling on AbovegroundStorage Tanks (ASTs) Building 991 at

There is rio hazardous waste label on the inactive hazardous waste storage tank adjacent to Building 991. Of the two 25(]-g~llon aboveground storage tanks located adjacent to Building 991 used for collection and storage of hazardous waste, only one is in use at any one time. The tank in use is labeled as hazardous waste(I-TCM-22). Althoughthe other tank contains residual hazardous wastes, the RockyFlats Plant (RFP)considers it emptyand doesnet label it as hazardous. other tank, being "empty", is not labeled despite the fact it The contains residual hazardous wastes. Aoollcable BMP Recommendations

The "empty" tank should be labeled as hazardous waste.

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TCM/eMP-4

Toxic and ChemicalMaterials

Lack of SecondaryContainment for Building 551 Chemical Storage Area

L~ck of secondary containment sp{ll cleanupcapability in the chemicalstorage area and of Building 551 could result in a release of chemic~ materials to the environment. Bulk chemicals,suchas 55--gallon drums ferrous sulfate andmethylene of chloride, are stored adjacent to the west wall of Building 551 (I-TCM-27). Theoverhead doors in the west wall do not provide an adequate seal when closed, and spilled materials could be released to the environment. Building 551 personnel havenot beentrained in spitl cleanupand there are no spill kits in the building. Spill kits havebeen orderedandfour building personnel will attend spill training within the next month. Aoollcable 1~4P Recommendations

Ramp bermaor flexible door thresholds should be instalted for the overhead doors in the west side of Building 551. A formal procedure shouldbe issued whichdetails the actions required if a spill wereto occur in Building 551. This procedureshould be posted in the chemica storagearea of the building.

3)

Building 551personnel shouldbe trained in spill cleanup spill kits shouldbe and available in the building. All chemicalstorage areas within the RockyRats Plant (RFP)should be inspected to verify that spill kits are available, cleanup procedures in place, andthat are personnel training has been documented.

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Audit Discipline

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Page TCM/BMP-5 21 of 40
August 1989

Toxic and ChemicalMaterials TCM/SMP-5 L.~ck of Secondary Containment for PermanentAboveground Storage Tank(AST)at Building 774

The abovegroundstorage tank labeled "Building 774 Untreated WasteStorage Tank 207" doesnot havesecondarycontainment. A release of untreated wastefrom the tank (approximate capacity of 15,0(]0 gallons) could migrate downslope and enter Woman Creek.Thetank wasinactive at the time of the audit but could be activated in the future (although site doesnot planto activate it). the A,l~pllcable BMPRe¢ommendatlons

In the event the Building 77,$ Untreated WasteStorage Tank 207 is placed back into service, secondarycontainmentshould be constructed. If the tank is not to be placed back into service, it should be decommissioned. containmentstructure should be The tested andapproved usepdorto activation of the tank. for

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TCM/BMP-8 ~,ugu=it 1989

Audit Olsciollne

Toxic and ChemicalMaterials TCM/BMP-6

Title

I

ImproperStorage of Chemical Materials Suilc~ing331 in

The storage of flammablechemicalsin a chemicalcabinet located over a drain trough posesthe potential for the releaseof chemicals the sanitary sewer to system. A cabinet for the storage of flammable chemicalsis located over the drainagetrough in Suilding 331. The drainage trough is connectedto the sanitary sewer system, which flows to the sewage treatment plant. ChemicaJs stored in the flammable chemical storage cabinet include spray cans of brake cleaner and cutting oils, plastic containers of diesel supplement (petroleum distillates), motoroil, andrefrigerant oil. Aoolleable BMP Recommendations

Relocatethe chemicalstorage cabinet to an area awayfrom the drainagetrough.

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Page 24 of 40 RA01ATION
August 1989

7.0 - RADIATIC)N $CGPE OF AUDIT Evaluate the dose~ssessment methodology,the pathways,and radionuclides considered. 2. 3. 4. 5. 6. 7. Evaluatethe samplingand analysis procedures usedfor the analysis of radiological pard,meters environmental in samples. Evaluatethe laboratory quality ~suranceprogram governing the radiochemistry analyses. Review selection of radiological analytes in environmental the media. Review instrumentation, procedures,and adequacy real-time monitors for of atmospher~o effluent streams. Reviewand evaluate radw~stemenitorthgand classification procedures. Review procedures ensurethat site practices satisfy Department to of Transportation regulations pertaining to the shipment radioactive materials and of their implementation. Review procedures ensurethat wasteshipments to satisfy radwastesite acceptance criteria. g. 10.
11.

Review andsoil monitoringprograms'toevaluate potential for contaminated air soil on-site to migrateto offsite locations by saltation andresuspension. Coordinate with air and water specialists to evaluate monitoringprograms. Coordinate with air andwaterspecialists to evaluateeffluent controls.

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RADIATION FiNDiNGS AUDIT RAD/AF-1 RA0/AF-2 RAD/AF-3 RAD/AF-4 RAD/AF-5 Calculation and Repo~ng Radiation OeseAssessments of Quality Control Checks,Radwaste Classification/Charantedzation Quality Assurance/Quality Control Practices for RadiochemistryAnalyses (Building 123 HS&E) Quality Assurance Deficiencies in the ChemistryStandards Laboratory- Building 881 Quality Assurance/Quality Control Practices for RadiechemistryAnalyses- 881 General Laboratory

~.EST

MANAGEMENTPRACTICES: Control of 903 PadArea Characterizationof Soil Contamination Staging Areasfor the Shipment Radioactive Waste of

RAD/BMP-1 RAD/BMP-2 RAD/BMP-3

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Radiation RAO/AF-1

Page 26 of 40

Audit Ftndlnc~ Title Audit PindlncI and ~,oollcable Reference

Calculation and Reportingof Radiation Dose Assessments

Theassessment the Rocky of Flats Plant (RFP)contribution to the public radiation dose. as reported in the Site Environmental Reportfor 1987(RAO-1),doesnot fully addressall potential exposure pathways and redionuclides. The reported assessments address the maximum site-boundary dose, the maximum community dose, and the estimated individual 80-kilometer dose estimate. The siteboundarydose calculation considers the inhalation, drinking water ingestion, and ground-planeirradiation pathways.The community 80-kilometer dose calculations and consider the inhalation pathway.Thereport states that other pathways (e.g.. swimming, ingestion of foodstuffs, drinking water ingestions, and ground-planeirradiation at community locations) are insignificant but there is not sufficient information providedto support this statement. During interviews. RFPstaff (I-RAO-7) provided adequate technical justification for not including all pathways the actual calculations, but no in formal documentation exists to demonstrate that the assessment includes all significant dosecontributors. The dose assessments for plutonium are based on the assumptionthat thd isotopic ratios are identical to that reported in the 1980Environmental ImpactStatement,Rocky Flats Plant Site, DOE/EIS-0064.hasnot been It verified that theseratios are-valid for the materials currently being processed the RFP.It is also assumed the air pathway) at (for that the americium-241 activity in air is 20% the alpha-emitting plutoniumactivity of because this is the highest americium-to-plutonium ratio that maybe present in the RFP plutoniumfrom the decayof plutonium-24-1. However, is not clear that this assumption it is valid because someprocessesat the RFPseparate plutonium and americiumand the latter maybe released independentlyof the former. In addition, because chemical of dissimilarities, theseelements separatein the environment. may The dose assessmentcalculations do not address the sameradionuclides for all pathways. As an example, the air pathway addresses plutonium and americium-241 while the drinking-water pathway also includes uraniumisotopes, Thereis no estimateprovidedof the collective effective doseequivalentto the population within a distanceof 80 kilometersfromthe sits. The discussion of the dose assessment the 1987 Environmental Monitoring Report in (RAD-1) not clearly written andit is difficult to follow the logic usedin preparing is the assessment. Citation and Reoulrements

"CIarification of ApplicableRadiation Protection Standards the Public for end the Environment,"Memorandum Distribution from JohnTseng, Acting to Director, Office of EnvironmentaJ Guidance Compliance, and U.S. Department of Energy, November 1987. 4.,
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"RadiationStandards Protectionof the Public in the Vicinity of 0OE for Facilities," MemorandumOistribution from W. A. Vaughan, to Assistant Secretaq/, Environment,Safety, and Health, U.S. 0epartment Energy, of August 5, 1985. DOE Order 5484,1, Chapter3 (Draft). Thesedocuments establish interim standardsto be useduntil the final DOE Ordersare promulgated.Theseinterim standards require that 0OE facilities assessthe potential facility contribution to the effective doseequivalent received by individual members of the public as well as the collective doseequivalentto the populationwithin a distanceof 88 kilometers from the site. Thesestandardsfurther require that the doseassessments include all pathwaysand be as accurate and realistic as the data allow. The dose assessments to be included in the annualenvironmental are monitoring report.

1)

Include all pathwaysand RFP-rslatedradionuclides in the dose assessment by e{ther calculating potential dosesor providing adequate information to support conclusions that certain pathwaysor radionuclidas are not significant dose contributors. This maybe included in a refersnceableaddendum in the text of or the annual environmentalmonitoring repot. Vedfythat the assumed plutonium isotopic ratio is representativeof materials that presently havethe potential to be releasedfrom the RFP site. Institute analysis of ambient air samples for americium-241 and uranium isotopes. Base the americium-241 dose assessments actual monitoring data on rather than assumed concentrationratios. Assign a technical writer to edit and revise the dose assessment section to improvethe cladty of the discussion. Initiate collection andanalysisof foodstuffsto allow doseassessments sufficient if documentationis not available to demonstratethat their ingestion is not a significant dosecontributor.

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~dlt

Flndln¢~

Numbe~

RAD/AF-2 Quality Control Checks Radwas~e Classification/ Characterization

Audit Flndlm3 Title

Audit Flndtno and Aoollceble The existing quality control practices associated with the radioanalyses for the classification and characterization of radioactive wastesare not sufficient to fully demonstratethe validity of the analytical data This finding applies to analyses conductedusing the passive active drum counter, the segmented gamma scanner, and the low specific activity counter. These systems are used to determine whether containerizedexcess materials are to be defined as residues, transuranic wastes,or lowlevel wastes,andto quantify the activity in the drums.Two deficiencies werenoted:

1)

Thereis no internal intercomparison program place to allow an evaluation to in be made of the consistency of analyses between analytical systems. Consequently, there is insufficient documentation indicate that all systems to would producethe sameresults. SafeguardsMeasurements in the planning is stages of an internal intercomparison program called the "Non-destructiveAssay (NDA)Accuracy Verification Program".In addition, DOE doesnot havea systemwide interoomparison programto ensure consistency betweenfacilities. RFP personnelhavestated that sucha systemis underconsideration (I-RAD-28). Thereare no formal written acceptance criteria for the evaluation of systemperformancein the analysis of the routine "Measurement Control Standards (MCS). Consequently, there is no assurancethat the system performance consistently evaluated. Safeguards Measurements an action plan to improve has the systemused to review the MCS results, including an interactive~on-line capability that will allow the generation and use of control charts, and the development formal acceptance of criteria (I-RAD-28).

ADl~llcable Cltatlon

and Reaulrem~nl;~

DOE Order No. 5820.2A, Radioactive WasteManagement. This order establishes the requirementfor the classification and characterization of transuranic and low-level radioactive wastes,including the specific requirements a quality assurance for program that satisfies the requirementsof "AmericanNational StandardsInstitute/American Society of Mechanical Engineers, Nuclear Quality Assurance-1(ANSI/ASME NQA-1). Included in NQA-1 requirementsto assessthe accuracyand precision of analytical are measurements. Recommendations 1) Expeditethe implementation the plannedNOA of Accuracy Verification Program. Expeditethe action plan for the development formal acceptance of criteria for the MCS results.

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3)

Encourage development a DOE-wide the of interfacility for waste-analysissystems.

intercomparisonprogram

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Page 30 of 40 RAD/AF-3
August 1989

Radiation Audit F]rldlna Number RA0/AF-3 Quality Assurance/Quality Control Practices for Radiochemistry Analyses (Building 123 HS&B) Audlt Flndlno and Aoollcable Reference Thequality assurance quality control practices for radiochemistryanalysesin the and Building 123 HS&E Laboratory do not conform to generally accepted practices. Consequently, laboratory cannotadequately the verify the validity of analytical results. Among deficiencies observedare: the

1)

The frequency of analysis and types of quality control (QC) samplesare not cleady defined. The laboratory does not analyze any portion of its samplesin duplicate, there is no set requirement the frequency blank analyses all for of for samples,and control standards are not usedon a routine basis (I-RAD-14,15, 16, 18). Instrument analytical control charts are not used(I-RAD-14, 16, 18). and 15, Thereare no current formal procedures the operation, calibration, or routine for performance testing for radioanalytical instrumentation(I-RAD-14, 16, 18). 15, Thereare no formal, written acceptance criteria for quality control andcritical analytical parameters suchas blank contamination,chemicalyields, and control sampleperformance (1-RAD-14, 16, 18). 15, Thelaboratory doesnot perform regular instrument performance checks on the gamma spectrometrysystems, such as efficiency, peakresolution, or peakshape (I-RAD-16).

2)

3) 4)

8) 7) 8)
9)

Alpha spectrometerchecksare conducted only on a monthly basis. (~-RAO-14). Protective coveringsare not usedin the interior of gamma spectrometer detector chambersor around sample containers during counting. This enhancesthe potential for detector contamination (1-RAD-16). Comprehensive instrument logbooksare not routinely usedfor the alpha spectrometers or the gamma spectrometers(I-RAD-16). Laboratory procedures not reflect current practices (I-RAD-14, 16, 18). do 15, Thepipet calibration checksfor the preparation of tritium samples basedon are the transfer of multiple aliquots to a graduated cylinder. This is not an accurate method(RAD-36). There is no formal procedureor requirement for the validation of computer softwareusedfor analytical calculations (I-RAD-16).

lo)
11)

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12)
13)

The laboratory does not have a comprehensive quality assurance program governingradiochemical analysesin the HS&E Laboratory (I-RAO-14, 15). SeeFindings RAO/AF-4., RAO/AF-5, QAJAF-1, QAJAF-2 related findings. and for Cltatlon and Requirements

Aootlcable

"Clarification of Applicable Radiation Protection Standardsfor the public and the Environment,"MemorandumDistribution from John Tseng, Acting Director, Office Of to Environmental Guidanceand Compliance, U.S. Departmentof Energy, November 4., 1987. "Radiation Standardsfor Protection of the Public in the Vicinity of DOE Facilities," Memorandum Distribution from W. A. Vaughan,Assistant Secretary, Environment. to Safety, and Health, U.S. Department Energy,August5, 1985. of ODE Order 5484.1, Chapter3 (Draft) Thesedocuments establish intedm standardsto be useduntil the final DOE Orders are promulgated.Theseintedm standards require that DOE facilities assessthe potential facility contribution to the effective doseequivalentto the population within a distanceof 80 kilometers from the site. These standardsfurther require that the doseassessments include all pathways. Dose assessments are based on measured releases of radionuclides and environmental monitoring programs. A formal comprehensive laboratory quality assurance program is necessary to ensure and documentthat radiochemistry data are accurate, precise and defensible. Theneed for such programs is explained and guidance for their developmentprovided in numerous documents, including: Establishing a Quality Assurance Program Analytical ChemistryLaboratories for within the Nuclear Industry, ASTM C1008-83. Manual the Certification of LaboratoriesAnalyzingDdnking for Water, EPA570/9-82-002, October, 1982. Handbook Analytical Quality Control in R-=dioanalyticalLaboratories, for L.Kanipe, U.S. EnvironmentalProtection Agency,1977,EPA-600/7-77-088. Evaluation of internal Control Measurements Radioassay, in Health Physics, A. S. Goldin, September 1984, Pages361-374. Quality Assurance Radiological Monitoring Program for (NormalOperations), Effluent Streamsand the Environment,U. S. NuclearRegulatory Commission, Regulatory Guide4.15. Principles of Quality Assurance Chemical of Measurements, Taylor J.K. National Bureauof Standards, NBSIR-85/3105, February 1985. Performance DesignCriteria for Systems and Usedin DOE Facilities to Sample and MeasureAirborne Radionuclide Emission to Comply with 40 CFR 61, Subpart H, U.S. Department Energy, Janua,'y 1986, DOE (issued for of EH comment).

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August 1989

A Guidefor Effluent Radiological Measurements DOE at Installations, U.S. Oepartment Energy. of Recommendations Clearly define the types and frequencyof qua{ity control analysesin either the analytical procedures or in a separate QCprocedure. Types of QCanalyses should include method blanks, duplicate, and control samples.Thefrequencyof analysis must be sufficient to demonstrate accuracy and precision of the analyses. Institute the use of control charts. Develop wdtten proceduresto prepare, use, andevaluate instrumentand analytical control charts. Include analysis of trends in the evaluationportions.

3)

Prepareformal procedures the operation, calibration, andperformance for testing of all majorinstruments. Develop written acceptance criteria for all quality control ana[yses critical and analytical parameters. Developproceduresto require regular performance checkson all irstruments to the extent practical. Theseshould be performedon a daily basis or whenever instrumentsare in use.

6) 7) 8) 9) 10)

Use protective coverings in the detector chamberor around samplesduring gamma counting. Institute the useof instrumentlogbooks. Update anal~calprocedures reflect current practices. all to Develop procedure the calibration of pipets using calibrated balances. a for Developformal proceduresfor the validation of software usedfor analytical calculations. Develop a comprehensive quality assurance program and implementation procedures, for the radiochemistry analyses, in conformance with the guidance of ASTM C1009. Provide all personnel with QAJQC training. Chemistsand supervisory personnel should receive additional training in the philosophy of QAand the development and evaluations of QA/QC programs.

13)

Coordinate with the Building 881, General Laboratory and the Chemistry Standards Laboratory to develop a quality assuranceprogramand procedures for radiochemistry analysesto make moreefficient use of development time and ensurethat the laboratories haveconsistent procedures requirements. and See Findings RAD/AF-4, RAD/AF-5,QA/AF-1,and QA/AF-2 for related recommendations.

14)

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1989

Radiation Audit Findlna Number RAD/AF-4 Quality Assurance Deficiencies in the Chemistry StandardsLaboratory (Building881

~,,udlt Ftndlna Title

Audit Plndlna and Aoollcable Reference The quality assurance~qualitycontrol practices in the ChemistryStandardsLaboratory (CSL) maynot be adequateto document the validity of the radiological reference standardspreparedby the laboratory. This laboratory preparesreference standardsfor use by the environmentalradiological laboratories, for instrument calibrations, as internal tracers, and for the preparation of control standards. Thelaboratory also prepares standards for use in the Rocky Plats Plant (RFP) Interactive Measurement Evaluation and Control System.Because these relationships, the validity of the data of producedby the RFPEnvironmant~ Monitoring Program dependent is uponthe ability of the CSLto document accuracyof the standardsit produces.The deficiencies noted the in the CSL's quality assurance/quality control practicesinctude:

1)

Existing laboratory procedures not reflect current practices. TheCSL do is in the processof revision, but doesnot havethe resources complete to the revisions in a timely manner (I-RAD-30,31). Thelaboratory doesnot checkthe activRy of standards preparedfrom certified or NBS-traceable solutions (I-RA0-30,31).

3)

Thefrequency type of instrument and quality control checks not clearly defined, is and there are no formal written acceptance criteda for the results of thesechecks (I-RAD-30,31). Thelaboratory doesnot usecontrol charts to track counting-instrument performance.

Ap~II~ble Citation

and Reauirements

"Clarification of Applicable Radiation Protection Standardsfor the public and the Environment,"MemorandumDistribution from John Tseng, Acting Director, Office of to Environmental Guidanceand Compliance, U.S. Departmentof Energy, November 4., 1987. "Radiation Standardsfor Protection of the Public in the Vicinity of DOE Facilities," Memorandum Distribution from W. A. Vaughan,Assistant Secretary. Environment, to Safety, and Health, U.S. Department Energy, of AugustB, 198B. DOE Order 5484.1, Chapter3 (Draft) Thesedocuments establish interim standardsto be useduntil the final DOE Orders are promulgated.These interim standardsrequire that ODE facilities assessthe potential facility contributionto the effective doseequivalentto the population within a distanceof 80 kilometers from the site. Thesestandardsfurther require that the doseassessments 7-13

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include all pathways, Dose assessments are based on measured releases of radionuclides and environmental monitoring programs. A formal comprehensive laboratory quality assurance program is necessary to ensure and documentthat radiochemistry data are accurate, precise and defensible. The needfor suc~ programs is explained and guidance for their developmentprovided in numerousdocuments, including: Establishing a Quality Assurance Program Analytical ChemistryLaboratories ~or within Ihe Nuclear Industry, ASTM C1009-83. Manual the Certification of LaboratoriesAnalyzingDrinking Water,EPA-570/9for 82-002, October, 1982. Handbook Analytical Quality Control in RadioanalyticalLaboratories, for L.Kanipe, U.S. Environmental Protection Agency,1977, EPA-60(:}f'/-77-088. Evaluation of Internal Control Measurements Radioassay, in Health Physics, A. S. Goldin, September 1984, Pages361-374. Quality Assurance Radiological Monitoring Program for (NormalOperations), Effluent Streamsand the Environment,U. S. NuclearRegulatory Commission, Regulatory Guide4.15. Principles of Quality Assurance Chemical of Measurements. Taylor J.K. National Bureaucf Standards,NSSIR-85/31(]5, February1985. Performance and Design Cdtedafor SystemsUsedin DOE Facilities to Sample and Measure Airborne Radionuclide Emissionto Comply with 40 CFR 61, Subp~ut U.S. Department Energy, January1986, DOE (issued for H, of EH comment). A Guidefor Effluent Rediological Measurements DOE at Installations, U.S. Department Energy. of Verification of Analytical Performance, CY.702. Institute of NuclearPower Operations. F~ecommendattons 1) 2) 3) Expedite preparationof revisedprocedures the that reflect current practices. Checkthe activity of 10 percent of all reference standards using a counting system calibrated with NBS-certified sources(primary or secondary standards). Clearly define in either instrument operation procedures, or in a separate instrument quality control procedure, the type and frequency of instrument performance checks to be used. Initiate the useof control cha~"ts. Preparea procedure the use, preparation, for and evaluation of control cha~s. Coordinate with the 881 General Laboratory and the HS&E Laboratory to cooperatively develop common procedures for quality assurance/control, instrument operations, and other laboratory activities, as appropriate.
7-14

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Page 35 of 40 RAD/AF-5

A.udlt Findln~ Number Audit F~[ndln~ Title

RAD/AF-5 Quality Assurance/Quality Control Practices for Radiochemistry Analyses (881 GeneralLaboratory)

Audit Ffndtno and Aoollcable References Thequality assurance quality control practices for radiochemistryanalysesin the and 881 GeneralL.~boratory maynot be adequate document validity of the analytical to the data. Among deficiencies observedare: the

1)

The frequency of analysis and types of quality control (QC) samplesare not clearly defined for all analytical procedures. Procedures mayspecify that QC samples run with everyset but "set" is not quantified in all procedures. be This is better defined in procedures revised within the last year, but older procedures are not clear. Proceduralrequirementsfor the analysis of method blanks, duplicates and control standards are inconsistent; some proceduresrequire such analyses while others do not (RAD-26, 28, and31). 27, Thereare no written proceduresor formal criteria for the preparation, use, or evaluationof instrumentor analytical control cherts (I-RAD-8 I-RAD-13). and Control charts are not evaluated for trends that mayindicate slowty changing systemperformance subtle changes or usedfor environmentallevel samples (I-RAD-8 and I-RAD-13). There are no formal procedures for the operations, calibration, or daily performance testing for the alpha spectrometers and the gross alpha/beta counters (I-RAD-8 and I-RAD-13). There no formal, written acceptance are Criteria for many quality control or critical analytical parameterssuch as blank contamination, chemical yields, duplicate analyses, and control sampleperformance (I-RAD-8 and I-RAD-13). Duplicate analyses have not been correctly used in somecases. Becauseof difficulties in performingthe americium-241 analytical procedures, laboratory the mustoften repeat the analyses. In order to preservesamples permit this, the to laboratory is conductingfewer than 10 percent of the analysesin duplicate, as required by the procedure. This is not viewedby laboratory personnelas a nonconformance the procedurebecause an intent to increase the frequencyof to of duplicate analyses. Upon resolution of the analytical problems, the duplicate frequencywill be increasedso that 10 percent of all analysesfor the calendar quarter will be duplicates. Theconceptbehindthe use of duplicates is to havea consistent, routine measureof the analytical precision. This requires that duplicates be uniformly distributed throughoutthe sample load (I-RAD-13).

2) 3)

7)

There is no formal procedure or requirement for the validation of computer softwareusedfor analytical calculations (I-RAD-8).

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The laboratory does not have comprehensive proceduresfor the implementation of a quality assuranceprogramgoverning radiochemicat analyses in the 881 GeneralLaboratory (I-RAD-8 and

9)

See Findings RAD/AF-3,RA0/AF.4,QAJAF-I, and QA/AF-2for related quality assurance tindings. Citation and Requirements

Aoollcabte

Interim Guidelines and Soe¢ifications for Preoarina Quality AssurancePlan~: EPAQAMS-005i60. Guidelines for Soecificatfons for Preaadn Quality AssuranceProGram Plan,~: EPAo QAMS-004/80. Strate(3v for the Im~31ementation the .=-PA's Mandatory of Quality Assurance Pro(3ram: EPA-QAMS-001 DOE Order 5700.68, ~.

40 CFR 136.2, Guidelinesestablishinmtest orocedures the analysis of oollutantm. for "Clarification of Applicable Radiation Protection Standardsfor the public and the Environment,"Memorandum Distribution for JohnTseng, Acting Director, Office of to Environmental Guidanceand Compliance, U.S. Department of Energy, November 4, 1987. "Radiation Standardsfor Protection of the Public in the Vicinity of DOE Facilities," Memorandum Distribution from W. A. Vaughan,Assistant Secretary, Environment, to Safety, andHealth, U.S. Department Energy,August5, 1985. of DOE Order 5484.1, Chapter3 (Draft) A formal comprehensive laboratory quality assuranceprogramis necessaryto ensure and document that analytical data are accurate, precise and defensible. Theneed for such programsis explained and guidance for their development provided in numerous documents, including: Establishing a Quality Assurance Program Analytical ChemistryLaboratories for within the Nuclear Industry, ASTM C1009-83. Manual the Certification of LaboratoriesAnalyzingDrinking Water, EPA-570/9for 82-002, October, 1982. Handbook for Analytical Quality Control in Radioanalytical Laboratories, L.Kanipe, U.S. EnvironmentalProtection Agency,1977,EPA-600/7-77-088. Evaluationof Internal Control Measurements Radioassay, in Health Physics, A. S. Goldin, September 1984, Pages361-374. Principles of Quality Assurance Chemical of Measurements, Taylor J.K. National Bureauof Standa'ds, NBSIR-85/3105, February 1985. Handbook Analytical Quality Control in water and Wastewater for Laboratories: EPA/600106.

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Samolin~~d ChemicalAnelvsi.~ Quali'w &ssurenceProar~m U.S. ArmyToxic of ~ild Hez=-~dous M~te~ialsAoencv,April 1982. Department the Army,U.S. Army of Toxic and N~zardousMaterials Agency, AberdeenProving Ground. Me 21010. ~ecommenda~oms Develop implementation procedures for a quality assurance program, for radiochemistry analyses, tO conformwith the guidanceof ASTM C1009. Prepareformal procedures the operation. ¢alibralJon, and performance for testing of all majorinstruments. Cleadydefine the types and frequencyof quality control analysesin either the analytical procedures or in a separate QCprocedure. Types of QCanalyses should include method blanks, duplioates, ~d control samples.Thefrequency of anatysis must be sufficient to demonstrate accuracy and precision of the analyses. Develop written acceptance criteria for all quality control analysesandcritical analyticaJ parameters. Develop written procedures to prepare, use, and evaluate instrument and analytical control chars. Include analysis trends theev~uation of in portions. Developformal proceduresfor the validation of software used for analytical calculations. Provide all laboratory personnelwith QA/QC training. Chemistsand supervisory personnel should receive addffional training in the philosophy of QAand the developmentand evaluations of QA/QC programs. Coordinate with the HS&E Laboratory and t~e Chemistry Standards Laboratory to develop a quality assurance program and procedures for radiochemistry analyses to makemoreefficient use of development time and ensure that the laboratories haveconsistent proceduresa~d requirements. g) See Findings RAD/AF-3,RAD/AF-4,QAJAF-1,and QA/AF-2for related quality assurance recommendations.

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Radiation RAO/SMP-1

R~,D/BMP-1 Page 38 of 40 August 198S

BMP Ftndlnc~ Title

Control of 903 PadArea

Access the 903padarea is not well controlled andthere is no indication of the hazard to in the area. Thearea is fenced with only double-strand barbedwire which has ungated openings.Thefenceis marked with small "keepout" signs that are rusted anddifficult to read. Therewas one additional sign observedthat included the statement to notify Environmenta~ Management information; however, for this sign is also rusted anddifficult to read. Thereare no signs presentto warnof potential hazards explain the potential or for transuranic conta.mination. piles of soil androck debris wereobserved Two within the fenced area; during interviews (I-RAD-4) Environmental Management personnel could not identify the source the material. of A work order (RAD-23)was issued by the RFP June 1, 1989for improvedfences and on signs, but the improvements not been implemented June 26, 1989. In addition, had by the proposed signs do not indicate the nature of the hazardor indicate an individual or organization caJl for information. to Aoollceble BMParid Recommendetlons

1)

Areas that have the potential for radioactive contamination should be clearly marked haveaccesscontrol, in order to prevent contamination individuals and of and equipmentand to prevent the spread of contamination. This is consistent with the conceptof ALARA low as reasonablyachievable). (as Installation of the plannedfence andsigns shouldbe expedited. Additional signs explaining the nature of the potential hazard and namingthe organizationresponsibleshould be postedin the area.

2) 3)

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RAD/SMP-2

BMPlndlno "rltle F
~MP Flndlnq

Characterization of Soil Contamination

Landin the vicinity of andto the east of the 9(}3 pad is known be contaminated to with low levels of plutonium and americium-2¢l, but the contamination has not been well characterized (RAD-I through 6). Although the area has been sampled the past, and in routine samplingis conductedannually (RAD-1 through 6), there has been no attempt made accurately characterize the levels and extent of contaminationsince a limited to effort in the early 1970s(I-RAD-4). Theexisting data are not adequate characterize to the current status of the contaminated areas. TheRFP proposedsamplingof the onhas site soils in this areaas a part of the site remediation effort (IWS-54). Aooll¢~l~ BMP end Recommendations

Areas containing radionuclide contamination needadequate characterization for effective management control the spread of contamination and minimize radiation to exposure individuals. TheRFP of should proceedwith the plannedsamplingeffort.

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BMP Finding

Number

RAO/BMP-3 Staging Areasfor the Shipment of Radioactive Waste

@Mp Findtn~ Tltle

The WasteStorage andShipping Facility (Building 664) doesnot have a dedicated staging area for radioactive wasteshipments.This situation maylead to delays in the staging of shipments, and increase the potential for nonconformances with shipping requirements. Building 664. is currentJy being used for the storage, staging and shipment of TRUmixed, pondcrete,and low-level radioactive wastes. Because spacelimitations there of is no area that is dedicatedfor the exclusive purpose staging pondcrete low-level of and wasteshipments.Consequently, is necessaryto rearrange wastecontainers in order it to prepare wastesto be toadedonto trailers for shipment,in addition, containers not intendedfor inclusion with a given shipment occasionallystored in proximity to those are that are to be shipped. Concern expressed a RockyFlats Plant manager was by that the needto rearrange drumsto prepare an area for staging maylead to potential safety hazardsand delays in the shipmentof wastes(I-RAP-12). In addition, concernhas been expressedthat the storage of waste in the proximity of containers designated for shipmentmayresult in somewastesbeing improperly loaded with a shipment,although this is not known haveoccurred(I-RAP-22). to TheRFP investigating the possibility of establishing a separatestaging area for the is shipmentof pondcrete(I-RAP-12). Aobltqable BMP 8nd Recommendations

Dedicated wasteshipment staging areas are beneficial in expediting the shipment of wasteby minimizingthe additional time required for unnecessary moving containers. of Suchan exclusive area also aids in avoiding the intermingling of drumsintended for storage with those being stagedfor shipment.

1)

The RFP should establish a dedicated exclusive radioactive wastestaging area in Building 664. Adequate space maybe obtained by either reducing the quantities of materials stored in the building or addingan expansion. TheRFP should expedite investigations and plans to establish a separatestaging area for pondcrete.

2)

7-23