Leigh Pegues, Director

1751 Congo W. L. Dickinson Drive Montgomery, AL 36130

(205) 271-7700 FAX 271·7950

270·5612

field Offices:

110 Vulcan Road Birmingham, AL 35209

(20S) 942-6168 fAX 941·1603

P.O. Box 953 Decatur, AL 35602

(205 ) 353-1713 FAX 340·9359

2204 Perimeter Road Mobile,AL

36615

(205 )479-2336 FAX 479·2593

ALABAMA

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

Guy Hunt Governor

July 1,1992 MEMORANDUM

TO: STEVEN O. JENKINS, CHIEF 5cr1 RCRA COMPLIANCE BRANCH ./ LAND DIVISION

THROUGH: GEORGE D. DAVIS, CHIEF ~~

NORTH UNIT I ~

RCRA COMPLIANCE BRANCH

FROM: LEEDAVIS 77t-~- .. "._..;;.-~. _NORTH UNIT

ReRA COMPLIANCE BRANCH

RE: Department of Energy/Chemical Waste Management Mixed Waste Investigation

USEPA Identification Number ALD 000 622 464

On May 19-21, 1992, a team of investigators visited Chemical Waste Management, Incorporated, located in Emelle, AL. The four parties involved in the investigation were contracted by The Environmental Restoration Waste Management Office of The Department Of Energy. Their objectives were to assess the impact that shipments of radioactive hazardous waste, (mixed waste), might have had on workers at Chemical Waste Management and the surrounding environment and public. Mr. Lee Davis represented Alabama Department of Environmental Management and Mr. Kirksey Whatley represented Alabama Department of Public Health.

The mixed waste was generated by Martin Marietta Energy Systems, Inc., a federal nuclear weapons plant located in Oak Ridge, TN. The mixed waste shipments to Chemical Waste Management occurred over a period of 12 years from 1980 to 1991. The waste consisted of dirt and debris and had an EPA hazardous waste code of D009, (mercury). Some of the waste was also contaminated with low levels of radioactive uranium 235, uranium 234, uranium 238, and technetium 99. See table 1., for the estimated activity in millicuries of each isotope and the specific source of generation.

The Martin Marietta generated waste was divided into three categories based on knowledge of radioactive contamination. Those categories are "known radioactive," "likely radioactive," and "clean." All of the "known radioactive" waste was received by Chemical Waste Management in 1991. The total quantity of "known radioactive" waste shipped in 1991 is 350,180 kg (385 tons). The radioactive activity of the "known radioactive" waste shipped in 1991 is 0.89 millicuries. A total of 39.374 millicuries of activity are estimated to have been sent to Chemical Waste Management over the 12 year period.

W

Printed on Recycled Paper ~ij

· ,

Page 2 MEMOIDOE-CWM July 1,1992

Total quantities of "likely" and "clean" wastes are 1,704,113.42 kg, (1874 tons) and 710,506 kg (781 tons) respectively. In 1990 Chemical Waste Management received the majority of the estimated radioactive activity, measured in millicuries: (26.971 of 39.374 total estimated millicuries of activity over the 12 year period). This is based on the estimated activity for a known quantity of "likely radioactive" waste shipped that year. See table 2., for a detailed breakdown of quantity of waste, the corresponding activity, and totals by year. Tables 1. and 2. were received by Mr. Lee Davis from M. H. Chew and Associates, one of the contracted parties investigating the Martin Marietta shipments of mixed waste to Chemical Waste Management, and were generated by the Department of Energy for the purpose of the investigation.

The peoples and parties involved in the investigation on May 19-21 at Chemical Waste Management, Emelle Facility are listed here. The objectives of each party follow. Representing Chemical Waste Management were Mr. Russell Zora, Emelle Facility, and ~rs. Carolyn Accoca, FJnvironmet;ltal Engineer, Marietta Regional Office. Also Involved and' representing Chemical Waste Management, Emelle Fac~lity were Mr. AI Talbot, Operations Manager; Mr. Larry Overstreet, Customer Assistance Manager; and Mr. Bob Browne, Health and Safety Manager.

Mr. M. H. Chew, President; Mr. Denzel K. Jenson, CHP; and Mr. James S. Dittig, CSP were all present for M. H. Chew and Associates, Inc. Their objective was to assess worker dose from processing the mixed waste. M. H. Chew and Associates were interested in the processes involved in handling the waste from transportation to ultimate disposal. They considered the number of workers involved, time of exposure of each worker to the waste, distance of workers from the waste at each stage in waste m.· •. anagement, level of personal protective equipment at each stage, and typical waste management procedures. Chew and Associates were also concerned with upset conditions, or situations which may have occurred in which typical waste management procedures might have varied.

Mr. S. Y. Chen, Ph.D. represented Argon National Laboratories. Dr. Chen's objective was to assess the impact of the mixed waste on the surrounding environment and public. He was concerned with technical standards of trench construction, population data, and routes that the transporters followed throughout the period of concern. Dr. Chen also obtained samples or sample data off site from Oak Ridge Associated Universities, another party involved with the investigation.

Representing Pacific Northwest Laboratories were Ms. Mary Field Jarvis, Ph.D. and Ms. Rosanne L. Aaberg. They were interested in setting a standard for RCRA facilities for accepting hazardous wastes. with M minimus levels of radioactivity. They were therefore investigating the Emelle facility from a generic standpoint, and were also interested in processes. This was being done because there was no s~t M miniJ?us level of radioactivity acceptable for waste disposal in a RC~ d~sposal facIlity and different DepB;rt!llent of. Energy field offices were. usmg different standards for determining which wastes were considered "non-radioactive." The Nuclear Regulatory Commission currently requires radioactive waste of any kind to be sent to a licensed facility. Chemical Waste Management, Emelle Facility is not licensed to receive radioactive waste. The

Page 3 MEMOIDOE-CWM July 1,1992

levels of radiation contained in the Martin Marietta generated waste were, however, below background for Chemical Waste Management, Emelle facility. This will be discussed further in the following portion of this report.

The fourth party involved in the investigation at the Emelle facility was Oak Ridge Associated Universities. Representing ORAU were Mr. William (Jack) Beck, CHP; Mr. George Foltz; and Mr.' Lee Mashburn. Their objective was to sample air, surface and groundwater, soil, leachate, and any matrix that may have been added to the mixed waste, (Portland Cement). They also took background samples. Sample results will be sent to ADEM.

M. H. Chew and Associates, Argon National Laboratories, Pacific Northwest Laboratories, and Oak Ridge Associated Universities were all contracted by the Environmental Restoration Waste Management Office of the Department of Energy.

Since M. H. Chew and Associates' objective was to assess worker dose from processing the mixed waste, manifests of the waste were categorized and all of the processes involved with each waste category were discussed and observed. The manifests were divided into four categories.

Manifests for 1984 were unavailable. The estimated activity of the waste received by Chemical Waste Management in 1984 is 7.950 millicuries of 39.374 total millicuries estimated to have been received by CWM over the 12 year period. Waste received in 1984 would either have gone directly to be landfilled or to a surface impoundment. If the waste received in 1984 was delivered in drums then there are several possible methods of processing which it might have received. They are discussed below.

The majority of the waste was direct landfilled. Persons involved in this process include the transporter, workers at bulk sampling, lab personnel, those persons operating equipment in the trench, and the landfill mapper on the berm of the trench.

Minimum personal protective equipment (PPE) for all workers consists of a hard hat, steel toed boots, and safety glasses. Additional PPE may be required in certain areas. PPE discussed in the following portion of this report will only cover that additional gear. AIl personnel which process hazardous waste undergo annual medical monitoring and yearly, eight hour updates for their 40 hour safety training.

In the landfill, the transporter is required to wear an air purifying respirator. Air purifying respirators typically contain the organic vapors, radionucleides, and particulates filters. Equipment operators in the trench include one to three earth movers, a back-hoe operator, and a loader. All of the equipment operators are required to wear tyvek suits, air purifying respirators, and gloves and booties. The landfill mapper does not wear additional safety equipment. He is in close proximity to the waste when the transporter hands him the manifests. The transporter then receives directions from the mapper on where to place the waste in the trench. Trucks were estimated to spend an average of ten minutes in the trench.

Page 4 MEMOIDOE-CWM July 1,1992

Workers at bulk sampling are required to wear air purifying respirators, tyvek suits, neoprene gloves, and rubber boots. Lab personnel wear a lab coat, safety glasses, and vinyl gloves only.

The next largest category of manifests of the mixed waste included waste that had to go to stabilization prior to being landfilled. Only one or two tons is thought to have required stabilization. This category of waste would involve all of the same personnel as that which went directly to the landfill, but would also include personnel at stabilization. M. H. Chew and Associates observed stabilization activity in both stabilization units.

The old stabilization unit went into operation in 1985. This unit employees three heavy equipment operators and one technician. A large quantity of dust is generated in the stabilization process. The closest man is approximately ten feet from the waste during stabilization. The technician p~obably ~eceives tht; least exposure as he handles the paperwork from the lab which contains the recipe for stabilization, and is involved with adding the cement to the waste bin.

The Chem Matrix building was also observed, as this new unit for stabilization might have processed some of the waste. The Chem Matrix building went into operation in 1990 and employees two heavy equipment operators, two chemical processors, one tec:h.nici.an, an~ a yard truck driv~r. A single supervis.or is .ov~r both the old stabilizatron unit and Chem Matnx. The Chern Matrix unit IS automated so workers were expected to have received less exposure than those at the old stabilization unit. Chem Matrix includes a size reduction unit, conveyors which weigh and transport the waste, and a magnetic belt. Portland Cement and stabilization chemicals are automatically added based on the weight of the waste, and its composition, which is determined by the lab. Debris removed by the magnetic belt is sent to the old stabilization unit. If debris is caught in the system, a man must enter the size reduction unit and remove it with a shovel.

Very little of the mixed waste is thought to have been received in drums. However, if received in drums some of this waste may have required stabilization prior to being landfilled. In. this instance, personnel in the Drum Management buildings would have been included. M. H. Chew and Associates observed operations here as well. Drums could be direct landfilled, contents of the drums could be emptied into a roll-off and either direct landfilled or stabilized and then landfilled, or waste could be stabilized in the drums. Some sampling occurs in the Drum Management building. All personnel in the Drum Management buildings wear air purifying respirators in addition to the standard safety equipment. In the case of the 1984 waste, stabilization would have to have been completed in the drums or in a roll-off as the old stabilization unit did not begin operation until 1985.

The third category of mixed waste manifests included one truckload of waste that went to a surface impoundment in 1986. This waste consisted of 4500 gallons of concentrated sodium hydroxide solution, pH 13-14. The surface impoundment was a six million gallon, approximately ten foot deep, rectangular pond with a division

Page 5 MEMO/DOE-CWM July 1,1992

down most of its length. The division served to separate the acidic side from the basic side of the pond. The division did not go the entire length of the surface impoundment in order to allow the two sides to mix at a controlled rate which served to neutralize the corrosive solutions. This unit was closed in 1988. The liquid portion was sent to Corpus Christi and. Port Arthur, TX for deep-well injection. The sludge was landfilled at the Emelle facility. Chew and Associates said that most of the radioactive uranium would have been landfilled with the sludge as uranium precipitates if the pH is greatly changed.

The fourth and final category of manifests included a PCB transformer which would have been drained and the oil would have gone to an incinerator. The transformer carcus would have been soaked in diesel to remove the remainder of the PCB contaminated oil, then drained and landfilled at the Emelle facility. Chew and Associates did not tour the PCB facility.

After a truck leaves the trench from hauling waste to be landfilled, it must go through the wheel wash facility. Here one man sprays the tires. He wears a yellow barrier suit, rubber gloves, and rubber boots. Again, Chew and Associates evaluated the dose that the man in the wheel wash may have been expected to have received based on the distance he stood from the truck which transported the waste, and the length of time an average wheel wash takes.

M. H. Chew and Associates summarized their unofficial findings on May 21. They felt that approximately 80 employees had come into contact with the mixed waste at some level. Personnel in bulk sampling, drum samplers, and persons in the old stabilization unit received the highest dose which was estimated to be approximately five minutes per sampling event. Four categories of exposure were evaluated: dermal contact, ingestion, inhalation, and bombardment. Bombardment is the only category which is considered to have had quantifiable exposure levels. This was a function of time and distance. The worst case scenario places exposure levels at approximately two or three tenths of a milliremper year. Terrestrial background levels of exposure to radiation in this area were estimated at 100-200 millirems per year. A meeting was held by Chew and Associates on May 21, open to all Chemical Waste Management employees, to address any concerns that they may have had about their personal exposure levels. Chew and Associates will send a copy of the final report to ADEM.

Dr. S. Y. Chen of Argon National Laboratories left after the first day of the investigation. He felt that the impact on the surrounding environment the public was none. The geology of the area and technical standards of trench construction were discussed.

Chemical Waste Management, Emelle Facility is situated on 650-750 feet of native chalk. This chalk consists of sandy, fossiliferrous limestone, and clay belonging to the Selma Chalk Group. The Selma Chalk Group is composed of two layers of chalk, ~he first 400 feet Demopolis. Ch. alk, aI?-d below that another 359 feet of Mooreville Chalk. The Selma Chalk Group SIts g>n the Eutaw Formation. The permeability of this chalk is tested at 1 X 10- cm/s. It is approximated by Chemical Waste Management, Incorporated that water leaching through this chalk would take 10,000 years to reach the aquifer beneath it. This is without the double-liner used in current trench construction. Trench 21 was opened in May of 1985. Wastes received prior to that time would have gone into an unlined trench.

, ,

Page 6 MEMOIDOE-CWM July 1,1992

Pacific Northwest Laboratories' (PNL) objective was to establish a standard for Department of Energy field offices to use in determining if a hazardous waste generated by them is mixed waste. They were evaluating Chemical Waste Management from a generic standpoint, and were interested in many of the same processes that M. H. Chew and Associates observed. Like Chew and Associates, PNL toured the facility but were not only interested in what happened to the mixed waste that was actually delivered to Chemical Waste Management, but all of the processes involved in waste management at the facility. Therefore, PNL reviewed the drum management building in greater detail, specifically the fuels recovery unit. Again, the focus was on the number of workers, PPE, distance of each worker from the waste, and length of exposure for each worker. Pacific Northwest Laboratories also considered the upset condition. In this instance the most likely deviation from normal operations would be the polymerization of chemicals in the fuels recovery tanks. This would require men to actually enter the tank to clean it, and level A PPE would be utilized.

Mr. Russell Zora of Chemical Waste Management questioned whether or not the mixed waste generated by Martin Marietta and received by Chemical Waste Management would meet 10 CFR part 20 standards since their standard operating procedures require all waste to be checked for radioactivity prior to being accepted for treatment or disposal, and compared to background levels for that site .. Since all of the mixed waste received by them from Martin Marietta passed this test the level of activity was lower than or equal to normal terrestrial levels in the area. M. H. Chew and Associates said that the shipments were still unauthorized in spite of the below background levels of activity due to the fact that the waste was contaminated with enriched uranium. The Nuclear Regulatory Commission sets criteria for "special nuclear material" (enriched materials) which are more rigorous than typical radioactive standards (which do not exist among the various Department of Energy field offices) for environmental and national security reasons. Pacific Northwest Laboratories will attempt to establish consistent standards for the DOE field offices to use to make mixed waste determinations.

M. H. Chew and Associates elaborated that typical background variation in the United States was from two to one hundred fifty picocuries of activity per gram of soil.

Samples collected by Oak Ridge Associated Universities on May 19 included one air sample at the stabilization pit, one sample of stabilization material, (Portland Cement), two surface-water samples at pond number seven, one surface-water sample at pond number three/four, and four soil samples around the perimeter of the facility. A pressure ionization chamber was used in conjunction with the soil samples. Additional samples were taken on May 20 including ground-water samples from monitoring wells, leachate (two samples from cell one's primary leachate collection system, and two samples from cell one's secondary leachate collection system), Leachate samples were taken at the leachate tank farm. It is not clear if cell one is of trench 21 or another trench. Cell one of trench 21 was closed approximately six months ago. ORAU stated on May 19 that they wanted to coUect two more air samples and four more perimeter soil samples in addition to the leachate and ground-water samples obtained on May 20. Results of samples will be forwarded to ADEM.

MLD/sdm:#1793

TABLE 1.

01/21/92 1984-1991 OFFSITE HAZARDOUS WASTE SHIPMENT

SITE ACTIVITY SUMMARY

BY FINAL TREATMENT/STORAGE/DISPOSAL FACILITY

Final TSO Facility Name:

Type of Service:

Location:

EPA 10 Number:

CHEMICAL WASTE MANAGEMENT

SO LRECOV/BLENO/LFILL/STABL/BROKER EMELLE ,AL

AL0000622464

Estimated Estimated Estimated Estimated Estimated
U234 U235 U238 TC99 Total
(mCi) (mci) (mCi) (mCi) (mc i.)
------------ ----.-------- ------------ ------------ ------------
ORO K25 0.09 0.00 0.02 2.87 2.98
ORO X10 0.00 0.00 0.00 0.00 0.00
ORO PORT 0.00 0.00 0.00 0.00 0.00
ORO PGOP 0.00 0.00 0.00 0.00 0.00
I ORO Y12 29.11 1.34 4.50 0.00 34.95
------------ ------------ ------------ ------------ ------------
Total 29.20 1. 35 4.52 2.87 37.93 ....

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ATTACHMENT 1 .

. @ Chemical Waste Management, Inc.

Emelle Faci.lity P.O. Box 55

Emelle, Alabama 35459·0055 205/652·9721

May 28, 1992

Jim Dittig - TSO Project Mgr. M.H. Chew and Associates, Inc. 1424 Concannon Blvd.

Livermore, California 94550

Re: Chemical waste Management, Inc.

Emelle, AI. Facility

Dear Jim;

Enclosed please find the summary report generated from the manifests which were reviewed during the dose assessment of May 19- 21, 1992. All the requested information is contained in the listing which is organized first by year of receipt and secondly by the type of shipment.

Certain terms or codes are used in the list which warrant some explanation. You will see some "mixed" physical state entries for drum loads. This denotes that some combination of solids, sludges or liquids were received in that shipment. "Mixed" container types means drums and transformers were received, and "drums" includes most types of containers like metal drums, boxes, crates, etc. with respect to management method, "081" denotes landfill operations, and "T21" means stabilization. Where drums of mixed physical state were received in 1990, we included information about how many drums were direct landfilled and how many required prior stabilization.

We trust this listing supplies you with the information required to draft the dose assessment. Should you have any questions or find any information lacking, please feel free to contact me at (205) 652-9721.

Sincerely,

CHEMICAL WASTE MANAGEMENT, INC.

~)tn-1~

RussellZora Environmental Manager

cc: Lee Davis - ADEM

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ATTACHMENT 2.

, .

SIGN-UP SHEET

DOSE ASSESSMENT MEETING MAY 19 I 1992 EMELLE, ALABAMA

=======================~=========================================

=================================================================

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