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final disposal acceptance criteria. In 1987, for example,

840 ash receivers from the 1977 shutdown of the feed

plant that were stored in C-746B, a radioactive waste

storage facility, were determined to also be hazardous

under RCRA. Therefore, this facility became a nonpermitted RCRA storage facility until the ash receivers

could be overpacked and moved to a permitted RCRA

facility. The limited degree of characterization has

resulted in storage problems and a need for very large

recharacterization efforts at the Plant, as discussed in

the Office of Oversight Phase I investigation report.

Oversight for hazardous waste activities also

increased from being a subset of landfill reviews to being

focused inspections. In the 1970s, OR conducted annual

appraisals of the C-746-K landfill and of water and air

pollution control facilities at the Plant. These appraisals

increased in scope and duration in the 1980s, with a

section specifically focused on hazardous waste

management practices. In addition, external regulators

began inspecting RCRA facilities and operations in the

1980s. Generally, these appraisals and inspections

praised the waste management programs. However,

problems were identified, including Notices of Violation

in 1985 for not performing detailed chemical and physical

analysis, and concerns about contingency planning with

local authorities and incomplete contingency plans. A

Notice of Violation was issued in 1986 for routine

disposal of sludge determined to be hazardous in the C404 facility, which had not been permitted for hazardous

waste. Conversely, the Plant also conducted evaluations

to determine whether private disposal sites were

adequately operated and capable of disposing of Plant

waste in accordance with applicable environmental

regulations.

Radioactive Waste Management

Radioactive waste management has been evolving

since the 1950s. In April 1953, efforts were initiated to

reduce the spread of contamination by using drums

designed for disposal in work locations known for

generating highly contaminated waste. Operating logs

in C-340 from 1958 discuss using a supply of scrap

drums from the holding pond for packaging black oxide

rather than putting the oxide in dumpsters. Actions to

segregate these wastes from the Plantís other waste

streams resulted in establishing radioactive disposal sites.

Although several small sites were used for special

disposal activities, including contaminated aluminum and

a modine trap, the Plant had three main radioactive

disposal sites:

ï C-749 Uranium Burial Ground. Used from 1957

to 1977, this site primarily contained pyrophoric

uranium metal in the form of saw dust, shavings,

and turnings covered in oil. The total amount of

uranium placed in this site is approximately 540,000

pounds.

ï C-340 Drum and Contaminated Burial Area. Used

from the late 1950s until the mid-1970s, this area

received C-340 uranium powder scrap. In the

1950s, 50 to75 drums were emptied into a pit 10

feet by 20 feet, and 7 feet deep. In the 1970s, two

more 7-foot-deep pits were used for disposal of

contaminated metals and equipment.

ï C-404 Solid Radioactive Waste Disposal Area. This

was the primary disposal site for radioactive waste

at the Plant. This area was constructed as a holding

pond for C-400 liquid waste, but in early 1957, it

was converted to a solid waste disposal area. The

pond was 380 by 140 feet, with 6-foot-high dikes.

By 1977, approximately 6,400,000 pounds of

uranium had been drummed and placed in the

holding area. Waste streams included incinerator

ash, contaminated alumina, highly contaminated

roofing waste, and gold recovery sludge. This area

continued in use into the mid-1980s. Subsequently,

this area was determined to contain sludge that was

also hazardous, thus requiring closure under RCRA

in 1987.

After the formation of the MTM Department,

radioactive waste disposal on site rapidly decreased. In

1978 and 1979, the amount of disposal was 330,690

pounds per year; in the 1980s, the average was 18,000

pounds per year. As a result of not burying radioactive

waste on site and restrictions for offsite disposal, the

site experienced a large buildup of contaminated waste

and scrap, as discussed in the Office of Oversight Phase

I investigation report.

4.2 Management and Disposal of

Scrap and Surplus Materials

Large volumes of scrap metal and surplus materials

were generated during construction, maintenance, and

facility upgrade activities at PGDP. These materials

were either managed as waste for disposal or stored

and managed as a commodity for resale. Much of the

material was contaminated, and large volumes have been
62

disposed of on site. Additionally, large volumes of scrap

metals remain in outside storage pending resolution of

policy issues associated with the resale of contaminated

materials.

As part of scrap metal activities at the Plant,

generators were responsible for requesting disposal

containers for contaminated and clean scrap metal and

then inspecting these containers to determine proper

usage. The Material Services Department established

and maintained approved scrap yards, and the

Maintenance Services Department collected and

transported the containers. In addition, special

responsibilities for classified scraps were defined in a

standard practice procedure. This procedure, dated

July 24, 1969, identified four scrap yards: C-746F for

buried classified material; C-746E for contaminated

material; an unclassified burial yard; and C-746C for

clean material (defined as less than 1000 alpha c/m/100

cm2 and less than 0.3 mrad/hr beta-gamma). This 1969

procedure also required supervisors to determine

whether contamination was sufficient to warrant

recovery at the C-400 decontamination and recovery

area. If not, the scrap was sent to one of the four

disposal yards. Source areas for scrap metal included

the C-340 metals plant, the cascades, the C-410 and C420 feed plant, the C-720 fabrication and maintenance

shops, and the laboratories. Part of the scrap was buried

directly (classified material); however, as the disposal

areas were filled, non-classified material began to

accumulate in above-ground piles that still exist. These

yards and disposal locations are now identified as

SWMUs for investigation and possible cleanup under

the current restoration program.

Some of the metal components, equipment, and

vehicles at PGDP had significant inherent value,

including a large amount of material that was considered

scrap as a result of upgrades or replacement of

equipment and process piping. Consequently,

management wished to sell to interested parties as much

of this material as was possible. Based on Plant health

physics records, it was clearly understood as far back

as the 1950s that ìcontaminatedî material above certain

limits could not be sold or released to the public.

Therefore, the handling and disposal of scrap materials

was subject to the corporate procedures described

above. While contamination limits and specific

categories changed over the years, scrap was required

to generally be categorized into one of four groups:

classified scrap, unclassified clean scrap, unclassified

contaminated scrap, and unclassified non-metal trash.

Dumpster pans were provided for each of these

categories wherever significant quantities of scrap were

generated. Line supervisors were responsible for

ensuring that employees segregated all scrap materials

appropriately. Once full, these dumpsters were hauled

to a designated location. The material categorized as

clean unclassified scrap was taken to the C-746C clean

scrap yards for placement and preparation for public

sale.

Interviews with former and current health physics

workers indicated that they believed materials released

to the public were surveyed for radioactive

contamination. However, the surveys were primarily

cursory, consisting largely of periodic inspections and

spot-checking of suspect materials in the clean scrap

yards based on process knowledge. Vehicle floorboards

and seats were also said to be spot-checked before sale

to the public, but the process was informal and was not

required by procedure. The Health Physics and Hygiene

Department was on the distribution for notices of pubic

sales and was aware of their responsibility to survey

ìsuspectî items to be sold. Documentation that proper

radiological surveys were performed was not

consistently maintained until the late 1980s, when the

Health Physics and Hygiene Department began to place

more emphasis on maintaining formal records for

radiological release of material and equipment from the

site.

The likelihood that contaminated items were

released to various parties during public sales is

highlighted by internal memoranda from the mid-1970s.

One memorandum calls attention to the fact that the

site was doing a less than adequate job of segregating

clean from contaminated scrap and that contaminated

scrap was often found in clean scrap locations. In May

1976, a health physics inspection of the C-746C scrap

yards identified a number of prohibited contaminated

items, most notably a 30-gallon drum of uranium metal

shavings. A Scrap Handling Committee was formed in

mid-1976 to study PGDP solid waste disposal problems,

including the issue of segregating contaminated scrap.

Some modifications to scrap handling procedures were

made; however, a 1977 memorandum indicated

continuing problems in this area, particularly with

proper implementation of the procedures.

Radiological surveys of several older DOE vehicles

still present at the site were conducted during this

Office of Oversight investigation. These surveys

revealed contamination in areas not likely to be

detected in cursory surveys of floorboards and seats,

such as in the tailgate of a station wagon and in the

motor housing and forks of a forklift.