Bettis - Pittsburgh Site Environmental Summary Report/67531/metadc720971/... · BETT’ISATOMIC POWER LABORATORY BETTIS-PITTSBURGH SITE ENVIRONMENTAL SUMMARY REPORT AUGUST 1999 Prepared

B-RCIE(EE)EMR-0500

Bettis - Pittsburgh SiteEnvironmental Summary Report

Bettis Atomic Power LaboratoryWest Mifflin, Pennsylvania 15122-0079

wq,,● Prepared for the

#

U.S. Department of Energy

:4

,., By Bechtel Bettis, Inc.

Under Contract No. DE-ACII-98PN38206\

*~p cw’M-lts printed on recycled paper

BETT’ISATOMIC POWER LABORATORY

BETTIS-PITTSBURGH SITE

ENVIRONMENTAL SUMMARY REPORT

AUGUST 1999

Prepared by

Bechtel Bettis, Inc.BETTIS ATOMIC POWER LABORATORY

West Mifflin, Pennsylvania

For theU.S. Department of Energy

Document Number: B-RC/E(EE)EMR-0500

DISCLAIMER

This report was prepared as an account of work sponsoredby an agency of the United States Government. Neitherthe United States Government nor any agency thereof, norany of their employees, make any warranty, express orimplied, or assumes any legal liability or responsibility forthe accuracy, completeness, or usefulness of anyinformation, apparatus, product, or process disciosed, orrepresents that its use wouid not infringe privateiy ownedrights. Reference herein to any specific commercialproduct, process, or service by trade name, trademark,manufacturer, or otherwise does not necessarily constituteor impiy its endorsement, recommendation, or favoring bythe United States Government or any agency thereof. Theviews and opinions of authors expressed herein do notnecessarily state or refiect those of the United StatesGovernment or any agency thereof.

DISCLAIMER

Portions of this document may be illegiblein electronic image products. Images areproduced from the best available originaldocument.

TABLE OF CONTENTS

TABLE OF CONTENTS .......................................................................................................

LIST OF FIGURES ............................................................................................................

LIST OF TABLES ............................................................................................................

LIST OF ACRONYMS ........................................ ..................................................................

1.0

2.0

3.0

4.0

5.0

OVERVIEW AND CONCLUSIONS .............................................................................1.1 Background .......................................................................................................1.2 Purpose ............................................................................................................1.3 Conclusions ............. .........................................................................................

THE BE717S ATOMIC POWER LABORATORY, BETTIS-PITTSBURGH SITE .........2.1 Bettis-Pittsburgh Site History .......................................................... ..................2.2 Significant Accomplishments ....... .....................................................................

DESCRIPTION OF SITE ............................................................................................3.1 Site Location ...... ...............................................................................................3.2 Land Use and Demography .............................................. ................................3.3 Topography, Geology and Seismology ............................. ................................3.4 Hydrology ............................................. .............................................................

3.4.1 Surface Water Description and Uses ...................................................3.4.2 Ground Water Description and Use .....................................................3.4.3 River Water Use ..................................................................................

3.5 Cultural Resources Management ......................................................................

DESCRIPTION OF OPERATIONS ... ..........................................................................4.1 Past Operations ...............................................................................................-4.2 Present Operations ...........................................................................................

WASTE GENERATION AND CONTROLS .................................................................5.1

5.2

5.3

Current Waste Management Programs .............................................................5.1.1 Current Radioactive Waste Management ............................................5.1.2 Current Non-Radioactive Waste Management .....................................5.1.3 Current Mixed Waste Management .....................................................Past Waste Management Practices ..... .............................................................5.2.1 Past Radioactive Waste Management .................................................5.2.2 Residual Radioactivity in Soil, Ground Water, Surface

Water and Sediment ............................................................................5.2.3 Past Non-Radioactive Waste Management .........................................5.2.4 Chemical Residues in Soil, Ground Water, Surface Water and

Sediment ............................................................................................Decontamination and Remedial Programs ........................................................5.3.1 Decontamination and Remedial Programs for Radioactivity ................5.3.2 Remedial Programs for Chemical Residues ........................................

i

...Ill

...Ill

iv

1111

555

6666889

1010

111111

16161618202121

2329

29343435

Beftis-Pittsburgh Environmental Summary Report

TABLE OF CONTENTS (Continued~

6.0

7.0

8.0

9.0

MONITORING PROGRAMS .................................... ...................................................6.1 Aerial Radiation Survey .....................................................................................6.2 Ground Water Monitoring ..................................................................................

ASSESSMENT OF HUMAN HEALTH IMPACTS ........................................................7.1 Radiological Assessment ..................................................................................7.2 Non-Radiological Assessment ....................... ............................................. ......

AUDITS AND REVIEWS ............................................................................................

REGULATORY MA~ERS .........................................................................................

REFERENCES ....................................... ..............................................................................

DISTRIBUTION .............................................................................. ......................................

373737

383838

40

43

45

46

ii

Bettis-Pittsburgh Environmental Summary Report

LIST OF FIGURES

FIGURE 1 BETHS-PllTSBURGH SITE PLOT PMN ......................................................7

FIGURE 2 SITES OF MAJOR PRESENT OPERATIONS ..............................................12

FIGURE 3 KEY AREAS WITH RADIOACTIVE AND/OR CHEMICAL RESIDUES ..........24

...Ill

LIST OF TABLES

TABLE 1 ENVIRONMENTAL INSPECTIONS OF THE BEITIS-PllTSBURGH SITE ..41

Beffis-Pittsburgh Environmental Summary Report

LIST OF ACRONYMS

ACHD Allegheny County Health Department

Consent Order Administrative Order of Consent

AEC Atomic Energy Commission

CAA Clean Ak Act

CERCLA Comprehensive Environmentaland Liability Act

CMS Corrective Measures Study

DCE Dichloroethylene

DOE U.S. Department of Energy

DOP Dioctylphthalate

EPA

EPCRA

FFCA

HTTF

IWIP

Iws

LWBR

MSL

MEL

MWSF

N-MTR

NNPP

NOV

NPDES

NRC

PADEP

Response, Compensation

U.S. Environmental Protection Agency

Emergency Planning and Community Right-To-Know Act

Federal Facility Compliance Act

High Temperature Test Facility

Inactive Waste Isolation Pit

Inactive Waste Site

Light Water Breeder Reactor

Mean Sea Level

Materials Evaluation Laboratory

Mixed Waste Storage Facility

N-Building Monitor Tank Room

Naval Nuclear Propulsion Program

Notice of Violation

National Pollutant Discharge Elimination System

Nuclear Regulatory Commission

Pennsylvania Department of Environmental Protection(Formerly Department of Environmental Resources)

iv


PAH

PCB

PCE

PNR

RCRA

RFI

SARA

SPCC

TCE

Voc

VNGI

WERF

LIST OF ACRONYMS (Continued~

Polynuclear Aromatic Hydrocarbon

Polychlorinated Biphenyls

Tetrachloroethylene (Also known as Perchloroethylene)

Pittsburgh Naval Reactors Office

Resource Conservation and Recovery Act

RCRA Facility Investigation

Superfund Amendments and Reauthorization Act

Spill Prevention Control and Countermeasure

Trichloroethylene

Volatile Organic Compound

Valley National Gases, Incorporated

Waste Experimental Reduction Facility

v

Bettis-Plttsburah Environmental Summarv Re~ort

1.0 OVERVIEW AND CONCLUSIONS

The Bettis Atomic Power Laboratory (Bettis-Pittsburgh) is owned by the U.S.Department of Energy (DOE) and wasoperated under Government contract by theWestinghouse Electric Company from 1949to 1999. In February 1999, Bechtel Bettis,Inc. assumed contract operations. TheBettis-Pittsburgh site in West Mifflin,Pennsylvania conducts research anddevelopment work on improved nuclearpropulsion plants for U.S. Navy warshipsand is the headquarters for all Laboratoryoperations (Section 4.0).

1.1 Background

For many years, environmental monitoringhas been performed to demonstrate that theBettis-Pittsburgh site is being operated inaccordance with environmental standardsas defined by law and regulation. Theresults of this monitoring have beenpublished in annual reports provided tofederal, state, and local officials. Thesereports document that Bettis-Pittsburghoperational practices meet and are oftenmore strict than the requirements ofapplicable laws and regulations. Themonitoring results confirm that Bettis-Pittsburgh has complied with environmentalstandards and guidelines and in most caseshas exceeded compliance with significantmargin.

1.2 Purpose

The purpose of this report is to describe thenature and environmental aspects of workand facilities at the Bettis-Pittsburgh siteand provide a historical perspective ofBettis-Pittsburgh operations that is notprovided by the annual reports. This reportalso provides background information, suchas the geologic and hydrologic nature of theBettis-Pittsburgh site, pertinent tounderstanding the environmental aspects ofBettis-Pittsburgh operations.

1

1.3 Conclusions

The following conclusions may be drawnfrom this report and the annualenvironmental monitoring results:

- Bettis-Pittsburgh has in placeeffective environmental controlprograms which meet or exceed therequirements of applicable laws andregulations. Bettis-Pittsburghperformance in radioactivity control iswell established and the laboratorymaintains levels of control that are farmore stringent than Federalrequirements (Sections 5.0, 6.0 and7.0). The following examplesillustrate this point

. Radiation exposure to anymember of the public due toBettis-Pittsburgh site operationsis too small to be measurable.The maximum possible annualradiation dose to any member ofthe public resulting from currentoperations can only be calculatedusing very conservativeassumptions of release andhuman uptake. The calculationsshow that the maximum dose isless than 0.003 Rem per year.This is less radiation thanreceived from cosmic radiationduring a round trip airline flightfrom Pittsburgh to the west coastof the United States (0.003-0.004Rem). The calculations alsoshow that the annual radiationexposures to people livingadjacent to Bettis-Pittsburgh in allprevious years were well belowthe annual regulatory limitsestablished by the U.S.Environmental Protection Agency(EPA) and the DOE.


. There are no radioactive wasteburial grounds at the Bettis-Pittsburgh site. There areminimal areas on the Bettis-Pittsburgh site where someradioactivity was released in theearly days of site operations. Thetotal amount of radioactivitycurrently in the affected onsiteareas is estimated to be”less than72 curies. This is less than theamount of naturally occurringradioactivity in the top 2 feet ofsoil covering any local area ofequal size to the Bettis-Pittsburghsite (Sections 5.2 and 7.0).

. In 1991 the PennsylvaniaDepartment of EnvironmentalProtection (PADEP) concludedthat the levels of residualradioactivity on and immediatelyadjacent to the site were farbelow action levels and furtherremedial action would not berequired.

Bettis-Pittsburgh site practices forhandling chemical materials andwaste conform with establishedregulatory requirements. In the earlydecades of operation, chemical wastedisposal was carried out inaccordance with what were commonindustrial practices at the time. Inaddition, some chemicals may havebeen disposed of or spilled on theground when the Bettis-Pittsburgh sitewas an airport. These practicesresulted in small amounts ofchemicals, such as decreasingsolvents, being present in the soil invarious locations around the site.Chemical residues have been foundin the landfill on a steep hillside on thenorthwestern portion of the site wheresome waste chemicals were disposedof prior to 1964. Chemical residueshave also been found at a separatelandfill area on the northeast side andat a few other locations ,adjacent to

2

buildings. Ground water monitoring atthe site has shown that severalchemical species are detectable inthe ground water. However, sinceneither Bettis-Pittsburgh nor thepublic use this ground water thatcontains the chemical residues, andgeologic conditions are likely toprohibit exposure of offsite receptorsto ground water, the chemicals do notpose any health hazard to the public(Sections 5.2.4 and 7.0).

An evaluation of the areas containingradioactivity and chemical residues atthe Bettis-Pittsburgh site wasconducted in accordance with theComprehensive EnvironmentalResponse, Compensation, andLiability Act (CERCLA) (SeeReference (1)). This evaluationdetermined that the risk presented bythe site to the public health andenvironment was not significant. Inaddition, the evaluation indicated thatthe Bettis-Pittsburgh site did notqualify for the National Priority Listunder the National “Superfund” law.This evaluation has been reviewed byRegion Ill of the EPA who assigned ahazard ranking score of zero. TheEPA concluded that no furtherregulatory action was required underCERCLA. Bettis-Pittsburgh hascontinued actions to reduce anyimpact on the environment fromresidual chemical or radioactivematerials by working within thebounds of federal, state, and DOEregulations (Sections 5.1 and 7.0).

Bettis-Pittsburgh operates ahazardous waste storage facilityunder a Hazardous Waste StoragePermit issued in February of 1995 bythe PADEP. During the periodbetween June 1985 and February1995, Bettis-Pittsburgh operated thehazardous waste storage facilityunder interim status. The ResourceConservation and Recovery Act


(RCRA) requires that sites havinginterim status and/or a final permit forhazardous waste treatment, storageor disposal address releases ofhazardous waste to the environment.This matter was formalized in anAdministrative Order of Consent(Consent Order) in August 1990. Aspart of the Consent Order, the EPAagreed that the conditions onsite donot require implementation of interimmeasures or immediate correctiveactions since Bettis-Pittsburgh siteconditions do not present an imminentsubstantial endangerment to humanhealth or the environment. TheConsent Order required that a RCRAFacility Investigation (RFI) andCorrective Measures Study (CMS) beperformed to address the residualchemicals in the soil and groundwater at the site. Bettis-Pittsburghhas completed the required RFI andCMS. The Final RFI Report,Reference (2), was approved by theEPA in August 1994. The Final CMSReport, Reference (3), was approvedby the EPA in March 1995. The EPAissued its final decision and responseto public comments in October 1997.The EPA terminated the ConsentOrder in November 1997 and statedthat all requirements of the ConsentOrder had been met. Many correctivemeasures have been initiatedvoluntarily pending issue of aCorrective Measures ImplementationConsent Order.

- Bettis-Pittsburgh operates a mixedwaste storage facility under theinterim status provisions of RCRA andCommonwealth of Pennsylvania rulesand regulations. The storage facilityis used to store mixed waste (wasteclassified as both radioactive andhazardous) prior to offsite shipmentfor treatment or disposal.

- A risk assessment was approved bythe EPA as part of the Final RFIReport. The objective of theassessment was to determine the“reasonable maximum exposure” ofonsite and offsite populations toenvironmental contamination at thesite. The risk assessment concludedthat chemical residues in theenvironment at the site do not posesignificant health risks to potentiallyexposed populations using“reasonable maximum exposure”assumptions.

Only one study area was found wherethe carcinogenic risk estimateexceeded the EPA comparisoncriterion of 1 x 10+. Valley NationalGases, Incorporated (VNGI) wasdetermined to have soil with amaximum carcinogenic risk ofapproximately 2 x 10-5. However,exposure (dermal contact, ingestion,and inhalation) for 250 days/year for25 years is required to achieve thisrisk. This risk is within the EPA post-remediation criteria of 1.0x 104 to 1.0x 10%. In addition, the estimated riskis highly conservative because thecontaminated portions of VNGIproperty are infrequently accessed orare located in undeveloped areas. Amore realistic estimate of the risk toexposed populations from VNGI soilis far less than 1.0 xl 0% (Section 7.2).

- Bettis-Pittsburgh operations andenvironmental performance havealways been subject to continuousoversight by Pittsburgh NavalReactors Office (PNR) {the residentrepresentatives of the Naval NuclearPropulsion Program (NNPP) of theDOE (previously the Atomic EnergyCommission (AEC) and the EnergyResearch and Development Agency)}and by periodic in-depth reviews andinspections by NNPP headquarterspersonnel (Section 8.0).

3


- In addition to Bettis-Pittsburgh and In conclusion, in over fifty years ofNNPP reviews and inspections, operation, there has been no significantvarious aspects of Bettis-Pittsburgh impact from Bettis-Pittsburgh operations onenvironmental programs have been the environment, the community, public, orinspected by federal, state, and local employees. The Bettis-Pittsburgh site has aagencies. These inspections have well-defined environmental program in placefound Bettis-Pittsburgh operations to to monitor current operations and addressbe in compliance with regulatory past activities.requirements (Section 8.0).

4


2.0 THE BETTIS ATOMIC POWER LABORATORY,BETTIS-PITTSBURGH SITE

The Bettis Atomic Power Laboratory isowned by the DOE and was operated underGovernment contract by the WestinghouseElectric Company from 1949 to 1999. [nFebruary 1999, Bechtel Bettis, Inc.assumed contract operations.

2.1 Bettis-Pittsburgh Site History

The Bettis-Pittsburgh site was originallyused as Pittsburgh’s first airfield. ThePittsburgh-McKeesport Airdrome opened in1925 but was later renamed Bettis Airfield inhonor of Lieutenant Cyrus Bettis, a famousaviator. In 1940, most commercial trafficmoved to nearby Allegheny County Airportbecause the Bettis airfield could not handlethe increasingly larger, modern aircraft.Private aviators used the field until 1948.

The newly formed Westinghouse AtomicPower Division bought the Bettis airfieldtract in early 1949 and purchased adjacentproperties in 1952. The land was acquiredaccording to a contract betweenWestinghouse and the AEC wherebyWestinghouse was assigned certainresponsibilities for engineering, design,procurement, and construction work for theprototype of the first Naval nuclear reactorplant. Later, in 1957, the AEC (now DOE)exercised its contractual option to purchasethe site and has held title since then. TheBettis-Pittsburgh site has evolved into adevelopment, engineering, and designfacility for Naval nuclear propulsion work.All Naval nuclear propulsion work has beenand remains under the sole technicaldirection of the NNPP. The NNPP operatedinitially as an element of both theDepartment of the Navy and the AEC, and

now operates as a joint Navy and DOEorganization.

2.2 Significant Accomplishments

The technology developed at Bettis-Pittsburgh is among the most valuable andsensitive military technologies in the UnitedStates. It is a critical element of theNation’s defense, making possible theextraordinary capabilities of U.S.nuclear-powered warships which todaycomprise about 40?40of the Navy’s combatfleet. Key achievements of Bettis-Pittsburghinclude the development of the power plantsfor the first nuclear-powered submarine, theNAUTILUS; the first nuclear-poweredsurface ship, the cruiser LONG BEACH; thefirst nuclear-powered aircraft carrier, theENTERPRISE; as well as the newest,technologically advanced submarine, theSEAWOLF.

Under the NNPP DOE authority, Bettis-Pittsburgh designed and developed the firstfull-scale nuclear power plant for civilianuse, the Shippingport Atomic Power Station.Later, Shippingport was also the site of thefirst Light Water Breeder Reactor (LWBR),an advanced reactor system developed tosignificantly improve the utilization of fuel innuclear reactors. Bettis-Pittsburgh has alsodeveloped advanced nuclear propulsionplants and long-lived reactor cores formodern nuclear-powered ships includingattack submarines and ballistic missilesubmarines. Work continues today onfurther advances in Naval nuclearpropulsion technology.

Bettis-Pittsburgh Environmental Summary Repoti

3.0 DESCRIPTION OF SITE

3.1 Site Location

The Bettis-Pittsburgh site is located in theBorough of West Mifflin, Allegheny County,Pennsylvania approximately 8 milessoutheast of central Pittsburgh. The site,shown in Figure 1, consists ofapproximately 202 acres of land.

The developed portion of the Bettis-Pittsburgh site consists of laboratories,offices, warehouses, workshops, and aboiler house for centralized heating ofseveral buildings. This developed sectionconsists of 20 acres of buildings and 17acres of parking area. Water for domestic,fire protection, and cooling purposes issupplied by the Pennsylvania-AmericanWater Company. Electrical power isfurnished by Duquesne Light Company.Domestic sewage from the site isdischarged into the local publicly ownedsewage treatment plant.

3.2 Land Use and Demography

The land use of the region surrounding thesite is largely industrial and residential. Thesection of West Mifflin Borough in which thesite is located is zoned as Heavy Industrial.The total population within a 50 mile radiusof the site is approximately 3,000,000.

A heavily wooded area borders the site onthe east. Most of this property is owned bythe Borough of West Mifflin. Some of thisWest Mifflin owned property has beendeveloped into the West Mifflin CommunityPark. A fence has been erected to preventinadvertent access to the site property fromthe park area. An industrial district islocated along the northern boundary of thesite. Commercial and residential develop-

ments border the site on the south andwest. Two public roadways run along thelength of the southern perimeter of theproperty and a railroad runs along thenorthern end.

3.3 Topography, Geology, andSeismology

Allegheny County, Pennsylvania is situatedwithin the Allegheny Plateau physiographicprovince of North America. Physiographyrefers to the natural physical Iandforms ofan area. Stream erosion of a formerlyraised plateau produced the present ruggedland surface at the Bettis-Pittsburgh site.The geologic formations are generally flat-Iying or gently folded and inclined.

The number of streams and the percentageof the land found in slopes decrease withdistance from the major waterways, such asthe Monongahela River.

The site is located approximately 6000 feetwest of the Monongahela River. Themaximum elevation at the site isapproximately 1200 feet above mean sealevel (MSL). The minimum elevation,approximately 975 feet above MSL, occurson the northern site boundary. The normalpool elevation of the Monongahela Rivernear the site is approximately 720 feetabove MSL. The developed portions of thesite are approximately 480 feet above thesurface of the Monongahela River.

Surface drainage at the site is primarilytoward the east, discharging into Bull RunStream and its tributaries. A narrow, mostlysloped area that includes a small develop-ed portion of the site drains northwestdirectly into Thompson Run Stream.

6

Bettis-Pittsburgh Envlronmenta/ Summary Report

i&ELllswJJ.amavw

Sn

8


The soils at the site are residual in origin,having been formed by weathering of theunderlying Monongahela Group bedrock orare the result of filling operations. None ofthe site land is utilized for agrarianpurposes. The soils onsite are classified asthe Culleoka and Urban Land-Guernseysoils. The Culleoka soils are characterizedas moderately deep, well drained soilsformed from shale and fine grainedsandstone bedrock. They generally occuron upland slopes, have moderatepermeability, and normally a water tablebelow four feet throughout the year. Thesurface soil can be described as darkbrown, granular silt loam, while the subsoilis yellowish-brown, blocky silt loam tochannery clay loam. The substrata consistsof yellowish-brown, massive, very channeryclay loam.

The Urban Land-Guernsey soils aredescribed as variable consisting ofdisturbed land resulting from cut and filloperation and subsequent coverage withurban works. These soils occur in acomplex pattern with Culleoka soils whichare described above. The Urban Land-Guernsey soils are characterized as deep,well drained soils with a low permeabilityand a winter water table within 1 or 2 feet ofthe surface. This soil type is formed frominterbedded clay shale, shale, andlimestone bedrock.

The geologic formations that underlie theportion of Allegheny County in which thesite is located are part of the PennsylvaniaSystem. The Monongahela, Conemaugh,and Allegheny Groups are all part of thePennsylvania System and underlie the site.The Monongahela Group, the uppermostgroup, includes beds of limestone, variableshales, discontinuous layers of sandstoneand coal beds. Several of these coal bedshad significant economic importance. Thebase of the Pittsburgh Coal marks the baseof the Monongahela Group.

Some of the important beds in theMonongahela Group are the UniontownLimestone, Benwood Limestone, SewickleySandstone, Fishpot Limestone, PittsburghSandstone, and the Redstone andPittsburgh Coal. Core borings taken onsiteconfirm that the bedrock consists of layersof limestone, shale, and sandstone.

Extensive mining of the Pittsburgh Coalseam has occurred to the west and south aswell as under the site. The Pittsburgh Coalseam lies about 200-250 feet below theactive portion of the site. Most of thePittsburgh Coal that can be mined has beenremoved. There are no current coal miningactivities in this area.

Bettis-Pittsburgh is located in a landslideand mine subsidence prone area of westernPennsylvania. The developed area of thesite is considered free of landslide hazards.While the steep slopes on the eastern andnorthern edge could be affected bylandslides, these areas are stabilized withvegetative growth. The probability of minesubsidence is considered very low becausethe mines are located approximately 200-250 feet below the site.

The seismic risks for the region in which theBettis-Pittsburgh site is located are judgedto be minimal. This conclusion is supportedby the U.S. Coast and Geodetic Survey of1947 which placed the site within a zonewhere earthquake damage has been minorand where intensities are normally belowthe threshold of structural damage.

3.4 Hydrology

3.4.1 Surface Water Description andUses

Surface water flow at the Laboratory,including stormwater management, isprimarily toward the east, discharging intothe Bull Run Stream and its tributaries. Anarrow, mostly sloped area that includes asmall portion of the developed area of the

Bettis-Pittsburgh Environmental Summary RepoH

site drains northwest into the ThompsonRun Stream.

The waters in the Bull Run Stream, whichoriginates on the site, include municipal,once-through, non-contact cooling water,stormwater runoff, and some dilute processwaste water. Springs and seeps alsodischarge to the stream from variouslocations onsite including the discharge oftreated ground water from the SpringwaterIntercept System. Approximately 52 milliongallons of water were discharged into theBull Run Stream from the Bull Run andNortheast Area outfall monitoring stations in1998; these outfalls are National PollutantDischarge Elimination System (NPDES)permitted outfalls #ool and #oo2,respectively. A significant portion of thisdischarge was precipitation runoff collectedby the site storm sewer system. The BullRun Stream flows about 1.4 miles beforejoining Thompson Run Stream whichempties into the Monongahela River inDuquesne. There are no known uses of theBull Run and Thompson Run Streams.Thompson Run is known to contain minedrainage and occasionally some rawsewage, neither of which comes from theBettis-Pittsburgh site.

An aquatic biology survey of Bull RunStream by representatives of the PADEP in1995 indicated the stream maintains adiverse, sustainable population of macro-invertebrates. This condition indicates goodwater quality in Bull Run Stream.

Because of the location and elevation of thesite, flooding from local streams or rivers isnot possible. Some minor bank overflowingfrom Bull Run Stream may occurdownstream from the site during heavyrainfall. There were a minimal amount ofidentified wetlands onsite associated withsprings.

Some water from offsite enters the sitestorm sewer system through a manholelocated west of Hangar #1. This offsite flowconsists mainly of precipitation runoff from

an offsite road and has been shown, onoccasion, to have an elevated pH and/or tocontain high levels of suspended solids.The constituents of this water can influencethe water quality of the Bull Run Outfall(#001 ) effluent and have resulted in onedocumented case of an NPDES non-compliant situation. Bettis-Pittsburgh hasinformed the PADEP and the PennsylvaniaDepartment of Transportation of thiscondition.

3.4.2 Ground Water Description and Use

Bettis-Pittsburgh has performed anextensive assessment of the hydrogeologic(ground water flow) conditions at the site.The results of this assessment are providedin Reference (2).

There are no wells or springs onsite or inthe local, hydraulically downgradient areawhich are known to be used for drinkingwater, industrial, or irrigation purposes.

The site is underlain by the geologic units ofthe Pennsylvanian Monongahela Group.The Monongahela Group is not an importantlocal aquifer. Well yields from theMonongahela Group range from less than 1to 30 gallons per minute.

The topographic features of the area suchas high hills cut by major stream valleysgreatly affect the direction and depth ofwater tables. There may be subregionalground water regimes where the dischargeof the ground water is to local streams. Incases where the stream channels lie belowthe water table, some aquifers maydischarge on valley slopes. Based on dataobtained through rock coring, monitoringwell drilling, geophysical logging, andground water elevation monitoring, theground water under the site was determinedto be in five different water-bearing zones.These water-bearing zones, in descendingorder, are the Perched zone, BenwoodLimestone zone, Sewickley Sandstonezone, Pittsburgh Sandstone zone, andPittsburgh Coal zone. The Pittsburgh Coal

9

Bettis-Pittsburgh Environmental Summary Repofl

water-bearing zone represents the bottom-rnost ground water flow studied at the site.

Several springs, which are surfacemanifestations of ground water, dischargeon the site property. The largest springswere on the eastern, undeveloped portion ofthe site. These were permanent springswith varying flows that were reflective of theseasons. A few of these springs containedtrace levels of decreasing solvents fromhistorical operations. In 1997, theSpringwater Intercept System was installedto collect and treat the ground waterdischarging from these springs.

3.4.3 River Water Use

Along with its role as a navigable waterway,the Monongahela River is a significantrecreational source and it supplies water fordomestic and industrial purposes. There isa public water supply intake (Becks Run)located about 8 miles downstream of theconfluence of Thompson Run Stream with

the Monongahela River. The Becks Runintake is operated by the Pennsylvania-American Water Company and servicesresidential and industrial customers,including Bettis-Pittsburgh, in themetropolitan area surrounding Pittsburgh.

3.5 Cultural Resources Management

An evaluation of the Bettis-Pittsburghcultural resources has been conducted.This evaluation indicated that there are nohistoric or archaeological properties eligibleto be listed in the National Register ofHistoric Places at the Bettis-Pittsburgh site.This evaluation has been documented in aCommonwealth of Pennsylvania,Department of Environmental Protection,General Environmental, Social andEconomic information, Module No. 9required as part of the Bettis-PittsburghRCRA Part B Permit application for thestorage of hazardous waste. This modulewas also provided as an Appendix inReference (1).

10

Bettis-Pittsburah Environmental Summarv Re~ort

4.0 DESCRIPTION OF OPERATIONS

4.1 Past Operations

In 1951, the Navy awarded the BettisAtomic Power Laboratory a contract to buildthe power plant for the world’s first nuclear-powered submarine, the NAUTILUS. Muchof the assembly work on the NAUTILUSnuclear reactor core was done at the Bettis-Pittsburgh site.

Since the NAUTILUS, advanced technologyfor submarine and surface ship nuclearreactor plants has constituted a majorportion of the work program. Bettis-Pittsburgh’s work on the prototype nuclearpropulsion plant for a surface ship, andsuccessful operation of the prototype at theNaval Reactors Facility in Idaho Falls,Idaho, led to the development of the firstnuclear-powered surface ship, the cruiserLONG BEACH, and the firstnuclear-powered aircraft carrier, theENTERPRISE. The ENTERPRISE waslaunched in September 1960.

Under the AEC Division of Naval Reactors,Bettis-Pittsburgh also worked on the designand development of the first full-scalenuclear power plant for civilian use. Thiswas the Shippingport Atomic Power Stationlocated in Shippingport, Pennsylvania.Subsequently, Bettis-Pittsburgh designedand developed the first LWBR core whichwas placed in the Shippingport reactorvessel in 1977 and was operated untilOctober 1982. The LWBR reactor core wasassembled at Bettis-Pittsburgh. Thisadvanced reactor system was developed toimprove significantly the utilization of fuel innuclear reactors. The technologydeveloped for the Shippingport program hasbeen made available to industry forcommercial application.’

11

Research to support the aboveaccomplishments was conducted in theareas of material development, fuel elementfabrication, high and low temperaturetesting of reactor components, and nuclearphysics.

The design, development, and operation ofnuclear propulsion plants for the propulsionof submarine and surface ships for the Navywas and still is the cornerstone of Bettis-Pittsburgh operations.

4.2 Present Operations

Much of the work at Bettis-Pittsburgh doesnot involve chemicals or radioactivity but isconducted in office and computer spacesemploying scientists and engineers inpropulsion plant design, operator trainingdevelopment, and procedure preparationactivities. Physical work involving thedevelopment of improved materials andcomponents for Naval nuclear propulsionplants is conducted in several Bettis-Pittsburgh facilities which are describedbelow and shown in Figure 2.

Chemical Laboratories

The chemical laboratories consist of severalindividual laboratories for massspectrometry, corrosion testing, chemicalanalysis, radiochemistry, and other relatedanalytical and developmental functions.Most of the chemistry laboratory wotkinvolves non-radioactive materials and isconfined to appropriate containment areassuch as hoods. For radioactive work, thecontainment areas are provided with highefficiency filtered and monitored ventilationexhaust systems. Liquids that aregenerated are collected for processing.

Bettk-Pittsburgh Environmental Swnmarv Report

12


Fluids and Corrosion Testinq Facilities

Fluids testing facilities are used to conductpower plant component testing. Both highand low pressure and temperature facilitiesare operated to support materials andequipment development work. Except fornon-contact once-through cooling waters,waste liquids from these test facilities arecollected, processed, and tested prior todisposal. Radioactive materials are notused in any of this test work.

Metalhmical Laboratories

These laboratories are operated to provideservices related to the development,fabrication, testing, and inspection ofmaterials for use in Naval reactors. Similarto the other laboratories, most of the work ison non-radioactive materials. Radioactivework involving easily divisible materials isconfined to containment serviced by highefficiency filtered and monitored ventilationsystems and radioactive liquids arecollected for processing.

Materials Evaluation Laboratory

The Materials Evaluation Laboratory (MEL)consists of a metallurgical laboratory asdescribed above and support facilities fortesting of low level radioactive materialspecimens. Routine physical, chemical,and metallurgical testing of highlyradioactive materials was discontinued in1993 and support facilities are undergoingdecontamination. The facility is designed toensure complete containment of theradioactivity within shielded rooms equippedwith high efficiency exhaust air filters thatfilter airborne radioactivity. Air iscontinuously monitored and radiation andcontamination surveys are petformedfrequently to verify the integrity of theshielded containment rooms and theeffectiveness of the air handling systems.

13

Machine Shops

Machine shop facilities are used to performmachining operations such as turning,milling, and drilling on a variety of metalproducts including non-radioactive metals,fuel specimens, and other radioactivematerials. The facilities for work onradioactive metals are segregated from theother work areas and are provided withspecial containment and high efficiencyfiltered ventilation exhaust systems whenthe possibility for radioactive contaminationresulting from the process exists.

Fuel Storaqe Vault

Fissile materials for use in reactordevelopment are stored in a fuel storagevault with special safety and securityprovisions. The storage vault is equippedwith radiation monitors. Personnel involvedin the handling of these materials arespecially trained in nuclear and radiologicalsafety and security.

SuPPort Facilities

In addition to the technical facilitiesdescribed above, there are a number ofsupport facilities necessary to sustainBettis-Pittsburgh operations. Thesefacilities include office buildings whichhouse the scientists and engineers, alibrary, a computing center, administrativecenters, and the following service facilities.

Main Boiler House

The Main Boiler House provides steam heatand hot water for the majority of the onsitebuildings. The Boiler House also containsthe circulating water pumps which supplychilled water for building and equipmentneeds and emergency fire service pumpswhich supplement fire line pressure upondemand. Auxiliary support facilities in thebuilding include feedwater treatmentcomponents, such as softeners, and asecondary water chemical addition tank for


treatment of boiler blowdown water. Boilerblowdown water is treated and dischargedto the sanitary sewer system. Combustiongases from onsite boilers, including boilersand hot water heaters discussed below, aredischarged through stacks.

The Boiler House has four large boilers,each with approximately 20 million BTU/hrinput. The boilers are operated inaccordance with the Allegheny CountyHealth Department (ACHD) air pollutioncontrol requirements. Two of the boilersoperate on natural gas and the other twoboilers operate on either natural gas or No.2 fuel oil. The fuel oil is stored in a diked,above ground tank adjacent to the MainBoiler House. The fuel oil storage tank hasa Spill Prevention Control andCountermeasure (SPCC) Plan prepared inaccordance with federal regulations.

Satellite Boilers

There are ten smaller boilers that provideheat to individual buildings or make hotwater. These boilers, located throughoutthe site, are operated in accordance withapplicable ACHD air pollution controlrequirements. All of these boilers operateon natural gas. Boiler blowdown water fromeach of the boilers is collected and treatedin the same manner as the Main BoilerHouse.

Test Facility Hot Water Heaters

There are five hot water heaters, each withan approximate 17 million BTU/hr input,used to provide a heat source for thermaland hydraulic testing. The heaters areoperated in accordance with the ACHD airpollution control requirements. The heatersare capable of operating on either naturalgas or No. 2 fuel oil which is stored in alarge revetted storage tank near the boilers.The storage tank has an SPCC Planprepared in accordance with federalregulations.

Demineralized Water Production Facilities

Demineralized water or pure water isproduced at several locations throughoutthe Bettis-Pittsburgh site. Pure water isgenerated by pumping city water through aseries of anion and cation resin beds toremove impurities. The resin beds areeither regenerated onsite using anacid-base regeneration system or are sentoffsite for regeneration. The onsiteregenerating solutions are collected andneutralized prior to discharge to the sanitarysewer.

Coolinci Towers

There are five forced-draft and five induced-draft cooling towers at the Bettis-Pittsburghsite that are used to dissipate the heatgenerated by computer, air conditioning,and other operations.

During operation, blowdown of the coolingwater occurs automatically to control theconcentration of solids that are naturaltypresent in the supply water. The smallquantity of blowdown water is directed intothe stormwater drainage or sanitary sewersystem.

Petroleum Storaqe Tanks

Bettis-Pittsburgh operates petroleumstorage tanks that service onsite facilitiesand equipment. The four largest storagetanks are: a 400,000-gallon above groundfuel oil tank to support test facility hot waterheaters, a 10,000-gallon above ground fueloil tank at the Main Boiler House, a 1,000-gallon above ground fuel tank for the L-Buiiding emergency generator, and a 4,000-gallon underground gasoline tank.Petroleum storage tanks are managed inaccordance with applicable federal andstate regulations governing such tanks.

14

Bettis-Piffsburgh Environmental Summary Repoti

Photoara~hic and Printinq Facilities

Photographic and printing services tofacilitate the preparation of designdocuments are provided onsite. Offsitevendors handle most photographicprocessing. Minor amounts of photographicprocessing are performed onsite to supportother operations and the wastes areshipped offsite to permitted treatment anddisposal facilities. Printing operationsgenerate waste materials that are eitherrecycled or disposed as municipal waste.

Radioactive Waste Management

Radioactive waste processing facilitiescollect and process water containing smallamounts of radioactivity and collect,process, package, and ship solid radioactivewaste. The processing facilities for liquidand solid wastes are monitored for radiationand contamination and are serviced byfiltered and monitored exhaust systems. In1998, construction was completed on abuilding that is being used as a centralizedfacility for the staging of containers ofradioactive waste materials generated atvarious onsite locations pending shipmentoffsite for disposal. See Section 5.1 for amore complete description of current wastemanagement programs.

Chemical/Hazardous Waste Management

The Chemical/Hazardous Waste StorageBuilding is operated under a PADEPHazardous Waste Storage Permit. Thefacility structure and operation are

15

maintained in compliance with applicablefederal and state regulations. This facility isused for temporary storage of chemicalwaste prior to shipment offsite to permittedtreatment and disposal facilities. The facilityis divided into five (5) revetted areas toseparate containers of incompatiblechemicals. The storage facility has thecapacity to store up to ninety 55-gallondrums and 225 gallons of waste in smallercontainers.

Mixed Waste Manaaement

The Mixed Waste Storage Facility (MWSF)is operated under the interim statusprovisions of RCRA and Commonwealth ofPennsylvania rules and regulations.Wastes that are both chemically hazardousand radioactive are stored in the MWSF inaccordance with the applicable federal andstate hazardous waste regulations and theConsent Agreement and Consent Orderagreed to by the EPA and PNR. TheMWSF is used to store mixed waste prior toshipment offsite to permitted treatment anddisposal facilities. The MWSF is also usedfor temporary storage of small quantities ofresidues from offsite treatment of NNPPmixed wastes. These residues are storedtemporarily at the MWSF until shipment to acommercial disposal site is arranged orDOE program-wide mixed waste disposalarrangements are established. The MWSFcontains revetments to prevent the releaseof wastes to the environment. Incompatiblechemicals are separated and stored inseparate containment.

Betfk-Pittsburgh Environmental Summary RepoH

5.0 WASTE GENERATION AND CONTROLS

The Bettis-Pittsburgh site is not amanufacturing facility. Previous productionefforts were limited to pilot projects such asbuilding the NAUTILUS and LWBR cores.As a consequence, the total quantities ofchemical and radioactive materials handledon the Bettis-Pittsburgh site have beensmall.

For example, during the period 1996-1998,the quantity of chemically hazardous wastesproduced by routine site operationsaveraged 7 tons per year. At Bettis-Pittsburghj this waste consists mainly ofwaste batteries, chemistry analysis wastes,and expired reagent chemicals. In thissame time period, an additional 25 tons ofhazardous wastes were generated as aresult of non-routine operations. Of the 25tons, 94% resulted from the excavation ofsolvent contaminated soil during facilityrenovations. The remaining 69!0 consists ofvarious remediation materials includinghazardous wastes generated duringpolychlorinated biphenyls (PCBS) andasbestos remediation operations, andhazardous wastes generated throughenvironmental sampling.

When sufficient quantities are accumulated,mercury, excess lead metal, and lead-acidbatteries are shipped offsite for reclamation.

Several of the current site buildings wereformerly used as airport hangars andprobably served as airport maintenanceareas. It is likely that degreasers andsolvents common to aircraft maintenancewere used in these early operations. Thereare no available records that show whetheror how much of such materials were used orwhere or how they were discarded.However, it is possible that spent solventsand degreasers may have been discardedon the site by airfield personnel and mayhave contributed chemical residues which

are currently detectable in site soil andground water.

The amount of radioactive materialsmanaged at the site is also small andconsists of irradiated test specimenresidues, special nuclear materials, and anumber of components with small amountsof radioactivity on their surFaces.Consequently, the amount of radioactivewaste material generated by currentoperations is small.

A discussion of current and past wastemanagement operations follows.

5.1

5.1.1

Current Waste ManagementPrograms

Current Radioactive WasteManagement

Liquid and solid radioactive wastes aregenerated and controlled in site operations.The Laboratory has maintained a vigorousradioactive waste control and minimizationprogram for many years. The generationprocesses and the minimization programare described below.

Radioactive Liquid Waste

Regulations applicable to commercialnuclear industries in the U.S. permitdischarge of low-level radioactive liquids ifthey meet concentration standardsestablished by the Nuclear RegulatoryCommission (NRC). DOE regulations alsopermit similar discharges of low-levelradioactive liquids. Bettis-Pittsburgh hasoperated to a far more conservativestandard for nearly two decades. Watercontaining low levels of radioactivity iscollected and processed to remove theradioactivity. When the water has noremaining detectable radioactivity, it isnormally discharged to the West Mifflin

16

Bettis-Pittsburcih Environmental Summary ReDort

Borough, Thompson Run SewageTreatment PIant. The processing systemincludes collection tanks, particulate filters,and mixed-bed ion exchange columns toremove inorganic. On occasion, smallamounts of radioactive liquids containinghigher levels of radioactivity are solidified.The filters, ion exchange media, andsolidified liquids are disposed offsite inapproved DOE radioactive solid wastedisposal sites.

Radioactive Solid Waste

Solid radioactive wastes are generated atthe Bettis-Pittsburgh site as a result ofresearch and development and decon-taminatiotidecommissioning operations. in-cluded in this waste are such radioactiveitems as process system filters, expendedresin, metal scrap, glass, cloth, wood,concrete, insulation, plastics, paper,ceramic or brick materials, roofing debris,sludges, asbestos, sampling planchettes,filter papers, swipes, and towels resultingfrom radiochemistry and radiationmonitoring operations, ventilation filters, andsolidified liquid wastes. The majority of thiswaste is from the decontamination offacilities no longer needed at the site.

When practicable, solid radioactive waste iscompressed to reduce the volume that mustbe shipped offsite for disposal. Solidradioactive wastes are packaged andshipped in accordance with therequirements of the U.S. Department ofTransportation. These wastes are disposedonly in land disposal sites owned by theDOE. All such sites are outside ofPennsylvania. The annual solid radioactivewaste volume generated and dispositionedduring 1996, 1997, and 1998 totaled 350,726, and 566 cubic meters, respectively,from routine and decontaminatiorddecommissioning operations.

Radioactive Recyclable Metal

During 1997 and 1998, approximately104,000 Ibs of radioactive scrap metal wereshipped to a commercial radioactivematerial processing facility for radioactivemetal recycling. The total includes heavymetal bearing equipment that consisted ofnon-radiologically contaminated leadencapsulated by externally contaminatedstainless/carbon steel.

Bettis has initiated a program for therecycling of radiologically contaminatedscrap lead. The first shipment of 7500pounds of radiologically contaminated leadfor recycling was made in 1998.

Radioactive Airborne Effluents

Exhaust systems that service radiologicalfacilities are designed and operated toprevent the discharge of potentiallycontaminated air to the environment. Mostsystems include high efficiency filters for theremoval of particulate radioactivity from theexhaust air. A few systems, in minorradiological facilities, utilize water scrubbersto remove acid fumes and particulateradioactivity from the exhaust air.

The exhaust systems are tested periodicallyto ensure that design flow rates aremaintained and that the filtration mediaprovide the proper collection efficiency. Allhigh efficiency particulate air filters thatdischarge to the environment are testedin-place after installation and periodicallythereafter. The testing is performed using0.7-micron diameter dioctylphthalate (DOP)smoke particles. The installation mustexhibit an overall collection efficiency of99.95 percent or higher to be accepted.

In addition, all radiological, forced-airexhaust systems are continuouslymonitored for particulate radioactivity.Systems servicing major radiologicalfacilities are provided with continuousmonitoring equipment that will alarm if theexhaust air contains levels of radioactivity


that are greater than normal but still muchless than the allowable Federalenvironmental standards at the siteboundary. Periodically, samples are alsoevaluated for Radon-220 gaseousradioactivity. Monitoring results arereported annually to federal and stateagencies.

Radioactive Waste Minimization

Bettis-Pittsburgh has maintained aradioactive waste minimization program formany years. The program includes work toidentify and eliminate sources of radioactivewaste generation and identify means tocompact or concentrate wastes to theminimum practicable volumes. The quantityof radioactive waste produced is much lessthan one percent of the low level radioactivewaste generated by all DOE sites.

5.1.2 Current Non-Radioactive WasteManagement

Bettis-Pittsburgh operations produce avariety of industrial waste products includingonce through cooling water, process rinsewater, waste oils, chemical wastes, boilerexhaust gases, and other such productstypical of a large laboratory. All such wasteproducts are controlled in accordance withvarious federal, state, and local laws andregulations. Bettis-Pittsburgh has ahazardous waste minimization program asrequired by the regulations.

The following is a discussion of the non-radioactive waste management practicesand the hazardous waste minimizationprograms.

Non-Radioactive Liquid Wastes

The small quantity of industrial waste liquidsfrom site operations is controlled by severalmethods depending on the volume andnature of the waste. Methods used toensure the safe disposal include: (1) localcollection and storage; (2) transfer ofwastes that contain hazardous materials or

recyclable oils and liquids to licensedsubcontractors for reclamation, incineration,or treatment at a licensed facility; (3) carefulmonitoring and control of chemicalconstituents to ensure that concentrations ineffluent water comply with applicablestandards and guidelines; and (4) extensiveemployee training in waste managementrequirements. Chemical wastes defined ashazardous are managed in accordance witha PADEP Hazardous Waste Storage Permitissued to the Laboratory in February 1995.

Liquid effluents discharged into the sitestorm sewer system are controlled andmonitored in accordance with an NPDESpermit issued by the PADEP. A total ofseven outfalls are permitted. Two of theoutfalls are permitted to discharge processwaste water, rinse water, and storm water.Four outfalls are permitted to dischargestorm water only. One outfall is permitted todischarge treated ground water.

Some water from offsite enters the sitestorm sewer system through a manholelocated west of Hangar #1. This offsite flowconsists mainly of precipitation run-off froman offsite road and has been shown, onoccasion, to have an elevated pH and/or tocontain high levels of suspended solids.The constituents of this water can influencethe water quality of the Bull Run Outfall(#001 ) effluent and has resulted in onedocumented case of an NPDES non-compliant situation. Bettis-Pittsburgh hasinformed the PADEP of this condition.

Sanitarv Waste Discharges

Sanitary waste from the site is discharged tothe West Mifflin Borough, Thompson RunSewage Treatment Plant. This plant usesthe activated sludge process to treat thesewage. The plant is operated under apermit issued by the PADEP to the Boroughof West Mifflin.

During 1998, approximately 32,000 gallonsof water generated from ground orsubsurface water collection and sampling

18


efforts were discharged to the sanitarysewer for treatment at the Thompson RunSewage Treatment Plant. The watercontained traces of volatile organiccompounds including tetrachloroethyleneand trichloroethylenethat were within limitsacceptable to the treatment plant. TheBorough of West Mifflin, the EPA and thePADEP have been notified of suchdischarges, as required by applicableregulations.

Polychlorinated B@henvls

All known transformers, capacitors andother such electrical equipment containingPCBS have been removed from service atthe Bettis-Pittsburgh site. PCB items at thesite are controlled in accordance with EPAregulations issued pursuant to the ToxicSubstances Control Act.

Non-Radioactive Solid Waste

Non-radioactive demolition debris and othersimilar materials as well as cafeteria wasteare dkposed in a licensed sanitary landfill.None of this waste is disposed at the Bettis-Pittsburgh site.

In accordance with state and localrequirements, Bettis-Pittsburgh has aprogram to recycle many non-radioactivesolid waste materials. One trash compactorhas been dedicated to compacting boxesand other corrugated paper that is taken toa local recycler. Bettis-Pittsburgh collectsglass and aluminum food and beveragecontainers for recycling. The Laboratoryhas a longstanding program to collect scrapmetal and sell it to a local scrap metaldealer. Bettis-Pittsburgh also has aprogram to collect and recycle high qualityoffice paper. During 1998, approximately58% of the municipal waste generated atBettis-Pittsburgh was recycled. Thisexceeds the PADEP goal of recycling 25%of municipal wastes.

Chemically hazardous solids are controlledin accordance with the requirements of

19

RCRA. No chemically hazardous wastesare sent to the municipal sanitary landfill(Section 4.2).

Non-Radioactive Airborne Effluents

The combustion gases from the 14 Bettis-Pittsburgh heating plant steam generatorboilers and 5 thermal and hydraulic testinghot water heaters are discharged throughelevated stacks. Bettis-Pittsburgh appliedto the ACHD, in 1995, for an Air PollutionOperating Permit for the entire site. TheACHD has not issued the permit, however,Bettis-Pittsburgh is operating in accordancewith all current regulations and conditionsidentified in the permit application.

Operation of the boilers is conducted inaccordance with ACHD regulations. Whilenatural gas is the primary fuel, No. 2 fuel oil,containing cO.5Y0 sulfur, may be used in twoboilers in the Main Boiler House and in thefive hot water heaters used for thermal andhydraulic testing.

Other sources of non-radioactive airborneeffluents include fume hood exhausts fromvarious Laboratory operations. Theseoperations have been identified, asappropriate, in the site Air PollutionOperating Permit application.

Non-Radioactive Waste Minimization

In accordance with RCRA, Bettis-Pittsburghhas a chemical waste minimization plan.The plan requires specific actions to identifyand minimize waste producing operations.These actions are accomplished byestablishment of strict procurementprocedures, substitution of non-hazardousmaterials where practical, and other similarmeasures.

Typical actions taken in recent yearsinclude:

. Careful control of type and quantity ofchemical acquisitions;


●

●

●

●

●

●

Over

Maximizing use of unused or partiallyused reagents through the Bettis-Pittsburgh Chemical ExchangeProgram;

Training of employees in the hazardsand proper control of the materialsused in their jobs;

Segregation of non-hazardous andhazardous wastes at the point ofgeneration;

27 tons of lead acid batteries wereshipped offsite for recycling from 1986through 1998;

194 tons of non-radioactive leadscrap were shipped otisite to the leadreclaimer from 1986 through 1998;and

1066 pounds of mercury waste havebeen shipped offsite for recyclingsince 1983.

the past several years, metalsrecovery, recycling, incineration,stabilization, secure Iandfilling, and wastewater treatment have been the primarymethods of offsite treatment and disposalfor Bettis-Pittsburgh-generated hazardouswastes.

In addition to recycling chemical wastes,Bettis-Pittsburgh recycles other materialsthat result in benefit to the environment.Examples of other materials sent offsite forrecycling include:

2634 tons of carbon and stainlesssteel from 1991 through 1998;

442 tons of corrugated paper from1991 through 1998;

31 tons of copper from 1991 through1998;

24 tons of aluminum from 1991through 1998; and

20

. 1391 tons of high grade office paperfrom 1994 through 1998.

5.1.3 Current Mixed Waste Management

Bettis-Pittsburgh site operations haveresulted in the generation of small volumesand various types of mixed waste. Thesewaste streams include oils, soil and debris,chemical analysis solutions, and processwastes.

The NNPP has agreed to applyPennsylvania hazardous wasterequirements to the hazardous constituentsof mixed waste prior to Pennsylvania beingdelegated mixed waste regulatory authorityby the EPA. Bettis-Pittsburgh manages allmixed waste in accordance with the Bettis-Pittsburgh Mixed Waste Management Planwhich was concurred with by the PADEP inSeptember 1995 and last revised inDecember 1998. In addition, in accordancewith the Federal Facility Compliance Act(FFCA), the EPA and DOE signed aConsent Agreement and Consent Order, inOctober 1995, that binds the DOE to treatBettis-Pittsburgh mixed waste inaccordance with the Site Treatment Planwhich was approved by the EPA.

In 1996, 90contaminatedEnvirocare ofdisposal.

Also, in 1996,

cubic feet of radiologicallylead waste was shipped toUtah, inc. for treatment and

Bettis-Pittsburgh initiated theonsite treatment of small amounts of mixedwastes as allowed by the Mixed WasteManagement Plan. Characteristicallyhazardous mixed wastes, such asradiologically contaminated zirconium andhafnium chips, or corrosive and toxicchemical wastes generated from theanalysis of radiologically contaminatedsamples, are treated to remove theirhazardous characteristics in accordancewith a waste analysis plan that is on file atBettis-Pittsburgh. After treatment, the non-hazardous treatment residue is disposed asradioactive solid waste. Since 1996, the


Laboratory has treated less than one cubicmeter of characteristically hazardous mixedwaste and disposed of it as radioactive solidwaste.

During 1997, 141 cubic feet of incinerablemixed waste was shipped by Bettis-Pittsburgh to the Idaho National Engineeringand Environmental Laboratory WasteExperimental Reduction Facility (WERF) fortreatment. The Bettis-Pittsburgh mixedwaste was combined with similar wastesfrom other NNPP sites and incinerated inthe WERF mixed waste incinerator. Withapproval of the PADEP, residuals from thistreatment campaign are temporarily storedat Bettis-Pittsburgh pending arrangementsfor offsite disposal. As additional mixedwaste treatment facilities come online,Bettis-Pittsburgh will continue to ship mixedwaste offsite for treatment and disposal inaccordance with the Site Treatment Planand implementing the Consent Agreementand Consent Order.

Minimization of Mixed Waste

Because of the difficulties and limitedavailability to treat and dispose of mixedwaste, Bettis-Pittsburgh uses every meanspractical to eliminate and minimize thegeneration of mixed waste. These methodsinclude:

. Radioactive materials are sorted,processed or otherwise handled tosegregate the radioactivity frommaterials or liquids which are subjectto hazardous waste requirements;

. To the extent practicable, radioactivematerials are not mixed or adulteratedwith products which could cause theresulting waste to be subject tohazardous waste requirements;

. Any new process that could result inthe generation of mixed waste isreviewed prior to performing theprocess; and

. Radiologically controlled metalscontaining hazardous constituents arerecycled or reused whenever feasible.

5.2 Past Waste Management Practices

Radioactive waste management practiceshave evolved over the years consistent withadvances in technology and changes inregulatory requirements. Typically, Bettis-Pittsburgh has maintained an environmentalprogram substantially more strict than therules in effect at the time.

Non-radioactive waste managementpractices evolved in a similar manner. Landdisposal of chemicals onsite was conducteduntil 1964. Current Bettis-Pittsburghpractices incorporate all of the strict controlsrequired by federal and state regulations.Each of these areas is discussed below.

5.2.1 Past Radioactive WasteManagement

Bettis-Pittsburgh has always been involvedin handling radioactive materials and hastherefore always had managementprograms for radioactive materials andwastes. Disposal practices appropriate toeach waste form (i.e., solids, liquids, gases)were developed and implemented.Requirements for the treatment anddisposal of these wastes were established.For example, retention tanks andevaporators for liquid waste, facilities forstorage of solid waste, and air cleaningsystems (such as high efficiency particulatefilters) were incorporated into the facilities.

The following is a description of thepractices employed in the management ofthese materials.

Radioactive Liuuid Waste

Operations which began at the Bettis-Pittsburgh site in 1949 have resulted in thegeneration of radioactive liquid wastes.These radioactive liquid wastes were aconsequence of fuel research and

21


development and the inspection andanalysis of irradiated materials specimens.These operations were all performed incontrolled areas within Bettis-Pittsburgh.

Prior to 1981, water, which potentiallycontained low-level radioactivity from thewashing of laboratory glassware,decontamination hand sinks, and variouslaboratory areas which processedradioactive materials, was collected inretention tanks and analyzed forradioactivity. If the radioactivity level of thewater was below the established limits, thewater was released to the storm sewer. Ifthe water failed to meet the release limits, itwas processed to remove the radioactivity.The purified water was then reused inoperations or released to the storm sewerafter confirmation that activity levels werebelow the limits.

Higher radioactivity-level liquid wastes werenormally evaporated to dryness. Theradioactive sludges resulting from theseprocesses were disposed offsite as solidwastes. Occasionally, some liquids weresolidified and disposed offsite as radioactivesolid waste.

During the 50 years of Bettis-Pittsburghoperation, less than 7 curies of Bettis-Pittsburgh-generated radioactivity havebeen released in water effluents. Allreleases were well within the applicablerelease limits. Only one percent of thisactivity has been released in water effluentssince 1969. The water effluents are thesource of the residual low-level radioactivitythat remains in a few locations along theBull Run Stream (Section 5.2.2).

Radioactive Solid Waste

The offsite disposal of solid waste materialswas made in accordance with therequirements established by the AEC andthe Energy Research and DevelopmentAgency, the forerunners of the DOE. Thesolid waste included rags, plastic bags,

contaminated materials, evaporator slurry,and filters.

In the years prior to 1961, combustible solidradioactive waste was incinerated in aspecially designed incinerator. The ash andnoncombustible wastes were solidified inconcrete and then shipped for disposal toAEC-approved areas.

In later years, the waste was packaged inthe Radioactive Waste Processing Facilityaccording to the regulations in effect at thetime. No radioactive solid waste was buriedon the Bettis-Pittsburgh site. Solid wasteswere shipped to an AEC-licensed disposalsite for disposition.

Radioactive Airborne Effluents

After passing through cleaning systems,where necessary, to ensure compliancewith existing radiation protection guides,ventilation air from radiological facilities wasdischarged to the atmosphere. The aircleaning systems included high efficiencyparticulate filters and wet scrubbers asappropriate for the process being served.

Monitoring of exhaust air has beenaccomplished through the collection andanalysis of samples of the effluent. Thesampling technique used was dependent onthe physical and chemical nature of theradioactivity and included filter papersampling.

Overall, an estimated 1000 curies ofradioactivity with half-lives greater than oneday have been contained in air emissionsduring the 50 years Bettis-Pittsburgh hasoperated. Most of this radioactivity was inair emissions in the earlier years ofoperations. The majority of the radioactivityconsisted of the inert gas krypton-85 andshorter lived iodine-1 31. Krypton-85 is aninert gas that does not deposit on surfacesand is readily dispersed in the atmosphere.iodine-l 31 has a half-life of 8 days anddecays rapidly upon release. Smalleramounts of other beta-gamma emitting

22

Bettis-Pittsburgh Environmental Summaw Report

fission products and trace quantities ofalpha emitting particulate comprised theremaining amount of the long-livedradioactivity in air emissions. Since 1993,radioactivity in air emissions with greaterthan a one day half-life has averaged lessthan 7 microcuries per year.

Since LWBR core development began,Bettis-Pittsburgh air emissions have alsoincluded the radioisotope radon-220.Radon-220 is an inert gas that is readilydispersed in the atmosphere and decaysvery rapidly (half-life of 55 seconds). Theconcentration of the short-lived radon-220 atthe location of the nearest offsite receptorshas always been far below the Federallimits for air in uncontrolled areas. Forperspective, radiation doses to offsiteindividuals from radon-220 emissions havebeen too low to measure. Conservativecalculations using EPA standard methodsestimate doses to be less than 0.001 Remper year to the maximally exposedindividual.

Bettis-Pittsburgh has employed calculationaltechniques that conservatively estimatepotential exposures. These methodsconsider inhalation, ingestion, and directradiation exposure pathways. Bettis-Pittsburgh conservatively estimates that themaximum possible annual radiationexposure to any member of the publicresulting from current operations is lessthan 0.003 Rem per year. This is lessradiation than received from cosmicradiation during a round trip airline flightfrom Pittsburgh to the west coast of theUnited States (0.003-0.004 Rem). Thecalculations also show that in all previousyears, the annual radiation exposures topeople living adjacent to Bettis-Pittsburghwere well below the annual regulatory limits.

5.2.2 Residual Radioactivity in Soil,Ground Water, Surface Water andSediment

Not withstanding’ the waste managementoperations described above, some site soil

23

contains residual radioactivity. In thediscussions which follow, levels ofradioactivity in soils are discussed in termsof picocuries per gram (pCi/g) of soil. Forcomparison, a typical home smoke detectorcontains about 1,000,000 pci ofradioactivity. The areas described beloware shown in Figure 3. Additionaldiscussion of the areas containing residualradioactivity can be found in the“Preliminary Assessment and SiteInspection Report for the Bettis AtomicPower Laboratory,” - Revision 1, datedJanuary 1990, Reference (1).

Inactive Waste Isolation Pit

Soil beneath the MEL in the vicinity of theInactive Waste Isolation Pit (IWIP) containssome low levels of radioactivity. The IWIP(identified in Figure 3) consists of two smallunderground concrete vaults containingtanks and equipment that were used forcollecting and processing radioactive liquidsgenerated in the MEL. The radioactivityoriginated due to the overflow of radioactiveliquid from collection tanks into the vaultsand leakage to the surrounding soil. Thesystem operated from 1956 until 1964.

In 1977, core bore soil samples werecollected from inside and outside of theMEL in the area of the IWIP down tobedrock. About half of the samplescontained levels of radioactivity detectableabove background with the majorradionuciide being strontium-90. Themajority of the radioactivity was found inone core bore hole immediately adjacent tothe IWIP, under the floor of the MEL.

In 1983, the soil around the IWIP with thehighest levels of radioactivity was removed.The soil volume removed wasapproximately 420 cubic feet and extendedto bedrock at a depth of about 9 feet.

Between 1983 through 1994, approximately1410 cubic feet of additional soil and backfillmaterial were removed from the areas eastand south of the IWIP. It was initially


//

/I

/I

\t

\\

L.

24

Betfis-Pittsburgh Environmental Summary Report

estimated that about 59 curies remain in thesoil surrounding the IWIP. However, corebore samples taken in the soil surroundingthe IWIP suggest that the amount ofradioactivity that remains in the soil aroundthe IWIP may be much lower thanpreviously estimated.

Surface water that accumulates in aninactive section of the storm drain systemadjacent to the MEL and IWIP is transferredand processed to remove radioactivity asdiscussed in Section 5.1.1.

N-Buildinq Monitor Tank Room

Bedrock beneath the floor of the N-BuildingMonitor Tank Room (N-MTR), identified inFigure 3, contains low levels of radioactivity.The N-MTR was installed in 1950 toprocess radioactive liquid waste andoperated until 1975. The radioactivityoriginated from spills of water containing lowlevels of radioactivity during waterprocessing operations and subsequentseepage of the water through cracks in theN-MTR floor.

After operations of the N-MTR had ceased,decontamination efforts were undertaken.These efforts included removal of the floorand the fill material which supported thefloor. In 1980, Bettis-Pittsburgh completedremoval of the soil down to shale bedrock.This resulted in the removal of about 99% ofthe radioactivity. This material wasdisposed at a federal radioactive wastedisposal site. Less than 0.04 curie ofradioactivity remains at the location.

Associated with the N-MTR were twooutside storage tanks which were used tostore radioactive water for processing. Dueto leakage of these tanks, soil beneaththese tanks contained residual amounts ofradioactivity. After the tanks were removed,core bore samples were collected from thevicinity of the tanks. The average cobalt-60,cesium-1 37, and strontium-90 results of the

25

core bores were 0.6, 14.5, and 8.2 pCi/g,respectively.

Waste Processing Buildina Storaqe Pad

The storage pad behind the inactive WasteProcessing Building has residual low-levelradioactivity as a result of leaks incontainers of radioactivity which were storedon the pad. The storage pad was a14,900-square-foot pad located north andwest of the Waste Processing Buildingwhere radioactive waste was processedprior to shipment of the waste to anapproved, offsite disposal site. Thetriangular shaped pad is identified inFigure 3.

In the spring of 1972, 3,000 square feet ofthe concrete pad were removed along withsoil beneath the pad to a depth ofapproximately 18 inches. The removedmaterial was disposed of at an approvedoffsite disposal facility and the excavationwas backfilled with clean soil and repavedwith asphalt. In 1978, the remainder of thepad and underlying soil was removed anddisposed of in the same manner. Thesetwo actions removed most of theradioactivity from the location. Samplestaken throughout the pad area exhibitedvery low levels of radioactivity. Less than0.02 curie of radioactivity remains at thislocation.

Inactive Waste Site

A portion of the hillside north of the inactiveWaste Processing Building has residuallow-level radioactivity due to operationsconducted prior to 1969. This area is in thesouthwestern portion of the area referred toas the Inactive Waste Site (IWS), identifiedin Figure 3. The radioactivity originatedfrom leaks in containers of radioactivewaste which had been stored outside on theWaste Processing Building Storage Pad.Precipitation carried some activity to anearby storm sewer which discharged ontothe hillside.


Over 95% of the radioactivity on the IWSthat originated from the Waste ProcessingBuilding Storage Pad was removed byexcavation of soil and removal of the stormsewer. The contaminated soil was shippedto a licensed radioactive waste burial siteand the area restored.

Currently, the hillside still contains someresidual, low-level contamination, with lessthan 1.9 curies of activity remaining in thearea contaminated by runoff from the WasteProcessing Building Storage Pad.Radiation levels in the area are, for the mostpart, equal to background. Whilebackground is typically 10 @hr (0.00001Rem/hr), small areas exhibit radiation levelsof 15 to 18 @/hr with a few localized areasof up to approximately 40 @/hr.

Bull Run Stream Basin

As shown in Figure 3, the Bull Run Streamoriginates on the Bettis-Pittsburgh site as awet-weather drainage ditch. When there isno precipitation runoff, the primary source offlow in the stream is from the Bettis-Pittsburgh storm sewer outfalls and consistsof city water that was used for coolingpurposes. The stream runs approximatelyone-third of a mile on the Bettis-Pittsburghsite, roughly parallel to the eastern siteboundary. The stream passes through twosmall private properties indented along theboundary. After the Bull Run Stream leavesBettis-Pittsburgh property, it passes throughthe West Mifflin Park and continues on tojoin Thompson Run Stream which flows intothe Monongahela River. Neither Bull RunStream nor Thompson Run Stream areknown to be used as a source of water forhuman consumption.

In the first decades of site operation, watereffluents from Bettis-Pittsburgh to the BullRun Stream contained small amounts ofradioactivity at concentrations belowapplicable federal limits. Over 99 percent ofthe radioactivity contained in the effluentwater was released prior to 1969.

Although not required by federal or stateregulation, Bettis-Pittsburgh beganmonitoring the Bull Run Stream basin in theearly 1960s. The results of this monitoringwere initially reported to and published bythe U.S. Public Health Service in theirjournal “Radiological Health Data andReports.” Subsequently, the results havebeen provided in annual environmentalmonitoring reports to the EPA and PADEP.These documents indicate that, in additionto the presence of naturally occurringradioactivity in Bull Run Stream, very lowlevels of residual radioactivity from theearlier Bettis-Pittsburgh releases aredetectable. A detailed presentation ofresidual radioactivity in the Bull Run Streambasin was provided to the PADEP; asummary of this information was provided inthe Preliminary Assessment Report(Reference (1)) of the Bettis-Pittsburgh site,developed pursuant to CERCLA.

During the winter of 1976-77, most of theresidual radioactivity along the Bettis-Pittsburgh portion of the stream basin wasremoved and disposed of at a licensedburial facility offsite (392 cubic meters of soiland approximately 90% of the radioactivitywas removed). Soil samples taken after theremoval effort indicated that only a smallfraction of the residual radioactivityremained, with low, but still detectablelevels observed. Most of this residualmaterial is located along the lowertwo-thirds of the onsite Bull Run Streambasin in small, localized areas.

Radiation levels measured in surveys priorto the 1976-77 soil removal varied fromnatural background levels of approximately10 @/hr, to approximately 100 pR/hr atapproximately waist level in isolated onsitelocations, and from approximately 10 to 22@/hr in offsite areas; the offsite survey areaincluded an area about 1400 feetdownstream of the site boundary. Detailedsurveys of the onsite Bull Run basinperformed since 1976-77 show that thewaist-level radiation readings are less than

26

Bettis-Pittsburgh Environmental Summary Reporf

20 @7/hr. The average radiation level in thisarea is about 13 @3/hr at waist level, whichis only slightly above background.

As part of its detailed survey efforts, Bettis-Pittsburgh has also taken samples of thesoil along the stream basin and measuredthe concentration of residual radioactivitywith sensitive laboratory instruments. Inaddition to the naturally occurringradioactivity found in the soil, low levels ofcesium-137 are detectable. The typicalcesium-137 concentration along the streambasin is much less than 20 pCi/g, although afew, small spots contain cesium-137 toabout 200 pCi/g. The maximum cesium-137concentration measured to date was foundin 1982 in a small, isolated spot at a level of460 pCi/g; a subsequent sample in theimmediate area contained 9.6 pCi/g ofcesium-1 37.

During April 1993, Bettis personnel and arepresentative of the PADEP petiormed anenvironmental radiation survey of a portionof the Bull Run Stream basin in the WestMifflin Community Park. This portion of thebasin was selected because it representsthe only segment of Bull Run Stream in theWest Mifflin Park area that contains lowlevels of Bettis-generated radioactivityabove natural background levels in the soil.Radiation measurements were taken andrecorded on a 10 foot by 10 foot grid systemat approximately three feet above theground surface. The area within each 100square foot grid section was scanned.

The measured radiation levels varied frombackground, about 10 @/hr, to a maximumof 27 pl?lhr. These slightly enhanced, yetstill very low, radiation levels are due to thepresence of low levels of radioactivity,primarily cesium-1 37, from early siteoperations. These levels and locations areconsistent with previously measured andreported values and indicate that there hasbeen no migration or buildup of radioactivityinto or from the area since circa 1976.

Soil samples were also collected from thesurface down to rock at ten locations todetermine the radioactivity profile in the soil.The sample results confirm that the primaryradionuclide present is cesium-137.Cesium-137 radioactivity ranged frombackground to 120 pCi/g. As a measure ofthe significance of soil containing 120 pCi/gof cesium-1 37, an individual would have toconsume 27 pounds of soil to receive adose of 100 millirem which is the NRC doselimit for an individual member of the publicper year. The data shows low levels ofnatural uranium in the soil. The dataindicate the majority of the low levelradioactivity is found in the top one foot orless of the soil. This profile is consistentwith deposition from flooding of the areaand the affinity of cesium-137 for soilparticles.

The very low levels of residual radioactivityin the Bull Run Stream basin do not presenta hazard to the public. Sensitiveinstruments must be used to detect thevariations in radiation levels in the streambasin. The radiation levels detected are, onthe average, a few microrem per hourabove background. Since individuals havenot been routinely observed in the onsiteBull Run Stream area, the likely radiationdose from the Bettis-Pittsburgh generatedradioactivity in the onsite Bull Run Stream isO (zero) millirem (mrem). However, basedon a conservative estimate that anindividual would spend as much as onehour per day for the entire year along theonsite stream bank in the area with radiationlevels above background, the annualhypothetical dose received would be lessthan 2.2 mrem. This potential radiation doseto an individual in the onsite Bull RunStream area is well below the mostrestrictive dose limits of the NRC or of theDOE, and is less than 1YO of the radiationexposure a person receives from naturallyoccurring radiation in the environment (300mrem per year).

27

Bettis-FWsburgh Environmental Summary Report

Inactive Systems

Bettis-Pittsburgh has inactive systems suchas tanks, sumps, and underground linesassociated with the processing of low levelradioactive liquids. Radioactive con-tamination still exists in the remainingsystems. In addition, some of the systemscontain small quantities of residues andsome systems contain ground water. Theseinactive systems are included in plans foreventual removal.

These underground radioactive liquid wastedrain systems were installed in the 1950s.After more than 10 years of operation, theunderground systems were deactivated.Since then, most of the accessible pipingand adjacent soil containing low levels ofradioactivity, due to leakage from the piping,have been removed and disposed as solidradioactive waste. The inaccessiblesections of pipe were hydrostatically testedand capped to maintain system integrity.The remaining capped sections of pipe totalapproximately 7000 feet. The internalsurface of this piping is expected to containvery low levels of radioactivity.

There are a few additional locations atBettis-Pittsburgh where soil potentiallycontains low levels of radioactivity due topast minor breaches in containers or spills.Bettis-Pittsburgh has excavated soil frommany of these areas to remove theradioactivity, but some very small amountsof radioactivity still remain in the soil.

Ground Water Radiological MonitoringResults

The ground water radiological monitoringprogram results show that Bettis-Pittsburghoperations have not had a significant effecton the quality of the ground water at thesite.

This program has been maintained for morethan 10 years and includes ground watersamples from seeps, springs, andmonitoring wells. Samples are collected

28

regularly and analyzed for gross alpha,gross beta, and specific radionucjidesassociated with past or current Bettis-Pittsburgh operations, such as cobalt-60,cesium-1 34, cesium-1 37, and strontium-90.In addition, samples are also taken atremote sites for comparison of the levels ofradioactivity naturally occurring in theenvironment in southwestern Pennsylvaniawith the Bettis-Pittsburgh site results. Whilethe specific results from both onsite andoffsite sampling vary from sample to sampleand year to year, the results of themonitoring indicate that the gross alpha andbeta radioactivity levels in the ground waterat the Bettis-Pittsburgh site are consistentwith the naturally occurring radioactivitylevels found at remote locations.

Ground water monitoring well data in theIWS area indicate that, for the most part,gross alpha and beta radioactivity levels inthe ground water are equal to backgroundlevels found in ground water remote fromthe Bettis-Pittsburgh site. However, a fewground water samples collected frommonitoring wells near the middle of thehillside area have contained limitedamounts of non-naturally occurringradioactivity.

Low levels of radioactivity have beenidentified in the surface soil and surfacewater down grade and west of the IWShillside, off Bettis-Pittsburgh property. Thegross alpha and beta radioactivity levels inthe water and soil are consistent withnaturally occurring levels. Specificradionuclide analysis revealed the presenceof radioactivity in the soil and water. Theradiation dose that could be incurred fromthis residual radioactivity in the soil is lessthan the exposure a person would receivefrom natural cosmic radiation during anaverage cross-count~ airline flight. Thelevels in the water are below both thefederal limit for water in unrestricted areasand the limit for drinking water.

Ground water monitoring wells have beeninstalled around the MEL to monitor the


migration of residual radioactivity fromunder the MEL. Low levels of strontium-90have been detected in these wells. Thedata has not shown an increase in theradioactivity levels since the monitoringbegan. The levels of strontium-90 found inthe wells are much less than the limit forwater in unrestricted areas.

The radioactivity data for the PittsburghCoal water-bearing zone wells areconsistent with natural background levelswith two possible exceptions. There are twoPittsburgh Coal water-bearing zonemonitoring wells located on an adjacentproperty within a few feet of each other.The results from these two wells indicatedthe presence of low levels of strontium-90.The highest detected concentration wasone-tenth the federal drinking water limitwhich is the most restrictive strontium-90limit for water. In addition, the levels ofstrontium-90 detected are similar to levels ofstrontium-90 which have been detected inground water around the country andattributed to past atmospheric nuclearweapons testing. Strontium-90 is present inthe soil in the IWS from past site operationsand higher than background levels ofstrontium-90 have previously been detectedin surface drainage from the IWS. It is notclear what part of the strontium-90 detectedin the wells is due to the presence ofstrontium-90 from past atmospheric nuclearweapons testing (Reference (5)).

5.2.3 Past Non-Radioactive WasteManagement

Over the years, Bettis-Pittsburgh hasgenerated a variety of chemical wastes. In~he firstoperation,commondischargeplacement

few decades of laboratorydisposal methods included

industrial practices such asto sanitary and storm sewers,

in municipal landfills,evaporation, and onsite land disposal. In1983, Bettis-Pittsburgh initiated efforts toidentify and define areas onsite that mayhave been used to dispose of chemicals.

5.2.4

The

Chemical Residues in Soil, GroundWater, Surface Water, andSediment

past waste management methodsdescribed above resulted in some chemicalresidues in soil. A detailed discussion of theareas containing chemical residues can befound in the Final RFI Report, Reference(2), and the Final CMS Report, Reference(3).

inactive Waste Site

The IWS (identified in Figure 3) was usedfrom the late 1950s to approximately 1964to dispose of mainly pIant rubbish andexcavation materials. The area was alsoused to dispose of some waste chemicals,such as solvents, oils, and various metal-containing sludges. Asbestos-containingmaterials were also deposited in the area.The site was covered with dirt from onsiteexcavation and construction jobs, with thelast use occurring in 1972. The IWS isapproximately 3.5 acres in size and islocated on the hillside on the northwestportion of the site away from areasfrequented by the public. The maximumdepth of the fill materials is estimated to be28 feet.

In 1985, Bettis-Pittsburgh drilled a series ofborings in the IWS. The principal chemicalin soil samples collected from the boringswas tetrachloroethylene, (also known asperchloroethylene or PCE) a commonlyused dry cleaning agent which was used atBettis-Pittsburgh for decreasing metal parts.

There are no odors or visual evidence ofenvironmental damage or stress, such asdead vegetation, in the area of the IWS.The vegetative growth, which consists ofgrasses, crown vetch, and small trees andbushes, limits direct contact with thematerials and airborne releases. Asbestosair sampling and organic vapor samplingindicated levels consistent with ambient.Sampling for PCBS using a standardOccupational Safety and Health

29


Administration method indicated levels lessthan 1?4.of worker limits.

The results of the soil, water, and airsamples collected in 1992 and 1993 duringthe RF! confirmed the types and levels ofchemical residues previously detected atthe IWS.

In 1989, surface soil and water samplescollected down grade from the IWS onadjacent industrial properties owned byDuquesne Light Company and VNGIshowed the presence of very low levels ofPCBS and volatile organic compounds(VOCS) in the soil and VOCS and asbestosin the water. These samples were collectedin a wet-weather ditch located in anundeveloped, limited access portion ofVNGI property. Subsequently, additionalsoil and surface water samples have beencollected from this area during the RFI andas part of annual monitoring. The PCBlevels found in the soil, with one exception,have been less than 10 parts per million.The levels of VOCS in the surface water andsoil are the result of migration from the IWS.The fiber sizes of the traces of asbestosfound in the water were smaller than thoseconsidered to be a health risk fromingestion. The results have been discussedwith and provided to the Duquesne LightCompany and VNGI. The results of soil andwater sampling performed in 1992 and 1993during the RFI generally confirmed thetypes and levels of chemical residuespreviously detected on Duquesne LightCompany and VNGI properties. During the1992 and 1993 sampling, additionalconstituents were analyzed for and somelow levels of polynuclear aromatichydrocarbons (PAHs) were detected.These levels of detected PAHs areconsistent with background levels for thearea surrounding Bettis-Pittsburgh and, assuch, do not pose any risk unique to Bettisoperations. Bettis-Pittsburgh is continuing asampling program to monitor for migrationof residues from the IWS and DuquesneLight Company and VNGI are aware of thepresence of these residues.

Soil Surroundirw Underground Waste OilTanks

In about 1960, Bettis-Pittsburgh installed 10steel underground storage tanks for thecollection of waste oil. The tank volumesranged from 65 to 550 gallons. Theirfunction was to serve as collection points forused oil from which a vendor could pumpthe oil for offsite disposition. In 1979, use ofthe tanks was terminated and the tanksemptied except for minor amounts ofresidual material. In 1986, Bettis-Pittsburghreopened the tanks and sampled theresiduals remaining in the tanks and the soilaround the tanks. Several of the soilanalyses showed the presence of residuesof the same products found inside the tanks.

Each of the tanks has been removed,cleaned, and reclaimed as scrap metal.The boundary of the affected soil around thetanks was not established in 1986 but wasduring 1992 and 1993. Samples of soilcollected from the underground storage tankexcavation areas in 1992 and 1993 duringthe RFI revealed that, for the most part, onlytrace levels of residues remain in theseareas. The source of the oil and solvents isthought to be from spillage when oil was.added to the tanks rather than tank leakage.This is supporled by the fact that all but oneof the removed tanks appeared to be intact.The quantity of affected soil is estimated tobe on the order of less than 30 cubicmeters.

All tank areas are inside the plant securityfence, limiting contact by outside persons.The excavated holes have been lined withplastic and filled with clean sand. The sitesare not being used for any purpose by plantpersonnel.

Petroleum Storaae Tanks

In addition to the waste oil tanks, twounderground gasoline tanks, anunderground airport fuel tank, and anunderground diesel fuel tank have beenremoved. These removal actions were

30

Bettk-Pittsburgh Environmental Summary Report

conducted in accordance with applicablefederal and state regulations.

F-Shop Area

This area (identified in Figure 3) is locatedimmediately outside a building, the F-Shop,that at one time contained two tanks usedfor vapor decreasing of metals. A soilsample collected in the area from a two-footlayer of soil above bedrock contained1.15 ppm of PCE. The source of thesolvent is thought to be from the disposal ofsmall quantities of solvents used in theF-Shop decreasing units.

The total quantity of solvent deposited inthis approximate 1600-square-foot area isestimated to be a few gallons. This area islocated within the plant security fence.There are no physical signs of the solvents,such as odors, nor is there any visualevidence of environmental damage.

Samples collected in 1992 and 1993 duringthe RFI confirmed the previously detectedlevels of VOCS in this small area.

Bettis Landfill Area

There are currently no landfills in use at theBettis-Pittsburgh site. From approximately1960 until 1987, Bettis-Pittsburgh operateda Iantilll area to dispose of soil andconcrete removed from site excavation andconstruction activities. The landfill was notused for disposal of radioactive waste.

In the fall of 1987, auger borings weredrilled into the fill and soil samples werecollected for analysis. The soil analysisrevealed the presence of PCE,trichloroethylene (TCE), trans-1 ,2-dichloroethylene (DCE), and PCBS. Theareas of the highest chemicalconcentrations appeared to be centeredaround two of the borings located in anolder portion of the fill. The chemicals werefound at depths of 5 feet or greater. Theexact quantity of these chemicals in the

31

landfill is unknown but is likely to be a fewhundred gallons.

The total surface area of the Bettis Landfillis approximately 1.5 acres with a maximumfill depth of approximately 20 feet. The areaof the highest chemical concentration isapproximately a quarter of an acre in size.There are no odors at the landfill surface orin the area surrounding the fill nor are thereany visual indications of environmentalstress at the landfill. Air sampling forasbestos and organic vapor indicated levelsconsistent with ambient. PCB samplingindicated trace amounts are detectable, butat levels less than 17. of worker limits.

This area is isolated from the developedportion of the site and the general public.The results of soil and air samples collectedin 1992 and 1993 during the RFI confirmedthe types and levels of previously detectedchemical residues at the Bettis Landfill.

Coke Gas Lines

Bettis-Pittsburgh investigated two 40-inchdiameter abandoned gas lines dating fromthe early 1900s that transect the Bettis-Pittsburgh site. The gas lines were used totransport coke oven gas between steel millsin the valleys of western Pennsylvania. Thelines have been inactive for many years, butthe investigations have found that somesections of the lines contain residual sludgeand water. This sludge and water containscoal tar derivatives and other hazardousconstituents such as benzene. Actions toaddress the coke gas lines are provided inthe Final CMS Report (Reference (3)).

Storm Sewer Svstem

The developed portion of the site is servicedby a storm sewer system which dischargesprimarily to the Bull Run and Northeast AreaStreams. Historicallyj some chemicals weredisposed of by discharging to the stormsewer system. Sampling of manholes incertain sections of the storm sewer systemhas resulted in the detection of chemical

Beftis-Pittsburgh Environmental Summary Report

residues, including VOCS and PCBS in thesediment. These chemical residues haveleaked into the soil/fill surrounding the stormsewer system in some locations. The VOCSin these areas have leached into the upperwater-bearing zones. In 1992 and 1993during the RFI, extensive sampling of thestorm sewer system was performed. Thissampling confirmed the presence of low-Ievel residues in certain portions of thestorm sewer system. These residues posean insignificant risk to human health.However, in 1997, a program wascompleted to remove the sediment that hadaccumulated in select manholes around thesite.

Other Onsite Areas

Other areas onsite were investigated in1992 and 1993 during the RFI for thepresence of chemical residues. Theinvestigations included the collection of soiland soil gas samples. Only trace quantitiesof chemical residues were identified in a fewareas and they pose an insignificant risk tohuman health and the environment.

In 1996, following completion of the RFI,small bead-like polyethylene particles,which contain approximately 7?4. lead byweight, were discovered in an outdoor areaon Bettis property. An investigation of thearea was conducted and a report of theresults submitted to the EPA. The reportconcluded that lead contamination wasrestricted to the top few inches of soil in thearea where the beads were observed on thesurface. An evaluation of the impact of thelead-contaminated soil on ground waterconcluded that, although the leadcontamination was not a threat to groundwater, removal of the beads and entrainedsoil for proper disposal offsite is a viableand prudent corrective measure. Thebeads and entrained soil have beenremoved for disposal.

32

Old Bettis-Pittsburuh Airfield Operations

It is possible that small quantities of sfsolvents and degreasers common to aircmaintenance may have been discardefsome areas during the time period wBettis-Pittsburgh was a privately owairfield. Bettis-Pittsburgh investigation:date have failed to identify any spedisposal areas from airfield operations.

Surface Water and Sediment

The results of analyses for VOCS in SUIIwater samples collected during 19921993 from onsite and offsite stretconfirm the data previously obtaithrough historical sampling and anal)The only surface water samplescontained site-related VOCS were colle(from Bull Run Stream downstream ofconfluence with the discharges from Buand other springs within the propboundary. VOCS associated withoperations were not detected in wsamples collected from the Bull RunNortheast Stream outfalls, the NorthStream, or the inactive High TemperaTest Facility (HITF) drainage challocated in the northwest portion ofBettis-Pittsburgh site. VOCS weredetected in surface water samples colleloffsite from Thompson Run StreSampling and analysis of surface wdemonstrated that no other chemicals vpresent at measurable levels.

The discharge of low levels of V{occurred primarily between Buono SFand the confluence of the Bull Run Strland Northeast Stream. The presenc(VOCS in Bull Run Stream waterattributed to the continuous discharg[water to the stream from various sprand seeps discharging from a \impacted water-bearing zone. The sprand seeps represented a continuous soIof VOC discharge to Bull Run StrcSurface water sampling and analysi:onsite locations downstream of the BullStream/Northeast Stream confluence

Betfis-Pittsburgh Environmental Summary Report

offsite locations were normally near orbelow the analytical method detection limitof 0.005 parts per million. These resultsindicated that VOCS in Bull Run Streamsurface water were not migrating offsite to ameasurable degree. However, based onthe findings of the RFI and CMS, Bettis-Pittsburgh proactively undertook measuresto further reduce the potential for VOCS tomigrate offsite. In late 1997, theSpringwater Intercept System was installedto collect and remove the VOCS prior todischarge to Bull Run Stream through anewly established NPDES outfall.Monitoring results for treated ground waterdischarged from the Springwater InterceptSystem indicate that the system is effectivein removing the VOCS.

VOCS associated with site operations werenot detected in sediment samples collectedfrom Thompson Run Stream, the NortheastStream, or the inactive HTTF drainagechannel. Sediment samples collected fromBull Run Stream and the Buono Springdischarge flow path contained VOCS. PCEwas the only VOC detected in Bull RunStream sediment. The primary source ofPCE in the sediment was the discharge ofwater from springs and seeps thatcontained low levels of PCE. The BuonoSpring and several other springs and seepsare now tied into the Springwater InterceptSystem. Therefore, PCE concentrations inthe Bull Run Stream sediment are likely todecline. The results of sediment samplingand analyses at onsite locationsdownstream of the Bull RunStream/Northeast Stream confluence andoffsite locations during the RF! were wellbelow screening concentrations identified byEPA Region Ill for risk assessmentthresholds. These levels indicated that PCEin Bull Run Stream sediment was notmigrating offsite to a measurable degree.

The presence of PCBS in onsite. streamsediment and the inactive HITF drainagechannel is likely associated with historicdisposal of wastes containing smallquantities of PCBS to the storm sewer

33

system and subsequent discharge to thevarious streams and the drainage channel.PAHs detected in onsite stream and springsediments are comparable to those presentin local stream sediments unaffected by sitedischarges and are not associated with anysite-specific operations, past or present.Sampling conducted during the RFIdetected only trace amounts of onepesticide and this was found in comparableconcentrations in both Thompson Run andBull Run sediments and was not associatedwith site activities.

Ground Water and Well Water MonitoringResults

Extensive ground water monitoring hasbeen conducted at the Bettis-Pittsburgh site.This ground water monitoring programincludes sampling wells, springs, andseeps. The chemicals in the ground waterinclude the solvent PCE and its degradationproducts TCE and DCE. The results forPCB, PAH, and pesticide monitoring did notreveal the presence of these materials inground water. The results of the well wateranalyses also revealed the presence ofcertain inorganic species such as iron,manganese, sulfates, and chlorides thatwere slightly above primary and secondatydrinking water maximum permissible levelsin a few cases. There are no uses for theground water at Bettis-Pittsburgh. The iron,manganese, and sulfates are inorganicspecies that are commonly found in theground water in western Pennsylvaniaeither naturally occurring or from man-madeactivities such as mining. The elevatedchloride levels in the well samples may bereflective of winter deicing activities onsite.

The results of the site ground waterinvestigations indicate that ground waterquality has been impacted by the release ofchemical constituents at the site. Groundwater quality impacts are evident in thePerched, Benwood, and Sewickley water-bearing zones and, to a much smallerdegree, in the Pittsburgh Sandstone water-bearing zone. Ground water data from


wells in the Pittsburgh Coal do not showevidence of chemical constituentsassociated with operations at the site. Theground water quality impacts in the Perchedwater-bearing zone are primarily related tothe past practice of discharging effluentscontaining chemicals into the onsite stormand sanitary sewer systems and theresultant discharge of these materials intothe ground water through leaks in thesesystems. Ground water quality impacts inthe Benwood Limestone and Sewickley andPittsburgh Sandstones are related to therelease of contaminants from the IWS,Bettis Landfill, and other areas that containchemical residues and, to a limited extent,the migrations of the chemical residues fromthe overlying water-bearing zones. Ingeneral, other areas of soil contaminationdo not appear to have had a significanteffect on ground water quality. The waterquality of springs that discharged from thewater-bearing zones reflected the waterquality obtained from the wells within thosezones.

The investigation of the ground water flowpath at the site, Reference (2), concludesthat there is no risk to the general publicfrom Bettis ground water migration.

5.3 Decontamination and RemedialPrograms

5.3.1 Decontamination and RemedialPrograms for Radioactivity

In September 1977, a long-term programwas initiated by Bettis-Pittsburgh todecontaminate and reduce the number offacilities and areas requiring radiologicalcontrols and to provide efficient use ofspace to support current operations. Thisprogram is in progress and to date, theprogram has accomplished the following:

. Decontaminated for productive usenearly 7500 square meters of buildingfloor space;

●

●

●

●

The

Removed more than 3100 meters ofpipes containing residual radioactivity

Removed over 400 cubic meters ofsoil with low levels of radioactivityfrom several regions onsite;

Removed over 100 deactivatedradiological ventilation systems; and

Removed approximately 8700 linearfeet and 21,000 square feet ofradiologically contaminated asbestosbuilding materials.

Bettis-Pittsburgh decontaminationprogram has - concentrated ondecontaminating facilities and removingcontaminated equipment and structures,rather than soil. Small quantities of soilcontaining residual radioactivity areremoved in conjunction with constructionand renovation activities.

The areas with residual soil radioactivity,discussed in Section 5.2, are monitored toensure that there is no potential forsignificant radiation exposure to workers orthe public. There is no nationallyrecognized standard for radioactivity in soil.Removal of soil with low concentrations ofresidual radioactivity is evaluated on a caseby case basis. When a national standardfor radioactivity in soil is established,additional soil removal will be considered.Further, if the site were everdecommissioned as a Federal laboratory,actions would be taken to release allfacilities and land for unrestricted use inaccordance with all applicablerequirements.

During 1991, the PADEP completed areview of radiological environmental data forthe site. The PADEP concluded that thelevels of residual radioactivity on andimmediately adjacent to the site were farbelow NRC action levels and that furtherremedial action would not be required.

34


5.3.2 Remedial Programs for ChemicalResidues

The Comprehensive EnvironmentalResponse, Compensation, and Liability Act(CERCLA), as amended by the SuperFundAmendments and Reauthorization Act of1986 (SARA), requires Federal facilities atwhich hazardous substances are located tobe evaluated for potential risks to publichealth and the environment. Thisevaluation is completed by the facility oragency using an EPA-generated rankingsystem used to identify facilities requiringprompt remedial action. The EPA, inconsultation with states, has theresponsibility to review the evaluation andofficially establish the ranking. Facilitieswith high rankings are considered forplacement on the National Priority List.Otherwise, sites are addressed inaccordance with individual staterequirements or the requirements of otherFederal laws such as RCRA. Bettis-Pittsburgh completed an evaluation forpotential risks to public health and theenvironment and submitted the results tothe EPA and the Commonwealth ofPennsylvania in Reference (1). Bettis-Pittsburgh concluded that the site has aranking value which is well below the cutofffor listing on the National Priority List. Thisevaluation has been reviewed by the EPAwho assigned a hazard ranking score ofzero and concluded that no regulatory orremedial actions were required underCERCLA

However, under the requirements of RCRA,sites having interim status or a final permitfor hazardous waste storage must addressreleases of hazardous constituents to theenvironment from past operations. Thismatter was formalized in a Consent Orderissued under Section 3008(h) of RCRA, andsigned by PNR and the EPA in August1990. As part of the Consent Order, theEPA agreed that the conditions onsite donot require implementation of interimmeasures or immediate corrective actionssince site conditions do not present an

imminent substantial endangerment tohuman health or the environment.

The Consent Order required a RCRAFacility Investigation (RFI) and CorrectiveMeasure Study (CMS) be conducted. TheRFI was conducted to characterize the siteand the CMS was conducted to determinesite-specific remediation alternatives. TheRFI work plans were approved by the EPAin 1991. Ground water monitoring wellinstallation and the ground water, surfacewater, soil, sediment and air samplingspecified in the RFI work plans werecompleted in 1993. The Final RFI Report,Reference (2), was approved by the EPA inAugust 1994.

The purpose of the CMS was to evaluateand recommend, where needed, correctivemeasures that would protect human healthand the environment. The need forcorrective measures was based on thecarcinogenic risks and the noncarcinogenichazards to human health potentially posedby the chemical contaminants of concern. Arisk assessment, which was included in theFinal RFI Report, demonstrated that thechemical residues in the environment at thesite do not realistically present a significant.risk or hazard to human health. Therefore,extensive correct.we measures are notconsidered necessary now or in theforeseeable future.

The Final CMS Report, Reference (3),proposed to the EPA several actions toensure the conclusions of the Final RFIReport remain accurate in the future, to limitpotential migration of chemical residues,and to reduce the chemical residues in theenvironment to as-low-as-reasonably-achievable. These actions included thecollection and treatment of select spring andseep water, removal of some coke gas lineresidues, continued environmentalmonitoring, and maintenance of existinghealth and safety requirements foraccessing areas that contain residualchemicals. The Final CMS Report wasapproved by the EPA in March 1995.

35

Be!tk-PMsburgh Environmental Summary Report

The EPA issued its preliminaryrecommendations for corrective measuresin November 1995 and requested publiccomment on the recommendations. TheEPA responded to public comments andissued final recommendations for correctivemeasures in October 1997. The EPAterminated the Consent Order in November1997 and stated that all requirements of theConsent Order had been met. AlthoughEPA is expected to issue a new ConsentOrder for implementation of correctivemeasures, no date has been established forthis action. Bettis-Pittsburgh has proactivelyimplemented several of the finalrecommended corrective measures.

Voluntarv Remedial Prourams

Bettis-Pittsburgh has actively addressedareas shown or suspected to containchemical residues. Some examples ofmajor voluntary efforts include the following.In the mid-1980s, Bettis-Pittsburgh removedten underground waste oil storage tanks.Leaking gasoline storage tanks have beenremoved and replaced with a new tank withsophisticated leak detection systems. Anold airport fuel tank and a site undergroundfuel oil tank for an emergency generatorhave been removed. Soil in the immediatevicinity of the tanks that contained chemicalresidues due to small spills or overfillingwas removed and properly disposed. Also,approximately 200 tons of soil thatcontained lead from a closed outdoor firingrange was removed and disposed at anoffsite licensed landfill. In addition, theSpringwater Intercept System was installedto collect and treat ground water containing

trace levels of VOCS. Bettis-Pittsburgh hasremoved sediment that had accumulated inselected manholes around the site.Polyethylene beads, containing a smallamount of lead, and entrained soil havebeen removed for disposal from an outdoorarea onsite. Work has been initiated on thecoke gas lines to remove sludge and waterin select areas, to remove portions of a line,and to monitor the lines.

Although not required by law, Bettis-Pittsburgh has been actively engaged in theremoval of friable asbestos containingmaterials from the Laboratory. In the past,this effort was directed to the removal ofsmall quantities associated with repairs orrenovation activities. In June 1991, aplanned program to remove friable asbestoscontaining materials was initiated. Thisprogram has resulted in the removal ofapproximately 66,000 linear feet and 31,000square feet of friable asbestos containingmaterial thus far. This program hasremoved most of the non-radiologicallycontaminated friable asbestos containingmaterial at Bettis-Pittsburgh. Asbestos workperformed since October 1, 1994 hasfocused on the removal of theapproximately 8,700 linear feet ofradiologically contaminated asbestos.

Non-friable asbestos containing buildingmaterials such as floor tiles and roofingmaterials are removed during normaloperations and maintenance work or as partof construction and prior to demolitionactivities. Although not required by law,Bettis-Pittsburgh has stopped usingasbestos containing building materials.

36

Bettis-Piffsburgh Environmental Summary Report

6.0 MONITORING PROGRAMS

Bettis-Pittsburgh maintains a com-prehensive environmental monitoringprogram covering all aspects of Bettis-Pittsburgh operations. This programincludes routine environmental monitoring ofoutfalls and of the Bull Run and NortheastArea streams, including sediment andvegetation, gaseous and particulateairborne effluents, sanitary effluents, groundwater, and environmental radiation levels.Evaluation of the environmental dataindicates that the operation of the Bettis-Pittsburgh site continues to have nosignificant effect on the environment. Theprogram is described in detail in the annualenvironmental monitoring reports. Inaddition to the routine monitoring, Bettis-Pittsburgh has conducted extensive specialmonitoring of areas of the site potentiallyaffected by chemical and radiologicalresidues. Examples of special monitoringefforts are described in the followingsections.

6.1 Aerial Radiation Survey

Convincing evidence that Bettis-Pittsburghdoes not represent a significant radiologicalproblem comes from the results of an aerialradiation survey of the site and thesurrounding areas, conducted in July 1983.The aerial radiation survey over the Bettis-

37

Pittsburgh site covered a 100-square-milearea. The survey area included WestMifflin, McKeesport, and other nearbycommunities. The results of the survey forthe Bettis-Pittsburgh site indicated radiationreadings of background with the exceptionof minor elevations of the readings in theimmediate vicinity of the buildings whereradiological work is undertaken. Nochanges in radiological conditions haveoccurred at the site that would affect theconclusion of the 1983 aerial survey.

6.2 Ground Water Monitoring

There are no wells or springs onsite or inthe local, hydraulically downgradient areawhich are known to be used for drinkingwater, industrial, or irrigation purposes.Nonetheless, Bettis-Pittsburgh monitors theground water under the site to determinewhat, if any, effects the operations at thesite have had on the quality of the groundwater. This program has involved theinstallation of over 100 ground watermonitoring wells. Selected wells andvarious springs onsite are monitored forboth chemical and radiological parameters.These analyses are used to evaluate theimpacts on the ground water. The results ofthe ground water monitoring are discussedin Section 5.2.4.

Bettk-Pittsburgh Environmental Summary Report

7.0 ASSESSMENT OF HUMAN HEALTH IMPACTS

The impact of Bettis-Pittsburgh operationson the environment can be assessedseparately in terms of radioactive andnon-radioactive effects.

7.1 Radiological Assessment

With respect to radioactivity, Bettis-Pittsburgh has been monitoring dischargesof radioactivity to the environment from thesite in liquid and airborne effluents. Effluentdischarges of radioactivity have been atlevels below limits prescribed by applicablefederal, state, and local authorities.

Bettis-Pittsburgh has never maintained aradioactive waste burial ground. However,activities in the past have resulted in smallamounts of radioactive material deposited inlocalized areas of soil onsite. There are fiveprimary locations onsite where suchreleases occurred: Inactive Waste IsolationPit, N-Building Monitor Tank Room, WasteProcessing Storage Pad, Inactive WasteSite, and the Bull Run Stream Basin. Bettis-Pittsburgh is continuing with a program tomonitor and, where appropriate, clean upand remove those structures and adjacentsoil where the radioactivity exists. At thepresent time, the estimated total quantity ofmanmade radioactivity in the soil at theBettis-Pittsburgh site is less than 72 curies,which is no more than the amount ofnaturally occurring radioactivity in the top 2feet of soil in a local area the size of theBettis-Pittsburgh site.

The comprehensive site radiationmonitoring program, which is described inthe annual environmental monitoring report,shows that the radiation dose to personsoffsite is too small to be measured. Bettis-Pittsburgh has employed calculationaltechniques that conservatively estimatepotential exposures. These calculationaltechniques consider inhalation, ingestion,and direct radiation exposure pathways.

The most recent assessment for 1997shows that the maximum potential radiationexposure to a member of the public wasless than 0.003 Rem for the entire year.The calculations also show that in previousyears, the annual radiation exposures topeople living adjacent to Bettis-Pittsburghwere well below the annual regulatory limits.

7.2 Non-Radiological Assessment

Regarding non-radiological environmentaleffects, Bettis-Pittsburgh monitors effluentwater, ground water, sanitary discharges,sediment, and surFace water to ensure thatthey meet the requirements of applicablefederal and state environmental standards.The annual environmental monitoring reportshows that Bettis-Pittsburgh operationshave no significant effect on theenvironment around the site or the generalpublic.

Hazard ranking calculations done inaccordance with guidelines for judging thesignificance of waste areas containingchemical and radioactive residues havebeen conducted in accordance with Federallaw (see Reference (1)). The calculationconcludes that the Bettis-Pittsburgh sitescores well below the values which wouldmake the site a candidate for placement onthe National Priority List. The calculationsand supporting documentation have beenreviewed by the EPA who assigned ahazard ranking score of zero. The EPAconcluded that no action was requiredunder CERCLA

A site specific risk assessment wasprepared as part of the Final RFI Report.This assessment was prepared using theSuperfund related methodology outlined inReference (4). The detailed assessment,presented in the Final RFI Report(Reference (2)), is summarized below.

38


The objective of the assessment was todetermine the reasonable maximumexposure of onsite and offsite populations toenvironmental contamination at the site.The media containing chemical residues aresoil, ground water, surface water (springsand streams), and sediment. Residueswhose concentrations exceeded the EPARegion Ill risk-based screening levels wereevaluated. The main residues evaluatedwere VOCS, PCBS, and PAHs.

Risks were evaluated for present and futurerealistic industrial land-use scenarios. EPAexposure default parameters were used foroffsite commercial/industrial workers. Site-specific exposure parameters were used forpathways where standard EPA values werenot available or were not appropriate. Allexposure pathways judged to be completenow and in the future were quantified.Ground water exposure was not quantifiedbecause the onsite and offsite populationsthat are hydraulically downgradient receivemunicipal water and this is unlikely tochange for the foreseeable future becausethe municipal water supply is convenient,reliable, and safe.

The risk assessment quantifiedcarcinogenic risk and noncarcinogenichazard for four potentially exposedpopulations:

. Onsite construction workers exposed tochemical residues in soil;

. Offsite commercial/industrial workersexposed to chemical residues in soil;

. Trespassing children exposed tochemical residues in water andsediments in springs and streams; and

39

. Offsite children exposed to chemicalresidues in water in a spring andsediment in a stream.

Based on EPA criteria, the calculatedcarcinogenic risk and noncarcinogenichazard values were compared with thevalues of 1.0 x 104 and 1.0, respectively,which represent acceptable risk levels. Thenon-carcinogenic hazard value of 1.0indicates that overall non-carcinogenichazards are not of concern. Remedialactions are generally not required until thehazard value exceeds 10.0.

In summary, the risk assessment concludedchemical residues in the environment at thesite do not pose significant health risks topotentially exposed populations usingreasonable maximum exposureassumptions. The only study area with acarcinogenic risk estimate exceeding thecomparison criterion is VNGI soil, with amaximum carcinogenic risk ofapproximately 2 x 10-5. However, exposure(dermal contact, ingestion, and inhalation)for 250 dayslyear for 25 years is required toachieve this risk. This risk is within the EPApost-remediation criteria of 1.0 x 104 to 1.0x 1O%. In addition, this risk is highlyconservative because the contaminatedportions of the VNGI property are ininfrequently accessed or undevelopedlocations. In reality, the risk at VNGI is lessthan 1.0 x 10% because the realisticexposure is much less than that used in thecalculations. Non-carcinogenic risks wereall significantly less than the comparisoncriteria of 1.0.

Bettis-Pittsburgh will continue actions topreclude any impact on the environmentfrom the remaining residual chemical orradioactive materials at the site inaccordance with federal, state, and DOErequirements.


8.0 AUDITS AND REVIEWS

Bettis-Pittsburgh uses training, sur-veillances, controls, checks andcross-checks, audits, and inspections ofnumerous kinds to maintain high standardsof environmental control. Examples include:

●

●

●

●

●

●

Each worker is specially trained in theappropriate controls as they relate totheir job.

Written procedures must be followed inmany cases.

Supervisors oversee environmentalmonitoring and related work.

Engineering and environmental staff areavailable to assist area personnel.

Bettis-Pittsburgh maintains anindependent audit program that coversenvironmental requirements andincludes in-depth audits of specificareas.

The NNPP maintains an onsite residentoffice with a technical staff that reportsdirectly to the Director, NNPP inWashington, D.C. Several personnel inthis office are assigned full time to auditand review environmental controls.NNPP headquarters personnel also

conduct periodic in-depth inspections ofthese areas.

[n addition to the above controls, variousaspects of the Bettis-Pittsburghenvironmental program are reviewed byother Government agencies. For example,both the PADEP and the EPA haveconducted onsite inspections of RCRAprograms as illustrated by Table 1. None ofthese EPA, state, or local inspections haveever detected a significant item ofnon-compliance in operations. Only minoradministrative shortcomings have beennoted and these have been corrected.

During negotiation of the Consent Order,Bettis-Pittsburgh received a Notice ofViolation (NOV) from the PADEPconcerning the presence of residualchemicals in the ground water at Bettis-Pittsburgh due to past practices aspreviously identified to the state in theevaluations discussed in Section 7.0. PNRand Bettis-Pittsburgh are working with thePADEP to resolve the NOV. A draftConsent Order requiring operation of theSpringwater Intercept System has beensubmitted to the PADEP for review andconsideration. It is expected that thisConsent Order would resolve the issuesraised in the NOV.

40

TABLE 1

ENVIRONMENTAL INSPECTIONS OF THE BETTIS-PllTSBURGH SITE

TOPIC DATE AGENCY

RCRA September 12, 1989 EPA-Region IllJune 12,1990 PADEPSeptember 12, 1990 EPA-Region IIIMay 29, 1991 PADEPAugust 16, 1991 EPA-Region Ill, PADEPAugust 26, 1992 PADEPAugust 16, 1993 PADEPSeptember 9, 1994 PADEPAugust 11,1995 PADEPJuiy 11, 1996 PADEPJuly 23,1997 PADEPSeptember 10, 1998 PADEP

Asbestos August 16,1991 EPA-Region IllSeptember 27,1991 (2) EPA-Region IllOctober 4, 1991 ACHDOctober 23, 1991 ACHDNovember 1,1991 (3) EPA-Region IllNovember 15,1991 EPA-Region IllDecember 20,1991 (2) EPA-Region IllFebruary 14, 1992 EPA-Region IllApril 5, 1992 ACHDMay 17, 1992 ACHDMay 29, 1992 (3) EPA-Region IllSeptember 4,1992 (2) EPA-Region IllSeptember 18, 1992 EPA-Region IllOctober 13, 1992 EPA-Region IllJanuary 22, 1993 EPA-Region IllMarch 12, 1993 (6) EPA-Region IIIApril 7, 1993 EPA-Region IllAugust 6, 1993 (2) EPA-Region IllOctober 29, 1993 (2) EPA-Region IllNovember 19,1993 (3) EPA-Region IIIDecember 10,1993 DOLIDecember 22, 1993 EPA-Region IllMarch 1,1994 EPA-Region IllMarch 26, 1994 DOLIMay 2, 1994 EPA-Region IllJuly 8,1994 (3) EPA-Region IllApril 6,1995 DOLIApril 19,1995 ACHDMay 19, 1995 ACHDMay 24, 1995 DOLIJune 8,1995 ACHDJune 21,1995 ACHDJuly 3, 1995 ACHDJuly 6, 1995 ACHDJuly 17, 1995 ACHDJuly 26,1995 (2) ACHDAugust 15,1995 ACHDSeptember 12, 1995 ACHDOctober 6,1995 (2) ACHDNovember 7, 1995 ACHDNovember 13,1995(3) ACHDNovember 16,1995 ACHDNovember 28,1995 ACHDDecember 8,1995 ACHDDecember 15, 1995 ACHDDecember 21, 1995 ACHDJanuary 30, 1996 ACHDMarch 15, 1996 ACHDMarch 29, 1996 ACHDAPri\ 8,1996 ACHDMay 20, 1996 ACHDMay 23, 1996 ACHD

41

Bettis-Pjifsburgh Environmental Summary Report

TABLE 1

ENVIRONMENTAL INSPECTIONS OF THE BEITIS-PllTSBURGH SITE (cent’d~

TOPIC

NPDES

Air

DATEJune 20, 1996 (2)June 24, 1996July 15,1996 (2)July 19, 1996July 30,1996September 22, 1996October 8,1996 (2)November 5, 1996 (2)December 20,1996 (4)January 8, 1997January 27, 1997February 7, 1997June 18,1997July 24, 1997August 20, 1997 (2)August 27, 1997September 22, 1997October 6, 1997October 10, 1997November 12, 1997 (2)December 11, 1997February 19, 1998April 2,1998 (3)April 16, 1998 (2)April 28,1998May 15, 1998May 26, 1998 (2)June 15,1998 (3)June 18, 1998JUly 13, 1998July 23, 1998 (2)July 28,1998August 21,1998 (2)August 27, 1998September 9, 1998 (2)September 18, 1998 (4)October 5,1998 (5)October 23, 1998 (2)November 5, 1998November 20,1998 (2)

November 20, 1995December 7, 1995March 12, 1996August 9, 1996March 13, 1997December 3, 1998

March 31, 1993September 27, 1996April 2, 1998September 18, 1998

AGENCYACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDDOLIACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHDACHD

PADEPPADEPPADEPPADEPPADEPPADEP

ACHDACHDACHDACHD

NOTES:

This table identifies inspections conducted during the period of 1989 through 1998.

When more than one inspection was performed, the number of inspections is shown in ( ).

EPA - U.S. Environmental Protection AgencyPADEP - Pennsylvania Department of Environmental ProtectionACHD - Allegheny County Health DepartmentDOLI - Pennsylvania Department of Labor and Industry

42

Bettk-Pittsburgh Environmental Summary Repotl

9.0 REGULATORY MATTERS

Bettis-Pittsburgh always responds promptlyand effectively to meet new federal, state,and local requirements. Bettis-Pittsburghmaintains a program to review changes inregulatory requirements to ensureoperations remain in compliance withapplicable laws and regulations.

Resource Conservation and Recoverv Act

m

This Act establishes requirements for theproper treatment, storage, and disposal ofchemically hazardous wastes. Currently,Bettis-Pittsburgh operates in accordancewith its Hazardous Waste Storage Permitwhich was issued by the PADEP inFebruary 1995. The Hazardous WasteStorage Permit includes specific detailsregarding operations and managementpractices for safe control and storage ofhazardous wastes. The permit applicationhas been amended to include the MixedWaste Storage Facility, currently operatedunder interim status.

During 1990, a Consent Order issued underSection 3008(h) of RCRA was signed byPNR and the EPA. Details of therequirements and compliance status of theConsent Order are provided inSection 5.3.2.

Federal Facilitv Compliance Act (FFCA)

This Act requires the DOE to prepare SiteTreatment Plans to address treatment ofmixed radioactive and hazardous waste foreach DOE site which generates and storesmixed waste. These plans were approvedby the states (or the EPA in cases wherethe state has not been delegated authorityto regulate mixed waste). The Bettis-Pittsburgh Site Treatment Plan wasprovided to EPA Region Ill and wasapproved by the EPA in October 1995. Inaddition, PNR and the EPA Region Ill

43

entered into a Consent Agreement andConsent Order which implements the SiteTreatment Plan.

Comprehensive Environmental Res~onselCompensation, and Liabilitv Act (CERCLA]

This Act, commonly known as Supetfund,establishes requirements for theidentification of areas where hazardousmaterials may be present in theenvironment and for the evaluation ofpossible risks from these contaminants tothe public health and the environment.Bettis-Pittsburgh has prepared andsubmitted to the EPA and theCommonwealth of Pennsylvania thedocumentation concerning such areas atthe site (discussed in Section 5.0) as isrequired by CERCLA (Reference (1)). Thesubmittal includes hazard rankingcalculations conducted in accordance withEPA methods. The ranking calculationconcludes that the Bettis-Pittsburgh sitescores well below the value which couldplace the site on the National Priority List.The EPA reviewed the submittal andassigned a hazard ranking score of zeroand concluded that no further action wasrequired under CERCLA.

SuPerFund Amendments andReauthorization Act [SARA~

This Act, more commonly known as SARA,is a five-year extension of the programsestablished under Superfund (CERCLA) toclean up hazardous releases at pasthazardous waste sites. In addition, SARAcreated a separate fund for the cleanup ofleaking underground petroleum storagetanks and defined a new regulatory programknown as the Emergency Planning andCommunity Right-to-Know Act (EPCRA).As part of the requirements of EPCRA,Bettis-Pittsburgh has submitted details onthe amounts, locations, and potential health

—.-


hazards associated with onsite hazardousmaterials to state and local emergencyplanning groups.

Clean Air Act {CAA)

This Act, as amended in 1990, establishedrequirements for the control of airemissions. The regulations promulgatedpursuant to the CAA also govern use ofozone depleting substances, the use andremoval of asbestos containing materials,and the emission of radionuclides to theenvironment. For the Bettis-Pittsburgh site,most of the non-radiological air programsare administered by the ACHD through itsArticle XXI regulations. In 1995, Bettis-Pittsburgh submitted an Air PollutionOperating Permit application in accordancewith updated CAA and ACHD requirements.The ACHD has not issued the permit,however, Bettis-Pittsburgh is operating inaccordance with all current regulations andconditions identified in the permitapplication. Radiological air emissions atBettis-Pittsburgh are monitored andreported annually to the EPA in accordancewith the requirements of the NationalEmission Standards for Hazardous AirPollutants.

44

Clean Water Act (CWA\

The Clean Water Act requires facilities thatdischarge pollutants to navigable waters toobtain authorization for their discharges byacquiring an NPDES permit. NPDESpermits specify the discharge limitations andmonitoring requirements for selectedparameters in a facility’s effluents. TheBettis-Pittsburgh site received its firstNPDES permit, which was issued by theCommonwealth of Pennsylvania, in 1977.The site NPDES permit has been renewedseveral times and currently covers sevenoutfalls. Two outfalls discharge stormwater, process water, and once-throughnon-contact cooling water. Four outfailsdischarge only storm water. The mostrecently permitted outfall discharges treatedground water from the Springwater InterceptSystem.

Other Laws and Regulations

Bettis-Pittsburgh also operates incompliance with other federal, state, andlocal environmental regulations. The PCBprogram onsite is managed in accordancewith Toxic Substances Control Actregulations. Compliance withCommonwealth of Pennsylvania laws andregulations that regulate waste, water, andtanks is also maintained.

I Bettis-Pittsburgh Environmental Summary Report

(1)

(2)

(3)

(4)

(5)

REFERENCES

Preliminary Assessment and Site Inspection Report for the Bettis Atomic PowerLaboratory, Revision 1, January 1990.

Final Resource Conservation and Recovery Act Facility Investigation (RFI) Report for theBettis Laboratory, West Mifflin, Pennsylvania, June 1994.

Final Corrective Measures Study (CMS) Report for the Bettis Laboratory, West Mifflin, PA,January 1995.

Risk Assessment Guidance for Supetfund (RAGS) Volume I (Part A), Human HealthEvaluation Manual, USEPA, 1989.

1997 Environmental Monitoring Report for the Bettis Atomic Power Laboratory, WestMifflin, Pennsylvania, August 1998.


DISTRIBUTIONNo. Copies

Admiral F. L. Bowman, Deputy Assistant Secretary for 50Naval ReactorsU. S. Department of EnergyWashington, D.C. 20585

Mr. H. A. Cardinali, Manager 3Pittsburgh Naval Reactors Office, U.S. Department of EnergyPost Office Box 109West Mifflin, Pennsylvania 15122

Office of Environmental Guidance and Compliance, EH-23 10U. S. Department of EnergyWashington, D.C. 20585

U.S. Department of Energy 1Headquarters Energy Library1000 Independence Ave. SWRoom GA 138 -MA -224Washington, D.C. 20585

U.S. Department of Energy 1Technical Information CenterPost Office Box 62Oak Ridge, Tennessee 37831

Science and Technology Department 1Carnegie Library of Pittsburgh4400 Forbes AvenuePittsburgh, Pennsylvania 15213

Mr. W. Michael McCabe, Regional AdministratorU. S. Environmental Protection AgencyRegion Ill1650 Arch StreetPhiladelphia, PA 19103-2029

Ms. Maria Parisi-Vickers, Associate DirectorOffice of RCRA ProgramsU. S. Environmental Protection AgencyRegion Ill1650 Arch StreetPhiladelphia, PA 19103-2029

46

1

1

I


DISTRIBUTION (Continued]No. Copies

Mr. Harry T. Daw, Chief RCRA Compliance and Enforcement 1

(3WC31)U. S. Environmental Protection AgencyRegion Ill1650 Arch StreetPhiladelphia, Pennsylvania 19103-2029

Ms. Carol Amend, Director, Office of Compliance and EnforcementU. S. Environmental Protection AgencyRegion Ill1650 Arch StreetPhiladelphia, Pennsylvania 19103-2029

Robert Kramer, Radiation Program ManagerU. S. Environmental Protection AgencyRegion Ill1650 Arch StreetPhiladelphia, PA 19103-2029

The Honorable Aden Specter711 Hart Senate Office Bldg.Washington, D.C. 20510

The Honorable Rick Santorum120 Russell Bldg.Washington, D. C. 20510

The Honorable Mike DoyleU. S. House of Representatives133 Cannon H.O.B.Washington, D. C. 20515

Secretary James M. SeifDepartment of Environmental ProtectionCommonwealth of Pennsylvania16th Floor Rachel Carson State Office BuildingPost Office Box 2063Harrisburg, Pennsylvania 17105

D. Richard Shipman, Division ChiefDivision of Hazardous Waste ManagementBureau of Land Recycling and Waste ManagementDepartment of Environmental ProtectionRCSOB – 400 Market StreetCommonwealth of PennsylvaniaP.O. BOX 8471Harrisburg, PA 17105

47

Bettis-Piftsburah Environmental Summarv ReDo?t

DISTRIBUTION (Continued\

Mr. Joseph W. Chnupa, Assistant Regional DirectorSouthwest Regional OfficeDepartment of Environmental ProtectionCommonwealth of Pennsylvania400 Waterfront DrivePittsburgh, PA 15222-4745

Mr. Terry A. Pallas, Chief, Monitoring and ComplianceOperations SectionWater Management ProgramPennsylvania Department of Environmental ProtectionCommonwealth of Pennsylvania400 Waterfront DrivePittsburgh, Pennsylvania 15222-4745

Mr. James Yusko, Regional ManagerRadiation ProtectionPennsylvania Department of Environmental ProtectionCommonwealth of Pennsylvania400 Waterfront DrivePittsburgh, Pennsylvania 15222-4745

David J. Allard, DirectorRadiation ProtectionDepar&ment of Environmental ProtectionRachael Carson State Office BuildingP. O. BoX 8469Harrisburg, PA 17105-8469

The Honorable Albert V. BeIanPennsylvania SenateCapitol BuildingHarrisburg, PA 17120

The Honorable Kenneth RuffingRepresentative – 38th District751 Pittsburgh/McKeesport Blvd.Dravosburg, Pa. 15034

Bruce W. Dixon, M. D., DirectorAllegheny County Health Department3333 Forbes AvenuePittsburgh, PA 15213

48

INo. Copies

1

1

1

1

1

1

1


DISTRIBUTION (Continued)

No. Copies

Mr. Roger Westrnan, Manager 1Air Quality ProgramAllegheny County Health Department301 Thirty-ninth Street, Building #7Pittsburgh, PA 15201-1891

Mr. Howard Bednar, Borough ManagerWest Mifflin Borough3000 Lebanon Church RoadWest Mifflin, PA 15122

The Honorable John Powell, MayorBorough of Dravosburg226 Maple AvenueDravosburg, PA 15034

49

Documents

Bettis - Pittsburgh Site Environmental Summary Report/67531/metadc720971/... · BETT’ISATOMIC POWER LABORATORY BETTIS-PITTSBURGH SITE ENVIRONMENTAL SUMMARY REPORT AUGUST 1999 Prepared