STATE OF WASHINGTON DEPARTMENT OF ECOLOGY PO Box 47600 9 Olympia, WA 98504--7600 9 360-407-6000 711 for Washington Relay Service 9 Persons with a speech can can' 877-833-6341 September 27, 2012 12-NWP-157 Mr. John G. Lehew CH2M HILL Plateau Remediation Company P.O. Box 1600 MSIN: H7-30 Richland, WA 99352 Mr. Matthew S. McCormick Richland Operations Office United States Department of Energy P.O. Box 550 MSIN: A7-50 Richland, WA 99352 Re: -Dangerous Waste Compliance Inspection at United States Department of Energy Hanford Facility, Central Waste Complex (CWC) on March 7, 8, 14, 15, 2012. RCRA Site ID: WA7890008967 Dear Mr. McCormick and Mr. Lehew: Thank you for your time during the recent inspection to determine compliance with the Washington State Dangerous Waste Regulations (Washington Administrative Code Chapter These regulations establish a system for safe and responsible management of dangerous waste. Several areas did not comply with the Dangerous Waste Regulations at CWC. These areas are listed in the enclosed Compliance Report. Ecology will be in contact with you to discuss actions to correct them, and to identify specified timeframes. You may contact me at 509-372-7921 or John.Price@ecy.wa.goV if you have questions or need further information. Sincerely, John B. Price Tri-Party Agreement Section Manager Nuclear Waste Program Enclosure cc W/enc: Michael Collins, USDOE Al Farabee, USDOE Joel Williamson, Administrative Record: CWC Environmental Portal USDOE-RL Correspondence Control -- L1 Washington Department of Ecology Hazardous Waste Toxics Reduction Program Compliance Report - Site - Hanford CWC Facility RCRA WA 7 89000 8967 Inspection Date: March.7, 8, 14, 15, 2012 Site Contacts: Mike Collins, US_Department of Energy (USDOE) - Stu Mortensen, CH Plateau Remediation Joel Williams, CI-IPRC Paul T. Karsohnia, Materials and Energy Corporation Phone: (509) 376-6536 Site Location: Box 550 Street Address Richland, WA 99352 At This Site Since: Current Site Status: Unverified Dangerous Waste Management Unit (DWMU) Ecology Lead Contact: Kerry Graber 360-407-6305 Other"Represe-ntatives: oanette Biebesheimer Kathy Conaway . Jerry Yokel Report Date: September 27, 2012 Report" By: Kerry Graber Qttkaa agaga I (Signed) (Date) Facility Background: I I The Hartford' Facility "boundary encompasses an area of _approximately 586 square miles. The Central Waste'Complex (CWC) is a treatment, storage, disposal (TSD) group consisting of many dangerous waste management units (DWMUS). CWC is an integral part of a waste management system that has developed over time to manage mixed or dangerous waste fiom the closure and cleanup of a number of operations at the Hanford Facility. This activity occurs under the Hanford Dangerous Waste permit and the Hanford Federal "Facility Agreement and Administrative Consent Order. The latter contains a compliance schedule (Appendix D) with milestones and is also known as the Tri--PaIty Agreement (TPA). The TPA references the M-91 milestone series as such: - The scope of the M--091 Milestone series is to complete removal of the retricvable stored waste (RSW) from the burial grounds and eliminate the backlog of mixed low-level waste (MLLW) and transuranic mixed waste in storage by December 31, 2030. When these milestones are complete, United States Department of Energy (USDOE) will have successfully treated the MLLW and shipped the TRUM waste offsite for disposal. TRUM waste is a higher level of radioactivity (concentrations greater than 100 fit/g), from elements with atomic numbers. ., greater than that of uranium. - USDOE Central Waste Cornplex Expansion Area Report Date: September 27, 201 I . WA7089000 8967 Page 2 of27 - . Inspection Date: March 8, 14, 15, 2012 The CWC is one of four TSD groups referred to as the solid waste operations complex (SWOC). The other three TSD groups are referred to as Waste Receiving and Processing Facility (WRAP), T-Plant Complex, and the Low-Level Burial Grounds Trench 31 34 31 34). . . The CWC is usually the first gr'oi1p_of SWOCthat receives containers of RSW and TRUM). Once retrieved, the MLLW containers are stored at CWC until either sent to one of the other SWOC TSD groups to a permitted facility for Land Disposal Restriction (LDR) treatment. The off>>-site facility opens the containers, inventories the contents, verifies the Waste, and repackages it for storage or disposal back at the Hanford Facility. LDR-treated containers are returned' to the Hanford Facility and may be stored at CWC, or disposed of at the Envir.onn1en_talRestoratior_1_ Disposal Facility (ERDF), a Comprehensive Envirornnental Response, Compensation, and Liability 'Act (CERCLA) landfill, or at 31 34. Currently LDR treated MLLW returning to the Hanford Facility is disposed at the 34 instead of The 31 34 do not have final status permit conditions in the current Hanford dangerous y_vast_e permit (Revision 80). TRUM vyaste containers have been 'cer_fc_i_fied by an onsite consultant at the Hanford Facility to ineeit the requirements for shipment to the Waste Isolation Pilot Project (WIPP) in New Mexico. The certifying contractor is no longer at the Hartford Facility, so TRUM waste_cannot'be shipped to WIPP at this time unless it is shipped to the Idaho USDOE facility for certification. Some TRUM "waste has been shipped to an offsite permitted facility for treatment, but then was returned -to ACWC for storage. Laclc of . adequate budget appears to be the primary factor in why TRUM waste is in long-term storage at the CWC. The Hanford Facility currently has a final dangerous Waste permit that was issued by the Department of Ecology' (Ecology) August 29, 1994' and expired in 2004. A number of permit modifications have been approved since the permit was issued, and-these are referred to as revisions. The current--approved - revision is referred to as Revision 8c.' A new draft per1niti(Revision 9) was issued May 1, 20l2_.__for public comment through October 22, 2012. The 1994 permit does not have the CWC listed and there 31? no Part permit requirements that establish and administer the dangerous waste - . acceptance and storage at the TSD group. USDOE asserts" the covered undera broad A, that assertion is applied to. all of the TSD groups, and that the SWOC TSD groups c_omply with requirements for an interim status facility. further claims that SWOC operates under the interim status'standards of the Washington A_d1ninistrative'Code (WAC) 1'73-3 03-400 and select. portions_ of the Revision 8c perrnit.. - i - Note: A review of a Part A referred to in the previous paragraph, submitted by USDOE in-2008, failed to any specific reference, photograph, or diagram of CWC expansion areas. For the purpose of this inspection, it is Ecology's position that the CWC outdoor expansion area does not have an interim status permit, because the existence of a final status permit voids: any claim to an interim status permit under chapter 70.105 RCW and chapter 173-303 WAC, specifically WAC 173- USDOE . Central Waste Complex Expansion Area Report Date: September 27, 2012 . WA7089000 8967 Page 3 of 27 Inspection Date: March 7, 8, 14, 15, 2012 The Dangerous Waste Permit Revision 8c, part I.A apply to.the'operation of this facility. This permit condition states: - - . . -. units operating or closing under interim status will maintain -interim status until that TSD unit is incorporated into Part-IH, V, and/or VI of this permit, or until interim status is terminated . under WAC Permit Number WA7890008967, Revision SC, Part I Standard Conditions, I.A Effect of -Permit. . . The standards used to evaluate compliance for this investigation are the interim status facility standards - in WAC and the regulations incorporated into the interim status standards byreference. Post-inspection documents provided by Mr. Collins at my request included: avtaste analysis plan from revision 7 of the 1994 permit, and waste acceptance. procedure "0063" (Hanford Site Solid Waste Acceptance Criteria, HNF-EP--0063) to further evaluatewhether current practices meet facility standards. Also provided at my request was technical procedure SW-040-043, Inspect CWC Miscellaneous Building; Revision 8, change 5 dated 03/09! 12 by for the inspection plan. Inspection On February 7, 2012 Ms. Kathleen Conaway received a phone call froin Wayne Toebe, CI-IPRC, to. inform Ecology that a leak was detected fiorn a container stored at CWC expansion area, box 231-2.- DR-1 1 . - Note: This contrasts with claims in letter dated 19__April 2012 fiorn Mr. McCormick to Mr. Kowalski that labels were present but not visible on the photos. On February 21, 2012 Joanette'Biebesheimer, Ecology Inspector, and Steve Lowe, Ecology SWOC Lead Permit Writer, visited CWC. Also present were Joel Williams, Stu Mortensen, Dave'Gillis of CI-IPRC, Mike Collins and Tony McKarr1s for USDOE, and Paul T. of Ecology staff were told at'this meeting that the box 231-Z-DR--1 1 leak was discovered by radiological control technicians (RCTS) during monitoring of the box as a contamination area (CA). The CA had been identified in the November/December, 2011 tirnefrarne. During the February 6 survey of the CA boundary the RCTs found' 84,000 disintegrations per minute (dpm)/10001112 from direct sampling. Direct sampling at the-"leak from the box measured 480,000 dpm/l00crn2. - Note: It was explained later that direct sampling means holding the instrument approximately inch from a surface and taking _a reading. Mr. Lowe recorded in his notes that the box originated from the east end of trench 1 at the LLBG 218- According to his notes a total of 36 gallons of liquid had been collected so far in the blue bottles (carboys). - USDOE Central Waste Complex Expansion Area Report Date: September 27', 2012 WA7089000 8967 Page 4 of 27 - Inspection Date: March 7, 3, 14, 15, 2012 During the February 21, 2012 meeting USDOE informed Ecology that a sample ofthe liquid had been pulled on Friday, February 17, and was going to be analyzed at Waste Sampling and Characterization . Facility (WSCF) for metals, PCB, and specific volatile organic "compounds that were supposed to be in the box 'according to records. .- The full scan of organic: compounds was not ordered. The delay -in analysis of the samples was explained as' anecessary delay because the samples were pulled on a Friday and could not go to the lab on the weekend. Samples were going to take from seven to thirty days to get results. We were proyided the results on March 8, _2012. (The laboratory report gives two sample dates, with two" separate samples for 21' 12/ 12 and 2/ 6/ 12. Joel Williams clarified" verbally to Ecology that the later date was a blank provided to the laboratory at their request.) - - During the February 21, 2012 meeting specific questions about the care of the box were posed by Ecology. to the facility staff. It was noted that while the plywood boxes have covers, the two cernent boxes such as the leaking one were not covered. Mr. Collins stated that nothing gave them the indication that the concrete boxcsneeded tarps,'they- appeared .to not need them-. (There are two concrete boxes, the 'larger of thetwo is - - - I - clluestionedlabout the laclc of a report on the spill in the regularly submitted "occurrence. reports" provided to Ecology, the response was that the spill was "not reportable" and did not meet the "fcz'iteria"' for reporting. 1 Ms. Bteheeheithet and Mt. the b'o'x'fr'ori:1 a distance during this the visit. Photosytete'. f. taken. Drip pans with blue bottles laid on their side horizontally were noted. The box had rusted seams" on one side visible through binoculars. Mr. Mortensen said that leaks are coming fiorn the joints," and that they put wicki-ng on the leaking areas_'to'lielp' liquid into the bottles. During the February 21, 2012 site visit Ms. Biebesheirner was told_ that fixatiyes had been placed on the ground and covered with yellow plastic. Fixatives are a chemical product that when applied helps "fix" radioactive contarnination in place. __At the debriefing before leaving the site, Ms. Biebesheimer requested the following documents: report . - . . . 2. Operating records for the box 1' . 3. CA identification,- how long the box has been a CA, and why . 4. Sampling and Analysis Plan used for sampling the collected liquids (SAP) 5. Total calculations of the amount leaked to the ground, and the amount collected in bottles. Note: By March 7 the only information provided to Ecology from this list was the AK and SWITS report provided to Ms. Biebesheirnen 1. The AK [acceptable knowledge] package and solid waste information' tracking USDOE Central Waste Complex Expansion Area Report Date: September 27,2012 WA7089000 8967 Page 5 of 27 - Inspection Date: March 7, 3, 14, 15, 2012 During the discussion of records, Mr. Williams indicated that'Wayne Toebe called Ms. Conaway on February 6, 2012. This did not match_Ec0logy's records. Mr. Williams insisted Ecology was notified on the day of the spill. Mr. Williams indicated that the 'Washington Department of Health requested logs of the day of the spill and two other -dates. Ms. Biebesheirner requested the log records since the CA had been identified in December 2011. I - During a follow up conversation with Mr. Williams the afternoon of February 21, 2012 Ms. Biebesheimer requested that the laboratory analyze for all of the constituents from the waste codes identified for the box specifically the constituents found in the ""F-codes", F001, 2, 3, and 5. Ms. Biebesheimer received copies of photos from DOH of box #23 1 11 that were taken in May of 2011. These photos clearly indicate a roped--off, CA boundary aroundthis specific box from this earlier time. 'Photos of the box show the absence of proper labeling in areas easily visible for inspection. (See photo log of DOH photos.) Ecology requested access to the box to sample liquid being collected from the box via temporary drip pans and the carboys. USDOE agreed to provide Ecology access for the purpose of this sampling and it was arranged for a return to the CWC on March 7 and 8 for sampling. March 7, 2012 An in-briefing meeting washeld with USDOE at the federal buildingin Richland to introduce the-focus of the inspection and discuss the approach of the investigation. During this meeting, I requested access to View the box, review documentation, and interview personnel involved in.-the discovery and management of the release. Attendees to this meeting are listed one copy of the sig11~in sheet placed in Ecology's file. Duringthe in~briefing Mike Collins of USDOE informed me that analytical results were received. from' I the box samples they submitted to the WSCF, a laboratory located on the Hartford Facility. Preliminary - results showed that the collected material was not dangerous waste. I requested a copy of the laboratory report. We agreed to meet at the CWC, and concluded the Ms. Biebesheirner, Steve Lowe, and I arrived at the CWC at approximately 11:45 am. We were shown to a' large conference room where we were introduced to Dave Gillis, operations manager for CWC, and Stu Mortensen. Mr. Mortensen is the facility manager for the CWC, WRAP, and 31 34 TSD groups, and Mr. Gillis' supervisor. Both are employees of Also present for were Brian Oldfield, manager for the radiation monitoring program. Paul "Tad" was present as an environmental manager for Mike Collins was present for USDOE. Additional personnel that participated in the discussion are provided on the attached sign-in sheet copy we collected for this meeting. I briefly discussed the purpose of the inspection, and I explained that we were. investigating what we understood to be a release to the environment- of mixed or dangerous waste from container USDOE Central Waste Complex Expansion Area Report Date: September 27, 2012 . WA7089000 .8967 Page 6 of.?.7 . Inspection Date: March 7, 8, 14, 15, 2012 1 1. Mike Collins asserted that there-has not been a release of dangerous or mixed waste to the - - environment. We discussed the verbal results of the USD OB analytical. data fiom theirsarnples again.- Mr. Collins asserted there were no dangerous -waste constituents above-TCLP thresholds, and no reportable quantity. I explained-that under WAC 1-73-303-145 the requirement was to report and - mitigate a release of a hazardous substance. Detection of a hazardous' substance would be evidence of a release, so it is important to look for laboratory detections rather than only dangerous waste designation levelswent over the eventsand the -tirneline of the circumstances around" the release. oanette and I. were provided a small office to review documents and conduct interviews. Joel Williams of took down the records requests (a document request form?was provided, see attached). The following-records were provided forlreview on--siteOperating log book kept by the daily dispatcher for the SWOC facilities. (Provided as part of the operating record.) - I data sheet for-the box. - -- - We met Dean Nestor -of and discussed the sampling event and our quality assurance project plan .1 request 21. 20.12 fora copy of the sampling plan used by personnelito collect to WSCF on that date. Once it was 'clear what I was asking, Mr. Nester explained to methat there was a work order with -a a "technical that was their direction -for sarnplingthe liquid previously collected from the box. There was no sampling and analysis plan used for their -sample collection. I requested a copy of both the work order and technical procedure, and received these copies. . The technical 'procedure was authored by the contractor-, -and titled; Technical Procedure. Coritaineri Sampling,' Revision .-1, Change 6, published and effective 12/115/1-1; Note: I concluded that the first sample collection did not conform to the established technical procedure. The sample volume was collected in Nalgene bottles that are not appropriate for collecting and transporting samples for volatile organic' compounds. "Samples were collected by- operational staff and not one of the dedicated site-wide sampling teams normally called in for a sampling event. We 'returned_to'the small office and spent additional. tinie interviewing specific individuals for more information on the liquid release. The individuals we spoke to Were: - Paul T. Dean Nestor, Brian Oldfield, We questioned about the operating log book entries kept by the dispatchers. Entries are - made by the "on-duty dispatch." The Nuclear Chemical Operator (NCO) makes daily log entries. When USDOE - Central Waste Coinplex Expansion Area Report Date: September 27,- 2012 WA7089000 8967 Page 7 of 27 Inspection Date: March 7, 8, 14, 15, 2012 an incident happens and a problem is noted by a worker at one of the "facilities, a call is made to tile on- duty dispatcher' who notifies the chain of command. - - As supervisor of the RCTS and responsible for the radiological survey program, Brian Oldfield was interviewed about his knowledge of how the leak from the box was discovered. He explained" that radiation surveys (rad surveys) are performed on retrieved boxes at the retrieval site and when they are moved to CWC storage. Containers must be surveyed when they first arrive before being placed into a storage unit. The 1 "box arrived" at CWC on February 26, 2009. Shawna Terry, CWC NCO, would be able to get the results of this initial radiation survey for us, so we requested a copy. (This was the first request for the baseline rad survey on the box.) Theiniplication was that the leak was discoveredby RCTs conducting surveys, but Mr. Oldfield did not respond directly to my original question. . Note: Follow-up interviews on March 14 and 15, 2012 clarified that RCTs were the first to report the release. I This box is in done 14, and we were told this zonerneasures approximately 150' 150'. Zones are areas defined by and USDOE as allowed to have a certain range of rad,waste,' so that containers are segregated by their radioactivity. The original location of the box was the I burial ground. The box itself was an unused container repurposed from Purex and therefore still contained a label. The box was likely dragged off the bed of arailcar with a chain and back hoe into the trench where it was buried until retrieved. - - The SWITS sheet indicates it was labeled 12" fiom the PFP "plant," containing distillates with plutonium out of uranium rods. The residual liquids were separated into drums and as liquids went to tanks, located at the Hartford tank farm. The SWITS specific tracking number, 218-W-4C was for the - burial ground trench designation. Dave Gillis told us he ordered twice daily dangerous waste inspections "when the drip pans were placed under -the box, (February 9 according to Mortensen). Before the release was noted, Mr. Oldfield said conducted (rad) inspections of randomly selected boxes. Mr; Gillis added that dangerous waste inspections are weekly. At this point Dean Nester 'came in the room -to get clarification about the Ecology sampling planned for March oanette and I spoke with Jerry Yoke], chemist, by phone, a1lowi_ng- Mr. Nester to join in the call. After discussing our ideas for sanipling based on what we heard earlier on how the carboys of collected liquid were being managed, we were told by Mr. Nester that our collected samples would have to undergo rad screening and could not exceed a cumulative 10 nanocuries/gram as a worst case. This is because of a limit imposed on transporting andlor receiving mixed waste samples at the destination laboratory Ecology uses, Paragon. - - - During this discussion Mr. Nestor clarified that theifrst set of sample bottles were collected fiom liquid dripping off the box. There was still one of the two 1-liter Nalgene bottles kept fiorn this USDOE Central Waste Complex Expansion Area Report Date: September 27, 2012 WA7089000 8967 Page 8 of .27 . . Inspection Date: March 7, 8, l4, 15, 2012 first sample collection, now stored in the "first? 55-gallon drum container staged nearthe 231-Z-DR-11 box. The first Naigene bottle was already sent to WSCF where it was processed and analyzed. _(The results fiorn this sampling are found in the WSCF laboratory data package, and further evaluated in the attached memo from Jerry Yokel to Kerry Graber dated June 25, 2012.) - . . . In the CWC expansion area, Jeanette and I were escorted to Zone 14 to look' at container box ll. We observed the box from outside a roped area, behind a chain-_li_nk_ fence approximately twenty feet away.- Jeanette took photos. of thebox fiom, the east, looking at the west side of the box. A -nian-lift was deployed and facility. personnel were able. to take a photo of the top of the box forioanette. - . - Directly behind box 23 1-Z-DR-1 1.-is a second, smaller concrete box that appears to have good integrity, and is not leaking at this time. 7-This smaller box was retrieved" at the same time and fiom the same. general trench location. Stu Mortensen explained that the concrete lid is aboutsix inches thick and sits on a rubber gasket. He described a- portion of the metal fittings on the box being in a channel (like the shape of a on its side (J) where the wall ofvthe container sits in the middle of the This was difficult to observe objectively from the twenty feet setback required for the radiation CA boundary. It appeared that the wicking pads (that positioned in the joints of the box) deployed to collect liquid sat at the lip of this metal fitting. I was told.the-walls of the-box are-4 to 6 inches thick concrete. I was also told that design drawings are available for the box, and I requested a copy o_f these. (These drawings were rec_eiv'ed'Match 7,2012 ..-- - Frorn our-view looking west at the box, was told the ground is sloped to the south, toward the side. - where the drip pans were deployed. Stu explained that the drip pans were set under the box on February 10, which was as fast as he could get them constructed. According to Stu drip pans-needed to be fabricated, because they were not-keptin. stock at the CWC. -The delay represented about five working shifts and 3 calendar days befo_re the _drip_ pans could be available for use. . We looked at the newly constructed cover engineered for the 231-Z-DR 11 box; It was a cover made of plastic tarp material on a sturdy metal frame like a carport structure, weighted down by "ecology" blocks. This structure will-prov_ide_ cover only for the top of the box. The plans were in place to have - the cover lifted into place overnight. There was a possibility if this work was not completed by the morning itcould interfere with our plans to sample the following day. We were tentatively planning to start the next day back at CWC at 7:30 a.m. .- - - . Back in the CWC small office, we went over the request for documents and interviews. I asked Mr. . Williams forthe CA monitoring and inspection records. Mr. Williams said that he did not have permission fiom USDOE to provide it. Williams was asked-who was denying permission, and he declined to say. . - Mr. Williams left-the 'room at this point, so the discussion turned to Mr. We asked him who made the decision to construct a cover over the box. He thought it was a decision made as part of the CA response required for a radiological release. USDOE I Central Waste Complex Expansion Area Repoit Date: September 27, 2012 WA7089000 8967 Page 9 of 27 - Inspection Date: March 7, 8, 14, 15, 2012 We discussed preliminary plans for a path forward for the box with Mike Collins. The plan is eventually to move the box, keep it covered, and cleanup the impacted soil. Mr. Collins laid out the following options: I Plan Option 1, the preferred option, would be to transport the box to a_ nearby off--site treatment facility, Perrnafix. Mr. Collins indicated that the CWC project is just funded for on--going care and maintenance, and there are no funds currently for sending the box o'ff-site. - Plan Option 2 would be to move the two concrete boxes to a storage building (box 23 1 and the smaller, intact concrete box stored next to it). I restated my understanding of the mitigation plan -for '23 box 'by listing the. following tasks: Contain the leak Cover the box Evaluate the integrity of the box Move the box Clean up the impacted soils I confirmed with Mr. Collins that this was the USDOE plan so far, and he nodded yes. Mr. Collins said he was advised not to provide us the rad documents. This was the first denial of access to a portion of the operating record during the inspection. We left the CWC at approximately 4:20 pm. March 8, 2012 We provided the following list of additional documents to Joel Williams based on the previous day's inspection: Field log book entries for 2/12/12 and 2/16/12. Guideline/requirement for responding to a radiation threat (the 30 day limit) CA monitoring/inspection records (This was the third request for this record.) Fixative MSDS 's I Soil Cement - Hanford MSDS #03 5321 [Acrylic and polyvinyl' Acetate Polymer] Invisible Blue Hanford MSDS 1,2,3-Propanetricl, UV Blue and Deionized water] Chrornatographs/raw data package on USDOE's sample Detailed records on twice daily inspections Operating log for 2/6/12 RCRA Inspection logs notes and footnotes 0090 0000 We arrived for the Ecology sampling event at approximately 7:55 am. at CWC Building M0--720 and was provided a safety briefing for the field sampling period . USDOE Central Waste Complex" Expansion Area Report Date: September 27, 2012 8967 Page 10 of 27 Inspection Date: March 7, 3, 14, 15, 2012 The room was full of people, and we circulated our. own sign--in sheet to help us track the attendees. Jim Hogan, CI-IPRC, was present as the facilitysampling team supervisor. The task document, 2x--12-- 01430/4 WCN #3 was reviewed by the safety supervisor. The safety briefing lasted until 10:10 am. . with one short break in the middle. During the safetji briefing, the material -covered was pri.tnari1y- 'for the sample crew and radiological I technicians assigned to conduct the sampling activity. Inthe of the briefing, We spent about twenty minutes revising our sampling plan based on additional information about the collected, containerized liquid fiorn the 23l--_Z--DR--ll box. - - - - There were four 55--gallon drums that held carboys of the collected liquid inside and the drums were located near the box. The first drum (referred to as..Drum held the 1--liter Na] gene bottle from the first collection of liquid as well as additional carboys containing liquids collected once the Wicking was applied to the box. Drum #4 held the most recently collected material.' The source of the liquid in the carboys was both from the wicks directing it into them, and water in the drip pans _t_hat_collected flom precipitation because workers were told to just dump the pans into thevcarboys when the carboys are changed. The following sampling plan was agreed to: #45 I .. - 1 metals sample only if sufficient volume is present to split the sample 1 Drum#l: . Take entire 1 liter Nalgene bottle, and use one semi-VOA bottle Drums #1 and 0 Composite samples fiorn all carboys into split metals sample The drawing below is _fronji my field notebook 8, 2012. The drawing was copied fiom a whiteboard hand sketch by Mr; Nester and depicts Zone'14, the box, and the drums to be sampled. USDOE . Central Waste. Complex Expansion Area Report Date: September 27, 2012 WA7089000 8967 Page 11 cf27 Inspection Date: March 7, 8, 14, 15, 2012 We requested photos of the drums showing any labeling on them. It was explainedthat each drum has a "pin" number for tracking, usually with a barcode identifier. Field sample ID numbers will indicate the drum it came from according to our numbering convention, drum #1 through with #1 beingthe "oldest" drum, and #4 the most "recent." Drums are labeled as waste pending analysis with dates. The sample method is to "punc the carboy plugs into the container, insert plastic tubing in to the punched area of the carboy, and use a peristaltic pump to fill the sample bottles. Once the safety briefing was complete Mr. Hogan expressed concerns about being able to meetthe field sample schedule and get the samples shipped out the same day. The briefingadjourned at 10:10, and oanette and I continued our paperwork review and interviews in . the CWC office. Jerry Yokel brought our own sample bottles, and accompanied the sample crew out to the box to observe the sampling. _(The sample crew used their sample collection containers that contained a. preservative, whereas the unused Ecology containers for "metals" samples did not.1: E'-q%75mflWthe office Ms. Biebesheimer and I took a closer look at the CWC operating log book numbered 109." This book contains entries organized by date. Entries are entered by the dispatch on duty, and are noted by time of entry by the named person. we and aom USDOE . I Central Waste Complex Expansion Area Report Date: September 2'7, 2012 WA7089000 896'? Page 12 of 27 Inspection Date: March 7, 3, 14, 15, 2012 We spoke further with Brian Oldfield, and Joel Wi-lliarnsto get a .better understanding around the events of December 20, 2011 when rad surveys firstreported an elevation in radiation. We asked them to identify and make available the HPT (RCT) that conducted the survey on thatvdate, Shawna Terry and Rob Taylor were identified as the RCTs that conducted some of the radiological survey work. We were told that one of the RCTS was a union employee and entitled to have a union representative present. We were told that the front line supervisor also has to be present. The implication of .this was that we would not be able to speak to. anyone without prior arrangement, and itwill take time. - - - - I.renewed'n1y request for the information on the CA survey, and Mr. Williams .said we. need to email Cliff Clarke a request for records with the cited -authorities for requesting them. I was told by Richland Ecology staff that this requirement to provide a written request was something new, a step that has not been required before. (This was the second time requesting this portion, of the operating record during the inspectiondeterminedthe names of people to request to be.intervieW_ed aboutthe discovery of the leak fiom the box, and the decision to build a cover over the box. Mr. Oldfield identified that Mark Higby, Frank Hamata, and Stu Mortensen were the individuals to talk to about the decision to build a cover. Mr. told us that USDOE has directed that Ecology must provide a list of people to interview, and that USDOE will review the list and arrange for us to talk to them at a later date. We requested to speak with people in engineering operations, specifically Mike Jennings, Jay Botenus, radiological control. We did not provide a written list at this time due to my concerns that this was a new demand on Ecology compliance staff. - Note: Both the denial of access to CA reciordsas part of the operating record (the RCT technicians were the first to notice a stain fioin the box) and the limiting of access to key individuals to be interviewed obstructed our ability to gain a complete understanding of the natnre of the release and the problems with the box this date, March 8 2012. The consequence was that Ecology was delayed in our investigation necessitating a return visit. This denial of records appears to be coming fiom a difference of position between' (1) USDOE who maintains that Ecology does not have authority to regulate rad materials, and (2) Ecology's position that we have jurisdiction over mixed waste. .- We asked to _see the work package for the construction of the box cover, and to discuss the protocols around "flagging" a box for the abnormal container management program (ACMP). When asked, Mr. explained that the motivation for getting a cover built is that it is a requirement under the He 'clarified that it is also possible thebox is being placed into the ACMP because they are placing a cover over it. It could be either. (Thiskind of equivocation made it very difficult to discern how decisions were being made about proper management of the 231-Z-DR 11 box.) USDOE Central Waste Complex Expansion Area Report Date: September 27, 2012 8967' Page 13 of27 Inspection Date: March 7, 8, I4, 15, 2012 We left Mr. with a copy of the document request list for' March 8, 2012 because Mr. Williams had left the 'room. We were unable to interview 'any more of the requested individuals because they were not made available to us. We were o'ff--site at 12:43 pm. and returned to the NWP office to prepare for a short out--briefing with USDOE managers, managers, and attorneys for both parties. - Outbriefing John Price of Ecology's Nuclear and Mixed Waste Program did the introductions. I thanked everyone for their professional conduct-." I-explained that Ecology's position is that there was a release fiom the box. I expressed two major concerns, primarily over the lack of a timely response once the release was discovered. I also explained that Ecology was hampered in our investigation because of the denial of access to the documentation. -- Mr. Cliff Clarke asserted that Ecology was not entitled to the documentation we requested. He wanted to know under what legal authority we were requesting the information. I explained that the monitoring and survey information, specifically since the spill was discovered by radiation control technicians, was part of the operating record. As an operating TSD, the operating record must be made available to Ecology upon request. I said that the radiation monitoring information, or surveys, was an- indicator there was a release to - the environment. As a container with mixed waste, the radiation component is an integral part of the waste. The surveys area part of the operating record. As Mr. Clarke already: knew, Ecology has authority to regulate the management of mixed waste.' - - . Clarke responded that Ecology was tryinglto regulate radio-nuclides, and referenced a past lawsuit that clarified that Ecology did not have authority over radio-nuclides. I countered that I was clear, there has been a release of mixed waste to the envirornnent fiorn a mixed waste container. The USDOE is operating a TSD at the CWC, and the requirements placed on that facility by the dangerous waste regulations are clear. Not providing operating records upon request is a regulatory violation. I added that we were not provided access to the people involved in discovering the releases so that we could interview them, either. I shared my fiustration that Ecology was being obstructed in our attempts to investigate the incident, and that this was puzzling to me because USDOE and CI-IPRC called to report a release, and now we were being challenged on the assumption there was a release. Mr. Collins said that he made the decision to deny interviews because he was not on--site at the time and he didn't want people called in who didn't know the issue at hand. - I explained further that Ecology needs to understand USDOE's and criteria for making the decisions at CWC, and that the decisions made around management of the box are not being shared with us. Until March 7 we didn't know a cover was being built for the box, and we still did not have a clear. explanation as to why or under what criteria a cover is being placed. The implication is that Ecologyis 'Page 14 of27 USDOE I - Central Waste Complex Expansion Area Report Date: September 27, 2012 WA7089000 8967 - - Inspection Date: March 7, 8, 14, 15, 201.2 job as the regulator has been made more difficult in deterrnining what appropriate steps are being taken to comply with WAC when there are no adequate e_xplanation_s provided for what is being done at CWC about the box, and why. . - - Mr. Collins admitted he didn't understand before, in his earlier statements, what a release was under - WAC 173-303-145. He added that Stu Mortensen and Frank Hamata were not made available because he made the decision about access to interviews. Mr. Collins explained this was because he did not know the context of the interviews. Mr. Collins didn't want people called who didn't know or understand the issues associated with the box. After the outabriefing, Mr. Stu Mcrtensen was made available to be a number of individuals stayed for this including Mr. Collins. Mr. Mortensen was able to givehrnore of alchronololgry of events pertaining to the box, sun1m'arized' as follows: - I ,0 . -December 20, 201 1, rad survey staff discovered the radiation contamination while I conducting random surveys of containers. -A fixative was applied that dayto the contaminated-area on the outside of the box. - - - - The box was not rad surveyed agai1_1_u_zitil 20 l2. this rad survey, co'nta1ni1iation'ofradiat'ion was found on" the ground next to tlie,box. - 0 There was a meeting at CWC that took placevto determine whether the box should enter the ACMP process. Rad survey technicians applied fixative to the outside of the box. Fixative was also applied around the box. There were two types of fixative used, one that was readily visible, and 'a second type that is not visible. - - I I I The rad survey inspections were increased ("ramped up") by to take place daily. 0 February 6 or 7 is when the brown stain next to the box was noticed on the ground. -I On Tiebruary 9 CI-IPRC operations started discussing'structu'ra1 issues like cover and containment. - - - Mr. Collins interjected at this point that under the they are required to take "appropriate measures." The interview digressed with a discussion about lack of funding dollars for treatment, - storage, or disposal for this mixed waste, and barriers to getting covers bought and placed_ on allthe - uncovered mixed waste containers. - - - 3 Mr. Mortensen clarified that starting in 2009 there was an effort to obtain resources and planning was undertaken to get covers for the boxes. Employees were recruited; materials 'identified, and detailed measurements taken of the boxes in order to get specially designed tarps. He explained that the challenge is the -weather, and UV wears out the tarps. He said they are building a schedule to cover them all. I USDOE I. . Central Waste Complex Expansion Area Report Date: September 27, 2012 WA7089000 8967 Page 15 of 27 Inspection Date: March 7, 8, 14, 15, 2012 We briefly 'discussed improvements for-dangerous" waste inspections and an inspection checklist example that would better fit the situation at CWC. I said I would look around for a better example to send him. (Due to the complexity of the operations I am holding off on providing this at this time.) We asked Mr. Mortensen about engineering of the box, as the structure of the concrete box with metal projections does not lend itself to the specially constructed felt--lined tarps. He stated that Frank Harnata is the engineer who as part of the ACMP procedures got involved in designing a cover; This was about February 9. The reason cited for the cover was concern about precipitation and rainfall. March 9, 2012 was the deadline for getting the cover in place for the ACMP program which has a 30- day time requirement under the program. Ms. Biebesheimer asked if the '23 11 box had ever been a CA prior to December 20'. .Mr. Mortensen did_n't know because he started his new position in October of 2011. Mr. Collins said he didn't know. Ms. Biebesheimer made a formal request forthe irrforrnation on whether this box was ever a CA prior to December 20, 2011. 'Note': I According to a" review of CA surveysfrorn December,' 201 l, the box' 23 was posted This completed the interviews, and completed the first phase of the inspection. March 14, 2012 Arrangements were made tolconduct employee interviews on March 14 and 15, 2012. Kathy Conaway and I returned to the CWC at approximately 10 am. for this purpose. We met with Joel Williaznsand Brian Oldfield of Also present was Ray Swenson, attorney for Mike Collins for USDOE, and Paul "Tad" front While we waited for the first interview, Mr. "Collins described the construction of the 23 1box' by drawing a picture on the white board in the conference room. This picture showed in profile an inner metal liner like a tray, the concrete slabs that make up flie Wall and floor, the (previously called shaped brace that the-wall of the box sits in, and a metal plate like a sled, with one up-turned edge to make dragging the box in and out of the trench easier. All of this sits on a metal frame off the ground; what they call a lift platform. Ourfirst interviewof the day was with Patricia Carter, CWC Nuclear Chemical Operator (NCO). She is a technician assigned duties to occasionally perfonn dangerous waste inspections. With" her was Dave Cleavenger, who is Ms. Ca1ter's union representative and employee of Ms. Carter has ten years (off and on) in this position, with training, and refresher training every two years. Ms. Carter said she looks for leaks, cracks, anything that is not normal conditions. If she finds a problem, the procedure is to report it torthe on-duty supervisor, andfor the on>> USDOE I Central Waste Complex Expansion Area Report Date: September 27, 2012 WA7089000 8967 Page 16 of 27 Inspection Date: March 7, 8, 14, 15, 2012 - duty dispatch. Any necessary follow-up on problems would be included in pre- and post-job briefings. This would take place with the entire grouponthat shift-.' An open item-, or unsatisfactory condition, - would be put onto an open item list on their internet. Every week she would get a copy of the open item list before' going out for an inspection. Examplesof open items! would be: Scratches on the floor Jarnrned door' Tumbleweeds. Loose 'covers- R'opes not attached' Wood" debris Non-imminent items go on to the work 'packages and get scheduled for fixing. Ms. Carter did not recall finding anything coming out of the boxes on the particular date in'-question. She usually acts as dispatch, buthas been doing the "inspection for the 1 box,' in the morning and the afternoon. Once the leak was found with _th_i-s box Ms. Carter stat?d that the action switched to a_"recovery team" to deal withthe recovery of material. Members of the team were Russ Lowery, Rich Monlux, Kevin Wallis, Gene Rowlette, Dan Ridgley, and Bob Olsen. The next interview was with Michael Kiehn, who has 'worked atthe CWC for four years. Day_e:- Cleavenger sat in on this interview. Mr. Kiehn explained that in 2009 the various areas at CWC changed to zones, each zone has a different curie level limit. . - . -- Mr. Kiehn performs dangerous waste inspections ef the CWC, including the outdoor areas with containers, and has been going out to the inspections with Christine Kiehn conducting OJT for her. training. Someone else was the first to notice _the leak, Once the release was-reported and a established, it was not possible to get close for the required weekly DW inspection, forcing the CWC inspectors to use binoculars fo_r seeing up close. Normally they -get close enough to touch the box, although they do not as.a matter of practice. They would get close enough to notice weeping, dripping, or staining and identify l_abels. I Mr. Kiehn talked about the inspection che_cl;lis_ts. He told us Bob Maunisis the procedure writer and manager for Mr. Kiehn's group. Changes to the checklist itself are submitted to_Mr. Mannis from the NCO's. _The checklists they use are for the entire CWC, not just the outdoor expansion area where this box i_s stored. We learned through this .disc_uss_ion that the source of the checklist is fiom the dangerous Waste site-wide permit, and it not specific to any of the indivi'_du_al DWMUS at CWC where it is used." Both certified NCOs and managers conduct the_ training inspection procedures. Note: At my request Mr. Collins provided Technical Procedure Inspect_CWC Miscellaneous Buildings, Revision 8, Change 5, published 03/19/12, Effective 03/09/12, by The procedure referenced above is the current one used for conducting dan'g'erous waste inspections. It is not part of the current permit. USDOE Cernral Waste Complex Expansion Area Report Date: _September 27, 2012 Page 17 of 27 - Inspection Date: March 7, 8, 14, 15, 2012 Ms. Conaway asked if this training was dangerous waste, mixed waste, or hazardous substance training. This caused some confusion, and the only answer was that it was "procedures" training. Cindy Faith, also an NCO, was interviewed next. Ms. Conaway asked her about observations of big chunks of rust falling off the containers (this was identified in the notes section in the inspection checklists Ms. Conaway was reviewing.) Ms; Faith explained they receive training on rust what is a problem, what is normal. They are trained to observe problems with containers formally and with OJT: The reference of rust chunks would have been about a flake or layer of rust peeling off. Ms. Conaway asked Ms. Faith to describe how she does inspections. Ms. Faith described looking at boxes when they come in before they are covered, and' noting their conditions. Once covered, the cover takes care of most of the problems. Ms. Faith said she looks for anything new on the cover, around the container, or under the box if she can see. Boxes are not automatically covered when they arrive. Ms. Conaway asked about what she thought of the uncovered box we' are concerned about. Ms. Faith said someone else would have decided not to cover this box right' away. She was not involved. Ms. Faith clarified that about three years ago she conducted inspections routinely. Some of her job duties have changed. The safety" log book keeps track of container problems when they come over and when they are placed in CWC. Newly arrived boxes are expedited for action. Ms. Faith has had a two--'-year training certification, performance demonstration, a test, OHJT initially, and HAZWOPER training. Either 24 or 40 hour HAZWOPER training is provided: as part of a training plan. Nextwe interviewed Dwayne Bierman, supervisor of the NCO's. Mr. Bierman supervises Patricia Carter, Michael Kiehn, Christine Kiehn, and Cindy Faith. Mr. Bierman was asked about the open item' list.' He explained it is not something readily accessible. He agreed to obtain a copy for us to look at. Mr. Bierznan explained that a work package is developed to fix an open item. He stated that he will try to fix new items the week it is discovered, but if he can": fix it, it will be noted week to week until it is fixed. We asked Mr. Bierman about the box covers. He said they are made of heavy gauge plastic with a felt liner. Some will last for months, some only last days. The boxes are irregular, and no two are the same. He stated that he works on the campaign to move the boxes from the burial ground, and does radiological assays in order to move the boxes to the CWC facility. He explained that you cannot place boxes or boxes with covers in the CWC buildings because they are made of material that could be considered fuel, or "combustible" in a fire. When asked about where the restriction comes from, we were told by Mr. Bierman that it is an limit on what can be put into a building. stands for "fire hazard assessment." There are technical safety requirements (TSRS) along with fire prevention requirements what can go into the buildings. Plywood and -fiberglass (materials that some containers are constructed with) or the covers are considered combustible materials. . USDOE Central Waste Complex Expansion Area Report Date: September 27, 2012 - 8967 Page 13 of 27 Inspection Date: March 7, 8, 14, 15, 2012 He stated that is why some of the containers are outside. Mr. Bierinan said they are in the process of over packing boxes into metal boxes that can be moved into a building. The metal boxes can. be 9' 5? 8' 4' The range tends to be from 11. to 14 feet in size. _Once packed into metal boxes, they can be stored in the buildings." Mr. Bierrnan said the mo_tiVation for the assay campaign was to yerify contents of boxes so they could- be .shipped off-"site for treatment anddisposal. - PBRMAFIX Northwest (Perrnafix) is an off-site facility that receives containers from USDOE fortreatment and repackaging. --Permafix will return these treated andfor repackaged containers to -Hanford for storage or disposal. - - Mr. Collins added that cuties are 'measurements of. radiation. needs' to know the radiation amountto meet P_ermafix's waste acceptanceand permit requirements before shipping there. . Ms. Conaway asked Mr. Bierman about the open itemnumbers assigned forvarious problems noted on the inspection checklists. Mr. Bierman responded item numbers are assigned for a specific situation. The."09" in the number indicates the year. Once itis assigned an open item number, Mr. Bierrnan starts working to fix it. Itusually takes time toarrange for crews to do the -work. For example, the- - tumbleweed crew cannot work in all weather conditions. Mr. Bierman stated that Fixes that require additional expenditures are_e1evated_up:throt1gh Dave Gillis -and.Stu Mortensen. spare. box covers in inventory. There usually are some available. -Mr. Bierrnan said he took over the open itern list in October of 201-1. Ms. Conaway askedabout labeling. Mr. Mortensen explained-that CWC operations work on the -- - labeling and relabeling. The box in question is now labeled as dangerous waste PCB, and: . . ACMP. The DW and PCB label were already on prior to the box being placed in the ACMP. The box went into the ACMP on February 9, "2012. The rad was found in the soil on February 6. According to Mr. Mortensen, procedures require.-adding the ACMP .-label. when it enters the program. Mr. Bieirnan said he vras revarnping the open--item'list_ to shoxy the close cat, to be able to go back and. figure. out how an item was closed out. He stated zthatright now, items that get closed out just drop off the list and there is no' documentation kept on the history After a lunch break, we reconvened to speak with Brandon Hamilton, radiological control technician (RCT). Mr. Hamilton has worked as a RC.T for 10 years. He conducts the rad surveys, takes air samples, and perforrns weekly routine surveys at the CWC expansion area.- :.It is part of his job to do. the- surveys because it is a designated radiation area for waste storage. . .Mr. Collins interjected that some of the boxes have more rad in them others and they are segregated into zones by radiation.-level. Mr. Hamilton said "a higher energy" form of radiation, mostly garmna, escapes the boxes. Close in to the boxes you find alpha Within 1 -to 2 inches. He said that alpha is from the physical presence of the wasteUSDOE Central Waste Complex Expansion Area Report Date: September 27, 2012 8967 Page 19 of 27 Inspection Date: March 7, 8, 14, 15, 20l2 Mr. Hamilton said that either late November or early December 201 1, (not sure of dates exactly), he moved backefrom another Hanford site to CWC. For the rad surveys, RCTS choose boxes and locations to survey rad on the boxes randomly, so that while the surveys -are done weekly, the same box is not always going to be sampled in the routine survey. Mr.'Hamilton stated that he chose the 231-Z-DR -1'1 concrete box for sampling (according to the survey form we obtained later this was confirmed to be on December 20, 2011). He found alpha contamination on the box. He stopped and notified management.' He said this is when it was "up--posted" to a CA, with a boundary distance of about three feet around and out from the box. There were physical-access constraints because of the proximity of the box to other boxes next to it. Next, he checked for. soil contamination on the ground around the box. As he recalled, the contamination limit for a CA posting was greater than 20 for alpha, and greater than 100 for gamma. The box was sprayed with invisi-blue, a fixative for rad contamination. . Mr. Hamilton explained to us that "fixed" contamination is radiation that is not easily removable compared to "removable" contamination, radiation that can move on to the ground 'or elsewhere. This is what happened around the box in question. That day he took a rad sample from the side of the box, (a smear using a special material to wipe) and found fixed rad contamination. These samples indicated alpha and beta radiation. - He described the procedure in more detail. Approximately 100 square centimeters are scraped with a rough paper usedfor the purpose. This is scanned in the field with instrumentation, and sometimes tested at "the lab." The levels are checked against the radiological work permit (RWP) limits to see if they are exceeded. These were exceeded .on the box, and that was when he called management and posted the area as a CA by roping it off. Mr. Hamilton did not reenter the CA area after November 2011- (again, according to the actual CA survey records, he conducted the survey on December 20, 2011, and therefore according to his statement did not enter the CA area after this). He performed "direct" sampling of soils. He explained that this means holding the instrumentation about inch from the soil. Soil monitoring was started as soon as it was posted as a CA. Mr. Hamilton said that the soils didn't come up "hot" until late January 2012 or early February 2012. To Mr. Hamilton, this indicates "removable" contamination. He said it would be someone else who would have the exact dates. Ms. Conaway showed Mr. Hamilton a copy of the survey form, providing the date of February 6. This rad survey indicated that the contamination had gone outside the three~foot zone indicating movable rad contamination. Mr. Hamilton stated that he was the RCT that completed the survey form. According to Mr. Hamilton when something is wrong radiologically it goes into the Condition 'Reporting and Resolution System (CRRS), and is given to Mark Higby, radiological control. Notingithe condition of containers is routine, but not necessarily part of the training RCTs receive. A CRRS is only noted once, and is not repeated on the survey forms after a CRRS is submitted (unlike the DW inspection checklist.) Mr. Hamilton applied iixative on the day the contamination was detected__as a part of a routine response, and he did not reapply a fixative until the radiation contamination was found to have spread outside of USDOE . I Centra.l Waste Complex Expansion Area Report Date: September 27, 2012 . 8967 Page 20 of 27 Inspection Date: March 7, 8, 14, 15, 2012 - the posted CA boundary. He reiterated that the CA boundary was about three feet around. The December 20 survey document was number 100991'. Readings and smear results are indicated -at the bottom of page 1 of the CA report. About twelve or thirteen peopledo this typeof work. - Mr. Hamilton knows the containersfboxes are sample smeared prior to being placed in CWC. Containers cannot be moved to CWC -without being cleared as meeting allowable radiological standards. The next interview was with Mark I-Iigby and Rob Taylor together. We talked in general ajboiit the CRRS process, which is designed for an anomaly or problem. Bill Frisbee is the health physicist that generates the CRRS report. system is a tracking. system. The CRRS.report goes to the appropriate g'oup's management team to make a schedule for. fixing. a problern. Problems are referred back to CWC management (Dave Gillis and Stu Mortensen). - I Mark Higby confirmed that RCTS will, through experience and observation, target containers to do a rad survey on. They look for conditions that are most likely to be contaminated. Rob Taylor said that the containers smeared each day are listed on the rad s_urvey.form, and locations of the smears are shown on a map, also part of the survey form. If contamination is found the results are-annotated. Mr. Higby talked about a second CA involving a different box at the When the container 'was brought in they found contamination on the "platform." Contamination was mitigated on the trailer. The container was -wrapped with plastic, and then posted as The boundary of this areawas posted as areas "feet neat ma.' "still" 'preseh't'to'day." There surveys conducted around' the boundary, -and these surveys have indicated no contamination outsidethis boundary._. Because of the 20-foot posting, RCTs have stayed out- except when they have been in to . survey in support of workers getting to other boxes that are in close proximity. - Mr. Collins interjected that boxes from the trenches are assumed to be mixedwaste. Mr. Taylor said that when the surveys for inspections note "ureter infiltration" it is referring to the plastic. wrapping that has visible water 'condensate on the inside. Some notations are abouttorn wrappings, and it means containers. are exposed to the elementsMr. I-Iigby said that dosage rates noted on the forms' are different than contamination measurements. - Reference to 2000 00 emf is the threshold alpha levels. Mr. I-Iigby stated that the monitoring shows the levels associated with 231-Z-DR-11 are going down well below the-threshold, and he thinks this is because of the fixative that was applied to control the removable rad contamination. 'He further explained it takes very little plutonium contamination to exceed 2000, specifically what Mr. I-Iigb termed "plutonium americinm?' which is a form of radiation stored in this I The liquid coming off the rail along the bottom-of the box was dripping. They placed the wicking in order to channel it into the carboys. Mr. Taylor said they haven't seen any new_drip.locations on the box since placing the wicking on the 'rail. He noted that reference to the ""iso-platform" "is the name of the metal yellow beams the box sits on to keep it off the ground so as to facilitate transport of the box when needed. . - - - USDOE Central Waste Complex Expansion Area Report Date: September 27, 20l2 WA7089000 8967 Page 2} of 27 - Inspection Date: March 7, 8, 14, I5, 2012 A Mr. Taylor went on to explain that the bottles or carboys are changed by operations staff. He doesn't believe the liquid is coming from inside the box, so in his opinion putting a cover over it makes sense. They believe it is fioin rain contacting the outside of the box. In regard to a "leakpath" there is no air pathway so far, and this has been confirmed by When asked about the possible sources of the leak, Mark Higby said it could be cracks and crevices from the box, since the box has been buried in the ground. A pinhole-in a container could" release radioactivity. He explained that a leak path can be a physical path and a very small hole in something, (for example a microg1'am hole) could leak radiation, particularly a form of radiation like 'fplutonium arnericiurn," a very high 'Curie rad that emits both alpha and beta radiation. Mr. Taylor agreed with this assertion. - - Mr. Higby explained that when a box arrives at CWC, there are different surveys perfornied. For the 231-2 box, a removable' contamination survey was done when the box came to CWC. It is important to check for removable contamination when boxes arrive at CWC. By contrast, a direct contamination survey (survey of "fixed," or not easily removable, contamination) of the box would not have been done. Mr. Higby said that a routine survey of containers in storage at CWC also includes the additional surveying for direct contamination. Exceeding 20' 00 cm2 would be the trigger to take a closer look. Mr. Taylor said that when they look at structural integrity they look for rusting or cracks in the concrete. I askedwere staff complaining about the condition of the box? Mr. Taylor said no, not until the survey readings fiorn December, 2011. Mr. Higby said now there will be attention to the concrete boxes. Mr. Taylor said photos on-the survey forms show the location markings on a box where the direct samples' are taken. The attached page on the survey form has the correlated sample results fiom each- direct 'sample location. - Ms. Conaway requested that Mr. Collins provide the number of the box in the other CA area. This box is in the southeast corner. This task was referred to Mr. Williams. (Note: We received the number by email as A #751 ODMA-06.) Mr. Taylor ended with explaining he has been working at CWC three years in his current job. Before that, he has worked ten years as a rad technician, moving to another location and then back here. We finished the day by requesting interviews the following day with Melvin Lakes, Christina Kiehn, Keith Yates", Dick Steen, and Pete Saiz. Because of high winds we did not. look at the box. We left the site about 3:30 pm. Ma1'ch 15, 2012 USDOE Central Waste Complex Expansion Area Report Date: Septeniber 27, 2012, I WA7089000 8967 Page 22 of 27 - - 'inspection Date: March 7, 8, 14, I5, 2012 Ms. Conaway and I returned to the CWC at 12:5(l on March 15 to resume the interviews. We were met by Mike Collins, Joel Williams, _Ray Swensen and Paul - - Dick Steen from a subcontractor for joined us. Mr. Steen works in engineering-solid waste operations at the CWC and the low level burial grounds. 'He has been in this engineering group since 2003. 'He is a design- authority for CWC. . We asked Mr. Steen about "design authority" and he explainedthis is a qualification under design safety packages and-radiation safety program. Mr. Steen explained thatthe cover now over the 23 1- box is a temporary cover. It be replaced with a metal structure similar to a metal carport. Parts for the replacement cover are now at CWC, it just needs assembly. Mr.- Steen- said the first part of February-2012, the CWC operations group requested help. with _a weather cover. USDOE has a rad requirement for safety, and so the cover design has to. comply with these . requirements. Dangerous Waste concerns. associated with -the boxwere not part of the cover-design scoping. Additionally, he provided construction direction to. the sheet_ metal shop for the drip pansthat were placed around thebox. Drip pans-were constructed of carbon steel sheet-rnetal- . -- . - When asked about the structural integrity of boxes in the expansion area, Mr. Steen agreed that the structural integity of the boxes would have to be eva1uated,.starting with the drawings. He has looked. atsaucairaii integrity of boires before, rusuaririy w'o6'd' sexes'; tests are perforrned. cross-'sis an is evaluated under the design authority for 'containers. .This is referred to as standard, a DOT standard. 'The box in question was evaluated by the expert who does this type of evaluation against the standard. Box 231-2-DR-11 was the last in a -line of woo_d_en.boxes in the trench found in early. 2009. .- - "Woody" John Woodberry did this assessment, but he is not on staff now. We requested the name of the person who does design authority now. We were provideduthe name Scott Edward of -an engineerMelvin Lakes was the next to be interviewed. Mr. Lakes is responsible for designating dangerous waste, and was responsible for designating the liquid coming fiorn the box. Mr. Lakes has 15 years of experience, and is re-qualified every year with training. Training consists of a class, OJT, and a sign off I by a manager. Mr. Lakes is an contractor assigned to perform dangerous waste designation for Mr. Lakes made anurnber of assurnptionson the dangerous waste designation for-the liquid collected from 1. He started by looking at the AK package for the box; numb er AK 07-01. Mr. Lakes was aware that the waste designation for the contents of the box included a number of listed wastes. Instead of applying the listing with -the assumption that the liquid was a listed dangerous- waste derived horn a listed dangerous waste, Mr. Lakes was requested to take.a look at the WSCF data package for the collected liquid from the box by Dean Nester and was directed to use this information instead. He received and reviewed the data fionl the WSCF lab analysis and used this information to determine the liquid from the box was not a dangerous waste because there were no detections of the listed constituents, and no exceedances of the TCLP thresholds. USDOE Central Waste Complex Expansion Area Report Date: September 27, 2012 WA7089000 8967 Page 23 of 27 Inspection Date: March 7, 8, 14, 15, 2012 Note: Ecology made a determination that a release fiorn box has occurred. USDOE was informed of this determination on March 8, 2012, and in writing in the Immediate Action letter dated March 22, 2012. Liquids coming out of the box, or coming in contact with releases from the box, must-' _be considered listed dangerous waste because of the designation-assigned to the box by USDOB from the 231-Z AK package. - Mr. Lakes explained that the AK packages are put together by a group of technical staff that conduct extensive research into historical activities. This effort takes almost six months of research to figure out what could be in a waste stream. I asked Mr. Lakes if the 23 package and the SWITS description are accurate, why is the box so heavy? He told me that the lid alone weighs about-seven tons. _The box structure itself probably weighs thirty tons. Mr. Collins thinks up to 60,000 pounds may bethe weight of the concrete box alone which does not include the weight of the waste inside the box. The next person we interyiewed was Christine Kiehn with Dave Cleavenger present. Ms. Kiehn has been employed at Hanford since 2004, but she has only been responsible for DW inspections over the last two weeks" in a training capacity. She has been perfor'n1ing'D.W inspections of the 1 box over the last two weeks. Ms. Kiehn explained she has to look for the container labeling and overall condition of container covers. She looksfor the ID number on the container as the number one priority. If the box is labeled as an ACMP, she stated that it will be written with a marker pen on the container. Sometimes sticky labels. come off containers; If the label is missing, she would not know whether a container should have waste codes and/or specific labels. Note:' The 231-2-DR-1 1 box had a sticker label with "Ac1\n" on it. Mr. Cleavenger interjected and explained that there is a yearly container inventory conducted, but it looks at quantity only. There is an effort to match up ID-numbers and labeling, and Mr. said CWC takes a selected sampling of containers at a time, like up to sixty, and checks against the records for the existence of proper labels'. This is a process; last time it was done it took about ten hours. Ms. Kiehn continued and said she was not expecting or looking for leaks or anything dripping onto the ground, especially "a box that has been in the ground (previous trench) for thirty years". She asked rhetorically, "What could still be liquid in a box that old?" Ms. Kiehn said she had dealt with the unexpected presence of liquids in containers stored in the CWC buildings. She stated that even an overpacked drum has been found in containers deteriorating from the presence of liquids. We thanked Ms. Kiehn for her time, and this completed our interview with her. Mr. 'said that temporary pads were deployed on the ground around the box maybe February (there was a photo that showed a kind of temporary plastic liner under the box.) USD OE . Ceiitral Waste Complex Expansion Area Report Date: September 27, 2012 8967 Page 24 of 27 - Inspection Date: March 7, 3, 14, 15, 2012 We talked with Mr. Mr. Collins, Mr. Swanson, and Mr. Williams_ about improving the dangerous waste inspections, possibly using the barcodes (like the Boeing facility) to help identify which DW labels are required on each'D_W and mixed waste container. Containers needto have the - . required labels and be verified they. are correct. Ms. Conaway said it is required under the d_ang'erous I waste rules-. Mr. acknowledged the require1nent,.but noted it is currently a time consuming - task. Ms. Ccnaway re1_1ewed_he:_r request for documented proof of the permit authorization status of the CWC expansion area as an approved DWMU. 'S_peeifica11_y, "she asked Mike about the 09,1 and retrieval of ugastefrom the"Hanfo'rd burial grounds/trenches. She wanted to knowif the . milestone had directionsfor dangerous v(raste'c'ontainer' rnanageinent'requireni_ents once the containers were retrieved from a trench. Mr. Collins said that M-091 does not say rnuch about the boxes (containers) once retrieved and stored elsewhere. uncertified waste is now held for storage at CWC. Note: must b'e"certif1'ed"as appropriate to go to the WIPP. The treated low level mixed' waste from PerrnaFix is returned to Hartford for disposal at either the ERDF, a CERCLA landfill, or to trenches 31 or 34 at the burial grounds. Trench.3l and 34, dangerous waste management units are lined, but do not have unit-specific permit e_ondition's or requirements in Permit Rev _8c. The contractor that was hiI_ed't_o_ certify containers to go" to is no longer at the Hanford facility.' Lacking the capability" to obtain c'ertifications,: a requirement for waste acceptance at WTPP, percent would need to be dealt with at _I-Ianford. What followed "Was a discussion about the various challenges Waste at the burial grounds or" above" ground location. Mr. Collins said they have 'concerns that Pennafix isn'-t 'set up-to deal 'With this '1 heavy of a box like the 231-4Z box. USDOE is looking into cn--site' capability to deal with it. Mr. Collins estimates seventy percent ofthe boxes in the CWC expansion area would-be acceptable to go to - Pennaflx or the Waste Isolation Pilot Project (WIPP) for treatment and disposal.- The remaining thirty We asked What kinds of inspections -are required at CWC. Mr. Karschina told us that there are weekly. dangerous waste inspections, ACMP inspections, and and quarterly safety and prevention equipment inspections for emergency response capability, The weekly inspection schedule is a_ result of an interim states permit. _Ms. Conaway corrected Mr. Karschina, explaining the facility may be operating to interim status standards and does not have a final or interim status permit. Mr. Karschina agreed. Ms. Conaway asked when the CWC expansion area was authorized for dangerous waste storage, and who authorized it. Mr. Karschina told us that the entire expansion area is within, the CWC Part A'pe_r1nit boundary like the other waste management units such as WRAP and T-Plant Complex (SWOC). Mr. Karschina and Joel Williams added that there were discussions about the CWC expansion area with Eric Van Mason, an inspector and CWC permit-lead for Eeology, (no longer employed with the agency.) We were told that the CWC is in the Part permit application of the current Rev 9 draft permit, and also incorporated into the current permit, Revision SC (Rev 80). . - Note: The Part A submitted as a part of the Revision 9 (Rev 9) permit application currently under public notice for CWC does not include the expansion area where the boxes are stored. Previously submitted Part A's are also lacking any description of the expansion area. USDOE Central Waste Complex Expansion Area Report Date: Septen1'ber'27, 2012- WA7089000 8967 Page 25 of27 - Inspection Date: March 7, 8, 14, 15, 2012 The draft permit Rev 9, Addendum H, Inspections, has no substantive changes to the dangerous waste inspection schedule currently being used at CWC. To conduct dangerous waste inspections, the facility follows SW040043, a procedure that includes a DW inspection checklist. This is procedure and checklist is not part of the current Rev 8C permit. The procedure is not referenced by the Rev 9 Part permit application. USDOE's position is that facility procedures need to he flexible, and therefore should not be in the permit. Mr. said that ACMP containers sometimes overlap with the discrepant container 'management process (DCMP) containers. An overlap may depend on a particular problem, for example, if corrosion of a container is the issue it may also be in the ACMP. For mitigation of a rad issue, the procedure is to apply fixative and cover the container. The time clock for these actions would be ten days or thiity days. The original work package for the box (begun. on February 6) required a rad survey and application of fixative. Once this was completed, additional tasks were added to the original work package. - Mr. thought in order to move forward with solving the problems associated with this box, they need to figure out how to move it without further contamination and evaluate the b0x's structural integrity _of the "box. It was his thought that they would evaluate it as only a rad issue, but he conceded it is important to get the DW analytical data from the lab samples back. Joel Williams interjected to inform us that the WSCF lab is sending the unused sample volume back to the CWC facility. For the out--hrief of the day I provided an overview of the immediate action letter content. Present for the out-briefwas Joel Williams, Mike Collins, Ray Swensen, and Paul "Tad" I commended them on the people we interviewed expressing that they were knowledgeable, helpful and professional. . The following is a list of my initial feedback on the inspection: 6 Emphasis is on radiation associated with containers and not dangerous waste compliance, they were slow to notify Ecology, and they were slow to mitigate the release by getting the trays in place. 0 CWC is not operationally prepared to respond to dangerous waste problems that come from containers stored outside like the CWC expansion area storage. Th'e CWC DWMU outside expansion area is not adequately designed (gravel floor, no roofl lack of container covers, no secondary containment, open areas) to properly store the boxes. 9 There. are concerns with the weekly dangerous waste inspections, their quality, meeting WAC 173-303, attention to proper labeling, and ability to detect releases. 9 DW contents of containers (like the box) are not verified and characterized at CWC or the burial ground or another Hanford DWMU therefore, CWC cannot rely on the hazardous debris-only assumption. . USDOE Report Date: September 27, 2012- Page 26 of 27 Central Waste Complex Expansion Area WA7089000 8967 Inspection Date: March 7, 8, 14, 15, 2012 0 During the time spent conducting the inspection and the interviews, nothing was said or provided that proves a release of hazardous constituent-s has not occurred. The initial determination that a hazardous release occurred stands of this date.: . - 0 An immediate action-letter will be issued. (Signed and delivered March 22, 2012.) 0 The letter will be followed by an inspection report that will include recommendations for further action. Ecology will decide the next steps after that. i We left the site. at approxirnately 3 :30 the' afternoon. Summary 'of Facts Box'Release The following summary of facts was established from review of the paperwork, interviews and sample data: - Hartford 6 Control,Technicians on this date. - The 231-Z-DR-11 mixed-waste; container is identified as containing federallyilisted dangerfous - waste biphenyls The ll mixed-waste container was identified as a Contamination Area (CA) on -. December 20, 2011; weekly radiation surveys '_on'the' box were established_in_ accordance with the During weekly radiation surveys of the' aforementioned liquids were "found leaking from 231- box on February 6, 2012. Brovvn stains on the ground were observed by Radiation On February 7, 2012, USDOE informed Ecology of liquids coming from a box, the box. This was done bya phone call to Nuclear Waste Program compliance inspector Ms.'Kath'y'Coi1away.' - 7 Drip pans were placed around the edges and under the 1 mixed-vvaste box on February 1-0, 2012. Plastic carboy containerswere placed on their sides in the drip pans under the direction of Operations managing the CWC outdoor-expansion' area. A wicking-type material was inserted in the metal joints of the 231-Z-DR-1 1 box to control the direction of the flow of liquid to the carboy containers and the drip pans. - USDOE collected discolored liquid samples coming from _tl1e 231-Z--DR-1 1 rr1ixed--waste box. According to the Waste Sampling Characterization Facility (WSCF) laboratory data package, samples were taken on February 12 and 16," 2012. These samples were analyzed by the WSCF laboratory located on the Hartford 'site. (The laboratory report from this sampling was received the afternoon of March 7.) Sample analysis reported measureable levels of cadmium, chromium, lead, USDOE I I Central Waste Complex Expansion Area Report Date: September 27, 2012 8967 Page 27 of 27 Inspection Date: March 7, 14, 15, 201?. mercury, and PCBs. (For a more detailed analysis of this data refer to Memo from Jerry Yokel to- Kerry Graber, dated June 25, 2012, attached.) USDOE and are unable to substantiate the claim that the rnixed-waste is not leaking, and are unable to support the claim that the collected liquid is only rainwater and/or snow melt. USDOE and are unable to substantiate the assertion that elevated radiation levels are not associated with contents escaping from mixed-waste container 1. End of report. kag i Technical Procedure SW--O40-043 Inspect CWC Miscellaneous Buildings (Reizision 8, Change 5, dated 03/09/12, was provided by Mr. Collins at my request for inspection procedures for CWC. This document describes the inspection program and includes a copy of the checkiist used for these inspections. The reference by Ms. Carter to inspecting buildings as well as the graveled storage areas is consistent with this procedure. This seems contradictory to eariier statements however the conflict may be due to not getting a clear understanding of the status of CWC as a regulated unit (DWMU). It is this process that Ecology would like to see accelerated. KL neceivep JUL 1 1 2013 June 28, 2013 mfg" err tic rriam. TO: ?/valarie Peery Records Manager Nuclear Waste Program FROM: Kerry Graber Hazardous Waste Inspector Southwest Regional Office of the Hazardous Waste Program SUBJECT: Amendment to inspection Report Dated March 7, 8, 14, 15, 2012 Department of Energy Hanford Facility, Central Waste Complex," Richland, Washington RCRA ID WA7890008967 The purpose of this memo is to transmit the attached amendment to the above--referenced inspection report for the administrative record. The amendment contains the citation of violations of the dangerous waste regulations as determined by anextended process of evaiuation and discussion with US Department of Energy and its contractor, CH PRC. it is my understanding that the remedy for these violations is under evaluation by the Nucleargwaste Program at this time. Please either attach this amendment directly to the inspection report with this memo, or insert a cross- reference in the inspection report that describes the location of this memo so that the compliance record is complete. This amendment contains additional information not specified in the existing inspection report. Please be sure to foliow your normal procedures for updating any public disclosure requests (on this topic) that took place prior to this date, letting requestors know there has been an amendment of a report that was previously disclosed. Thanks. kag cc: John Level John Price Kathy Conaway Joanette Biebesheimer Attachment: Compliance Problems List (1) - Each in two parts: citation from the lregunllatilons I USDOE and did not notify Ecology of the release until February 7, 245 houre health and the environment diking to prevent contamination of state waters, shutting of open valves). Amendment to March, 2012 CWC inspection Report Kerry A. Graber, Hazardous Waste inspector July 3, 2013 0' Personnel at the CWC'are responsible for takingiimmediate actions to mitigate spills . or discharges of dangerousvvaste or hazardous substances at CWC. in For the release from box 23 1, when liquid was observed on February 6 the CWC did not have spill containment pans available immediately for mitigating the release. - Spill containment pans were not deployed for three days after the spill was identified, from February 6, 2012 until February 9, 2012 at box 1. WAC and 170(1)(a) Failure to designate Waste according to required procedures. A person is responsible for designating their waste as dangerous Waste or extremely hazardous Waste in accordan_ce_With the process provided in the dangerous Waste regulations. 0 I As regulated generators of dangerous waste, USDOE and are required to designate its waste in accordance with WAC 173-303-070 and -170. - USDOE and failed to designate the waste in the drums holding liquids collected from box l. 0 Wastes derived from listed waste must be designated with .the associated listed waste codes. . (Ci) Test procedures. Failure to obtain samples in accordance with procedures designed to yield representative analytical results of an acceptable quality required by the analytical methods. Ecology will consider a sample to bea representative sample when it is obtained using any of the applicable sampling methods described in WAC 173-303-110(2) Representative samples. Quality control procedures specified by the testing method or an approved equivalent method must I be followed for the analytical result to be considered valid for designation and test procedures. Compliance with representative samples and analytical test procedures is required when testing is utilized to comply with WAC 0 Samples obtained of the release from box 23l--Z--DR--ll in February 2012 by operations staff at CWC were placed in a Nalgene bottle and not the appropriate sample bottles for collecting representative sampling as specified by the methods for volatile organic compounds. -0 CWC operations staff collected samples on their own initiative (initial sample collection), and then collected split samples (later sample collection) when Ecology requested samples. . 0 Operations staff collecting the initial samples did not follow established test methods, protocols, analytical and quality control procedures, or the required sample collection method. Amendment to Match, 2012 CWC Ins Kerry A. Graber, Hazardous Waste Inspector July 3, 2013 operator must d, stored or disposed. gerous Waste knowledge to manage box 231-Z-- reduced the appropriate storage. threat to human health. 0 inspections at the malfunction, deterioration and discharges. The deterioration of box 231-Z-- -11 at resulted a release of angerous waste constituents the envtronme 7. WAC Ins areas subject to spills. Th of or must conduct these inspections often Jfy problems In time to correct them before they harm human he or the environment. Areas sub 0 USDOE and RC were only conduct' on a Weekly basis. Based on USDOE's -and containers from the Waste rettieval proj been performing dai ly dangerous waste 10. 2 WAC 173--so3--32o(3) Inspections. Amendment to March, 2012 CWC inspection Report Kerry A. Graber, Hazardous Waste inspector July 3, 2013 0 The expansion area does not have a containment system capable of preventing liquids from entering underlying soils. In addition, box 23l--Z--DR-ll is aging (at least 30 years old) and is not intended for long term outdoor storage. Failure to immediately remedy problems revealed during the inspection of box 231-Z--DR--11. An owner or operator must remedy any problems revealed by inspections and on a schedule which prevents hazards to the public (human) health and the environment. Where a hazard is imminent or has already occurred, remedial action must be taken immediately. I CWC personnel failed to timely respond and take' remedial action in response to the release from box 231--Z--DR-1 1. 0 Given the observation of elevated radiation levels on December 20, 2011, and the observation of visible dripping liquid to the ground from box 23 l--Z--DR--ll on February 6, 2012, remedial actions such as providing secondary containment should have occurred without delay. WAC Preparedness and prevention. Facilities must be designed, constructed, maintained and operated to minimize the possibility of fire, explosion, or any unplanned sudden or release of dangerous Waste or dangerous waste constituents to air, soil, or surface or ground Water which could threaten the pubic (human) health or the environment. 0 The CWC outdoor expansion area has no secondary containment, roof cover, or adequate container covers. 0 The CWC did not have spill containment pans (as preventative equipment that could mitigate spills and releases) available immediately for the leak that was observed coming from box lon February 6, 2012. 0 . Spill containment pans were not deployed until February 9, 2012, at box 1. WAC Facility recordkeeping. Failure to provide operating records upon request from Ecology. The owner or operator of a facility must keep a . written operating record at their facility. 0' On [dates February 7, 8, and 21, April 19, and May 23, 2012], Ecology requested access to CWC operating records. I - USDOE denied Ecology access to CWC operating records on those dates. 0 The denial of access to records caused Ecology delays in completing the release investigation. 11. 12. 13. 14. A WAC 173-303-630(2) Condition of containers. Amendment to March, 2012 CWC Inspection Report Kerry A. Graber, Hazardous Waste Inspector July 3, 2013 Failure 'to maintain containers in good condition. If a container holding dangerous waste is not in good condition or if it begins to leak, the owner or operator must transfer the dangerous waste from the container to a container that is in good condition or manage the waste in some other way that complies with the requirements of chapter 173-303 WAC. 0 Box is constructed of a steel frame with concrete walls, floor, and lid. The box shows signs of severe rust and deterioration. I DR--11 and the leak, CWC staff failed to transfer the waste in that box to a container in 'good condition or otherwise manage the container in compliance with the requirements of WAC 173-3 WAC 173-303-630(3) Identification of containers. Failure to adequately label containers with the major risk, and/or to maintain identification of containers. Containers must be labeled in a manner which adequately identifies the major risk(s) associated with the contents of the containers for employees, emergency response personnel, and "the public; the owner or operator must ensure that labels are not obscured, removed, or otherwise unreadable in the course of "inspection required under WAC 173-303-320. - Box was not labeled properly so that a facility. operator conducting the I The drums containing leaked waste from box 231-Z--DR--11 should have been labeled with the waste codes from the originating box as waste derived from listed waste. WAC Management of containers. Failure to properly store box A container holding dangerous waste must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak. I Box is stored in the open subject to extreme weather conditions and without cover or containment. . 0 The box has 'deteriorated to the point of leaking to the environment. WAC Containment. Failure to provide an adequate secondary containment system. The owner or operator must have a containment system that is capable of collecting and holding spills and leaks. 5! Amendment to March, 2012 CWC inspection Report Kerry A. Graber, Hazardous Waste Inspector July 3, 2013 0 Box was transferred from the low level burial grounds and stored at the CWC outdoor expansion area in 2009 according to USDOE records. I The CWC outdoor expansion area is a graveled surface area that does not have a secondary containment system. In addition, the CWC expansion area did 'not have a system to protect containers from the elements by means of a building or other protective covering. 0 Box 23l--Z-DR--ll had not been continued to contain no free liquids be free of liquids. I The CWC has more than one expansion area that does not have secondary containment. - OTHER CONIPLAINCE PROBLEMS 1. The criteria currently followed by USDOE and at CWC for notification of spills, releases, and emergency incidents does not function to maintain compliance with the requirements in WAC 173-3034-45, --350-- and -360. The contingency plan for CWC must be updated to include criteria that results in compliance with the requirements. 2. Spill pans and other preventative equipment must be in stock and able to be deployed when a spill or release occurs at the CWC, pursuant understanding that CWC has procured supplies and equipment to upgrade the available equipment . 3. The Waste Analysis Plan must be revised to meet the requirements of full characterization pursuant to WAC 173-303-300, for all wastes received at CWC so that waste management practices match the risk presented by the contents of -containers. 4. The discrepant container management system must be revised so that problems with the condition of containers, or problems with the content of containers, are more aggressively acted upon and corrected in a timely manner, pursuant to the requirements of WAC 173 -3 03-630 and WAC 173 -3 03-3 20. The inspection schedule and inspection practices must be improved so that areas asubj ect to spills, storage units that are storing waste containers not confirmed to be free of liquids, are inspected daily, and observations of container deterioration are noted and - remedied on an appropriate response schedule. 5. The graveled expansion areas holding waste from the M-91 waste retrieval project do not meet the required secondary containment standards for sto_rage of containers with free liquids or oontainerized liquids. Some of these containers retrievedfrorn burial trenches are known to contain, and have been proven to -contain, both free liquids and containerized liquids. Ecology has determined this from historical records as well as records review at Permafix Northwest, an off~site TSD facility receiving and opening these containers for treatment. The CWC graveled 6 Amendment to March, 2012 CWC Inspection Report Kerry A. Graber, Hazardous Waste inspector July 3, 2013 expansion areas are not exempt from the secondary containment requirements under WAC 173- as has been claimed by USDQE and 6. CWC personnel do not appear to have the required training to sample containers or spills and releasesfrom containers. The correct bottle and method for sample collection is basic knowledge that should be available to personnel at CWC so that they know what to do if they are called upon to sample. Procedures and protocols for correctly collecting samples must be part of an adequate training plan for CWC. The requirements of WAC 173-303-110 are requirements for every dangerous waste sampling event. 7. It is my understanding that the CWC does not have a dedicated area for treatment in containers, but that treatment activity is a capability that USDOE and maintains they must have to deal with certain containers. CWC must have an appropriately' designed area to conduct treatment in containers that is designed to handle spills,'releases, and unexpected reactions to treatment processes. I am concerned that the CWC is not designed or prepared for treatment in containers, and the personnel on the site are not adequately trained to safely treat wastes at this facility. CWC should not conduct treatment without first addressing these issues. 8. The CWC does not have an accurate Part A with clear descriptions and explanations of each regulated unit with the operational boundaries of the CWC. A revised Part A that follows the requirements of WAC 173-3 03-806 and the form instructions for providing complete information must be submitted as soon as possible. Future expansions or additions of new units must follow the permit modification process under WAC 173-303-830 because the entire Hanford Facility is under a final status permit. 9. It is unacceptable to withhold information from Ecology that is part of the operating record and is required to be available on site during inspections by the__Dangerous Waste Regulations. USDOE and must remedy this problem so that future inspections are not hindered by records that are either unavailable because they are not at the site,'or withheld because personnel are uncertain about operating record requirements. This is both a training issue and an internal management issue that must be corrected. End of March, 2012 CWC inspection report amendment. KAG