Text

Final Rept of Environ Assessment of Proposed Site Stabilization at Amax,Inc,Parkersburg,Wv Site
	ML20236S357
Person / Time
Site:	07000036
Issue date:	11/17/1981
From:	Belanger R, James Hammelman, Roland R; SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	; NRC
Shared Package
ML20236Q363	List: IA-98-110, Requests Assistance in Obtaining Info Requested by C Paperiello Re Costs & FTE Spent on Close Out of Each Site Decommissioning Mgt Plan Site & Two Reactors Decommissioned by Division of Waste Management; ML20236R389; ML20236S357; ML20236S366; ML20236S374; ML20236S382; ML20236S391; ML20236S497;
References
	CON-NRC-02-80-035, CON-NRC-2-80-35, FOIA-98-110 SAI-82-549-WA, NUDOCS 9807240278
	Download: ML20236S357 (92)
	v • d • e

{{#Wiki_filter:___ I N4e: G w 93 i r t t' s ENVIRONMENTAL ASSESSMENT OF THE . PROPOSED SITE STABILIZATION ?.. ,. :~ - AT AMAX INC.'s F2 PARKERSBURG, WEST VIRGINIA SITE ~ ~ u,.;. . FINAL REPORT ] w SAI Report No. SAI-82-549-WA November 17, 1981 James Hamelman Raymond Roland Richard Belanger Phuoc Le Prepared for: U.S.' Nuclear Regulatory Comission Contract No. BOA NRC-02-80-035 Task 0009 Docket No. 70-36 i r t a E q. Post Office Box 1303,1710 Goodridge Drive, McLean, Virginia 22102, (703) 821-4300 )$ r; b 9807240278 980714 I PDR FOIA ( GARDNER98-110 PDR

4* a Summary Amax Inc. has made an application to the U. S. NRC for a license to stabilize its Parkersburg West Virginia site, thereby reducing the risk to the. public from the contaminated soils and pyrophoric materials which exist on the formerly used site. An environmental assessment of the proposed action has been prepared using some synthesized guidelines for evaluating the acceptability of the environmental impac t. Synthesized guidelines were necessary because there is only a limited number of directly applicable NRC or EPA requirements. The guidelines were synthesized from proposed or actual NRC and EPA regulations applicable to similar problems such as low-level waste management, mill tailing stabilization, and hazardous wast'e management. The proposed action involves the consolidation of contaminated soils into' an area containing the pyrophoric material and placing this material in a mound which will be capped with clay and protective top soil. This action is intended to 1) reduce or eliminate leaching of the contaminated material, 2) reduce emission of radon from the ground surf ace, 3) prevent erosion and dispersion of surf ace activity, and 4) eliminate the ootential for contact with the pyrophoric material. An estimation of the radiological consequences associated with the proposed action was made as part of the assessment. This analysis showed three things. 1) The current emissions of radon from the site are producing low levels of radiation exposure -to the nearest residents. 1

2) The planned site stabilization activities are expected to l

result in a temporarily increased level of radiation exposure as a result of du st generated during the stabilization activ ities. i l l t- __ _ _ _. _ _ _ _ _ _. _ _ _ _ _.. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _

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3) After site stabilization, the radiat%n exposures from the stabilized site are expected to decrease to near natural background levels.

The pyrophoric material which is currently buried on the site and which will be covered with contaminated soil in the proposed action is expected to oxidize slowly to Zr0. This will result in a gradual reduction of. amount of 2 chemically hazardous material. In the process of conducting the environmental assessment, analysis of possible'off-normal situations was performed. The most significant accident of a radiological nature that. was examined involved tile postulated degradation of I integrity of the clay cover with resultant increased leaching of containment materi als. Based on-analysis conducted as part of this environmental assessment, the fo11owing conclusions are drawn. 1. The proposed action does reduce direct radiation exposure, the amount of radionuclides leaching, the rate of radon-226 emission and the potential for surface contamination erosion and dispersion. Furthermore, it reduces the potential for personnel coming in contact with j the slowly-oxidizing zirconium waste. 2. During this activity several precautions should be exercised to reduce the dose consequences to personnel involved in the stabilization and to nearest residents. l These precautions should include the use of water or similar agents to minimize dusting, the use of dust masks for site construction personnel and suspension of work when wind l conditions are such that the nearest residents could receive significant dust exposures. 3. The stabilization action should seek to minimize the uce I of organic materials in the soil mound so as to minimize the generation of water soluble organic compounds which could function as complexing agents and reduce the radionuclides retardation potential of the natural soil. 4. Action should be taken to render the buried drainage tile i system to a stable condition. This is necessary to assure that existing contamination is not washed from the system. l l 11 l l g

l l l~ i S. A maintenance and monitoring orogram should be implemented ~ f oll owing stabilization to assure that the stabilized area retains its design features. This program should also check that deep-rooted plants are not established i on the. cap. Groundwater monitoring should be continued to l verify the performance of the cap. Care should be taken to l assure that no major water pumping is performed in the area without strict and fre quent. sampling of groundwater monitoring wells during such activity. L a i l iii

TABLE OF CONTENTS Page Section i Summary......................... 1.0 PURPOSE AND NEED FOR THE PROPOSED ACTION........ I 2 2.0 THE ASSESSMENT..................... 2 2.1 SCOPE.......................... 5 2.2 ACTIVITIES....................... 6 2.3 ORGANIZATION...................... 7 3.0' PROP 6 SED ACTION AND ALTERNATIVES............ 7 3.1 PROPOSED ACTION..................... 8 3.1.1 Site Description................... 25 3.1.2 Site History..................... 3.1.3 Stabilization Plan / Construction............ 36 3.1.4 Containment and Monitoring.............. 37 3.2 ALTERNATIVES TO THE PROPOSED ACTION........... 40

3. 2.1 -

Stabilization of the Pyrophoric Material Before - Si te Stabili zation............... 41 3.2.2 Disposal of the Material at~ 0ther Authorized Sites.. 41 42 3.3.3 No Action....................... 4.0 AFFECTED ENVIRONMENT.................. 43 4.1 AFFECTED ENVIRONMENT OF THE PROPOSED ACTION....... 43 4.2 AFFECTED ENVIRONMENT OF THE ALTERNATIVES........ 44 4.2.1 Alternative 1 - Site Stabilization Af ter Pyrophoric Material Stabilization............. 44 4.2 2 Alternative 2 - Disposal Off-Site........... 45 4.2.3 Alternative 3 - No Action - Denial of Request for Stabilization Approval............. 45 4.3

SUMMARY

QUALITATIVE EVALUATION............. 45 5.0 CONSEQUENCES OF THE PROPOSED ACTION........... 48 5.1 CONSEQUENCES OF CONSTRUCTION AND NORMAL MAINTENANCE... 48 5.2 CONSEQUENCES OF 0FF-NORMAL CONDITIONS.......... 57 5.3

SUMMARY

EVALUATION................... 59 A-1 APPENDIX A APPENDIX B DISCUSSION OF THE WASTE LEACHING PHENOMENA AND ASSOCIATED CONSEQUENCES................. B-1 APPENDIX C CALCULATION OF RADON FLUX FROM THE PROPOSED BURIED MOUND.......................... C-1 REFERENCES iv

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~- ' LIST OF FIGURES Figure Page .3.1-Wood County. and Amax Site Locations............. 9 -3;2 Amax Location in Washington Bottom............... 10 3.3. Amax Property-........................ 11 I '3.4-Commercialized Portion of Amax Property........... 13 . 3. 5 Geohydrologic Profile Typical of the Amax Site........ '16 3.~ 6 ' Present Site Surface Water ' Runoff Directions... -...... 18 L - 3.7 Seismic Risk Map of the United States............. 23 f '3.8 Contaminated Areas,-1977 Survey............... 27 l 3.9 Amax Site History...,..................... 28 l- -3.10 Present Location of L. B. Foster Buildings.......... 29-I o 31 l -3.11 Areas of Ground ' Contamina tion................ 3.12. . Radioactivity Greater than Twice. Background.as a Function l of: Depth............................ 33 3.13 . Storm Drain ........................ -34 3.14 -. Conceptual Cross Section of the Burial Mound......... 38 3.15-Plan View of the Proposed Burial Mound............ 39 5.1 Dust Concentration to the South as a Result of Site 4 L Stabilization Activi ties........-. '.......... 51 i s 11 ~ A plot of h/he vs. s/so for the Proposed Waste Burial Mound. B-5 B E l l: i I t v u-_

t LIST OF TABLES Page_ Tabl e_ 14 3.1 Population Data...................... 21 Annual Average Chi /0 Values at Various Distances...... 3.2 22 Annual Average Chi /Q Values at Various Segments...... 3.3-46 4.1 Impact Comparison Matrix.................. Maximum Doses t'o Personnel Involved in Site Stabilization 5.1 50 Ac ti v i ti e s......................... Doses to the Nearest Resident and the General Population 5.2 52 As a Result of Site Stabilization Activities........ Doses to the Nearest Resident and the General Population As 5.3. a Result of Radon Releases Before and Af ter Site Stabiliza-54 tion............................ 5.4 Estimated Dose' to a Hypothetical Individual Consuming Leachate at a Point Just Prior to Mixing With the Ohio 55 River........................... 5.5 Calculated Consequence of Off-Normal Waste Leaching 58 Conditions......................... 5.6 Summary Comparison of Status of the Proposed Action 60 Relative to the Guidelines................. Amount of Rainwater Expected to Reach the Top of the Clay BI B-2 Cap Each Month....................... B-2 Calculation Table for the Leaching and Transport of B-7 Radionuclides from the Proposed Amax Inc. Burial Mound... B-3 Estimated Dose to a Hypothetical Individual Consuming Leachate at a Point Just Prior to Mixing With the Ohio B-9 River.......... B-4 Calculation Table for the Leachate Concentrations Under B-10 Off-Normal Conditions................... B-5 Predicted and Measured Leachate Concentrations Beneath B-11 the Amax Inc. Site..................... C-5 C-1 Estimated Properties of the Material of the Cover Layers.. I vi

L. 1.0 PURPOSE AND NEED FOR THE PROPOSED ACTION i Amax Inc. presently owns a 375-acre site in Wood County, West Virginia, a portion of which was occupied by a zirconium ore processing f acility. When test activities were ceased in 1977 and Amax decided to close the r l Parkersburg W.Va. site, an NRC site survey was conducted. This survey identified some soil activity levels which result in unrestricted area dose levels above the l 1 acceptable limits of the Code of Federal Regulations, Title 10, Part 20, Section 105 (10 CFR 20.105). There is a need for Amax to take action to reduce these unrestricted area dose - levels. Amax has applied for a new possession only license for the purpose of effecting a site stabilization project which will f - provide for. the safe storage of the contaminated soil on the site previously occupied by the zirconium processing operations. The proposed stabilization project is to provide for protection of l health, to minimize danger to life, and to restore a major portion of the land area to unrestricted or productive uses. ( I l l l 1

2.0 THE ASSESSMENT 2.1 SCOPE This environmental assessment of the proposed Amax site stabilization f the Code of project has been performed in accordance with the requirements o Federal Regulations, Title 10, Part 51 (10 CFR 51) " Licensing and Regulatory Policy and Procedures for' Environmental Protection." Part 51.5 (b) 4 (iii) lists radioactive waste' disposal as an activity which may require an environment ~ impact statement (EIS). This report is an environmental assessment which examines the proposed action and provides a basis for the. decision regarding the necessity of an EIS. The requirements of 10 CFR 51.31 stipulate an environmental assessment is to be used by the Nuclear Regulatory Commission (NRC) staff as an aid and a basis for deciding whether to prepare an EIS or to issue a negative decl aration. This assessment addresses, several issues, only some of which are directly covered by existing legislation or guidelines for repositories specifically designed, constructed' and operated for the disposal of radioactive and other hazardous substances (in this case, contaminated earth and pyrophoric material). Therefore, guidelines for use in this assessment were developed through synthesis of the Federal regulations, proposed rules and reports which are listed and exerpted or paraphrased below. o Federal Register 6/24/81 p 38081-38105 " Proposed Rulen.aking on-Land Disposal of Low-Level Radioactive Waste." This proposed rule states NRC's planned approach to evaluating shallow land burial sites and operation. These rules address many requirements and practices which are thought to be very similar to those involved in the proposed action. 40 CFR 190 " Environmental Radiation Protection Standards for o Nuclear ' Power Operations." While this is not applicable to operations of site stabilization activities,.this standard does define a generally applicable dose limit of 25 mrem /yr whole body, 75 mrem /yr thyroid and 25 mrem /yr to any(other organ of the general public due to routine operations i.e., chronic exposure ). It appears reasonable to apply such operational standards to the proposed action. 2 e w

o Federal Register 1/9/81 p 2556-2563 " Proposed Disposal Standards for Inactive Uranium Processing Sites." This specifies groundwater protection stancards which are applied at 0.1 km from a tailings disposal pile and thereby establishes guidelines for an operation such as the Amax site stabilization project which involves similar waste and similar long-term safety concerns. o 10 CFR 20 " Standards for Protection Against Radiation." This specifies concentration and dose limits for a wide variety of licensed activities and the "as low as reasonably achievable" philosophy. These guidelines and concepts are applicable throughout the fuel cycle and are expected to be applicable for site stabilization operations. o' Federal Rt <ister notifications relative to the implementation of the Resource Conservation and Recovery Act of 1976 and its amendments. The primary Federal Register notices of concern here have been December 18,1978 p 58946-59028; May 19,1980 p 33159-33258; January 12, 1981 p 2802-2897; and February 5, 1981 p 11126-11177. These identify issues of concern in the management of hazardous waste in landfill (shallow land) disposal sites. The concerns related to hazardous waste dis posal are similar to - those appropriate to low-level and reactive wastes found at the Amax site. These Federal Register notice serve to identify reasonable approaches to the waste disposal concerns. o Final Generic Environmental Impact Statement on Uranium Milling, N UREG-0706. This report, by the U. C Nuclear Regulatory Comission, identifies the hazards and analytical methods appropriate for a waste which is somewhat similar to the Amax wastes. The report is related to the Federal Register notice of 1/9/81 for the disposal of mill tailings. o Improvements Needed in the Land Discosal of Radioactive Wastes - A Problem of Te'nturies D0 report toTongress dated 12 January 1976. This report reviewed 'the historical performance of several shallow land burial operations and made recommendations for future activities by NRC. Some of these concerns are still relevant. Among the points it highlights is the need for sites which have simple geolooic and hydrologic characteristics so that safety analysis can be performed with a reasonable level of confidence. o U.S. EC Branch Technical Position on the Disposal Onsite Storage of Residual Thorium or Uranium From Past Operations (SEC 81-576) October 5, 1981. This paper to the NRC conynissioners identifies performance and to some degree i design standards which the NRC Staff intends to use in 3 i ,e

i evaluating action plans for sites with residual uranium or-thorium contamination. The synthesis resulted in development of several specific criteria. These into four criteria are presented ~ in the following paragraphs and are grouped Site Selection, Construction, Containment, and Site Release. general" phases: Site selection The site should be selected such that it is: -o of relatively uncomplicated geological and hydrological features so that-reasonable quantitative analysis is

possible, easily and rapidly draine'd of rainwater and snow melt.

o Construction During construction of the burial mound certain activities should be pursued to assure that performance of the stabilized mound will be compatible with design objectives. The specific actions considered to be necessary are to: control-of dust to minimize on-and off-site doses, o o verify extension of the clay cap down to the gravel-sand l ayer to assure that lateral movement of water into the contaminated soil is not possible, o verify the operation of the drainway around the mound to assnre that standing water does not exist. i i 4 ( t.

i i Containment l Continuing and periodic monitoring of the burial site will be required to assure that the engineered and natural barriers which limit material tradsport remain in place and are working properly. These activities consist of: o maintenance activities such as inspection for erosion and removal of undesirable plants such as deep-rooted vegetation or trees o monitoring of the annual dose to the nearest actual resident. It should be less than 25 mrem whole body, 75 mrem to the thyroid and % mrem to other organs. o monitoring the groundwater at the plant boundary to assure that it does not exceed the limits in the National Primary Drinking Water Standard or 10 CFR 20 Appendix B. Site Release The removal of contaminated material must proceed until activity levels low enough so that the site can be released for unrestricted use. The levels of activity which are acceptable for release are' based on the levels specified in j NRC branch technical position for disposal or onsite storage of residual thorium or uranium from past operations, i.e.,10 pCi/gm total activity level. 2.2 ACTIVITIES i During preparation of the assessment, applicable Federal and State i legislation and Federal guidelines were reviewed. Appropriate Federal and State agencies were contacted in person, by phone or mail. Conferences were held with Amax personnel and consultants. A site inspection, including surrounding areas and coninunities, was conducted. Data from the site visit, personal contacts and independent investigation were collected, evaluated and analyzed for { incorporation into the final assessment. 4 5 ~

1 f 2.3 ORGANIZATION This assessment is organized according to the guidelines established by the President's Council on Environmental Quality (40 CFR 1506) and the Part 3.0 -requirements of the U.S. Nuclear Regulatory Comission (10 CFR 51). Part 4.0 identifies the describes the Proposed Action, including alternatives. environmental ' components affected by the proposed action and the alternatives, Part and evaluates, in qualitative terms, the proposed and alternative actions. 5.0 addresses the environmental consequences of the Proposed Action. These parts are followed by an Appendix A which supports Section 4.0 in that it contains an identification and justification 'of environmental "non-issues" in this assessment; Appendix B which presents details of'the leaching and water transport analysis;. and Appendix C which presents details of the radon emission calcul ations. 6

3.0 PROPOSED ACTION AND ALTERNATIVES I A description of the existing site, environmental characteristics, relevant site history, and details of the proposed action are presented in Section 3.1. Possible alternative actions are identified and briefly described in Section 3.2. This information serves as a data base for the identification of i environmental components which wuld be affected by both the proposed action and { the alternatives. The identifi cation of those environmental components are presented in Section 4 3.1 PROPOSED ACTION l The soil at a number of locations on the Amax site in Wood County, West Virginia has been found to be contaminated with low levels of natural uranium and thorium as a result of previous zirconium ore processing activities. Investigations of the site have also indicated the presence of pryophoric i materi al. The proposed action is to stabilize the radioactively contaminated soil and the reactive (pyrophoric) waste material so that major portions of the site may be restored to productive, unrestricted use. The basic plan is to move i contaminated soil to a limited area where additional contaminated soil exists and . the pyrophoric material is buried. A clay cap with a protective earthen cover j will then be constructed to cover the material and minimize rainwater infiltration and leaching of the radioactive contaminants. A brief discussion of the site and the surrounding area is presented in Subsection 3.1.1 and review of the site history of the last 24 years is presented in Subsection 3.1.2.- Details of the clearing and cap construction are discussed 3 in Subsection 3.1.3. 7

s 3.1.1 Site Description The Amax site is in Wood County, West Virginia (Figure 3.1) at 39015 '01"N and,810 1'W. Wood County consists of 235,520 acresl with a reported 4 population of 93.648 (U.S. Bureau of Census 1980).2 About 43% of the county j Though a number population reside in the City of Parkersburg, the County Seat. of industries flourish in the Parkersburg area, the county is best characterized i in an The Amax site is situated on the east bank of the Ohio River, as rural. area known as Washington Bottom. Washington Bottom, as a geologic feature, becomes evident about five miles west of Parkersburg and trends westward, then southwestward and south for a distance of five miles. It is bounded on the north and west by the Ohio River and on the east by an escarpment which in the past constituted the eastern bank The area of the Bottom is about 21,000 acres about half of which of the river. is f armland. The remainder has become industrialized during the past 30 years. The Amax property which lies at the approximate center of the Bottom (Figure 3.2), is about eight miles southwest of Parkersburg and one mile south of the town of Washington, West Virginia. About one-third of the Amax property, 126 acres, has been developed for commercial use. The primary access road, Foster Road, intersects Dupont Road to the east and marks the northern boundary of the property (Figure 3.3). Additional access is via a rail spur from the B&O Railroad which parallels DuPont Road to the east. The most predominant feature on the conrnerci alized (northeastern ) portion of the site is a water storage tower. About 700 feet west of Dupont Road x 50 feet and 100 feet south of Foster Road is a one story building of 100 dimensions which is the L.B. Foster office. South of the office is an area, intersected by' the railroad spur, about B00 x 800 feet which is principally occupied by remains (mostly foundations) of the former Amax plant and concrete floor slabs on which construction of the L.B. Foster pipe f abrication plant was initially consnenced. The portion of this area between the rail spur and the 8

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1 The office building is now.used as a temporary finished pipe storage area. larger (350 f t. x 300. ft. x 40 ft. high) of the two relocated pipe f abrication plant buildings is 650 feet west of the office..The second f abrication structure (125 ft. x 75 f t. x 40 f t. ' high) is 300 feet south of the' larger pipe plant buil' ing (Figure 3.4). d Land tise Imediately to the north of the Amax site -(Reference Figure 3.2) is f armland which extends northward for some 3,000 feet to the Borg-Warner Chemicals plant property which, in turn, borders the property of the E. I. duPont de Co. ' property. - Together, the property of these two companies, each of Nemours which employ more than 1,000 persons, extends northward for about one mile.3 The Northeast of the duPont plant are some scattered small industrial buildings. remainder of'the bottomland to the east is unoccupied. The land imediately.to the south of.the Amax site is' owned by the There are two Monongahela Power Company, but is currently, leased as f armland. industries south of the Amax property; AGA Burdox, Inc. (.3 miles, bordering DuPont Road) which produces oxygen and nitrogen and employs less than 100 persons and the Nitro Industrial Coverings Company, an even smaller concern.3 The remainder -of the bottomland to the south is f armland with scattered residences in. There are the eastern portion starting about a mile south of the Amax property. four residences.which are within.less than a mile of the proposed stabilization site: one,1,800 ft. to the south; two, 2,200 ft. to the northwest; and one, 4,000 ft. to the northeast. Demography As has.been' previously indicated, the Amax site is not near any large population centers. Population distribution out to 50 miles for each of the 16 cardinal compass directions is shown on Table 3.1. 12

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l l [- l l Geology The geology of the river bottom land between river miles 190 to 194, the general area of interest in this assessment, has been defined as a result of a number of wells having been drill ed and is very similar throughout. Topographically the area is characterized by a series of river bank terraces which rise in elevation from the river (590 ft. msl) eastward to about 635 ft. ms1 at the industrialized area of the Amax property. The terraces are drained by gullies with intermittently flowing streams. The soils in the area are ) classified as the Huntington-Ashton-Wheeling Association and are characterized by a clayey silt that ranges from one to ten f eet thick.1 This is underlain by interbedded layers of sand and intermixed sand and gravel down to bedrock which lies about 100 feet below the surf ace. Figure 3.5 shows the t ypical geohydrologic profile of the area. Toward the end of the Pleistocene Epoch (12,000-15,000 years ago) when l glacial melt water flowed through the Ohio River Valley at a much higher rate, coarse sands and gravels were transported to the Washington Bottom area. These sands and gravels were deposited from the slower moving water on the inside of the meander bend. As flow rates in the river decreased the sand and gravel was overlain by fine sand, silt and clay. { The groundwater level at the Amax site is located approximately 50 feet below the surf ace which is nearly the elevation of the Ohio River.4 The flow J f direction of this groundwater is variable but is generally perpendicular to the river flow.5,6 The groundwater table is charged by the river as the surf ace layer of highly impermeable silty clay causes precipitation to run off on the surf ace j to the Ohio River. The strata from the water table to the surf ace constitutes j the unsaturated zone wherein there is only capillary water and little water J / l movement except in the absence of the overlying silty clay layer which prevents infiltration of runoff. Water, if it does enter these unsaturated sand and gravel layers, moves rapidly and vertically down to the water table. i j j l 1 15 l 4

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~ } i Hydrology-Subsurf ace Six wells have been drilled at the Amax site, two of which_ were geophysically logged using four logs. These were the natural gama log, the epithermal neutron log, the gama gama density log, and caliper log. These well logging techniques provide an accurate description of the gechydrologic strata penetrated. The natural gabina log is the measure of the natural radioactivity and is indicative of silt and clay lenses or radioactive contamination at a site. In the case of Monitor Well 1, the natural gama tool recorded very low count 4 rates within the subsurf ace materials with a small increase within the top 7 feet of materials. This increase is indicative of a finer grained matrix (clay and silt). Otherwise, the gama ray log showed clean sands and gravels Lhroughout the borehole. The neutron epithermal neutron tool and gama gamma tools were used to assess variation in subsurf ace porosity and density. Both of these tools are affected by changes in borehole diameter and rugosity (nonuniformity) so a caliper log was run in conjunction with them. In no instance has there been any evidence of clay lenses or perched water within the unsaturated zone. The absence of clay or any other material that would hold or cause horizontal water j movement in the unsaturated zone has been further verified by the f acts that; 1) during examination of the site for radiological contamination below the surf ace, Aone o[ th[1', Dest holes that were water jetted to a depth of 12 feet held 7 and 2) none of the 27 on-site test pits, dug down to initial contact with water sands and gravels, will hold water even during heavy rains.8 Hydrology-Surf ace a surf ace water features are dominated by the Ohio River as the only continually running water source. Surf ace runoff from rainf all at the site flows toward 1) the ditch parallelling the B&O railroad tracks or 2) the drainage channel running south and then west to the Ohio River or 3) directly into the Ohio River. The flow directions for runoff water are sumarized in Figure 3.6. l l l 17

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i f Although the land on which the L.B. Foster and former Amax f acilities ) are located is classed as river bottom l and, it is neither wetland nor i floodpl ain. The highest recorded floodwater level reached only to a. level of 616.5 ft. ms1 in 1913. The potential for flooding at the level where site l- ' stabilization is planned (625-630 ms1) is not considered credible. l Climatology l The climate of Parkersburg can be described as moderate. Located on the bank of the Ohio River ~ and in the extreme north of the " upper south,' Parkersburg is in the f arthest north area where tender vegetation, s uch as magnolias, are able to survive most of the winters. In suntners, prolonged hot weather is infrequent. During the period of record (90 years), there have been 0 only 24 days with a temperature of 100 F or more. Likewise, prolonged cold 0 weather is infrequent; temperatures of -10 F or lower have occurred on only 13 0 days. The average temperature is lowest in January (33 F) and highest in July l (75.2 F). Precipitation averages 38.9 inches per year. The heaviest rains are 0 in June and July. The lightest amounts are in October. On the average of once every four or five years, a dry spell in July or August does some damage to crops in the vicinity. Days with measurable snowf all average about 25 for the year; l the average annual snowf all is about 24 inches. However, total snowf all amounts vary greatly.from winter to winter, ranging from over 55 inches to less than 4 inches. Parkersburg is not a windy city, the winds being light most of the . time. Occasionally a winter storm may be accompanied by winds up to gale force ] and, also infrequently, the winds associated with a sunener thunderstorm may be nearly as intense.9 [ During the last 89 years the highest wind speed recorded was 66 mph from the northwest, during the month of November, 1966. High northwesterly winds, when they occur, are caused by the passage of a strong, rapidly moving cold front. There are no indications that tornado velocity winds have been 19

4 1 ~ Due to the f act experienced during the period of record in the Parkersburg area. that the Parkersburg area is, for the major portion of the year, under the influence of the circulation of the Bermuda High pressure-pattern s, the prevailing wind is southwesterly. On-site meteorological data on wind speeds and direction is not However, general climatological characteristics in available from the applicant. the area can be referenced to the U.S. National Weather Service recording station at Parkersburg.10 For subsequent atmospheric dispersion calculations, s int frequency o distributions of wind direction, speed and stability class from Parkersburg were used. The meteorological dispersion f actors (chi /Q) were produced from the Gaussian Plume model and diffusion coefficients for Pasquill tpe turbulence as described in Regulatory Guide 1.111. The annual average chi /Qs as a function of distance up to 50 miles from the site in the sixteen 22-1/2 degree compass point sectors (i.e., centered on the north, northeast, southeast, etc.) were calculated and are shown in Tables 3.2 and 3.3. These point source chi /Q values will be used together with the concept of an " apparent" point source for the purpose of calculating downwind concentrations from the site areal sources. Seismology Parkersburg is located in a seismic risk Zone 1 (Figure 3.7), where be expected.11,12 U.S. Geological Survey data show the only minor. damage may epicenter of a mild (IV on the Modified Mercali Scale) earthquake occurred at Parkersburg on July 15, 1874. At the town of Rockport, about 13 miles south-southeast of Parkersburg, there was an earthquake epicenter of intensity V on October 20, 1974. The next closest recorded seismic activity (M.M.IV) was about 80 miles south-southeast of Parkersburg in 1970. 20

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i Air Quality The Ambient Air ~ Quality Standards for the State of West V.irginia Although the only parallel those of the Federal Ambient Air Quality Standards. ambient air monitoring station in the Parkersburg area (about 8 miles downwind from the Amax site) does not provide any measurement of air quality at the Amax site, it is the opinicn of State Air Pollution Control Commission that the area of interest is an attainment area.13 Water Quality There are no water quality sampling stations on the Ohio River in the vicinity of Parkersburg and the Amax site. Therefore, a year's (1979) records from the nearest sampling stations at Willow Island (about 30 miles upstream from Parkersburg) and Belleville (about 10 miles downstream), were examined. The objective of examining these data was to determine the quality of the Ohio River water. Thirty-five water quality parameters were sampled, twenty of which are listed as state water quality criteria.14 Six (dissolved oxygen, CACO, ammonia, 3 in the barium, manganese, and fecal coli) of the twenty criteria were exceeded samples from both stations. With the exception of fecal coli, which was 151 mg/l higher at Belleville, the criteria were exceeded in nearly equal amounts at both sampling stations. The criterion for phenols was slightly exceeded at the Willow Island sampling station but was not exceeded, and was significantly lower at tha downstream Belleville station. No measurements of radioactivity have been made by the state but a recent groundwater sampling program by Amax show that radioactivity in the groundwater under the site conforms to EPA standards (40 CFR 141.15) and NRC standards (10 CFR 20, Appendix B).15 24

l t I 3.1.2 Site History The Wood County plant site was originally developed by the Carborundum Company in 1957 for the production of high-grade zirconium metal for use'in the l construction of nuclear reactors for the U.S. Navy under an Atomic Energy Comission contract. This process started with the conversion of zircon ore (ZrSiO ) to zirconium carbonitrile followed by chlorination of the carbide to 4 zirconium tetrachloride (ZrCl ). The zirconium tetrachloride was purified and 4 reduced to zirconium metal by the Kroll. process which involves reacting the zirconium tetrachloride with magnesium metal to produce primarily zirconium metal j and magnesium chlorica. During 1961 and 1962, the Carborundum Company processed Nigerian zirconium ore under an Atomic Energy Comission license. In addition to l zirconium, this ore contained 6 percent haf nium, up to 8 percent thorium (Th0 ) 2 and 0.2 percent uranium (UO ). The processing of the radioactive Nigerian ore 2 was under license by the Atomic Energy Comission, and both the ore and all residuals were stored in drums on the site. The use of Nigerian ore ended in 1962 when another source of zircon ore, which contained no radioactivity, was est ablished. Operations with this uncontaminated ore continued until 1970. Amax and Carborundum operated the f acilit.y as a joint venture, under the name of Carborundum Metals Climax, from 1965 to 1967. Amax then became the 1 sole owner of the business. The Nigerian ore and radioactive residual, left over from processing during 1961 and 1962, were stored on the site until September 1968. During the seven years of storage, some drums deteriorated and spilled on the soils in the storage area. To reduce the residual radi ation, soil located j beneath the stored drums was disposed of by packaging for of f-site burial. l Nearly 3,000 drums of ore, residual material, and soil were transported from the property to an approved AEC burial site at Morehead, Kentucky in 1968. ) The processing of zirconium ore was discontinued in late 1969, when purchased zirconium tetrachloride was substituted. Amax produced zirconium and 1 25 q tE---

metal sponge until November 1974, at which time all prodJction at the site was terminated. t In November 1974,. Amax received a license from the Nuclear Regulatory Comission - (PRC) to conduct laboratory-scale experiments on baddeleyite ore The test -(Zr0 ) which contained less than 0.5 percent total thorium and uranium. 2 material and all 'of the process residuals. were contained within one building on After the laboratory tests were concluded in late 1975, all remaining the site. residuals were - transported to an baddeleyite ore was sold and its process approved NRC disposal site. Based on a site inspection in 1977 concerning the closecut of Amax's baddeleyite license, NRC identified soil associated with the Nigerian ore at above acceptable radiation limits. This inspection included the - the east and north by the security fence, on the west by the area bounded on westernmost on-site road and on the south by the railroad tracks (Figure 3.8). A number of locations, the hatched portions in Figure 3.8, within the survey area were found to be emitting at 50 to 80 times natural background. A cleanup program was initiated and subsequently seventy (70) drums of contaminated soil was. collected and shipped to an approved NRC disposal site. B. In 1977, the Wood County property and buildings were sold to L.- Foster Company (Foster) for use as a pipe manuf acturing f acility. Building construction, which started in 1977, ceased in March 1978 when pyrophoric material was uncovered. As a result of problems encountered in the construction of new buildings with regard to pyrophoric material found on the property in 1978, Amax repurchased the site from Foster. The history of the ownership and major activities at the Amax site which has been presented in the foregoing paragraphs is-sumarized diagrammatically in Figure 3.9. During 1979, Foster leased from Amax a portion of the property west of the former zirconium plant which was found to be free of radioactivity, and their pipe manuf acturing buildings were relocated as shown in Figure 3.10. The manuf acture of pipe was begun again in late 1979 by Foster. Today the f acilities 26

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on the property consist of an office building, new plant buildings, roadways, old building foundations (slabs and floors), storage areas, water and gas mains, an elevated water storage tank and well field, storm drainage systems, and a line leading to the ' plant railroad spur from the Baltimore and Ohio Railroad (Figure 3.10). In addition to the obvious physical features remaining from the previous use of the site there also remain areas where the soil is contaminated with radioactivity. In 1980 a survey was conducted during which the area invest.Jcted was much larger than that surveyed in 1977.7 The area of investigation north of the railroad tracks was basically the same as that of the 1977 survey except that it The area to the south, including was expanded to 25 feet beyond the fence lines. the railroad tracks, extended to the southern boundary of the Amax property, and approximately 200 feet and 75 feet further east and west of the northern portion, respectively. The entire area was divided into a grid pattern consisting of l 1,422 twenty-five by twenty-five foot squares. Each square was meas ad for both surf ace and subsurf ace radioactivity. The surveyors also examined areas outside j this grid pattern and, as a result, located two small areas of contamination. One was slightly to the west of the grid pattern and the other area was southwest into the property adjoining the Amax southern property line. Approximately one quarter of the survey area (excluding that on other property), about five acres total, was found to be emitting gamma radiation at rates of from two to over ten times the natural background. Activity was found to range from two-to five times backgrsund over 52% of the total contaminated l area, over 26.5% of the area emissions were from five to ten times background, { The l and greater than ten times background over 21.5% of the contaminated areas. areas of ground contamination are shown in Figure 3.11. The most highly active l portions of the contaminated areas shown in Figure 3.11 were in the: f i I 30

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f Area north of the railroad tracks o l o Along the tracks Center of the area just south of the tracks between the two o old slabs along the southern edge of the easternmost old slab o o central' and southwestern portion of the most southwestern contaminated area. The area of contamination which crosses the Amax property line and continues southwestward was all wit.,in the "two to five times background" range. As was previously mentioned, subsurface radioactivity was also measured. Figure 3.12 shows radioactivity greater than twice background. as a function of depth. In the contaminated area north of, and including, the railroad tracks investigations have indicated that the radioactivity in the soil is highest, by a f actor of two to four, two to four inches below the surf ace and has tapered off to background by 24 inches depth. The activity in the contaminated soil which extends well into the property to the south has been found to degrade to background at a maximum depth of 18 inches. An explanation of the presence of the radioactive soil..its areal extent, and depths at which detected south of the railroad tracks, has not been forthcoming. The area was used for refuse and waste disposal hcwever was not designated for radioactive or reactive wastes. In addition to the aforementioned contaminated areas there is a storm drain that runs from the Amax manuf acturing area to the Ohio River (Figure 3.13). As shown on the figure, the drain has four man ways. The man ways were measured 'for radioactivity and attempts were made to decontaminate them. The decontamination efforts were not successful as the gamma activity was minimally 32

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i --. DUPONT ROAD -.-j E,' : ' :- RAILROAD m,no ~ j. . '. L i, j s 1 ,I \\ L._._._._:_ l 1 STORM DRAIN LINE WITH LOCATION OF l FOUR MAN WAYS i 62 i iii! } i, 3 ,1 r l' \\ i j__ _~ l- ; g4 i s l' 'w j s .i-t I l; I 'I './Ns E OMO i Figure 3.13. Storm Drain 34

I l affected. The levels of activity in the man ways f ar exceeds the levels the NRC* f has specified as acceptable, and it must be presumed that the piping associated with the system also is cMtaminated to unacceptable levels. Plans for stabili-zation of this component of the Amax site have not been addressed. It would appear appropriate to eliminate the pipeline as a site drainage method, hydraulically isolate and possibly backfill it to provide structural stability. During initial construction of buildings for the L.B. Foster pipe f abrication

plant, it was discovered that some areas also contained nonradioactive pyrophoric waste material.

) While doing surf ace grading in the area of the western "old s l ab, " Figure 3.10, the bulldozer encountered material which ignited. The resultant fire destroyed the bulldozer. Soon thereafter, while using a backhoe in the dirt-floor area of a Butler Building that had been erected on the eastern "old slab," an explosion occurred. The force of this explosion hurled a large steel I component from the backhoe through the roof of the building, 40 feet above. After two other minor' instances of combustion, construction work was stopped. During the previously discussed radiological survey while holes were being water jetted for subsurf ace radioactivity measurements an MSA Explosimeter was used for detection of explosive gasses in the air just above the hole. In total, four holes were determined to have detectable concentrations of flammable atmospheres and in three of these cases white smoke was noted indicating a minor l pyrophoric or chemical reaction. In June of this vear there was an absolutely spontaneous combustion of what had appeared to be nothing more than plain earth. The pyrophoric materi al i s, thought to be waste zirconium and production by-product material known as " sidewall materi al." " Sidewall material" results from the Kroll reduction process which converts zirconium tetrachloride (ZrC1 ) 4 L

Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special j

Nuclear Material. 35 L___---------_-_--

i i to zirconium metal. The composition of " sidewall material" is variable but it contains zirconium metal, magnesium metal and chloride salts of these two metals I and is known to be pyrophoric. l The exact nature of pyrophori c' reactions, their initiating and propagation conditions are not fully understood. Many mechanisms have been suggested to explain pyrophoricity of metals, but no single theory is completely The pyrophoric combustion adequate in explaining the nature of this phenomenon. reactions are not completely reproducible and therefore caution must be used in dealing with such materials. Investigations of the site by Amax7,15 suggests that the most likely I location for the pyrophoric material is in the area where the Foster buildings were originally to be constructed, that is, south of the original zirconium There is some uncertainty with this assessment because of the processing area. lack of satisf actory zirconium survey techniques. 3.1.3 Stabilization Plan / Construction The stabilization plan proposed by Amax is based on a series of technical studies involving site characterization and radiation surveys, safety evaluations and cost estimates. The proposed plan is to move all of the contaminated soils into parcel C (Figures 3.10 and 3.11) south of the railroad spur and construct a mound designed to preclude material transport. This. stabilization involves five major steps. These steps are:

1) Collection of all the contaminated soil (about 10,000 cubic yards) into the area which is designated ' Parcel C.'

This soil will be compacted to fom a mound which has surf ace runoff f eatures compatible with the rest of the site area.

2) After the contaminated soil is compacted in the desired shape, the entire mound will be covered with a 6-inch layer 36

of clayey material. This clayey material is designed to provide a base for a final clay cover.

3) The final clay cover of,12-inch thickness, is to be added to the mound in order to form a highly impermeable layer and to protect the waste material from leaching.

Th permeability of the final clay cap will be less than 1 x 10 g cm/sec.

4) A 30-inch layer of soil will then be placed over the clay cap to protect it from weathering or erosion and to provide a soil base for growing an acceptable cover crop.

5) The final step in stabilization will be the seeding of the soil cover wi'5 a naturally growing grass to control erosion.

Figure 3.14 shows a cross section of the completed burial mound. The drawing is not to scale. It does show, however, several major features of the stabilization plan. These major features are: 1) a clay cover to prevent infiltration, 2) a slope to carry away precipitation, 3) a clay cap that extends down to the sand and gravel layers to prevent horizontal movement of water and 4) a drainage system to remove surf ace water. The shaded area in Figure 3.15 indicates the approximate areal extent of the burial mound. The local area clays found on the river bottomland have been described by the West Virginia Geological Survey as river silt consisting principally of illite with some galenite and clarinite.5 Woodward and Clyde, Consulting Engineers, as a result of extensive on site sampling and analysis programs, have established that sufficient clay, suitable for cap construction, exists on site and could be used.8 The Amax plan, however, calls for obtaining the clay from a i local comercial borrow pit. 3.1.4 Containment and Monitoring The design and construction (detailed in 3.1.3) of the proposed cap to cover and prevent migration of contaminants from the gathered, compacted, and covered soil should obviate the possibility of leachate generation and migration to the adjacent surf ace or subsurf ace soils. Two interrelated natural phenomena, 37 L L-_- _ _- _

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rain runoff and erosion, will continually be at work to degrade the integrity of the protective cap. In order to sustain the integrity of the effluent control system (the cap) and its eff ective performance, a program of scheduled inspection and maintenance needs to be developed. Preservation of healthy vegetation cover over the entire area (Figure 3.15) will be required to prevent thinning of the topsoil layer and exposure of the underlying clay cap to weathering and possible ' infiltration of water into the buried, contaminated earth. This will also preclude loss of topsoil and subsequent clogging of drainage ways. Periodic clearance of the perimeter drainage ways must also be effected so there will be area and no no standing rain runoff water around the perimeter of the capped possibility of water seeping under the edges of the cap. In addition to the implementation of a scheduled maintenance program, The evaluation an evaluation of the containment program needs to be instituted. program will consist of periodic sampling of groundwater monitoring wells which are to be located around the perimeter of the stabilization cap. absolutely vital to the effluent control system integrity, Last, but the capped area must be barred from human use, i.e., no construction and no disturbance of the surf ace which would reduce tt.a effectiveness of the cap as an infiltration barrier. 3.2 ALTERNATIVES TO THE PROPOSED ACTION In addition to the proposed action, three alternatives have been defined and are addressed in this section. These alternatives are: stabilization of the pyrophoric material before stabilization of the site (3.2.1), disposal of the material at other authorized sites (3.2.2) and no action-defer stabilization (3.2.3). Each of these alternatives are discussed in the following paragraphs. to the extent of identifying the environmental Analysis of the alternatives, components that would be affected, is presented in Section 4. 40

3.2.1 Stabilization of the Pyrophoric Material Before Site Stabilization Because the " sidewall materi al" is pyrophoric and represents some degree of hazard, it might be considered appropriate to stabilize the material prior to ' covering it as part of a site stabilization effort. Because of the uncertain nature of the causes and mechanism for metal pyrophoricity, there are no standard techniques by which this metal stabilization can be effected. It is generally considered, however, that oxidation of the pyrophoric metal will render it stable. To accomplish such an oxidation reaction, it is possible to burn the pyrophoric material in an open pit or trench fire. This was practiced in stabilizing pyrophoric zirconium scrap at Oak Ridge National Laboratory.17 ' This treatment technique for the pyrophoric materials at the Amax site would involve several steps. First, the materials would have to be located and dug out by using equipment which minimized the potential for initiation of a pyrophoric reaction and maximized personnel protection. The unearthed materials would the.1 be transported to a fire and burned. Thus, the reactive pyrophoric materials could be stabilized by oxidation. Following this, the site could be stabilized according to the proposed method. 3.2.2 Disposal of the Material at Other Authorized Sites The radioactively contaminated soil could be consolidated at one point on the property and packaged in DOT approved containers, labeled and transported to an authorized disposal site. Likewise, the residue from the oxidation of the pyrophoric material (Section 3.2.1) could be collected and packaged for shipment to a. licensed disposal site. This would preclude the work associated with on-site capping of the contaminated material and the necessity for possible l long-term monitoring of the capped material. l l l 41 l 4 I L

i 3.3.3 No Action No action would, in effect, be a denial of the application for the fie., the. action proposed was not considered a satisf actory

action, proposed resolution of the. problem and submittal. of.a different proposed action would be required.

/ e 42

4.0 AFFECTED ENVIRONENT The previous section (3.0 Proposed Action and Alternatives), identified-the actions that could be taken to stabilize the Amax site. Each of these actions, if implemented, wuld have some impact on the environment. This section identifies those environmental components which are expected to be impacted by the proposed action as well as by the alternatives. Part 4.1 identifies those environmental components which would be impacted by the proposed action, part 4.2 i dentifies the environmental components which would be impacted by the alternatives and part 4.3 presents a qualitative evaluation of both the proposed action as well as the alternatives. 4.1 AFFECTED ENVIRONENT OF THE PROPOSED ACTION The proposed action, as described in Section 3.1, involves the movement of soils from some areas of the site to a specific area of the site where l stabilization is to occur. The estimated total surf ace area of disturbed land is about 30 acres, including the on-site, and topsoil borrow areas. Such earth moving operations would generate some quantity of dust, and thus will impact the air quality in the imediate area of the site. Additionally, there will be a l significant increase in truck traf fi c on Foster and DuPont roads as large l quantities of cover materials will be imported from an off-site comercial borrow j. pit. During site stabilization, the areas where soils are removed will be left unprotected against erosion and some would occur during periods of rainf all thereby affecting the surf ace water quality in the surrounding area. If proper management of surf ace run-off such as slope grading, surf ace water diversion, collection and treatment or release to the river are observed, the impact on the Ohio River will be negligible. After site stabilization some potential for water quality impacts may exist if the disturbed areas are not properly managed (i.e., ] proper slope grading, revegetation, and drainage). Besides air and water quality j impacts, some impacts on natural resources due to the proposed action will occur. 43

Removal of the top soil from certain areas of the site, the soil borrow areas totaling approximately 11 acres, will not be readily usable for f arming purposes. In s umary, air quality, water quality and natural resources will be the environmental components impacted by the proposed action. 4.2 AFFECTED ENVIRONMENT OF THE ALTERNATIVES Section 3.2 defined three alternatives, these being (1) site stabilization but only after stabilization of the pyrophoric material. (2) removal of the stabilized pyrophoric and radioactive material for shipment to licensed or approved waste buri al sites and (3) no action--denial. of stabilization authorization. This section identifies the environmental Each alternative is components which would be impacted by the alternatives. addressed on an individual basis. 4.2.1 Alternative 1 - Site Stabilization After Pyrophoric Material Stabilization This alternative would involve the same environmental components as would be impacted by the proposed action. The extent of impact, however, would be greater. Stabilization by open incineration would impact air quality more than the proposed action because (1) additional earthmoving must be accomplished to retrieve the buried pyrophoric material and to construct an incineration pit or trench and (2) the products of incineration will generate a significant amount of particulate. There is also an inherent hazard in digging for and retrieving the pyrophoric material. 44 I u

1 4.2.2 Alternative 2 - Disposal Off-Site The alternative of disposing of the material at one or more existing off-site waste disposal sites was also considered. Such an alternative would involve the excavation of material from the present site. This earthmoving would impact both air quality (dust), water quality (Siltation) and increase the potential for pyrophoric material handling accidents. Stabilization-of the l pyrophoric material would also be a part of this off-site disposal option. The onsite impacts would then be comparable 'to the impacts found in the previous alternative (Site Stabilization after Pyrophoric Material Stabilization). l The transportation of material away from the Amax site would involve the risk of enroute accidents wherein material might be ' soill ed. The added expense of transportation does not enhance the cost-effectiveness of this disposal alternative. 4.2.3 Alternative 3 - No Action - Denial of Request for Stabilization Approval A final alternative was defined as denial of Amax's request to initiate site stabilization. This would produce less air quality impact because no earth moving would be involved. It would, however, result in continued surface radiation, greater radon releases and surf ace water quality impact due to runoff fron contaminated soil. As such, even the no action alternative has air and water quality impact. 4 4.3 SLM1ARY QUALITATIVE EVALUATION A matrix has been prepared in which the various available options (the proposed action and the alternatives thereto) are plotted against the environmental concerns associated with each option. The comparison matrix is presented in Table 4.1. The table shows that higher air and water qual it y 45 l l

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i I impacts are associated with waste retrieval or processing activities on the site. Over the longer term, higher air and water quality impacts would result from the no action option. The pyrophoric nature of some of the waste material means that some potential for pyrophoric reaction exists in either the long-or the short-term. The f act that oxidation is expected to occur in the ground should decrease the longer term potential for pyrophoric reaction. l The potential for transportation accidents associated with off-site disposal ' options means that these options have an element of risk to the environment and the public which the on-site disposal options do not. 1 In summary, it appears that while there are impacts associated with the proposed action, they are less severe than those associated with alternative actions. A quantification of these impacts and a comparison of these impacts against the guidelines identified in Section 2 is presented in the following section. 4 i 1 l l l i 47 l

5 5.0 CONSEQUENCES OF THE PROPOSED ACTION l The previous section identified those environmental components which will be impacted by the proposed action and :the alternatives. This section quantifies, to the extent possible, the impacts and also evaluates the proposed This section is action relative to the guidelines synthesized in Section 2.2. organized into three major parts. The first (5.1) addresses environmental impacts and consequences resulting from normal operation. The second (5.2) addresses environmental impacts and consequences resulting from off-normal conditions. The third section (5.3) presents a sunrnary evaluation of the proposed action in light of the guidelines identified in Section 2.1. 5.1 CONSEQUENCES OF CONSTRUCTION AND NORMAL MAINTENANCE The proposed stabilization operation will result in some environmental As identified in Section 4.1, the impacts are in the area of air quality impac t. and water quality, and natural resources. The air quality impacts are (1) short-term (about one month) generation of airborne particulate associated with the construction activity and (2) l ong-term (continuous) radon generation associated with the decay of thorium in the buried soil. Water quality impacts are of short-term and are associated with siltation which would occur during the site stabilization. Impacts to natural resources will result from on-site removal of topsoil and, unless positive restoration action is taken, these borrow areas -will remain unsuitable f or other purposes for a number of years. The . radiological and non-radiological impacts which can be quantitatively estimated are discussed in the following paragraphs. 48

i Radiological The radiological impact of proposed activities will involve two mechanisms. The first is generation of airborne particulate containing thorium and uranium associated with the stabilization activities. The second is radon emission from the stabilized site as the result of thorium decay. 1 The dusting which will occur with the site stabilization activities has 18 been estimated using an U.S. EPA source term f actor. The f actor is based on i the use of a wetting agent, such as water, which is' being planned by Amax Inc. 3 The estimated cloud density'in the actual operation area is 4.2 mg/m, 3 Assuming 1) a breathing rate of 9.6 m / day, 2) one-half the particles being in the respirable size range, 3) 0.8 weight percent thorium and 0.2 weight percent uranium and 4) one month of exposure, the maximum occupational doses of personnel ] involved in the stabilization activit y have been calculated. The results are presented in Table 5.1. This table shows that the major doses are to the lungs and the bone. The cormiitted dose to the lungs is 9.8 rem which, if linearized over 50 years, amounts to an annual dose of 0.2 rem / year. This can be further l reduced by about an order of magnitude through the use of half-mask respirators. D irect radiation exposure to construction people is estimated to be 10 to 20 millirem based on measured external dose rate at the site. Dosages to the nearest resident from the stabilization activities was also estimated. The nearest resident is located about 1400 feet to the south of l l the stabilization area. Dust concentrations to the south have been estimated using meteorological data from Parkersburg, the guidelines of U.S. Nuclear Regulatory Guideline 1.111, and the concept of an " apparent" point source. The latter point allows for the calculation of downwind concentrations from an areal source. Figure 5.1 shows the calculated results. The figure shows that air quality standards (40 CFR 50) are expected to be met at distances of greater than about one-half mile. Using this calculated dust concentration profile, the doses to the nearest res'ident were calculated. In addition, general population doses were calculated. These are presented in Table 5.2. The table shows again that 4 49

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I I 9 i the organs receiving the major doses are bones and lungs. The major dose comitment level is 27 mrem to the _ lungs. For the general public, the lung is again the organ which receives the greatest dose, 55 man-rem. In addition to the dust generated during site stabilization, there are some off-site doses resulting from the natural decay of the on-site uranium and ) thorium. Radon, an inert gas resulting from the decay of Th-232 and U-238, will migrate to the surf ace and be emitted from the waste pile. Radon emission rates were estimated using the procedures in the Final Generic Environmental Impact Statement on Uranium Milling.19 A more detailed discussion of the calculational method and results is presented in Appendix C. The result of the calculation for 2 the covered waste is that the radon-222 emission rate is 1.3x10-4 pCi/m -sec. The dose consequences of the Rn-222 release rate to both the nearest resident and the general population have been calculated are presented in Table 19 5.3. These doses are based on the currently recomended dose conversion f actor 3 of 0.625 mrem /yr per pCi/m. The table also shows the annual dose estimate which is estimated to occur if site stabilization were not to occur. In this latter 2 case the emission rate would be about 6.8x10-4 pCi/m -sec. Direct radiation exposure following stabilization should be at rates consistent with the surrounding area, i.e., about 10-15 uR/hr. A potential off-site dose is that associ ated with leaching of the covered waste. An analysis of this covered waste leach situation is presented in Appendix B. The results of this analysis show that some leaching is expected but the expected dose consequences due to radionuclides transport to the Ohio River are extremely small. A more pessimistic calculation of the doses resulting to J someone who consumed the leachate prior to mixing with the Ohio River was also l l performed. The results of this analysis are presented in Table 5.4 The table shows that for even this pessimistic case, the dose consequences are small (49 mrem to the bone). 53 9

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i Non-Radiological 1 In addition to the radiological consequences of the proposed action, i there. will be some non-radiological impacts. The impacts of concern in this assessment are those associated with air and water quality. The air qualit y impact is the result of dust during stabilization and the water quality impact is the result of siltation, also during stabilization. l Dusting - during construction has been estimated and presented in the previous. paragraphs. The results were presented in Figure 5.1 and it shows that These air quality standards are expected to be met a short distance off-site. consequences from a non-radiological standpoint are similar to that which might be expected from the f arming activities which occur in other areas of Washington Bottom. A second non-radiological impact associated with the proposed action is siltation and its impact on water quality. It is estimated that during the construction of the soil stabilization f acility a total of about 15 acres of i l ground will be bare of vegetation and/or otherwise disturbed. This disturbed l area can readily be managed and the consequences of reasonable siltation l management practices would be that no significant impact should be noticed in the context of the Washington Bottom area with its f arming activities. Another non-radiological impact as soci ated with the proposed action will be the disturbance of about 10 to 15 acres of Amax property to secure topsoil for the final earthen cap at the burial site. Removal of about 18 inches of soil will first be required to get root-free dirt. It is estimated another 18 inches will then have to be excavated to meet the requirements for covering the clay cap. This activity will result in the surf ace depression of a f airly large area or a number of smaller areas. Such areas will probably become swampy as I have other areas on the site where shallow excavations have been made. 1 I i i 56

1 5.2 CONSEQUENCES OF 0FF-NORMAL CONDITIONS Radiological Off-normal situations are also potential reasons for environmental impacts. The most. severe accident is considered to be the degradation of the clay cap which will result in leaching of the waste contents. In evaluating the accident it was assumed that the soil cover is intact but the clay cao is fractured so that rainwater can penetrate the contaminated material and leach contained radionuclides. Using the water balance method developed by 9 Thornthwaite20 and the Parkersburg meteorological data, leaching is expected to occur during the months of January through April. Details of the leach analysis - are presented in Appendix B, Section B.3. .The dose consequence of this postulated accident were calcul ated , assuming that a person received all of their water from a contaminated well near the Ohio River. The concentration and associated dose levels. for this postulated accident are shown in Table 5.5. This shows that the critical organ is the bone of the well user and that the 50-year dose comnitment is moderate, 690 mrem. Non-radiological A potential non-radiological release that could arise from a f ailure of the cap would be a leaching of non-radiological components from the buried waste. Principal contaminates which might be contained in the waste are zirconium tetrachloride (ZrC1 ), magnesium chloride (MgCl ), as well as metallic zirconium j 4 2 and magnesium. The greatest source of chloride is thought to be MgCl. Because 2 (54g/100 ml H O) it. will be leached relatively it is. quite soluble in water 2 l . quickly producing a chloride concentration in the leachate of up to about 40 0 l-g/ liter. This level would be diluted when it reached the groundwater but might be detectable. If.it were detectable, the chloride ion would be a good indicator I that some other waste material was also being leached. l L 57 (:

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I The buried pyrophoric material is expected to oxidize slowly to a stable Zr02 form over a long time period. The soil cover acts as an oxygen diffusion barrier which prevents any oxidation from occurring rapidly. 5.3 StNMARY EVALUATION The previous parts of this section have presented quantitative analysis of the impacts associated with the proposed site stabilization plan. This part is intended to sumarize this evaluation considering the guidelines identified in l Section 2.1. Table 5.6 presents a comparison of the status of the proposed action relative to the guidelines. Ths table shows that the projected performance is adequate, provided that measures are taken to assure continued design performance of the passive protection systems. The issue of uncertain l groundwater flow direction is recognized. Current groundwater flow patterns (toward or away from the river) are acceptable. Concern would be appropriate if signifi cant water pumping were to occur in the area which would change groundwater flow direction and rate. l l I 1 l 59 1

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4 ) APPENDIX A i s The purpose of including this appendix in the environmental assessment I is to identify and explain why certain environmental components are not issues in connection with the proposed action. Further, its inclusion is to provide assurance that possible impacts of the proposed action on all environmental components.have been investigated and assessed. Environmer.31 issues are classed as key, significant, and minor. Key environmental issues are those that could prevent the proposed action. Signifi cant issues are those that would not necessarily prevent the proposed action but require thorough investigation and possible p l an, program, or procedure modification in order to obviate or mitigate environmental impacts to l an acceptable level. Minor issues are those which are very short-term in nature, can be obviated or mitigated by the use of alternative but standard engineering practices, or are of such small magnitude that their environmental effects are well within the legislated limitations, i.e., they are insignificant. Those environmental components which will not be subject to any adverse impacts as a result of the proposed action are classed as "non-issues." Identification and l justifi cation for such cl assifi cation of the following listed environmental components is provided below: Climatology / Meteorology - Climatological impacts or changes result from changes l in the physics of the upper atmosphere, stratosphere and ionosphere. These kinds of changes would, in turn, alter meteorological characteristics of a local area. I Very localized, short-term, small-scale changes in meteorological phenomena have been observable at certain large metropolitan areas under specif a meteorological conditions. Such alterations have been due to city-generated heat or industrial and transportation-related pollution. These pollutants will not be generated at the Amax site as a result of implementation of the proposed action. A-1 V L

l i Geoloqy - The proposed action does not. involve any significant construction, but in a small rather will result in some minor changes to the surf ace expression area (appro ximately 11 acres). No significant excavation is pl anned so no subsurf ace strata will be disturbed or altered in any way. There is no evidence that the ) Historical and Archaeological Resources i previously developed 126 acres on the Amax property trespassed on any historical or archaeological resources. The proposed action does.no t consist of any expansion of the presently developed area. Therefore, these resources will not l be impacted. Hydroloqy - The proposed action will result in the construction of a mound l approximately 700 x 700 feet in area the highest point of which (the center) will i be about 9 feet above the existing grade. This will result in no increase in total runoff from this area and while perimeter drainage ways will be provided, they will. lead into existing natural drainage channels so there will be no net effect on the local sarf ace hydrology. Likewise, due to the small area covered j by the impermeable clay cap, there will be no significant effect to the vadose zone. Land Use - The proposed action involves stabilization of portions of previously l industrialized l and lying within the Amax property limits. There will be no areal expansion beyond the present property boundries due to the proposed actiot, f Therefore land use, for the purposes of this environmental assessment, is not an l issue. I l Natural Resources - Water - The use of natural resources in carrying out the proposed action will be insignificant. A number of thousands of gallons of water may be required for dust suppression during construction, but this is returned 1 immediately to the environment. l A-2 ______________________________j

i l' l Socioeconomic - The proposed project will be shoi t-term (four to six months) and offer employment to no more than a dozen persons. It would, therefore, have no j affect on the elements that comprise socioeconomic as an environmental component. i t The area is not a habitat for any threatened or l - Species and Ecosystems endangered species. The f act that the site has been industrialized for over 20 years renders it unattractive to all but small forms of wildlife. Soil conditions and dearth of vegetation in the area of the former Amax complex would make that particular portion of. the propertv even less habitable. f 1 I i A-3

i APPENDIX B DISCUSSION OF THE WASTE LEACHING PHENOMENA AND ASSOCIATED CONSEQUENCES The leaching of waste constituents (U, Th, Ra, etc.) from the buried contaminated soil and the subsequent transport of these contaminants to a potable water supply is a general release scenario of concern in this environmental assessment. Quantitative estimates of the release amounts and the consequences of these releases are developed and presented in this appen-dix. Section B.1 presents estimates of the water balance for the soil cover overlaying the clay cap. These estimates show the timing and amount of water available at the upper layer of the clay cover. Section B.2 presents esti-mates of the & mount of water that penetrates the clay cap under normal condi-tions and also estimates the transport of waste constituents away from the burial site. Section B.3 presents estimates of the leaching of waste constitu-ents in off-normal conditions where the clay cap may be fractured. Section B.4 presents estimates of the leaching that occurs when no waste burial action is taken. Section B.5 presents a summary of the leaching analysis presented in previous sections and draws conclusions concerning the effectiveness of the proposed action. B.1 WATER BALANCE FOR THE COVER SOIL The soil cover which is proposed to be placed over the clay covered contaminated soil acts as both a deflector for incident rainwater as well as an absorber of water which moderates the amount of water available at the top of the clay cap. A method of quantitatively estimating the availability of 2 water at the top of the clay cap is presented in an EPA document which draws heavily on previous work by Thornthwaite.2 This technique has been used, s together with data on Parkersburg, West Virginia meteorology and Wood County West Virginia soils," to develop quantitative estimates of the water available at the upper surface of the clay cap. Table B.1 presents the results of this l analysis and shows the expected amount of water at the surface of the clay cap. The table shows that water is expected at the cap only during the months of January through April. In other months the evapotranspiration potential and B-1

0 4 vo N 7 6 0 1 4 t c 3 6 0 O 1 h tn 9 1 o t M p e 9 7 0 'h S 1 ca E 2 4 p g a u 3 9 0 C A 2 ya l y 0 8 C l h u 4 0 0 e t J 2 1 h n t o M f e 1 4 o n u 2 0 0 p J 2 1 o T e 5 8 h y t a 7 8 0 ~M 1 ~ l h i c o a s 0 2 9 e R r m p 2 8 1 c o A 1 / t 0 2 d H e r 3 0 1 t a c M 6 9 6 mc ep 4 x 0 E b 2 0 1 e r F 1 7 6 e b e t o a t w n 5 3 9 'd n a i J 0 8 1 e a t R am ) f i o m t c t' s ( ) e nu n m o o c s i m C i ( A ta 'r y t e t e r i t i 1 u p i c t i k a B a c p r e e a e e r l c l p P b b m a d l a e y n e T T l i i h a y t r f l n D h o e t M d h n e T o e t M g c a i n r d e a e e t e v r o M A P N ?m

o the soil capacity are such that free water does not exist at the upper clay

{ surface. B.2-WATER PENETRATION OF THE CLAY CAP Water that reaches the top of the clay cap can either run off the . sides into the drainways or can penetrate the clay cap. Estimates of the amount of water which goes each way can be developed using the technique described by Wong which is also discussed in an EPA report.' The model 5 developed by Wong is based on analysis of a rectangular saturated volume which retains its rectangular shape while it either penetrates the clay _ liner or flows toward the drain. A graphical integration technique is used for the equation V_1.. 'h s Vo ,E d s_o, The fundamental equations required to do this graphical integration are: f=1-t/tt d cose

kt/tt~

d h E*I# ho hacose with-tt =. so/(kt sine) and y h tane k-= where V /Vo = fraction of water volume which goes to the drain system t = length of the saturated volume at time t .(cm) s so = length of the saturated volume at time = 0 (11,500 cm) h - = height of. the saturated volume at time t (cm) 4 ho = height of the saturated volume at time =' 0 (76.2cm) t = time (sec) kt = s'aturated hydraulic conductivity of cover soil (4.23x10-"cm/sec)

k2.= saturated' hydraulic conductivity of cap (1x10-7 cm/sec) d = thickness of the clay liner (30.5 cm) 0 = angle of the mound slope (13.78)

B-3

1 The h/ho vs s/s, results are plotted in Figure B.'1 so that the graphical inte-gration can be made. Two curves were drawn, one for the pessimistic ref,erence case with values listed above and one for a more optimistic case with a higher saturated conductivity for the cover soil (4.23x10-8 cm/sec). Integration of the curve shows that drain efficiency is expected to range from 78% to 97.5%. This means that an estimate of the annual leach generation rate can be made as follows: V=h where V = leach volume (t) 2 A = area of the burial zone (4.05x10' cm ) = 1.4x10' liters d = annual depth of rainwater to reach the top of the clay cap / (15.9 cm) n = fraction of water seeping through the liner (s22) This is an estimate based on the lower drain efficiency factor. If the higher drain efficiency factor (.975) is used, a water volume of 1.6x105 liters is obtained. This leaching will result in a solution containing waste components. the initial. concentration of these waste components can be estimated by assuming tnat sparingly soluble but plentiful components (e.g., _ uranium, thorium) are at their solubility limit while more soluble but less plentiful components (e.g., radium) are totally solubilized. After waste components have been solubilized and are transported by the flowing water the concentration of these materials will decrease due to three phenomena; dispersion, adsorption and decay. A simplified expression which is a useful estimator of waste component concentration after release 7 from the burial site is the following equation -D Cov e a C = 8x108(1rT) 3/2 4DD xyz resulting concentration (pCi/t) where C = Ce = initial solute concentration (pC1/t) 3 Va = leachate generation (m ) B-4

1 j 1.0 Alternative .9 .8 l ,gete6" .7- - .6 h/h. .5 j .4 .3 1 .2 .1 0 0 .1 .2 .3 .4 .5 .6 .7 .8 .9 1.0 s/s o A plot of h/ha vs. s/so for the proposed waste burial mound. i Figure B.1 I B-5

4 i 2 diffusion coefficient (m /yr) D = di. stance from leachate entry point (m) L = A.= radionuclides decay constant (yr-2) = In 2/ half life in years solutetraveltimefordistanceL(hrs)=h(1+pK/0) d T = groundwater velocity (m/yr) v = ~ 8 ' bulk density of the medium (g/cm ) = p distribution coefficient for the particular species in the Kd= particular medium (ml/g) ef'2ctive porosity of the medium 0 = A summary of the waste inventories, initial leachate concentration and leachate concentration at a point 670 meters west of the site (just prior to mixing with the Ohio River) is presented in Table B.2. Several major assumptions which were made in constructing this table are: 1. The puff dispersion model is a reasonable predictor of the concentration levels at different locations down the flow stream from the release point.. This would appear to be the case because the release time (0.25 years) is much less than the travel time to the observation point (100-300 years). 2. The concentration of parent isotopes (U-238 and Th-232 are based on measurements reported by ATCOR, Inc.' and are set at 1.8 and 2.5 Ci respectively. 3. The concentration of daughter isotopes down to actinium and protactinium are assumed to be in equilibrium with the parent -isotopes because of their limited solubility. 4. Radium and its daughters will exist at levels significantly below equilibrium levels because its moderate solubility (about 11 grams / liter) allows it to be washed away by each year's water seepage (1.6x10 liters). In fact, only one 5 year's amount of production will be assumed available during the start of the leach cycle. The consequences of these normal releases can be bounded by examining the dose consequences to anyone drinking the water prior to entering the Ohio River. Any doses resulting from water consumption after the dilution by the Ohio River would be orders of magnitude lower. The 50-year dose commitment to an individual whose annual water intake consists entirely of contaminated water would be: B-6 l f

ti 1 1 f aC x 0 x x x x 0 2 3 3 g cp 1 C( / 3 9 1 1 1 lm 0 5 = 5 s s s s s s r r r r r r d ) a a a a a a K r e e e e e e s y y y y y y y e ( d T 6 6 4 4 9 9 4 1 1 2 2 0 0 0 i c '3 1 1 2 2 3 l m = r u a n O e o y i d 3 e a 5 e m R ) 5 5 1 n c o f 0 0 0 0 0 0 / g M o r 1 1 1 1 1 1 n y x x x x x x i 8 5 4 0 4 0 6 d t. ( M rd A 1 on 4 1 8 5 2 1 ec pu u = W so d nM o p a r rl p T a 3 r 8 d r ) 1 5 3 6 8 a m i 0 0 0 0 2 2 e u nu .i 0 1 1 1 1 2 2 y i aB V. C 1 / n h p x 0 x x x x s a 1 1 m g. C( 5 4 0 r r u nc e u i n 1 7 1 2 2 i t d hI e r n m o a c r ax f ea f f d 0 L m o o o 0 m A i 7 a e e r r ee t hd t, g n t e an p / mh u s h o v l ro ci) 5 5 5 2 2 o m op att m t f o ea/ 0 0 0 0 0 a r L ri 1 1 1 1 1 n s 5 o r 2 &m eP tC x 0 x x x x e e 3 h l l np 4 6 4 3 t d t b e ae( r e n c. 9 4 6 1 1 ah u m a i Tt t nC o o e f 0 m i nm nC e. 7 u L oo I ~ i a 6 i i r r t f r = o a e h l ) ) v L t u ) ) o c l l ) l ( ( s ) i a 0 2 r C C 3 3 e s ( 2 2 t r " e 5 h h i a t y T T l e + sr 0 2 2 ao 1 A y 8 5 8 8 5 1 B Wt x 0 0 n ( 5 e. e. 1 2 1 1 n 1 i 1 1 x h e ev 1 e 6 l ( ( b n 0 2 f = I a 3 3 1 i T 2 2 l e m h h f i T T e l t C C m a u h l e = = l / e d o 2 v i l 6 8 0 2 4 8 6 8 v a c 2 2 3 3 3 3 2 2 n r u 2 2 2 2 2 2 2 2 h I t n c o a a h h U U a a a = = R R T T R R e i C C L A T da 8 2 8 5 R ?u

4 A Dj.=_Cj!wDCFi 50-year dose commitment from isotope i (rem) where Dj =. concentration of isotope 1 (uCi/t). Ci = Iw = individual's annual water intake-(800 t/yr) DCFj = 50-year dose conversion factor (rem /uCi) The lA summary of the calculated doses is presented in Table 8.3. table shows that doses are minimal with doses of tens of millirem being received by the total body and the bone. From this it can be extrapolated that the more probably doses which would result from radionuclides consumption following dilu-tion into the Ohio River would be nondetectable. 8.3 0FF-NORMAL LEACHING CONDITIONS In addition to the normal leach conditions discussed in Section B.2 it must' be recognized that a degradation of the cap could cause ' additional . leaching'to occur. Accurate prediction of the degree of cap failure is impossible to predict but some reasonable assumptions can be made and the effects evaluated. For' this particular analysis, it is assumed that the clay-cover is effective in diverting only 50% of the water at its upper surface. This means that a leach volume of 3.2x10' liters are generated annually. The-impact of this is presented in Table' B.4 which is a simplified version of Table B.2.-f This. table shows a factor of 20 increase in the concentrations of thorium and uranium. This would mean an increase in doses from uranium from-those established in Table 8.3. B.4 LEACHATE CONCENTRATION IF NO ACTION IS TAKEN It is also possible to estimate the leachate concentration resulting - from the present situation where no waste cover exists. The estimate is gene-rated by assuming that: 1. Each year's generation of radium (1.5x10-5 Ci) is washed away because of. its significant solubility. '2. The annual amount of leachate produced is 50% of the annual precipitation times'the contaminated area (10 acres) or a volume 7 2x10 liters. With these assumptions, Table B.5 has been prepared. Analysis of the table shows.that the predictive models for radium and thorium appear reasonable in B-8

t 1 c 5 1 3 3 3 a 5 0 0 0 0 r 0 8 T 1 1 1 1 1 x 0 0 x x x x 6 2 3 1 7 1 ) m I 1 9 1 1 2 er G ( s e n t a a g h r 2 5 2 2 2 c O 5 a e 0 0 0 0 0 e s n 1 1 1 1 1 L u o x 0 0 x x x x o B 5 8 6 9 1 3 g ir 1 4 1 1 4 n. ir a me V uv si o nR t o 8 Co e 7 8 3 .i s r 5 l h o e 0 1 0 0 0 0 aO D v 1 1 1 1 1 u i x 0 0 x x x x d e L 7 9 0 5 9 1 h i vt 2 1 1 9 1 i dh nt Ii W lag cn ii t x ei 2 8 3 2 hM 5 0 2 0 0 0 0 t l y oo a 1 1 1 1 1 d x 0 0 x x x x pt t o y oB 8 0 5 2 1 1 Hr T o 1 2 1 9 1 ai r oP t t es su oJ D t d n 'n ei t o o aP i) 1 5 5 m tl 1 8 8 8 ia am t r/ 0 0 0 0 0 st ti 1 1 1 1 1 Ea nC x 0 x x x x 0 2 3 3 ep 1 c( n 3 9 1 1 1 o 3 C B 'e l ba T e po t 6 8 0 2 4 8 o 2 2 3 3 3 3 l s 2 2 2 2 2 2 a i t o a a h h U U o i R R T T T da R {

1 Table B.4. Calculation Table for the Leachate Concentrations Under Off-Normal Conditions. Coutlet Waste Initial Leachate Radionuclides' Inventory (Ci) 2 Concentration (uC1/L) 2 (uCi/L) 8 Ra-226

1. 5x10- s 4.7x10-5 3.1x10-'

Ra-228 0 0 0 Th-230 1.8 4.6x10-' 1.8x10-12 Th-232 2.5 6.4x10-' 2.4x10-11 U-234 1.8 1.3x10-2 2.6x10-" U-238 1.8 1.3x10 2 2.6x10-" 2 Initial inventories same as in Table 8.1. Initial concentration of radium decreased by dilution effect; Th, U are 2 unchanged because they are based on solubility limits. The same factors used for A and for T in Table 8.1 are used here. 8 I E 1 B-10 i

I Table B.S. Predicted and Measured Leachate Concentrations Beneath the Amax Inc. Site i Radionuclides Predicted (pCi/t) Measured (pCi/t) Ra-226 0.75 0.04 .Th-230 0.0046 0.006 - 0.016 Th-232 0.0064 0.001 - 0.013 U (234 and 238) 26,000 0.5 - 2.0 i ) B-11

that they compare with predicted numbers within an order of magnitude. The uranium leachate is overpredicted by a significant amount. Two possible reasons for this overprediction are 1) selective adsorption of leached uranium before or after it reaches the water table, or 2) a very slow reaction rate (kinetics) for the dissolution of uranium at lower temperatures (s25'C). This second phenomena has been reported by Ogard et al.' B.5

SUMMARY

This appendix has presented a quantitative analysis of the hydrologic performance c' the proposed contaminated burial site. The analysis has shown that the concentration of radioisotopes in the leachate is minimal and that the doses resulting to a hypothetical person who might consume the leachate before it is mixed with the Ohio River are minimal (49 mrem /50 years to the bone). The' more credible doses which would result to someone using or consuming Ohio River water would be many orders of magnitude lower because of natural dilution with the Ohio River waters. Under off-normal or no action conditions the amount of uranium and thorium' leached would be increased with a resulting increase in downgradient uranium and thorium concentrations. The result is doses which increase by about an order of magnitude. Based on the ability to predict existing groundwater concentrations, the quantitative predictions are considered to be accurate within an order of magnitude for radium 226 which is one of the major dose contributing isotopes and pessimistic for uranium 234 and 238 which are the other major dose contribut-ing isotopes. B-12

. Q REFERENCES FOR APPENDIX B 1. D. G. Fenn, et al, Use of the Water Balance Method for Predicting Leachate Generation from Solid Waste Disposal Sites, U.S. Environmental Protection Agency, EPA /530/SW-168, October 1975. 2. C. W. Thornthwaite and J. R. Mather, The Water Balance, Publications in Climatology, Vol. III, No.1, Drexel Institute of Technology, Centerton, New Jersey, 1955. 3. U.S. Department of Agriculture Soil Conservation Service in cocreration with the West Virginia Agricultural Experimental Station, Soil Survey, Wood and Wirt Counties West Virginia, 1970. 4. National Oceanic and Atmospheric Administration, Department of Commerce, Local Climatological Data, Annual Summary With Comparative Data, Parkers-burg, West Virginia, 1978, 1979, 1980. 5. J. Wong "The Design of a System for Collecting Leachate From a Lined Landfill Site" Water Resources Research, Vol. 13, No. 2. pp. 404-410. 6. C. A. Moore, Landfill and Surface Impoundment Performance Evaluation Manual U.S. Environmental Protection Agency, SW-869, September 1980. 7. R. A. Freeze, et al., Groundwater, Prentice-Hall, Englewood Cliffs, New Jersey, 1979. 8. ADCOR, Inc., Radiological Assessment Report for Amax Inc., Property Located at Parkersburg, West Virginia, Vol.1, 2, December 1,1978. 9. Allen Ogard, et al, "Are Solubility Limits of Importance to Leaching?" Scientific Basis for Nuclear _ Waste Management, Vol. 3. Plenum Press, New York, 1981. l l l B-13 1

.n p' I APPENDIX C CALCULATION OF RADON FLUX FROM THE PROPOSED BURIED MOUND This appendix summarizas the method used for estimating the radon emission rate from the proposed burial mound and presents the calculations which establish the estimate. Radon exhalation from radioactive waste can be attenuated by pro-viding covers over tM burial site. The degree of radon emission attenuation depends upon the cover material's ability to restrict the diffusion of radon, and the cover thickness. The method used in this assessment for estimating the radon attenuation through a cover is based on Appendix P of " Final Generic Environmental Impact Statement on Uranium Milling" report (NUREG-0706). -The proposed burial site will consist of radioactive soils covered by a composite soil cover. The materials and thickness of the cover are illustrated in Figure 3.14. As shown in this figure, the cover is comprised of a 6-inch layer of clayey soil, a 12-inch layer of impermeable clay and a 30-inch layer of vegetated top soil. The calculation for the rate of radon diffusion through a composite soil cover can be obtained using the following equation: n n Jn"do (m=1 f ) exp (-I b,x,) (1) N m m=1 where: th radon flux at the surface of the n layer of the c.over ( ) J = n radon flux at the surface of the radioactive soil layer J = g pCi (m2sec y ( )* b, = decay constant of radon isotopes (sec-1) A = D, effective bulk diffusion coefficient of the mth layer ( ) = C-1

e i P, porosity of the soil material of the mth layer ~ = the thickness of the mth layer (cm) = x, The function f,is given by the following expression: 2 (2) f = P,,1 ' D,, y / P,, y' P,7 'D,,y/Pm-1 mm P D,/P, g _ ,P, D,/ P, ), (g # The term for the radon flux at the surface of the radioactive soil is given as follows: ' AD ' b (10" cm /m ) (3) 0 2 2 J, = [Ra]pE p .o' where [Ra] = concentration of radium in the contaminated soil (Pgm ) density of the contaminated soil (g/cc) = o emanating power E = The sources of radon generation considered in this study are Th-232 for Rn-220 and U-238 for Rn-222. The decay chain of Th-232 generates Ra-228 which then decays to Rn-220. Because of the long half-life of Th-232, the annual amount of leachate generated and the high solubility of Ra-228, the amount of Ra-228 estimated to be accumulated in the mound is negligible. Thus generation of Rn-220 will not be significant. On the other hand, the decay i chain of U-238 produces during one year measurable amounts of Ra-226 which in - turn decay to Rn-222. The estimated quantity of Ra-226 generated in the burial mound each year is calculated at 1.5x10-5 Ci (see Appendix B). This quantity of Ra-226 concentration is associated with about 10,000 cubic yards of soil and so the average concentration is 1.4x10-8 pCi. gm C-2

s The average density of the contaminated soil is assumed to be ~ similar to.the average = density of the natural soil at the. site which is about 1.3 g/cc. The emanating power represents the percentage of the quantity of radon' gas available for release from the contaminated soil in which -it is' generated. The emanating power can then be assumed at 20% as was done in !~ NUREG-0706. Values of the effective bulk diffusion coefficient (D) may be measured experimentally for any given material at ambient moisture level and expected degree of compaction. In cases where values of D are not readily ) available, they can be obtained through the use of an empirical equation obtained from experimental data: f=0.106exp(-0.261M)- (4) where M is the weight-percentage of soil moisture, D is the effective bulk l- - diffusion coefficient and P is the porosity of the soil. l The moisture ' percentages of the different layers of s mound cover are not readily available, thus approximate values are estimated for these i layers as follows: o' For the excavated radioactive soil or layer (0), the soil moisture percentage is estimated at 6 to 8% which is typical for non-clay soils. L o For layer (1), the soil can be termed as clayey material, thus the moisture percentage is assumed to be from 8% to j 10%. o The layer (2) consists of highly impermeable clay, thus its moisture percentage is assumed to be from 9% to 15%. o-The moisture percentage of the top soil layer or layer (3) is again assumed to be from 6 to 8% as in layer (0). From the estimated moisture percentages, equation (4) can thus be used' to calculate the ratio of the bulk effective diffusion coefficient and the porosity of the soil for each individual layer. (D,/P,). Layer (0): Maverage " 7% k = 0.106 exp (-0.261 x 7) = 0.017 cm /sec 2 C-3

'h i Layer-(1): Maverage " 9% k.=0.106exp(-0.261x9)=0.010cm/sec 2 Layer (2): Maverage = 12% k=0.106exp(-0.261x12)=0.005cm/sec 2 Layer (3): Maverage " 7% k=0.017cm/sec 2 The porosity of each soil layer is calculated from the following equation: k en x 100) Porosity (P) = 100% - (par e] de s ty The'following' data on bulk density and particle density for each layer are estimated from literature information. . article Density p Bulk Density Clay 1.65 g/cc 2.65 g/cc Clayey soil 1.60 g/cc 2.65 g/cc l top soil' 1.30 g/cc 2.65 g/cc Thus the calculated porosity value's of layer (0), (1), (2), and (3) are 51%, 40%, 38%, and 51% respectively. Table C.1sumarizes the pertinent properties of each layer. C-4

l l,- L,.. Table C.I. Estimated Properties of the Material I of the Cover Layers 2 Layer . Type of Soil D,/P,(cm /sec) P,.(%) '(0 ). Silty loam, clayey loam 0.017 51 (1) Clayey soil 0.010 40 (2)- Clay- '0.005 38 - (3 ). Silty loam, clayey loam 0.017 51 The thickness of layers (1), (2) and (3) are respectively 15 cm, 30 cm, and 75 cm. Estimate for Rn-222 Generation l i As discussed previously, the source of Rn-222 generation is Ra-226 which is a decay product of U-238. The concentration of Ra in' the contaminated soil available for Rn-222 generation is estimated at 1.4x10-8pCi/g. The radon flux at the surface of the radioactive soil can then be calculated using equation (3). With 2.1x10-' sec-1 (Rn-222 decay constant) A = k=0.017cm/sec 2 I 0.2 E = 1.3 g/cc j p = 1 4 1 then Jo is given as follows: Jo = (1.4x10-8)(1.3)(0.2)(2.1x10-5 x 0.017)'8(10") 2 6.88x10-" pCi/m 3,e = To calculate the radon flux at the surface of the top soil layer (Ja-), equation I (1).can be rewritten as follows: m=3' m=3 l. Ja = Jo([f,)exp(-gb,x,) C-5

4 ~ c ja or f fs) exp (-{b xt+b2x2+b x3]) (5) J 'Jo (fi 2 2 3 = b,x,=.(APm)b-x, b x3 = (A ) xi: = ( {~) (15) = 2.175x10-2 3 0 = (2.1 ) (30)=.6.15x10-2 (h)b b2x2 = x2 b = (2.1 ) (75) = 8.325x10-2 ='(y,1)h b x3 x 3 and f,is presented as in equation (2); thus: 0.895 = f = (1+k b)+'(1.-k b)e-Zbxi t 2 2 lwhere Po = 0.51: P3 = 0.40; Do/Po = 0.017 cm /sec; D /P = 0.01 cm /sec and 2 bixt = 2.175x10-2 0.853 = -f = . (1. + k h)+(1-k h) e-Zb x2 2 2 = O.005 cm /sec, P '= 0.38, b x2 = 6.15x10-2 2 where-02/P 2 2 1.319 = (1+k h) + (1 - k %) e-2b3x3 0.51; bsx = 8.325x10-2 ~ 2 where 0 /P = 0.017 cm /sec; P = 3 -thus: Ja = Jo-(f f fs)'exp (-(b xt + b2x2 + bax3]) i2 3 6.88x10-", c (0.895)(0.853)( 1.319 )e@.M + W + 0.4 = ' 'I.31x10-" pCi/m sec-2 = C-6 . _ = -

l i t A, REFERENCES i 1. U.S. Department of Agriculture Soil Conservation Service in cooperation with the West Virginia Agricultural Experimental Station, Soil Survey, Wood and Wirt Counties West Virginia, 1970. 2. U.S. Department of Commerce, Bureau of the Census, 1980 Census of Popu-lation and Housing, West Virginia and Ohio. '3. Parkersburg, West Virginia-Chamber of Commerce, Ferrous Metal Opera-tions; Utilities and Services; Local History and Geography; Transporta-tion; Glass Plants; Chemical Plants; and Industries and ProdFcers,1980, i 4. Roy E. Williams and Associates, Hydrology of the Amax Property in Wood County, West Virginia, Viola, Idaho, August 1980. 5. Aureal. T. Cross and Mart P. Schemel, " Geology of the Ohio River Valley in West Virginia." Charles D. Carlson and George D. Graeff, Jr., " Groundwater Resources of the Ohio River Valley in West Virginia." Parts I and III of Geology and Economic Resources of the Ohio River Valley in West Virginia, Volume XXII, West Virginia Geological Survey, 1956. 6. Russell M. Jeffords, in cooperation with the U. S. Geological Survey, I West Virginia Geological Survey, Bulletin No. 10, Ground-Water Condi-tions Along the Ohio Valley at Parkersburg, West Virginia, 1945. 7. Adcor, Inc., Radiological Assessment Report For Amax. Inc., Pro 3erty Located at Parkersburg, West Virginia, Vol.1, 2, December 1,1973. 8. Woodward Clyde Consultants, Wood County Project Near Parkersburg, West Virginia, August 5, 1980. 9. Natiunal Oceanic and Atmospheric Administration, Department of Commerce, Local Climatological Data, Annual Summary With Comparative Data, Parkers-burg, West Virginia, 1978, 1979, 1980. 10. U.S. Department of Commerce, National Oceanic and Atmospheric Adminis-tration, Environmental Data Service, National Climatic Center, Wind Distribution by Pasquill Stability Classes, Parkersburg, West Virginia. 11. Peter Lessing, Earthquake History of West Virginia, West Virginia Geo-logical and Economic Survey, 1974. 12. B. G. Reagor, C. W. Stover, and S. T. Algermissen, Miscellaneous Field Studies, Seismicity, West Virginia, U.S. Geological Survey, Department of the Interior,1980. l 13. Personal Communication R. Roland with Charles Spann, West Virginia Air Pollution Control Commission.

~ N i f '14. Letter Deborah M. Wilson, Ohio River Valley Water Sanitation Consnission ~ to Ray Roland, June 5, 1981. 15. Letter' Nancy Mandeltort, Chem-Nuclear Systems, Inc., to Jim Kerrigan Amax Environmental Services, May 14, 1981. 16. Chem-Nuclear Systems, Inc. Radiological Assessment and Stabilization Scenarios, Parkersburg, West Virginia Site, Feburary 1980. R. B. Smith "Pyrophoricity - A Technical Mystery Under Vigorous Attack"

17..

Nucleonics, December 1956, p. 28-33. 18. U.S. Environmental Protection Agency, Compilation of Air Pollutant .- Emission Factors, Third Edition, August 1977. 19. U.S. Nuclear Regulatory Commission, Final Generic Environmental Impact Statement on Uranium Milling, NUREG-0706, 1980. 20. C. W. Thornthwaite and J. R. Mather, The Water Balance, Publications in Climatology, Vol. III, No.1, Drexel Institute of Technology, Centerton, New Jersey, 1955. 21. L. L. Ames et al., Radionuclides Interactions with Soil and Rock Media, Battelle Pacific Northwest Labs EPA /520/6-78/007-A, August 1978. 22. D. -Isherwood Geoscience Data Base Handbook for Modeling a Nuclear Waste Repository, NUREG-CR-0912 Lawrence Livermore Laboratory, Livermore,Ca. January 1981.

N$ Ty o% e CEI UNITED STATES ,cg ,'o NUCLEAR REGULATORY COMMisslON g y ,g WASHINGTON, D. C. 20555 sy D t! y

- - - - l b

MAY 5'1982 Do ~m y r?$ G:- g', AMAX D;;ironme'ntal Services, Inc. t ATTN: Mr. James E. Kerrigan Senior Environmental Engineer Denver West Office Park 1707 Cole Boulevard Golden, Colorado 80401 -.I Gentlemen: Enclosed for your information are five copies of our environmental impact appraisal of the proposed site stabilization at AMAX Inc.'s Parkersburg, West Virginia site. We have also enclosed for your information five copies of the notice which will be published in the Federal Register. Sincerely, sca 1 % W. A. Nixon Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS

Enclosures:

1. Environmental Impact Appraisal 2. Notices ~ l L' 4b O OFFICIATIN -- m

~ 7590-01 l* UNITED STATES NUCLEAR REGULATORY COMMISSION DOCKET NC. 40-8355 AMAX INC. NEGATIVE DECLARATION REGARDING STORAGE OF CONTAMINATED SOIL UNDER LICENSE The U.S. Nuclear Regulatory Commission (the Commission) is considering licensing AMAX Inc., to stabilize and store soil contaminated with source material at a site in Wood County, West Virginia. The low-level contamination resulted from past zirconium ore processing operations at the site. AMAX Inc. ~ has proposed to collect and move all soi'l contaminated above acceptable limits to a central area on the' site and to stabilize the wastes under a clay cap designed to reduce water inf.iltration, prohibit' dispersal of solid radioactive particulate into air and to limit an; radon or thoron emissions. The stabilized material would remain in storage under a license issued by the Commission to AMAX Inc. The Commission's Division of Fuel Cycle and Material Safety has prepared an environmental impact appraisal for the proposed contaminated soil stabili-zation and storage actions. On the basis of this appraisal, the Commission has concluded that the environmental impact created by the proposed actions would not be significant and does not warrant the preparation of an environ-mental impact statement, and, accordingly, it has been determined that a negative declaration is appropriate. The environmental impact apppraisal is available for public inspection at the Comission's Public Document Room

r J at 1717 H Street, N.W., Washington, D.C. A copy may be obtained upon request addressed to the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, . ATTENTION: Director, Division of Fuel Cycle and Material Safety. Dated at Silver Spring, Maryland, this 3rd day of May,1982. R. G. Pag ief Uranium Fuel 1,1 censing Branch Division of Fuel Cycle and Material Safety, NMSS e b o e

o. s3

s l:

ENVIRONMENTAL IMPACT APPRAISAL ) 3 AMAX INC. PARKERSBURG, WEST VIRGINIA SITE DOCKET NO. 40-8355 n PROPOSED SITE STABILIZATION 1 I J PREPARED BY . DIVISION OF FUEL CYCLE AND MATERIAL SAFETY 'U. S. NUCLEAR REGULATORY C0fMISSION l APRIL 1982 i i-p

t t e. e i e r r ( ' I. i i l l ( n t I I APPENDIX D I I 1 i I 1 i f i 1 i ] 1 i ___.._____.___;}}

ML20236S357

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